January, 2017 Mr. Rodney Gardiner Box 216 Ile-A-La-Crosse, Sask. S0M
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January, 2017 Mr. Rodney Gardiner Box 216 Ile-a-la-Crosse, Sask. S0M 1C0 Hon. Dustin Duncan Minister of the Economy Room 346, Legislative Building 2405 Legislative Drive Regina, Sask. S4S 0B3 Hon. Dustin Duncan, Minister of the Economy: On December 14, 2016, I carefully observed the Canadian Nuclear Safety Commission’s webcast of hearings concerning Decommissioned Uranium Mine and Mill Sites. I made two submissions to this commission: 16 M49.2 and 16 M49.2A. A local trapper, Ed Flett, made a submission as well. My submission involved the SRC (Saskatchewan Research Council) analysis of moose flesh from an animal I harvested near the Cluff Lake Mine site, as well as concerns regarding the storage of core samples on site. Unfortunately, a 2-day CNSC agenda was given only one day of hearings, resulting in a very cursory discussion of my concerns, very late in a long day of proceedings. Sadly, this also resulted in no mention of the important submission by Edward Flett, describing a recent large die-off of fish in a creek and lake (Island Lake) just downstream from the mine site. Never in a lifetime of trapping the area has such a die-off been witnessed. Imagine seeing the shores lined with dead fish, which then the eagles, bears, gulls and otter proceeded to eat. It is observations like this, combined with my own observations over more than 30 years of hunting, fishing and working 33 years at the mine site, that cause me to write to you today. AREVA has profited from extracting 62 million pounds of yellow cake from our traditional hunting and fishing territory. However, when decommissioning was planned, a very inexpensive and short-sighted approach seemed to be undertaken, despite the fact that this waste involves radioactive contaminants which will remain radioactive and dangerous for thousands of years. Crushed rock and tailings at the mine site contain 85% of the radioactivity from the ore. Uranium breaks down into radium and about two dozen other radioactive materials, and the effective half-life of this radioactivity is 80,000 years. (After 80,000 years there will be half as much radioactivity in these tailings as there is now.) Fortunately for AREVA, radiation from such sources has no taste, no sound, no form by which it can be seen, and no odour. AREVA has essentially dumped everything (the entire mill and all equipment) either into the pits (ie. Claude Pit) or the tailings management area. They then backfilled, and covered with one meter of till. The till was also deposited on the frozen tailings area and after the thaw in the spring the till began to sink into the tailings. (It would be much like placing till over muskeg in winter.) Other material from the tailings area was pushed up in this process. Rock that was deposited on the tailings sank into the tailings and then was pushed up again by frost. Some areas of this cover are very thin now. Clearly, this decommissioning approach is showing evidence of failure less than 10 years into the Transition period. AREVA is eager to move to Institutional Control so they are no longer financially liable. I urge the Minister to extend the period of Transition to ensure that the province is not left with another environmental mess like Gunnar, in terms of long-term impact. AREVA has done a good job on the superficial visual appearance of the mine site, which was certainly not done at Gunnar. But the intention to walk away and let the province deal with the consequences over hundreds and even thousands of years is identical. Less than 10 years into Transition I see problems like the following: o Seepage from the tailings rock pile moving into Cluff Lake. o The real threat of a high-water year causing a breach in the dam on the west side of the tailings area o Thin areas of cover, less than one meter o East of Claude Waste pile there were two trenches dug through muskeg for about 100 yards, into which was placed peat and later contaminated metal such as old cat tracks, old cat sprockets and eventually steel shavings. This “filter” would actually qualify as a source of contamination in that muskeg. o At the DJ Pit, water was predicted to return to ground-water level but never did and in high water years comes very close to crossing the berm. The berm is not a sufficient barrier into the future when climate change conditions guarantee that we will have extreme events such as very high water years. o Cement vaults that originally contained high grade tailings, with high radium content, were stored on a hill on six-by-six blocks with no cement floor under them. Blocks cracked, vaults leaked, some vaults tipped over, or were accidentally dropped and tipped over. The soil from that area was never removed or cleaned up in any way. Trees and grass eventually grew in the area, which is of course providing food for animals as it grows up out of contaminated surface soil. After the containers were emptied for gold recovery, they were tossed in the tailings area and remained there in the open until they were finally covered with tailings. o Evidence of 4-wheelers getting stuck in wet areas of the tailings management area o Former workers reporting 20 loads of ore being dumped in the Claude Waste Pile o In the Shea Creek (high grade) core storage area, there is evidence of people entering the core sample area, removing items including plywood covers from above the core samples and pieces of the core samples themselves; children’s tracks were visible in and around core samples o Moose sinking into the wet tailings in some spots o Moose eating the green growth on young trees growing out of the tailings (the roots of these trees offering a way of transferring contaminants into the larger ecosystem) o Moose licking exposed tailings rock because of its salt content and licking the mud on the shore of Island Lake, probably for salt content o Cluff Lake area hunters and fishermen are reporting abnormalities in the organs of game animals and lumps and sores on whitefish and pickerel o The moose liver from a moose harvested near the Cluff Lake Mine site was inedible, having a terrible flavor and a smell reminiscent of battery acid According to AREVA’s report to the CNSC everything has been returned to a natural state at the Cluff Lake Mine site and all food harvested on the mine site is fine to eat. Yet everything I describe here has been witnessed on the ground. As a local person who has worked and hunted in the Cluff Lake area most of my life, I am often asked if the food harvested at the Cluff Lake site is good to eat. What can I honestly tell them? At the CNSC hearings, one person suggested my moose data must be “dated” because it didn’t correlate with their data. Note that I harvested the moose and had it analyzed this past fall. He also had the audacity to suggest the moose must have had legs 4-5 meters long to be able to sink into the tailings. I ask the Ministry, at the very least, to consider extending the Transition Period before Institutional Control so that Independent samplers can be sent in regularly to monitor the site for a more extended period of time, including performing detailed radiological reviews. Fortunately, when the baseline studies were done for AMOK at the beginning of this mining project, considerable baseline data was collected. Interestingly, at the CNSC hearings, President Binder suggested that Saskatchewan wouldn’t be stupid enough to take back a site that will cost them more in the future. But Saskatchewan’s decision is only as good as the data it is based upon, so please have independent researchers re- sample everything for which we have baseline data. Perhaps this is something you have planned to do? Based on my on-the-ground observations, Saskatchewan is at risk of making a huge mistake if we take on Institutional control in 2019, as AREVA intends us to do. Please respond to my concerns at the address above. Sincerely, _______________________________ Rodney Gardiner cc: Hon. Scott Moe, Minister of the Environment, MLA Buckley Belanger, Critic for Energy and Resources, MLA Cathy Sproule, Environment Critic, MLA Doyle Vermette, Critic for Northern Saskatchewan, MP Georgina Jolibois, MP Linda Duncan, Critic for Environment and Climate Change, Mr. Keith Cunningham, Senior Analyst, Uranium, Ministry of Economy. .