Cameco response to Sierra Club submission opposing renewal of licences

September 27, 2013

Sierra Club Canada’s submission to the Canadian Nuclear Safety Commission opposing relicensing of Cameco’s uranium mining operations in northern Saskatchewan creates an entirely false impression of the environmental performance of these facilities. 

Protecting the health and safety of people and the environment is Cameco’s top priority. Our operations meet all provincial and federal regulations. Cameco employs more than 200 people in Saskatchewan who are exclusively focused on achieving continual improvement in our safety, health and environmental performance. 

Comprehensive environmental assessment of each of our operations and several decades of intensive monitoring clearly demonstrate that these operations have a minimal impact on the environment. Issues that are identified are addressed in a systematic and responsible way as detailed in our licensing submissions. 

Sierra Club’s allegations of “previously undisclosed large-scale contamination” and “massive” exceedance of regulatory limits are false. Their submission lacks context and demonstrates a limited understanding of environmental issues related to uranium mining in northern Saskatchewan and the performance of our operations and regulatory agencies.    

Below you will find Cameco’s responses to the “highlights” included in the Sierra Club’s submission directly related to our operations. We would be pleased to provide further information on any of these subjects.

For more information, contact:

Rob Gereghty
Manager, Media Relations
(306) 956-6190

Sierra Club: “We show that Cameco’s operations already emit an extraordinary and increasing amount of air and water releases that are a major source and pathway for pollution both south and north. Theses pollutants are often not regulated at all.” 

Cameco: Cameco’s operations are not a major source or pathway of pollution to the north or the south, and are thoroughly regulated by the Canadian Nuclear Safety Commission (CNSC) and the Saskatchewan Ministry of Environment. Air and water emissions from Cameco’s three mines and two mills in northern Saskatchewan are extraordinarily low and are declining due to renewal of production facilities and improved water treatment at all operations. Extensive monitoring programs are in place at each operation with results reported on a regular basis to provincial and federal regulators. 

Sierra Club: “The only public radiation protection level provided in regulations is a generally described effective dose rate of 1 mSv per year, which standard is not an appropriate proxy for coherent and protective regulatory limits to environmental releases.” 

Cameco: There is no measureable dose to the public from emissions from Cameco’s mining and milling operations. Radiation exposures to Cameco’s workers are carefully managed, intensively monitored and reported to the CNSC and individual workers.  The exposure limits reflect the international scientific consensus on safe levels of ionizing radiation as determined by the International Commission on Radiological Protection (ICRP) and enforced by the Canadian Nuclear Safety Commission. 

Sierra Club: “Even where there are standards, Cameco is not required to report airborne mercury emissions and waterborne mercury, uranium and cadmium release [sic] are merely identified as an “effluent characterization” not subject to specific limits. There is no limit for uranium in groundwater. Despite limits were [sic] they exist, Cameco is allowed to wildly exceed them without consequence.” 

Cameco: Uranium mining is one of the most heavily regulated mining activities in the world. Cameco is in compliance with all regulatory limits established by provincial and federal regulators. The provincial Mineral Industry Environmental Protection Regulations contain limits for uranium in treated mine effluent. Releases at all of our operations are well below this regulatory limit. 

We conduct extensive groundwater monitoring at all of our facilities, with information regularly reported to the regulatory agencies. 

Emissions to air as well as ambient concentrations surrounding our operations are routinely monitored, and this information is regularly reported to the regulatory agencies. Monitoring results indicate that we do not influence regional air quality, and that the quality of air at our surface lease boundaries is the same as background. 

At a minimum, our treated effluent is sampled for cadmium and mercury on a quarterly basis. Concentrations of mercury in treated water from our operations are very low and at or below laboratory detection limits. Cadmium in the treated water released is also low and, in fact, both parameters are better than Saskatchewan Surface Water Quality Objectives when released to the environment.   

Mercury is not associated with any of the processes at our operations, and therefore is not considered a constituent of potential concern by Cameco and regulatory agencies. This is confirmed by the lack of mercury in our treated effluent. Further, the low levels of cadmium in our treated effluent do not pose an environmental risk.

Sierra Club: “We calculate that should CNSC approve the Key Lake expansion application, we can expect an increase of almost 400 percent in the airborne release of uranium and radioactive lead 210 from the Yellowcake drying equipment alone! We are unable to calculate for mercury or cadmium as those air emissions were not reported.” 

Cameco: We do not expect concentrations of these parameters to increase significantly with production. The yellowcake calcining and packaging circuits have dedicated dust collection and gas scrubbing systems, which remove particulates from the gas prior to release to the environment. 

Further, we expect a reduction in our already low air emissions from the new calciner that is currently under construction at the Key Lake mill. 

Emissions to air as well as ambient concentrations surrounding our operations are routinely monitored, and this information is regularly reported to the regulatory agencies. Monitoring results have indicated that we do not influence regional air quality, and that the quality of air at our surface lease boundaries is the same as background. 

Sierra Club: “Despite failed reverse osmosis treatment and on-going sloughing failures at the tailings ponds containing uranium, lead, arsenic and polonium 210 from the mill effluent, the Saskatchewan Ministry of Environment permits Cameco to release water from the Gaetner [sic] and Deilmann tail ponds directly into the environment at Horsefly Lake. This lake drains into the Wheeler River to Wollaston Lake where is [sic] drains both to Hudson Bay and through the effects of McArthur River mine [sic], through the Mackenzie River to the Beaufort Sea.” 

Cameco: Reverse osmosis has in fact been successful at the Key Lake operation. Water released to the environment following reverse osmosis treatment at Key Lake is of such high quality that it meets Canadian Drinking Water Quality Guidelines.  

There are no “ongoing sloughing incidents” at our tailings management facilities where solid waste from milling is placed. The last minor event occurred in 2009. There has been no effect on the environment as a result of sloughing and no effect on the long-term integrity of the facility. Cameco is now completing a major project to cut back the slopes of the Deilmann tailings management facility (TMF) at the Key Lake operation to permanently stabilize the walls. 

Water collected from the Deilmann TMF drainage collection system is treated in the Key Lake mill’s water treatment system. The quality of this treated water is consistently better than regulatory criteria. 

Groundwater from the Gaertner and Deilmann dewatering systems is collected and treated by reverse osmosis. Upon release, this water not only meets Saskatchewan Surface Water Quality Objectives, but even Canadian Drinking Water Quality Guidelines. Further, treated water released to Horsefly Lake is better than all regulatory standards. 

Sierra Club: “As of 2010, water releases from Deilmann Tailings in cadmium [sic] exceed the Saskatchewan standard by an extraordinary 5,782 percent. Uranium concentrations were above the standard on average 1,323 percent and at the high level value by 10,153 percent! Radium 226 and lead 210 concentrations on average exceed the standard by 1,481 and 140 percent respectively.” 

Cameco: Water is not released from the Deilmann TMF. The numbers cited by Sierra Club are from testing of water before it is treated. Water is collected and sent for treatment and when it is released meets regulatory requirements. 

Treated water released from the reverse osmosis plant is considerably better than Saskatchewan Surface Water Quality Objectives and Canadian Drinking Water Quality Guidelines. Further, treated water released to Horsefly Lake is better than all regulatory standards when it is released to the environment. 

Sierra Club: “While there is no Canadian groundwater standard for uranium, Cameco reports concentrations at the Deilmann waste pile 1,190 times greater than the comparable Arizona standard.” 

Cameco: Water collected from the Deilmann TMF drainage collection system is treated in the mill water treatment system. The quality of this treated water is consistently better than the regulatory criteria. 

Groundwater from the Gaertner and Deilmann dewatering systems is collected and treated by reverse osmosis and the quality of treated water released is considerably better than Saskatchewan Surface Water Quality Objectives and Canadian Drinking Water Quality Guidelines. Further, treated water released to Horsefly Lake is better than all regulatory standards. 

Sierra Club: “At the McArthur River site, concentrations of arsenic, selenium, and uranium in water effluent have exceeded the standards by 54 percent for arsenic, 700 percent for selenium and an astronomical 1,230 percent for uranium. There is no reporting done on mercury. Blueberries and fish are contaminated with uranium.” 

Cameco: McArthur River is fully compliant with all provincial and federal regulatory limits. Treated effluent from the operation has been of excellent quality, with all parameters well below regulatory limits. 

Mercury in our treated water is sampled on a monthly basis and reported to provincial and federal regulators on a regular basis. Mercury contained within the treated effluent is consistently at or below laboratory detection limits. 

Monitoring has shown that blueberry plants and fish sampled near the McArthur River mine do not pose a risk.

Extensive monitoring of fish downstream confirms that there are no issues associated with fish, other aquatic life, or people. 

Sierra Club: “The Saskatchewan government permits Cameco to directly discharge water from Shaft 3 into the environment despite exceedences in both mercury and cadmium releases.“ 

Cameco: Water from Shaft No. 3 does not come into direct contact with mine workings and does not require treatment prior to release.  As confirmed by CNSC’s Environmental Risk Assessment Division experts, trace elements, metals and radionuclides within water from Shaft No. 3 are within the ranges recorded for surface waters before mining began. 

Routine monitoring has shown mercury is below laboratory detection levels in water released from Shaft No. 3. There have been no mercury exceedances in the Shaft 3 discharge. Mercury is not associated with any of the processes at our operations, and therefore is not considered a constituent of potential concern by Cameco and regulatory agencies. 

Further, there is no environmental risk associated with cadmium in the clean water released from Shaft No. 3, as evidenced by the low levels routinely reported to provincial and federal regulators. 

Sierra Club: “There is an increasing trend in radiation air concentrations of lead 210 and polonium 210.” 

Cameco: This is not correct. In fact, monitoring results show a declining trend in the very low concentrations of lead 210 and polonium 210 measured in the air at our operations. 

Our sulphur dioxide and stack emissions as well as ambient air concentrations surrounding our operations are routinely monitored, and this information is regularly reported to the regulatory agencies. Monitoring results have indicated that we do not influence regional air quality, and that the quality of air at our surface lease boundaries is the same as background. 

Sierra Club: “As the longest operating uranium mine in Saskatchewan, the Rabbit Lake Mine and Mill shows an extraordinary increase in uranium contamination of Hidden Bay’s sediment at Wollaston Lake of 9,233 percent between 1992 and 2007.” 

Cameco: Monitoring continues to indicate that the Rabbit Lake operation has not caused any significant adverse environmental effects in Hidden Bay of Wollaston Lake. Recent improvements in the quality of treated water released by the operation provide additional confidence that Hidden Bay is, and will continue to be protected. 

Monitoring has shown that uranium concentrations in our treated effluent and loadings to the receiving environment in Hidden Bay have significantly decreased. Since 2008, we have seen a decrease in uranium loadings of approximately 63%. Concentrations of uranium in the sediment of near-field water bodies have shown a three-fold decrease from 2002 to 2012. 

We routinely sample the sediment in Hidden Bay and report the results to the regulatory agencies. We expect that the improving trend observed in sediment quality downstream of the Rabbit Lake operation will continue. 

Sierra Club: “There has been an extreme increase in uranium concentrations in lichen near the D-Zone pond, one of the three flooded open pits at the site, by 2,167 percent and of radiation by 3,400 percent respectively also between 1992 and 2007.” 

Cameco: Environmental studies completed in 2008 and reviewed by provincial and federal regulators conclude there would be no adverse effect on animals near the operation. The highest concentrations of uranium in lichen at the D-Zone mining area were recorded in 1998 shortly after the D-Zone deposit was mined. Since that time, concentrations have declined by half and are expected to continue to decline as reclamation of the area continues.  

Sierra Club: “Cameco does not report on mercury, cadmium, lead and radiation, including polonium and cesium-137, air releases from the Yellowcake drying equipment on site. Cameco also does not report on groundwater quality “as it is also not an SMOE requirement”. 

Cameco: Cameco has an extensive monitoring program at all of our operations. In fact, it is a requirement to report groundwater results to the Saskatchewan Ministry of Environment and the CNSC.

Cameco conducts independent stack sampling at its milling facilities.  This stack sampling involves metals, radionuclides and particulates.  Cesium-137 is not sampled as it is a fission product formed in nuclear power plants or other nuclear reactions and is not part of the natural uranium decay chain.  High-volume air samplers are in place to measure ambient air quality for the primary metals and radionuclides of interest.  These are reported within the annual report submitted to the regulators. 

Sierra Club: “The fish around the B Zone pit lake are contaminated with polonium-210 and radium-226.” 

Cameco: This statement is incorrect. Results from several monitoring programs have indicated that concentrations measured in the fish surrounding the B-Zone pond in Collins Bay are near or at background levels. 

Sierra Club: “It is both inadequate and a clear conflict of interest to rely on Cameco to establish its action levels and hence the limits to the release of radiation and heavy metals into the environment. It is a failure of regulation and inconsistent with the government of Canada’s domestic and international obligations to not pay particular attention to establish enforced regulatory limits for the uranium sector to air and waterborne releases mercury, cadmium, lead and radiation.” 

Cameco: Action levels are approved by the CNSC and regulatory limits for Cameco’s operations are set by the CNSC, Environment Canada, and the Saskatchewan Ministry of the Environment. These have proven to be effective in protecting the health and safety of people and the environment. 

Sierra Club: “Given what is well known about the links between uranium mining and severe pollution, any effort less than comprehensive impact assessment cannot be said to strike the right balance between development and sustainability.” 

Cameco: We strongly disagree with the statement alleging links between uranium mining and severe pollution. The uranium mining industry is one of the most regulated industries in Canada. We are continually a top performer under the Metal Mining Effluent Regulations, and meet all other regulatory requirements. 

Each operation has extensive monitoring programs in place, with results reported to provincial and federal regulators on a regular basis.