UNPROTECTED/NON PROTÉGÉ ORIGINAL/ORIGINAL CMD: 17-H9 Date signed/Signé le : MARCH 27, 2017 A Licence Renewal Un renouvellement de permis AREVA Resources Canada Inc. (AREVA) McClean Lake Operation AREVA Resources Canada Inc. (AREVA) Établissement de McClean Lake Commission Public Hearing Audience publique de la Commission Scheduled for: June 7 and 8, 2017 Prévue pour : 7 et 8 juin 2017 Submitted by: CNSC Staff Soumise par : Le personnel de la CCSN e-Doc 5131260 (WORD) e-Doc 5131410 (PDF)
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UNPROTECTED/NON PROTÉGÉ
ORIGINAL/ORIGINAL CMD: 17-H9
Date signed/Signé le : MARCH 27, 2017
A Licence Renewal
Un renouvellement de permis
AREVA Resources Canada Inc. (AREVA)
McClean Lake Operation
AREVA Resources Canada Inc. (AREVA)
Établissement de McClean Lake
Commission Public Hearing
Audience publique de la Commission
Scheduled for: June 7 and 8, 2017
Prévue pour : 7 et 8 juin 2017
Submitted by: CNSC Staff
Soumise par : Le personnel de la CCSN
e-Doc 5131260 (WORD) e-Doc 5131410 (PDF)
17-H9 UNPROTECTED/NON PROTÉGÉ
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Summary This Commission Member Document (CMD) presents information about the following matters of regulatory interest with respect to the AREVA Resources Canada Inc. (AREVA) McClean Lake Operation (MLO):
Canadian Nuclear Safety Commission (CNSC) staff review and assessment of AREVA’s application to renew uranium mine operating licence UMOL-MINEMILL-McCLEAN.01/2017
Compliance performance on all safety and control areas during the current licence term and an environmental assessment under the Nuclear Safety and Control Act
Résumé Le présent document de la Commission (CMD) présente des renseignements sur les questions d'intérêt réglementaire suivantes concernant l'exploitation d'AREVA Resources Canada Inc. (AREVA) à McClean Lake : Examen et évaluation par le personnel
de la Commission canadienne de sûreté nucléaire (CCSN) de l'application d'AREVA’s pour renouveler la licence d'exploitation des mines d'uranium UMOL-MIN MILL-McCLEAN.01 / 2017
Les résultats de la conformité sur toutes les aires de sûreté et de contrôle pendant la période de licence actuelle et une évaluation environnementale en vertu de la Loi sur la sûreté et la réglementation
CNSC staff recommend the Commission:
Renew the Uranium Mine Operating Licence to authorize AREVA to operate the McClean Lake Operation until June 30, 2029
Accept AREVA’s McClean Lake revised financial guarantee for decommissioning in the amount of C$107,241,000
Authorize the delegation of authority as set out in this CMD
Le personnel de la CCSN recommande que la Commission :
Renouveler le permis d'exploitation proposé UMOL-MINEMILL-McCLEAN.00 / 2029 pour une période de 12 ans
Accepter la Garantie financière révisée pour le démantèlement au montant de 107 241 000 de $CA
Autoriser la délégation des pouvoirs telle qu’établie au présent CMD
The following items are attached:
Environmental Assessment Report
Proposed licence UMOL-MINEMILL-McCLEAN.00/2029
Draft Licence Conditions Handbook
Current licence UMOL-MINEMILL-McCLEAN.01/2017
Les éléments suivants sont joints :
Rapport d’évaluation environnementale
Permis proposé UMOL-MINEMILL-McCLEAN.00/2029
Ébauche du Manuel des conditions de permis
Permis actuel UMOL-MINEMILL-McCLEAN.01/2017
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2. MATTERS FOR CONSIDERATION ........................................................ 15 2.1 Environmental Assessment ........................................................... 15 2.2 Relevant Safety and Control Areas ............................................... 15 2.3 Other Matters of Regulatory Interest ............................................. 16 2.4 Regulatory and Technical Basis .................................................... 16
3. GENERAL ASSESSMENT OF SCAS ..................................................... 16 3.1 Management System ..................................................................... 17 3.2 Human Performance Management................................................ 20 3.3 Operating Performance ................................................................. 22 3.4 Safety Analysis .............................................................................. 30 3.5 Physical Design ............................................................................. 33 3.6 Fitness for Service ......................................................................... 39 3.7 Radiation Protection ...................................................................... 41 3.8 Conventional Health and Safety .................................................... 48 3.9 Environmental Protection .............................................................. 53 3.10 Emergency Management and Fire Protection ............................... 69 3.11 Waste Management ...................................................................... 73 3.12 Security ......................................................................................... 78 3.13 Safeguards and Non-Proliferation ................................................. 81 3.14 Packaging and Transport .............................................................. 83
4. OTHER MATTERS OF REGULATORY INTEREST ................................ 88 4.1 Aboriginal Consultation .................................................................. 88 4.2 Other Consultation......................................................................... 89 4.3 Cost Recovery ............................................................................... 90 4.4 Financial Guarantees .................................................................... 91 4.5 Improvement Plans and Significant Future Activities ..................... 92 4.6 Public Information and Disclosure ................................................. 95 4.7 Proposed Licence Period .............................................................. 96 4.8 Licence Conditions Handbook ....................................................... 98 4.9 Delegation ..................................................................................... 98
5. OVERALL CONCLUSIONS AND RECOMMENDATIONS ...................... 99
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A. RISK RANKING ........................................................................................... 108
B. RATING LEVELS ......................................................................................... 109
C. BASIS FOR THE RECOMMENDATIONS ................................................... 110 C.1 Regulatory Basis ............................................................................. 110 C.2 Technical Basis ............................................................................... 125
D. SAFETY AND CONTROL AREA FRAMEWORK ........................................ 126 D.1 Safety and Control Areas Defined ................................................... 126 D.2 Specific Areas for this Facility Type ................................................. 128
E. ENVIRONMENTAL ASSESSMENT REPORT ............................................. 130
PART TWO ....................................................................................................... 131
AREVA Resources Canada Inc. (AREVA) is the operator of the McClean Lake Operation (MLO) located in the Athabasca Basin area of northern Saskatchewan. In 1996, an operating licence was first issued to AREVA’s MLO by the Atomic Energy Control Board, predecessor of the Canadian Nuclear Safety Commission (CNSC). The current operating licence was renewed on July 1, 2009 for an eight-year term until June 30, 2017. This licence authorized AREVA to operate a nuclear facility for the mining of uranium ore, production of uranium concentrate and disposal of tailings at the JEB1 tailings management facility (TMF). The licence was amended following a public hearing held on October 24, 2012 [1] to allow AREVA to modify the mill, process high grade ore and increase production.
During the licensing period, CNSC staff carried out 45 compliance inspections of various aspects of the mill and surface facilities. The MLO addressed all non-compliances and recommendations arising from these compliance inspections in a satisfactory and timely manner. CNSC staff’s compliance activities verified that the MLO operated safely and AREVA made adequate provision for the health and safety of the workers, the protection of the public and the environment, and Canada’s international obligations.
In July 2010, the MLO underwent a safe and systematic temporary shutdown of production operations due to depletion of ore. CNSC staff’s compliance activities were adjusted to focus on the key areas of environmental protection, maintenance activities, and conventional health and safety. Throughout the production shutdown period (2010-2014), AREVA maintained all necessary safety and environmental provisions, including water treatment and effluent discharge control measures.
In March 2014, ore slurry shipments from Cameco Corporation’s Cigar Lake mine commenced and the mill restarted in September 2014. CNSC staff closely monitored AREVA’s commissioning activities and return to operations at the MLO. CNSC staff’s compliance activities and the review of AREVA’s Report on Commissioning & Restart of the McClean Lake Mill concluded that AREVA demonstrated its capability to meet production targets as designed in each circuit, while meeting objectives and licensing requirements for the protection of the environment and safety of workers.
During restart and commissioning of the MLO, an increasing trend of selenium effluent concentration and sulphur dioxide emissions were identified. As requested by the CNSC, AREVA submitted a selenium management plan to control selenium releases in effluent, as well as a sulphur dioxide management plan to eliminate in-circuit exposures to sulphur dioxide gas and minimize the release of sulphur dioxide from the calciner stack. CNSC staff have verified AREVA’s proactive approach in implementing a selenium management strategy and employing process improvements to control sulphur dioxide emissions. CNSC staff have reviewed these plans and concluded that AREVA took adequate measures to manage and control these risks to an acceptable level. CNSC staff have accepted AREVA’s selenium and sulphur dioxide plans and will continue to monitor the progress of the control measures.
1 JEB represents the initials for John Everett Bates, who discovered the uranium deposit.
In February 2016, AREVA submitted a request to increase the annual authorized production rate from 13 to 24 million pounds of uranium concentrate per year [2]. CNSC staff reviewed the proposed change and determined that the production increase was within the licensing basis2, and the health and safety of workers and the environment remain safe. CNSC staff accepted the requested production increase in May 2016.
In August 2016, AREVA submitted an application for the renewal of its operating licence for a period of 12 years [3]. AREVA has requested authorization for the continued operation and modification of a nuclear facility; the mining of uranium and the production of uranium concentrate; and the possession, storage, transfer, importation, use and disposal of nuclear substances and radiation devices.
An environmental assessment under the Nuclear Safety and Control Act (NSCA) was conducted by CNSC staff for AREVA’s MLO licence renewal. CNSC staff concluded that AREVA has made and will continue to make adequate provision for the protection of the environment and the health and safety of persons.
In this Commission member document (CMD), CNSC staff present its review and assessment of AREVA’s application for a licence renewal and AREVA’s compliance performance during the current licence term, and also provide conclusions and recommendations to support the Commission’s consideration and decision pursuant to section 24 of the NSCA regarding AREVA’s licence renewal application.
Table 1 presents AREVA’s performance operating the MLO by safety and control areas (SCA) for the current licence period (2009-2016).
2 The licensing basis for a regulated facility or activity is to achieve the level of protection of the health, safety, and security of the public and workers, and the protection of the environment that were identified in environmental and human health risk assessments that were carried out in support of the licence application (LCH, Licence Condition G.1).
Table 1: McClean Lake - performance ratings from 2009 to 2016
Safety and control areas Ratings
2009 2010 2011 2012 2013 2014 2015 2016
Management system SA SA SA SA SA SA SA SA Human performance management SA SA SA SA SA SA SA SA
Operating performance SA SA SA SA SA SA SA SA
Safety analysis SA SA SA SA SA SA SA SA
Physical design SA SA SA SA SA SA SA SA
Fitness for service SA SA SA SA SA SA SA SA
Radiation protection SA SA SA SA SA SA SA SA
Conventional health and safety SA SA SA SA SA SA SA SA
Environmental protection SA SA SA SA SA SA SA SA Emergency management and fire protection SA SA SA SA SA SA SA SA
Waste management SA SA SA SA SA SA SA SA
Security SA SA SA SA SA SA SA SA Safeguards and non-proliferation SA SA SA SA SA SA SA SA
Packaging and transport SA SA SA SA SA SA SA SA SA = Satisfactory.
Based on CNSC staff’s technical assessments of AREVA’s licence renewal application and supporting documents, and CNSC staff’s monitoring and evaluation of AREVA’s compliance performance operating the MLO during the current licensing period, CNSC staff conclude the following with respect to paragraphs 24(4)(a) and (b) of the NSCA, in that AREVA:
is qualified to carry on the activities authorized by the licence
will, in carrying out that activity, make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed
In October 2016, AREVA submitted a revised preliminary decommissioning plan (PDP) and cost estimate following a five-year cycle requirement [4]. AREVA revised its PDP to include the authorized changes to operations as well as increases in labour and material rates. CNSC staff have assessed the proposed revisions and concluded the revised PDP including cost estimates and financial guarantee (FG) meets the criteria of the CNSC regulatory guides G-219, Decommissioning Planning for Licensed Activities, G-206, Financial Guarantees for the Decommissioning of Licensed Activities, and CSA Group standard N294-09, Decommissioning of Facilities Containing Nuclear Substances. CNSC staff recommend that the Commission accepts AREVA’s proposed FG in the amount of C$107,241,000 for the MLO. The Saskatchewan Ministry of Environment, the actual beneficiary of the FG and responsible for any associated work, has accepted this proposed amount. This is discussed in greater detail in subsection 3.11.2 (decommissioning plans), and section 4.4 (financial guarantees).
AREVA has submitted an application with a request to renew its McClean Lake operating licence for a period of 12 years. CNSC staff note that current practice is to issue 10-year term licences to similar facilities. In support of the licence renewal AREVA has submitted, in 2016, both an Environmental Performance Technical Information Document (TID), Volume 1 of 2 – Environmental Monitoring and Environmental Performance Technical Information Document, Volume 2 of 2 – Environmental Risk Assessment. CNSC staff reviewed the TIDs and concluded that the predicted impacts for the current anticipated MLO milling and decommissioning plans are consistent with those predicted in previously approved environmental assessments and environmental risk assessments (ERA).
The TIDs are an important consideration for future licence renewals. The TIDs review, evaluation and final acceptance by CNSC require a minimum of one year. Therefore, the requested 12 year licence term will allow AREVA and CNSC staff to coordinate future licence renewal activities considering submissions; review and acceptance of future TIDs including updated ERAs which are required on a five year review cycle.
Earlier this year, CNSC staff conducted an outreach session with Athabasca First Nation communities. Overall, community members and leadership indicated that they are supportive of AREVA’s licence renewal including the proposed licence term. CNSC staff also noted that the communities are pleased with the work being done as part of the implementation of the recently signed Collaboration Agreement between Cameco, AREVA, and Athabasca Basin Communities including: Black Lake, Hatchet Lake, and Fond du Lac First Nations and the northern settlements of Stony Rapids, Wollaston Lake, Uranium City and Camsell Portage. AREVA has also conducted engagement activities and presented its proposed 12 year licensing term to local communities and Aboriginal groups.
AREVA’s MLO is a mature facility with established programs and a management system focused on continuous improvement. AREVA’s request for a 12 year licence term does not impose any additional risks to the public or the environment. Taking into consideration AREVA’s regulatory compliance performance over the current licence period, CNSC staff, while acknowledging the recent practice for 10 year licences, recommend that the Commission accept staff’s assessment and conclusions and issue the proposed licence UMOL-MINEMILL-McCLEAN.00/2029 for a 12 year term. CNSC staff will continue to report on AREVA’s regulatory compliance performance through annual regulatory oversight reports presented to the Commission at public proceedings.
CNSC staff will verify through its regulatory oversight activities that AREVA continues to operate the MLO safely and continues to maintain its commitments to transparency of operations, public outreach and engagement.
This CMD also provides information pertaining directly to the current licence UMOL-MINEMILL-McCLEAN.01/2017, the proposed licence UMOL-MINEMILL-McCLEAN.00/2029 and the draft licence conditions handbook (LCH) to accompany the proposed licence.
1.1 Background AREVA Resources Canada Inc. (AREVA) is the operator of the McClean Lake Operation (MLO). Ownership of the MLO comprises of AREVA (70%), Denison Mines Inc. (22.5%), and Overseas Uranium Resources Development Canada Co., Ltd. (7.5%). In 1996, Atomic Energy Control Board, predecessor of the Canadian Nuclear Safety Commission (CNSC), issued an operating licence to AREVA’s MLO. The current licence UMOL-MINEMILL-McCLEAN.01/2017 was renewed by the CNSC on July 1, 2009 for an eight-year term with an expiry date of June 30, 2017. The licence authorizes AREVA to operate a nuclear facility consisting of a mine, mill and waste management systems, produce uranium concentrate, possess nuclear substances and radiation devices and manage the care and maintenance of the Midwest Project site. AREVA is the majority owner and operator of the Midwest Project, a known uranium deposit. The site continues to be maintained in a care and maintenance state. In 2009, the Midwest Project care and maintenance licence was revoked and consolidated into the current McClean Lake licence.
Construction of the MLO began in 1994. Mining and milling of uranium ore from five open-pit mines has been completed and conventional mining has not been carried out at the MLO since 2008. Mill tailings have been deposited in the JEB tailings management facility (TMF), which was engineered from the mined out JEB open pit. The MLO was designed and constructed with radiation protection features (e.g. lead shielding, concrete enclosures and lined leach tanks) for processing of undiluted high grade ore averaging from 20 percent uranium to as high as 30 percent uranium.
In December 2016, CNSC staff reported on AREVA’s performance, from 2010 to 2015, through CNSC staff’s annual regulatory oversight report presented to the Commission.
1.1.1 McClean Lake location and layout The MLO is a uranium mine and mill facility located approximately 750 kilometres north of Saskatoon in the Athabasca Basin area of northern Saskatchewan. The MLO includes the JEB milling area, Sue mining area, TMF and the undeveloped McClean, Midwest and Caribou ore deposits. Access to the site is by an all-weather road that connects with the provincial highway system (Highway 905) with an access road to the combined Sue and JEB sites and a dedicated access road to the Midwest Project site. Workers commute to and from the site by aircraft landing at Points North, a private airstrip, and continue by bus to the MLO. The nearest permanent communities are Wollaston Post and the Wollaston Lake Indian Reserve (Hatchet Lake Indian Band), located approximately 50 kilometres by air from the mine to the southeast on the far shore of Wollaston Lake.
An aerial view of the JEB site (milling area) and the Sue site is shown in figure 2.
Figure 2: McClean Lake – aerial view of the JEB and Sue sites
1.1.2 Amendments during current licence period Following a public hearing held on October 24, 2012, the Commission approved AREVA’s amended licence UMOL-MINEMILL-McCLEAN.01/2017 to allow operation of the high grade ore slurry receiving circuit and high grade milling circuits; increase maximum annual production of uranium concentrate (U3O8) from 8 to 13 million pounds per year; and the receipt and processing of ore slurry from Cameco Corporation’s McArthur River mine [1]. The request to process McArthur River ore at the MLO underwent a screening level environmental assessment (EA), which was completed in April 2012 [5]. However, AREVA did not proceed to process McArthur River ore at the MLO.
1.2 McClean Lake Operation The McClean Lake mill uses sulphuric acid and hydrogen peroxide leaching and a solvent extraction recovery process to extract and recover uranium product from ore slurry received from Cigar Lake mine.
The main components of the mill processing circuits are slurry receiving, grinding, leaching, counter current decantation (CCD), clarification, solvent extraction (SX), yellowcake preparation, tailings preparation, calcining and packaging. Figure 3 shows a simplified process flow diagram of the mill.
Figure 3: McClean Lake – mill process block diagram
The MLO ore processing methods are described as follows:
Grinding – Ore material (run-of-mine-ore) is taken from the JEB ore pad and fed into the grinding circuit. The slurry product from the grinding circuit reports to the storage pachucas and then pumped into leaching circuit as required.
Slurry transportation – slurry receiving - High grade ore slurry from the Cigar Lake mine is transported to the MLO in the Type IP-23 rated containers and unloaded in the slurry receiving area.
The MLO milling process is briefly described below:
Leaching - The slurry is pumped into the leaching circuit where it is acidified with sulphuric acid, amended with ferric sulphate, and hydrogen peroxide is added as an oxidant.
Counter Current Decantation (CCD) - The discharge from the leaching circuit is pumped to the CCD consisting of six high rate thickeners for solid/liquid separation to wash the solids to remove soluble uranium.
Clarification - The soluble uranium recovered from the CCD is forwarded to the clarification circuit where solids are removed. The large volume clarifier allows sufficient settling time to lower the suspended solids content. Overflow from the clarifier goes through sand filters, which further removes residual solids. This pregnant4 aqueous solution containing dissolved uranium then flows into the solvent extraction circuit.
Solvent extraction - The pregnant aqueous solution from the clarification circuit is contacted counter-currently with barren organic solution in a four-stage extraction process. In the stripping process, uranium is transferred from the organic phase back to an aqueous phase in five counter-current stages. The resultant pregnant strip solution from solvent extraction reports to the yellowcake precipitation circuit where molybdenum is removed.
Yellowcake precipitation - Following molybdenum removal, uranium present in the pregnant strip solution is precipitated with ammonia and fed to yellowcake thickener. The resulting product, known as yellowcake, is moved into the calcining circuit.
Calcining - The purpose of the calcining circuit is to dry the precipitated yellowcake at a high temperature to remove moisture and other impurities from the product. This converts the uranium to a black oxide called calcined yellowcake uranium concentrate (U3O8).
Product packaging - The calcined yellowcake is finally packaged into steel drums for shipment.
3 A type of industrial package (‘IP’) designed in accordance with the applicable requirements of the IAEA regulations. These Type IP-2 packages refer to slurry totes used to transport/receive ore slurry. 4 A solution that contains uranium.
Figure 4 depicts a mill operator collecting a sample of uranium solution in the yellowcake precipitation circuit.
Figure 4: McClean Lake – collection of uranium solution sample
1.3 Highlights AREVA McClean Lake Operation’s current licence is valid for a period of eight years from July 1, 2009 to June 30, 2017. AREVA submitted an application with a request to renew its operating licence for a period of 12 years until June 30, 2029. While CNSC staff note that current practice has been to issue licences for a 10 year term, CNSC staff have confirmed that the requested licensing term of 12 years for the MLO does not compromise health and safety of the persons and the environment.
AREVA’s MLO is a mature facility with established programs and a management system focused on continuous improvement. CNSC staff conduct regular oversight activities to ensure AREVA continues to meet regulatory requirements. Annual regulatory oversight reports are presented to the Commission to allow for updates regarding licensee performance and CNSC regulatory oversight activities.
In support of this licence renewal AREVA submitted, in 2016, Environmental Performance Technical Information Documents (TIDs) which include environmental monitoring data and information on the impacts licensed activities may have on the environment. These TIDs are required on a five year cycle. CNSC staff reviewed the TIDs and concluded that environmental assessment monitoring results at the MLO are consistent with the predictions in the approved environmental assessment and environmental risk assessments (ERA). The TIDs are an important consideration in reviewing the licence. The review, evaluation and final acceptance of the TIDs by CNSC staff requires a minimum of one year. Therefore, the requested 12 year licence term will allow AREVA and CNSC staff to effectively complete two cycles of review and acceptance of the TIDs before any future licence renewal. A 12 year licence term will also allow AREVA and CNSC staff to present more environmental data and trending information to the Commission and the public.
In preparation for the licence renewal, CNSC staff held a CNSC 101 information session for the Wollaston Post/Hatchet Lake First Nation communities in October 2016. The information session included detailed information on the proposed licence renewal. CNSC staff also participated in an outreach session at the Black Lake and Fond du Lac First Nation communities in January 2017. Overall, community members and Leadership indicated that they are generally supportive of AREVA’s MLO licence renewal request including the proposed licence term.
Processing of ore at the MLO was suspended and the mill was temporarily shut down in July 2010 due to a shortage of ore. The high grade ore slurry shipments from Cameco Corporation’s Cigar Lake mine began in March 2014 and the MLO restarted in September 2014. After restart and commissioning of the MLO with Cigar Lake ore slurry, CNSC staff focused oversight activities on AREVA’s radiation protection program implementation. CNSC staff verified that the MLO continued to keep worker doses as low as reasonably achievable (ALARA) while processing high grade ore at higher production levels. CNSC staff also confirmed that AREVA’s environmental management system has proven successful in protecting the environment and environment performance objectives for the MLO continue to be achieved.
During the current licence period (2009-2016), AREVA implemented several key significant projects to improve overall operational performance. Based on continued monitoring and assessments by CNSC staff of AREVA’s compliance performance at the MLO, CNSC staff confirmed that AREVA has continued to improve the management and safety performance of the facility. CNSC staff rated AREVA’s performance at the MLO site for all 14 safety and control areas (SCAs) as “satisfactory”. AREVA’s overall performance ratings of the MLO are presented in section 3.
The operation and modification of a nuclear facility for the mining of uranium and the production of uranium concentrate; and import, process, use, store, transfer and dispose of nuclear substances and radiation devices are the primary activities in AREVA’s licence renewal application. There are no new licensed activities proposed. In the upcoming licence term, AREVA has confirmed to develop and implement a formal selenium adaptive management plan to control JEB water treatment plant (WTP) selenium effluent concentration. AREVA has also requested to implement the JEB TMF expansion project to modify and expand the outer perimeter of the TMF to increase tailings storage capacity required for the future operation of the MLO. These plans are discussed in further detail under section 4.5 Improvement Plan and Significant Future Activities of this CMD (subsection 4.5.3 – Selenium Adaptive Management Plan; subsection 4.5.4 – JEB Tailings Management Facility Expansion Project).
The JEB TMF expansion project was taken into consideration in AREVA’s recently submitted environmental risk assessment (ERA). An environmental assessment (EA) under the Nuclear Safety and Control Act (NSCA) was conducted by CNSC staff for the MLO licence renewal including the JEB TMF expansion. The EA report (addendum E) provides an update on CNSC staff’s review of MLO’s environmental programs, and concludes that AREVA has made and will continue to make adequate provision for the protection of the environment and the health and safety of persons.
1.4 Overall Conclusions CNSC staff conclude the following, with respect to paragraphs 24(4)(a) and (b) of the NSCA, in that AREVA:
1. is qualified to carry on the activities authorized by the licence
2. will, in carrying out that activity, make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed
1.5 Overall Recommendations The licensing recommendations are based on the overall assessment of AREVA’s compliance with the NSCA and associated Regulations, the adequacy of the measures in place to ensure the health and safety of persons and the environment and of the measures related to security and Canada’s international obligations during the period that the proposed licence covers. CNSC staff recommend that the Commission:
1. renew the Uranium Mine Operating Licence (UMOL) to authorize AREVA to operate the MLO valid until June 30, 2029 pursuant to subsection 24(2) of the NSCA
2. accept AREVA’s McClean Lake revised financial guarantee for decommissioning in the amount of C$107,241,000
3. authorize the delegation of authority as set out in section 4.9 of this CMD
2.1 Environmental Assessment An EA under the NSCA and associated Regulations was conducted for AREVA’s MLO licence renewal application. Further information can be found in the EA report provided in addendum E. CNSC staff concluded that AREVA has made, and will continue to make, adequate provision for the protection of the environment and the health and safety of persons.
2.2 Relevant Safety and Control Areas Regulatory oversight is performed in accordance with a standard set of safety and control areas (SCAs). SCAs are technical topics used across all CNSC regulated facilities and activities to assess, evaluate, review, verify and report on licensee regulatory requirements and performance. Further information about SCAs is provided in addendum D of this CMD.
Risk ranking and rating levels Table 2 provides the level of risk ranking and overall rating level associated with each SCA at the MLO. This CMD provides an evaluation of AREVA’s past performance of the MLO over a period extending from 2009 to 2016, henceforth referred to as the current licence period. Additional information about risk ranking and rating levels are provided in addendums A and B respectively of this CMD.
Table 2: McClean Lake - safety and control areas relevant to the MLO
Functional area Safety and control area Risk ranking Overall rating level*
Management Management system H SA
Human performance management M SA Operating performance M SA
Facility and equipment
Safety analysis L SA
Physical design L SA Fitness for service L SA
Core control processes
Radiation protection H SA
Conventional health and safety H SA Environmental protection H SA Emergency management and fire protection M SA Waste management M SA Security L SA Safeguards and non-proliferation L SA Packaging and transport L SA
Notes: H = High M = Medium L = Low SA = Satisfactory
* This represents an overall rating level for the current licence period (from 2009 up to February 28, 2017).
2.3 Other Matters of Regulatory Interest The following is a list of other matters of regulatory interest relevant to this CMD:
Aboriginal consultation
other consultation
cost recovery
financial guarantees
improvement plans and significant future activities
public information and disclosure
proposed licence period
licence conditions handbook
delegation
These other matters of regulatory interest are further discussed in section 4 of this document.
2.4 Regulatory and Technical Basis The regulatory and technical basis for the matters discussed in this CMD come directly from the Uranium Mines and Mills Regulations and the General Nuclear Safety and Control Regulations (GNSCR) as well as other regulatory requirements associated with the NSCA. Further information regarding the regulatory and technical basis for the matters discussed in this CMD is provided in addendum C of this document and in the draft LCH.
3. GENERAL ASSESSMENT OF SCAS CNSC staff’s assessments provided in the following sections are based on a comprehensive review of AREVA’s past performance at the MLO and a thorough evaluation of the safety and control measures to be implemented for the next licence period, outlined in AREVA’s licence application and documentation submitted to support this application.
The CNSC implements a risk-informed approach in the regulation of nuclear facilities and activities. The depth of regulatory reviews of each SCA and the baseline frequency of regulatory compliance activities is informed by the risk ranking of that SCA (section 2.2, table 2).
CNSC staff provided continuous regulatory oversight at the MLO which consisted of licensing and compliance activities. Table 3 provides a summary of CNSC staff licensing and compliance activities and CNSC onsite inspections carried out at the MLO during the current licence period.
Table 3: McClean Lake - CNSC staff’s regulatory effort and number of inspections carried out during the current licence period, 2009-16
Year 2009 2010 2011 2012 2013 2014 2015 2016
Person days for licensing activities 64 47 94 148 314 46 22 69*
Person days for compliance activities 303 478 516 533 321 242 342 256*
Number of inspections 4 6 7 5 5 6 6 6
*2016 numbers are from January 1 to September 30, 2016.
3.1 Management System The management system SCA covers the framework that establishes the processes and programs required to ensure an organization achieves its safety objectives, continuously monitors its performance against these objectives, and fosters a healthy safety culture.
3.1.1 Trends The following table provides the annual compliance ratings for the management system SCA for the current licence period 2009 to 2016:
MANAGEMENT SYSTEM SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has a mature management system which continues to improve to meet evolving regulatory requirements. CNSC staff monitor implementation of the management system at the McClean Lake Operation through compliance verification activities which includes desktop reviews and onsite inspections. During the current licensing period, areas of improvement have been identified and implemented by AREVA.
AREVA continues to have an effective management system and has taken proactive steps to review and incorporate the requirements of CSA Group standard N286-12, Management System Requirements for Nuclear Facilities into the McClean Lake Operation management system.
Management system AREVA is expected to establish a management system to oversee its MLO activities to assure the protection of health, safety and the environment. AREVA is also required to implement and maintain written operating procedures and carry out the licensed activities in accordance with the policies and programs for the purposes described in the licence renewal application. AREVA uses an integrated quality management system (IQMS) for the MLO that is comprised of management system policies and reference to IQMS procedures, work instructions, forms and other controlled documents (including reports and training manuals). CNSC staff monitored and evaluated the management system processes used for the licensed activities during the current licensing period.
CNSC staff verified AREVA’s implementation of its management system in accordance with CNSC regulatory requirements through inspections and desktop reviews during the current licence period. In 2015, a focused management system inspection was conducted to verify implementation and effectiveness of AREVA’s management system at the MLO. CNSC staff developed inspection criteria to sample selected components of the management system and mitigation measures identified by AREVA to manage risks to the operation. The inspection report outlined some low risk deficiencies that resulted in five non-compliances in the areas of design control/change control, independent and self-assessments, contractors’ management, and documentation related to non-conformance procedure. As required by CNSC staff, AREVA provided an action plan to address non-compliances. CNSC staff reviewed and confirmed that AREVA addressed the non-compliances in a timely and satisfactory manner and have taken appropriate corrective actions; therefore, all five non-compliances have been closed.
In 2015, CNSC staff completed a desktop review of AREVA’s IQMS. The main objective of the review was to confirm that the IQMS met CNSC regulatory requirements. Some areas for improvement of low safety significance were identified by CNSC staff and promptly addressed by AREVA. In 2016, a desktop review was carried out by CNSC staff to assess the MLO IQMS compared to the CSA Group standard N286-12, Management System Requirements for Nuclear Facilities. The review identified some minor gaps against the CSA Group standard N286-12. All gaps have been addressed by AREVA to the satisfaction of CNSC staff. AREVA was proactive in reviewing and incorporating the requirements of the standard into its IQMS. Currently there are no issues between the requirements as outlined in CSA Group standard N286-12 and the MLO IQMS. In conclusion, AREVA’s revised IQMS is in compliance with the requirements of CSA Group standard N286-12. Continued implementation of the IQMS program at the MLO will be verified as part of CNSC staff’s ongoing compliance verification activities.
Contractor management program AREVA’s contractor management program ensures that all contract workers at the MLO comply with the same requirements as the licensee’s permanent staff. In 2015, CNSC staff reviewed AREVA’s contractor management program and carried out a focused management system onsite inspection, using LCH compliance verification criteria as inspection guidance. Only one minor issue with AREVA’s documentation related to the contractor oversight was identified. Subsequent to the inspection, AREVA prepared and implemented a corrective action plan to address the issue, which CNSC staff reviewed and found acceptable. CNSC staff conclude that AREVA’s performance in this area is satisfactory.
3.1.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance Through review of AREVA’s documentation and CNSC staff’s regular compliance inspections, CNSC staff found that AREVA’s performance in this area meets CNSC regulatory requirements. CNSC staff rated AREVA’s performance for the management system SCA at the MLO as satisfactory over the last eight-year licence term.
Regulatory focus CNSC staff will continue to monitor AREVA’s performance in this area through regulatory oversight activities including onsite inspections and desktop reviews.
Proposed improvements There are no other proposed improvements for this SCA. CNSC staff, as part of on-going compliance activities will review any proposed modifications to AREVA’s management system documentation as it is adapted to conform to CSA Group standard N286-12.
3.1.4 Conclusion CNSC staff conclude that AREVA met its regulatory requirements and has maintained and implemented a satisfactory management system program.
Two conditions in the proposed licence are associated with the management system SCA. Licence condition 1.1 requires AREVA to implement and maintain a management system. Licence condition 1.2 requires AREVA to ensure that every contractor working at the facility complies with the licence. Compliance verification criteria for these licence conditions are provided in the draft LCH.
3.2 Human Performance Management The human performance management SCA covers activities that enable effective human performance through the development and implementation of processes that ensure a sufficient number of licensee personnel are in all relevant job areas and have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties.
3.2.1 Trends The following table provides the annual compliance ratings for the human performance management SCA for the current licence period 2009 to 2016:
HUMAN PERFORMANCE MANAGEMENT SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
CNSC staff consistently rated the human performance management SCA as satisfactory during the current licence period. AREVA has an acceptable training program and has improved performance through the implementation of a systematic approach to training (SAT) at the McClean Lake Operation during the licensing period.
AREVA was in compliance with Version 1 of CNSC REGDOC-2.2.2, Human Performance Management, Personnel Training. In December 2016, CNSC published Version 2 of REGDOC-2.2.2. AREVA continues to maintain and improve its training system and confirmed implementation of Version 2 by December 2017.
3.2.2 Discussion A SAT is the framework endorsed by the CNSC for establishing and maintaining training for persons working in uranium mines and mills. AREVA is required to ensure that employees and contractors are trained and assessed to confirm that they have acquired and maintain the knowledge, skills, and competencies to safely perform their work assignments. AREVA has implemented a SAT framework to train its workers at the MLO.
AREVA reports to the CNSC annually on improvements to its training programs and training delivered to MLO workers. CNSC staff review AREVA’s adherence to its training plan and maintenance of training records through periodic routine compliance inspections.
CNSC regulatory document, REGDOC-2.2.2, Human Performance Management, Personnel Training, Version 1 originally published in August 2014 and updated as Version 2 in December 2016, defines the requirements for the development and implementation of a training system in a nuclear facility. It requires licensees to develop and implement a training system to systematically analyze, design, develop, implement, evaluate, document and manage training for persons working in a nuclear facility. AREVA reviewed its training documentation against updated REGDOC-2.2.2, Version 2 and confirmed implementation by December 2017.
AREVA’s revised IQMS included sections related to the training program and a suite of training procedures. CNSC staff evaluated AREVA’s training documentation to determine if regulatory requirements of the human performance management (training) SCA are being met. CNSC staff concluded that AREVA is qualified to carry out its authorized licensed activities and are satisfied with the training system at the MLO.
In January 2015 CNSC staff conducted an inspection at the MLO to evaluate and verify compliance regarding AREVA’s training program and its effective implementation. In particular, the inspection reviewed the analysis and changes made to the training program as a result of the startup and commissioning of the MLO after significant modifications following a four-year mill shutdown. Two non-compliances and three recommendations were noted by CNSC staff. The non-compliances were related to minor deficiencies in areas of job task analyses, mandatory training requirements for advanced radiation protection, mill operators training certification, and managing non-conformance processes at the MLO. CNSC staff verified that AREVA provided the basic radiation health and safety training required by the licence; however minor deficiencies were identified in the advanced radiation protection training to four mill operators whose training had expired and required refresher training. The deficiencies including refresher training to the four mill operators were addressed by AREVA to CNSC staff’s satisfaction and all non-compliances were corrected.
CNSC staff will continue to verify AREVA’s progress on implementing programs and procedures at the MLO that support the human performance management SCA as part of ongoing regulatory oversight activities. Based on the above assessment, CNSC staff conclude that AREVA’s performance in SAT has been satisfactory.
3.2.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements for human performance management at the MLO are presented in the following subsections.
Past performance In support of the licence renewal and based on a comprehensive review of AREVA’s updated training documentation, annual reports and routine compliance inspections, CNSC staff conclude that AREVA’s performance for this area meets regulatory requirements. CNSC staff rated AREVA’s overall performance for the human performance management SCA at the MLO as satisfactory for the current licence period. CNSC staff are also satisfied that AREVA has taken, or will continue to take, all appropriate corrective actions necessary to resolve any non-compliances that stem from inspections and document reviews conducted during and/or after the current licence period.
Regulatory focus CNSC staff’s regulatory focus for the next licensing period will be on ensuring AREVA’s compliance with a SAT and the requirements of REGDOC-2.2.2, Version 2 at the MLO. CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews.
Proposed improvements There are no other proposed improvements for this SCA. For the current licence period, the performance rating for this SCA has been largely focused on the training program and its implementation.
CNSC staff, as part of on-going compliance activities, will review any proposed modifications to AREVA’s training program.
3.2.4 Conclusion Based on the above assessment, CNSC staff conclude that the performance of AREVA’s training system and resulting training programs for the MLO are satisfactory, and AREVA is qualified to carry out its authorized licensed activities.
One condition in the proposed licence is associated with the human performance management SCA. Licence condition 2.1 requires AREVA to implement and maintain a training program for its MLO. Compliance verification criteria along with REGDOC-2.2.2, Human Performance Management, Personnel Training are included in the draft LCH.
3.3 Operating Performance The operating performance SCA includes an overall review of the conduct of the licensed activities and the activities that enable effective performance.
3.3.1 Trends The following table provides the annual compliance ratings for the operating performance SCA for the current licence period 2009 to 2016:
AREVA has implemented and maintained operating performance systems at the McClean Lake Operation that include construction, commissioning and operation of the facility in accordance with CNSC regulatory requirements. CNSC staff monitor implementation of this operating program through compliance verification activities which includes routine desktop reviews and onsite inspections. The operating performance SCA is a key compliance area and is included in the majority of CNSC staff inspections. CNSC staff’s compliance activities verify that AREVA continues to improve its operating performance.
AREVA’s McClean Lake Operation operating performance program continues to improve, be effective and meet regulatory requirements.
3.3.2 Discussion The operating performance SCA requires that the licensee implement and maintain an operating performance program for the conduct of licensed activities. This SCA focuses on the conduct of operations and the controls that are in place to manage risks from licensed activities. During the conduct of activities, the CNSC expects AREVA to take all reasonable precautions to protect workers and to control the release of nuclear and hazardous substances into the environment. The necessary precautions include engineering and administrative controls to minimize risks. The licensee is expected to maintain the integrity of its facilities and to apply managed processes for operations and control.
During the licensed period, CNSC staff confirmed that AREVA operated the MLO in accordance with regulatory requirements. CNSC staff are satisfied with AREVA’s programs, which provide adequate assurance that any modifications to the facility or its operation will remain within the licensing basis.
After temporary shutdown of the MLO (2010 to 2014), AREVA restarted the mill with commissioning of new and modified circuits and the restart of existing circuits to process Cigar Lake ore slurry. During the McClean Lake mill restart in September 2014, uranium ore grades and production rates were systematically increased. Ore grade was increased incrementally from 0.3 percent to 23 percent while production rates increased to 1.6 million pounds of uranium concentrate (U3O8) per month until the end of 2015. This incremental production increase allowed verification of the safety and control systems related to worker health and safety as well as radiation and environmental protection. The production rate continues to ramp up as the operation is further optimized.
The table below provides the annual McClean Lake milling production data from 2009 to 2016.
Table 4: McClean Lake - milling production data, 2009-16
1.0 Mlbs = 1,000,000 lbs * The MLO mill temporarily stopped producing uranium concentrate in July 2010. ** Ore that had been mined before the end of 2008 and ore extracted during the Surface Access Borehole
Resource Extraction (SABRE) project were processed by the MLO mill during 2009 and 2010. *** 2016 values are based on January to June 2016 data.
All major improvement projects including the JEB mill upgrade, leaching circuit modifications, restart and commissioning of the MLO with Cigar Lake high grade ore slurry, and annual production increase were sufficiently described and supported for CNSC staff to conduct necessary technical reviews. When additional information was requested by CNSC staff, AREVA provided it in a timely manner and met regulatory requirements.
AREVA’s performance at the MLO in this area is satisfactory. Details of CNSC staff’s assessment of major improvement projects are presented in the following sections.
JEB mill upgrade project In December 2012, AREVA submitted an application to construct the JEB Mill Upgrade Project which would increase the mill’s annual production capacity to 24 million pounds of uranium concentrate [6]. The JEB mill upgrade project included modifications, alterations and additions to some of the mill uranium production circuits, mill utilities and supporting facilities. CNSC staff conducted a detailed technical assessment of AREVA’s proposal and verified that there were no potential impacts to the environment or human health and the project remains within the bounds of previous environmental assessments and the safety case.
Figure 5: McClean Lake – aerial view of the mill
CNSC staff reviewed the proposed project including supporting submissions and concluded that AREVA provided sufficient information for CNSC staff to determine that the proposed changes were within the licensing basis. Programs have been implemented to manage the construction and commissioning of changes to the MLO facility and the safe operation of the upgraded mill. CNSC staff are satisfied that the proposed changes are safe with respect to the environment and to the health and safety of persons. CNSC staff verified AREVA’s safety performance for the construction activities related to the JEB mill upgrade project through onsite inspections. AREVA’s staff and contractors worked over two million man-hours in completing this MLO project safely with no lost time injuries (LTI).
Changes to the leaching circuit Results of lab tests conducted by AREVA on Cigar Lake ore determined that hydrogen gas was produced during acid leaching; stagnant high point volumes within the leaching vessels presented a risk of hydrogen accumulation. There is a potential that hydrogen gas concentrations in the leaching circuit could reach flammable levels. In order to mitigate the hydrogen risk, AREVA submitted a request in January 2014 to the CNSC to modify the MLO leaching circuit [7]. AREVA used a defence-in-depth strategy to ensure that hydrogen concentrations in the headspace of leaching tanks operate within acceptable limits. The following lists some of the key changes made to the leaching circuit:
eliminated high point dead spots within the leaching vessel headspace
reallocated the nozzles to the lid of each leaching vessel to move the reagent addition points to higher mixing zones
improved the level indication reliability with non-contacting level technology by installing new rod source nuclear level gauges and point source nuclear level switches
isolated the leaching process ventilation from the existing mill process ventilation systems
increased dilution air and process ventilation capacity to manage hydrogen generation in the leaching vessels
added nitrogen purge capabilities to each leaching vessel
reconfigured the leach vault ventilation as necessary to provide protection from hydrogen (H2) accumulation at the top of the vault enclosure
altered leaching controls and interlocks
CNSC staff reviewed all the information and concluded that AREVA provided sufficient information to determine that the proposed changes were within the licensing basis and that the changes, with the implementation of the described engineering and administrative controls, will protect the health and safety of workers and the environment. In January 2016, CNSC staff verified through an onsite inspection that the modified leaching circuit is operating as designed. The air sweep, nitrogen purge, gas monitoring systems and related safety interlocks have proven effective.
Restart and commissioning of the MLO with Cigar Lake ore slurry After temporary shutdown of the MLO from 2010 to 2014, the mill restarted in September 2014 to process Cigar Lake high grade ore slurry. After one year into operation of the McClean Lake mill, CNSC requested AREVA to submit a commissioning report providing safety analysis and confirmation of performance with respect to conventional health and safety, radiation protection and environmental protection. Accordingly, AREVA submitted a Report on Commissioning & Restart of the McClean Lake Mill in December 2015 discussing in detail the commissioning and restart activities, circuit by circuit, including any design changes with implications and mitigation measures [8].
The submitted report provided an evaluation of the construction, commissioning and operating performance of the mill. AREVA also provided a review of the MLO worker conventional health and safety, radiation protection and environmental performance as it relates to the commissioning and operation of the upgraded mill and increased production rate. After a thorough review, CNSC staff accepted the commissioning report and concluded that the operations at the MLO have demonstrated capability to meet production targets as designed in each circuit while meeting objectives for the protection of the environment and safety of workers.
Increase to McClean Lake annual production rate In February 2016 and in accordance with the LCH, AREVA submitted a request to increase the MLO annual production rate from 13 to 24 million pounds of uranium concentrate per year [8]. Annual production at this rate has been considered in several environmental assessments carried out since 1995 until most recently in 2011 with the Midwest Project environmental assessment determination, subsequently approved by the Commission [9].
CNSC staff reviewed AREVA’s request to increase the MLO’s annual production rate, including radiation and environmental protection aspects. CNSC staff conclude that a comprehensive radiation protection program, which meets the requirements of the Radiation Protection Regulations, has been implemented at the MLO to support the protection of workers as production rates increase. The radiation protection monitoring of workers and workplaces validates that the MLO is continuing to keep worker doses as low as reasonably achievable (ALARA) while processing high grade ore at higher production levels. The environmental management system (EMS) at the MLO provides a system for control of environmental aspects. Environmental performance relating to tailings, wastewater treatment and air quality during restart and commissioning continue to show that the MLO is performing within the operating parameters as described in the environmental code of practice (ECOP).
CNSC staff reviewed AREVA’s submission for production increase and requested the following information for greater clarity:
identification of risk categorization to include mitigation measures in relation to the health and safety of workers and the environment for the proposed modifications to the leaching, counter current decantation (CCD), calciner, ammonium sulphate crystallization and sulphuric acid plants
corrective measures to improve tailings thickener underflow density, sulphur dioxide and selenium management
AREVA responded to CNSC staff comments in a timely and satisfactorily manner. CNSC staff determined that the proposed increase in production remains within the existing authorized activities and the operations remain within the safety case as approved by the Commission. CNSC staff conclude that AREVA provided sufficient information for CNSC staff to determine that the proposed change is within the licensing basis and the health and safety of workers and the environment remain safe.
Reporting and trending As required by the current licence, UMOL-MINEMILL-McClean.01/2017, AREVA is required to submit the following reports regarding the MLO as shown in table 5.
Table 5: McClean Lake - reports required under CNSC licence
Reports Frequency Unplanned events within 24 hours
Radiological area monitoring monthly
Personal alpha dosimeter dose estimates monthly
Gamma dose estimates quarterly
Radiological monitoring reports quarterly
Environment reports quarterly
Compliance reports annually
AREVA is also required to report unplanned events at the MLO and take necessary corrective actions to improve safety and to prevent the recurrence of such events. AREVA’s Action Tracker System (ATS) is used for its internal reporting, follow-up and trending of incidents at the MLO. When unplanned events occur that could potentially increase the risk to the health and safety of persons and the environment, CNSC staff increase its regulatory oversight at the MLO facility and monitor AREVA’s activities related to corrective actions and its implementation.
During the current licence period, events related to plant operations, lost time injuries, environmental spills, radiation protection (RP) and environmental protection (EP) action levels exceedances were promptly reported to the CNSC and other relevant regulators including Saskatchewan Ministry of Environment (SMOE), Ministry of Labour Relations and Workplace Safety (LRWS), and Environment and Climate Change Canada (ECCC). All incidents were of low safety significance. No event initial reports (EIR) were presented to the Commission during the current licence term. In accordance with its Public Information Program and Disclosure Protocol, AREVA has continued to proactively disclose reportable events.
CNSC staff verified that AREVA conducted investigations into these events to determine probable causes and that necessary corrective actions were taken by AREVA to prevent reoccurrences. CNSC staff confirmed that persons and the environment continue to be safe. CNSC staff are satisfied with the MLO event reporting, investigation process, and timely implementation of corrective actions and lessons learned to minimize and/or eliminate future recurrences.
3.3.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance AREVA has operated the MLO in compliance with CNSC regulatory requirements. Findings from inspections or desktop reviews were addressed in a timely manner. CNSC staff rate AREVA’s overall performance for the operating performance SCA at the MLO as satisfactory for the current licence period.
Regulatory focus As required by CNSC, AREVA will implement a selenium adoptive management plan to control selenium effluent concentration. AREVA has also requested to modify the JEB TMF; therefore, CNSC staff’s regulatory focus will be on ensuring that these activities are completed safely and protecting the environment. These plans are further discussed in subsections 4.5.3 and 4.5.4.
CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of MLO’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements Improvements to operation, equipment and programs are identified on an ongoing basis and implemented as part of continuous improvement. There are no other proposed improvements for this SCA.
3.3.4 Conclusion During the current licence period, CNSC staff observed that AREVA has operated the MLO facility in compliance with the CNSC’s regulatory requirements.
Based on the above assessment, CNSC staff concluded that AREVA has improved operational performance, and has made adequate provision for safe operation of the MLO. CNSC staff rate the operating performance SCA as satisfactory.
Two conditions in the proposed licence are associated with the operating performance SCA. Licence condition 3.1 requires AREVA to implement and maintain an operating program, which includes a set of operating limits. Licence condition 3.2 requires AREVA to implement and maintain a program for reporting to the Commission or a person authorized by the Commission. Compliance verification criteria for these two conditions are included in the draft LCH.
3.4 Safety Analysis The safety analysis SCA covers the maintenance of the safety analysis that supports the overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards.
3.4.1 Trends The following table provides the annual compliance ratings for the safety analysis SCA for the current licence period 2009 to 2016:
SAFETY ANALYSIS SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has implemented and maintained a process to identify hazards and assessment of risks related to the protection of the environment and to the health and safety of workers and the public, as well as radiation protection. CNSC staff verifies AREVA’s implementation of the safety analysis SCA through onsite inspections and desktop reviews.
AREVA’s safety analysis program continues to be effective in providing CNSC staff with an assessment of the proposed changes or modifications, identification and evaluation of risks and impacts, and proposed mitigation measures.
In conformity with CNSC requirements, AREVA is required to implement and maintain a process to identify and assess hazards and risks on an ongoing basis at the MLO. This includes identifying and evaluating new or unforeseen risks that were not considered at the planning and design stages and updating previous risk assessments by replacing important assumptions with performance data.
Hazard analysis Hazard analysis provides an opportunity to identify and mitigate potential hazards to worker health and safety, and to the environment, to an acceptable level or ALARA. These are completed by workers and subject matter experts before the job begins. AREVA uses the following methods for identifying risks and hazards at the MLO as the jobs are being planned:
risk assessment
safe work plans
Risk assessment As per CNSC regulatory requirements, AREVA’s MLO continues to maintain a register of hazards, risks and mitigation measures for the facility, which are reviewed and updated for the new projects, significant changes or modifications and non-routine tasks. Risk assessments for permanent mill areas are reviewed at a minimum of every two years or:
prior to changes to facilities
following high potential incidents
following legislation/regulation changes
following required actions as identified in investigations, inspections or by regulators
Risks are mitigated with consideration to the following hierarchy:
Safe work plans are conducted for any work considered non-routine and high risk. The purpose is to assess hazards specific to tasks, to ensure controls are developed and that all personnel understand the risks associated with the completion of the job. The safe work plan outlines the tasks and hazards involved, corrective actions, level of risk, training and personal protective equipment required. Safe work plans are to be reviewed and signed by all personnel working on the job.
Prior to implementing any significant changes or modifications, AREVA provides the CNSC with an assessment of the proposed changes or modifications, identification and assessment of potential risks and impacts and proposed mitigation measures for the MLO.
AREVA has a change control process for the MLO which CNSC staff have reviewed and accepted. Changes to the mill and associated facility processes are completed through MLO’s change control process which also includes a risk assessment requirement. CNSC staff conducted inspections and desktop reviews to confirm that safety analysis is also completed on an ongoing basis by AREVA’s MLO on specific job requirements to assess all jobs of non-routine or complex nature. Through onsite inspections, CNSC staff also verified that AREVA has the necessary safety analyses to plan, implement and monitor construction ensuring mitigation of risks to workers, the public and the environment have been conducted. An inspection conducted in January 2016 confirmed safety analysis SCA compliance verification criterion and found AREVA to be in compliance.
3.4.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance Through CNSC staff’s review of AREVA’s MLO safety documentation, CNSC staff concluded that the safety analysis program meets requirements.
For the current licence period, CNSC staff rated AREVA’s overall performance for the safety analysis SCA as satisfactory.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of MLO’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements There are no other proposed improvements for this SCA.
3.4.4 Conclusion Based on the above assessment, CNSC staff concluded that AREVA is meeting the regulatory requirements and CNSC staff’s expectations to protect both workers and the environment at the MLO as it relates to the development and maintenance of the safety analysis for the facility.
One condition in the proposed licence is associated with the safety analysis SCA. Licence condition 4.1 requires AREVA to implement and maintain a safety analysis program. A compliance verification criterion for this licence condition is included in the draft LCH.
3.5 Physical Design The physical design SCA relates to activities that impact the ability of structures, systems and components to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account.
3.5.1 Trends The following table provides the annual compliance ratings for the physical design SCA for the current licence period 2009 to 2016:
PHYSICAL DESIGN SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has implemented and maintained a design control process that verifies and validates the design to ensure safety, performance and dependability of the facility.
AREVA has a mature physical design control system in place which continues to remain effective and meet regulatory requirements.
3.5.2 Discussion The CNSC expects licensees to implement and maintain a design control process to ensure that design outputs are verified against design inputs and performance expectations. AREVA’s MLO physical design is described and documented in its facility description manual (FDM) [10]. The FDM provides details including physical description, technical specifications and capacities. The FDM provides the next level of detail in support of the mining facility licensing manual [11]. AREVA uses facility change control and design control processes to ensure that any physical changes to the facility are reviewed and approved by site management before implementation. The facility change control and design control processes have been reviewed and accepted by CNSC staff. Site inspections conducted in March 2016 and May 2016, by CNSC staff, verified that continuous improvements to the facility’s change control process have been implemented thereby making the process more effective.
The MLO has been designed to process high grade ores at higher production rates without any dilution. CNSC staff previously reviewed and approved the mill design to ensure compliance with CNSC regulatory requirements as described in sections 5(1)(2) of the Uranium Mines and Mills Regulations. The licensee is encouraged to make continuous improvements to the design of the facilities and equipment. CNSC staff will continue to monitor any proposed changes to the design to ensure that the changes remain within the licensing basis authorized by the Commission.
The physical design of important milling circuits is described below ensuring CNSC regulatory limits are met and remain ALARA.
JEB tailings management facility The JEB tailings management facility (TMF) is an in-pit tailings disposal facility. The TMF was designed and managed to provide long-term hydrodynamic containment of tailings. The TMF consists of:
Figure 6: McClean Lake – JEB tailings management facility
The drift and raise system consists of sand and gravel filters, a drain rock under the tailings that is penetrated by a rock-filled drift, and three raised wells that penetrate the drift outside the JEB TMF. The system pulls tailings pore water and surrounding groundwater through the filter, pumps it through the leaching circuit heat exchanger and onto the process water tank for use throughout the mill. Any excess water not used for mill processes is directed to the JEB water treatment plant (WTP). Four observation wells associated with the JEB TMF are used to confirm groundwater hydraulic head values and groundwater quality. This is also used in congruence with the reclaim system to maintain hydraulic containment of the TMF.
The JEB TMF and supporting systems design have been previously reviewed and accepted by CNSC staff.
Shielding design In designing the MLO, CNSC staff required radiation protection objectives be identified for radiological parameters to ensure compliance with regulatory requirements. The shielding design features, incorporated into the mill design to maintain worker radiation doses ALARA, have been reviewed and accepted by CNSC staff. Radiation protection is achieved through protective shielding, separation of workers from potential increased exposure areas, containment of contaminants, and area designation.
The primary shielding features incorporated into the MLO include:
The ore receiving hopper is covered with 24 millimetres of lead shielding on the outside surface.
The grinding operator’s control room has a concrete wall enclosure.
The slurry receiving operator’s control room has a concrete wall enclosure.
The slurry tank and the slurry receivers are contained in a concrete enclosure.
The carbon steel pachuca tanks are enclosed in a 300 millimetre thick concrete enclosure room.
The leach tanks are a neoprene lined carbon steel tank set into a 300 millimetre thick concrete enclosure room.
The bottom cone of each CCD thickener is covered with 24 millimetre thick lead plates.
The neutral thickener and tailings thickener also have similar lead shielded cones.
Separation and containment design Separation has been used throughout the mill to distance the workers from the radioactive materials and to control and contain the materials during normal operation. Separation and containment design features were incorporated into the mill design to ensure compliance with regulatory requirements. These forms of separation include:
Control rooms designed to enable operators to complete job tasks reducing proximal work to radiation sources.
A shielded floor slab separates the workers on the leaching operation floor from the leach vessels on the lower level. The design reduces gamma radiation exposure to maintenance and operation staff from the vessels allowing access to the components on the operating floor for maintenance purposes.
The lower mill level is divided into concrete cells which contain process vessels. The cells are designed to provide shielding to the general work areas and ensure containment of radioactive materials.
The floors in specific locations are steeply graded toward sumps ensuring liquid spills are efficiently contained and removed to minimize worker contact with radioactive materials.
The calciner (yellowcake dryer) is located within an enclosure to provide separation from general work areas and containment of any radioactive materials.
Ventilation design As per regulatory requirements, the purpose of the ventilation systems at the MLO is to provide a safe work environment by eliminating exposures to workplace airborne contaminants, particularly radon and its progeny. The design objective for the MLO is to maintain workplace concentrations of radon progeny below 0.03 working levels. The ventilation design ensures that CNSC regulatory dose limits (50 mSv/year) are met and are ALARA.
Workplace protection is accomplished by implementing:
single pass air flow to facilitate airborne contaminant loading without recirculation
process ventilation systems are established to capture emissions at the source
process exhaust systems to maintain negative pressure differential within the tanks and vessels
all process vessels within work areas are fully enclosed
control rooms with a fresh air supply under positive pressure
general fresh air supply and exhaust to provide sufficient air exchanges for the various process areas
upset ventilation when additional ventilation capacity is required
independent ventilation systems for restricted access enclosure areas
ventilation performance monitoring criteria (i.e. operational specifications are established for the various operating systems)
Mill ventilation is a single pass system and therefore has no chance of contaminated air recirculation. The ventilation system is designed to replace exhausted air and maintain pressure gradients between the process areas (e.g., cells around leach tanks) and the non-process areas (e.g., control rooms).
The maintenance of pressurization is important to control airborne radioactive contaminants ensuring air flow patterns travel from low potential contaminant areas to high potential contaminant areas. The ventilation units are centrally located above the corridor and main control room areas with a common elevated fresh air intake of both radioactive and non-radioactive airborne contaminants. The exhaust fans are located throughout the process areas and discharge through the roof or walls of each areas.
Pressure differential is accomplished by maintaining a positive air pressure in the corridors with respect to the cells around the process tanks. Tanks are exhausted to the outdoors to minimize airborne radiation leakage from the tank into the cell by maintaining the tank at a lower air pressure than that of the cell. Through onsite inspections, CNSC staff verified that ventilation systems operation and performance is controlled through preventive maintenance, monitoring systems and a field monitoring program. In keeping with the ALARA principle, ventilation systems are routinely assessed to identify areas of improvement and optimization.
After a temporary shutdown of the MLO from 2010 to 2014, the mill restarted in September 2014. Following the restart, commissioning and production ramp up of the MLO, CNSC staff requested AREVA to review and assess the mill ventilation system and establish operational specifications. AREVA summarized the results and submitted a ventilation monitoring specification report for the MLO [12]. CNSC staff reviewed the report and requested additional information (clarification about design objectives for hydrogen, sulphur dioxide and ammonia in view of the process ventilation system and rationale to change design objective for radon progeny). All comments were addressed satisfactorily by AREVA and met CNSC staff expectations. CNSC staff accepted the ventilation report and concluded that it meets the requirements of CNSC regulatory guide G-221, A Guide to Ventilation Requirements for Uranium Mines and Mills.
3.5.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance During the current licence period, CNSC staff confirmed that AREVA demonstrated the ability to follow the design control process when a modification or addition to facilities, processes, or equipment was required. The design control process is also used for any new development (e.g., design not related to existing facilities). Other examples of upgrades or replacements to the physical design made during the licence term were reviewed and found acceptable by CNSC staff.
Inspections were conducted in March and May 2016 to ensure implementation and verify physical design SCA compliance verification criteria. All non-compliances of low safety significance and recommendations have been adequately addressed and closed. AREVA’s MLO continues to implement and follow the design control process as per CNSC regulatory requirements.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of MLO’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements During the next licensing term, AREVA has requested to modify the JEB TMF to increase tailings storage capacity. CNSC staff will ensure that the project is completed safely and the environment is protected. AREVA is required to verify hydrodynamic containment of the JEB TMF and report to the CNSC through its annual report.
Improvements to operation, facility equipment and processes are identified on an ongoing basis and implemented as part of continuous improvement.
3.5.4 Conclusion CNSC staff confirmed that AREVA made significant changes and improvements to the facility during the licence period. The changes were carried out in accordance with conditions of the licence and AREVA’s design and change management processes. AREVA completed work on the projects as planned with no major deficiencies or events. CNSC staff assessed AREVA’s documentation and analyses under this SCA and found it to be acceptable. CNSC staff conclude that AREVA’s overall performance at the MLO for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities in this SCA.
One condition in the proposed licence is associated with the physical design SCA. Licence condition 5.1 requires AREVA to implement and maintain a design program. A compliance verification criterion for this licence condition is included in the draft LCH.
3.6 Fitness for Service The fitness for service SCA covers activities that impact the physical condition of structures, systems and components to ensure that they remain effective over time. This area includes programs that verify all equipment is available to perform its intended design function when called upon to do so.
3.6.1 Trends The following table provides the annual compliance ratings for the fitness for service SCA for the current licence period 2009 to 2016:
FITNESS FOR SERVICE SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
CNSC staff are satisfied with the overall equipment fitness for service and performance. AREVA’s maintenance program met applicable CNSC requirements and performance objectives for the McClean Lake Operation.
3.6.2 Discussion The fitness for service SCA at the MLO covers activities that impact the physical condition of systems, components and structures to ensure they remain effective over time. The licensee is required to manage maintenance activities to comply with regulatory requirements and accepted industry practice to minimize potential impacts to workers, the public and the environment. In addition, maintenance activities must provide assurance to achieve desired results, provide effective management of inventory of maintenance materials, and provide systematic management of maintenance change control. As per regulatory requirements, the fitness for service program is required to provide documentation and formalized pre-established maintenance activities.
AREVA’s maintenance group organizes and stores equipment and facilities information on a computerized maintenance management system to coordinate the routine, predictive and preventative maintenance (PM) activities at the MLO. This computerized maintenance management system keeps track of the preventive maintenance program for all mill equipment and logs the equipment operating history. A facility change control procedure, reviewed and accepted by CNSC staff, is in place to control and record changes to the facilities.
CNSC staff verified through inspections and desktop reviews that AREVA maintains the MLO according to regulatory requirements and that AREVA uses operational experience to ensure that the procedures, processes, structures, containment systems and components remain effective over time. AREVA has identified the safety-significant structures, systems and components at the MLO and implemented a PM program to ensure that these remain effective. The requirements of this program are documented in the IQMS and related procedures.
CNSC staff’s review of the maintenance management system at the MLO during regular inspections confirms that PM activities are scheduled, completed and recorded. CNSC staff routinely inspect maintenance records associated with the MLO PM program and found them acceptable. Random sampling of equipment, maintenance and monitoring records were also checked during onsite inspections. These compliance verification activities confirmed that the maintenance program is well documented and implemented. CNSC staff conducted compliance verification activities in January 2016; all elements related to the fitness for service SCA were in compliance to the regulatory requirements.
3.6.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance Based on the review of AREVA’s annual compliance reports and CNSC staff’s compliance inspections, CNSC staff rate AREVA’s performance for the fitness for service SCA at the MLO as satisfactory for the current licence period.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements There are no major changes anticipated in the near future for this SCA.
3.6.4 Conclusion CNSC staff have assessed AREVA’s MLO documentation under the fitness for service SCA and found them to be acceptable. AREVA continues to maintain the facility to ensure that structures, systems and components remain effective over time.
One condition in the proposed licence is associated with the fitness for service SCA. Licence condition 6.1 requires AREVA to implement and maintain a fitness for service program. A compliance verification criterion for this licence condition is included in the draft LCH.
3.7 Radiation Protection The radiation protection SCA covers the implementation of a radiation protection (RP) program in accordance with the Radiation Protection Regulations. The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained ALARA.
3.7.1 Trends The following table provides the annual compliance ratings for the radiation protection SCA for the current licence period 2009 to 2016:
RADIATION PROTECTION SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has implemented a radiation protection program that meets regulatory requirements and protects the health and safety of workers. During the current licence period, no worker or member of the public received a radiation dose in excess of CNSC regulatory limits.
The McClean Lake Operation re-started processing undiluted high grade ore from Cameco’s Cigar Lake mine while continuing to keep radiation doses well below regulatory limits.
Effective dose A worker means any person who performs work that is referred to in a CNSC licence. This consists of both AREVA employees and contractors hired by AREVA to perform work at the MLO.
The regulatory effective dose limit for a nuclear energy worker (NEW) is 50 mSv/year and 100 mSv over a five-year dosimetry period. AREVA’s MLO has radiation protection design features enabling it to accept high grade ore and process it without diluting it to a lower uranium concentration, with averages of 20 percent uranium to as high as 30 percent uranium. As seen in the following graph, annual doses to workers at the MLO remained well below the 50 mSv/year regulatory limit even with processing of high grade ore slurry at higher production levels in 2015 to 2016. Figure 7 displays the maximum and average individual effective doses to NEWs from 2009 through to 2016.
Figure 7: McClean Lake – maximum and average individual effective doses to NEWs, 2009-16
*2016 values are based on January to June 2016 data.
3.7.2 Discussion The Radiation Protection Regulations require licensees to establish a RP program to keep exposures ALARA through the implementation of a number of controls, including: management control over work practices, personnel qualification and training, control of occupational and public exposures to radiation, and planning for unusual situations. The Radiation Protection Regulations also prescribe dose limits for workers and members of the public. As required by the CNSC, AREVA has a RP program and radiation code of practice (RCOP) in place at the MLO. The RP program includes continuous and routine radiological monitoring, dosimetry, contamination control and long-lived radioactive dust exposure control.
Application of ALARA The RP program describes how the MLO manages radiation protection issues, meets applicable regulatory requirements and keeps radiation exposures ALARA, social and economic factors considered (ALARA principle). Commitment to the ALARA principle has been demonstrated through the RP program implemented at the MLO, which was developed in line with CNSC regulatory guide G-129, Keeping Radiation Exposures and Doses “As Low As Reasonably Achievable (ALARA)”.
AREVA’s application of ALARA within its RP program at the MLO includes management commitment and oversight, personnel qualification and training, and facilitation of ongoing dialogue and a culture of continuous improvement. Annually, AREVA establishes ALARA targets for the MLO focused on worker dose reduction initiatives, in addition to key performance indicators for parameters such as RP training, objectives, personnel dosimetry results, and workplace monitoring data.
CNSC staff are satisfied with AREVA’s measures in applying the ALARA principle to keep the doses to workers ALARA at its MLO.
Worker dose control The source of radiological exposure at the MLO is the milling of high grade uranium ore received from Cameco’s Cigar Lake mine. The three primary dose contributors are gamma radiation, radon progeny and long-lived radioactive dust. Long-lived radioactive dust is controlled through ventilation, dust control methods and good housekeeping. Gamma radiation is controlled through time, distance and shielding. Radon progeny’s main control mechanism is through ventilation. AREVA uses a combination of design features, staff training and qualification, and dose management tools such as work planning, administrative levels, and management oversight to ensure radiation doses to workers are controlled and kept ALARA.
AREVA’s RP program at the MLO establishes criteria to provide assurance that all persons that satisfy the definition of a NEW (as defined by the NSCA) are informed as such. As required by the Radiation Protection Regulations, all NEWs are notified in writing of their status, the risks associated with radiation that they may be exposed to in the course of their work and of the applicable effective and equivalent dose limits. Female NEWs are also notified in writing of their rights and obligations related to pregnancy.
AREVA’s dosimetry program at the MLO includes techniques for both external and internal dose assignment. The total effective dose assignment for workers are the sum of whole body dose as measured by optically stimulated luminescent dosimeters (OSLD) and personal alpha dosimeters (PAD).
During the current licensing period, worker doses at the MLO were split among the three primary dose contributors with the following percentages from 2009 to 2016:
gamma radiation (46%)
radon progeny (30%)
long-lived radioactive dust (24%)
The dose contributions following the increased ore grade and production levels are consistent with these historical values. In the review period, the working groups with the highest effective dose were the mill maintenance and mill operations. No MLO worker received an effective or equivalent dose that exceeded the corresponding regulatory dose limits pursuant to the Radiation Protection Regulations.
Radiation protection program performance
CNSC compliance activities CNSC staff assessed AREVA’s RP program performance at the MLO over the current licence period through various compliance verification activities, including desktop reviews of monthly, quarterly and annual compliance reports. CNSC staff have observed and verified RP practices during compliance inspections; a focused RP inspection was conducted in December 2014. In particular, the following compliance verification criteria from the RP safety and control areas were evaluated:
Radiological conditions are monitored and sources of external and internal radiation exposures are controlled. Access and work in radiological areas are controlled so that collective and individual radiation exposures are kept ALARA.
RP instrumentation and equipment are calibrated, maintained, and used so that radiation levels are accurately determined.
The personnel dosimetry program ensures that external and internal radiation doses to individuals are accurately determined and recorded.
Appropriate contamination control measures are implemented to control and minimize the contamination of areas, equipment and personnel.
After evaluating the facts and evidence, CNSC staff identified areas of strengths and also noted minor low risk deficiencies (ore sample management in the metallurgical lab does not conform to the work instruction; and Scalars required for counting long-lived radioactive dust (LLRD) and swipe samples are being used with lower counting efficiencies) that resulted in two non-compliances of low safety significance. CNSC staff verified corrective actions taken by AREVA and these non-compliances were closed.
In support of the licence renewal, AREVA’s MLO submitted RP program documents and associated procedures to meet applicable regulatory requirements. CNSC staff performed a desktop review of the documents and identified potential opportunities for improvement based on operating experience and lessons learned. AREVA has committed to address applicable comments and CNSC staff will continue to monitor the progress at the MLO. Overall, AREVA’s RP program documents suite are acceptable and operating experience has demonstrated that the program is adequate in protecting workers.
As a result of onsite inspections and desktop review verification activities, CNSC staff found that AREVA’s RP program documentation at the MLO complies with CNSC regulatory requirements.
Radiological action levels The Uranium Mines and Mills Regulations and the Radiation Protection Regulations require that a licensee report any radiation action level exceedances as defined in the Radiation Code of Practice (RCOP). The action levels for effective dose are 1 mSv per week and 5 mSv per quarter of a year.
There were two RCOP action level exceedances; both exceedances occurred in 2015 and were included in the 2015 regulatory oversight report presented to the Commission in December 2016. These two action level events were exceedances of the weekly action level with no exceedances of the quarterly action level.
The first action level event took place in May 2015 and was attributed to the work in the calciner enclosure. Yellowcake passes through a series of six calcining hearths and into a lump disintegrator before being packaged. A broken seal allowed product to enter a bearing in the lump disintegrator which caused it to fail. Material continued to feed the lump disintegrator while it was down, causing it to plug and forcing a build-up of product in the calciner hearths. Mill operator worked manually to clear out excess material wearing respirators to restore normal operating conditions. The dose received by the operator was predominately due to the calcined yellowcake exposure while under respiratory protection and wearing calciner PPE. After applying the respirator protection factor for the use of a Powered Air Purifying Respirator, the employee was assigned a long-lived radioactive dust dose of 1.6 mSv which exceeded RCOP weekly action level of 1 mSv. In response to the event, AREVA identified the following corrective actions:
installed an interlock system in the calciner to prevent product feed when the lump disintegrator is inoperable
installed an industrial vacuum system in the calciner enclosure to transfer material in a controlled manner
the work instruction outlining calciner hearth checks has been updated to ensure a more regular inspection frequency for all six hearths
The second action level event took place in June 2015 and was attributed to work in the slurry receiving circuit. The employee’s personal alpha dosimeter recorded a radon progeny exposure of 0.89 mSv and a long-lived radioactive dust exposure of 1.93 mSv. The corrective actions identified by AREVA included:
work practice modifications include use of the temporary hose to direct material to the sump and vacating the enclosure area during the draining process
applicable work instructions for the slurry receiving area were reviewed and updated to provide clear instructions
operations workers were provided additional coaching on using common ALARA work practices and obtaining radiation work permits to ensure appropriate monitoring and dose assignments
CNSC staff are satisfied with the actions taken by the MLO to address these action level exceedances and to prevent similar future occurrence.
CNSC staff are satisfied with the performance of AREVA’s RP program and its implementation at the MLO.
Radiological hazard control Radiation and contamination control programs have been established at the MLO to control and minimize radiological hazards and the spread of radioactive contamination. The MLO has been delineated into four zones; methods of control include the use of radiation zone controls.
Radiological monitoring programs confirm the effectiveness of contamination control and include a combination of direct and indirect contamination monitoring of eating areas, footwear, work clothing and personal protective equipment (PPE). Routine airborne monitoring programs have been established for long-lived radioactive dust and radon progeny. When sample results exceed administrative levels, protective actions are taken as specified in the RCOP. Air contamination monitoring is augmented by providing containment systems such as dust collectors, scrubbers, fume hoods and well ventilated operating areas. The MLO uses continuous alpha radiation visual detectors with warning lights to monitor and warn workers of elevated radon progeny.
AREVA has established contamination limits for each zone at the MLO. During a May 2016 compliance inspection, CNSC staff identified that the boundaries between zones were not clearly delineated by appropriate signage. As a result of this inspection finding, AREVA responded in a timely manner and areas are now clearly marked.
AREVA possesses sealed sources, unsealed sources and radiation devices at the MLO that are regulated under the Nuclear Substances and Radiation Devices Regulations. These radiation sources range in type from fixed nuclear gauges to radiation instrumentation calibration sources. The controls associated with these radiation sources are supported by the RP program including training, leak testing, radiation warning signs and access control to areas where such sources are used or stored.
In September 2016, AREVA submitted the Results of the Radiation Performance Confirmation Plan (RPCP) as required by CNSC [13]. The RPCP was developed to validate the radiological design while processing high grade ore. The MLO has incorporated specific radiation protection features into its design in order to process undiluted, high grade uranium ore. During the initial commissioning of the McClean Lake mill in 1999, radiation measurements and analyses were conducted to assess the performance of the radiation protection design features according to a radiation assessment plan. CNSC staff reviewed the RPCP report and concluded that although the MLO is processing high grade uranium ore slurry at production rates significantly higher than in the past, worker exposures continue to be maintained well below regulatory limits and ALARA due to the incorporation of radiation protection design features, ventilation system, and effective execution of the RP program. Prior to and during the restart of the MLO and ramp-up of production, several continuous improvement initiatives have been implemented. These have proven to be effective in managing doses ALARA and ensuring the RP program remains effective.
The RPCP report documents that in 2015 the average worker dose was 0.89 mSv and the maximum worker dose was 5.3 mSv. The report demonstrated that average doses to all work groups were below predicted values and in most cases the average doses were significantly below predicted values. The RPCP report provides evidence with a high degree of certainty that the routine worker exposures will continue to remain below the AREVA dose constraint of 14 mSv/year (CNSC regulatory limit is 50 mSv/year). The report demonstrates that in most instances the design radiological objectives of 5 µSv/h for gamma, 0.12 Bq/m3 for uranium ore dust and 0.03 working levels for radon progeny have been met.
CNSC staff are satisfied that radiological hazards have been adequately controlled at the MLO.
3.7.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance Based on the review of AREVA’s monthly, quarterly and annual compliance reports, and CNSC staff’s routine compliance verification activities, CNSC staff rate AREVA’s performance for the radiation protection SCA as satisfactory for the current licence period.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation at the MLO pertaining to this SCA.
Proposed improvements No major changes are anticipated in the near future for the radiation protection SCA.
3.7.4 Conclusion CNSC staff assessed AREVA’s documentation and analyses at the MLO under the RP SCA and found them to be acceptable. CNSC staff are satisfied with AREVA’s efforts in applying the ALARA principle to keep the doses to persons ALARA over the current licence period. Therefore, CNSC staff concluded that the overall performance for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities at the MLO in this SCA.
One condition in the proposed licence is associated with the radiation protection SCA. Licence condition 7.1 requires licensee to implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within seven days. Compliance verification criteria for this licence condition are provided in the draft LCH.
3.8 Conventional Health and Safety The conventional health and safety SCA covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment.
3.8.1 Trends The following table provides the annual compliance ratings for the conventional health and safety SCA for the current licence period 2009 to 2016:
CONVENTIONAL HEALTH AND SAFETY SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has an acceptable health and safety program to identify and control risks. CNSC staff monitor implementation of this program to ensure protection of workers. AREVA has been proactive in identifying and managing risks to improve health and safety performance.
AREVA’s conventional health and safety program and its implementation continues to improve, be effective and meet applicable regulatory requirements.
3.8.2 Discussion CNSC expects licensees of uranium mines and mills to develop, implement and maintain effective safety programs to promote a safe and healthy workplace for employees and to minimize the incidence of occupational injuries and illnesses. AREVA is expected to identify potential safety hazards, assess the associated risks, and implement the necessary materials, equipment, programs and procedures to effectively manage, control and minimize these risks at the MLO. The occupational health and safety program at the MLO is made up of several components that are designed for employees, visitors and contractors. This health and safety program has been developed to meet legislated requirements, internal standards and the Occupational Health and Safety Assessment Series (OHSAS)18001:2007. The program includes hazard identification and risk assessments, incorporating proactive minimization of risk to workers and the public through continual improvement in health and safety performance. Work plans consider the identification of workplace hazards, risks, and mitigation measures.
Performance A key performance measure for this SCA is the number of lost time injuries (LTIs) that occur per year. An LTI is an injury that takes place at work, resulting in the worker being unable to return to work and carry out their duties for a period of time.
The table below shows a total of nine LTIs that occurred from 2009 to 2016 at the MLO. CNSC staff reviewed the investigation reports and verified that corrective actions have been implemented and remain effective. Since 2010, all LTIs are discussed and reported to the Commission as part of the CNSC staff annual regulatory oversight report.
Table 6: McClean Lake - total number of FTE workers, LTI, severity rate and frequency rate, 2009-16
Year 2009 2010 2011 2012 2013 2014 2015 2016*
Total number of FTE workers1 309 225 163 249 348 739 793 297
Number of LTIs2 0 1 0 1 0 3 3 1
Severity rate3 4.1 13.3 0.0 1.2 0.0 4.3 27.7 12.3
Frequency rate4 0.0 0.4 0.0 0.4 0.0 0.4 0.4 0.3
1 Total number of workers (employees and contractors) expressed as full-time equivalents (FTE). FTE = total person-hours / 2,000 hours worked per employee per year. 2 Lost-time injury - an injury that takes place at work and results in the worker being unable to return to work
for a period of time. 3 Severity rate - the accident severity rate measures the total number of days lost to injury for every 200,000
person-hours worked at the site. Severity = [(# of days lost in last 12 months)/# of hours worked in last 12 months)] x 200,000.
4 Frequency rate - the accident frequency rate measuring the number of LTIs for every 200,000 person-hours worked at the site. Frequency = [(# of injuries in last 12 months)/ # of hours worked in last 12 months)] x 200,000.
*2016 values are based on January to June 2016 data.
During restart and commissioning of the MLO, a safety issue was encountered in 2015 that was not identified prior to restart; the impact of sulphates in the mill circuits and subsequent release of sulphur dioxide gas. Upon recognition of this challenge, process improvements were undertaken and emissions of sulphur dioxide from the calciner stack have been brought under control through operational parameters adjustments. Control of sulphur dioxide has been achieved through maintaining key process variables. As required by CNSC, a sulphur dioxide mitigation plan was submitted by AREVA [14], which has been reviewed and accepted by CNSC staff. CNSC staff have verified that the corrective measures are effective in controlling sulphur dioxide emissions after reviewing quarterly environment monitoring reports and through site inspections. CNSC staff will continue to monitor the implementation of the plan.
Inspections regarding conventional health and safety were also carried out by the Ministry of Labour Relations and Workplace Safety (LRWS) inspectors during the current licensing period. Inspection reports are shared with CNSC and regular oversight is provided by CNSC staff as needed. Safety related findings and incidents were properly investigated and corrected by AREVA in a timely manner and the resulting reports were acceptable to both the CNSC and LRWS.
Practices In addition to the NSCA and its associated regulations, McClean Lake’s activities and operations must comply with the Canada Labour Code, Part II: Occupational Health and Safety, and other applicable federal and provincial health and safety related acts and regulations. AREVA has a joint occupational health and safety committee in accordance with the Saskatchewan Occupational Health and Safety Act. To assure continued strong safety performance and continual improvement, AREVA’s conventional health and safety program at the MLO includes the following provisions:
scheduled safety orientation and training
five-point daily safety cards
work permits for specialized work
planned inspection program
occupational health committees
health centre operation
incident investigations and corrective action performance tracking
CNSC staff have observed and verified safety practices during compliance inspections. The conventional health and safety SCA is included as a component in all CNSC inspections. AREVA reported safety events in a timely manner for the MLO and in compliance with the regulations.
AREVA uses leading key performance indicators (KPIs) to monitor preventative efforts. Health and safety objectives are developed based upon the review of the hazard register, reviews of investigation and inspection reports and reviews of five-point safety cards.
Contractor safety risk continues to be effectively managed. Contractors are expected to follow AREVA’s safety program or have an equivalent program. Contractors are expected to be knowledgeable, trained, and experienced in the work they perform. They are required to comply with program requirements and regulations, manage the hazards and controls associated with its work, and provide a health and safety program for its workers.
AREVA performs safe work planning for routine and non-routine work at the MLO through the identification of workplace hazards, its assessment, and the development of controls to mitigate risks. An updated hazard register is maintained at the MLO.
Both general safety and high hazard specific procedures have been developed to assist employees with planning work and mitigate risk. Some specific high hazard work procedures include confined space entry, ground disturbance, hot work, lock-out, working in hot environments and respiratory protection.
New employees are provided with basic safety orientation to ensure they are familiar with site and department specific safety requirements. Ongoing training is provided to ensure all employees are competent. Specific safety duties and expectations are outlined for managers, supervisors, workers, the safety group, and the occupational health and safety committee.
AREVA is meeting expectations and CNSC staff are satisfied with its performance at the MLO in this area.
Awareness
AREVA established conventional health and safety policies and programs for the MLO to ensure the protection of workers from physical, chemical and radiation hazards that may arise in the course of their work at the facility. AREVA has developed and continues to deliver safety-related training courses to employees and contractors. These courses encompass the safety areas of general health and safety knowledge, radiation protection, fire protection, regulatory requirements and job/task-specific safety training related to hot work permit, lock out/tag-out, and the use of a Workplace Hazardous Materials Information System (WHMIS) which provides information on the safe use of hazardous materials.
Weekly safety meetings are conducted by each MLO department to discuss various safety topics; this may include safety target updates, review of recent incidents, safety concerns, and safety procedures for specific tasks. Employees are expected to report all incidents to their supervisors. Incidents are investigated by AREVA’s safety group, with the assistance of supervisors and those involved with the incident. The purpose is to determine the root causes and to implement preventive measures as required. The MLO industrial hygienist also conducts monitoring to evaluate potential chemical, physical, biological and ergonomic hazards.
At a minimum, and as per regulatory requirements, program elements are reviewed every two years. The quality and compliance group also conduct several audits of the program elements annually.
3.8.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance Through the review of the occupational health and safety documentation, site conditions and practices during the licence period, CNSC staff conclude that AREVA’s occupational health and safety program at the MLO meets CNSC regulatory requirements.
For the current licence period, CNSC staff rated AREVA’s overall performance for the conventional health and safety SCA as satisfactory.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements CNSC staff, as part of on-going compliance efforts for all programs, will review any proposed modifications to AREVA’s licensing documentation as it is adapted to conform to future revisions of CSA Group standards and CNSC’s regulatory framework. There are no other proposed improvements for this SCA.
3.8.4 Conclusion Based on the above assessment, CNSC staff conclude that AREVA has effectively managed workplace safety hazards at the MLO. Compliance verification activities will continue to be conducted at the facility to confirm that AREVA’s MLO continues to view conventional health and safety as an important consideration.
In conclusion, AREVA’s conventional health and safety program and implementation continue to be effective, meet applicable regulatory requirements, and are rated as satisfactory.
One condition in the proposed licence is associated with the conventional health and safety SCA. Licence condition 8.1 requires AREVA to implement and maintain a conventional health and safety program at the MLO. Compliance verification criteria for this licence condition are provided in the draft LCH.
3.9 Environmental Protection The environmental protection SCA covers programs that identify, control and monitor all releases of nuclear and hazardous substances and effects on the environment from facilities or as the result of licensed activities.
3.9.1 Trends The following table provides the annual compliance ratings for the environmental protection SCA for the current licence period 2009 to 2016:
ENVIRONMENTAL PROTECTION SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA has implemented, maintained and continuously improved its environmental protection program at the McClean Lake Operation that protects the environment and the public in accordance with evolving CNSC regulatory requirements.
During the current licence period, releases to the environment were well below the release limits specified in the CNSC licence. CNSC staff monitor AREVA’s implementation of the environmental protection program through compliance verification activities.
AREVA updated its environmental risk assessment in 2016 and the predicted impacts for the current anticipated McClean Lake Operation milling and decommissioning plans are consistent with those predicted in previously approved environmental assessments.
A risk of elevated selenium in effluent resulting from processing Cigar Lake high grade ore was identified. AREVA has taken a proactive approach and implemented a selenium management plan which has been reviewed by CNSC staff and found acceptable. As requested by CNSC, AREVA has confirmed to develop and implement a formal selenium adaptive management plan to control JEB WTP selenium effluent concentration. This plan is further discussed in detail later in the CMD under section 4.5 Improvement Plan and Significant Future Activities (subsection 4.5.3 – Selenium Adaptive Management Plan).
Under the Uranium Mines and Mills Regulations, AREVA’s MLO is required to develop and implement environmental protection policies, programs and associated procedures that comply with all applicable federal and provincial regulatory requirements, in order to control the release of radioactive and hazardous substances into the environment, and to protect the environment and human health.
During the current licence period, CNSC staff verified AREVA’s performance with respect to environmental protection through inspections and desktop reviews. A focused environmental protection inspection was conducted in July 2016; all findings were minor in nature and have been adequately addressed (cleaning and maintaining of Magnehelie gauges on the calciner scrubber; procedures and work instructions for surface water and air monitoring are in alignment with current practice). The results of this inspection allowed CNSC staff to conclude that AREVA’s implementation of the environmental protection program at the MLO meets CNSC regulatory requirements.
Effluent control (releases)
AREVA controls and monitors liquid release to the environment at the MLO under implementation of its environmental and radiation protection programs.
Treated effluent released to the environment must meet the effluent discharge limits stipulated in appendix B of the current licence, which are the Metal Mining Effluent Regulations (MMER). The effluent discharge is also subject to regular toxicity testing as required by the MMER and to the action levels specified within the MLO’s environmental code of practice. Action levels provide early indication of a potential loss of control of part of the environmental protection program. Action levels are used to ensure that the licence release limits will not be exceeded.
At the MLO, two effluent streams are processed in separate treatment facilities before being released to the environment:
The mill effluent is processed at the JEB WTP with a treatment system of chemical precipitation and liquid/solid separation and treated water released to the Sink/Vulture Treated Effluent Management System (S/V TEMS).
Effluent from the mined-out open pits to maintain hydraulic containment of groundwater is treated in the Sue WTP using a chemical precipitation and settling pond clarification process before being released to the S/V TEMS.
The blended treated effluent is released in a controlled manner and monitoring has verified that this effluent poses no environmental concern.
The S/V TEMS controls the release of effluent from the MLO to the environment while allowing water treatment effluent to discharge as required. The S/V TEMS has been operated according to the objectives in the ECOP so that the impact of the discharge to Collins Creek is minimized and the water quality in Collins Creek meets Saskatchewan Surface Water Quality Objectives (SSWQO) for the protection of aquatic life.
The final treated mill effluent released to the environment at the final point of control (JEB Water Treatment Plant) for the facility must meet the effluent discharge limits. During the licensing period, concentrations of contaminants in the effluents remained very low. The effluent contaminant concentrations were maintained below the effluent discharge limits, the effluent discharge passed all toxicity tests and there were no exceedances of the effluent action levels contained in the environmental protection code of practice (ECOP).
Molybdenum, uranium and selenium in effluent AREVA temporarily ceased milling operations at the MLO in July 2010 with a restart in September 2014; however, effluent treatment of the JEB TMF pond water continued while the mill was not in operation. The concentrations of molybdenum, selenium and uranium in treated effluent remained low while shut down. The concentrations increased with the restart and commissioning of operations, as expected, but, other than selenium, have since decreased as the operation was optimized (see figures 8, 9 and 10).
Molybdenum Figure 8: McClean Lake – concentrations of molybdenum from JEB WTP, 2009-16**
* Key Lake action level for molybdenum is the most stringent of the five operating mines and mills and is shown for reference only. ** 2016 values are based on January to June 2016 data.
Selenium Figure 10: McClean Lake – concentrations of selenium from JEB WTP, 2009-16**
* Province of Saskatchewan’s selenium discharge limit is shown for reference only. ** 2016 values are based on January to June 2016 data.
During restart, commissioning and subsequent milling of Cigar Lake ore slurry, it has been noted that the selenium loading to tailings preparation circuit and the JEB WTP have been observed to increase, though effluent concentrations remain within historical ranges and below administrative levels described in the MLO’s ECOP [15]. Process improvements have been implemented in various mill circuits; these changes resulted in improved control of selenium oxidation and speciation. As required by CNSC, AREVA submitted a selenium management plan [16]. CNSC staff reviewed the plan to verify that adequate measures have been taken by the MLO to manage and control selenium effluent releases from the JEB WTP and to limit concentrations of selenium in the aquatic receiving environment. Based on CNSC staff review comments, AREVA established a single interim administrative level and action level in the ECOP. This interim administrative and action level shall be reviewed annually to determine whether it remains adequate, or whether it should be revised to reflect actual performance while taking into consideration predicted performance for the following year. In addition to the adoption of the interim selenium administrative and action levels, a selenium risk management field studies plan has also been established to garner additional data and characterize effects in the receiving environment.
CNSC staff will continue to monitor the progress related to the selenium management plan closely.
Annual monthly means concentrations of treated effluent The annual monthly means concentrations and associated licence limits for the treated effluent are provided in table 7. Releases have been lower than the licence limits.
Table 7: McClean Lake - annual monthly mean concentrations of treated effluent released to the environment from JEB water treatment plant (JEB WTP), 2009-16
ANNUAL MONTHLY MEANS CONCENTRATIONS OF TREATED EFFLUENT RELEASED TO THE ENVIRONMENT FROM JEB WTP
* Provincial limits. ** No provincial or federal limit is available. Level of molybdenum in treated effluent meets the federal water quality guidelines. *** 2016 values are based on January to June 2016 data. **** pH taken from daily discharge samples – not measured in monthly composite samples. † Selenium value taken from monthly composite samples for 2009. Selenium was not measured in individual discharges until part way through that year.
Environmental management system AREVA has implemented and maintained an environmental management system (EMS) to describe the activities associated with the protection of the environment at the MLO. The EMS is described in its IQMS and includes programs for effluent and environmental monitoring. The core activity of the environmental monitoring program (EMP) is to acquire the data essential for assessing impacts of the operation and ensuring that possible impacts are detected as early as possible and mitigated. The EMP provides details about monitoring locations, frequencies and environmental parameters to be measured. Key components of the EMP are air quality, surface water hydrology, water quality, terrestrial monitoring, aquatic ecology, and groundwater monitoring. AREVA’s environmental protection program at the MLO also meets the requirements of the ISO14001:2004 standard.
AREVA conducts internal audits to determine whether the EMS has been properly implemented and is effective. Any deficiencies and findings that are identified from the internal audit are documented and a plan devised to address any non-conformance items. AREVA verifies compliance of its EMS through an annual management review where minutes and follow-up actions to outstanding issues from the internal audits are documented.
CNSC staff verifiy the MLO’s EMS through desktop reviews of quarterly environmental reports, annual compliance reports, and onsite inspections. Proactive steps have been taken by AREVA to review and conduct a gap analysis to ensure that the EMP is in alignment with CSA Group standard N228.4, Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills, and N288.5, Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills. AREVA recently submitted an Environmental Monitoring Program Design Document, Version 2 and Environmental Monitoring Program, Version 9 to reflect alignment with CSA Group standards. These documents are currently under CNSC staff review. Once accepted, both submissions will form part of the licensing basis documents and will be added and/or replaced respectively as a new version in appendix C of the LCH.
Assessment and monitoring Environmental effects monitoring at Saskatchewan uranium mines and mills is necessary to meet the requirements of the Metal Mining Effluent Regulations (MMER) plus any additional requirements from CNSC and SMOE. CNSC staff review the environmental effects monitoring information along with any other routine or special investigations to ensure any impacts to the receiving environment and biota are identified.
Environmental monitoring programs serve to demonstrate that the site emissions, wastes, tailings and effluent discharge of nuclear and hazardous substances are properly controlled at the MLO.
AREVA’s terrestrial monitoring program at the MLO determines if there is influence on the environment from aerial deposition as soil and terrestrial vegetation may be affected by atmospheric deposition of particulate and adsorbed metals and radionuclides associated with onsite activities. This program includes measurements of metals and radionuclides in soil and vegetation.
In May 2016, AREVA submitted the McClean Lake Operation Environmental Performance Technical Information Document (TID) Volume 1 - Environmental Monitoring [17]. This report provided an update on the current environmental monitoring data from the previously submitted 2012 environmental performance TID. The document provided a comprehensive understanding of the environment surrounding the MLO and the operation’s current environmental performance. It presents updated data on the physical environment, climate, air quality, aquatic environment, and the terrestrial environment. The environmental performance TID compares the current state of the environment to predictions made in previous environmental assessments and environmental risk assessments. The MLO transitioned to a period of care and maintenance from July 2010 to September 2014, therefore, only 15 months of monitoring data (September 2014 to December 2015) reflect the return to active milling operations.
CNSC staff reviewed the environmental performance TID to confirm whether the risks to ecological and human receptors accepted by the CNSC in previous environmental impact statements (EIS) and environmental risk assessments (ERA) are still valid and the public and the environment remain protected. Some minor technical review comments were provided to AREVA requesting additional information and clarifications to improve future assessments. CNSC staff concluded that the TID contained sufficient information to complete a review of the environmental performance of the MLO from 2011 to 2015 relative to predictions contained in the 2012 ERA. CNSC staff confirmed that the environment and human health in the vicinity of the MLO remains protected.
Soil monitoring Soil monitoring results from soil samples collected in 2015 are presented in the environmental performance TID showing that the soil metal parameter concentrations were below the Canadian Environmental Quality Guidelines for industrial and residential/parkland land use. Three metal parameters (arsenic, nickel and uranium) measured in soil samples at the MLO were below the CCME Soil Quality Guidelines levels. Radionuclide concentrations in soils were also low, and near or at background levels and analytical detection limits. CNSC staff concluded that the level of airborne particulate contaminants produced by the MLO is acceptable and does not pose a risk to the environment.
Vegetation monitoring Vegetation sampling results were also presented in the environmental performance TID and indicated most parameters were within the range of concentrations previously measured in lichen, Labrador tea and blueberry twig samples. Blueberry twigs are monitored to determine if soil-born contaminants (if present) are being absorbed through the roots into the growing plant parts. Lichen samples are analyzed to determine the level of airborne particulate contaminants deposited on the surface of the lichen as a means of ensuring that a significant level of contamination is not entering lichen consumers, such as caribou. The concentrations of metals and radionuclides in lichen, Labrador tea and blueberry twigs were higher than background concentrations within the site boundary in the immediate vicinity of mining activities. These higher concentrations were below levels that are toxic to plants and decreased to within background concentrations within a short distance. Therefore, no changes are predicted to terrestrial habitat, both within and outside the site boundary. The elevated concentrations of contaminants within the site boundary were modelled in an environmental risk assessment and no adverse effects were predicted for terrestrial non-human biota. Local persons do not have access to the site and therefore this pathway was not assessed in the human health risk assessment. CNSC staff concluded that the level of airborne particulate contaminants produced by the MLO is acceptable and does not pose a risk to browse (twigs and Labrador tea) and lichen consumers such as caribou.
Monitoring and assessment activities are further detailed in the EA report provided in addendum E.
Air monitoring Air quality at the MLO is monitored through direct measurement of emissions from the mill, ambient air quality near the operation, and indirectly through measurements of metal accumulations in the terrestrial environment. The four stacks at the MLO are equipped with scrubber systems to reduce the concentration of particulates in the air released to the environment. AREVA hires third party contractors to perform sampling twice per year to check emission rates and particulate mass. CNSC staff reviewed the data and note that the stack emissions results from these monitoring locations are acceptable.
Air quality monitoring at the MLO includes programs for ambient radon, total suspended particulate (TSP), sulphur dioxide and exhaust stack monitoring. Ambient sulphur dioxide and exhaust stack monitoring resumed in September 2014 with the mill restart and commissioning activities.
Environmental monitoring for radon concentrations is conducted using the passive method of track-etched cups. There are 23 monitoring stations in various locations around the site-lease boundary. Figure 11 shows the average concentrations of radon in ambient air for 2009 to 2016 were below the reference level for radon. The radon concentrations were also typical of the northern Saskatchewan regional baseline of less than 7.4 Bq/m3 to 25 Bq/m3.
Figure 11: McClean Lake - concentrations of radon in ambient air, 2009-16**
* The value of 60 Bq/m3 has been derived from ICRP-65 as referenced in the Radiation Protection Regulations. The reference level represents an incremental increase above natural dwelling radon levels that could result in a member of the public being exposed to an incremental dose of 1 mSv. * Values are calculated as geometric mean. ** 2016 values are based on January to June 2016 data.
Five high volume sampling units are strategically located at various locations around the MLO to monitor dust, particulates and associated contaminants. TSP values remained low and well below the provincial standard of 70 µg/m3 as shown in figure 12.
Figure 12: McClean Lake - concentrations of total suspended particulate (TSP), 2009–16**
* Province of Saskatchewan’s authorized concentration of contaminants monitored for ambient air quality as listed in the facilities Approval to Operate Pollutant Control Facilities is shown. The ambient air quality standards for TSP have been revised under the Saskatchewan Environmental Management and Protection Regulations and will be updated when the Approval to Operate issued by the Province of Saskatchewan is renewed. * Values are calculated as geometric mean. ** 2016 values are based on January to June 2016.
TSP samples are also analyzed for concentrations of metals and radionuclides. The mean concentrations of metal and radionuclides adsorbed to TSP are low and below reference annual air quality levels identified in table 8.
1 Reference annual air quality levels have been derived from Ontario 24-hour Ambient Air Quality Criteria (Ontario Ministry of Environment 2012).
2 Reference level has been derived from ICRP 96. * Province of Ontario and ICRP reference annual air quality levels are shown for reference only, as no
federal or Province of Saskatchewan limits are currently established. **2016 values are based on January to June 2016 data.
The sulphuric acid plant was shut down in July 2010 and restarted in December 2014. The emissions from the sulphuric acid plant stack are controlled through proper operations and through maintaining a desired sulphur conversion ratio. Sulphur dioxide is continuously monitored at the stack. In addition, a sulphur dioxide monitor is used during operations to continuously measure ambient sulphur dioxide concentrations associated with mill emissions. The monitor is located approximately 200 metres downwind of the sulphuric acid plant stack. The measured sulphur dioxide monitoring data (figure 13) shows no exceedances of the annual standard of 30 µg/m3 during the licensing period.
Figure 13: McClean Lake - concentrations of ambient sulphur dioxide, 2009-16***
* Province of Saskatchewan’s standard is shown. ** Ambient sulphur dioxide (SO2) was not monitored during the temporary shutdown of the mill. Therefore ambient SO2 concentrations were not measured for the years 2011 to 2013. On December 29, 2014, measurement of ambient SO2 concentrations began again when the acid plant restarted. *** 2016 values are based on January to June 2016 data.
Surface water monitoring As per AREVA’s surface water quality monitoring program, the MLO acquires surface water samples at 20 locations around the site at different intervals. These samples are submitted to the Saskatchewan Research Council (SRC) Analytical Laboratory and are analyzed for heavy metals, radionuclides, nutrients and general chemistry. The results are compared against the SSWQO and are reported to the CNSC on a quarterly basis. CNSC staff reviewed the surface water quality results and concluded that there is minimal risk to the environment. The results are consistent with baseline and historic results and are generally below the SSWQO. At some of the control and exposure stations, the concentrations of iron, aluminum and cadmium are naturally higher than the SSWQO.
The CNSC implemented its Independent Environmental Monitoring Program (IEMP) to verify that the public and the environment around nuclear facilities are safe. It is separate from, but complementary to, the CNSC’s ongoing compliance verification program. The IEMP involves taking samples from public areas around the facility and measuring and analyzing the amount of radiological (nuclear) and hazardous substances in those samples. In 2016, samples of radon and gamma in air, surface water, fish, medicinal/edible plants and berries were collected in publicly accessible exposure and reference locations in the vicinity of the MLO.
The water samples were analyzed for uranium, thorium-230, radium-226, polonium-210, lead-210, total suspended solids, calcium, magnesium, arsenic, selenium, molybdenum, manganese, nickel, zinc and ammonia. The fish, medicinal/edible plants and berries samples were analyzed for uranium, thorium-230, radium-226, polonium-210, lead-210, arsenic, cadmium, cobalt, copper, molybdenum, nickel, lead, selenium, and zinc. These analytes were chosen because they were contaminants that had the most regulatory and public significance. Radon gas detectors were placed at the exposure and at the reference location. These detectors were retrieved by the contractor in February 2017 and replaced with a second set of radon gas detectors. The results from these detectors are currently being analyzed by the contractor. The second set of detectors will be collected in August 2017.
Based on the results received to date, the IEMP confirms that the public and the environment around the MLO are safe. These results are consistent with results submitted by AREVA, demonstrating its environmental protection program protects the health of people and the environment.
The results will be posted on the CNSC’s IEMP webpage. Further information regarding the CNSC IEMP is summarized in the EA report provided in addendum E.
Protection of the public AREVA is required to demonstrate that the health and safety of the public are protected from exposures to hazardous and radioactive nuclear substances released from the McClean Lake facility. The effluent and environmental monitoring programs currently conducted by AREVA at the MLO are used to confirm that releases of hazardous substances do not result in environmental concentrations that may affect public health.
CNSC receives reports of discharges to the environment through the reporting requirements outlined in the MLO licence and LCH. CNSC staff’s review of discharges to the environment for the MLO indicated that no significant risks to the public or environment have occurred during this period.
Based on review of the programs at the MLO, CNSC staff have concluded that the public continues to be protected from facility effluent releases and emissions.
Environmental risk assessment AREVA submitted an ERA as per CSA Group standard N288.6-12, Environmental Risk Assessment at Class I Nuclear Facilities and Uranium Mines and Mills in September 2016 [18]. CNSC staff reviewed the ERA and determined the MLO to be in compliance with this standard.
The predicted ecological and human health risks due to releases to air and water from the MLO are within the predictions in the previous EISs and ERAs accepted by CNSC and are listed as licensing basis documents in the draft LCH, with the exception of predicted short term exposure of aquatic organisms to selenium in McClean Lake East Basin, which is located within the S/V TEMS and is considered as an exposure lake. Previous EISs and ERAs accepted by CNSC predicted negligible impacts to the aquatic biota in the McClean Lake East Basin [19].
The McClean Lake mill restarted in September 2014 to process Cigar Lake ore slurry and since that time, an increasing trend has been identified for the JEB WTP selenium effluent concentration. In response to this trend and the associated ERA predictions, AREVA has proactively pursued continual improvement and adaptive management strategies. AREVA is assessing operating data and controls for the MLO to further optimize the mill process for selenium removal and other opportunities for continual improvement. AREVA also commenced a technology evaluation to identify additional selenium control and treatment technologies that could be implemented by 2020, if required.
As required, AREVA provided a selenium management plan for the MLO, which was reviewed and accepted by CNSC staff. Further, AREVA initiated enhanced receiving environment monitoring to support possible future investigations and assessments by both AREVA and the CNSC.
AREVA’s MLO will increase surface water quality monitoring frequency and conduct supplemental studies on fish health if selenium surface water concentrations or fish flesh exceed prescribed thresholds. If the supplemental studies suggest fish population level effects in McClean Lake East Basin, CNSC staff will address the risk through regulatory controls and oversight.
Additional information is provided in the EA report provided in addendum E.
A summary of AREVA’s past performance, regulatory focus and proposed improvements at the MLO are presented in the following subsections.
Past performance
AREVA has developed, implemented and maintained an effective environmental protection program at the MLO that protects the environment and the public in accordance with CNSC regulatory requirements. During the current licencing period, all monitored releases to the environment were well below release limits specified in the CNSC licence and known provincial limits. CNSC staff monitors implementation of the environmental protection program through compliance verification activities. CNSC staff rate AREVA’s overall performance at the MLO for this SCA as satisfactory for the current licence period.
Regulatory focus
CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements
There are no other proposed improvements for this SCA. AREVA has implemented the requirements of CSA Group standard N288.4, Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills, and N288.5, Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills. CNSC staff, as part of on-going compliance activities, will review any proposed modifications to AREVA’s environmental management program documentation to ensure effective implementation with updates to CSA Group standards and CNSC’s regulatory framework.
3.9.4 Conclusion
AREVA’s MLO has implemented and maintained an environmental protection program that adequately protects the environment and the public in accordance with regulatory requirements. CNSC staff monitors AREVA’s implementation of this program through compliance verification activities which includes routine desktop reviews and onsite inspections. An inspection focused on the environmental protection SCA was conducted in July 2016 and found AREVA to be in compliance with its environmental protection program.
AREVA updated its ERA in 2016 and the predicted impacts for the current anticipated MLO milling and decommissioning plans are consistent with those predicted in previously approved environmental assessments and environmental risk assessments with the exception of predicted short term exposure of aquatic biota to selenium in the McClean Lake East Basin. AREVA has committed to assessing and if required, implementing additional controls for selenium releases.
CNSC staff will address any identified residual risks through regulatory controls and oversight. No adverse effects are expected on human health during operation and after decommissioning. Impacts to aquatic receptors from contaminant exposure are expected to be limited to the near-field environment during operation and are predicted to decline following decommissioning. Currently, selenium concentration in the effluent is within regulatory limits as shown earlier in figure 10.
In conclusion, the environmental protection program at the MLO continues to be effective in protecting the environment and minimizing adverse impacts to human health. As documented in the EA report (addendum E), CNSC staff concluded that AREVA’s MLO has and will continue to make adequate provision for the protection of the environment and the health and safety of persons.
Two conditions in the proposed licence are associated with the environmental protection SCA. Licence condition 9.1 requires licensee to implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 24 hours. Licence condition 9.2 requires that licensee, where the effluent concentration reaches or exceeds the discharge limits, immediately investigate and take corrective action to ensure that the effluent concentration is maintained below the discharge limits. Compliance verification criteria for these licence conditions are provided in the draft LCH.
3.10 Emergency Management and Fire Protection The emergency management and fire protection SCA covers emergency plans and emergency preparedness programs that exist for emergencies and for non-routine conditions.
This SCA also includes the requirement for AREVA’s MLO to have a comprehensive fire protection program to minimize the risk to the health and safety of persons and to the environment from fire, through appropriate fire protection system design, fire safety analysis, fire safe operation and fire prevention.
The following table provides the annual compliance ratings for the emergency management and fire protection SCA for the current licence period 2009 to 2016:
EMERGENCY MANAGEMENT AND FIRE PROTECTION SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has an acceptable emergency preparedness and response program that meets CNSC regulatory and performance requirements. AREVA’s fire protection program is in place to minimize both the probability of occurrence and the consequences of fire and meets CNSC regulatory requirements.
3.10.2 Discussion Emergency preparedness program For emergency situations, uranium mines and mills are required to have emergency plans in place for the protection of the health and safety of workers, the public and the environment. AREVA’s emergency response program and emergency response plan contain the necessary guidelines and responsibilities for a McClean Lake staff response should an emergency occur. The plan identifies the onsite emergency response organization members and their duties and responsibilities for responding to emergencies. The plan also specifies the required equipment to be used in responding to such emergencies, maintenance of equipment and detailed response procedures. The emergency response plan addresses both general emergency response and firefighting response procedures.
As required by CNSC and Saskatchewan’s The Mines Regulations, 2003, AREVA must train emergency response team members. AREVA employs classroom and field training, as well as drills and exercises to ensure the preparedness of licensee personnel and the emergency response team (ERT). The knowledge and performance for the ERT is tested during planned emergency exercises. Ongoing field training includes drills and exercises to ensure the preparedness of site personnel. To test specific skills, the ERT is mobilized for events such as medical emergencies and transportation of ill or injured personnel, rescue drills, fire drills with search and rescue, ventilation and fire suppression activities. As well, AREVA’s ERT trains for, and regularly competes in, emergency mine rescue and industrial fire and response competitions.
CNSC staff verified AREVA’s implementation of its emergency response program at the MLO in accordance with CNSC regulatory requirements through inspections and desktop reviews during the current licence period. In September 2015, a focused emergency preparedness inspection was conducted to verify implementation and effectiveness of AREVA’s emergency response program at the MLO. The inspection report outlined some low risk deficiencies (emergency response work instruction and check sheets were not being used in the emergency command center; personal names rather than position titles were routinely used during communications; no clear ‘end of exercise’ announcement to all players and site staff at the termination of the exercise) resulting in one non-compliance and four recommendations. AREVA provided an action plan addressing the inspection findings in a timely and satisfactory manner and have taken all appropriate corrective actions. CNSC staff have verified and are satisfied with the corrective measures taken by AREVA.
Fire protection AREVA has a fire protection program (FPP) in place at the MLO to minimize both the probability of occurrence and the consequences of fire at the facility. The program has been established to comply with the requirements of the National Building Code of Canada 2015 and the National Fire Code of Canada 2015.
AREVA maintains a fire safety plan (FSP) at the MLO that describes the facilities, systems, activities and training designed to prevent the outbreak of fire, to protect the health and safety of all persons and to minimize the loss of property in the event of a fire. The FSP is a province of Saskatchewan requirement of The Occupational Health and Safety Regulations and the National Fire Code of Canada, 2015. The province administers fire protection requirements in accordance with The Mines Regulations, 2003 which provides specific requirements applicable to mines including underground workings.
The FSP provides information on specific responsibilities, emergency instructions in the event of a fire, training provided to personnel during orientation, fire protection inspections, execution of fire drills, description of how fire hazards are controlled and descriptions of specific fire hazards at the site. The FSP is reviewed annually at a minimum.
The maintenance, tests and inspections performed on the fire protection system at the MLO are designed to meet the requirements of the National Fire Code of Canada 2015, National Building Code of Canada 2015, National Fire Protection Association, provincial regulations and OHSAS:18001 standards. AREVA utilizes a third party consultant to review proposed projects with potential impact to fire protection. The third party consultant evaluates the proposed change(s), assesses its potential fire hazards, appropriate fire protection system and features used to mitigate the fire hazards. These third party reports were submitted to - and reviewed by - CNSC staff.
The objective of the fire hazard assessments (FHA) is to demonstrate that a comprehensive assessment has been made of the potential fires and that its impacts on people, equipment, buildings and the environment are within acceptable limits. This was accomplished by demonstrating that the fire protection objective for a facility, as defined by the CNSC, can be met under foreseeable fire events. As required by the CNSC, a FHA was completed in 2015 by a third party consultant for all existing JEB and Sue site buildings at the MLO along with a corrective action plan to address recommendations arising from the FHA [22]. The FHA and corrective action plan were reviewed by CNSC staff and found to be acceptable and meeting expectations.
3.10.3 Summary
A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance
Emergency preparedness program
Based on CNSC staff’s desktop reviews and onsite inspections, CNSC staff concluded that AREVA’s emergency preparedness program continues to be satisfactory at the MLO. AREVA continues to improve its emergency preparedness and response program based on changes to regulatory requirements as well as lessons learned from exercises and drills.
Fire protection program
AREVA’s MLO has an acceptable FPP in place to minimize both the probability of occurrence and the consequences of fire. The contents of the FPP contain elements that would be expected for a mine/mill facility and comply with the requirements of the National Fire Code of Canada 2015 and the National Building Code of Canada 2015.
In conclusion, AREVA’s FPP and its implementation at the MLO continue to meet regulatory requirements.
Regulatory focus
CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
LRWS, under its agreement with Human Resources and Skills Development Canada (HRSDC) and the CNSC, also conduct regular compliance inspections including fire protection. Inspection reports are shared with the CNSC and regular oversight is provided by CNSC staff as needed.
For the proposed licence term, CNSC staff added regulatory document REGDOC-2.10.1, Nuclear Emergency Preparedness and Response to the draft LCH and asked AREVA to do a gap analysis. AREVA has committed to the implementation of the uranium mines and mills applicable sections of CNSC regulatory document REGDOC-2.10.1by December 2017. CNSC staff will continue to monitor implementation through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting on this matter.
3.10.4 Conclusion As part of the licence renewal application, revised emergency preparedness and fire protection program documents and associated procedures were submitted by AREVA to meet applicable regulatory requirements. CNSC staff performed a desktop review of the documents and identified some gaps. AREVA addressed CNSC staff comments satisfactorily and in a timely manner.
Based on desktop reviews and onsite inspections, CNSC staff concluded the overall performance for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities at the MLO in this SCA. In March 2011, CNSC staff requested that all uranium mines and mills conduct a review of its facility’s safety assessments and designs from Fukushima lessons learned. AREVA reviewed the initial lessons learned, in particular the underlying defence-in-depth concept, with a focus on external hazards such as seismic, flooding, fire and extreme weather events, including measures for prevention and mitigation of severe accidents and emergency preparedness. CNSC staff confirm that there are no outstanding action items related to Fukushima lessons learned.
Two conditions in the proposed licence are associated with the emergency management and fire protection SCA. Licence condition 10.1 requires AREVA to implement and maintain an emergency preparedness program. Licence condition 10.2 requires AREVA to implement and maintain a fire protection program. Compliance verification criteria for these licence conditions are included in the draft LCH.
3.11 Waste Management The waste management SCA covers internal waste-related programs that form part of the facility’s operations up to the point where the waste is removed from the facility to a separate waste management facility. This area also covers the planning for decommissioning.
3.11.1 Trends The following table provides the annual compliance ratings for the waste management SCA for the current licence period 2009 to 2016:
WASTE MANAGEMENT SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation programs are adequate for the management of domestic, industrial and chemically/radiologically contaminated waste. CNSC staff monitor AREVA’s implementation of this program through compliance verification activities.
AREVA’s McClean Lake Operation presently has a valid preliminary decommissioning plan in place, which was updated and accepted by CNSC staff in October 2016.
CNSC staff are satisfied with AREVA’s waste management program and its implementation.
3.11.2 Discussion Licensees of uranium mines and mills are expected to have in place a waste management program for collecting, transporting, receiving, treating, processing, storing, or disposing of the wastes that are produced as a result of licensed activities. AREVA is expected to take all reasonable precautions to protect workers and the environment and to control releases of nuclear and hazardous substances.
AREVA has implemented its waste management program to effectively control wastes generated and stored at the McClean Lake facility. The objectives of this program are to minimize the generation of waste at the facility and dispose of wastes and by-products generated in accordance with CNSC regulatory requirements. The waste management program documentation that is referenced in the LCH describes how waste is managed throughout its lifecycle to the point of disposal. This includes waste generation, storage, processing, recycling and removal/transfer activities.The regulated activities at AREVA’s MLO have and will continue to produce or dispose of various wastes which include the following:
waste water (effluent, sewage, dewatering discharge, runoff)
During the review period, CNSC inspections regularly included waste management aspects. An inspection was conducted in May 2016 to verify some elements of the waste management SCA compliance verification criteria, and found AREVA to be in compliance.
Waste rock piles AREVA has a waste rock management plan for three separate waste rock piles which include the JEB, Sue C and Sue E. All three waste rock piles originated from previous open-pit mining operations that occurred from 1999 to 2008. In June 2013 AREVA submitted a TID on waste rock management. The conclusions of this document were:
The operational data to date shows that problematic waste rock has been effectively segregated from clean waste rock at the MLO.
Disposal of problematic waste in the Sue C/A pit is not anticipated to result in concentrations that exceed Saskatchewan Surface Water Quality Objectives (SSWQO) in receiving surface water bodies under any of the scenarios considered.
CNSC staff continue to monitor the management of waste rock at AREVA’s MLO to verify compliance with CNSC regulatory requirements.
Figure 14 shows an aerial view of the Sue site showing the mined out Sue A, B, C and E pits, Sue infrastructure and the Sue clean waste rock piles. In this figure, Sue E is in the foreground and Sue C is in the background.
Figure 14: McClean Lake – aerial view of the Sue site
Tailings management An engineered tailings management facility (the JEB TMF), was constructed from the previous JEB open-pit mine. Tailing deposition at the JEB TMF began in 1999 and continues to receive tailings from the McClean Lake mill.
AREVA hires a third party to conduct an annual geotechnical inspection of the various embankment/containment structures including the JEB TMF at the MLO. AREVA submits the third party report with a corrective action plan to disposition third party recommendations for CNSC staff review. The JEB TMF is inspected by CNSC staff during regular compliance inspections to verify that the facility is operating as designed.
Key performance indicators of the tailings management system as a whole include properties of production tailings from the tailings preparation circuit, the ability to maintain hydrodynamic containment within the TMF, and the properties of in situ tailings placed in the TMF.
Prior to issuing construction and operating licences for the TMF, a comprehensive follow-up test work program was developed to verify, optimize and validate the stated tailings performance data using tailings produced during full scale production. This tailings optimization and validation plan (TOVP) was first submitted by AREVA and approved by AECB (predecessor of CNSC) in 1999.
During the first five years of operation, TOVP status reports were submitted annually both to the CNSC and SMOE; currently these reports continue on five-year cycle requirement. The most recent TID on tailings management was submitted to CNSC in May 2015. The objective of this TID was to provide a description of the design, operation, performance and decommissioning of the tailings management system at the MLO. The long-term, post-closure environmental effect predictions are also included in the TID. This TID aims to integrate the results of the TOVP report on long-term tailings performance.
CNSC staff reviewed the tailings management TID to ensure it met regulatory requirements. All CNSC staff comments were addressed by AREVA proficiently and to CNSC staff’s expectations. CNSC staff will continue to monitor and verify that the management of tailings is protective of the environment over the long-term.
Solid and Liquid Wastes Industrial, radiologically contaminated, chemically contaminated, dangerous goods and domestic wastes are generated in both liquid and solid forms at the MLO. A waste management system has been implemented at the MLO to track and control the appropriate disposition of contaminated and non-contaminated wastes. The MLO has a ‘4 R’ waste management program to reduce, reuse, recycle and recover wastes. AREVA’s 2015 annual compliance report showed an upward trend in the amount of materials recycled since 2009. In May 2016, CNSC staff verified through an onsite inspection that wastes are being disposed of in an appropriate manner in approved facilities.
Decommissioning plans In accordance with paragraph 3(a)(viii) of the Uranium Mines and Mills Regulations and the CNSC regulatory guide G-219, Decommissioning Planning for Licensed Activities, AREVA is required to maintain decommissioning plans throughout the lifecycle of the MLO. The Saskatchewan Ministry of Environment (SMOE) and CNSC staff work closely in aligning and coordinating requirements. A memorandum of understanding (MOU) with province of Saskatchewan guides the nature of the cooperation between the parties [21].
AREVA’s Preliminary Decommissioning Plan and Financial Assurance sets out the strategy and the preliminary plan by which MLO will be decommissioned in the future. The PDP must be kept current to reflect any changes in the facility or operations, and meet the requirements of CSA Group standard N294-09, Decommissioning of Facilities Containing Nuclear Substances, and CNSC regulatory guide G-219. The licensee’s submitted plan is reviewed and assessed by CNSC staff in accordance with these documents.
AREVA revised and submitted the PDP and cost estimate for its MLO following a five-year cycle requirement. The PDP has been updated to include decommissioning of the expanded McClean Lake mill, current labour and equipment rates, and future water treatment requirements. AREVA proposed a revised financial guarantee of C$107,241,000 to reflect changes in its operation, as well as revised and increased costs for decommissioning. The revised plan was prepared based on a “decommission tomorrow” scenario with consideration of planned activities within a five-year period to the end of 2020 and covered all decommissioning costs resulting from past and expected future activities.
Based on current mineral reserves, AREVA has indicated that McClean Lake operation could continue until approximately 2050. AREVA has provided timeline estimates for the completion of each of the major decommissioning activities planned. The decommissioning of the facility is expected to occur over a period of approximately 19 years, post operation, as indicated in the following figure.
Figure 15: preliminary schedule of the proposed decommissioning phases
CNSC staff reviewed the proposed revisions and concluded that the revised preliminary decommissioning plan including cost estimates and financial assurance meet CNSC regulatory requirements. The SMOE has also reviewed and approved the revised PDP and associated cost estimates (refer to section 4.4 for further details on the FG). This approval was conveyed by official correspondence to AREVA and copied to the CNSC [22].
3.11.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance Through the review of waste management documentation and onsite inspections during the licence period, CNSC staff concluded that AREVA’s MLO waste management program meets regulatory requirements.
For the current licence period, CNSC staff rated AREVA’s overall performance for the waste management SCA as satisfactory.
Regulatory focus CNSC staff will continue to monitor performance in this area through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements AREVA has submitted plans to expand the current JEB TMF to increase tailings storage capacity at the MLO. CNSC staff will ensure that the project is completed safely and the environment is protected. This is further discussed in detail in subsection 4.5.4 – JEB Tailings Management Facility Expansion Project.
3.11.4 Conclusion Based on desktop reviews and onsite inspections, CNSC staff have concluded that the overall performance for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities at the MLO in this SCA. Two conditions in the proposed licence are associated with the waste management SCA. Licence condition 11.1 requires AREVA to implement and maintain a waste management program. Licence condition 11.2 requires AREVA to implement and maintain a decommissioning strategy. Compliance verification criteria for these licence conditions are included in the draft LCH.
3.12 Security The security SCA covers the programs required to implement and support the security requirements stipulated in the regulations, the licence, orders, or expectations for the facility or activity.
3.12.1 Trends The following table provides the annual compliance ratings for the security SCA for the current licence period 2009 to 2016:
SECURITY SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has implemented a security program that meets regulatory requirements under the General Nuclear Safety and Control Regulations to prevent the loss or unauthorized removal of nuclear substances, radioactive sources, prescribed equipment or information. As requested by CNSC, AREVA submitted an updated security threat risk assessment in 2016. The security threat risk assessment has been reviewed by CNSC staff and found to be acceptable and meeting CNSC requirements. CNSC staff monitor AREVA’s implementation of this program through compliance verification activities.
There were no significant threats to the security or incidents reported at the McClean Lake Operation.
3.12.2 Discussion Pursuant to the NSCA and its regulations, AREVA is obligated to protect the environment, the health and safety of persons, and maintain security.
AREVA maintains a security system or other measures at the MLO in order to minimize risk to the public, employees, the environment and to protect company assets from sabotage, theft, criminal acts by internal or external agents and potential vulnerabilities.
Based on review of AREVA’s vulnerability at the MLO, the lack of incidents involving theft and sabotage to the operation, the remote location of the operation, the percentage of long-term employees, and the lack of evidence of any threats to the operations, the security risk is considered low. There is no change to the security threat at the MLO and the security measures currently in place are adequate.
During the current licensing period, no theft of nuclear material from the MLO was reported. A physical inventory of all uranium material is conducted annually by an external auditor and monthly by AREVA personnel. There is no history of sabotage or any evidence of intent of actual or planned sabotage threats conveyed to CNSC.
CNSC staff monitor implementation of this program through compliance verification activities. An inspection was conducted in January 2016 at the MLO to verify elements of the security program SCA compliance verification criteria. In response to the inspection finding, AREVA submitted an updated Security Threat and Risk Assessment [23]. The security threat and risk assessment has been reviewed by CNSC staff and found to be acceptable and meeting regulatory requirements.
CNSC staff have concluded that the security measures are sufficient to address the current threat level.
3.12.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance AREVA’s MLO has implemented a security program that meets regulatory requirements. CNSC staff monitor implementation of this program through compliance verification activities. An inspection was conducted in January 2016 that verified compliance of the security program SCA verification criteria. In response to the inspection finding, AREVA submitted an updated threat, risk vulnerability assessment for CNSC staff review and acceptance. During the current licence period, there have been no thefts or any evidence of malicious acts or planned sabotage against nuclear substances at the MLO.
Regulatory focus AREVA’s MLO is required to meet the applicable requirements of sections 3 and 12 of the GNSCR. The GNSCR requires reasonable measures be in place to: maintain site security; implement means for alerting the licensee in the event of illegal use, illegal removal, sabotage or attempted sabotage; and, train workers on the security program at the licensed site.
CNSC regulatory document REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources, provides guidance to prevent the loss, sabotage and illegal use, possession or removal of sealed sources during its entire life cycle. For the proposed licence term, CNSC staff added regulatory document REGDOC-2.12.3, to the draft LCH and asked AREVA to do a gap analysis. AREVA has committed to the implementation of the uranium mines and mills applicable sections of CNSC regulatory document REGDOC-2.12.3 by December 2017.
CNSC staff will monitor implementation of this document through regulatory oversight activities including onsite inspections and desktop reviews of AREVA’s compliance reporting on this matter.
Proposed improvements No changes are anticipated in the near future for this SCA.
3.12.4 Conclusion CNSC staff assessed AREVA’s documentation and analyses under the security SCA and have found it to be acceptable. CNSC staff concluded that the overall performance for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities at the MLO in this SCA. CNSC staff also concluded that AREVA has acceptable security programs in place at the MLO that meet regulatory requirements and make adequate provisions for the maintenance of national security.
CNSC staff will continue ongoing compliance activities and monitoring activities in the security area to verify that AREVA’s security programs at the MLO, including its implementation, continue to meet regulatory requirements.
One condition in the proposed licence is associated with the security SCA. Licence condition 12.1 requires AREVA to implement and maintain a security program. Compliance verification criteria for this licence condition are provided in the draft LCH.
3.13 Safeguards and Non-Proliferation The safeguards and non-proliferation SCA covers the programs and activities required for the successful implementation of the obligations arising from the Government of Canada and the IAEA safeguards agreements as well as other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons (NPT).
The scope of the non-proliferation program for this licensee is limited to the tracking and reporting of foreign obligations and origins of nuclear material. This tracking and reporting assists the CNSC in the implementation of Canada’s bilateral Nuclear Cooperation Agreements with other countries. The import and export of controlled nuclear substances, equipment and information identified in the Nuclear Non-Proliferation Import and Export Control Regulations require separate authorization from the CNSC, consistent with GNSCR subsection 3(2).
3.13.1 Trends The following table provides the annual compliance ratings for the safeguards and non-proliferation for the current licence period 2009 to 2016:
SAFEGUARDS AND NON-PROLIFERATION SCA
Overall compliance ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation continues to implement and maintain an effective program for safeguards measures and nuclear non-proliferation commitments arising from Canada’s international obligations under the Treaty on the Non-Proliferation of Nuclear Weapons.
3.13.2 Discussion CNSC’s regulatory mandate includes ensuring conformity with measures required to implement Canada’s international obligations. AREVA has an effective safeguards program at the MLO that conforms to measures required by the CNSC to meet Canada’s international safeguards obligations as well as other measures arising from the NPT.
Pursuant to that treaty, Canada has entered into a Comprehensive Safeguards Agreement and Additional Protocol with the IAEA (hereafter, the safeguards agreements). The objective of the safeguards agreements is for the IAEA to provide annual assurance to Canada and to the international community that all declared nuclear material is in peaceful, non-explosive uses, and that there is no indication of undeclared material.
The CNSC provides the mechanism, through the NSCA, regulations and a licence condition, for the IAEA to implement the safeguards agreements at the MLO. Conditions for the application of IAEA safeguards are contained in the operating licence and criteria in order to meet the conditions contained in the LCH and in CNSC’s regulatory document RD-336, Accounting and Reporting of Nuclear Material. Compliance includes the timely provision of reports on the movement and location of all nuclear materials, the provision of access and assistance to IAEA inspectors for verification activities.
To comply with the safeguards agreements, AREVA’s MLO ensures that:
an up-to-date of inventory of uranium concentrate is maintained
uranium concentrates are sold under contracts that are subject to the safeguards
controlled nuclear substances exports or imports follow appropriate permitting and licensing
related required information is provided and an annual update for the IAEA protocol is submitted to the CNSC
In May 2016, CNSC received a request from the International Atomic Energy Agency (IAEA) for complementary access (CA) to conduct an inspection of AREVA’s MLO. Both the IAEA and CNSC staff were able to carry out all planned activities during the CA from May 19 to 20, 2016 at the MLO. As reflected in the IAEA conclusions pursuant to article 10.a of the Additional Protocol, IAEA staff were satisfied with all the documents provided by AREVA and the CA that was given to conduct the inspection at the MLO.
3.13.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance During the current licence period, AREVA provided CNSC staff with documentation necessary to verify safeguards requirements are being met, and also complied fully with all IAEA and CNSC requests. In 2016, a safeguards inspection was conducted by an IAEA inspector with CNSC staff participation at the MLO. AREVA provided the IAEA and CNSC with necessary access and assistance to perform its activities, and complied with all regulatory requirements.
AREVA’s program for safeguards and non-proliferation at the MLO continues to meet CNSC requirements and expectations.
Regulatory focus CNSC staff will continue to monitor performance through participation in IAEA inspections and through CNSC regulatory oversight activities independent of the IAEA. Monitoring will include onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements No changes are anticipated in the near future for this SCA.
3.13.4 Conclusion CNSC staff assessed documentation and analyses under the safeguards and non-proliferation SCA and have found it to be acceptable. CNSC staff concluded that the overall performance for this SCA is satisfactory and that AREVA is qualified to carry out the authorized activities at the MLO in this SCA. One condition in the proposed licence is associated with the safeguards and non-proliferation SCA. Licence condition 13.1 requires AREVA to implement and maintain a safeguards program. Compliance verification criteria for this licence condition are provided in the draft LCH.
3.14 Packaging and Transport The packaging and transport SCA covers programs for the safe packaging and transport of nuclear substances to and from the licensed facility.
3.14.1 Trends The following table provides the annual compliance ratings for the SCA packaging and transport SCA for the current licence period 2009 to 2016:
PACKAGING AND TRANSPORT SCA
Overall Compliance Ratings
2009 2010 2011 2012 2013 2014 2015 2016
SA SA SA SA SA SA SA SA
AREVA’s McClean Lake Operation has a packaging and transportation program that ensures compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations. CNSC staff monitor AREVA’s implementation of this program through compliance verification activities.
AREVA continues to make improvements to its packaging process and installed a new yellowcake packaging system. CNSC staff have confirmed that the packaging and transport activities are conducted in a safe manner.
3.14.2 Discussion AREVA has developed and implemented a packaging and transport program for activities at all AREVA operated sites to ensure compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations for all shipments to and from the site. AREVA’s packaging and transport program also covers elements of package design, package maintenance, and the registration for use of certified packages as required by the regulations.
Packaging and transport Packaging The yellowcake packaging system at the MLO is comprised of the packaging scrubber, product bin, uranium powder packaging machine, yellowcake drum weigh scale and outfeed conveyor systems.
Drums are filled with yellowcake, lids are automatically placed and securing rings added. The drums are then air cleaned, brushed under vacuum and deionized to remove static charge. Drums are stored until the required numbers of drums are packaged to complete a “Lot”. Once a “Lot” is completed, the drums are checked by the radiation group. After successfully passing of a “swipe test”, the “Lot” is then moved to the clean storage area for shipping. The yellowcake packaging enclosure has an airlock door system under negative pressure to prevent contamination of other areas with any potential airborne yellowcake when packaging is in progress. The following figure depicts an area containing packaged yellowcake drums.
Figure 16: McClean Lake – packaged yellowcake drums
Transport During 2009 and the first half of 2010, the MLO mined, milled, packaged and transported product originating from ore mined at the Sue B open pit mine. The ore slurry shipments from Cameco’s Cigar Lake mine began in March 2014 and the McClean Lake mill restarted in September 2014. The ore slurry is shipped in containers which are similar in design to the containers that have been safely used at Cameco's McArthur River and Key Lake Operations since 1999 (figure 17). These containers meet the regulatory requirements for industrial packages (IP-2) as defined in the Packaging and Transport of Nuclear Substances Regulations, 2015.
Figure 17: McClean Lake – slurry totes loaded on a tractor trailer
In support of the licence renewal, AREVA submitted documents related to the packaging and transportation for CNSC staff review. Some areas of improvement were identified and addressed by AREVA in a timely manner. CNSC staff concluded that AREVA’s packaging and transportation documents meet applicable regulatory requirements.
During the review period, CNSC staff conducted compliance inspections of the MLO that covered various aspects of McClean Lake’s transport and packaging program. In October 2016, CNSC staff conducted a focused transportation and packaging inspection at the MLO. CNSC staff reviewed procedures, workers’ training records, transportation logs, package labeling and shipping documents. Packaging and loading of product and work practices were observed. CNSC staff concluded that the transport and packaging program and associated procedures complied with regulatory requirements. AREVA addressed minor deficiencies identified during the inspection to CNSC staff’s satisfaction.
During the licence term, minor packaging and transport incidents involving ore slurry totes slightly exceeding surface contamination limits were reported by AREVA for the MLO. None of the incidents resulted in health or radiological effects, or releases to the environment. Corrective actions were taken by the licensee to CNSC staff’s satisfaction.
In 2014 a newly designed yellowcake packaging system was commissioned at the MLO. Although the packaging system was intended to be dustless, average long-lived radioactive dust concentrations within the enclosure were higher than anticipated. Long-lived radioactive dust concentrations generally improved in 2016 with more operational and preventative maintenance experience with the packaging system. The packaging enclosure is currently operated as a restricted area and requires full personal protective equipment prior to entry (e.g., disposable coveralls, gloves, and powered-air full face respirator).
3.14.3 Summary A summary of AREVA’s past performance, regulatory focus and proposed improvements are presented in the following subsections.
Past performance AREVA is performing satisfactorily in the packaging and transport SCA at the MLO and continues to demonstrate compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations. For the current licence period, CNSC staff rated AREVA’s overall performance for the packaging and transport SCA as satisfactory.
Regulatory focus CNSC staff will continue to monitor performance in this area including AREVA’s commitment of continual improvement for the packaging system through regulatory oversight activities. Monitoring will include onsite inspections and desktop reviews of AREVA’s compliance reporting and revisions to relevant program documentation pertaining to this SCA.
Proposed improvements AREVA has expressed a commitment to continual improvement of the packaging system to control ambient long-lived radioactive dust concentrations within the enclosure to reduce or eliminate the need for additional PPE in this area.
3.14.4 Conclusion Based on the above assessment, CNSC staff concluded that AREVA has an effective program for the safe packaging and transport of radioactive materials at the MLO that meets regulatory requirements. CNSC staff rate this SCA as satisfactory.
One condition in the proposed licence is associated with the packaging and transport SCA. Licence condition 14.1 requires AREVA to implement and maintain a packaging and transport program. Compliance verification criteria for this licence condition are provided in the draft LCH.
4.1 Aboriginal Consultation The common law duty to consult with Aboriginal groups applies when the Crown contemplates actions that may adversely affect potential or established Aboriginal and/or treaty rights. The CNSC ensures that all of its licensing decisions under the NSCA uphold the honour of the Crown and consider Aboriginal peoples’ potential or established Aboriginal and/or treaty rights pursuant to section 35 of the Constitution Act, 1982.
4.1.1 Discussion CNSC staff have identified First Nation and Métis groups who may have an interest in the proposed licence renewal:
Ya'thi Néné Lands and Resource Office (representing Black Lake First Nation, Hatchet Lake First Nation, and Fond du Lac First Nation). The Ya'thi Néné Lands and Resource Office is a new organization that was created as part of the recently signed Collaboration Agreement between Cameco, AREVA and Athabasca Basin Communities including: Black Lake, Hatchet Lake, and Fond du Lac First Nations and the hamlets of Stony Rapids, Wollaston Lake, Uranium City and Camsell Portage. The CNSC received a letter from the Ya'thi Néné Lands and Resource Office, signed by the leadership of all of the communities represented, confirming their role as the sole point of contact for all resource development activities.
Métis Nation Saskatchewan - Northern Region 1
Kineepik Métis Local Inc. (#9) – Pinehouse Lake
English River First Nation
Prince Albert Grand Council
Federation of Sovereign Indigenous Nations
These groups and organizations were identified because they have all previously expressed interest in being kept informed of CNSC licensed activities occurring in their treaty lands and/or asserted traditional territories in relation to the McClean Lake facility and other uranium mines and mills in northern Saskatchewan.
CNSC staff sent letters of notification in November 2016 to the identified groups above, providing information regarding the proposed licence renewal, the availability of participant funding and details on how to participate in the Commission’s public hearing process. Follow-up phone calls to the identified groups were conducted to ensure they had received the letters and to answer any questions. To date, no issues related to potential impacts on Aboriginal or treaty rights as a result of the licence renewal application have been raised by the identified First Nation and Métis groups.
CNSC REGDOC-3.2.2, Aboriginal Engagement, published in February 2016, sets out requirements and guidance for licensees whose proposed projects may raise the Crown’s duty to consult. While the CNSC cannot delegate its obligation, it can delegate procedural aspects of the consultation process to licensees. The information collected and measures proposed by licensees to avoid, mitigate or offset adverse impacts may be used by the CNSC in meeting its consultation obligations.
As AREVA’s licence renewal application does not propose any new activities, there will be no requirement of REGDOC-3.2.2. However, CNSC staff encourage AREVA to continue to keep interested Aboriginal communities informed of the licence renewal application and on-going activities of interest to the communities.
4.1.2 Conclusion Based on the information received and reviewed, CNSC staff determined that the MLO is an existing site with restricted access and AREVA is not proposing any changes to its current operations; this licence renewal application will not cause adverse impacts to any potential or established Aboriginal and/or treaty rights.
Therefore, CNSC staff determined that the decision before the Commission does not raise the duty to consult. However, the identified First Nation and Métis groups have been notified and encouraged to participate in the licence renewal application review process and in the Commission’s public hearing to advise the Commission directly of any concerns they may have in relation to this licence application.
4.2 Other Consultation As per its normal public notification process for Commission proceedings, CNSC staff informed the public via the CNSC’s website, email subscription list, social media channels, radio and print advertisements in local communities in northern Saskatchewan of the public Commission hearing and availability of participant funding.
The CNSC also provided a CNSC 101 information session to over 100 participants in the Wollaston Post/Hatchet Lake First Nation community on October 11, 2016, including representatives from other northern Saskatchewan First Nation and Métis communities and organizations. This session provided an introduction to the CNSC and the work it does to ensure that nuclear facilities in northern Saskatchewan and across Canada are safe and how the public can participate in the licensing process. In addition, the CNSC hosted a CNSC 101 session for leadership and staff of the Prince Albert Grand Council and the Federation of Sovereign Indigenous Nations in Saskatoon, Saskatchewan on October 12, 2016.
4.2.1 Discussion The CNSC made available up to C$75,000 through its Participant Funding Program (PFP) to assist members of the public, Indigenous groups, and other stakeholders in providing value-added information to the Commission through informed and topic-specific interventions. This funding was offered to review AREVA’s licence renewal application and associated documents and to prepare for and participate in the Commission’s public hearing.
The deadline for applications was December 12, 2016. A Funding Review Committee (FRC), independent from CNSC staff, reviewed the funding applications received, and made recommendations on the allocation of funding to eligible applicants. Based on recommendations from the FRC, the CNSC awarded participant funding to the following recipients, who are required to submit a written intervention and make an oral intervention at the Commission’s public hearing:
Kineepik Metis Local Inc. (#9) Pinehouse
David Parker
Ya’thi Néné Lands & Resource Office
Saskatchewan Environmental Society
Dr. Philip D. McLoughlin
Angela Laventure (President of Unifor Local 48s)
Lac La Ronge Indian Band
Buffalo River Dene First Nation
Birch Narrows Dene First Nation
4.2.2 Conclusion Based on the above information, CNSC staff followed its process and the public have been encouraged to participate in the Commission’s public hearing. The CNSC offered assistance to interested members of the public, Indigenous groups, and other stakeholders, through the PFP, to prepare for and participate in the Commission’s public hearing.
4.3 Cost Recovery It is a requirement of the NSCA under paragraph 24(2)(c), that the licence application is accompanied by the prescribed fee. The Cost Recovery Fees Regulations (CRFR) set out the specific requirements based on the activities to be licensed. An applicant for a uranium mines and mills licence is subject to “Part 2” of CRFR, which is based on “Regulatory Activity Plan Fees”.
4.3.1 Discussion AREVA is in good standing with respect to CRFR requirements for its MLO.
AREVA’s licence renewal application is not an initial application and as such the applicant is not required to submit the initial fee of C$25,000 as described in paragraph 7(1)(a), which is only for initial applicant. In this case, AREVA is subject to subsection 5(2), which relates to quarterly invoices sent to licensees.
4.3.2 Conclusion After assessing CNSC records, CNSC staff conclude that AREVA is in good standing with respect to MLO CRFR requirements.
No licence condition is required for this matter.
4.4 Financial Guarantees Under subsection 24(5) of the NSCA, AREVA is required to provide a financial guarantee (FG) in a form that is acceptable to the Commission. GNSCR paragraph 3(1)(l) stipulates that, “an application for a licence shall contain a description of any proposed financial guarantee related to the activity for which a licence application is submitted.” Regulatory guide G-206, Financial Guarantees for the Decommissioning of Licensed Activities, covers the provision of financial guarantees for decommissioning activities.
4.4.1 Discussion As discussed in subsection 3.11.2, AREVA has revised its PDP and cost estimate for the MLO. The revised plan was prepared based on a “decommission tomorrow” scenario and covered all decommissioning costs. AREVA proposed a revised financial guarantee of C$107,241,000 to reflect changes in its operation because of some major improvement projects listed under the operating performance SCA, which were reviewed and accepted by CNSC staff. CNSC staff and SMOE officials reviewed the proposed revisions and concluded that the revised PDP including cost estimates and FGs meet regulatory requirements.
The Government of Saskatchewan, under The Mineral Industry Environmental Protection Regulations, 1996, also requires that mining and milling projects be covered by FGs. The provincial review of AREVA’s PDP and cost estimate is independent to CNSC staff’s review. The MOU between CNSC and the province allows a single PDP and financial assurance, subject to consultation and mutual acceptance. The MOU also specifies that the FG is conditional until approved by the Commission. The SMOE is the beneficiary of the FG for all the operating and decommissioned uranium mines and mills, and is the owner of the lands.
As a financial guarantee instrument, AREVA continues to use letters of credit in accordance with CNSC regulatory guide G-206. AREVA has provided copies of its letters of credit to the CNSC [24].
One condition in the proposed licence is associated with financial guarantee. Licence condition G.3 requires AREVA to maintain a financial guarantee for decommissioning that is acceptable to the Commission.
4.4.2 Conclusion CNSC staff have reviewed the proposed revisions and concluded that the revised PDP including cost estimates and FGs meet CNSC regulatory requirements. CNSC staff are satisfied AREVA’s proposed FG is adequate for decommissioning of the MLO and recommend that the Commission accept AREVA’s proposed FG in the amount of C$107,241,000.
4.5 Improvement Plans and Significant Future Activities
4.5.1 Discussion For any future significant activities and improvement plans, CNSC staff will review the information submitted by AREVA to determine if the proposed activity meets the licensing basis. Any changes not within the licensing basis will be brought to the Commission for approval.
The improvement plans listed below are part of AREVA’s operational ongoing activities to better control sulphur dioxide emissions and further reduce selenium effluent concentrations. CNSC staff will continue to conduct regulatory oversight of these activities during inspections as part of compliance verification. CNSC staff will report back to the Commission on these improvements through annual regulatory oversight reports.
4.5.2 Sulphur Dioxide Mitigation Project During restart and commissioning, AREVA initially encountered a safety issue at the MLO. As part of management system continuous improvement plans, AREVA took action to eliminate the risk associated with elevated sulphur dioxide emissions from the calciner exhaust stack and elevated ambient airborne concentrations of sulphur dioxide in and around the MLO. As required by CNSC, AREVA submitted a sulphur dioxide management plan, which CNSC staff reviewed and accepted. Stack emissions have been brought under control through adjustments to operational and control parameters. Control of sulphur dioxide has been achieved through maintaining key process variables such as clean-up thickener pH, scrubber solution flow, and venture pressure differentials within targeted ranges. To eliminate workplace exposures, sulphur dioxide monitors have been installed at four different strategic locations inside the mill. Continuous improvements include re-purposing the existing slurry transfer tank in the yellowcake precipitation circuit to replace the existing yellowcake wash tank. This change will reduce risk related to sulphur dioxide release from the calciner stack by reducing the amount of sulphur fed to the calciner. Another improvement identified by AREVA was to increase scrubber stack extension. Increasing the stack height by a few metres resulted in better dispersion characteristics.
4.5.3 Selenium Adaptive Management Plan After restart of the MLO in September 2014, AREVA identified an increasing trend for the JEB WTP selenium effluent concentration. While AREVA has been taking a proactive approach and has anticipated the need to trigger adaptive management, CNSC staff requested AREVA to develop a formal selenium adaptive management plan, which would incorporate the following strategies: Pollution Prevention Plan, Best Available Technology Economically Achievable (BATEA) Assessment, and Active Commissioning Plan. The pollution prevention plan includes a description of the continuous improvement techniques that were implemented and will be implemented to keep selenium concentrations and loadings to the environment as low as reasonably achievable (ALARA). The BATEA assessment includes a characterization of selenium source terms in the effluent to the JEB WTP, an options analysis, development of an appropriate design objective for selenium, and justification for selection of the final design. The design objective will be used during the options analysis to help select the appropriate technology and techniques to reduce concentration of the selenium in the discharge. The active commissioning plan contains information about the operational performance, performance assessment, training process, and standard operating procedures.
In April 2017, AREVA is expected to submit its formal selenium adaptive management plan for the MLO. CNSC staff will review the plan to ensure it meets regulatory requirements. CNSC staff will continue to monitor the progress of the adaptive management process accordingly.
4.5.4 JEB Tailings Management Facility Expansion Project Project description AREVA has operated the JEB TMF since 1999 and is currently authorized for disposal of tailings in the JEB TMF up to a consolidated tailings elevation of 434 metres above sea level (mASL). As per current design, the remaining tailings storage available in the JEB TMF is approximately 0.8 million cubic metres. Based on current mining and milling projections, AREVA expects to generate approximately 2.4 million cubic metres of tailings over the next 18 years.
AREVA has submitted a request to expand the JEB TMF [25] to maximize tailings placement. The proposed expansion project would provide additional tailings capacity of 1.7 million cubic metres with sufficient water cover and freeboard and would require:
construction of an embankment around a portion of the JEB TMF perimeter to bring the low-side elevation up
placement of a processed waste rock/till bentonite-amended liner for hydraulic containment throughout operations
CNSC staff assessment CNSC staff have conducted a thorough technical assessment of AREVA’s TMF expansion proposal. CNSC staff have concluded that the increase of consolidated tailings elevation remains within the licensing basis and will continue to achieve the operational and post-closure objectives developed to ensure safety and protection of the environment. The expanded JEB TMF will continue to:
maintain hydrodynamic containment of the tailings through the operating period
limit infiltration of pond water into the overburden during the operating period through the placement of a low permeability liner
place tailings sub-aqueously
place consolidated tailings below the ground surface
manage storm water effectively
validate the geochemical and geophysical aspects of the facility design
limit groundwater migration through the tailings mass during the post-closure period by establishing a hydraulic conductivity contrast between the consolidated tailings and the surrounding host materials
CNSC staff asked AREVA to provide clarity and additional information related to the source term, the robustness of the cover, engineering controls and other design features. AREVA provided the requested information in a timely and satisfactorily manner. CNSC staff evaluated AREVA’s response, found it acceptable and meeting regulatory requirements. The detailed technical review of AREVA’s submission including supporting documents is now complete. As discussed in the EA report (addendum E), disposal of tailings has been assessed and CNSC staff concluded that the JEB TMF expansion project is within the licensing basis. AREVA has provided a tentative schedule indicating that the construction activities will start in 2018 with the relocation of infrastructure and completion of TMF optimization stage 2 expected by 2021. As required by CNSC staff, AREVA has committed to provide construction details prior to initiating any construction activities for CNSC staff review and acceptance.
CNSC staff, as part of its compliance activities, will carry out the following activities to ensure safety and protection of the environment:
1. Verify annually that hydrodynamic containment of the JEB TMF is being maintained.
2. Review tailings consolidation studies which are on five-year cycle.
3. Confirm the timely implementation of any mitigation measures necessary to ensure that the aquatic ecosystem in nearby Fox and Pat Lakes are protected.
CNSC staff expect AREVA to continue to apply the principles of continuous improvement to safety, health and environmental performance for the facility. Any changes and improvements to its McClean Lake facilities over the proposed licence period will be reviewed for compliance with licensing requirements to verify AREVA remains within the licensing basis. Compliance inspections by CNSC staff will be conducted to ensure the activities proposed are completed safely and are protecting the environment.
4.6 Public Information and Disclosure 4.6.1 Discussion
Uranium mines and mills are required to implement public information programs, in accordance with CNSC’s regulatory document RD/GD-99.3, Public Information and Disclosure. These programs are supported by disclosure protocols which outline the type of information on the facility and its activities that will be shared with the public (e.g., incidents, major changes to operations, periodic environmental performance reports) and how that information will be shared. The objective is to ensure that timely information about the health, safety and security of persons and the environment and other issues associated with the lifecycle of the nuclear facility are effectively communicated.
AREVA has a robust public information program for its MLO. The licensee has undertaken numerous activities and effort to continuously improve and maintain communication with those interested in and concerned about their operation. During the current licence period, AREVA has continued to disclose quarterly environmental monitoring summaries, engage in social media, host open houses and participate in community-lead events, produce regular community newsletters, and is a major contributor to Opportunity North, a quarterly magazine with a circulation of 9,500 copies distributed out of Air Ronge, Saskatchewan to northern Saskatchewan communities.
The licensee has undertaken regular public opinion surveys in northern Saskatchewan to help determine the effectiveness of its public information activities. The CNSC recognizes AREVA’s efforts in developing and sustaining effective public information programs that inform and engage the citizens of northern Saskatchewan.
4.6.2 Conclusion CNSC staff concluded that AREVA has a satisfactory public information and disclosure program that meets CNSC regulatory requirements and that information related to the health, safety and security of persons and the environment, and other issues associated with the lifecycle of the facility is being effectively communicated to the public.
One condition in the proposed licence is associated with public information and disclosure. Licence condition G.5 requires AREVA to implement and maintain a public information and disclosure program. Compliance verification criteria for this licence condition are provided in the draft LCH.
4.7 Proposed Licence Period AREVA has submitted an application with a request to renew its McClean Lake operating licence for a period of 12 years. While CNSC staff note that current practice has been to issue 10 year term licences, CNSC staff have confirmed the requested licensing term of 12 years is not an impediment to safety of the public or the environment.
In support of the licence renewal AREVA has submitted, in 2016, both an Environmental Performance Technical Information Document (TID), Volume 1 of 2 – Environmental Monitoring and Environmental Performance Technical Information Document, Volume 2 of 2 – Environmental Risk Assessment. The TIDs are required every five years and provide information about the environmental performance and risk assessment of the MLO. The TIDs submitted in 2016 are for the 2011 to 2015 report period and assess performance relative to the predictions contained in the 2012 Environmental Risk Assessment (ERA).
CNSC staff reviewed the TIDs to confirm whether the risks to ecological and human receptors accepted by the CNSC in previous Environmental Impact Statements and ERAs are still valid and the public and the environment remain protected. ERA updates are completed to confirm that air, soil, water and sediment quality predictions are still met and that the environment and public are protected.
The TIDs are an important consideration for future licence renewals. Review, evaluation and final acceptance by CNSC staff of the TIDs require a minimum of one year. Therefore, the requested 12 year licence term will allow AREVA and CNSC staff to coordinate two cycles of TID review and evaluation. Two TID cycles will provide added environmental data and information trends.
CNSC staff confirmed that the environment and human health in the vicinity of the MLO remain protected. As previously described in subsection 3.9.2, Environmental Risk Assessment, CNSC staff concluded that the predicted impacts for the current anticipated MLO milling and decommissioning plans are consistent with those predicted in previously approved environmental assessments and environmental risk assessments with the exception of predicted short term exposure of aquatic biota to selenium in the McClean Lake East Basin. As previously discussed, AREVA has committed to investigate and evaluate an advanced selenium treatment technology. CNSC staff will continue to monitor AREVA’s progress to reduce selenium concentrations in effluent and will update the Commission during annual regulatory oversight reports.
In preparation for the licence renewal, CNSC provided a CNSC 101 information session to Wollaston Post/Hatchet Lake First Nation communities in October 2016 which included information on the proposed licence renewal. In addition, CNSC staff also participated in an outreach session at the Black Lake and Fond du Lac First Nation communities in January 2017. Overall, community members and leadership indicated that they are supportive of AREVA’s MLO licence renewal request including the proposed 12 year licence term. CNSC staff also noted that the communities are pleased with the work being done as part of the implementation of the recently signed Collaboration Agreement between Cameco, AREVA and Athabasca Basin Communities including: Black Lake, Hatchet Lake and Fond du Lac First Nations and the northern settlements of Stony Rapids, Wollaston Lake, Uranium City and Camsell Portage. AREVA, in accordance with its public information program and discharge protocol, reviewed and accepted by CNSC staff, has also conducted engagement activities and presented its proposed 12 year licensing term to local communities and Aboriginal groups.
AREVA’s MLO is a mature facility with established programs and a management system focused on continuous improvement. Current practice has been to issue 10 year term licences to similar facilities. Although the requested licence term exceeds current practice, it does not impose any additional risks on the public or the environment. CNSC staff took into consideration that hazards associated with the proposed licensed activities are well characterized, impacts well predicted and within the scope considered in the EA report (addendum E).
Through CNSC’s compliance monitoring program, CNSC staff also verified AREVA’s effective and proper implementation of program improvements over this period. AREVA has strong operating experience and demonstrated compliance in carrying out the activities under its MLO licence in a safe and environmentally sound manner. AREVA’s MLO programs provide assurances that safety-related activities are examined and maintained. AREVA’s performance in all SCAs has remained stable or improved during the current licence term.
Annual regulatory oversight reports (RORs) are presented to the Commission at public proceedings to allow for updates regarding licensee performance and CNSC regulatory oversight activities. These RORs ensure routine reporting to the Commission and the public on licensee performance, important events and substantive changes to the facility.
CNSC staff will continue to engage regularly with communities in northern Saskatchewan to ensure ongoing communications on safety performance, and to facilitate discussion on any matters of concern as they relate to the regulated activities.
All activities, including proposed changes, will be governed by the licence and LCH. Any changes outside of the licensing basis will continue to require Commission review and approval through the Commission public hearing process.
Given the above analysis, CNSC staff conclude that a 12 year licence period will better align licensee submissions and CNSC staff’s reviews. AREVA’s performance has been consistent and adequate over the past license period and reporting processes are in place to monitor performance over the proposed licensing period. Therefore, CNSC staff recommend that the Commission accept AREVA’s request for a 12 year licence period.
4.8 Licence Conditions Handbook The LCH associated with the MLO provides compliance verification criteria used to determine whether the conditions listed in the licence have been met. The LCH sets out how CNSC staff will assess AREVA’s compliance with the licence. It provides details associated with each licence condition, such as: applicable CSA Group standards and CNSC regulatory documents, regulatory interpretation, compliance verification criteria, version-controlled documents, licensees’ written notification documents and guidance. This structure allows more freedom for the facility to evolve and update its documentation within the licensing basis.
4.9 Delegation The Commission may include in a licence any condition it considers necessary for the purposes of the NSCA. The Commission may delegate authority to CNSC staff with respect to the administration of LCs, or portions thereof.
There is one proposed LC in the proposed licence that contains the phrase “the Commission or a person authorized by the Commission”:
LC 3.2 Reporting Requirements
CNSC staff recommend the Commission delegate its authority for the purposes described in the above LC to the following staff:
Director, Uranium Mines and Mills Division
Director General, Directorate of Nuclear Cycle and Facilities Regulation
Executive Vice-President and Chief Regulatory Operations Officer, Regulatory Operations Branch
There is one compliance verification section of the draft LCH that contains the phrase “the Commission or a person authorized by the Commission”:
LC 3.3 Nuclear Substances
CNSC staff recommend the Commission delegate its authority for the purposes described in the compliance verification section of the draft LCH related to LC 3.3 to the following staff:
Director, Uranium Mines and Mills Division
Director General, Directorate of Nuclear Cycle and Facilities Regulation
Executive Vice-President and Chief Regulatory Operations Officer, Regulatory Operations Branch
5. OVERALL CONCLUSIONS AND RECOMMENDATIONS CNSC staff conclusions and recommendations consider an overall assessment of AREVA’s compliance with the NSCA and its regulations during the current licence period (2009-16), and AREVA’s programs, resources, and measures in place at the MLO to ensure the health and safety of persons and the environment and of the measures related to security and Canada’s international obligations during the proposed licence period.
5.1 Overall Conclusions
CNSC staff conclude the following, with respect to paragraphs 24(4)(a) and (b) of the NSCA, in that AREVA:
1. is qualified to carry on the activities authorized by the licence
2. will, in carrying out that activity, make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed
5.2 Overall Recommendations
CNSC staff recommend that the Commission:
1. renew the Uranium Mine Operating Licence (UMOL) to authorize AREVA to operate the MLO valid until June 30, 2029 pursuant to subsection 24(2) of the NSCA
2. accept AREVA’s McClean Lake revised financial guarantee for decommissioning in the amount of C$107,241,000
3. authorize the delegation of authority as set out in section 4.9 of this CMD
1. Record of Proceeding, Including Reasons For Decision In the Matter of AREVA Resources Canada Inc. to Amend the Uranium Mine Operating Licence for the McClean Lake Operation, Public Hearing Date October 24, 2012 (e-Doc 4056339).
2. AREVA Resources Canada Inc., McClean Lake Operation, ‘Notification of Increase to McClean Lake Annual Production Rate’, February 2016 (e-Doc 4932128).
3. Letter from Dale Huffman (AREVA Resources Canada Inc.) to Marc Leblanc (CNSC), titled: ‘McClean Lake Operation – Operating Licence UMOL-MINEMILL-McCLEAN.01/2017 - Licence Renewal Request’ for a 12-year term, dated August 22, 2016 (e-Doc 5067590).
4. AREVA Resources Canada Inc., McClean Lake Operation, ‘Preliminary Decommissioning Plan and Financial Assurance, Version 8, Revision 3’, October 2016 (e-Doc 4953011).
5. AREVA Resources Canada Inc., McClean Lake Operation, ‘Environmental Impact Statement, Receipt and Processing of McArthur River Ore at the McClean Lake Operation’, June 2011 (e-Doc 3766698).
6. AREVA Resources Canada Inc., McClean Lake Operation, ‘265ML JEB Mill Upgrade – Technical Support Document, December 2012 and HAZOP Risk Register, March 2013’, (e-Docs 4054241, 4115664).
7. AREVA Resources Canada Inc., McClean Lake Operation, ‘Notification of Changes to the Leaching Circuit’, January 2014, (e-Doc 4276885).
8. AREVA Resources Canada Inc., McClean Lake Operation, ‘Report on Commissioning & Restart of the McClean Lake Mill’, December 2015, (e-Doc 4909213).
9. AREVA Resources Canada Inc., McClean Lake Operation, “Midwest Project Environmental Impact Statement”, September 2011 (e-Doc 3814837).
10. AREVA Resources Canada Inc., McClean Lake Operation, ‘Facility Description Manual, Version 5, Revision 1’, October 2016 (e-Doc #5107638).
11. AREVA Resources Canada Inc., McClean Lake Operation, ‘Mining Facility Licensing Manual, Version 7, Revision 1’, October 2016 (e-Doc 5103114).
12. AREVA Resources Canada Inc., McClean Lake Operation, ‘Ventilation Monitoring Specification Report, January 2016 and Response to CNSC Staff comments on the Ventilation Monitoring Specification Report, June 2016’, (e-Docs 4923406, 5014608).
13. AREVA Resources Canada Inc., McClean Lake Operation, ‘Results of the Radiation Performance Confirmation Plan, Version 1’, September 2016 (e-Doc 5094163).
14. AREVA Resources Canada Inc., McClean Lake Operation, ‘Sulphur Dioxide Management in Precipitation and Calciner Circuits, May 2016 and Response to
CNSC Staff Comments on the Sulphur Dioxide Management Plan, September 2016’, (e-Docs 5007886, 5078356).
15. AREVA Resources Canada Inc., McClean Lake Operation, ‘Environmental Protection Code of Practice, Version 1, Revision 7’, October 2016 (e-Doc 5107660).
16. AREVA Resources Canada Inc., McClean Lake Operation, ‘Selenium Management, May 2016; Selenium Risk Management – Revision and Response to CNSC Staff Comments, September 2016; and Selenium Risk Management – Revision and Response to CNSC Staff Comments, October 2016’, (e-Docs 5008472, 5086059, and 5112674).
17. AREVA Resources Canada Inc., McClean Lake Operation, ‘Environmental Performance Technical Information Document Volume 1 – Environmental Monitoring’, May 2016 (e-Doc 5012881).
18. AREVA Resources Canada Inc., McClean Lake Operation, ‘Environmental Performance Volume 2 of 2 – Environmental Risk Assessment, Version 03, Revision 00’, September 2016 (e-Doc 5094511).
19. AREVA Resources Canada Inc., McClean Lake Operation, “Technical Information Document – Environmental Performance”, January 2012 (e-Docs 3884391 and 3884405).
20. AREVA Resources Canada Inc., McClean Lake Operation, “Fire Hazard Assessment, July 2015 and Fire Hazard Analysis – Corrective Action Plan, July 2015 (e-Docs 4813096 and 4811690).
21. Atomic Energy Control Board, Memorandum of Understanding between Saskatchewan and AECB, September 1996 (e-Doc 3816864).
22. Saskatchewan Ministry of Environment, “Preliminary Decommissioning Plan, Version 8”, January 2016 (e-Doc 4923472).
23. AREVA Resources Canada Inc., McClean Lake Operation, ‘Security Threat and Risk Assessment’, October 2016 (e-Doc 5121279).
24. AREVA Resources Canada Inc., McClean Lake Operation, ‘Updated Letters of Credit’, February 2017 (e-Doc 5193385).
25. AREVA Resources Canada Inc., McClean Lake Operation, ‘Notification of Modification to the JEB Tailings Management Facility Expansion Project’, June 10, 2016 (e-Doc 5020837).
Accept Accept means to indicate compliance with requirements.
Acceptable Acceptable means to meet the requirements of CNSC staff.
Action Level A specific dose of radiation or other parameter that, if reached, may indicate a loss of control of part of a licensee’s radiation protection program and triggers a requirement for specific action to be taken (Radiation Protection Regulations; (Glossary of CNSC Terminology).
Approval Approval means the granting of consent by a regulatory body. Typically used to represent any form of consent from the regulatory body that does not meet the definition of authorization (IAEA Glossary).
Authorization Authorization means the granting by a regulatory body or other governmental body of written permission for an operator to perform specified activities (IAEA Glossary): Authorization could include, for example, licensing, certification,
or registration.
The term authorization is also sometimes used to describe the document granting such permission.
Authorization is normally a more formal process than approval.
CMD A document prepared for Commission hearings and meetings by CNSC staff, proponents and intervenors.
Commission The CNSC established by section 8. (NSCA)
Note 1: The Commission consists of not more than seven members, appointed by the Governor in Council, to:
make independent, fair and transparent decisions on the licensing of nuclear-related activities
establish legally binding regulations
set regulatory policy direction on health, safety, security and environmental issues affecting the Canadian nuclear sector
Note 2: This term is not used when the intention is to refer to both Commission members and CNSC staff (Glossary of CNSC Terminology).
Compliance Conformity by regulated persons or organizations with the requirements of the Nuclear Safety and Control Act (NSCA), the regulations made under the NSCA, the licences, decisions, certificates and orders made by the CNSC.
Effective Dose The sum of the products, in sievert, obtained by multiplying the equivalent dose of radiation received by and committed to each organ or tissue set out in column 1 of an item of Schedule 1 by the weighting factor set out in column 2 of that item (Radiation Protection Regulations; Glossary of CNSC Terminology).
Financial Assurance
This is the Saskatchewan Provincial name equivalent to the CNSC Financial Guarantee.
Hazardous Substance
A substance, other than a nuclear substance, that is used or produced in the course of carrying on a licensed activity and that may pose a risk to the environment or the health and safety of persons (Class II Nuclear Facilities and Prescribed Equipment Regulations; Uranium Mines and Mills Regulations, Glossary of CNSC Terminology).
IAEA An independent international organization related to the United Nations system. The IAEA works with its Member States and multiple partners worldwide to promote safe, secure and peaceful nuclear technologies. The IAEA reports annually to the UN General Assembly and, when appropriate, to the Security Council regarding non-compliance by States with respect to their safeguards obligations, as well as on matters relating to international peace and security (Glossary of CNSC Terminology).
Licensing Basis A set of requirements and documents for a regulated facility or activity comprising:
the regulatory requirements set out in the applicable laws and regulations
the conditions and safety and control measures described in the facility’s or activity’s licence and the documents directly referenced in that licence
the safety and control measures described in the licence application and the documents needed to support that licence application (Glossary of CNSC Terminology)
The framework of processes, procedures and practices used to ensure that an organization can fulfill all tasks required to achieve its objectives safely and consistently. Note: The management system integrates all elements of an organization into one coherent system to enable all of the organization’s objectives to be achieved. These elements include the structure, resources and processes. Personnel, equipment and organizational culture, as well as the documented policies and processes, are parts of the management system (Glossary of CNSC Terminology).
Notification The submission of information by the licensee to CNSC staff.
Person Authorized by the Commission
Person authorized by the Commission means the Project Officer overseeing the licensing and compliance activities for the PWMF, the Director of the Wastes and Decommissioning Division, the Director General of the Directorate of Nuclear Cycle and Facilities Regulation, or the Executive Vice-President and Chief Regulatory Operations Officer of the CNSC.
Shall For the purpose of this handbook, “shall” is used to express a requirement, i.e., a provision that the user is obliged to satisfy in order to comply with CSA Group standard N286-12, Management system requirements for nuclear facilities.
The CNSC uses a risk-informed regulatory approach in the management and control of regulated facilities and activities. CNSC staff have therefore established an approach to identifying appropriate levels of regulatory monitoring and control for specific classes of licensed facilities and types of licensed activities based on risk ranking.
Risk ranking is applied to each SCA, and is determined by considering the probability and consequence of adverse incidents associated with each SCA as it relates to the given facility and activity types.
The methodology used to determine risk ranking is based on Canadian Standards Association guideline CAN/CSA-Q850, Risk Management: Guideline for Decision Makers. This guideline provides a description of the major components of the risk management decision process and its relationship to each other, and describes a process for acquiring, analyzing, evaluating, and communicating information that is necessary for making decisions.
In subsection 2.2 of this CMD, in the safety and control areas relevant to the MLO table, the “risk ranking” column shows a high (H), moderate (M) or low (L) indicator for each SCA that is relevant to the current facility and activities being addressed in this CMD. The risk rankings are not static and will change over time for a given facility and activities (e.g., facilities age, facilities and equipment are upgraded, activities cease or begin, licensees change, technology and programs mature, knowledge and understanding of impacts and probabilities increase, etc.).
The following matrix provides a high-level overview of risk ranking, and the management and monitoring approach associated with the various degrees of risk.
APPROACH TO ASSESSING AND MANAGING POTENTIAL RISK CONSEQUENCE MANAGEMENT/MONITORING APPROACH
Significant impact
Considerable management of risk is required
Must manage and monitor risk with occasional control
Extensive management is essential. Constant monitoring and control
Moderate impact
Occasional monitoring
Management effort is recommended
Management effort and control is required
Low impact Random monitoring Regular monitoring Manage and monitor
Probability of occurrence
Unlikely to occur Might occur Expected to occur
RISK RANKING SCALE L Low Risk M Moderate Risk H High Risk
On this basis, a high-risk SCA would be subject to increased regulatory scrutiny and control while a low-risk SCA would generally require minor verification and control.
Rating levels used in this CMD for the MLO are defined below.
Fully Satisfactory (FS) Safety and control measures implemented by the licensee are highly effective. In addition, compliance with regulatory requirements is fully satisfactory and compliance within the SCA or specific area exceeds requirements and CNSC expectations. Compliance is stable or improving, and any problems or issues that arise are promptly addressed.
Satisfactory (SA) Safety and control measures implemented by the licensee are sufficiently effective. In addition, compliance with regulatory requirements is satisfactory. Compliance within the area meets requirements and CNSC expectations. Any deviation is only minor, and any issues are considered to pose a low risk to the achievement of regulatory objectives and CNSC expectations. Appropriate improvements are planned.
Below Expectations (BE) Safety and control measures implemented by the licensee are marginally ineffective. In addition, compliance with regulatory requirements falls below expectations. Compliance within the area deviates from requirements or CNSC expectations to the extent that there is a moderate risk of ultimate failure to comply. Improvements are required to address identified weaknesses. The licensee or applicant is taking appropriate corrective action.
Unacceptable (UA) Safety and control measures implemented by the licensee are significantly ineffective. In addition, compliance with regulatory requirements is unacceptable, and is seriously compromised. Compliance within the overall area is significantly below requirements or CNSC expectations, or there is evidence of overall non-compliance. Without corrective action, there is a high probability that the deficiencies will lead to an unreasonable risk. Issues are not being addressed effectively, no appropriate corrective measures have been taken, and no alternative plan of action has been provided. Immediate action is required.
C.1 Regulatory Basis The recommendations presented in this CMD are based on compliance objectives and expectations associated with the relevant SCAs and other matters. The regulatory basis for the matters that are relevant to this CMD are as follows.
Management System
The regulatory foundation for the recommendation(s) associated with management system includes the following:
The General Nuclear Safety and Control Regulations requires that an application for a licence shall contain, under paragraph:
o 3(1)(k), the applicant’s organizational management structure insofar as it may bear on the applicant’s compliance with the Act and the regulations made under the Act, including the internal allocation of functions, responsibilities and authority.
It is a requirement of the General Nuclear Safety and Control Regulations under section 15 that every applicant for a licence and every licensee shall notify the Commission of:
o 15(a), the persons who have the authority to act for them (the applicant/licensee) in their dealings with the Commission.
o 15(b), the names and position titles of the persons who are responsible for the management and control of the licensed activity and the nuclear substance, nuclear facility, prescribed equipment or prescribed information encompassed by the licence.
o 15(c), any change in the information referred to in paragraphs (a) and (b) within 15 days after the change occurs.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (b) in relation to the activity to be licensed:
o 3(b)(v), the proposed quality assurance program for the activity.
The regulatory foundation for the recommendation(s) associated with human performance management includes the following:
It is a requirement of the General Nuclear Safety and Control Regulations under section 12, that every licensee shall:
o 12(1)(a), ensure the presence of a sufficient number of qualified workers to carry on the licensed activity safely and in accordance with the Act, the regulations made under the Act and the licence.
o 12(1)(b), train the workers to carry on the licensed activity in accordance with the Act, the regulations made under the Act and the licence.
o 12(1)(e), require that every person at the site of the licensed activity to use equipment, devices, clothing and procedures in accordance with the Act, the regulations made under the Act and the licence.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (d) in relation to health and safety:
o 3(d)(v), proposed training program for workers.
It is a requirement of the Uranium Mines and Mills Regulations under section 10, in relation to operating procedures:
o 10(b), that every licensee shall train its workers to perform their work in accordance with operating procedures.
It is a requirement of the Uranium Mines and Mills Regulations under section 15, in relation to training program:
o 15(1), that where a worker successfully completes the training program in basic radiation health and safety referred to in a licence, the licensee shall issue to the worker a certificate indicating that the worker has completed a training program in basic radiation health and safety that is acceptable to the Commission.
o 15(2), that every licensee shall provide a copy of the training program referred to in the licence to a worker’s representative.
It is a requirement of the Uranium Mines and Mills Regulations under section 16, in relation to records to be kept and made available:
o 16(1)(k), that every licensee shall keep a record of the training received by each worker.
o 16(3), that every licensee shall retain a record of the training referred to in paragraph (1)(k) for the period that the worker is employed at the uranium mine or mill.
The regulatory foundation for the recommendation(s) associated with operating performance includes the following:
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 29(1), that every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
o 29(1)(a), a situation referred to in paragraph 27(b) of the Act.
o 29(1)(b), the occurrence of an event that is likely to result in the exposure of persons to radiation in excess of the applicable radiation dose limits prescribed by the Radiation Protection Regulations.
o 29(1)(c) a release, not authorized by the licence, of a quantity of radioactive nuclear substance into the environment.
o 29(1)(d), a situation or event that requires the implementation of a contingency plan in accordance with the licence.
o 29(1)(f), information that reveals the incipient failure, abnormal degradation or weakening of any component or system at the site of the licensed activity, the failure of which could have a serious adverse effect on the environment or constitutes or is likely to constitute or contribute to a serious risk to the health and safety of persons or the maintenance of security.
o 29(1)(h), a serious illness or injury incurred or possibly incurred as a result of the licensed activity.
o 29(1)(i) the death of any person at a nuclear facility
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 29(2), that every licensee who becomes aware of a situation referred to in subsection (1) shall file a full report of the situation with the Commission within 21 days after becoming aware of it, unless some other period is specified in the licence, and the report shall contain the following information:
o 29(2)(a), the date, time and location of becoming aware of the situation.
o 29(2)(b), a description of the situation and the circumstances.
o 29(2)(c), the probable cause of the situation.
o 29(2)(d), the effects on the environment, the health and safety of persons and the maintenance of security that have resulted or may result from the situation.
o 29(2)(e), the effective dose and equivalent dose of radiation received by any person as a result of the situation
o 29(2)(f), the actions that the licensee has taken or proposes to take with respect to the situation.
It is a requirement of the Uranium Mines and Mills Regulations under paragraphs 6(1)(a) and 6(2)(a), that an application for a licence in respect of a uranium mine and mill shall contain the results of any commissioning work.
It is a requirement of the Uranium Mines and Mills Regulations under paragraphs 6(1)(c) that an application for a licence in respect of a uranium mine and mill shall contain the proposed policies, methods and programs for operating and maintaining the mine
It is a requirement of the Uranium Mines and Mills Regulations under subsection 10(a), that every licensee shall establish, implement and maintain written operating procedures for the licensed activity.
Safety Analysis
The regulatory foundation for the recommendation(s) associated with safety analysis includes the following:
3(1)(i) of the General Nuclear Safety and Control Regulations requires that an application for a licence shall contain a description and the results of any test, analysis or calculation performed to substantiate the information included in the application.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (c) in relation to the environment and waste management, and (d) health and safety:
o 3(c)(iii), effects on the environment that may result from the activity to be licensed and the measures that will be taken to prevent or mitigate those effects.
o 3(d)(i) the effects on the health and safety of persons that may result from the activity to be licensed, and the measures that will be taken to prevent or mitigate those effects
The regulatory foundation for the recommendation(s) associated with physical design includes the following:
Paragraph 3(1)(d) of the General Nuclear Safety and Control Regulations requires that an application for a licence shall contain a description of any nuclear facility, prescribed equipment or prescribed information to be encompassed by the licence.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (a) in relation to the plan and description of the mine or mill:
o 3(a)(ii), a surface plan indicating the boundaries of the mine or mill and the area where the activity to be licensed is proposed to be carried on.
o 3(a)(iii), a plan showing existing and planned structures, excavations and underground development.
o 3(a)(iv) a description of the mine or mill, including the installations, its purpose and capacity, and any excavations and underground development
It is a requirement of the Uranium Mines and Mills Regulations under subsection 5(2), that an application for a licence to prepare a site for and construct a uranium mill shall contain the following information in addition to the information required by section 3 and subsection 4(2):
o 5(2)(h), a description of all proposed laboratory facilities and programs.
It is a requirement of the Uranium Mines and Mills Regulations under paragraphs 6(1)(b) and 6(2)(b), that an application for a licence to operate a uranium mine and mill shall contain a description of the structures, components, systems and equipment including any changes to its design and its design operating conditions as a result of the commissioning.
It is a requirement of the Uranium Mines and Mills Regulations under paragraphs 16(1)(e) that every licensee shall keep a record of the design of the uranium mine or mill and of the components and systems installed at the mine or mill.
The regulatory foundation for the recommendation(s) associated with fitness for service includes the following:
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (a) in relation to the plan and description of the mine or mill:
o 3(a)(vii), a description of the design of and the maintenance program for every eating area.
It is a requirement of the Uranium Mines and Mills Regulations under paragraphs 16(1)(a) and 16(1)(h), that every licensee shall keep a record of its operating and maintenance procedures and the inspections and maintenance carried out in accordance with the licence or the regulations made under the Act.
Radiation Protection
The regulatory foundation for the recommendation(s) associated with radiation protection includes the following:
The General Nuclear Safety and Control Regulations require, under subsection 3(1), that a licence application contain the following information under paragraphs:
o 3(1)(e), the proposed measures to ensure compliance with the Radiation Protection Regulations.
o 3(1)(f), any proposed action level for the purpose of section 6 of the Radiation Protection Regulations.
The General Nuclear Safety and Control Regulations require, under subsection 17(b), that a worker comply with the measures established by the licensee to protect the environment and the health and safety of persons, maintain security, control the levels and doses of radiation, and control releases of radioactive nuclear substances and hazardous substances into the environment.
It is a requirement for uranium mines and mills licensee to follow the Radiation Protection Regulations.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 4(2), that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain a proposed code of practice that includes:
o 4(2)(a), any action level that the applicant considers appropriate for the purpose of this subsection.
o 4(2)(b), a description of any action that the applicant will take if an action level is reached.
o 4(2)(c), the reporting procedures that will be followed if an action level is reached.
It is a requirement of the Uranium Mines and Mills Regulations under section 9, that every licensee shall post a copy of the code of practice referred to in the licence at a location within the uranium mine or mill that is accessible to all workers and where it is most likely to come to their attention.
It is a requirement of the Uranium Mines and Mills Regulations under section 13, that no licensee shall rely on the use of a respirator to comply with the Radiation Protection Regulations unless the use of the respirator:
o 13(a), is for a temporary or unforeseen situation.
o 13(b), is permitted by the code of practice referred to in the licence.
It is a requirement of the Uranium Mines and Mills Regulations under section 14, that every licensee shall:
o 14(a), post signs at all entrances to each area where the dose rate of gamma radiation exceeds 25 µSv/h, designating the area as a radiation area and indicating the dose rate of gamma radiation in that area.
o 14(b), provide every worker who is to enter an area where the dose rate of gamma radiation exceeds 100 µSv/h with a direct-reading dosimeter.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 16(1), that every licensee shall keep a record of:
o 16(1)(f), the method and relevant data used to ascertain the doses of radiation received by the workers at the uranium mine or mill and the intake of radioactive nuclear substances by those workers.
Conventional Health and Safety
The regulatory foundation for the recommendation(s) associated with conventional health and safety includes the following:
The General Nuclear Safety and Control Regulations require, under paragraph 12(1)(c), that every licensee shall take all reasonable precautions to protect the environment and the health and safety of persons and to maintain the security of nuclear facilities and of nuclear substances.
The General Nuclear Safety and Control Regulations require, under subsection 16(1), that every licensee shall make available to all workers the health and safety information with respect to their workplace that has been collected by the licensee in accordance with the Act, the regulations made under the Act and the licence.
It is a requirement of the General Nuclear Safety and Control Regulations under section 17, that every worker shall:
o 17(a), use equipment, devices, facilities and clothing for protecting the environment or the health and safety of persons, or for determining doses of radiation, dose rates or concentrations of radioactive nuclear substances, in a responsible and reasonable manner and in accordance with the Act, the regulations made under the Act and the licence.
o 17(b), comply with the measures established by the licensee to protect the environment and the health and safety of persons, maintain security, control the levels and doses of radiation, and control releases of radioactive nuclear substances and hazardous substances into the environment.
o 17(c)(i), promptly inform the licensee or the worker’s supervisor of any situation in which the worker believes there may be a significant increase in the risk to the environment or the health and safety of persons.
o 17(e), take all reasonable precautions to ensure the worker’s own safety, the safety of the other persons at the site of the licensed activity, the protection of the environment, the protection of the public and the maintenance of the security of nuclear facilities and of nuclear substances.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (d) in relation to health and safety:
o 3(d)(i), the effects on the health and safety of persons that may result from the activity to be licensed, and the measures that will be taken to prevent or mitigate those effects.
o 3(d)(ii), the proposed program for selecting, using and maintaining personal protective equipment.
o 3(d)(iii), the proposed worker health and safety policies and programs.
AREVA’s McClean Lake Operation activities and operations must comply with the Canada Labour Code, Part II: Occupational Health and Safety.
Environmental Protection
The regulatory foundation for the recommendation(s) associated with environmental Protection includes the following:
The General Nuclear Safety and Control Regulations, under paragraphs 12(1)(c) and (f), require that each licensee take all reasonable precautions to protect the environment and the health and safety of persons, and to control the release of radioactive nuclear substances and hazardous substances within the site of the licensed activity and into the environment.
The Radiation Protection Regulations prescribe dose limits for the general public, which under subsection 1(3) is 1 mSv per calendar year.
It is a requirement of the General Nuclear Safety and Control Regulations under section 17, that every worker shall:
o 17(a), use equipment, devices, facilities and clothing for protecting the environment or the health and safety of persons, or for determining doses of radiation, dose rates or concentrations of radioactive nuclear substances, in a responsible and reasonable manner and in accordance with the Act, the regulations made under the Act and the licence.
o 17(b), comply with the measures established by the licensee to protect the environment and the health and safety of persons, maintain security, control the levels and doses of radiation, and control releases of radioactive nuclear substances and hazardous substances into the environment.
o 17(c)(i), promptly inform the licensee or the worker’s supervisor of any situation in which the worker believes there may be a significant increase in the risk to the environment or the health and safety of persons.
o 17(e), take all reasonable precautions to ensure the worker’s own safety, the safety of the other persons at the site of the licensed activity, the protection of the environment, the protection of the public and the maintenance of the security of nuclear facilities and of nuclear substances.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (c) in relation to the environment and waste management:
o 3(c)(ii), the program to determine the environmental baseline characteristics of the site and the surrounding area.
o 3(c)(iii), effects on the environment that may result from the activity to be licensed and the measures that will be taken to prevent or mitigate those effects.
o 3(c)(iv), the proposed positions for and qualifications and responsibilities of environmental protection workers.
o 3(c)(v), the proposed environmental protection policies and programs.
o 3(c)(vi), the proposed effluent and environmental monitoring programs.
o 3(c)(vii), the proposed location, the proposed maximum quantities and concentrations, and the anticipated volume and flow rate of releases of nuclear substances and hazardous substances into the environment, including its physical, chemical and radiological characteristics.
o 3(c)(viii), the proposed measures to control releases of nuclear substances and hazardous substances into the environment.
o 3(c)(ix), a description of the anticipated liquid and solid waste streams within the mine or mill, including the ingress of fresh water and any diversion or control of the flow of uncontaminated surface and ground water.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 4(2), that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain a proposed code of practice that includes:
o 4(2)(a), any action level that the applicant considers appropriate for the purpose of this subsection.
o 4(2)(b), a description of any action that the applicant will take if an action level is reached.
o 4(2)(c), the reporting procedures that will be followed if an action level is reached.
It is a requirement of the Uranium Mines and Mills Regulations under section 9, that every licensee shall post a copy of the code of practice referred to in the licence at a location within the uranium mine or mill that is accessible to all workers and where it is most likely to come to their attention.
The McClean Lake Operation operating licence requires AREVA to control, monitor and record releases of effluent concentrations from the facility and that the releases shall not exceed the limits found in the licence.
Emergency Management and Fire Protection
The regulatory foundation for the recommendation(s) associated with emergency management and response includes the following:
12(1)(c) of the General Nuclear Safety and Control Regulations states that every licensee shall take all reasonable precautions to protect the environment and the health and safety of persons and to maintain security.
12(1)(f) of the General Nuclear Safety and Control Regulations states that every licensee shall take all reasonable precautions to control the release of radioactive nuclear substances or hazardous substances within the site of the licensed activity and into the environment of the licensed activity.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (a) in relation to the plan and description of the mine or mill:
o 3(a)(ix), a description of the proposed emergency power systems and its capacities.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (c) in relation to the environment and waste management:
o 3(c)(viii), the proposed measures to control releases of nuclear substances and hazardous substances into the environment.
o 3(c)(x), the proposed measures to prevent or mitigate the effects of accidental releases of nuclear substances and hazardous substances on the environment, the health and safety of persons and the maintenance of security, including measures to:
3(c)(x)(A), assist off-site authorities in planning and preparing to limit the adverse effects of an accidental release.
3(c)(x)(B), notify off-site authorities of an accidental release or the imminence of an accidental release.
3(c)(x)(C), report information to off-site authorities during and after an accidental release.
3(c)(x)(D), assist off-site authorities in dealing with the adverse effects of an accidental release.
3(c)(x)(E), test the implementation of the measures to control the adverse effects of an accidental release.
Waste Management
The regulatory foundation for the recommendation(s) associated with waste management includes the following:
It is a requirement of the General Nuclear Safety and Control Regulations under paragraph 3(1)(j) that an application for a licence include the name, quantity, form and volume of any radioactive waste or hazardous waste that may result from the activity to be licensed, including waste that may be stored, managed, processed, or disposed of at the site of the activity to be licensed, and the proposed method for managing and disposing of that waste.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, (c) in relation to the environment and waste management:
o 3(c)(ix), a description of the anticipated liquid and solid waste streams within the mine or mill, including the ingress of fresh water and any diversion or control of the flow of uncontaminated surface and ground water.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 6(1), that an application for a licence to operate a uranium mine shall contain the following information in addition to the information required by section 3 and subsection 4(2):
o 6(1)(c), the proposed policies, methods and programs for operating and maintaining the mine.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 5(2), that an application for a licence to prepare a site for and construct a uranium mill shall contain the following information in addition to the information required by section 3 and subsection 4(2):
o 5(2)(f), a description of the proposed design, construction and operation of the waste management system, including the measures to monitor its construction and operation, the construction schedule, the contingency plans for construction and the measures to control the movement of water in existing waterways.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 6(2), that an application for a licence to operate a uranium mill shall contain the following information in addition to the information required by section 3 and subsection 4(2):
o 6(2)(c), the proposed policies, methods and programs for operating and maintaining the mill.
o 6(2)(g), a description of the proposed operation of the waste management system.
It is a requirement of the Uranium Mines and Mills Regulations under subsection 16(1), that every licensee shall keep a record of:
o 16(1)(d), the plans of every tailings-containment structure and area and every diversion structure and system associated with the waste management system.
Security
The regulatory foundation for the recommendation(s) associated with security includes the following:
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 3(1), that an application for a licence shall contain the following information:
o 3(1)(g), the proposed measures to control access to the site of the activity to be licensed and the nuclear substance, prescribed equipment or prescribed information.
o 3(1)(h), the proposed measures to prevent loss or illegal use, possession or removal of the nuclear substance, prescribed equipment or prescribed information.
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 12(1), that every licensee shall:
o 12(1)(g), implement measures for alerting the licensee to the illegal use or removal of a nuclear substance, prescribed equipment or prescribed information, or the illegal use of a nuclear facility.
o 12(1)(h), implement measures for alerting the licensee to acts of sabotage or attempted sabotage anywhere at the site of the licensed activity.
It is a requirement of the General Nuclear Safety and Control Regulations under section 17, that every worker shall:
o 17(c), promptly inform the licensee or the worker’s supervisor of any situation in which the worker believes there may be;
o 17(c)(ii), a threat to the maintenance of the security of nuclear facilities and of nuclear substances or an incident with respect to such security.
o 17(c)(iv), an act of sabotage, theft, loss or illegal use or possession of a nuclear substance, prescribed equipment or prescribed information.
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 29(1), that every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
o 29(1)(f), information that reveals the incipient failure, abnormal degradation or weakening of any component or system at the site of the licensed activity, the failure of which could have a serious adverse effect on the environment or constitutes or is likely to constitute or contribute to a serious risk to the health and safety of persons or the maintenance of security.
o 29(1)(g), an actual, threatened or planned work disruption by workers.
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 29(2), that every licensee who becomes aware of a situation referred to in subsection (1) shall file a full report of the situation with the Commission within 21 days after becoming aware of it, unless some other period is specified in the licence, and the report shall contain the following information:
o 29(2)(d), the effects on the environment, the health and safety of persons and the maintenance of security that have resulted or may result from the situation.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations,
o 3(e) in relation to security, the proposed measures to alert the licensee to acts of sabotage or attempted sabotage at the mine or mill.
The regulatory foundation for the recommendation(s) associated with safeguards and non-proliferation includes the following:
It is a requirement of the General Nuclear Safety and Control Regulations under paragraph 12(1)(i) that each licensee take all necessary measures to facilitate Canada’s compliance with any applicable safeguards agreement.
Under subsection 21(1) of the General Nuclear Safety and Control Regulations, information that concerns any of the following, including a record of that information, is prescribed information for the purposes of the Act:
o 21(1)(a), a nuclear substance that is required for the design, production, use, operation or maintenance of a nuclear weapon or nuclear explosive device, including the properties of the nuclear substance.
o 21(1)(b), the design, production, use, operation or maintenance of a nuclear weapon or nuclear explosive device.
o 21(1)(c), the security arrangements, security equipment, security systems and security procedures established by a licensee in accordance with the Act, the regulations made under the Act or the licence, and any incident relating to security.
o 21(1)(d), the route or schedule for the transport of Category I, II or III nuclear material, as defined in section 1 of the Nuclear Security Regulations.
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 30(1), that every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the situation and of any action that the licensee has taken or proposes to take with respect to it:
o 30(1)(a), interference with or an interruption in the operation of safeguards equipment or the alteration, defacement or breakage of a safeguards seal, other than in accordance with the safeguards agreement, the Act, the regulations made under the Act or the licence.
o 30(1)(b), the theft, loss or sabotage of safeguards equipment or samples collected for the purpose of a safeguards inspection, damage to such equipment or samples, or the illegal use, possession, operation or removal of such equipment or samples.
It is a requirement of the General Nuclear Safety and Control Regulations under subsection 30(2), that every licensee who becomes aware of a situation referred to in subsection (1) shall file a full report of the situation with the Commission within 21 days after becoming aware of it, unless some other period is specified in the licence, and the report shall contain the following information:
o 30(2)(a), the date, time and location of becoming aware of the situation.
o 30(2)(b), a description of the situation and the circumstances.
o 30(2)(c), the probable cause of the situation.
o 30(2)(d), the adverse effects on the environment, the health and safety of persons and the maintenance of national and international security that have resulted or may result from the situation.
The Agreement between the Government of Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons.
The Protocol Additional to the Agreement between Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons.
Packaging and Transport
AREVA’s McClean Lake Operation is required to comply with the Packaging and Transport of Nuclear Substances Regulations 2015 and Transport Canada’s Transportation of Dangerous Goods Regulations.
Decommissioning Strategy and Financial Guarantees
The regulatory foundation for the recommendation(s) associated with AREVA’s McClean Lake Operation’s Decommissioning Strategy and Financial Guarantees includes:
The General Nuclear Safety and Control Regulations requires under paragraph 3(1)(l) that a licence application contains a description of any proposed financial guarantee relating to the activity to be licensed.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, in relation to the plan and description of the mine or mill:
o 3(a)(viii), the proposed plan for the decommissioning of the mine or mill.
It is a requirement of the Uranium Mines and Mills Regulations under section 3, that an application for a licence in respect of a uranium mine or mill, other than a licence to abandon, shall contain the following information in addition to the information required by section 3 of the General Nuclear Safety and Control Regulations, in relation to the environment and waste management:
o 3(c)(i), the program to inform persons living in the vicinity of the mine or mill of the general nature and characteristics of the anticipated effects of the activity to be licensed on the environment and the health and safety of persons.
C.2 Technical Basis The technical basis for recommendations, including several guidance documents, national standards and regulatory documents has been presented in this CMD and is addressed in detail in the LCH.
D.1 Safety and Control Areas Defined The functional areas of a licensed facility or activity consist of a standard set of safety and control areas (SCAs). SCAs are technical topics used across all CNSC regulated facilities and activities to assess, evaluate, review, verify and report on licensee regulatory requirements and performance. The safety and control areas identified in subsection 2.2, and discussed in summary in subsections 3.1 through 3.14 are comprised of specific areas of regulatory interest which vary between licensed facilities. The following table provides a high-level definition for each SCA. The specific areas relevant to each SCA for the MLO are identified in D.2.
SAFETY AND CONTROL AREA FRAMEWORK Functional
Area Safety and
Control Area Definition
Management Management system
Covers the framework which establishes the processes and programs required to ensure an organization achieves its safety objectives and continuously monitors its performance against these objectives and fostering a healthy safety culture.
Human performance management
Covers activities that enable effective human performance through the development and implementation of processes that ensure that licensee staff is sufficient in number in all relevant job areas and that licensee staff have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties.
Operating performance
This includes an overall review of the conduct of the licensed activities and the activities that enable effective performance.
Facility and equipment
Safety analysis Covers maintenance of the safety analysis that supports that overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards.
Physical design Relates to activities that impact on the ability of systems, components and structures to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account.
Covers activities that impact on the physical condition of systems, components and structures to ensure that they remain effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so.
Core control processes
Radiation protection
Covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained ALARA.
Conventional health and safety
Covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment.
Environmental protection
Covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities.
Emergency management and fire protection
Covers emergency plans and emergency preparedness programs which exist for emergencies and for non-routine conditions. This also includes any results of exercise participation.
Waste management
Covers internal waste-related programs which form part of the facility’s operations up to the point where the waste is removed from the facility to a separate waste management facility. Also covers the planning for decommissioning.
Security Covers the programs required to implement and support the security requirements stipulated in the regulations, in their licence, in orders, or in expectations for their facility or activity.
Safeguards and non-proliferation
Covers the programs and activities required for the successful implementation of the obligations arising from the Canada/IAEA safeguards agreements, as well as all other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons.
Packaging and transport
Programs that cover the safe packaging and transport of nuclear substances to and from the licensed facility.
The following table identifies the revision history of this document.
Revisionnumber Change Summaryofchanges Date
000 Initial release N/A
001
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EXECUTIVESUMMARY
The Canadian Nuclear Safety Commission (CNSC) conducts environmental assessments (EA) under the Nuclear Safety and Control Act (NSCA) for all projects in accordance with its mandate to ensure the protection of the environment and the health of persons. The safety component of CNSC’s mandate is covered in the safety case assessment carried out for all projects.
This EA Report, written by CNSC staff for the Commission and the public, describes the findings of the EA under the NSCA completed for the licence application by AREVA Resources Canada Inc. (AREVA) to renew the McClean Lake Operation Uranium Mine Operating Licence (UMOL-MINEMILL-McCLEAN.01/2017 issued July 1, 2009 and expiring June 30, 2017). This licence covers the operation and modification of the McClean Lake Operation for the mining of uranium and the production of uranium concentrate; and the ability to import, possess, use, store, transfer and dispose of nuclear substances and radiation devices.
This EA Report includes CNSC staff’s assessment of the licence application and the documents submitted in support of the application, annual environmental monitoring reports, the results of previous studies, compliance verification activities (e.g., inspections, audits, and reviews) conducted at the McClean Lake Operation, as well as the findings of CNSC’s Independent Environmental Monitoring Program (IEMP).
The EA Report focuses on items that are of current public and regulatory interest such as releases to air and surface water, as well as the health of the surrounding human populations, and the protection of groundwater, surface water, aquatic, and terrestrial environments.
CNSC staff’s conclusions are based on, but are not limited to, the following:
AREVA’s environmental protection programs which meet CNSC regulatory requirements.
The findings and methodology of AREVA’s 2016 updated Environmental Risk Assessment (ERA).
The results of CNSC’s 2016 IEMP that confirm the public and the environment in the vicinity of the McClean Lake Operation are protected from the releases of the facility.
Based on the EA under the NSCA conducted for this licence application, CNSC staff conclude that AREVA has made, and will continue to make, adequate provision for the protection of the environment and the health of persons.
ListofTablesTable 2.1: Summary of the McClean Lake Operation Environmental Risk Assessment conclusions ................................................................................................................................................ 10
Table 2.2: Annual monthly mean concentrations of treated effluent released to the environment between 2009 to the second quarter of 2016 ...................................................................................... 13
Table 2.3: Previously completed EAs under Federal EA processes for the McClean Lake Operation ................................................................................................................................................... 19
Table 3.1 Species at Risk that may occur in the local assessment boundary ................................ 25
Table 4.1: Summary of the McClean Lake IEMP 2016 results ......................................................... 48
Table 4.2: Summary of the McClean Lake IEMP 2016 Results – Radioactivity in Food .............. 49
Table 4.3: Summary of McClean Lake IEMP 2016 Results – Chemical Parameters in Food ..... 50
ListofFigures
Figure 1.1: Location of McClean Lake Operation .................................................................................. 5
Figure 1.2: McClean Lake Operation General Site Layout ................................................................. 6
Figure 3.1: Geographic location and surroundings of the McClean Lake Operation ..................... 21
Figure 3.2: Conceptual Site Model – Project Releases ...................................................................... 30
Figure 3.3: Conceptual Site Model – Environmental Risk Assessment ........................................... 31
Figure 4.1.1: Overview of McClean Lake Operation IEMP Sampling Program .............................. 44
Figure 4.1.2: Locations of 2016 IEMP Samples near McClean Lake Operation ............................ 45
Figure 4.1.3: Locations of 2016 IEMP Samples near McClean Lake Operation ............................ 46
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1.0 INTRODUCTION
1.1 PurposeThe purpose of this Environmental Assessment (EA) Report (EA Report) is to document the results of the EA conducted under the Nuclear Safety and Control Act (NSCA) for the McClean Lake Uranium Mine and Mill. This EA report is presented in support of CNSC staff’s review of the licence application by AREVA Resources Canada Inc. (AREVA) to renew the McClean Lake Operation Uranium Mine Operating Licence (UMOL-MINEMILL-McCLEAN.01/2017) for a period of 12 years [1]. The EA under the NSCA was conducted to determine whether AREVA has made, and will continue to make, adequate provisions for the protection of the environment and the health of persons, and to support the CNSC staff recommendation to the Commission to renew the Uranium Mine Operating Licence (UMOL) for the McClean Lake Operation.
This EA Report will be used as a mechanism to communicate to the public, Indigenous communities and the Commission the current status of the facility and its activities. It will also summarize CNSC staff’s review of the 2016 Environmental Performance Technical Information Documents, Volume 1: Environmental Monitoring [2], and Volume 2: Environmental Risk Assessment (ERA) [3], the McClean Lake Operation – Notification of modification to the JEB Tailings Management Facility (JEB TMF) Expansion Project [4], and the updated Preliminary Decommissioning Plan (PDP) [5].
This EA Report is based on information submitted by AREVA and activities completed by CNSC staff which includes the following:
regulatory oversight (section 2)
CNSC staff review of the most recently submitted ERA by AREVA, including CNSC staff’s review of the notification of modification to the JEB TMF Expansion Project (section 2.1.1)
CNSC staff review of the preliminary decommissioning plan (section 2.2)
update on the status of the environment (section 3)
Independent Environmental Monitoring Program (IEMP) results (section 4)
An analysis has been conducted for all components related to the project, but only a selection of topics are presented in detail in this report. Topics were selected as those being of interest to the Commission, members of the public, Indigenous communities, or of regulatory interest. These topics are atmospheric, aquatic, geological and hydrogeological, and terrestrial environments and human health.
CNSC staff assess the environment at each phase of a project, and will continue to do so until the decommissioning and abandonment of the site. An EA under the NSCA is also carried out at each phase for the entire lifecycle of the project.
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1.2 BackgroundThe current McClean Lake Operation UMOL will expire on June 30, 2017. On August 22, 2016, AREVA submitted an application for the renewal of its licence for a period of 12 years. This UMOL encompasses operations for the entirety of the McClean Lake Operation, including the operation and modification of a nuclear facility for the mining of uranium and the production of uranium concentrate; and the ability to import, possess, use, store, transfer and dispose of nuclear substances and radiation devices.
As part of the application for renewal of the McClean Lake Operation UMOL, AREVA provided CNSC with a list of potential activities that may occur over the proposed licensing term. Included in this list is the expansion of the JEB TMF. It is important to note that this project was taken into consideration in AREVA’s most recent ERA [3] submitted in September 2016, and therefore any potential impacts from this project have been included in the predicted environmental effects assessment as documented in section 3.2 of this report.
1.2.1 Site Operations and History
The McClean Lake Operation is located approximately 15 km west of Wollaston Lake in northern Saskatchewan (Figure 1.1). The site consists of three main areas (Figure 1.2):
the JEB area which includes the permanent camp, the McClean Lake mill (previously referred to as the JEB mill), the JEB TMF, the clean waste rock management area, and the JEB water treatment plant (WTP)
the Sue mining area which includes the mined out Sue A/C, Sue B, and Sue E pits, and the Sue WTP
the Sink/Vulture Treated Effluent Management System (S/V TEMS) which includes Sink Reservoir and its control structure, Vulture Lake, and the effluent diffuser system which discharges effluent into the east basin of McClean Lake
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Figure 1.1: Location of McClean Lake Operation
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Figure 1.2: McClean Lake Operation General Site Layout
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1.2.2 Overview of Licensing History
The uranium deposits in the McClean Lake region were initially discovered in 1979. Exploration continued throughout the 1980s and a proposal to develop the ‘McClean Lake Project’ was developed in the early 1990s together with several other uranium mine projects in northern Saskatchewan, including Midwest, McArthur River and Cigar Lake, and the expansion of the existing Cluff Lake mine.
The federal Environmental Assessment Review Process Guidelines Order (EARPGO) appointed a joint federal-provincial EA review panel (Joint Panel) to study uranium mine developments in northern Saskatchewan and to assess their acceptability.
The McClean Lake Project was part of the Joint Panel review from 1991 to 1993. The Project was considered as a stand-alone development and was given government approval in December 1993 [6]. Construction began in 1994 and the JEB ore body was mined from 1995 to 1997. However, as the review of uranium developments in northern Saskatchewan continued, the Joint Panel acknowledged the potential environmental benefits of milling and tailings storage from several mines at one site. As a result, the McClean Lake Project grew to include the milling and tailings storage associated with the ore from the Midwest and the Cigar Lake projects [7] [8], with an annual mill production rate of up to 24 million pounds of Triuranium octoxide (U3O8) per year. The resultant tailings are stored at the McClean Lake site, in the JEB TMF. Government approvals for these two projects were issued in 1998. Licensing for the construction of the expanded JEB mill to receive ore from the Cigar Lake mine was granted and work was completed in 2006.
The CNSC has issued several licences for activities at McClean Lake, all of which were subject to the CNSC’s staged licensing process. As a result, the uranium production facility has developed in stages. Extraction of the ore at McClean Lake began in 1996 and ore processing into yellowcake product commenced in 1999.
In 2005, the McClean Lake Operation began construction of the Mill Expansion Project, including construction activities to modify the McClean Lake mill for receipt and processing of high grade ore slurry from the Cigar Lake mine. In 2012, AREVA received approval from the CNSC to operate the high grade ore slurry receiving circuit and high grade ore milling circuits, to process high grade ore from the McArthur River mine and to increase the licensed annual production to match the McClean Lake mill’s capacity of 13 million pounds. In 2012, AREVA submitted a notification to the CNSC and application to the Saskatchewan Ministry of Environment to construct the McClean Lake Upgrade Project, which would increase the mill’s capacity to 24 million pounds per year. Approval of the McClean Lake Upgrade Project was included as an amendment to the McClean Lake Operation’s Licence Condition Handbook (LCH).
Since the initial start-up of the McClean Lake Operation in 1999, there have been several projects and activities at the site which were not within the scope of the Joint Panel’s review. These projects underwent EA’s under the Canadian Environmental Assessment Act, 1992, (CEAA), as outlined in table 2.3.
In July 2009, AREVA’s UMOL was renewed for an eight-year period from the end of the previous licence to June 30, 2017.
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This EA report has been prepared to address AREVA’s application to renew its licence to June 2029.
2.0 REGULATORYOVERSIGHTThe CNSC regulates nuclear facilities and activities in Canada to prevent unreasonable risk to the environment and health of persons in a manner that is consistent with federal and provincial environmental legislation, Canadian policies, and with Canada’s international obligations.
To meet CNSC’s regulatory requirements, AREVA is responsible for implementing and maintaining environmental protection measures that identify, control, and (where necessary) monitor all releases of radioactive and hazardous substances and effects on the environment, including the public, from the McClean Lake Operation. These environmental protection measures must comply with, or have implementation plans in place to comply with, the regulatory requirements and technical requirements and guidelines set out in:
CSA N288.4-15, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills [10]
CSA N288.5-11, Effluent monitoring program at Class I nuclear facilities and uranium mines and mills [11]
CSA N288.6-12, Environmental risk assessment at Class I nuclear facilities and uranium mines and mills [12]
CSA N288.7-15, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills [13]
CSA N294-09, Decommissioning of facilities containing nuclear substances [14]
Compliance activities of verification, enforcement and reporting are in place to ensure that CNSC licensees exhibit a high level of compliance with CNSC’s regulatory framework. AREVA is required to submit to the CNSC an annual environmental monitoring report that details the results of the environmental protection measures related to the operations of the site. These annual reports are reviewed by CNSC staff and are available upon request.
The following sections provide information on CNSC’s regulatory oversight of environmental protection measures at the McClean Lake Operation.
2.1 EnvironmentalProtectionMeasuresEnvironmental protection measures identify, control, and monitor releases of radioactive and hazardous substances from facilities or activities. Environmental protection measures are an important component of the overall requirement for licensees to make adequate provision for protection of the environment and the health of persons. (Note: environmental protection measures may also be referred to as environmental protection programs)
The necessary environmental protection measures required for the McClean Lake Operation are described in this section.
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2.1.1 Environmental Risk Assessment
An ERA is a systematic process that evaluates the likelihood that adverse effects may occur or are occurring as a result of physical disturbances (stressors) or releases of radioactive or hazardous substances, and the severity or significance of those adverse effects. An ERA is a practice or methodology that provides science-based information to support decision-making and to prioritize the implementation of mitigation measures.
An ERA:
identifies proposed activity characteristics and site-specific environmental characteristics
identifies interactions between activities and the environment
assesses the likelihood and significance of these interactions and the resulting potential effects on the environment and the health of persons
will be used to demonstrate protection of the environment and human health under the NSCA, and should be conducted every five years or when major changes have occurred to the facility, or new scientific information is available [12]
AREVA submitted an updated ERA as per CSA standard N28.8.6-12 Environmental risk assessment at Class I nuclear facilities and uranium mines and mills [12] in September 2016 [3]. ERAs have been previously conducted for the McClean Lake Operation and AREVA has used the results effectively to assess environmental performance relative to ERA predictions within a 5-year Environmental Performance Technical Information Document [2] [3]. CNSC staff reviewed the 2016 ERA and determined it to be compliant with the CSA standard.
The objective of the ERA for the McClean Lake Operation was to provide an update of the assessment of the risks from the emissions from the current and future anticipated site operations on human health and the environment. The purpose of the ERA was to refine model inputs to conduct a multi-tier human health and ecological risk assessment for radiological and non-radiological (i.e., chemical) contaminants of potential concern (COPCs) and compare the results to previous predictions. Further, the updated ERA is a method to identify opportunities for continual improvement and the need for additional mitigation measures if required.
AREVA’s predictions and conclusions of the ERA are summarized in table 2.1. The predicted ecological and human health risks due to releases to air and water from the McClean Lake Operation are generally consistent with the overall conclusions of the original EAs, the 1991 Environmental Impact Statement for the McClean Lake Project [15] and the 1995 Cigar Lake Project [16] which assessed the impact of milling of Cigar Lake ore at the McClean Lake Operation.
The rate and volume of water released to the downstream environment is controlled by weirs at the outlet of Sink Reservoir and Vulture Lake to limit changes to the downstream water levels. Surface water enters McClean Lake East from Vulture Lake via a discharge pipeline. Sink Reservoir and Vulture Lake are referred to as the Sink/Vulture Treatment System (S/V TEMS).
The ERA predicts a potential short-term impact (2016 to 2020) to fish, duck, and mammals and birds feeding on emergent aquatic insects in McClean Lake East due to selenium exposure. This short-term impact will be mitigated after the installation of additional effluent treatment to
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address the comparatively high selenium concentrations present in the Cigar Lake ore. The ERA assessed the potential impact to species at risk that could be present in the local study area (LSA). Potential habitat for leopard frog and rusty blackbird, assessed as Species of Special Concern and olive-sided flycatcher and common nighthawk, listed as Threatened Species according to the Species at Risk Act exists in the LSA. CNSC staff have recommended that AREVA confirms the presence or absence of these species in the LSA, and if these species are present, AREVA should submit a plan for further studies to assess the potential impact.
Table 2.1: Summary of the McClean Lake Operation Environmental Risk Assessment conclusions
Stressor
type
Members of the
public
Aquatic biota Terrestrial biota
Radiological
No adverse effects expected from radiological COPCs released from the McClean Lake Operation
No adverse effects expected from radiological COPCs released from the McClean Lake Operation
No adverse effects expected from radiological COPCs released from the McClean Lake Operation
Non-radiological
No adverse effects expected from most non-radiological COPCs released from the McClean Lake Operation beyond the S/V TEMS with the exception of exposure to selenium through the consumption of fish and duck
No adverse effects expected from most non-radiological COPCs released from the McClean Lake Operation beyond the S/V TEMS with the exception of potential effects to fish and mammals that live in aquatic habitat from selenium exposure.
No adverse effects expected from most non-radiological COPCs released from the McClean Lake Operation beyond the S/V TEMS with the exception of potential effects to birds feeding on emergent aquatic insects from selenium exposure.
The ERA included an assessment of risks from selenium and concluded potential short term impacts due to selenium exposure. As outlined in sections 2.1.3.1 and 3.2, AREVA has implemented a selenium adaptive management plan in order to ensure that all possible measures to minimize selenium releases are taken, in the interim 4-year period prior to commissioning a long-term treatment facility in 2020. In November 2016, AREVA also submitted an update on selenium risks that provided a forecast of expected selenium concentrations in treated effluent. This assessment predicted that selenium concentrations will be much lower than those assumed in the ERA (at or below 40 µg/L) thereby reducing the potential impacts to fish, mammals and birds. Additional mitigation measures will also be put into place such as increased water quality monitoring and supplemental studies on fish health, if required, to ensure that fish tissue in McClean Lake east basin remains below the U.S. EPA fish tissue criterion for selenium.
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2.1.1.1 JEB TMF Expansion Project
AREVA has operated the JEB TMF since 1999 and is currently authorized for disposal of tailings in the JEB TMF up to a consolidated tailings elevation of 434 metres above sea level (mASL), which corresponds to the top of the sandstone formation. The tailings elevation authorization corresponds with the Joint Panel [8] recommendation that tailings, after consolidation, should not be above the top of the sandstone formation.
The Government of Saskatchewan nuanced the Joint Panel’s recommendation by recommending that tailings should not be allowed above the top of sandstone formation unless it can be demonstrated that environmental impacts would not compromise environmental objectives for the facility. As such, AREVA proceeded with an assessment of alternatives that included:
a new purposely built pit
expanding the current JEB TMF to the ground surface for additional tailings capacity using clay liners (AREVA’s preferred alternative)
the use of existing open pits
CNSC staff reviewed the alternatives assessment against the expectations of CNSC RD/GD-370, Management of Uranium Mine Waste Rock and Mill Tailings, [17] and found the assessment to meet its expectations.
In June 2016, AREVA submitted a request to expand the JEB TMF to modify/expand the outer perimeter to accommodate disposal of tailings to a consolidated tailings elevation of 448 mASL. The proposed expansion project would provide additional tailings capacity of 1.7 million cubic meters and would require:
construction of an embankment around a portion of the JEB TMF perimeter to bring the low-side elevation up from 448 mASL to 457.5 mASL
placement of a processed waste rock/till bentonite-amended liner for hydraulic containment throughout operations
AREVA has projected that the un-consolidated tailings will consolidate and return below the current ground surface post-closure, but above the top of the underlying sandstone formation.
AREVA’s ERA indicated that the sandstone and clay liner surrounding the tailings mass up to the ground surface and the engineered cover on top of the tailings would limit contaminant infiltration into the groundwater. Therefore, AREVA predicted that the worst case concentrations of metals and radionuclides in surface water of the adjacent Fox and Pat Lakes after the closure of the JEB TMF will remain similar to baseline concentrations except for sulphate, ammonia, arsenic, molybdenum, nickel and uranium. Although above baseline, these contaminants are expected to remain below federal water quality guidelines and provincial surface water quality objectives. Therefore, AREVA predicted no impacts to Fox and Pat Lakes as a result of this expansion project. AREVA also concluded that the JEB TMF Expansion Project would not lead to significant impact to humans.
CNSC staff reviewed AREVA’s long-term predictions of levels of contaminants in Fox and Pat Lake as a result of the JEB TMF Expansion Project proposal under the NSCA and relative to
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previous EAs, including relevant Joint Panel recommendations. In particular, the Joint Panel recommended that AREVA demonstrate experimentally that pore-water contaminant concentrations can be maintained at acceptable levels in aged tailings and that the adjacent Fox Lake must not be used as a mixing zone [8]. In order to reduce uncertainty in the long-term predictions, on December 22, 2016, CNSC staff requested further information to be provided in advance of the public hearing [18]. In particular, CNSC staff members requested that AREVA provide additional information on aspects of the source term (i.e., arsenic, polonium, radium), performance of the cover (i.e., infiltration rate), engineering design and verification, and contingency measures in case of liner failure. AREVA submitted additional information to CNSC on February 8 and 27, 2017 [35] [36]. CNSC staff have completed their technical review and have accepted AREVA’s proposal to expand the JEB TMF. As required by CNSC staff, AREVA has committed to provide construction details prior to initiating construction activities for CNSC staff review and acceptance.
2.1.2 Environmental Management System
An Environmental Management System (EMS) refers to the management of an organization’s environmental policies, programs and procedures in a comprehensive, systematic, planned, and documented manner. It includes the organizational structure, planning and resources for developing, implementing, and maintaining policies related to environmental protection.
An EMS is the integrated set of documented activities (policies, programs, and procedures) that provide a framework for action with respect to environmental protection. An EMS includes:
control measures on releases and wastes to prevent or mitigate environmental effects
demonstration of the effectiveness of those control measures
training of personnel
public disclosure and information
AREVA has developed and is maintaining a corporate EMS to describe the activities associated with the protection of the environment at the McClean Lake Operation. AREVA’s EMS is described in its approved Integrated Quality Management System manual and includes activities such as establishing annual environmental objectives and targets, which are reviewed and assessed by CNSC staff through compliance verification activities.
AREVA conducts internal audits to determine whether the EMS has been properly implemented and maintained. AREVA documents any deficiencies and findings that are identified from the internal audit and devises a plan to address any non-conformance items. AREVA verifies compliance of its EMS through an annual management review, and documents minutes and follow-up actions. CNSC staff review their documents as part of compliance verification. The results of this review demonstrate that AREVA is meeting CNSC requirements as outlined in section 4.6 of REGDOC 2.9.1 [9], and that identified issues are being addressed.
2.1.3 Effluent and Emissions Control and Monitoring
Controls on releases to the environment are established to provide protection to the environment and to meet the principles of sustainable development, pollution prevention, and continuous
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improvement. The effluent and emissions control measures are established on best industry practice and incorporate the results of the ERA.
Licensee’s effluent and emissions monitoring is the primary indicator of performance in terms of releases to air, surface water, groundwater, and soil from both activity operations and waste management activities. This type of monitoring addresses both the nature and quantities of releases of radioactive and hazardous substances.
AREVA has implemented and maintained an (effluent and emissions) environmental monitoring program (EMP) at the McClean Lake Operation. Table 2.2 shows the annual monthly mean concentration of the major COPCs in the treated effluent discharged from the JEB water treatment plant to Sink Reservoir during the previous licence period between 2009 and the second quarter of 2016. The release limits are obtained from the Metal Mining Effluent Regulations (MMER). As shown in table 2.2, all effluent releases have remained below the release limits.
Table 2.2: Annual monthly mean concentrations of treated effluent released to the environment between 2009 to the second quarter of 2016
(a) pH taken from daily discharge samples. It is not measured in monthly composite samples (b) provincial limits (c) no provincial or federal limit is available. (d) interim action level (e) McClean Lake currently does not have an action level for Mo; the internal administrative level is presented
in it’s place (f) 2016 values are based on data up until second quarter of 2016
For effluent discharge, short term action levels were calculated as 80% of maximum monthly arithmetic mean concentrations of key parameters in treated effluent. These action levels are applied to individual composite samples of effluent discharged from the Sue and JEB WTPs. A composite sample is a quantity of effluent that has been collected at an equal rate, or at a rate proportionate to the flow over a sampling period, between 7 to 24 hours. Action levels are
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established for key indicator parameters of performance for the WTPs. Action levels exist for arsenic, nickel, total suspended solids, pH, radium-226, and uranium. AREVA is currently assessing their existing action levels for environmental releases to ensure compliance with the newly published CSA Group Standard N288.8-17, Establishing and implementing action levels for releases to the environment from nuclear facilities, by December 2017.
In 2014, the McClean Lake mill restarted and began processing Cigar Lake ore. Since restarting the mill, the selenium in the effluent from the JEB WTP has been steadily increasing in concentration because of the higher selenium concentrations in Cigar Lake ore relative to McClean Lake ore. In response, AREVA proactively developed a selenium adaptive management plan, including a Selenium Risk Management Plan, to reduce releases of selenium to the receiving environment. CNSC staff reviewed AREVA’s resultant Selenium Risk Management Plan and accepted it in November 2016. See section 2.1.3.1 below for background and further details.
Based on review and assessment of the results presented in AREVA’s reports and compliance verification activities, CNSC staff conclude that the effluent monitoring program currently in place for the McClean Lake Operation continues to provide adequate protection to the environment.
2.1.3.1 Control of Selenium Releases to the Environment
Selenium has been identified as a COPC for uranium mining under the NSCA. It has been determined that releases below the Saskatchewan Government effluent licence limit (0.6 mg/L) can pose an unreasonable risk to the environment depending on the environmental and biological characteristics of the receiving environment. As a result, since 2004, the CNSC has required uranium mines and mills to monitor releases to, and within, the aquatic environment and where necessary, complete advanced field investigations to determine whether additional treatment systems are required. To date, treatment system upgrades have been necessary at the Rabbit Lake and Key Lake Operations, with all other facilities continuously assessing current and future risks associated with this substance through their site-specific ERA. This approach places the CNSC at the forefront of selenium regulation in Canada. Regulation of selenium at the national level is currently being considered under both the Fisheries Act via the latest proposals to amend the Metal Mining Effluent Regulations (MMER) and the Canadian Environmental Protection Act, 1999 (CEPA 1999) recent draft proposal declaring selenium a CEPA toxic substance. Additional information on the potential effects of selenium in the McClean Lake receiving environment is discussed in section 3.2 of this EA report.
As an outcome of CNSC’s review of AREVA’s Selenium Risk Management Plan, AREVA developed interim administrative and action levels for selenium at the JEB WTP. The interim administrative level for selenium is 0.084 mg/L and will be applied to individual pond selenium concentrations. The interim action level for selenium is 0.112 mg/L and will be applied to individual pond discharge results collected at the final point of discharge to ensure administrative action levels are not reached. The interim selenium administrative and action levels are incorporated into AREVA’s most recent Environmental Code of Practice submitted to CNSC staff in October 2016 [19]. CNSC staff reviewed and accepted the Environmental Code of Practice. AREVA will review the interim administrative and action levels annually to determine whether these levels remain adequate, or need to be revised to reflect actual performance and
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predicted performance for the subsequent year. The interim administrative and action levels will serve to ensure control and oversight of selenium releases until AREVA commissions their new selenium treatment technology in 2020.
As previously stated, AREVA proactively triggered adaptive management for selenium in 2014 as a result of the steadily increasing selenium concentration in effluent resulting from the processing of Cigar Lake ore. AREVA included a Selenium Risk Management Field Studies Plan in the Selenium Risk Management Plan and initiated a process to determine a long-term selenium treatment option considering best available technology economically achievable (BATEA). Some technologies currently being considered by AREVA are ion exchange and zero valent iron. In November 2016, AREVA submitted an Update on Selenium Risks and Improvement Initiatives which describes continuous improvement techniques being implemented to reduce selenium concentrations in the interim four year period prior to commissioning of a long-term treatment solution and to ensure that all possible measures to minimize selenium releases are taken.
CNSC staff requested that AREVA develop a formal Selenium Adaptive Management Plan, to incorporate the following strategies: Pollution Prevention Plan, BATEA assessment of available technologies and techniques, and an Active Commissioning Plan for the selected technology. The Pollution Prevention Plan will include a description of the continuous improvement techniques that were implemented, or will be implemented in the interim, to keep selenium concentrations and loadings to the environment as low as reasonably achievable (ALARA). The BATEA Assessment will include a characterization of selenium source terms in the effluent to the JEB WTP, an options analysis of available treatment technologies and development of an appropriate design objective for selenium treatment. The design objective will be used during the options analysis to inform the selection of the appropriate technology and techniques. The Active Commissioning Plan will contain AREVA’s plan for the commissioning of the selected treatment technology, including information on its operational performance and performance assessment, as well as the training process, and established standard operating procedures for the selected treatment option.
2.1.4 Environmental Monitoring
AREVA’s EMP is designed to sample, measure, analyze, interpret and report the following in the vicinity of the McClean Lake Operation:
concentration of nuclear and hazardous substances in environmental media
effect, or lack of effect, on biological organisms or communities if such potential is predicted by the ERA or required by legislation
intensity of physical stressors and their potential effect on human health and the environment
physical, chemical and biological parameters of the environment normally considered in the design of the environmental monitoring necessary to support the interpretation of the results
As a result of this program, AREVA collects environmental samples from different locations near the McClean Lake Operation. The samples are sent to the Saskatchewan Research Council (SRC) Analytical Laboratory for analysis. Data from the program are also used to assess the
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human health impacts resulting from the routine operation of the McClean Lake Operation and to verify predictions made in ERAs. The ambient air monitoring program is comprised of quarterly high-volume air samplers and semi-annually integrated radon sampling. The soil and terrestrial vegetation monitoring program consists of sampling soil, lichen, blueberries, and Labrador tea at select locations around the facility and local area every three years. The McClean Lake Operation also has benthic macroinvertebrate, sediment quality, fish monitoring, and groundwater monitoring programs.
As part of their surface water quality monitoring program, AREVA samples surface water at twenty lakes around the site at varying intervals. These samples are submitted to SRC Analytical Laboratory and are analyzed for heavy metals, radionuclides, nutrients and general chemistry. The results are compared against the Saskatchewan Surface Water Quality Objectives (SSWQO) and are reported to the CNSC on a quarterly basis. CNSC staff reviewed the surface water quality results and conclude that there is minimal risk to the environment. The results are consistent with baseline and historic results and are consistently below the SSWQO.
AREVA submitted an updated Environmental Monitoring Program which has been reviewed an accepted by CNSC staff. CNSC staff verified that all treated effluent discharged to the environment complied with licence requirements during the previous licence period.
Throughout the licence term, CNSC staff conducted both focused and general compliance inspections which included various aspects of environmental protection. Most recently, an inspection focused on environmental protection was performed by CNSC staff at the McClean Lake Operation in July 2016. CNSC staff concluded from the inspection that AREVA was in compliance with their environmental protection program. All environmental related action notices and recommendations have been properly addressed by AREVA and are considered closed by CNSC staff. Environmental protection inspections have also been conducted by Saskatchewan Ministry of the Environment (SMOE) staff.
2.1.5 Public Dose
Radiological releases to the environment are controlled and monitored by the effluent and emissions control and monitoring, and environmental monitoring programs. The Radiation Protection Regulations require licensees to implement a radiation protection program for the protection of the public. The focus for radiation protection within the environmental protection framework is on radiological protection of the environment and the public.
The Radiation Protection Regulations define prescribed dose limits for workers and members of the public, and require doses to be monitored by direct measurement or by estimation of the quantities and concentrations of any nuclear substance released as a result of a proposed activity.
A human health risk assessment (HHRA) is completed for both radioactive and hazardous substances. Licensees must meet the requirements of the NSCA and the regulations for radiological protection of members of the public. AREVA’s HHRA concluded that the highest estimated annual dose to a public receptor is 0.1 mSv. CNSC staff reviewed AREVA’s assessment and concluded that public doses are below the annual public dose limit of 1 mSv.
CNSC receives reports of releases to the environment through the reporting requirements outlined in the UMOL and the LCH. These are submitted to the CNSC in the form of quarterly
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performance reports, annual compliance reports, or event reports in the case of spills. CNSC staff review these reports to ensure that no significant risk to the public or environment have occurred, and that AREVA has adequately responded to any action level exceedances or spills, by taking appropriate corrective actions and preventative measures. All environmental related incidents during the current licence term were properly investigated in a timely manner, and the resulting reports were acceptable to both CNSC staff and SMOE staff.
CNSC staff conclude that the public continues to be protected from facility effluent releases and emissions.
2.2 PreliminaryDecommissioningPlanThe McClean Lake Operation has a preliminary decommissioning plan (PDP), prepared in accordance with CSA Standard N294-09, Decommissioning of facilities containing nuclear substances [14] and submitted to the CNSC in accordance with CNSC’s Regulatory Guide G-219: Decommissioning Planning for Licensed Activities [20]. This EA report considers the full lifecycle of the project. CNSC staff examined the PDP to assess project-environment interactions until the end state of the mine.
In October 2016, AREVA submitted an updated PDP to CNSC staff [5]. The PDP was submitted in accordance with the stipulations mentioned above and in support of the licence application for the renewal of the McClean Lake Operation operating licence in 2017. The information contained within the PDP is subject to change due to, but not limited by, changes to scientific approaches, technical measures used for decommissioning activities, and the surrounding environment. It is for these reasons that licensees are required to periodically update their PDPs when seeking licence renewal for major facilities and that the CNSC licences take a phased approach. A Detailed Decommissioning Plan, with a more thorough examination of the potential effects, will be submitted by AREVA in support of their eventual application for a decommissioning licence.
The objective of the McClean Lake Operation’s PDP is to remove, minimize, and control potential contaminant sources and thereby minimize the potential for adverse environmental effects associated with the decommissioned property. The decommissioning plan is designed to return the licensed property to a state that will be safe for human and non-human biota, be both chemically and physically stable, allow utilization for traditional purposes, and minimize potential constraints on future land use planning decisions.
AREVA expressed the intention to undertake a progressive reclamation approach to decommissioning activities of the McClean Lake Operations, meaning that several decommissioning activities are carried out and completed during the operational phase of the mining operation to facilitate future work. This approach is advantageous in that it allows for the opportunity to identify technically challenging issues in advance so that appropriate measures can be taken at the appropriate time. The remainder of the decommissioning work will take place once production activities have ceased and this work is predicted to occur over a period of approximately 19 years in five phases:
1. Post-Operational Phase: Work in this phase will involve detailed work planning related to licensing and permitting processes, and preparatory clean-up activities.
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2. Initial Decommissioning Phase: All buildings/facilities that are not required for continued decommissioning and water treatment activities will be demolished during this time, as well as final closure and reclamation of areas not needed during interim phase.
3. Interim Monitoring and Tailings Consolidation Phase: Tailings will be consolidated into the existing TMF and water treatment will be required for a period of approximately 10 years post operations.
4. Final Decommissioning Phase: Remaining site infrastructure will be demolished and a cover will be constructed over the consolidated tailings in the TMF.
5. Post-Closure Monitoring Phase: The final phase entails 5 years of environmental performance monitoring to ensure that the decommissioning objectives have been met.
Once all phases have been completed and the site has been cleared of all radiological and non-radiological contamination above background levels, AREVA will be eligible to apply for a licence to abandon, releasing them from CNSC regulatory oversight as outlined in CNSC Regulatory Guide G-219: Decommissioning Planning for Licensed Activities [20].
2.3 EnvironmentalAssessmentsandReviewsThe CNSC has conducted EAs for proposed and ongoing projects at the McClean Lake Operation under the NSCA and the CEAA 2012 (and the former CEAA 1992). The purpose of an EA is to identify the possible environmental effects of a proposed project, and determine whether these effects can be mitigated, so that the environment and health of persons will be protected, before a licence decision can be made. Under the CEAA, a decision must be taken that the project, after implementation of mitigation measures, will not cause significant adverse environmental effects. Under the NSCA, the EA itself is included in the information that informs and supports the regulatory decision being sought.
The McClean Lake Operation has undergone several CEAA EA reviews related to the mine and mill. In addition, as a condition of the McClean Lake licence, extensive environmental monitoring data, including environmental effects data, has been collected since the start of mining and milling operations on the site (mid 1990’s and 1999, respectively). Table 2.3 provides a complete list of previously completed federal EA’s for the McClean Lake Operation.
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Table 2.3: Previously completed EAs under Federal EA processes for the McClean Lake Operation
Project EA start date EA decision date
Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan: Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture.
1992 October 1993
McArthur River Uranium Mine Project. Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan.
1995 February 1997
Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan: Midwest Uranium Mine Project; Cigar Lake Uranium Mine Project; Cumulative Observations.
1996 November 1997
Cigar Lake Rock disposal in the McClean Lake Mining Facility Sue C Pit, CEAA Screening Report
October 1999 August 2003
McClean Lake Operation Sue E Ore Project, CEAA Screening Report
October 2003 June 2005
Ferric Sulphate Production at the McClean Lake Operation, CEAA Screening Report
February 2006 October 2006
Rabbit Lake Solution Processing Project, CEAA Screening Report February 2005 August 2008
Proposed Caribou Project, CEAA Screening Report February 2007 April 2010
Receipt and Processing of McArthur River Ore at the McClean Lake Operation, CEAA Screening Report
February 2010 April 2012
CEAA Comprehensive Study Report for the Proposed Midwest Mining and Milling
March 2006 September 2012
2.4 EAFollow‐UpProgramA follow-up program verifies the effectiveness of mitigation measures and the accuracy of environmental predictions. Where appropriate, the results of a follow-up program may also support the implementation of adaptive management measures to address previously unanticipated adverse environmental effects.
Detailed follow up programs were identified and developed for the Sue E Project, the proposed Caribou Project and for the proposed Midwest Project. To date, neither the Caribou Project, nor the Midwest Project have advanced to the licensing stage. If AREVA proposes to carry these
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projects out and applies for licenses for these projects, the EAs will be revisited at that time, including the review and implementation of detailed EA follow-up programs.
Follow-up components of the Sue E Ore Project included hydrogeology modelling, waste rock geochemistry, waste rock pore water geochemistry, and transfer factors associated with exposures to molybdenum.
All data collection for the Sue E Ore follow-up program was completed by the end of 2010. The follow-up program report was submitted to the CNSC on March 31, 2011. Six comments were received and were addressed by the end of 2011. On January 27, 2012, the CNSC indicated that the responses were accepted and one additional comment was received regarding molybdenum transfer. This comment was addressed and all comment responses were integrated into a finalized version of the report. The finalized report was submitted to the CNSC in August 2012, and was approved on October 8, 2013. This completes the Sue E follow-up program.
3.0 STATUSOFTHEENVIRONMENTThe following sections of the EA Report include summaries of project-environment interactions that were assessed by CNSC staff and were deemed to be of specific public and/or regulatory interest including atmospheric, aquatic, geological and hydrogeological, and the terrestrial environment and human health, for the licence application by AREVA to renew the McClean Lake UMOL. It should be noted that all environmental components are regularly reviewed through annual reporting requirements and CNSC compliance verification activities.
3.1 DescriptionofBaselineEnvironment
3.1.1 Geographic and Geologic Setting
The McClean Lake Operation is located in the Athabasca Basin Ecoregion of northern Saskatchewan, approximately 350 km northeast of La Ronge near Wollaston Lake in the Boreal Shield Ecozone.
Other uranium operations in the area include Rabbit Lake, Key Lake, McArthur River, Cigar Lake and Cluff Lake decommissioned mine site. Proposed uranium mines in the area include the Midwest Project and the Millennium Project. The closest communities to the site include Wollaston Post, Uranium City, Camsell Portage, Black Lake, Stony Rapids, and Fond du Lac. The Athabasca Basin covers an area of approximately 100,000 km2.
The Athabasca Basin is composed of sandstone formations which vary in thickness from 0 m to 200 m. Underneath the sandstone is an older basement rock consisting of granite and gneiss. The sandstone formations are covered with up to 50 m of glacial deposits of silt and sand mixed with boulders and gravel.
The Athabasca Group contains a maximum thickness of approximately 1,500 m of mainly flat-lying Helikian sandstone. It lies with marked angular unconformity above north-to-northeast trending.
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Figure 3.1: Geographic location and surroundings of the McClean Lake Operation
3.1.2 Atmospheric Environment
The project site at the McClean Lake Operation is located in the continental subarctic region of northern Saskatchewan. The climate is characterized by long, cold winters and short, cool summers. Mean monthly temperatures range from 15 degrees Celsius in July to -24.4 degrees Celsius in January. The average annual precipitation measures at the McClean Lake station between 2010 and 2015 was 387 mm, with 77% occurring as rain. Prevailing winds are from the west-northwest and the northwest, with an average wind speed of 14 km/h.
Ambient air quality in the local assessment boundary was determined using baseline monitoring data from past environmental assessments (Midwest and McClean Lake) and current McClean Lake Operation monitoring results. Data are available for total suspended particulates (TSP), airborne metals and radionuclides, radon, and sulphur dioxide concentrations.
All TSP measurements met the national and provincial air quality standards. Concentrations of metals and radionuclides in TSP are below Ontario’s 24-hour ambient air quality criteria (there are no Saskatchewan guidelines for TSP metal concentrations). Radon data over the 2000 to
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2015 period indicate that, with isolated exceptions immediately near the Sue ore stockpile, radon levels are low and comparable to expected background levels and measurements at the reference station. It is important to note that workers are minimally exposed to radiation from ore slurry as all loading and offloading facilities are remotely controlled and containers have built in shielding. Continued implementation of AREVA’s current Radiation Code of Practice continues to reduce the potential for gamma radiation, radon gas, radon progeny and long lived radioactive dust exposure affecting human health.
3.1.3 Aquatic Environment
The McClean Lake Operation is located within the Upper Collins Creek watershed, which is a sub-basin of the larger Wollaston Lake west basin. Treated effluent and clean dewatering well water from current operations is discharged into the S/V TEMS, which then flows into the McClean Lake east basin and eventually Collins Creek. The SV/TEMS is used to manage the volume and flow of effluent from the McClean Lake Operation to Collins Creek. Sink Reservoir was formed by the construction of a dam at the outlet of the small and shallow Sink Lake. Sink Reservoir now receives treated effluent from both the JEB WTP pipeline and from the Sue WTP pipeline. Water is discharged from Sink Reservoir to Vulture Lake via a buried pipeline. Similarly, water from Vulture Lake is discharged via a buried pipeline which terminates in an effluent diffuser to enhance mixing in the east basin of McClean Lake. This system provides a means of storing effluent, to minimize effects to the receiving environment, while allowing water treatment to proceed on demand.
Lakes located in the LSA are typical of nutrient-poor (oligotrophic) Canadian Shield lakes, with circumneutral pH (6.5 to 8.0), low hardness, low alkalinity, low dissolved organic carbon and low phosphate levels. These lakes typically have abundant and diverse phytoplankton communities; the dominant phytoplankton division is Chrysophyta (golden-brown algae) or Chlorophyta (green algae). The dominant zooplankton taxa are Cladocera, Copepoda and Rotatoria. The dominant macrophyte species is Carex (sedge), and benthic composition includes diptera, molluscs and chironomids. Common fish found within the local assessment boundary include northern pike, lake whitefish, white sucker, lake trout, ciscoes, ninespine stickleback, and lake chub.
Within the LSA, radionuclide levels were generally low or undetectable and concentrations of most metals were below (or at) federal and provincial water quality guidelines. Decreasing trends in ammonia, chloride, magnesium, molybdenum, and potassium concentrations were identified over the 2000 to 2015 period at all locations assessed. Molybdenum was also trending downward, due to the April 2004 JEB WTP molybdenum removal optimization project.
Sediment chemistry data (e.g. metals, radionuclides and nutrients) show elevated concentrations of calcium, sodium, arsenic, molybdenum, nickel, selenium, and uranium in exposure areas. These levels are below or around the “lowest effect level” (measure below which sediment biota are safe) and localized to the exposure areas (e.g. S/V TEMS). Slowly increasing levels of uranium were observed in the McClean Lake east basin, however, levels remained well below the predicted maximum mean concentrations presented in 1991 and 1995 Joint Panel EAs and the 2012 ERA and well below sediment quality guidelines. Sediment monitoring is completed on a three year sampling frequency.
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Fish tissue monitoring has shown that some COPCs are present at levels higher in fish tissue from Sink Reservoir and Vulture Lake relative to reference levels. Mean concentrations of selenium in northern pike fish tissue were below 2012 maximum mean predicted concentrations in all but northern pike muscle tissue from Vulture Lake. The concentrations of selenium in the muscle tissue of northern pike from Vulture Lake marginally exceeded the maximum mean fish tissue prediction, but remained well below the 95th percentile prediction.
3.1.4 Geological and Hydrogeological Environment
The project site is located on the eastern margins of the Athabasca Basin. Surficial deposits consist mainly of unconsolidated glacial till, with eskers, muskeg deposits, and boulder fields. The ore is located within a 120 m (on average) layer of sandstone and conglomeratic sandstone, which is underlain by weathered Precambrian basement rock. Uranium is also found within the basement rock, higher up in the sandstone, and at the transition zone between the sandstone and basement rock layers (called the unconformity), but these occurrences are within 100 m or so of the proposed site. The ore body is the shape of an irregular and elongated ellipsoid that dips northeast-southwest.
Groundwater flow in the McClean Lake area has two major components: the Quaternary glacial sediments as well as the underlying sandstone and basement crystalline rock. Groundwater flow is largely dependent on the hydraulic properties of the surficial and bedrock geology of the region and topography. The region is covered by a veneer of glacially derived sediments, primarily heterogeneous glacial tills whose clay content affects hydraulic conductivity. Additionally, the many surface water bodies in the area influence the shallow groundwater flow system by acting as groundwater discharge points. Most of the surface water bodies in the area are entirely contained with the glacial tills and have little connection with the underlying sandstone. The deeper groundwater flow system, located in the underlying sandstone and crystalline basement, is controlled by fractures and the hydraulic conductivity and permeability of the rock.
Shallow groundwater flow (up to 30 m below ground surface) mimics the local topography and surface drainage features (e.g. Collins Creek and Wollaston Lake). Regionally, deep groundwater flows west to east towards Wollaston Lake, with local influences from bedrock type and characteristics.
Water chemistry data for groundwater samples collected from the area surrounding the site show low concentrations of metals, radionuclides and other trace elements with only minor exceedances of applicable provincial surface water quality guidelines, which is characteristic of groundwater in this region. Compared to the other samples, only one sample, collected near the unconformity, showed elevated concentrations.
3.1.5 Terrestrial Environment
The McClean Lake Operation is situated in the northern-most part of the Cryoboreal soil climatic region. Upland soils are generally formed on sorted glaciofluvial deposits or unsorted moraines, which produces eluviated Dystric brunisols. Lowland areas, such as bogs and fens, are generally characterized by organic soils. Although permafrost was not encountered during soil surveys, it may occur in small pockets within the LSA.
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Chemistry data for soils and vegetation (Labrador tea, blueberry and lichen) demonstrate that concentrations of various constituents (radioactive and non-radioactive) are below applicable criteria. There is little evidence that the McClean Lake Operation has had a measurable effect on metal or radionuclide concentrations in soils. Concentrations of radionuclides are relatively consistent across each exposure area and levels remain well below available Canadian environment quality guidelines for industrial soils. While concentrations of arsenic, lead, uranium, radium-226 and thorium-230 in vegetation near the Sue mining site are somewhat higher compared to reference areas due to mining activities, these concentrations are below the applicable guidelines of levels toxic to plants. The potential effect of the higher concentrations of arsenic, lead, uranium, radium-226 and thorium-230 in vegetation was modelled in the risk assessment for terrestrial biota and no adverse effects were predicted.
The LSA is dominated by coniferous forests and shrubs, with smaller areas of lowland habitat (bogs, fens, marshes, and riparian vegetation). The soils, landforms, vegetation, and wildlife within the local area are typical of the regional Boreal Shield ecozone. Fire plays a significant role in shaping the northern terrestrial environment. The local area illustrates a predominance of immature and mature jack pine forest stands, interspersed with bogs and open fens that provide breeding and rearing areas for amphibians and reptiles. Lichens form a significant ground cover in mature upland jack pine and black spruce stands, which provides suitable forage habitat for caribou. Riparian zones contain abundant food and cover for moose, beaver, snowshoe hare, small mammals, water birds, amphibians, and reptiles. These prey species provide a diversity of food for carnivores such as fisher, marten, lynx, wolves, eagles, hawks, falcons, and owls. All habitat types provide a broad range of niches for breeding songbirds. Of the habitat represented by the LSA, less than one percent has been directly affected by the McClean Lake Operation infrastructure development.
Birds observed in the LSA include spruce grouse, willow ptarmigan, bald eagle, osprey, northern goshawk, red-tailed hawk, rough legged hawk, northern harrier, great horned owl, snowy owl, hawk owl, 28 species of water birds, and at least 57 songbird species. Diversity is considered moderate (i.e. neither rich nor poor in terms of the variety of species situated here). Amphibians observed in the local assessment boundary include the boreal chorus frog and wood frog.
Mammals observed (or presence inferred) in the LSA include moose, black bear, weasel, marten, red fox, mink, snowshoe hare, red squirrel, voles, shrews, lemmings and mouse. Wolf, barren-ground and woodland caribou, and beaver are also present in the area but with limited activity. The local assessment boundary is within the barren-ground caribou herd winter range, however, barren-ground caribou can be absent from the area for several years.
Species that may occur in the LSA that are either listed under the Species at Risk Act (SARA) or have been identified by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) are outlined in table 3.1 below.
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Table 3.1 Species at Risk that may occur in the local assessment boundary
Common Name Scientific Name SARA Status (Schedule 1) COSEWIC Status Notes
Common nighthawk Chordeiles minor Threatened Threatened
Red knot, rufa subspecies
Calidris canutus rufa
Endangered Endangered Migrant only
Peregrine falcon Falco peregrinus Special concern Special concern Migrant only
Rusty blackbird Euphagus carolinus
Special concern Special concern
Short-eared owl Asio flammeus Special concern Special concern
Yellow rail Coturnicops noveboracensis
Special concern Special concern Outside range, occurrence unlikely
Barn swallow Hirundo rustica No Status Threatened Edge of range Bank swallow Riparia riparia No Status Threatened Red-necked phalarope
Phalaropus lobatus
No Status Special concern Migrant only
Buff-breasted sandpiper
Tryngites subruficollis
No Status Special concern Migrant only
Horned grebe Podiceps auritus No Status Special concern Mammals
Northern myotis Myotis septentrionalis
Endangered Endangered
Little brown myotis Myotis lucifugus Endangered Endangered Woodland Caribou, Boreal Population
Rangifer tarandus
Threatened Threatened
Caribou – Barren-ground population
Rangifer tarandus
No Status Threatened Edge of range
Wolverine Gulo gulo No Status Special concern Amphibians Northern leopard frog – western boreal/prairie population
Lithobates pipiens
Special concern Special concern Edge of range, occurrence unlikely
Arthropods Gypsy Cuckoo Bumble Bee
Bombus bohemicus
No Status Endangered Within range
Yellow-banded Bumble Bee Bombus terricola No Status Special concern Within range
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Woodland Caribou
Woodland caribou are distributed broadly throughout the boreal forest and have the potential to occur in the LSA. They require large areas comprised of continuous tracts of undisturbed habitat rich in mature to old-growth coniferous forest, lichens, muskegs, peatlands and upland or hilly areas. Large areas with suitable quality habitat allow woodland caribou to disperse across the landscape when conditions are favourable (e.g. natural fire disturbance or anthropogenic disturbances) and to maintain low population densities to reduce their risk of predation. Woodland caribou are not migratory and inhabit much of the province’s northern forest year round.
Woodland caribou are listed as Threatened under the federal SARA – Schedule 1. Schedule 1 mandates that a recovery strategy and action plan are created to help mitigate further species decline. A national recovery strategy was developed and subsequently posted on the federal Species at Risk Public Registry in 2012 [21]. The state of critical habitat necessary to achieve population and distribution objectives for recovery of woodland caribou was identified and assessed for all ranges in Canada, with the exception of the Boreal Shield (SK1) portion of Saskatchewan’s range.
For any given range the federal recovery strategy identified the minimum disturbance management threshold for undisturbed habitat at 65%, which represents the critical habitat identification for woodland caribou, and is directly linked to the population’s probability of survival through time (i.e., self-sustaining population).
The federal assessment of critical habitat concluded that insufficient information was available for SK1 in order to identify critical habitat. SK1 disturbance is comprised of 3% anthropogenic and 55% fire. Both of these disturbance proportions are outside the data range present in the other 50 ranges assessed by Environment and Climate Change Canada (ECCC), which varied from 12% – 100% for anthropogenic disturbance, and as high as 42% for fire disturbance. The high fire disturbance in combination with very low anthropogenic disturbance estimates for the SK1 range represent a unique situation outside the range of variability observed in the data that informed the disturbance model used by ECCC. Additionally, the SK1 range did not have any formal population data or population trend data available from previous studies or surveys. The uncertainty associated with the application of ECCC’s model to the SK1 range was considered too great compared to the other 50 ranges analyzed in the recovery strategy.
Therefore, the disturbance model that informed the identification of critical habitat was not applied to SK1. In addition, the probability of self-sustainability was reported as “unknown” due to the uniqueness of the disturbance regime and the uncertainty regarding the status of the population.
In order to address the lack of information specific to SK1, a five-year, multi-faceted research program on the population dynamics and critical habitat of woodland caribou in the Saskatchewan Boreal Shield was launched in 2013. At the applied level, this study will assess the current status of woodland caribou in SK1 with respect to their population, and the effects that the low anthropogenic and high fire disturbance pattern specific to the SK1 range might have on the population.
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An interim report resulting from this research was released November 18, 2016 with the following preliminary observations and conclusions with respect to habitat characteristics, population status and trends for woodland caribou in the Saskatchewan Boreal Shield:
the population occupies some of the most pristine habitat available to non-migratory, forest-dwelling caribou in Canada, with very low levels of anthropogenic disturbance
despite high fire frequency, the SK1 unit retains large tracts of high-quality woodland caribou habitat
selected habitat was found to support some of the highest densities currently observed for non-migratory, boreal caribou in mainland Canada
both wolf densities and human hunting pressure are believed to be low
These conditions have resulted in a population characterized by high adult female survival and pregnancy rates with moderate to low recruitment. This suggests the population is experiencing density dependent growth controls, but show no evidence of population decline.
For SK1, critical habitat identification is expected near the end of 2018. Given this timeline, development of a draft range plan for SK1 is not expected until 2020.
It is expected that AREVA will continue to work with the Saskatchewan Mining Association to contribute to ECCC’s National Recovery Strategy for Woodland Caribou [21]. Once critical habitat is identified and a provincial range plan is in place for SK1, AREVA will be required to update the McClean Lake Wildlife Management Plan accordingly.
3.2 PredictedEnvironmentalEffectsAssessmentThis section presents an overview of the assessment of predicted effects of the Project on the environment and the health of persons. The assessment of likely effects of the Project was carried out in a stepwise manner as follows:
identifying potential project-environment interactions (see table 3.2)
identifying potential environmental and health effects
identifying mitigation measures (beyond standard design and operational measures) and monitoring and follow-up requirements
determining whether the environment and health of persons is protected
An analysis has been conducted for all components related to the project, but only a selection of topics are presented in detail in this section. Topics were selected by CNSC staff as being of interest for the Commission, members of the public and Indigenous communities, or of regulatory interest. These topics are atmospheric, aquatic, geological and hydrogeological, and terrestrial environments and human health.
3.2.1 Project Environment Interactions
Table 3.2 identifies the potential interactions between the project and the environment for the continued operations of the McClean Lake Operation and the expected decommissioning activities as outlined in the PDP.
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Table 3.2: Project-Environment Interactions
PHYSICAL WORKS AND ACTIVITIES
Atmospheric environment Aquatic environment Geological and hydrogeological
○ = Project-environment interactions that have been determined to result in no effects on the environment and health of persons ● = Project-environment interactions that have been determined to result in potential effects on the environment and health of persons
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3.2.2 Predicted Environmental Effects Assessment of Continued Operations
As noted in section 2.1.1 of this report AREVA submitted a revised version of the ERA study in September 2016 [3]. The CNSC assessed the potential for adverse effects based on pathways of effects and the regular releases and emissions from the McClean Lake Operation.
Sections 3.2.2.1 to 3.2.2.5 discuss releases from the McClean Lake Operation and their potential impacts for existing and planned activities during the upcoming licence term. The predicted ecological and human health risks due to predicted future releases to air and water from the continued operation of the McClean Lake Operation were compared with the overall conclusions of the original Environmental Assessments, the 1991 Environmental Impact Statement for the McClean Lake Project [15], the 1995 Cigar Lake Project [16], which assessed the impact of milling of Cigar Lake ore at the McClean Lake Operation, and previous predictions included in past ERAs accepted by the CNSC.
The 2016 ERA evaluated the potential radionuclide and non-radionuclide releases from the key source areas of the McClean Lake Operation. Figure 3.2 is AREVA’s conceptual site model for releases to the atmosphere and to surface water. The releases from the following key source areas were assessed:
Atmospheric releases of dust from:
drilling and blasting
material handling
grading and dozing
unpaved roads
wind erosion
mill operations
backfill plant
pug mill
radioactive dust and metals
Atmospheric releases of gaseous pollutants from:
mining equipment and vehicles
acid plant
waste incineration
back-up power generation
Atmospheric releases of radon from:
exposed surfaces of rock containing U-238
rock breaking and rock handling
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ore processing
tailings management
water inflow into McClean Lake Underground
Effluent releases to surface water via the Sink Reservoir from:
JEB WTP
Sue WTP
future Midwest WTP
The contaminants released from each of the key source areas were considered as candidate COPCs. The concentrations of the COPCs were screened against environmental and human health guidelines. All radionuclides were retained for further analysis in the ERA. If the concentrations of non-radionuclide releases were below the guidelines, they were screened out from further assessment, since the resultant predicted concentrations in the terrestrial (air, soil), groundwater and aquatic environment surrounding the site would be less than any concentration known to cause adverse effects to terrestrial, aquatic and human receptors. Non-radionuclide releases that were above environmental and human health guidelines were retained for further analysis in the ERA.
For contaminants that were retained, environmental transport and fate models were used to predict resultant concentrations to which humans and valued ecosystem components would be exposed to in air, soil, groundwater, surface water, and the aquatic environment. Figure 3.3 provides the conceptual pathways for releases to humans and the environment surrounding the McClean Lake Operation. If the modeled concentrations were greater than environmental and human health guidelines, a potential risk to an environmental receptor or human receptor was identified and assessed.
Figure 3.2: Conceptual Site Model – Project Releases
Source: AREVA [3]
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Figure 3.3: Conceptual Site Model – Environmental Risk Assessment
Source: AREVA [3]
In the ERA, AREVA modelled the potential risks to humans and to aquatic and terrestrial biota from three effluent scenarios:
1. The continued increase of selenium effluent concentrations to 100 µg/L and no additional control for selenium in the effluent (Base Case).
2. Treatment installed by 2020 that will reduce selenium effluent concentrations by 90% to 10 µg/L.
3. Treatment installed by 2020 that will reduce selenium effluent concentrations by 60% to 40 µg/L.
The ERA included predictions of future effluent quality released from the JEB WTP in consideration of the milling of Cigar Lake ore and future milling of the Midwest deposit. The McClean Lake mill restarted in 2014 to process Cigar Lake ore and since that time, the JEB WTP selenium effluent concentration has increased steadily. In response to this trend and the associated ERA predictions, AREVA has proactively pursued adaptive management. AREVA has commenced a BATEA evaluation to identify additional selenium control and treatment technologies and plans to install an additional effluent treatment circuit to further control selenium concentrations in the effluent, if required, by 2020.
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AREVA submitted an update on selenium risks and improvement initiatives in November 2016 [22], which provided an updated forecast of expected selenium concentrations in treated effluent given a more recent life of mine plan for the mining of Cigar Lake ore. The life of mine plan predicts that the input of selenium to the mill from Cigar Lake ore has peaked, and that future input selenium concentrations will result in a Base Case (no additional control for selenium) of approximately 40 µg/L in the effluent, rather than the 100 µg/L Base Case scenario assumed in the ERA.
The following sections provide CNSC staff conclusions on the potential effects from the future operation of the McClean Lake Operation and whether AREVA will continue to make adequate provisions for the protection of the environment and human health.
3.2.2.1 Atmospheric Environment
Air Quantity
Atmospheric releases from the McClean Lake Operation are monitored through an air quality monitoring program. The air quality monitoring program includes both source and ambient air monitoring. Source monitoring includes monitoring of exhaust stacks and ambient air monitoring includes monitoring of ambient radon, total suspended particulate (dust) and ambient sulphur dioxide.
Gaseous Effluent
Emissions from various stacks at the facility (i.e., grinding stack, calciner stack, crystallizer stack, packaging stack, acid plant stack and incinerator) are monitored through a source monitoring program.
Ambient Air Monitoring
Routine ambient air quality monitoring at the McClean Lake Operation includes continuous collection of meteorological data as well as monitoring of precipitation pH, total suspended particulate, ambient sulphur dioxide, and ambient radon concentrations. The objective of the ambient air monitoring program is to confirm the effectiveness of emission control measures and evaluate the impact of the facility on the environment.
Ambient sulphur dioxide concentrations associated with mill emissions are continuously measured using a sulphur dioxide monitor located 200 m downwind of the acid plant. Annual average sulphur dioxide concentrations are below the province of Saskatchewan’s Ambient Air Quality Standard of 10 parts-per-billion. Radon measurements are collected semi-annually using track etch cups. Measured radon levels have been low and comparable to background concentrations and measurements at reference stations.
TSP in dust is measured weekly using hi-volume samplers at four exposure locations and one reference location. The measured values for TSP have been below the province of Saskatchewan’s Ambient Air Quality Standards for all monitoring sites. TSP is analyzed for both radionuclides and metals. Concentrations of metals in TSP were compared to the Ontario Ministry of the Environment and Climate Change’s Ambient Air Quality Criteria [23], as
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mentioned previously; there are no similar criteria for the province of Saskatchewan. The concentrations of metals and radionuclides are lower than the relevant air quality guidelines.
Air Dispersion
As part of the 2016 ERA for the McClean Lake Operation, air dispersion modelling was carried out to predict the impact of releases from the ongoing operations at the McClean Lake site on the environment. Five emission scenarios were assessed to evaluate ongoing operations of the facility. The dispersion modelling demonstrated that potential effects of the McClean Lake Operation would be minimal and limited to a small area within a few hundred metres of the McClean Lake Operation. COPCs are expected to return to background levels within a distance of a few kilometres of the operation.
Conclusion
The ERA predicted that potential effects of the future proposed operations at the McClean Lake site on the ambient air quality in the local and regional study areas are minimal and limited to small areas within a few hundred metres of the McClean Lake Operation.
Based on the review of the ERA and compliance monitoring data, CNSC staff have concluded that AREVA’s reported radionuclide and hazardous releases at the McClean Lake Operation during the current licensing period have remained below their respective regulatory limits. AREVA’s emissions monitoring program confirms that radionuclide and hazardous concentrations in air surrounding the McClean Lake Operation are low and that ecological and human receptors are protected.
3.2.2.2 Hydrogeological Environment
Groundwater Quantity
The McClean Lake Operation pumps groundwater from the bottom of the JEB TMF and the areas surrounding the Sue site pits to ensure that contaminated groundwater does not enter the surrounding surface water features via seepage. The groundwater is treated at the JEB and Sue WTPs. The pumping of groundwater lowers the water table in adjacent areas, and AREVA conducts groundwater monitoring to determine the extent of impact to the groundwater table. AREVA also monitors the elevation of surface water features and wetland communities in adjacent areas to assess the potential decrease in surface water elevation and plant community composition due to the decreased groundwater quantity.
Groundwater Quality
At the McClean Lake site, groundwater is a pathway for the transport of COPCs. The discharge of groundwater into surface water delivers COPCs to the receiving environment exposing receptors in these surface water bodies. Groundwater does not pose a direct risk to human health or the environment, as it is not used as a drinking water resource.
The most recent ERA stated that groundwater contaminated by contact with mining pits, tailings management facilities or operational processes is pumped, treated and incorporated as effluent from the water treatment process to surface water bodies.
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AREVA’s EMP assesses both chemical and physical aspects of the groundwater system at the McClean Lake Operation. The groundwater quality monitoring program portion of the EMP incorporates well sampling in both the overburden and bedrock aquifers in addition to wells located both near and distant from mine operations. The program is reviewed periodically by CNSC staff, and AREVA is currently in the process of reviewing the program internally against CSA N288.7-15, Groundwater protection programs at Class 1 nuclear facilities and uranium mines and mills [13]. Once the review is complete, if gaps are identified, changes to the groundwater quality monitoring program portion of the EMP will be implemented.
Groundwater located near mining pits, tailings management facilities or other operational processes have the potential to be impacted from mine operations. Many of these wells display higher concentrations of COPCs than wells located away from mine operations and mineralized areas. The pump and treat programs currently in place at the McClean Lake Operation limit the spread of contaminants via groundwater transport. AREVA has also developed a groundwater flow model that is used to predict and assess impacts to groundwater flow and quality from mine operations.
Conclusion
The results of groundwater monitoring demonstrate that groundwater is impacted by mine activities. This groundwater is collected, treated and discharged as effluent to surface water bodies. The recent ERA conducted by AREVA considered groundwater discharging to lakes and streams and the contribution of COPCs to the environment from this source. Future operations will ensure that groundwater contaminated by contact with mining pits, tailings management facilities or operational processes is pumped, treated and incorporated as effluent from the water treatment process. Once discharged as effluent, this water is part of the surface water environment.
Based on review of the submitted ERA and the annual groundwater monitoring data, CNSC staff have concluded that AREVA’s reported radionuclide concentrations in groundwater wells surrounding the McClean Lake Operation have remained below their respective regulatory limits during the current licensing period, and therefore, no effects were predicted.
3.2.2.3 Aquatic Environment
Surface Water Quantity
Surface water quantity at the McClean Lake Operation is influenced by groundwater pumping to ensure hydraulic containment of the JEB TMF and maintenance of hydraulic containment at the Sue open pits. Surface water level monitoring in lakes potentially influenced by groundwater pumping has confirmed that dewatering and hydraulic containment pumping has had a limited influence on the water levels of Fox, Johannes, Pat, and Wallace Lakes during the period of operations as the long-term trends in lake levels generally reflect the natural variability due to climatic variations.
Surface water quantity of the Collins Creek drainage system, including Sink Reservoir, Vulture Lake, McClean Lake East, Collin’s Creek and Kewen Lake could be influenced by the discharge of treated effluent from the JEB, Sue and future Midwest WTPs to Sink Reservoir. The S/V TEMS control structures were constructed in 1997 in order to ensure minimal fluctuations to the
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downstream hydrology of McClean Lake East, Collins Creek and Kewen Lake due to the discharge of effluent to the Sink Reservoir. Measured streamflow values on Collins Creek have been slightly influenced by effluent discharge to Sink Reservoir from the Sue and JEB WTPs and regular water withdrawals for operational use from Pat Lake.
The ERA provided a description of future activities at the McClean Lake Operation that could potentially influence surface water quantity due to dewatering or hydraulic containment operations and release of treated effluent to the S/V TEMS. The ERA concluded that planned activities and operations during the upcoming licensing period are not anticipated to have significant impacts to the surface water levels in the LSA.
Surface Water Quality
Any groundwater potentially contaminated by the JEB TMF and areas that have been mined or are being used to store mine waste is captured and treated at the Sue and JEB WTPs before being released to Sink Reservoir. Process water from the McClean Lake mill is directed to the JEB WTP and then released to the S/V TEMS. Effluent quality is monitored prior to being released.
As stated in Section 3.2.2, AREVA included three effluent selenium concentration scenarios in the 2016 ERA. The release of different concentrations of selenium in effluent will influence concentrations in the environmental pathways (surface water and sediment), which in turn will affect the concentrations of selenium to which human and environmental receptors are exposed.
Following release to the Sink Reservoir, surface water discharges to the Collins Creek watershed via Vulture Lake, McClean Lake East, Collins Creek and Kewen Lake. AREVA conducts extensive surface water quality monitoring at downstream locations that receive treated effluent (primary exposure stations) and to confirm that lakes adjacent to mining and waste management activities (secondary exposure stations) do not receive significant inputs of contaminated groundwater via seepage. The surface water quality monitoring program also includes locations that are not exposed to mining and milling inputs (control stations) in order to compare exposure station water quality to lakes in the local area.
Predicted Surface Water Quality
The ERA modelled the predicted concentrations of COPCs in surface water as a result of predicted future effluent quality for the upcoming licensing period. Future surface water COPCs concentrations at the primary and secondary exposure monitoring stations were predicted based on assumed future effluent volumes and COPCs concentrations. The majority of the future predicted COPCs concentrations downstream of the S/V TEMS are similar or lower than those assessment predictions contained in previous EAs and ERAs.
Predicted future concentrations of chloride, sulphate, total dissolved solids (TDS), cobalt and selenium in water within and downstream of the S/V TEMS are higher than previous assessment predictions contained in EAs and ERAs. Although the surface water quality guidelines for the protection of aquatic life are predicted to be exceeded for several COPCs within the S/V TEMS (chloride, fluoride, sulphate, TDS, arsenic, cobalt, copper, molybdenum, selenium and uranium), only the predicted concentrations of sulphate and selenium in water were indicated to potentially exceed the applicable surface water quality guidelines at exposure monitoring stations downstream of S/V TEMS. The potential effect to aquatic, terrestrial and human receptors from
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exposure to increased concentrations of arsenic, copper, lead, molybdenum, nickel, uranium, and zinc were considered in the assessment of potential effects, even though the predicted concentrations were below surface water quality guidelines for the protection of aquatic life. Potential effects from the predicted future activity of radionuclides in surface water at downstream exposure monitoring stations were also considered in the radiological assessment of ecological receptors and human health.
Sediment Quality
The ERA modelled the predicted concentrations of COPCs in sediments as a result of predicted future effluent quality for the upcoming licensing period. Future sediment concentrations at the primary and secondary exposure monitoring stations were predicted based on assumed future effluent volumes and COPCs concentrations. The future predicted COPCs sediment concentrations of arsenic, copper, zinc and radionuclides downstream of the S/V TEMS are lower than those assessment predictions contained in previous EAs and ERAs.
Sediment quality benchmarks or guidelines for the protection of aquatic life are predicted to be exceeded for arsenic, molybdenum, nickel and selenium at exposure monitoring stations downstream of S/V TEMS. Potential effects from the predicted future activity of radionuclides in sediments at downstream exposure monitoring stations were also considered in the radiological assessment of ecological receptors and human health.
Aquatic Biota
Previous EAs and ERAs accepted for the McClean Lake Operation concluded moderate to major impacts to aquatic biota in the S/V TEMS due to the discharge of treated mill effluent and contaminated groundwater from the JEB and Sue WTPs. Negligible impacts were predicted for the primary exposure stations downstream of the S/V TEMS and in the secondary exposure stations adjacent to the JEB TMF and adjacent to areas that have been mined or are being used to store mine waste.
The 2016 ERA provided predictions of potential impacts to aquatic biota from future activities at the McClean Lake Operation. No adverse effects on aquatic biota are expected from radiological COPCs released from future anticipated site operations as predicted radiological doses are similar to background or reference sites.
The ERA predicts risks due to selenium exposure for a variety of aquatic-based receptors in the S/V TEMS, however, previous EAs and ERAs concluded that the McClean Lake Operation would have moderate to major impact to aquatic biota S/V TEMS. Therefore these risk predictions were previously assessed and accepted.
The ERA concluded that the release of non-radiological COPCs from future operations will not have measurable impacts to aquatic biota at the secondary exposure monitoring stations and at the primary exposure monitoring stations beyond the S/V TEMS, with the exception of selenium.
The ERA predicts that there could be risk to waterfowl (i.e. merganser and scaup) and mammals that live in aquatic habitat (i.e. mink and muskrat) in McClean Lake East that would persist for several decades under the 100 µg/L selenium effluent scenario. Additional information submitted by AREVA in November 2016 [22] states that selenium concentrations in treated effluent will,
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on average, be at or below 40 µg/L. For this effluent scenario, potential risks to waterfowl and mammals that live in aquatic habitat in McClean Lake East would be reduced but not eliminated. The installation of a selenium treatment system to lower effluent concentrations to 10 µg/L by 2020 will result in much lower potential risks to these receptors, with only mink being slightly at risk to increased selenium levels in McClean Lake East. Potential risks to waterfowl and mammals that live in aquatic habitat are limited to McClean Lake East for all effluent release scenarios, whereby receptors further downstream in Collins Creek and Kewen Lake are unlikely to be impacted.
The ERA predicts that there could be risk to fish in McClean Lake East that would persist for several decades under the 100 µg/L selenium effluent scenario. Additional information submitted by AREVA in November 2016 [22] states that selenium concentrations in treated effluent will, on average, be at or below 40 µg/L. For this effluent scenario, risks to fish in McClean Lake East will be lower than those predicted for the 100 µg/L selenium effluent scenario but fish tissue selenium concentrations would still be above acceptable levels for several decades. The installation of a selenium treatment system to lower effluent concentrations to 10 µg/L by 2020 will lower, but not eliminate, the potential risk to fish in McClean Lake East. Between 2016 and 2020, prior to the installation of a selenium treatment system, the ERA predicts that selenium levels in McClean Lake East could result in fish tissue levels that could result in teratogenicity in offspring and potential fish population impacts. Potential risks to fish downstream of McClean Lake East in Collins Creek and Kewen Lake are very low to negligible for all effluent release scenarios.
AREVA proactively created a selenium risk management plan in May 2016 [24] which was revised [25] in response to CNSC staff comments and accepted by CNSC staff in October 2016. The selenium risk management plan includes AREVA’s commitment to examine and implement techniques to limit selenium releases to as low as reasonably achievable (ALARA) while treatment technologies are being evaluated. AREVA will increase surface water quality monitoring frequency in McClean Lake East and will conduct supplemental studies on fish health if selenium surface water concentrations or fish flesh exceed prescribed thresholds. If the supplemental studies suggest fish population level effects in McClean Lake East, CNSC staff will address the risk through regulatory controls and oversight.
Effects due to selenium are expected to be local and limited to the S/V TEMS during the operating period. Further, CNSC staff provided AREVA regulatory expectations regarding the development, documentation and implementation of a Selenium Adaptive Management Plan to reduce selenium releases to the environment, and to mitigate any potential effects of selenium on the environment for the period leading up to the installation of additional treatment for selenium in 2020 [26].
Conclusion
The overall assessment indicated that there would be no negative effects expected in aquatic biota beyond those accepted in previous EAs and ERAs with the exception of potential impacts to aquatic biota in McClean Lake East due to selenium exposure. Risks to the aquatic environment will be minimized if AREVA installs additional treatment for selenium to control releases to 10 µg/L by 2020. AREVA has proactively implemented a selenium risk management plan which includes enhanced modelling and additional assessments of fish health if prescribed
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thresholds in McClean Lake East are exceeded. In order to address the period leading up to the installation of additional treatment for selenium in 2020, CNSC staff have provided expectations regarding the development, documentation and implementation of a Selenium Adaptive Management Plan to meet the requirements of the Nuclear Safety and Control Act and corresponding regulations for the protection of the environment.
Based on the review of the ERA and the results presented in AREVA’s annual monitoring reports, compliance verification activities, and AREVA’s proposed Selenium risk management plan, CNSC staff conclude that the effluent monitoring program currently in place for the McClean Lake Operation continues to provide adequate protection to the aquatic environment.
3.2.2.4 Terrestrial Environment
The primary components of the terrestrial environment include soil, vegetation, wildlife, and wildlife habitat. Baseline studies completed in the McClean Lake Operation LSA were designed to characterize the terrestrial environment, predict impacts, and to focus the study design on key components for the monitoring program. During the initial EA [2], key components of the terrestrial environment identified for monitoring included wetland plant communities, terrestrial vegetation and soil chemistry. Exposure areas were chosen based on areas identified in the 1991, 1995, and 2011 EAs to be within the predicted zone of influence of the McClean Lake Operation.
Soil Quality
The evaluation of soil COPCs within the McClean Lake Operation LSA in 2011 and 2015 indicated that elevated concentrations of some metals and radionuclides were relatively consistent across each exposure area and levels remained well below available Canadian environment quality guidelines for industrial soils [27]. The ERA predicted that future mining activities at the McClean Lake Operation will continue to result in elevated soil concentrations of some COPCs within the footprint of the site.
Terrestrial Biota
Wetland communities were most recently assessed in 2015 to monitor the potential impact of groundwater dewatering. Monitoring data and the analyses completed in 2015, as well as previous reporting cycles, have not noted any shifts in bog and fen communities towards upland forest and drier sedge meadow communities respectively, due to groundwater dewatering at the McClean Lake Operation. This result is not surprising given that the effects of dewatering were less than initially anticipated, and bogs almost exclusively receive moisture via precipitation, rather than groundwater. Based on the analysis, groundwater dewatering has not had a significant effect on wetland plant communities. Groundwater dewatering associated with future mining activities at the McClean Lake Operation is not expected to result in significant changes to wetland communities in the vicinity of the McClean Lake site.
AREVA collects and analyzes samples of Labrador tea, blueberry and northern reindeer lichen from exposure and reference stations coincident with the locations where soils are sampled. COPCs tended to be elevated in the terrestrial vegetation at locations within the McClean and Sue exposure areas that are adjacent to mining activities and the haul road, with concentrations
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generally decreasing at those locations since 2008, coincident with the cessation of mining activities in the area. The results suggest that the McClean Lake Operation has had a localized effect on concentrations of COPCs in vegetation, with changes in concentrations noted at locations immediately adjacent to mining activity over time.
The ERA predicted that future mining activities at the McClean Lake Operation will continue to result in elevated concentrations of some COPCs in vegetation within the footprint of the site, but no direct effects on the health of plants due to COPCs exposure were predicted. The potential effect of the predicted changes to vegetation quality was modelled in the risk assessment for terrestrial biota and no adverse effects were predicted.
The ERA provided predictions of potential impacts to terrestrial biota from the McClean Lake Operation due to the release of COPCs to the aquatic environment via the discharge of treated effluent via the JEB and Sue WTPs. No adverse effects are expected from radiological COPCs released from the current and future anticipated site operations, as predicted radiological doses are similar to background or reference sites.
The ERA concluded that the release of non-radiological COPCs from future operations will not have impacts to terrestrial biota beyond the SV/TEMS, with the exception of potential effects to birds exposed to selenium from feeding on insects that spend part of their lifecycle in aquatic habitats. Additional information submitted by AREVA in November 2016 [22] states that selenium concentrations in treated effluent will, on average, be at or below 40 µg/L. For this effluent scenario, potential risks to birds feeding on insects emerging from McClean Lake East would be reduced but not eliminated. The installation of a selenium treatment system to lower effluent concentrations to 10 µg/L by 2020 will lower but not eliminate the potential risks to these receptors. Birds feeding on insects emerging from the downstream habitats of Collins Creek and Kewen Lake are unlikely to be impacted if selenium effluent concentrations are at or below 40 µg/L.
The ERA assessed the potential impact to species at risk that could be present in the LSA. CNSC staff have recommended that AREVA confirm the presence or absence of these species in the LSA in the upcoming licensing period, and if these species are present, AREVA must submit a plan for further studies to assess potential impacts.
To acknowledge uncertainty around woodland caribou population abundance and distribution in the SK1 range, it is expected that AREVA will continue to work with the Saskatchewan Mining Association to contribute to ECCC’s National Recovery Strategy for Woodland Caribou [21]. Once a provincial range plan is in place for SK1, AREVA’s caribou management protection plan (within the McClean Lake Wildlife Management Plan) will require updating to reflect the findings and guidance of the provincial range plan.
Conclusion
Groundwater dewatering associated with future mining activities at the McClean Lake Operation are not expected to result in significant changes to wetland communities in the vicinity of the McClean Lake site. The potential effect of the predicted changes to soil and vegetation quality was modelled in the risk assessment for terrestrial biota and no adverse effects were predicted.
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The overall assessment indicated that there would be no negative effects to birds due to exposure of contaminants via the aquatic pathway, with the exception of potential impacts to birds feeding on insects that spend part of their lifecycle in McClean Lake East from selenium exposure. Risks to insect-eating birds are expected to be minimized if AREVA installs additional treatment for selenium to control releases to 10 µg/L by 2020. AREVA has proactively implemented a selenium risk management plan to protect fish health in McClean Lake East. This risk management plan is anticipated to also protect birds feeding on insects emerging from McClean Lake East, as concentrations in surface water will be closely monitored to ensure environmental concentrations remain as low as possible.
The potential effect of the predicted changes to vegetation quality was modelled in the risk assessment for terrestrial biota and no adverse effects were predicted.
3.2.2.5 Human Health
Public Exposure (Radiological)
The human receptors (adult, child and toddler age groups) selected in the human health risk assessment include:
the resident of Wollaston Lake which is 40 km from the McClean Lake site
the Wollaston Lake resident who spends three months of the year trapping in the area near the McClean Lake site
the operator of the fishing lodge located on Hidden Bay of Wollaston Lake
the Rabbit Lake non-NEW camp worker
the onsite non-NEW worker
the Points North worker; and
the Hatchet Lake Lodge operator
All estimated incremental doses were below the annual public effective dose limit of 1 mSv. The receptor with the highest estimated incremental dose was the Wollaston Lake resident who spends three months of the year trapping near the McClean Lake site. The estimated annual 95th percentile incremental effective dose to this receptor is 0.1 mSv (100 µSv) with an expected annual mean incremental effective dose of 0.03 mSv (30 µSv). The primary exposure pathways are ingestion of fish and duck.
Conclusion
CNSC concur with the 2016 ERA predictions for current and future operations at the McClean Lake site that radiation doses to members of the public are and will be continue to be below the public effective dose limit of 1 mSv.
Public Exposure (Non-radiological)
For the same human receptors selected for radiological human health risk assessment, the following COPCs were assessed: arsenic, cobalt, copper, lead, molybdenum, nickel, selenium,
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uranium, and zinc via the ingestion route (food, water and soil) of exposure, and arsenic and nickel via the inhalation route of exposure.
Estimated exposures to non-radionuclides for the adult, child, and toddler human receptors were modeled in the ERA. The model calculated annual exposures which were converted to a daily exposure by dividing the body weight of receptors (adult, child and toddler) and the number of days in a year (365 d). These exposures were compared to the toxicity reference values (TRVs). The TRVs, derived to protect the most sensitive individuals, were used in the assessment. For non-carcinogenic COPCs, the TRVs are based on threshold effects concentrations, and for carcinogenic COPCs, they are based on non-threshold effects. In addition, exposure to gaseous air pollutants such as NO2 and SO2, and particulate matter (dust of particle size PM10 and PM2.5), via the inhalation route were assessed using health-based criteria.
The non-radiological human health risk assessment indicated that, with the exception of selenium (see below), the predicted intakes of COPCs were not expected to have a negative effect on human receptors. The estimated incremental cancer risk for people was also negligible. The maximum concentrations of NO2 and SO2 were well within the health-based limits. Exposure of people off-site to particulate matter would be low but there would be short term exceedances at the JEB camp. Therefore, the probability of negative effects related to dust exposure was considered to be low.
With respect to selenium, consumption of fish and duck were the major contributors for selenium exposure in human receptors. If no additional treatment for selenium is implemented at the JEB WTP and selenium effluent concentrations were 100 µg/L, selenium intake would result in an exceedance of the TRV, with a potential risk of selenosis in exposed Wollaston Lake Trapper’s toddler and infant receptors. This potential risk would be concomitantly reduced if effluent selenium concentrations were 40 µg/L and would result in lower intakes of selenium in the Wollaston Lake Trapper receptors, notably for the toddler where exposures would be below the TRV. If additional treatment would reduce selenium concentrations to 10 µg/L, the potential risk of selenium exposures would be further reduced for these receptors. Therefore, ensuring the treatment of selenium in effluent is reduced to 10 µg/L will ensure the lowest risk of selenosis in human receptors exposed through consumption of fish and duck in the diet.
Conclusion
The overall assessment indicated that there would be no negative effects expected in humans from future operations at the McClean Lake site, provided that exposure to selenium was minimized through a reduction in selenium releases in the effluent. AREVA has implemented a Selenium Adaptive Management Plan in order to ensure that all possible measures to minimize selenium releases are taken, in the interim 4-year period prior to commissioning a long-term treatment facility by 2020. Additional mitigation measures will also be put into place such as increased water quality monitoring and supplemental studies on fish health, if required, to ensure that the fish tissue in McClean Lake East basin remains below the United States Environmental Protection Agency (EPA) fish tissue criterion for selenium. Treating selenium concentrations in the effluent to maintain concentrations at or below 10 µg/L will ensure the lowest risk of selenosis in humans exposed through consumption of fish and duck in the diet.
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3.2.2.6 OVERALL CONCLUSIONS
The ERA, in concordance with previous EAs and ERAs, concluded that future operations at the McClean Lake site will not result in impacts to the environment from exposure to radiological contaminants and non-radiological contaminants, with the exception of selenium exposure for aquatic biota and for birds feeding on insects that spend part of their lifecycle in aquatic habitat. Risks to these receptors will be minimized if AREVA installs additional treatment for selenium to control releases to 10 µg/L by 2020.
Predicted radiation doses to members of the public from future operations, including current and future operations, decommissioning and post decommissioning, at the McClean Lake site are below the public effective dose limit of 1 mSv. The human health risk assessment for non-radiological contaminants indicated that there would be no negative effects expected in humans from future operations, provided that exposure to selenium was reduced through a reduction in selenium releases in the effluent. Treating selenium concentrations in the effluent to ensure concentrations are at or below 10 µg/L will ensure the lowest risk of selenosis in humans.
AREVA has proactively implemented a selenium risk management plan and will submit a Selenium Adaptive Management Plan to meet the requirements of the Nuclear Safety and Control Act and corresponding regulations to ensure continued protection of the environment.
CNSC staff concludes that AREVA is making adequate provision for the protection of the environment and human health as part of their relicensing application.
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4.0 CNSCIndependentEnvironmentalMonitoringProgramThe CNSC has implemented its IEMP to verify that the public and the environment around licensed nuclear facilities are protected. It is separate from, but complementary to, the CNSC’s ongoing compliance verification program. The IEMP involves taking samples from public areas around the facilities, and measuring and analyzing the amount of radiological (nuclear) and hazardous substances in those samples. CNSC staff collect the samples and in the case of most IEMP sampling campaigns, send them to the CNSC’s state-of-the-art laboratory for testing and analysis.
In part, due to the remote location of uranium mines and mills, CNSC contracted out the collection and analysis of the samples for the McClean Lake Operation to Canada North Environmental Services Limited (CanNorth). To maintain its independence, CNSC’s IEMP field technician accompanied CanNorth and assisted in the sample collection and preparation for shipping and analysis. The samples were sent to Saskatchewan Research Council’s (SRC) laboratory for analysis as the volume of samples exceeded the capacity of the CNSC lab.
4.1 IEMPatMcCleanLakeThe IEMP for the McClean Lake Operation consists of measurements of COPCs in the environment based on the potential releases from the McClean Lake Operation. A site-specific sampling plan was developed based on AREVA’s approved environmental monitoring programs and the CNSC’s regulatory experience with the site. In 2016, samples were collected around a reference and exposure lake outside the perimeter of the McClean Lake site (as shown in figure 4.1.1) [28]. IEMP sampling for the McClean Lake Operation focused on both radiological (nuclear) and non-radiological (hazardous) contaminants.
CNSC staff sampled the following in the vicinity of the McClean Lake Operation (shown in figures 4.1.2 and 4.1.3):
radon in ambient air (6 locations in 2016)
water (2 locations in 2016)
fish – (20 whitefish and 20 northern pike from 2 lakes in 2016)
gamma radiation (8 locations in 2016)
traditional plants – Labrador tea (8 locations in 2016)
foodstuff – wild blueberries (8 locations in 2016)
Samples were collected by qualified personnel from the CNSC and an environmental contractor. Samples were analyzed, under contract to the CNSC, in SRC’s laboratory in Saskatoon.
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Figure 4.1.1: Overview of the McClean Lake Operation IEMP Sampling Program
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Figure 4.1.2: Locations of 2016 IEMP Samples near the McClean Lake Operation
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Figure 4.1.3: Locations of 2016 IEMP Samples near the McClean Lake Operation
4.2 ResultsThe IEMP results indicate that the public and the environment in the vicinity of the McClean Lake site are protected from the releases from the facility. The measured radioactivity in all samples was below CNSC screening levels. CNSC screening levels are established based on conservative assumptions about the exposure scenario and using CSA Standard N288.1-14 [29]. The screening level for a particular radionuclide in a particular medium (e.g., water, air and foodstuff) represents the activity concentration that would result in a dose of 0.1 mSv per year. The approach used by CNSC staff to calculate a screening level is similar to Health Canada and World Health Organization’s approach for drinking water guidelines where 0.1 mSv per year is also used.
Conservative assumptions that are taken into account when calculating screening levels include the use of upper percentiles of population inhalation and ingestion rates, full-time occupancy factors at given locations, conservative estimates of time spent outdoors and the use of dose conversion factors that already have safety factors built in. The primary difference in screening levels between different types of food consumed is reflective of the difference in the ingestion/consumption rates of that particular food in a year. Screening levels developed for the
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McClean Lake IEMP sampling campaign are conservative and based on ingestion rates for a regional Indigenous diet.
Tables 4.1, 4.2 and 4.3 provide the range of results from the 2016 sampling campaign. The IEMP results are currently available through a public-friendly dashboard on CNSC’s website, http://nuclearsafety.gc.ca/eng/resources/maps-of-nuclear-facilities/iemp/index-iemp.cfm. Full technical reports are available upon request. It should be noted that radon in ambient air is monitored through the use of track-etch cups stationed over a period of a year. Results of radon will be made available on the public website following their retrieval and analysis.
The IEMP results indicate that the public and the environment around the McClean Lake Operation are protected and that there are no health or environmental impacts associated with the McClean Lake Operation.
Some pH levels in water samples were slightly below the guidelines, however they are within known regional background levels. The pH in this area is naturally low which is attributed to natural acid generating conditions. There is no concern to the environment or to human health at these levels.
Levels of polonium-210 and lead-210 in some fish samples were slightly above the highly conservative screening levels. These concentrations were identified in fish caught from both the exposure station and the reference station, which is not impacted by the operation of the facility and is considered background. These levels are also within the natural background of the region, and are not expected to result in any adverse health effects [30].
These results are consistent with the results submitted by AREVA, demonstrating that the licensee’s environmental protection program continues to protect the health of persons and the environment.
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Table 4.1: Summary of the McClean Lake IEMP 2016 results
(1) the concentration required for a hypothetical person (most exposed member of a critical group) to receive an
effective whole body dose of 0.1 mSv/year due to exposure to the given radionuclide. Screening levels
calculated based on conservative assumptions using CSA Standard N288.1‐14 [29] and using a regional
Indigenous diet [31]
(2) the < symbol indicates that a result is below the detection limit for laboratory analysis
(3) some pH levels are slightly below the guidelines, however they are within known regional background levels
(4) regional background taken from the CNSC report, Environmental Performance of Uranium Mine or Mill
Regulated Under the Nuclear Safety and Control Act: Based on Environmental Data Associated with Operating
Uranium Mines and Mills (2000 – 2012) presented at the Quebec Bureau d’audiences publiques sur
5.0 CONCLUSIONCNSC staff reviewed and assessed AREVA’s environmental protection measures against regulatory requirements. Furthermore, CNSC staff completed regular compliance verification activities (e.g., inspections, audits, reviews) to ensure AREVA’s environmental protection measures continue to meet CNSC regulatory requirements.
CNSC staff also reviewed AREVA’s most recent ERA and PDP submitted as part of licensing and regulatory requirements. The PDP was reviewed to ensure that the full life-cycle of the McClean Lake Operation was taken into consideration, and CNSC staff have concluded that it meets regulatory criteria and CSA Group standards. CNSC staff have also concluded that the ERA is satisfactory and meets both the requirements of the CNSC and CSA Group standard N288.6-12, Environmental risk assessment at Class I nuclear facilities and uranium mines and mills.
CNSC IEMP 2016 results are consistent with the results submitted by AREVA, demonstrating the licensee’s environmental protection program protects the health of persons and the environment.
This EA under the NSCA conducted for the McClean Lake Operation licence renewal concludes that AREVA has made, and will continue to make, adequate provision for the protection of the environment and the health of persons. Through ongoing licensing and compliance activities and reviews, CNSC staff will continue to verify and ensure that the environment and the health of persons are protected, and will continue to be protected, until the safe state and abandonment of the McClean Lake Operation.
The information provided in this EA Report supports the recommendation by CNSC staff to the Commission to renew the McClean Lake Operation Operating Licence.
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ACRONYMS
Acronym Term
AL Action Level
ALARA As Low As Reasonably Achievable
AREVA AREVA Resources Canada Inc.
BATEA Best Available Technology Economically Achievable
CEAA, 2012 Canadian Environmental Assessment Act, 2012
CEAR Canadian Environmental Assessment Registry
CEPA Canadian Environmental Protection Act
CNSC Canadian Nuclear Safety Commission
COPCs Contaminants of Potential Concern
CSA Canadian Standards Association
DDP Detailed Decommissioning Plan
DRL Derived Release Limit
EA Environmental Assessment
EARPGO Environmental Assessment Review Process Guidelines Order
[2] AREVA Resources Canada Inc. McClean Lake Operation Technical Information Document. Environmental Performance Volume 1 of 2 – Environmental Monitoring, May 2016, e-Doc: 5012881
[3] AREVA Resources Canada Inc. McClean Lake Operation Technical Information Document. Environmental Performance Volume 2 of 2 – Environmental Risk Assessment, September 2016, e-Doc: 5094511
[4] AREVA Resources Canada Inc., JEB Tailings Management Facility Expansion Project, August 2011, e-Doc: 3800270
[5] AREVA Resources Canada Inc., McClean Lake Operation, Preliminary Decommissioning Plan and Financial Assurance, Version 8, Revision 3, October 2016, e-Doc: 4953011
[6] Joint Panel 1993. Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan: Dominique-Janine Extension, McClean Lake Project, and Midwest Joint Venture. October 1993.
[7] Joint Panel 1997a. McArthur River Uranium Mine Project. Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan. February 1997.
[8] Joint Panel, 1997b. Report of the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan: Midwest Uranium Mine Project; Cigar Lake Uranium Mining Project; Cumulative Observations, November 1997
[16] Cigar Lake Mining Corporation. The Cigar Lake Project: Environmental Impact Statement, Impact Prediction and Mitigation.1995, e-Doc: 4870399
[17] Canadian Nuclear Safety Commission. 2012. RD/GD-370: Management of Uranium Mine Waste Rock and Mill Tailings. http://nuclearsafety.gc.ca/pubs_catalogue/uploads/March-2012-RDGD-370-Management-of-Uranium-Mine-Waste-Rock-and-Mill-Tailings_e.pdf
[18] CNSC. Letter to Dale Huffman from Salman Akhter. December 22, 2016. McClean Lake Operation Notification of modification to the JEB Tailings Management Facility expansion project. e-Doc: 5149299
[19] AREVA Resources Canada Inc., McClean Lake Operation, ‘Environmental Protection Code of Practice, Version 1, Revision 7’, October 2016, e-Doc: 5107660
[20] CNSC Regulatory Document G-219: Decommissioning Planning for Licensed Activities, June 2000, http://nuclearsafety.gc.ca/eng/acts-and-regulations/regulatory-documents/index.cfm
[21] Environment Canada. 2012. Recovery Strategy for the Woodland Caribou (Rangifer tarandus caribou), Boreal population, in Canada. Species at Risk Act Recovery Strategy Series. Ottawa. xi + 138pp. http://www.sararegistry.gc.ca/virtual_sara/files/plans/rs_caribou_boreal_caribou_0912_e1.pdf
[22] AREVA Resources Canada Inc., Letter to Salman Akhter from Dale Huffman. McClean Lake Operation – Update on Selenium Risks and Improvement Initiatives. November 18, 2016, e-Doc: 5126369
[23] Ontario Ministry of the Environment (MOE), Ontario’s Ambient Air Quality Criteria, PIBS#6570e01, Prepared by Standards Development Branch, April 2012, http://www.airqualityontario.com/downloads/AmbientAirQualityCriteria.pdf
[24] AREVA Resources Canada Inc. Letter to Salman Akhter from Dale Huffman. McClean Lake Operation – Selenium Management. May 25, 2016, e-Doc: 5008472
[25] AREVA Resources Canada Inc. Letter to Salman Akhter from Dale Huffman. McClean Lake Operation – Selenium Risk Management – Revision and Response to Comments. October 27, 2016, e-Doc: 5112674
[26] CNSC. Letter to Dale Huffman from Salman Akhter. McClean Lake Operation Environmental Performance Technical information Document, Volume 2 – Environmental Risk Assessment. December 9, 2016. e-Doc: 5142751
[27] Canadian Council of Ministers of the Environment, Canadian Environmental Quality Guidelines - Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health, http://st-ts.ccme.ca/en/index.html?chems=all&chapters=4
February 2017 Environmental Assessment Report
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[28] AREVA. McClean Lake Operation - Environmental Monitoring Program Locations, Frequencies and Parameters. October 2016, e-Doc: 5115434
[29] CSA Group, CSA N288.1-14, Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities, Update No.2, 2014
[30] CNSC. Environmental Performance of a Uranium Mine or Mill Regulated Under the Nuclear Safety and Control Act, Based on Environmental Data Associated with Operating Uranium Mines and Mills (2000 – 2012). October 2014, e-Doc: 4479810
[31] Canada North Environmental Services (CanNorth). 1999. Hatchet Lake dietary study. Prepared for the Atomic Energy Control Board, Ottawa, Ontario
[32] Richardson, G.M. 1997. Compendium of Canadian Human Exposure Factors for Risk Assessment. Ottawa: Published by O'Connor Associates Environmental Inc.
[33] McAuley, C., Dersch, A., Kates L.N., Sowan, D.R. and Ollson, C.A. 2016. Improving
Risk Assessment Calculations for Traditional Foods Through Collaborative Research with First Nations Communities. Risk Analysis, 36: 2195-2207. Doi:10.1111/risa.12578
[34] Health Canada. 2010. Federal Contaminated Site Risk Assessment in Canada. Part II:
Health Canada Toxicological Reference Values (TRVs) and Chemical-Specific Factors. Version 2.0
[35] AREVA Resources Inc. E-mail to Salman Akhter from Dale Huffman. February 8, 2017.
McClean Lake Operation – Response to CNSC Comments on Tailings Management Facility Project. e-Doc: 5186303
[36] AREVA Resources Inc. E-mail to Salman Akhter from Tina Searcy. February 27, 2017. 20170224 – AREVA Follow Up Responses on TMF Expansion - DRAFT. e-Doc: 5199082
Overview AREVA’s operating licence for the MLO was renewed on July 1, 2009 for an eight-year term with an expiry date of June 30, 2017. The licence was amended following a one-day public hearing held on October 24, 2012. The amended licence issued by the Commission was presented in a new format and, for the first time, was accompanied by a licence conditions handbook (LCH) prepared by CNSC staff. Since the licence amendment, the LCH has been subject to continuous improvements to enhance regulatory oversight as a result of experience gained.
Operating Licence The proposed licence for the MLO continues to contain conditions that authorize changes that are within the licensing basis as defined in CNSC’s information document INFO-0795, Licensing Basis Objective and Definition. Standard licence conditions included in the licence allows the licensee to implement and maintain programs for CNSC’s defined SCA. The proposed licence uses the standard format and incorporates the current standard licence conditions.
Other notable change to the proposed licence is described below:
Appendix B containing Authorized Effluent Discharge Limits removed from the current licence and moved to the draft LCH under licence condition 9.2 for consistency with other operating uranium mines and mills.
The current MLO licence and proposed MLO licence are attached to this CMD.
Licence Conditions Handbook The draft LCH describes the compliance verification criteria (CVC) on how the licensee is expected to meet the licence conditions in the proposed licence. A consistent format for all licence conditions has been applied, which includes a preamble, CVC and guidance sections. The LCH also describes the process to be followed by the licensee and CNSC staff when making changes to the facility, its operation or safety and control measures as described the licence application and supporting documentation.
The draft LCH under licence condition 9.2 includes Authorized Effluent Discharge Limits as described above, AREVA’s commitments for the implementation of CNSC regulatory documents, codes and standards and updated CVC to improve regulatory clarity and reflect program updates and improvements at the MLO.
The Commission considers the LCH in its decision to renew the MLO’s operating licence and maintains regulatory oversight by receiving annual updates of major LCH changes through annual regulatory oversight reports presented to the Commission at public proceedings.
Canadian Nuclear Commission canadienne Safety Commission de sûreté nucléaire
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URANIUM MINE OPERATING LICENCE AREVA RESOURCES CANADA INC.
McCLEAN LAKE OPERATION
I) LICENCE NUMBER: UMOL-MINEMILL-McCLEAN.00/2029 II) LICENSEE: Pursuant to section 24 of the Nuclear Safety and Control Act,
this licence is issued to:
AREVA Resources Canada Inc. 817 – 45th Street West P.O. Box 9204 Saskatoon, Saskatchewan S7K 3X5
III) LICENCE PERIOD: This licence is valid from July 1, 2017 to June 30, 2029, unless
otherwise suspended, amended, revoked, replaced or transferred.
IV) LICENSED ACTIVITIES:
This licence authorizes the licensee to:
a) operate and modify a nuclear facility (hereinafter, “the facility”) for the mining of uranium ore and the production of uranium concentrate at a site known as the McClean Lake Operation in the province of Saskatchewan, as shown on the drawing referenced in appendix A to this licence
b) mine a nuclear substance (uranium ore)
c) produce a uranium concentrate
d) import, possess, use, store, transfer and dispose of nuclear substances and radiation devices that are required for or associated with laboratory studies, field studies, fixed gauge use and borehole logging devices
Licence page 2 of 7 UMOL-MINEMILL-McCLEAN.00/2029
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V) EXPLANATORY NOTES:
a) Unless otherwise provided for in this licence, words and expressions used in this licence have the same meaning as in the Nuclear Safety and Control Act and its associated Regulations.
b) The McClean Lake Operation Licence Conditions Handbook (LCH) identifies the criteria used to meet the conditions of this licence. The LCH also provides information regarding delegation of authority and document version control.
VI) CONDITIONS: G. GENERAL G.1 Licensing Basis for Licensed Activities
The licensee shall conduct the activities described in Part IV of this licence in accordance with the licensing basis, defined as:
(i) the regulatory requirements set out in the applicable laws and regulations
(ii) the conditions and safety and control measures described in the facility’s or
activity’s licence and the documents directly referenced in that licence
(iii) the safety and control measures described in the licence application and the documents needed to support that licence application
unless otherwise approved in writing by the Canadian Nuclear Safety Commission (hereinafter “the Commission”).
G.2 Notification of Changes
The licensee shall give written notification of changes to the facility or its operation, including deviation from design, operating conditions, policies, programs and methods referred to in the licensing basis.
G.3 Financial Guarantee
The licensee shall maintain a financial guarantee for decommissioning that is acceptable to the Commission.
G.4 Public Information and Disclosure The licensee shall implement and maintain a public information and disclosure program.
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1. MANAGEMENT SYSTEM 1.1 Management System
The licensee shall implement and maintain a management system. 1.2 Management of Contractors
The licensee shall ensure that every contractor working at the facility complies with this licence.
2. HUMAN PERFORMANCE MANAGEMENT 2.1 Training Program The licensee shall implement and maintain a training program. 3. OPERATING PERFORMANCE 3.1 Operations Program The licensee shall implement and maintain an operating program, which includes a set of
operating limits. 3.2 Reporting Requirements
The licensee shall implement and maintain a program for reporting to the Commission or a person authorized by the Commission.
3.3 Nuclear Substances and Radiation Devices
The licensee shall implement and maintain a program for nuclear substances and radiation devices.
4. SAFETY ANALYSIS 4.1 Safety Analysis Program The licensee shall implement and maintain a safety analysis program. 5. PHYSICAL DESIGN 5.1 Design Program
The licensee shall implement and maintain a design program.
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6. FITNESS FOR SERVICE 6.1 Fitness for Service Program
The licensee shall implement and maintain a fitness for service program.
7. RADIATION PROTECTION 7.1 Radiation Protection Program
The licensee shall implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 24 hours.
8. CONVENTIONAL HEALTH AND SAFETY 8.1 Conventional Health and Safety Program
The licensee shall implement and maintain a conventional health and safety program. 9. ENVIRONMENTAL PROTECTION 9.1 Environmental Protection Program
The licensee shall implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 24 hours.
9.2 Reaching or Exceeding Effluent Discharge Limits The licensee shall where the effluent concentration reaches or exceeds the discharge
limits specified in the Metal Mining Effluent Regulations, immediately investigate and take corrective action to ensure that the effluent concentration is maintained below the discharge limits.
10. EMERGENCY MANAGEMENT AND FIRE PROTECTION 10.1 Emergency Preparedness Program
The licensee shall implement and maintain an emergency preparedness program.
10.2 Fire Protection Program The licensee shall implement and maintain a fire protection program.
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11. WASTE MANAGEMENT 11.1 Waste Management Program The licensee shall implement and maintain a waste management program. 11.2 Decommissioning Strategy The licensee shall implement and maintain a decommissioning strategy. 12. SECURITY 12.1 Security Program The licensee shall implement and maintain a security program. 13. SAFEGUARDS AND NON-PROLIFERATION 13.1 Safeguards Program The licensee shall implement and maintain a safeguards program. 14. PACKAGING AND TRANSPORT 14.1 Packaging and Transport Program
The licensee shall implement and maintain a packaging and transport program. SIGNED at OTTAWA, this ______ day of ______________, 2017. ___________________________________________ Michael Binder, President on behalf of the Canadian Nuclear Safety Commission
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APPENDIX A
LOCATION OF THE McCLEAN LAKE OPERATION
The location of the McClean Lake Operation is shown on McClean Lake Operation Drawing No. ML100-D-015 (e-Doc 5146834).
Sections changed: 2.4, 4.1, 4.3 Appendix C.1 Added information about the JEB Mill Upgrade Project; updated the versions of the Mining Facility Licensing Manual, the Radiation Protection Code of Practice and the Dosimetry Monitoring Strategy; changed name of MED Program to SABRE Project; added CVC 4.3.9 and made minor editorial changes
N/A
April 23, 2014 2 3826266 (Word) 3991355 (PDF)
Throughout document: Changed Document Version Control to Written Notification Documents; Editorial changes Section 4.1: Added reference to Commissioning Management Plan and ore slurry storage on JEB Ore Pad Section 4.3: Added Co-60 nuclear gauges to Table of Authorized Devices Sections 10.1, 13.1, C.1, C.2, D.2: Updated references
All changes recorded in e-Doc 4419950
June 23, 2016 3 3826266 (Word) 3991355 (PDF)
Section 2.4: Added text for use of JEB Ore Pad as a contingency measure; changed annual production from 13 to 24 million pounds Section 3.1: Text modified for the sections “Compliance Verification Criteria” and “Recommendations and Guidance” to be consistent with other DNCFR facilities Section C.1: Updated reference for Radiation Code of Practice Section C.2: Documents added to the licensing basis Section D.2: REGDOC-2.2.2 added and updated reference for TPED-01
Section 2.4: Added text: Disposal of tailings up to 448 metres above sea level Section 5.1: Moved text related to ERA from the safety analysis SCA to the environmental protection SCA Section 10.2: Added authorized effluent discharge limits Updated licensee documents Updated licensing basis and guidance references
15. FACILITY SPECIFIC ........................................................................................ 51
APPENDIX A CHANGE CONTROL PROCESS ........................................................... 52
APPENDIX B LICENSEE DOCUMENTS THAT REQUIRE NOTIFICATION OF CHANGE ............................................................................................................ 57
APPENDIX C LIST OF DOCUMENTS USED AS GUIDANCE OR CRITERIA ............ 58
The general purpose of the Licence Conditions Handbook (LCH) is to identify and clarify the relevant parts of the licensing basis for each licence condition (LC). This will help ensure that the licensee maintains facility operation in accordance with the licensing basis for the facility and the intent of the licence. The LCH should be read in conjunction with the licence.
The LCH typically has three parts under each LC: the Preamble, Compliance Verification Criteria (CVC), and Guidance. The Preamble explains, as needed, the regulatory context, background, and/or history related to the LC. CVC are criteria used by CNSC staff to oversee compliance with the LC. Guidance is non-mandatory information, including direction, on how to comply with the LC.
Throughout the licence, the statement “or consent of a person authorized by the Commission” reflects to whom the Commission may delegate certain authority (hence “consent”) to CNSC staff. Unless otherwise indicated in the CVC of specific LCs in this LCH, the delegation of authority by the Commission to act as a “person authorized by the Commission” is only applied to the incumbents of the following positions (source: Record of Decision 2017):
• Director, Uranium Mines and Mills Division
• Director General, Directorate of Nuclear Cycle and Facilities Regulation
Interaction between the licensee and CNSC staff that is described in this LCH is governed by the prevailing communications protocol between the two, unless specified otherwise in the LCH.
This LCH has the following appendices.
• APPENDIX A, which describes the change control process applied to the LCH
• APPENDIX B, which lists licensee documents that require notification of changes
• APPENDIX C, which lists documents used as guidance or criteria
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GENERAL
G. GENERAL
Licence Condition G.1 The licensee shall conduct the activities described in Part IV of this licence in accordance with the licensing basis, defined as:
i) the regulatory requirements set out in the applicable laws and regulations
ii) the conditions and safety and control measures described in the facility's or activity's licence and the documents directly referenced in that licence
iii) the safety and control measures described in the licence application and the documents needed to support that licence application
unless otherwise approved in writing by the Canadian Nuclear Safety Commission (hereinafter “the Commission”).
Preamble The licensing basis is discussed in CNSC INFO-0795.
The authorized activities at the McClean Lake Operation include:
• operation of the McClean Lake mill to produce up to 10,909,090 kilograms (24 million pounds) of uranium concentrate (U3O8) per year
• mining of uranium ore and receipt of uranium ore from other mines
• disposal of tailings in the JEB tailings management facility (JEB TMF) up to a consolidated tailings elevation of 448 metres above sea level (MASL), which is the approximate low point of the natural ground elevation
• operation of the JEB dewatering and water management systems and the JEB water treatment plant (JEB WTP)
• operation of the Sue water treatment plant (Sue WTP)
• operation of the Sink/Vulture treated effluent management system (S/V TEMS)
• care and maintenance of the Midwest Project site
• storage of clean and special waste rock
• operation of the Surface Access Borehole Resource Extraction (SABRE) Project
• handling and storage of hazardous materials and disposal of hazardous wastes
• import, possess, use, store, transfer and dispose of nuclear substances and radiation devices that are required for or associated with laboratory studies, field studies, fixed gauge usage and borehole logging devices
• use of storage cell on the JEB ore pad as a contingency measure only to store Cigar Lake ore slurry (ore slurry quantity will not increase from the surrounding ditch capacity available at the time of use and AREVA will provide a written notification before implementing a contingency plan)
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Environmental assessments carried out since 1995 until most recently in 2012 evaluated the environmental effects from the operation of the JEB mill at an annual production rate up to 12.247 million kilograms (27 million pounds) of uranium concentrate from the following ore sources: JEB, Sue, Caribou, McClean, Cigar Lake, Midwest and McArthur River. As a result, all of them are approved sources of ore for the JEB mill. AREVA is required to provide prior notification before processing other ore sources or increasing the annual production rate above 10,909,090 kilograms (24 million pounds) of uranium concentrate per year to the CNSC so that it can be verified that the proposed activities meet CNSC requirements and remain within the licensing basis for the McClean Lake Operation.
There are no active mines at McClean Lake; however, environmental assessments have been carried out for the mining of the Midwest, Caribou, McClean, JEB and the Sue ore bodies. Prior to constructing or operating a mine for these ore bodies or future ore bodies, AREVA is required to submit detailed construction and operating plans, designs and programs for mining the ore body or ore bodies to the CNSC so that it can be verified that the proposed activities meet CNSC requirements and remain within the licensing basis for the McClean Lake Operation.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Licensing Basis, Objective and Definition INFO-0795
Licensing Basis Documents
Source Document Title Document Number Notification Requirements
AREVA Minatco Ltd., The McClean Lake Project - Environmental Impact Statement, 1991
AREVA Cigar Lake Mining Corporation, Cigar Lake Project Environmental Impact Statement
N/A Acceptance
AREVA COGEMA Resources Inc. and Cigar Lake Mining Corporation, Disposal of Cigar Lake Waste Rock, Environmental Impact Statement, COGEMA Resources Inc. and Cigar Lake Mining Corporation, 2001
1037776 Acceptance
AREVA McClean Lake 6 to 8 Million Pound Production Increase Screening Report
AREVA AREVA Resources Canada Inc., Receipt and Processing of McArthur River Ore at the McClean Lake Operation, 2011
3766698 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, 265ML JEB Mill Upgrade – Technical Support Document, December 2012 and HAZOP Risk Register, March 2013
4054241 4115664
Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Notification of Changes to the Leaching Circuit, January 2014
4276885 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Report on Commissioning and Restart of the McClean Lake Mill, December 2015
4909213 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Notification of Increase to McClean Lake Annual Production Rate, February 2016
4932128 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Technical Information Document, Tailings Management, Version 02, Revision 00, May 2015
4775706 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Technical Information Document, Hydrogeology and Groundwater Modeling of the Collins Creek Basin, Version 2, December 2011
3870068 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Technical Information Document, Environmental Performance, Version 02,Revision 00, January 2012
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Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation, Technical Information Document, Environmental Performance, Volume 2 of 2 – Environmental Risk Assessment, Version 3, September 2016
5094511 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Technical Information Document, Waste Rock Management, Version 02, Revision 00, June 2013
4163394 Acceptance
AREVA AREVA Resources Canada Inc., McClean Lake Operation, Environmental Monitoring Program Design Document, Version 2, Revision 0, October 2016
5115434 Acceptance
Part (i) of the licensing basis lists the applicable laws and regulations that are set out in several federal statutes and agreements, including the following:
• the Nuclear Safety and Control Act
• the Canadian Environmental Assessment Act
• the Canadian Environmental Protection Act
• the Nuclear Liability and Compensation Act
• the Transportation of Dangerous Goods Act
• the Radiation Emitting Devices Act
• the Access to Information Act
• the Canada/International Atomic Energy Agency (IAEA) Safeguards Agreement Part (iii) of the licensing basis consists of the safety and control measures described in the licence application and the documents needed to support that licence application. The safety and control measures include important aspects of analysis, design, operation, etc. They may be found in high-level, programmatic licensee documents but might also be found in lower-level, supporting documentation. They also include safety and control measures in licensing basis publications (e.g., CNSC REGDOCs or CSA Group standards) that are cited in the application or in the licensee’s supporting documentation.
Licensing basis publications are listed in tables in this LCH under the most relevant LC. All “shall” or normative statements in licensing basis publications are considered CVC unless stated otherwise. If any “should” or informative statements in licensing basis publications are also considered CVC, this is also explained under the most relevant LC.
The licensee documents in question, as well as the relevant licensing basis publications, may cite other documents that also contain safety and control measures (i.e., there may be safety and control measures in “nested” references). There is no predetermined limit to the degree of nesting at which relevant safety and control measures may be found.
LC G.1 requires the licensee to conform to, and/or implement, all the safety and control measures.
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GENERAL
Note, however, that not all details in referenced documents are necessarily considered to be safety and control measures.
• Details that are not directly relevant to safety and control measures for facilities or activities authorized by the licence are excluded from the licensing basis.
• Details that are relevant to a different safety and control area (i.e., not the one associated with the main document), are only part of the licensing basis to the extent they are consistent with the main requirements for both safety and control areas.
The licensing basis is established by the Commission at the time the licence is issued. Per LC G.1, operation during the licence period that is not in accordance with the licensing basis is only allowed based on the written approval of the Commission. Similarly, only the Commission can change the licensing basis during the licence period; this would also be expected to be recorded in writing.
In the event of any perceived or real conflict or inconsistency between two elements of the licensing basis, the licensee shall consult CNSC staff to determine the approach to resolve the issue.
This LC is not intended to unduly inhibit the ongoing management and operation of the facility or the licensee’s ability to adapt to changing circumstances and continuously improve, in accordance with its management system. Where the licensing basis refers to specific configurations, methods, solutions, designs, etc., the licensee is free to propose alternate approaches as long as they remain, overall, in accordance with the licensing basis and have a neutral or positive impact on health, safety, the environment, security, and safeguards. However, the licensee shall assess changes to confirm that operations remain in accordance with the licensing basis.
Changes to certain licensee documents require written notification to the CNSC, even if they are in accordance with the licensing basis. Further information on this topic is provided under LC G.2.
For unapproved operation that is not in accordance with the licensing basis, the licensee shall take action as soon as practicable to return to a state consistent with the licensing basis, taking into account the risk significance of the situation.
In the event that the Commission grants approval to operate in a manner that is not in accordance with the licensing basis, this would effectively establish a revised licensing basis for the facility. The appropriate changes would be reflected in the CVC of the relevant LC.
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Guidance When the licensee becomes aware that a proposed change or activity might not be in accordance with the licensing basis, it should first seek direction from CNSC staff regarding the potential acceptability of this change or activity. The licensee should take into account that certain types of proposed changes might require significant lead times before CNSC staff can make recommendations and/or the Commission can properly consider them. Guidance for notifications to CNSC related to licensee changes are discussed under LC G.2.
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Licence Condition G.2 The licensee shall give written notification of changes to the facility or its operation, including deviation from design, operating conditions, policies, programs and methods referred to in the licensing basis.
Preamble
CNSC staff track, in appendix B, the version history of licensee documents that require notification of change. Tables under each LC in the LCH identify the documents (if any) requiring written notification of change. Notification requirements follow for these documents, as some may be adopted without prior notification, while others require notification prior to implementation, and others require notification and acceptance by the CNSC prior to implementation. The abbreviations for each definition follow with its associated clarification requirements.
Definition Abbreviation Description
Notification Required Notification Notification to the CNSC is required, but implementation by the licensee may be immediate.
Prior Notification Required Advance
Prior notification of 30 days is required. Unless CNSC staff have comments, no formal acknowledgement of receipt will be given.
Prior Notification and Acceptance Required Acceptance
Prior notification and CNSC acceptance is required before implementation. CNSC staff will formally acknowledge receipt of the submission and report acceptance of the submission before authorization to implement is granted.
Compliance Verification Criteria Written notification is a physical or electronic communication from a person authorized to act on behalf of the licensee to a CNSC delegated authority or a CNSC staff member acting on behalf of a CNSC delegated authority.
In general, the changes for which the licensee shall notify the CNSC are captured as changes to specific licensee documents. The LCH identifies them under the most relevant LC. However, the licensee documents identified in the LCH only represent the minimum subset of documents that require notification of change. For any change that is not captured as a change to a document identified in the LCH, if it negatively impacts designs, operating conditions, policies, programs, methods, or other elements that are integral to the licensing basis, the licensee shall provide written notification of the change. For example, if a licensee document in the CVC refers to another document, including a third-party document, without citing the revision number of that document, if that document changes and the licensee uses the revised version, the licensee shall determine if it is necessary to notify the CNSC of the change.
The documents needed to support the licence application may include documents produced by third parties (e.g., reports prepared by third party contractors). Changes to these documents require written notification to the CNSC only if the new version continues to form part of the licensing basis. That is, if the licensee implements a new version of a document prepared by a third party, it shall inform the CNSC of the change(s), per LC G.2. On the other hand, if a third
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GENERAL
party has updated a certain document, but the licensee has not adopted the new version as part of its safety and control measures, the licensee is not required to inform the CNSC that the third party has changed the document.
Licensee documents tabulated in the CVC of the LCH are subdivided into groups having different requirements for notification of change – ones that require prior written notification of changes and those that require written notification only. For the former type, the licensee shall submit the document to the CNSC prior to implementing the change. Typically, the requirement is to submit the proposed changes 30 days prior to planned implementation; however, the licensee shall allow sufficient time for the CNSC to review the change proportionate to its complexity and the importance of the safety and control measures being affected. For the latter type, the licensee need only submit the document at the time of implementing the change.
If the licensee document, or some part of it, also requires CNSC acceptance of change, add a footnote to the table. Such a requirement may be established in the document itself, in another LC, or in a licensing basis publication.
Written notifications shall include a summary description of the change, the rationale for the change, expected duration (if not a permanent change), and a summary explanation of how the licensee has concluded that the change remains in accordance with the licensing basis (e.g., an evaluation of the impact on health, safety, security, the environment and Canada’s international obligations). A copy of the revised written notification document shall accompany the notification. All written notifications shall be transmitted to CNSC per established communications protocols.
Changes that are not clearly in the safe direction require further assessment of impact to determine if Commission approval is required in accordance with LC G.1.
The licensee shall notify the CNSC in writing when it plans to implement a new licensing basis publication, including the date by which implementation of the publication will be complete. The notice shall indicate the corresponding changes to licensee documents listed in CVC of the LCH.
Guidance For proposed changes that would not be in accordance with the licensing basis, the Guidance for LC G.1 applies.
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GENERAL
Licence Condition G.3
The licensee shall maintain a financial guarantee for decommissioning that is acceptable to the Commission.
Preamble The General Nuclear Safety and Control Regulations require that a licence application contain a description of any proposed financial guarantee relating to the activity to be licensed. The latest revision of the preliminary decommissioning plan and estimation of the cost of decommissioning were finalized in Preliminary Decommissioning Plan and Financial Assurance, October 2016. Letters of credit payable to the Saskatchewan Ministry of Environment for C$107,241,000 are sufficient to fund the estimated cost of implementing the preliminary decommissioning plan.
As part of the licensee’s annual report, to be submitted by March 31st each year, the licensee shall confirm that the letters of credit remain valid.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CSA Group
Decommissioning of Facilities Containing Nuclear Substances N294-09
CNSC Decommissioning Planning for Licensed Activities G-219
CNSC Financial Guarantees for the Decommissioning of Licensed Activities G-206
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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Licence Condition G.4
The licensee shall implement and maintain a public information and disclosure program.
Preamble The primary goal of the public information and disclosure program is to ensure that information related to the health and safety of persons and the environment and other issues associated with the lifecycle of the nuclear facility is effectively communicated to the public. In addition, the program shall include a commitment to and protocol for ongoing, timely communications regarding emissions, effluent releases, unplanned events and other incidents and activities related to the licensed facility that may be of interest to the public.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Public Information and Disclosure RD/GD-99.3
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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MANAGEMENT SYSTEM
1. MANAGEMENT SYSTEM Licence Condition 1.1
The licensee shall implement and maintain a management system.
Preamble The “management system” safety and control area covers the framework which establishes the processes and programs required to ensure an organization achieves its safety objectives, continuously monitors its performance against these objectives and fosters a healthy safety culture.
This LC requires that the licensee implement and maintain a management system that brings together in a planned systematic and integrated manner the processes for managing the nuclear facility, the actions necessary to satisfy the requirements set out in the NSCA, regulations made pursuant to the NSCA, the licence and the measures necessary to ensure that safety is of paramount consideration in the implementation of the management system.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CSA Group
Management system requirements for nuclear facilities N286-12
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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MANAGEMENT SYSTEM
Licence Condition 1.2
The licensee shall ensure that every contractor working at the facility complies with this licence.
Preamble This LC requires that the licensee retain responsibility for the protection of the health, safety, and security of the public and workers, and the protection of environment when contractors perform licensed activities.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
The management of contractors shall be evaluated against the following principles:
1.2.1 The risks to contractors and risks to the organization from the use of contractors are evaluated to identify, assess, and eliminate or control hazards.
1.2.2 The duties and authorities of contractor personnel are clearly defined and documented.
1.2.3 When the licensee requires contractors to implement parts of the management system, the licensee is directly responsible for ensuring expectations are established, understood and achieved.
1.2.4 Contractors are adequately trained on relevant licensee procedures and are qualified and competent.
1.2.5 Qualified and competent members of the licensee’s staff maintain oversight of the contractors’ performance. The oversight program is planned, defined and the results documented.
1.2.6 Contractor personnel are held to the same performance standards as licensee employees.
Guidance There is no guidance provided for this licence condition.
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HUMAN PERFORMANCE MANAGEMENT
2. HUMAN PERFORMANCE MANAGEMENT Licence Condition 2.1
The licensee shall implement and maintain a training program.
Preamble The “human performance management” safety and control area covers activities that enable effective human performance through the development and implementation of processes to ensure that licensee staff members are sufficient in numbers in all relevant job areas and have the necessary knowledge, skills, and tools in place to safely carry out their duties.
This LC requires that the licensee implement and maintain a program to provide training to ensure that employees and contractors are trained and assessed to confirm that they have acquired and maintain the knowledge, skills and competencies to safely perform their work assignments.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Human Performance Management, Personnel Training, Version 2, December 2016 REGDOC-2.2.2*
* AREVA has committed to the implementation of the REGDOC-2.2.2 by December 31, 2017.
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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OPERATING PERFORMANCE
3. OPERATING PERFORMANCE Licence Condition 3.1 The licensee shall implement and maintain an operating program, which includes a set of operating limits.
Preamble The “operating performance” safety and control area includes an overall review of the conduct of the licensed activities and the activities that enable effective performance.
This LC requires that the licensee implement and maintain an operating performance program for the conduct of the licensed activities including the siting, construction and operation of the nuclear facility. Construction includes the commissioning of the constructed structures, systems and components. Operation includes the care and maintenance of facilities that are temporarily shut down. Operation also includes the remediation of areas of the facility where no further activities are expected to occur.
Effluent discharged from the JEB and Sue WTPs must comply with the limits for final treated effluent quality as stipulated in LC 9.2.
The design, construction, operation and maintenance of ventilation systems will be assessed against CNSC regulatory guide G-221, A Guide to Ventilation Requirements for Uranium Mines and Mills, June 2003.
Mining of the northern pods of the McClean Lake ore deposits is being carried out under the Surface Access Borehole Resource Extraction (SABRE) Project in accordance with the process identified in Supporting Information: Application for Amendment to Continue MED Program. Prior to 2013, this project was referred to as the Mine Equipment Development (MED) Program. The licensee is required to notify the Commission before mobilizing equipment to commence the mining of each new pod and before commencing the practice of eliminating the use of a casing to isolate the drill hole from the ore zone.
The conduct of licensed activities must comply with operating limits identified in section 5 of the Mining Facility Licensing Manual and with the requirements of the Code of Practice-Environmental Protection, the Radiation Protection Code of Practice and the Tailings Optimization and Validation Plan.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC A Guide to Ventilation Requirements for Uranium Mines and Mills G-221
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
AREVA Environmental Monitoring Program Locations, Frequencies and Parameters, Version 9 5115434 Acceptance
AREVA Code of Practice – Environmental Protection, Version 1, Revision 7 5107660 Acceptance
AREVA Routine Radiological Monitoring Schedule, Version 10 5004035 Acceptance
AREVA Radiation Code of Practice, Version 1, Revision 5 5004035 Acceptance
AREVA Radiation Performance Confirmation Plan for Processing High Grade Ore Slurry at the JEB Mill, Version 1
5094163 Acceptance
AREVA Dosimetry Monitoring Strategy, Version 11 5004035 Acceptance
AREVA Technical Information Document Tailings Management, Version 2 4775706 Acceptance
AREVA SABRE Project, Version 2 5158270 Acceptance
Construction, commissioning and operating performance will be evaluated against the following principles:
3.1.1 The process for constructing structures, systems and components follows accepted construction and project management practices.
3.1.2 Construction activities are carried out in accordance with drawings and specifications and related work instructions.
3.1.3 Installation procedures and work instructions are documented, reviewed and approved.
3.1.4 Equipment and systems are commissioned in accordance with documentation prepared prior to commissioning.
3.1.5 Commissioning documentation is reviewed for conformity to the design.
3.1.6 Commissioning reports identify the acceptability of the commissioning results.
3.1.7 The turnover of structures, systems, components and documents to operations is controlled.
3.1.8 The mine, mill and associated facilities are operated, monitored and maintained in accordance with documentation that is consistent with the design and licensing basis.
3.1.9 Operational activities are controlled through the use of and adherence to operational documents.
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OPERATING PERFORMANCE
The planning, control and verification of work will be evaluated against the following principles:
3.1.10 Work activities are planned to ensure that they can be carried out safely and effectively. Hazards are assessed and controls are identified.
3.1.11 Job hazard assessments are completed prior to conducting non-routine or complex work activities to identify and mitigate potential hazards to worker health and safety, and to the environment to an acceptable level or as low as reasonably achievable (ALARA).
3.1.12 Measures are established and documented to assure that non-routine work is carried out under controlled conditions.
3.1.13 Work activities are identified, defined in approved plans, procedures, instructions, and/or drawings to provide an appropriate level of reference.
3.1.14 Work is assigned to qualified personnel.
3.1.15 Work is carried out according to specified requirements. Controls are implemented to assure that work is carried out under controlled conditions. Preventative and protective measures are implemented to address identified hazards and risks.
3.1.16 The implementation of routine and non-routine work activities is monitored.
3.1.17 Management verifies that work is carried out according to specified requirements.
3.1.18 The management of problems will be evaluated against the following:
• a process exists to formally identify problems
• problems are identified and immediately controlled, if required
• the significance of problems is evaluated and the underlying causes determined
• identified problems are accepted, mitigated or resolved
• implementation of actions employed to resolve problems are reviewed for effectiveness
Guidance There is no guidance provided for this licence condition.
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OPERATING PERFORMANCE
Licence Condition 3.2
The licensee shall implement and maintain a program for reporting to the Commission or a person authorized by the Commission.
Preamble This LC requires the licensee to implement and maintain a process for reporting information to the CNSC. This includes monitoring results, performance assessments and the occurrence and response to unusual events. The McClean Lake Operation is subject to requirements of other federal and provincial regulatory agencies. The licensee shall report any material violation of applicable law at the federal, provincial or municipal level that pertain to the activities authorized by this licence. A “material violation” is a violation that impacts the ability of a licensee to carry out its licensed activities in a way that takes into consideration the protection of the environment, health and safety of persons, maintenance of national security and measures required to implement international obligations to which Canada has agreed. When material violations occur, the licensee is expected to report the violation by providing the CNSC with copies of the report(s) or notification(s) prepared for other governing regulatory bodies.
The licensee shall report upon becoming aware of the following events:
• a discharge limit, specified in section 9.2 of the LCH has been reached or exceeded
• an AL specified in the Code of Practice – Environmental Protection has been reached
• a release of hazardous substance into the environment that was not authorized by the licence
• an AL specified in the Radiation Protection Code of Practice has been reached
Preliminary reports of failures or events should be made via telephone, fax or e-mail to the CNSC within 24 hours of becoming aware of the event. Preliminary reports must describe the location and circumstances of the situation, and any action that the licensee has taken or proposes to take with respect to it. A supplementary report must be submitted within 21 days of the event.
The licensee shall submit to the CNSC on a quarterly basis, within 90 days after the end of each quarter of a calendar year, the results of:
• the radiation monitoring program including quality assurance and quality control information; more frequent reporting may be requested on a case-by-case basis
• the environmental monitoring program including quality assurance and quality control information; more frequent reporting may be requested on a case-by-case basis
The licensee shall issue worker radiation dose records, within 90 days after the end of each quarter of a calendar year, to:
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OPERATING PERFORMANCE
The licensee shall submit to the CNSC an annual compliance report by March 31 of each year, covering the operation for the 12-month period from January 1 to December 31 of the previous year.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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OPERATING PERFORMANCE
Licence Condition 3.3
The licensee shall implement and maintain a program for nuclear substances and radiation devices.
Preamble AREVA must receive CNSC consent before acquiring amounts of nuclear substances and the types of radiation devices not included on the following table.
The authorized make and model of radiation devices and the maximum quantity of nuclear substance per each device are:
Radiation Device Make and Model Nuclear Substance Maximum Quantity per Radiation Device
Ronan Engineering SA-1 Cesium-137 370,000 MBq
Texas Nuclear 5201 Cesium-137 7,400 MBq
Thermo Fisher Scientific Material Analyzer AM282 Cadmium-109 740 MBq
Niton Thermo Electron 700XLP Cadmium-109 1,480 MBq
The possession limits for unsealed nuclear substances does not apply to natural uranium and its decay products that are contained in the processing and sampling streams.
There is no possession limit on the number of sealed nuclear sources or radiation devices.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Licence Application Guide Nuclear Substances and Devices 1.6.1
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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OPERATING PERFORMANCE
• acquisition of nuclear substances and radiation devices including the quantity received, the form of the substance, and the name of the vendor
• inventory of all nuclear substances and radiation devices at the facility
• disposition of all nuclear substances and radiation devices acquired for use or processed by the facility, including the name and address of the recipient, a copy of the recipient’s licence (if applicable), the quantity of the nuclear substance, and the date of shipment
3.3.2 Each room, area or enclosure where more than one exemption quantity of an unsealed nuclear substance is used at a single time is classified as a basic level laboratory. The quantity of an unsealed nuclear substance used at a single time shall not exceed 5 annual limit of intake (ALI).
3.3.3 A radioisotope safety poster approved by the Commission or a person authorized by the Commission, which corresponds to the classification of the area, room or enclosure is posted, in a readily visible location in areas, rooms or enclosures where nuclear substances are handled.
3.3.4 Non-fixed contamination in all basic level laboratories and associated storage areas does not exceed:
• 3 becquerels per square centimetre for all Class A radionuclides
• 30 becquerels per square centimetre for all Class B radionuclides
• 300 becquerels per square centimetre for all Class C radionuclides averaged over an area not exceeding 100 square centimetres
3.3.5 When in storage, radioactive nuclear substances or radiation devices are accessible only to persons authorized by the licensee; the dose rate at any occupied location outside the storage area, room or enclosure resulting from the substances or devices in storage does not exceed 2.5 micro Sieverts per hour and measures are in place to ensure that the dose limits in the Radiation Protection Regulations are not exceeded as a result of the substances or devices in storage.
3.3.6 The following conditions are met prior to removing basic level laboratories from use:
a) non-fixed contamination does not exceed:
i) 0.3 becquerels per square centimetre for all Class A radionuclides
ii) 3 becquerels per square centimetre for all Class B radionuclides
iii) 30 becquerels per square centimetre for all Class C radionuclides
averaged over an area not exceeding 100 square centimetres
b) the release of any area, room or enclosure containing fixed contamination, is approved in writing by the Commission or a person authorized by the Commission
c) all nuclear substances and radiation devices have been transferred
d) all radiation warning signs have been removed or defaced
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OPERATING PERFORMANCE
3.3.7 The dose rate from nuclear substances and devices in areas normally occupied by persons other than nuclear energy workers, does not exceed 2.5 micro Sieverts per hour.
3.3.8 A durable and legible sign that indicates the name or job title and the telephone number of a person who can initiate the accident procedure that pertains to the radiation device and who can be contacted in case of an emergency 24 hours a day is posted, in a readily visible location at the place where any radiation device is used.
3.3.9 Radiation devices are installed, mounted and dismounted in accordance with written procedures.
Guidance There is no guidance provided for this licence condition.
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SAFETY ANALYSIS
4. SAFETY ANALYSIS Licence Condition 4.1
The licensee shall implement and maintain a safety analysis program.
Preamble The “safety analysis” safety and control area includes the systematic evaluation of the potential hazards associated with the proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards.
This LC requires that the licensee implement and maintain a process to identify and assess hazards and risks on an ongoing basis. This would include identifying and evaluating new or unforeseen risks that were not considered at the planning and design stages and updating previous risk assessments by replacing important assumptions with performance data. The results of this process will be used to set objectives and targets and to develop preventative and protective measures.
Compliance Verification Criteria Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
AREVA McClean Lake Operation, Technical Information Document, Hydrogeology and Groundwater Modeling of the Collins Creek Basin, Version 2, December 2011
3870068 Acceptance
AREVA McClean Lake Operation, Technical Information Document, Environmental Performance, Version 2, Revision 00, January 2012
3884389 3884390 3884391 3884404 3884405
Acceptance
AREVA
McClean Lake Operation, Technical Information Document, Environmental Performance, Volume 2 of 2 – Environmental Risk Assessment, Version 3, September 2016
5094511 Acceptance
AREVA McClean Lake Operation, Technical Information Document, Waste Rock Management, Version 2, Revision 00, June 2013
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SAFETY ANALYSIS
The safety analysis program will be evaluated against the following principles:
4.1.1 A process has been implemented and maintained to identify, assess, and eliminate or control health and safety and environmental risks associated with existing and new processes or changes to work procedures, equipment, organizational structure, staffing, products, services and suppliers.
4.1.2 Risks to health, safety and the environment have been identified, assessed, eliminated or controlled for existing and new processes or for changes to work procedures, equipment, organizational structure, staffing, products, services and suppliers.
4.1.3 Appropriate methodologies are used to identify potential hazards and consider the effectiveness of preventative measures and strategies in reducing the effects of such hazards.
4.1.4 Modeling is regularly updated using measured values to replace important assumptions and to increase the certainty of predicted long-term behaviour of contaminants.
Job hazard assessments conducted when planning non-routine and complex work activities is discussed under operating performance.
Guidance There is no guidance provided for this licence condition.
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PHYSICAL DESIGN
5. PHYSICAL DESIGN Licence Condition 5.1
The licensee shall implement and maintain a design program.
Preamble The “physical design” safety and control area includes activities that impact on the ability of systems, structures and components to meet and maintain their design basis given new information arising over time, and taking changes in the external environment into account.
The design basis is the range of conditions and events taken into account in the design of structures, systems and components of a facility according to established criteria, such that the facility can withstand them without exceeding authorized limits for the planned operation of safety systems.
This LC requires that the licensee implement and maintain a design control process to ensure that design outputs (both interim and final) are reviewed, verified and validated against the design inputs and performance requirements, and to ensure that the design inputs are selected such that safety, performance and dependability of the design item are achieved.
The licensee is encouraged to make continuous improvements to the design of facilities and equipment, as long as the changes remain within the intent of the licensing basis authorized by the Commission.
The design of mining facilities must adapt to conditions encountered as development of the mine advances. An adaptive design process must be implemented and maintained to ensure that the design meets design criteria. The mine design process must include consideration of geology, hydrogeology, rock mechanics, ventilation, hydrology and water management, waste management including waste rock classification, handling and disposal, risk assessment and the identification and implementation of mitigation measures. Climate change should be considered in the mine design.
Compliance Verification Criteria Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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PHYSICAL DESIGN
5.1.3 A design authority responsible for the design control process is designated.
5.1.4 The design control process includes design planning, inputs, output, review, verification, validation, transfer, records and change management.
5.1.5 Design inputs are established and include such items as:
• functional requirements
• performance and operational requirements
• environmental, health and safety and human factors
• applicable codes and standards
5.1.6 The design is reviewed by considering design inputs, requirements, experience with similar designs, and the results of research and testing.
5.1.7 Design documents are maintained so the design can be related to the design requirements and used by organizations responsible for construction, commissioning, operation and decommissioning. The following are included in the design documents:
• design requirements
• inputs, assumptions, methods, modeling, test and development work, and results
• purchasing, installation and construction requirements
• design drawings
• characteristics of the design that need to be confirmed during commissioning
• system or equipment operating and maintenance requirements
5.1.8 The facility design and status documents are accurate and accessible to facility personnel.
5.1.9 Operational specifications and restrictions imposed by the design, including risk analyses, are appropriately communicated to the operators and incorporated into operating programs, procedures, practices and training.
5.1.10 Procedures have been implemented to ensure that design output information (document and/or data) appropriately and accurately reflect the approved design.
5.1.11 The facility’s as-built physical configuration reflects the approved design.
Guidance There is no guidance provided for this licence condition.
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FITNESS FOR SERVICE
6. FITNESS FOR SERVICE Licence Condition 6.1
The licensee shall implement and maintain a fitness for service program.
Preamble The “fitness for service” safety and control area covers activities that are carried out to ensure that the physical condition of systems, components and structures remain effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so.
This LC requires that the licensee implement and maintain a fitness for service program to ensure that the operating condition of systems, equipment and devices is preserved so that they can perform their function reliably. Accuracy is maintained by planning and carrying out periodic adjustments, calibrations, repairs and replacement.
It is expected that the licensee will conduct routine maintenance, inspection and testing to ensure that the availability, reliability and effectiveness of facilities and equipment that may impact health, safety and protection of the environment.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
The fitness for service program will be assessed against the following principles:
6.1.1 Systems, equipment and devices are maintained in good working order such that they can perform their design function.
6.1.2 Instruments, controls and associated indicators are maintained operational and in calibration. Method and interval of calibrations are defined, and records of calibrations are kept.
6.1.3 Preventative and corrective maintenance processes and systems have been implemented and are maintained.
6.1.4 Regular inspection and testing of critical infrastructure and equipment are carried out.
6.1.5 A process has been implemented to identify, plan and schedule maintenance activities.
6.1.6 Maintenance, testing, surveillance and inspection backlogs are monitored and minimized.
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FITNESS FOR SERVICE
6.1.7 Methods are used to show the current acceptance and operating status, and to prevent the use of systems, equipment or devices that are inaccurate or not in working order.
6.1.8 When deviations beyond accuracy limits are found or suspected, its consequence on past results, and on present performance is evaluated.
6.1.9 A process exists to verify that changes to calibration, testing and maintenance requirements due to system and equipment modifications and replacements are implemented.
Guidance There is no guidance provided for this licence condition.
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RADIATION PROTECTION
7. RADIATION PROTECTION Licence Condition 7.1
The licensee shall implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 24 hours.
Preamble The “radiation protection” safety and control area covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination and radiation doses received are monitored and controlled.
The Radiation Protection Regulations require that the licensee implement a radiation protection program and also ascertain and record doses for each person who performs any duties in connection with any activity that is authorized by the NSCA or is present at a place where that activity is carried out. This program must ensure that doses to workers do not exceed prescribed dose limits and are kept ALARA, social and economic factors being taken into account. The regulatory dose limits are explicitly provided in the Radiation Protection Regulations.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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RADIATION PROTECTION
The radiation protection (RP) program will be assessed against the following principles:
7.1.1 The organization and administration of RP provides effective implementation and control of RP activities. The roles, responsibilities and qualification requirements of all persons involved in the RP program are clearly defined. All levels of management and workers are committed to RP requirements and practices within their level of responsibility. A performance review process is established to evaluate the RP program.
7.1.2 Workers, supervisors and contractors have the qualifications (knowledge, skills, experience) needed to effectively perform RP practices associated with their work. A requalification program is implemented to maintain this qualification.
7.1.3 RP personnel and RP supervisors have the qualifications (knowledge, skills, experience) needed to effectively implement and conduct the RP program.
7.1.4 Radiological conditions are monitored and sources of external and internal radiation exposures are controlled. Access and work in radiological areas are controlled so that collective and individual radiation exposures are kept ALARA.
7.1.5 RP instrumentation and equipment are calibrated, maintained and used so that radiation levels are accurately determined.
7.1.6 The personnel dosimetry program ensures that external and internal radiation doses to individuals are accurately determined and recorded.
7.1.7 Appropriate contamination control measures are implemented to control and minimize the contamination of areas, equipment and personnel.
Action levels (ALs) are designed to alert licensees before regulatory dose limits are reached. By definition, if an AL referred to in a licence is unexpectedly reached, a loss of control of some part of the associated RP program may have occurred, and specific action is required, as defined in the Radiation Protection Regulations, the licence and the applicable code of practice. The licensee has identified the effective doses to individuals of 1 millisievert in one week and 5 millisieverts in a quarter as ALs. The weekly AL is assessed against engineering monitoring data. The quarterly AL is assessed against official dosimetry results. The licensee is expected to review and, if necessary, revise the ALs specified above at least once every five years in order to validate its effectiveness. The results of such reviews should be provided to the CNSC.
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CONVENTIONAL HEALTH AND SAFETY
8. CONVENTIONAL HEALTH AND SAFETY Licence Condition 8.1
The licensee shall implement and maintain a conventional health and safety program.
Preamble The “conventional health and safety” safety and control area covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment.
This LC requires that the licensee implement and maintain a program to manage workplace safety hazards and to protect personnel and equipment.
The regulation of non-radiological health and safety at uranium mines and mills is governed by the Canada Labour Code Part II, which is administered by Human Resources and Skills Development Canada (HRSDC). However, the Saskatchewan Uranium Mines and Mills Exclusion Regulations (SOR/2001-115) defer the regulation of occupational health and safety in Saskatchewan uranium mines and mills to the province of Saskatchewan in accordance with the requirements of The Occupational Health and Safety Act, 1993 (Chapter O-1.1 of the Statutes of Saskatchewan, 1993) and regulations (including The Mines Regulations, 2003 Chapter 0-1.1 Reg 2).
The CNSC also has regulatory responsibilities for the oversight of the protection of the health and safety of workers. The CNSC harmonizes the oversight of conventional health and safety with the Saskatchewan Ministry of Labour Relations and Workplace Safety.
The CNSC expects uranium mines and mills to develop, implement and maintain an occupational health and safety program to promote a safe and healthy workplace for employees and minimize the incidence of occupational injuries and illnesses.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CSA Group Selection, Use and Care of Respirators Z94.4-11
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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CONVENTIONAL HEALTH AND SAFETY
The conventional health and safety program will be assessed against the following principles:
8.1.1 The necessary people, materials, equipment, programs and procedures to effectively manage, control and minimize health and safety risks have been provided.
8.1.2 Housekeeping standards have been identified and are enforced to ensure that work areas are kept clean and organized.
8.1.3 Facilities, processes and procedures have been implemented to ensure the safe management of hazardous materials.
8.1.4 Employees and contractors actively participate in the management of conventional health and safety.
8.1.5 Management verifies that employees and contractors actively participate in the management of health and safety in their workplace.
8.1.6 Procedures have been established and are maintained to communicate information about conventional health and safety.
8.1.7 A process has been established and maintained to monitor, measure and record conventional health and safety performance and the effectiveness of the occupational health and safety program on a regular basis.
8.1.8 Routine inspections are performed by workers, supervisors, senior staff and/or safety professionals to identify any potential safety issues.
8.1.9 Processes and procedures are established and maintained to investigate accidents and incidents, to identify root causes, to implement corrective actions and to verify that corrective actions have been completed and will effectively prevent recurrence.
8.1.10 Procedures have been implemented and maintained for reporting work-related injuries, illnesses, fatalities and conventional health and safety incidents including near misses.
8.1.11 The causes of injuries are investigated, corrective actions implemented, and the effectiveness of corrective actions verified.
8.1.12 A preventative and corrective action procedure has been established and maintained to address non-conformances and inadequately controlled risks.
Guidance There is no guidance provided for this licence condition.
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ENVIRONMENTAL PROTECTION
9. ENVIRONMENTAL PROTECTION Licence Condition 9.1
The licensee shall implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 24 hours.
Preamble The “environmental protection” safety and control area covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities.
This LC requires that the licensee implement and maintain a program to ensure that environmental protection is managed via an integrated set of documented activities that are designed such that environmental issues are identified, monitored, interpreted and acted upon in a manner that demonstrates “adequate precaution” to protect the environment.
The environmental protection program must include an environmental monitoring program that monitors all releases of nuclear and hazardous substances to the environment and characterizes and monitors the quality of the environment associated with a licensed facility. The overall objective of the environmental monitoring program (EMP) is to measure the effects of a proposed licensed activity on the receiving environment with respect to the concentrations and quantities of nuclear and hazardous substances in the environment (abiotic and biotic) and/or measurable changes in biological processes. A site-specific ERA shall be used to design the monitoring program such that the EMP can be used to determine whether measurable effects are acceptable.
At the planning stage of a uranium mining/milling facility or a major change in a facility, an environmental assessment (EA) is carried out to determine whether the project is likely to result in a significant adverse effect or poses an unreasonable risk to the environment, taking into consideration the proposed mitigation measures. The EA includes the characterization of the baseline environmental conditions, and assessment of alternative ways of carrying out the project. Credible accident scenarios and an ERA that predicts and risk ranks the potential effects of a project on ecological and human health due to both radiological and hazardous substances.
The ERA also serves as an adaptive management tool to assess the results of the facility’s monitoring program to determine whether the impact on the environment and human health is within the bounds of those predicted as a basis for licensing and to assess whether additional mitigation measures are necessary. Additional mitigation measures may be necessary to ensure adequate provision and all reasonable precautions are taken to protect the environment and human health and safety and that the facility does not pose an unreasonable risk to the environment, workers and the public. The ERA should be updated with the monitoring results, and be reviewed periodically to identify and assess any risks that might have emerged or changed, and to verify its applicability.
The EAs listed under LC G.1 have been carried out to predict the effects of the McClean Lake Operation.
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ENVIRONMENTAL PROTECTION
Following the EA, recognized hazard analysis and risk assessment techniques are carried out during the design of systems, components and equipment to identify hazards and risks, and to identify the necessary engineering and administrative mitigation and control measures. Safety analyses are prepared for mine-mill development and waste management facilities. CNSC staff verify that the licensee assesses operating performance against these hazard analyses, risk assessments and safety analyses to ensure that the facility’s operation remains within the intent of the licensing basis.
Prior to implementing any significant changes or modifications, the licensee must provide the CNSC with an assessment of the proposed changes or modifications, identification and assessment of potential risks and impacts and proposed mitigation measures.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Environmental Protection: Environmental Principles, Assessments and Protection Measures REGDOC-2.9.1*
CSA Group
Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills N288.4*
CSA Group
Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills N288.5*
CSA Group
Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills N288.6-12
CSA Group
Groundwater Protection Programs at Class I Nuclear Facilities and Uranium Mines and Mills N288.7*
* AREVA has committed to the implementation of the standard by December 31, 2017.
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
AREVA Environmental Monitoring Program Locations, Frequencies and Parameters, Version 9 5115434 Acceptance
AREVA Code of Practice – Environmental Protection, Version 1, Revision 7 5107660 Acceptance
The environmental protection program will be assessed against:
9.1.1 Modeling is regularly updated using measured values to replace important assumptions and to increase the certainty of predicted long-term behavior of contaminants.
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ENVIRONMENTAL PROTECTION
Licence Condition 9.2
The licensee shall where the effluent concentration reaches or exceeds the discharge limits specified in the Metal Mining Effluent Regulations, immediately investigate and take corrective action to ensure that effluent concentration is maintained below the discharge limits.
Preamble This LC requires the licensee to investigate and take corrective action if measured parameters in the final treated effluent exceed the authorized effluent discharge limits.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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ENVIRONMENTAL PROTECTION
Notes:
1) Definition of Units: mg/L = milligrams per litre Bq/L = Becquerels per litre
2) All concentrations and activities are total values. 3) The above limits shall apply to all effluent discharged to Sink Reservoir from:
i) the monitoring ponds at the JEB water treatment plant ii) the sand filter discharge tank at the Sue water treatment plant
4) “Monthly mean concentration” means the average value of the concentrations measured in all composite or grab samples collected from the final discharge point during each month when liquid effluent is released.
5) “Composite sample” means: i) a quantity of effluent consisting of not less than three equal volumes or
three volumes proportionate to flow that have been collected at approximately equal time intervals over a period of not less than seven hours and not more than 24 hours; or
ii) a quantity of effluent collected continuously at a constant rate or at a rate proportionate to the rate of flow of the effluent over a sampling period of not less than seven hours and not more than 24 hours
6) “Grab sample” means a quantity of undiluted effluent collected at any given time. 7) “Acutely lethal effluent” means an effluent at 100 percent concentration that kills
more than 50 percent of the rainbow trout subjected to it over a 96-hour period when tested in accordance with the acute lethality test.
Guidance
Guidance Publications There is no guidance provided for this licence condition.
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EMERGENCY MANAGEMENT AND FIRE PROTECTION
10. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Condition 10.1
The licensee shall implement and maintain an emergency preparedness program.
Preamble The “emergency management and fire protection” safety and control area covers emergency plans and emergency preparedness programs which exist for emergencies and for non-routine conditions. It also includes any results of exercise participation.
This LC requires that the licensee implement and maintain an emergency preparedness program to prepare for and respond to emergency events, initiating at or impacting the licensed site, and for dealing with both the onsite and offsite effects of such emergencies. The program must demonstrate that the emergency preparedness activities are planned, coordinated, controlled and integrated to achieve the safety objectives.
The licensee is required to have documented emergency preparedness plans and emergency response procedures that take into account accident scenarios that could have adverse impacts on the environment and the health and safety of onsite staff and the public. Adequate resources, equipment, training and testing are required to ensure that individuals and organizational units are prepared and have the resources to effectively respond to and deal with emergencies. The program must demonstrate that the emergency management and fire protection activities are planned, coordinated, controlled and integrated to achieve the safety objectives.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Nuclear Emergency Preparedness and Response REGDOC-2.10.1 Version 2*
* AREVA has committed to the implementation of the UMM applicable sections of the standard by December 31, 2017.
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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EMERGENCY MANAGEMENT AND FIRE PROTECTION
Licence Condition 10.2
The licensee shall implement and maintain a fire protection program.
Preamble Licensees shall implement and maintain a fire protection program (a set of planned, coordinated, controlled and documented activities) to ensure that the licensed activities do not result in an unreasonable risk to the health and safety of persons and to the environment due to fire and to ensure that the licensee is able to efficiently and effectively respond to emergency fire situations.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
The fire protection program will be assessed against the following principles:
10.2.1 Use of third-party review for any proposed modification of the facility that potentially impacts protection from fire.
10.2.2 Biennial third-party review to ensure compliance with the inspection requirements of the National Building Code of Canada 2015 and the National Fire of Canada 2015.
Guidance
Guidance Publications Source Document Title Document Number
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WASTE MANAGEMENT
11. WASTE MANAGEMENT Licence Condition 11.1
The licensee shall implement and maintain a waste management program.
Preamble The “waste management” safety and control area covers internal waste-related programs which form part of the facility’s operations up to the point where the waste is removed from the facility. It also covers the planning for decommissioning.
This LC requires that the licensee implement a program to collect, treat, process, store, transport or dispose of the wastes that are produced by the licensed activities at the McClean Lake Operation.
Waste management facilities at the McClean Lake Operation include:
• the tailings preparation circuit
• JEB TMF
• Sue in-pit storage areas for mineralized and potentially acid-generating waste rock
• JEB and Sue clean waste rock and overburden piles
• JEB site run-off containment ponds
• drill core storage areas
• contaminated industrial waste storage
• storage and recycling facilities for hazardous wastes
• landfill for uncontaminated industrial and domestic waste
• domestic sewage treatment
• domestic waste incineration Ongoing assessment and optimization of tailings performance is carried out every five years in accordance with AREVA’s McClean Lake Operation, Technical Information Document, Tailings Management.
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
AREVA Facility Description Manual, Version 5, Revision 1 5107638 Acceptance
AREVA Technical Information Document, Tailings Management, May 2015 4775706 Acceptance
The waste management program will be assessed against the following principles:
11.1.1 A radioactive waste management program is implemented to control and minimize the volume of radioactive waste.
11.1.2 The volume of waste is minimized by applying the “reduce, reuse, recycle and recover” principle.
11.1.3 Work, including selecting and purchasing environmentally preferable material and equipment, is carried out in a manner that minimizes waste and prevents pollution.
11.1.4 Waste is stored or disposed of in the appropriate manner.
11.1.5 Wastes are managed in a manner that does not compromise reclamation or decommissioning plans.
11.1.6 Management verifies that employees and contractors comply with waste management practices.
11.1.7 The effectiveness of waste management practices is monitored, measured and recorded on a regular basis.
11.1.8 Routine inspections are performed to identify any potential waste management issues and to verify the condition of containment structures and waste management facilities.
11.1.9 The safety of embankments/dams is inspected and reviewed.
11.1.10 Records are kept of the quantities and types of waste generated and the method of disposal or management.
11.1.11 Wastes are managed to control the present and future releases of contaminants to the environment.
11.1.12 Surface water is managed to prevent or minimize the volume that is contaminated.
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WASTE MANAGEMENT
Licence Condition 11.2
The licensee shall implement and maintain a decommissioning strategy.
Preamble This LC requires that the licensee maintain a preliminary decommissioning strategy, referred to as a preliminary decommissioning plan (PDP).
A PDP provides an overview of the proposed decommissioning approach that is sufficiently detailed to assure that the proposed approach is, in the light of existing knowledge, technically and financially feasible, and appropriate in the interests of health, safety, security and the protection of the environment. The PDP defines areas to be decommissioned and the general structure and sequence of the principle work packages. The PDP forms the basis for establishing and maintaining a financial arrangement (financial guarantee) that will assure adequate funding of the decommissioning plan.
The latest revision of the PDP and estimation of the cost of decommissioning were finalized in Preliminary Decommissioning Plan and Financial Assurance, October 2016. It is expected that the PDP will be revised as the conditions at the facility change. When the PDP is revised the cost of decommissioning must be reviewed. At a minimum the PDP and the value of the financial guarantee must be reassessed every five years.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CSA Group
Decommissioning of Facilities Containing Nuclear Substances N294-09
CNSC Decommissioning Planning for Licensed Activities G-219
CNSC Financial Guarantees for the Decommissioning of Licensed Activities G-206
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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SECURITY
12. SECURITY Licence Condition 12.1
The licensee shall implement and maintain a security program.
Preamble The “security” safety and control area covers the programs required to implement and support the security requirements stipulated in the regulations, in their licence, or in expectations for their facility or activity.
This LC requires that the licensee implement and maintain security measures to prevent the loss of nuclear substances and prevent acts of sabotage at the facility.
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
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SAFEGUARDS AND NON-PROLIFERATION
13. SAFEGUARDS AND NON-PROLIFERATION Licence Condition 13.1
The licensee shall implement and maintain a safeguards program.
Preamble The “safeguards and non-proliferation” safety and control area covers the programs required for the successful implementation of the obligations arising from the Canada/International Atomic Energy Agency (IAEA) Safeguards Agreement.
This LC requires that the licensee implement a safeguards and non-proliferation program to report on the transfer of nuclear material from the facility, provide the required information on its operations for Canada’s annual nuclear fuel cycle declaration to the IAEA and to ensure that IAEA inspectors are granted prompt access to the facility.
Compliance Verification Criteria
Licensing Basis Publications Source Document Title Document Number
CNSC Accounting and Reporting of Nuclear Material RD-336
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
The safeguards and non-proliferation program will be assessed against CNSC regulatory document RD-336, Accounting and Reporting of Nuclear Material and the following principles:
13.1.1 Reasonable services and assistance are provided to the IAEA to enable the IAEA to carry out its duties and functions.
13.1.2 Prompt access to all locations at the facility is granted to the IAEA at all reasonable times where such access is required for the purposes of carrying on an activity pursuant to a safeguards agreement. Health and safety services and escorts are provided as required in order to facilitate activities.
13.1.3 Records that must be kept or any reports that are required to be made under a safeguards agreement are disclosed to the CNSC and the IAEA.
13.1.4 Reasonable assistance is provided to the IAEA to enable sampling and removal or shipment of samples.
13.1.5 Reasonable assistance is provided to the IAEA to enable measurements, tests and removal, or shipment of equipment.
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SAFEGUARDS AND NON-PROLIFERATION
13.1.6 Measures are implemented to prevent damage to, or the theft, loss or sabotage of samples collected pursuant to a safeguards agreement or the illegal use, possession or removal of such samples.
13.1.7 Reports and information, that is required to facilitate Canada’s compliance with any applicable safeguards agreement, is provided to the Commission.
Guidance
There is no guidance provided for this licence condition.
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PACKAGING AND TRANSPORT
14. PACKAGING AND TRANSPORT Licence Condition 14.1
The licensee shall implement and maintain a packaging and transport program.
Preamble The “packaging and transport” safety and control area covers the safe packaging and transport of nuclear substances and radiation devices to and from the licensed facility.
Transport of nuclear substances is subject to the Transport of Dangerous Goods Regulations and the Packaging and the Transport of Nuclear Substances Regulations.
The McClean Lake Operation receives uranium ore, and packages and ships uranium concentrate (yellowcake). In addition, small amounts of nuclear substances and radiation devices, radioactive samples and contaminated equipment are received, packaged and shipped.
This LC requires the licensee to implement and maintain a transport and packaging program for nuclear substances which include the necessary procedures, materials and equipment to:
• safely receive and unload packages
• use, inspect and maintain packaging and packages
• prepare, consign, handle and load packages
Compliance Verification Criteria
Licensee Documents that Require Notification of Change
Source Document Title Document Number Notification Requirements
AREVA McClean Lake Operation Integrated Quality Management System Manual, Version 8, Revision 1 5103205 Acceptance
The adequacy of the packaging and transport program will be assessed against the following principles:
14.1.1 All radioactive materials are transported in accordance with applicable regulations and procedures.
14.1.2 Procedures describe requirements for the choice of appropriate packages, preparation of transport documentation, packaging, storage and shipment of nuclear substances.
Guidance There is no guidance provided for this licence condition.
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APPENDIX A
APPENDIX A CHANGE CONTROL PROCESS A.1 Change Control Process
A change control process is applied to the LCH to ensure that:
• preparation and use of the LCH are properly controlled
• all referenced documents are correctly identified and maintained
• changes are conducted in accordance with CNSC regulatory policy P-299, Regulatory Fundamentals
• procedures for modifying the LCH are followed
A request to change this LCH can be initiated by either CNSC staff or the licensee. The licensee will be consulted on any changes to the LCH that are proposed by CNSC staff.
CNSC staff will take the following steps to update the LCH:
1. the CNSC receives or initiates written notification of proposed change
2. initiate a change request using the Change Request Form
3. complete a technical review of the proposed change, if required
4. consult the licensee and in case of disagreement on the proposed change, the dispute resolution process outlined in section A.3 will apply
5. obtain consent and signature from a Delegated Officer
6. update the LCH in accordance with the Change Request Form and send the updated document to the parties identified on the distribution list (see section A.5)
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APPENDIX A
A.2 Review Criteria for Proposed Changes to Licensing Basis Documents
The licensee must provide the CNSC with written notification of a proposed significant change to key licensee documents before the licensee implements the change. The notification must be accompanied by sufficient information to demonstrate that the change is within the intent of the licensing basis. Written notification of minor or administrative changes may be made in batches after the changes have been implemented.
The following criteria will be used by CNSC staff to determine if the proposed change is acceptable:
1. The submission includes the appropriate level and quality of information with regards to:
a) The description of the proposed change including:
• a summary of the change, including the purpose or need for the change
• a preliminary finding of whether this proposal or notification is required under the NSCA, a regulation made under the Act or the licence, or has implications under the CEAA, or whether a licence amendment or other licensing action would likely be required
• where applicable, the alternatives evaluated and the reasons for selection of the chosen option
• any changes to the inventories of nuclear substances onsite related to the proposed change
• the construction, commissioning and operating schedule for the proposed change including hold points or progress reports for regulatory review and approval (as appropriate)
• expected impacts, if any, on the proposed decommissioning or closure plans
• results of any risk analysis or HAZOPs studies performed, and a summary of the identified hazards and the mitigation measures identified to control potential hazards
b) The description of the design control, operating specifications and criteria including:
• the design basis and criteria, and performance specifications
• the design drawings such as the general arrangement, process and instrumentation diagrams, and process flow sheets
• the quality management program for the various key stages of the change (e.g., design, construction, commissioning, etc.)
c) The assessment of both the short and long term impacts with the mitigation measures in place on:
• worker’s health and safety, including potential radiological and non-radiological exposures
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APPENDIX A
• security
• Canada’s international obligations d) The planned administrative controls including:
• changes to the organization, roles and responsibilities
• changes to applicable programs and procedures
• a description of the proposed monitoring, inspection and test plans, including locations and frequency proposed to evaluate both positive and negative results
e) Changes to contingency plans including “full-stop measures”
f) Evidence that the licensee’s internal reviews and approvals have been completed, including meeting the requirements of the licensee’s change management procedure and consultation with the onsite occupational health and environmental committees, where applicable
g) Identification of the documents and training programs that may require revision when the proposed change is implemented
2. The effects of the proposed change or action remain within the licensing basis.
3. Following the implementation of the change the licensee will remain in compliance with the requirements set out in the applicable Acts, regulations, and LCs.
A.3 Dispute Resolution
In case of a dispute between the licensee and CNSC staff regarding changes to the LCH, both parties will meet to discuss the dispute and reach a decision on the path forward. The decision, including its rationale will be documented. If any party is not satisfied with the decision, the resolution process will proceed up to the Director, Director General or Executive Vice-President and Chief Regulatory Operations Officer level. If any party is still not satisfied with the decision, the issue will be brought to the attention of the Commission at a Commission meeting. The decision made by the Commission will be final.
A.4 Records Management
In order to track changes to the LCH, the document change request and accompanying documentation will be archived in records and referenced in the revision history of the LCH. Electronic communication related to the change, such as comments from reviewers will be stored in the CNSC information management system.
Canadian Nuclear Commission canadienne Safety Commission de sûreté nucléaire
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Directorate of Nuclear Cycle Our file Notre référence and Facilities Regulation 2.04 AREVA-ML
URANIUM MINE OPERATING LICENCE AREVA RESOURCES CANADA INC.
McCLEAN LAKE OPERATION
I) LICENCE NUMBER: UMOL-MINEMILL-McCLEAN.01/2017 II) LICENSEE: Pursuant to section 24 of the Nuclear Safety and Control Act,
this licence is issued to:
AREVA Resources Canada Inc. P.O. Box 9204 817 – 45th Street West Saskatoon, Saskatchewan S7K 3X5
III) LICENCE PERIOD: This licence is valid from July 1, 2009 to June 30, 2017, unless
otherwise suspended, amended, revoked, or replaced. IV) LICENSED ACTIVITIES:
This licence authorizes the licensee to:
a) operate and modify a nuclear facility (hereinafter, “the facility”) for the mining of uranium ore and the production of uranium concentrate at a site known as the McClean Lake Operation in the province of Saskatchewan, as shown on the drawing contained in Appendix A to this licence;
b) mine a nuclear substance (uranium ore);
c) produce a uranium concentrate;
d) import, possess, use, store, transfer, and dispose of nuclear substances and radiation devices that are required for or associated with laboratory studies, field studies, fixed gauge usage and borehole logging devices;
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V) EXPLANATORY NOTES:
a) nothing in this licence shall be construed to authorize non-compliance with any other applicable legal obligation or restriction;
b) unless otherwise provided for in this licence, words and expressions used in this licence have the same meaning as in the Nuclear Safety and Control Act and associated Regulations;
c) the UMOL-MINEMILL-McCLEAN.01/2017 Licence Conditions Handbook (LCH) identifies the criteria that will be used by Canadian Nuclear Safety Commission (CNSC) staff to assess the licensee’s compliance with the conditions listed in the licence. The LCH also provides information regarding delegation of authority and applicable version control of documents.
VI) CONDITIONS: 1. GENERAL 1.1 The licensee shall conduct the activities described in Part IV of this licence in accordance
with the licensing basis. 1.2 Changes to the facility, its operation, or safety and control measures described in the
application and the documents needed to support that application are permitted provided that the objective of the licensing basis is met.
1.3 The licensee shall give written notification to the Commission of any changes made to
the documents needed to support the licence application. 1.4 The licensee shall, in the event of any conflict or inconsistency between licence
conditions or any documents referenced in the LCH, direct the conflict or inconsistency to the Commission, or a person authorized by the Commission, for resolution.
1.5 The licensee shall implement and maintain a program for public information for the
facility, including a public disclosure protocol. 2. MANAGEMENT SYSTEM 2.1 The licensee shall implement and maintain a management system.
2.2 The licensee shall ensure that every contractor working at the facility complies with the
applicable conditions of this licence including those relating to the licensee’s policies, programs, and procedures with respect to the protection of health, safety, and the environment, and to the maintenance of security.
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3. HUMAN PERFORMANCE MANAGEMENT 3.1 The licensee shall implement and maintain a training program. 4. OPERATING PERFORMANCE 4.1 The licensee shall implement and maintain an operating program. 4.2 The licensee shall implement and maintain a process for reporting to the Commission or a
person authorized by the Commission that includes reporting of all events required by the Nuclear Safety and Control Act and its Regulations.
4.3 The nuclear substances and radiation devices possessed by the licensee shall not exceed:
a) the possession limit for unsealed sources; and
b) the maximum activity per sealed source or device; approved by the Commission or a person authorized by the Commission.
5. SAFETY ANALYSIS 5.1 The licensee shall implement and maintain a safety analysis program. 6. PHYSICAL DESIGN 6.1 The licensee shall implement and maintain a design program. 7. FITNESS FOR SERVICE 7.1 The licensee shall implement and maintain a maintenance program. 8. RADIATION PROTECTION 8.1 The licensee shall implement and maintain a radiation protection program. 9. CONVENTIONAL HEALTH AND SAFETY 9.1 The licensee shall implement and maintain an occupational health and safety program.
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10. ENVIRONMENTAL PROTECTION 10.1 The licensee shall implement and maintain an environmental protection program. 10.2 The licensee shall where the effluent concentration reaches or exceeds the discharge
limits specified in Appendix B to this licence, immediately investigate and take corrective action to ensure that the effluent concentration is maintained below the discharge limits.
11. EMERGENCY MANAGEMENT AND FIRE PROTECTION 11.1 The licensee shall implement and maintain an emergency management and fire protection
program. 12. WASTE MANAGEMENT 12.1 The licensee shall implement and maintain a waste management program. 12.2 The licensee shall maintain a preliminary decommissioning plan for the facility. 12.3 The licensee shall maintain a financial guarantee acceptable to the Commission which
shall remain valid and in effect and adequate to fund the Preliminary Decommissioning Plan referenced in licence condition 12.2 of this licence.
13. SECURITY 13.1 The licensee shall implement and maintain a security program. 14. SAFEGUARDS AND NON-PROLIFERATION 14.1 The licensee shall implement and maintain a safeguards program.
Licence 50f8 UMOL-MINEMILL-McCLEAN.Ol/2017
15. PACKAGEAND TRANSPORT
15.1 The licensee shall implement and maintain a packaging and transport program.
SIGNED at OTTAWA, this Jq~ day of}u-\,..... ,2012.
£;'~ Michael Binder, President on behalf of the Canadian Nuclear Safety Commission
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APPENDIX A
LOCATION OF THE MCCLEAN LAKE OPERATION
The location of the McClean Lake Operation is shown on McClean Lake Operation Drawing No. ML100-D-015 (e-DOC 3966418).
Location of the McClean Lake OperationUMOL-MINEMILL-McCLEAN.01/2017
0 2,000 4,000
Meters CZ 03 July, 2012
LegendMcClean Lake Site Boundary
Midwest Site Boundary
Midwest Project Facilities
Transportation and Waste Water Pipeline Corridor
Road
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Reference:NAD 83; UTM Zone 13; NTS 1:50,000 Topo
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APPENDIX B
AUTHORIZED EFFLUENT DISCHARGE LIMITS
Deleterious Substance Maximum Authorized
Monthly Mean Concentration
Maximum Authorized Concentration in a Composite Sample
Maximum Authorized Concentration in a Grab
Sample
Arsenic (mg/L) 0.50 0.75 1.00
Copper (mg/L) 0.30 0.45 0.60
Lead (mg/L) 0.20 0.30 0.40
Nickel (mg/L) 0.50 0.75 1.00
Zinc (mg/L) 0.50 0.75 1.00
Total Suspended Solids (mg/L)
15.00 22.50 30.00
Radium-226 (Bq/L) 0.37 0.74 1.11
Acid balance (as H3O+) reported as pH
In a range of 6.0 to 9.5
Acutely Lethal Effluent 0%
Notes:
1) Definition of Units: mg/L = milligrams per litre Bq/L = Becquerels per litre
2) All concentrations and activities are total values.
3) The above limits shall apply to all effluent discharged to Sink Reservoir from:
i) the monitoring ponds at the JEB Water Treatment Plant; and ii) the sand filter discharge tank at the Sue Water Treatment Plant.
4) “Monthly Mean Concentration” means the average value of the concentrations measured in all composite or grab samples collected from the final discharge point during each month when liquid effluent is released.
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Notes (cont’d): 5) “Composite Sample” means:
i) a quantity of effluent consisting of not less than three equal volumes or three volumes proportionate to flow that have been collected at approximately equal time intervals over a period of not less than seven hours and not more than 24 hours; or
ii) a quantity of effluent collected continuously at a constant rate or at a rate proportionate to the rate of flow of the effluent over a sampling period of not less than seven hours and not more than 24 hours.
6) “Grab Sample” means a quantity of undiluted effluent collected at any given time.
7) “Acutely Lethal Effluent” means an effluent at 100% concentration that kills more than 50% of the rainbow trout subjected to it over a 96-hour period when tested in accordance with the acute lethality test.
