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2016 How to Overcome the Challenges in In-situ Decommissioning of the Above Ground Tailings Management Facility?

Madhavan, Dayal

Madhavan, D. (2016). How to Overcome the Challenges in In-situ Decommissioning of the Above Ground Tailings Management Facility? (Unpublished master's thesis). University of Calgary, Calgary, AB. doi:10.11575/PRISM/26396 http://hdl.handle.net/11023/3115 master thesis

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How to Overcome the Challenges in In-situ Decommissioning of the

Above Ground Tailings Management Facility?

Dayal Madhavan

A THESIS

SUBMITTED TO THE FACULTY OF GRADUATE STUDIES

IN PARTIAL FULFILMENT OF THE REQUIREMENTS FOR THE

DEGREE OF MASTER OF ENGINEERING

GRADUATE PROGRAM IN CIVIL ENGINEERING

CALGARY, ALBERTA

July, 2016

This thesis focused on the challenges related to the in-situ decommissioning of the above ground tailings management facility (AGTMF) at Cameco’s Key Lake Uranium Milling and Mining

Operations. The uranium tailings stored in the AGTMF from 1983 to 1998 could adversely affect the regional biota and public health as the tailings. Significant uncertainties also exist in regards to the ultimate long-term storage of uranium mine tailings as the timescales involved are relatively long (e.g. 10, 000 years modelling required).

This study has explored the processes, challenges and lessons learned in the in-situ decommissioning and the methods on how to overcome the challenges related to decommissioning the AGTMF. The stored tailings are key areas of liability and this thesis has endeavoured to overcome the challenges by gaining insights from decommissioning activities within uranium industry globally to achieve a safe, cost effective, and environmentally sustainable decommissioning process for the AGTMF.

ii Preface

Decommissioning of the AGTMF at Key Lake is challenging as the primary objective is ensure the long-term geochemical and geotechnical stability of the facility. In addition to this and added challenge is to contour the tailings facility in order to better incorporate the tailings facility into the regional landscape. Mining and milling activities do change the landscape and returning the disturbed area to a sustainable landscape requires significant planning. It is a concern when theses mining/milling wastes are stored in an AGTMF as they may become a principal source term of contaminants (metals and radionuclides such as thorium, radium, radon, and lead). These elements of concern, if not properly contained, can present risk to the local biota for centuries to come.

Decommissioning of tailings management facilities within the mining industry is continually being researched by various institutions in order to make decommissioning practices cost effective and workable through enhanced technologies. This requires project management practices to be effective by adopting new technology as innovation emerges with a focus on meeting or exceeding regulatory requirements.

The objective of this thesis is to provide insight into project management decommissioning practices in order to meet the expectations to achieve a sustainable decommissioning process whereby protection of environment, public health and safety will be ensured through the decommissioning of the AGTMF.

iii Acknowledgements

Firstly, I am thankful to my guide Dr.Janaka Ruwanpura, Vice Provost (International) and

Professor, Department of Civil Engineering, University of Calgary for his continuous support of my M.Eng thesis. My sincere thanks goes out to Dr.Raafat El-Hacha, Dr.George Jergeas and

Dr.Gopal Achari for providing their valuable suggestions during my thesis defense.

I sincerely acknowledge Cameco Corporation, my employer for providing me an opportunity to carry out the M.Eng thesis on the in-situ decommissioning above ground tailings management facility at Cameco’s Key Lake Operation.

I sincerely thank Dr.Brett Moldovan, General Manager, Key Lake Operations, Cameco

Corporation for his guidance and kindly accepting to review my thesis. I would like to acknowledge my current and former supervisors at Key Lake Operation’s Superintendent,

Project Planning (Wayne Williams and Jason Piche) and Key Lake Operation’s Mill Manager

(Kevin Himbeault) for their long standing support.

I wish to recognise and thank the valued inputs provided to me by Key Lake Operation’s SHEQ

Superintendent (Daley McIntyre), Key Lake Operation’s Construction Management Team (Jason

Driedger & Jim Lessard), Cameco Geo-Environmental Division’s Manager (Barry Esford),

Cameco Geo-Environmental Division’s Chief Geo-Scientist (Dr.Thorsten Reszat) and Cameco’s

Chief Metallurgist (Arthur Lieu).

Last, but not least I sincerely express my profound gratitude to my wife Zinda and my sons

Yedu, Vaishnav and Pranav for their love, patience and unconditional support provided all throughout my years of study to accomplish this goal.

iv Dedication

This thesis is dedicated to my beloved son Yedu Dayal (24 yrs.) whose untimely loss on April

19, 2014 from a motor bike accident on our community road has saddened all who dearly loved him. His optimism, eternal smiles, and zeal to relish life wholly will be the driving force to all who loved him dearly to move ahead cheerfully reminding us of Trent Thomas’s quote,

“Do not allow the pain of loss, to stop the process of living”,

v Table of Contents

Abstract ...... ii Preface...... iii Acknowledgements ...... iv Dedication ...... v Table of Contents ...... vi List of Tables ...... x List of Figures and Illustrations ...... xii List of Symbols, Abbreviations and Nomenclature ...... xiii Epigraph ...... xiv

INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 A Brief History of the Above Ground Tailings Management Facility ...... 1 1.3 Purpose for Decommissioning the AGTMF ...... 6 1.4 Origin of Tailings Stored in the AGTMF ...... 12 1.5 Previous Investigations ...... 12 1.6 Objective ...... 13 1.7 Scope of the Thesis ...... 14 1.8 Decommissioning Strategies...... 15 1.9 Value and Originality of this Thesis ...... 15 1.10 Research Method ...... 16

LITERATURE REVIEW ...... 19 2.1 Regulatory Framework ...... 19 2.1.1 Federal Regulations ...... 20 2.1.2 Provincial Regulation ...... 25 2.1.3 Decommissioning and Licensing Process for AGTMF ...... 27 2.2 Types of Decommissioning for Above Ground Tailings Management Facility .....29 2.2.1 Decommissioning Options for AGTMF ...... 29 2.2.2 In-situ Decommissioning - Experiences of Cover Capping ...... 34 2.2.3 Decommissioning Options Selected for AGTMF at Key Lake Operation ...... 43

DECOMMISSIONING FRAMEWORK ...... 48 3.1 Technical Related Process in Decommissioning ...... 48 3.1.1 Characterization of the Tailings ...... 48 3.1.2 Delineation of the Radioactivity Tailings ...... 52 3.1.3 Contamination from the Tailings ...... 52 3.1.4 Recognizing the Unknowns ...... 54 3.1.5 Management of Low Level Radioactive Waste (LLRW) ...... 54 3.1.6 Climatic Conditions ...... 55 3.1.7 Environmental Issues ...... 55 3.1.8 Characterize the Geochemical, Geotechnical, and Hydrogeology ...... 56 3.2 Operational Related Process ...... 56 3.2.1 Radioactive Nature of Tailings ...... 56 3.2.2 Thawing Process for Consolidation ...... 57

vi 3.2.3 Non-Radioactive Nature of Tailings ...... 57 3.2.4 Dusts ...... 58 3.2.5 Proven Technology and Other Resources ...... 58 3.2.6 Experienced Decommissioning Contractors ...... 58 3.2.7 Protection of Decommissioning Personnel ...... 59 3.2.8 Pore Fluids...... 59 3.2.9 Funding for Decommissioning ...... 61 3.3 Project Management Process ...... 61 3.3.1 Implement a Project Planning Process ...... 61 3.3.2 Selection of viable decommissioning options ...... 62 3.3.3 Safety Factors ...... 64 3.3.4 Develop a Scope Meeting Regulatory and Public Acceptance...... 64 3.3.5 Cost Factors ...... 65 3.3.6 Manage and Obtain Consensus from Various Stakeholders ...... 66 3.3.7 Evaluate Social Attributes to Reassure the Stakeholders ...... 67 3.3.8 Implement a Project Schedule ...... 68 3.3.9 Manage Project Cost and Set Project Controls...... 69 3.3.10 Define Roles and Responsibilities to Assign Decommissioning Tasks ...... 70 3.3.11 Set Communication Strategy...... 71 3.3.12 Manage Risk...... 71 3.3.13 Procurement Process for a Decommissioning Contractor ...... 72 3.3.14 Review and Use Lessons Learned ...... 73 3.3.15 Develop and Implement Training...... 74 3.3.16 Develop and Implement Quality Assurance Program ...... 74 3.3.17 Typical Decommissioning Management Concerns ...... 75

DECOMMISSIONING CHALLENGES ...... 76 4.1 Technical Challenges ...... 76 4.1.1 Characterization of the tailings ...... 77 4.1.2 Delineation of the Radioactivity Tailings ...... 77 4.1.3 Contamination from the Tailings ...... 78 4.1.4 Recognizing the Unknowns ...... 78 4.1.5 Climatic Conditions ...... 78 4.1.6 Environmental Issues ...... 79 4.1.7 Characterize the Geochemical, Geotechnical, and Hydrogeology ...... 79 4.2 Operational Challenges ...... 80 4.2.1 Radioactive Nature of Tailings ...... 80 4.2.2 Thawing Process for Consolidation ...... 80 4.2.3 Non-Radioactive Nature of Tailings ...... 81 4.2.4 Dusts ...... 81 4.2.5 Pore Fluids...... 81 4.2.6 Proven Technology and Other Resources ...... 81 4.2.7 Experienced Decommissioning Contractors ...... 82 4.2.8 Protection of Decommissioning Personnel ...... 82 4.2.9 Funding for Decommissioning ...... 82 4.3 Project Management Challenges ...... 83 4.3.1 Project Planning Process ...... 83 vii 4.3.2 Selection of viable decommissioning options ...... 83 4.3.3 Safety Factors ...... 83 4.3.4 Cost of Decommissioning ...... 84 4.3.5 Develop a Scope Meeting Regulatory Acceptance...... 84 4.3.6 Manage Stakeholders and Obtain Consensus ...... 85 4.3.7 Project Schedule ...... 85 4.3.8 Manage Project Cost and Set Project Controls...... 85 4.3.9 Define Roles and Responsibilities ...... 86 4.3.10 Manage Risk...... 87 4.3.11 Lessons learned ...... 87

LESSONS LEARNED ...... 88 5.1 Early Planning for Decommissioning ...... 88 5.2 Communications ...... 90 5.3 Decommissioning Strategies...... 92 5.4 Regulation of Decommissioning ...... 93 5.5 Environmental Concerns ...... 94 5.6 Covers for tailings ...... 95 5.7 Funding of Decommissioning ...... 98 5.8 Estimation of Decommissioning Cost ...... 99 5.9 Management of Radioactive Waste from Decommissioning ...... 102 5.10 Selection of Technologies for Decommissioning ...... 103 5.11 Decommissioning Workforce ...... 103 5.12 Safety during Decommissioning ...... 104 5.13 Social Aspects ...... 105 5.14 Understanding Unionised Environment ...... 105 5.15 Decommissioning Cost – Justified or Not ...... 106 5.16 High Cost ...... 106 5.17 Community Environmental Quality Committee ...... 107

PROJECT MANAGEMENT OF IN-SITU DECOMMISSIONING METHOD ...... 108 6.1 Project Objectives ...... 108 6.2 Policy and Commitment of In-Situ Decommissioning of AGTMF ...... 109 6.3 Project Management Planning for In-Situ Decommissioning ...... 109 6.3.1 Conceptual Decommissioning Plan ...... 110 6.3.2 Detailed Decommissioning Plan ...... 111 6.4 Project Life Cycle of In-Situ Decommissioning ...... 112 6.5 Project Scope for In-Situ Decommissioning ...... 113 6.5.1 Pre-Decommissioning Stage - Feasibility - Phase I ...... 113 6.5.2 Pre-Decommissioning - Detailed Engineering –- Phase II ...... 117 6.5.3 Decommissioning Stage – Thawing Program – Phase III ...... 119 6.5.4 Decommissioning Stage – In-situ Decommissioning – Phase IV ...... 120 6.5.5 Post Decommissioning - Monitoring and Maintenance - Phase V ...... 123 6.6 Project Management Team for In-Situ Decommissioning ...... 125 6.6.1 Develop the Project Team ...... 126 6.7 Project Schedule for In-Situ Decommissioning ...... 129

viii 6.8 Project Cost Estimates for In-Decommissioning ...... 136 6.8.1 Assumptions for Project Schedule & Cost Estimates ...... 153 6.9 Project Controls for Decommissioning ...... 156 6.10 Project Quality Management ...... 156 6.11 Project Communication System ...... 157 6.12 Managing Stakeholders ...... 159 6.13 Project Risk Management ...... 161 6.14 Project Procurement Management ...... 164

CONCLUSIONS ...... 168 7.1 Summary ...... 168 7.2 Findings ...... 169 7.3 Recommendations ...... 172 7.4 Further Research ...... 173 7.5 Conclusion ...... 174

REFERENCES ...... 175

ix List of Tables

Table 1.1: Tailings Volume Frozen and Un-Frozen ...... 7

Table 2.1: Nuclear Safety Act ...... 22

Table 2.2: CNSC Regulatory Guides/Policies for Decommissioning ...... 23

Table 2.3: Canadian Environmental Assessment Act ...... 24

Table 2.4: Federal Legislative Requirements ...... 24

Table 2.5: Saskatchewan Legislation ...... 25

Table 2.6 Decommissioning Options for Tailings ...... 32

Table 2.7 Comparison of Decommissioning Options ...... 33

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 1 of 6) ..... 37

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 2 of 6) ..... 38

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 3 of 6) ..... 39

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 4 of 6) ..... 40

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 5 of 6) ..... 41

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 6 of 6) ..... 42

Table 3.1 General Geotechnical Tailing Properties ...... 49

Table 3.2 Overall Tailings Mineralogy ...... 50

Table 3.3 Characteristics of the Tailings Solids ...... 51

Table 3.4 Exposure Pathways of AGTMF Uranium Mill Tailings ...... 53

Table 3.5 Characteristics of the Porewater ...... 60

Table 3.6 Decommission Options ...... 63

Table 3.7 Cost of Decommissioning Tailings based on Past Project Value ...... 66

Table 6.1 Overall Preliminary Schedule for In-Situ Decommissioning of AGTMF ...... 130

Table 6.2 Preliminary Schedule for Feasibility Phase I of AGTMF ...... 131

Table 6.3 Preliminary Schedule for Detailed Engineering Phase II of AGTMF ...... 132

x Table 6.4 Preliminary Schedule for Thawing Program Phase III of AGTMF...... 133

Table 6.5 Preliminary Schedule for In-Situ Decommissioning Phase IV AGTMF ...... 134

Table 6.6 Preliminary Schedule for Post Decommissioning of AGTMF ...... 135

Table 6.7 Summary of Preliminary Cost Estimates for Each Stage & Phase of Decommissioning of AGTMF ...... 142

Table 6.8 Preliminary Cost Estimates for In-Situ Decommissioning of AGTMF ...... 143

Table 6.9 Project Risk Assessment Management for In-Situ Decommissioning ...... 165

xi List of Figures and Illustrations

Figure 1.1 – Location Map for Key Lake Operation ...... 3

Figure 1.2 – General Site Layout for Key Lake Operation...... 4

Figure 1.3 – Location of the AGTMF at Cameco Key Lake Operations ...... 5

Figure 1.4. General Arrangement of AGTMF ...... 8

Figure 1.5. AGTMF Embankment Sections Sheet 1 of 2 ...... 9

Figure 1.6. AGTMF Embankment Sections Sheet 2 of 2 ...... 10

Figure 1.7. AGTMF Plan ...... 11

Figure 2.1 CNSC’s Elements of the Regulatory Framework ...... 22

Figure 2.2: Flow Diagram for Decommissioning & Licensing Process for AGTMF ...... 27

Figure 2.3: Proposed AGTMF Cover Design ...... 47

Figure 6.1 Projectized Organization Chart for In-Situ Decommissioning ...... 128

Figure 6.2: Preliminary Cost Estimates for Each Phase of AGTMF Decommissioning ...... 141

Figure 7.1 Mining/Milling Life Cycle of Uranium Operations ...... 169

xii

List of Symbols, Abbreviations and Nomenclature

Symbol Definition

AFE Authorised Fund Expenditure AGTMF Above Ground Tailings Management Facility ALARP As Low As Reasonably Predictable ANSTO Australian Nuclear Science and Technology Organization CEAA Canadian Environmental Assessment Agency CNSC Canadian Nuclear Safety Commission Co Cobalt DOE Department of Energy DTMF Deilmann In-Pit Tailings Management Facility EVMS Earned Value Management Systems GDP Gross Domestic Product IAEA International Atomic Energy Agency KLO Key Lake Corporation LLRW Low Level Radioactive Waste Ni Nickel NSCA Nuclear Safety and Control Act pCi/m2-sec Radon emissions measurement - Picocuries per square meter-second SMOE Saskatchewan Ministry of Environment TMA Tailings Management Area U3O8 Triuranium Octoxide USNRC United States Nuclear Regulatory Commission uR/hr Gamma or X-Ray radiation measurement - 1 micro roentgen - One-millionth of a Rontgen WMA Waste Management Area

xiii

Epigraph

“Lokah Samastha Sukhino Bhavanthu”

Sanskrit Mantra

“May all beings everywhere be happy and free, and may the thoughts, words, and actions of our

own life contribute in some way to that happiness and to that freedom for all”.

xiv

Introduction

1.1 Background

Key Lake is located approximately 570 km north of Saskatoon, Saskatchewan, Canada. Figure

1.1 – Location Map for Key Lake Operation and Figure 1.2 – General Site Layout for Key Lake

Operation (Courtesy of Cameco Corporation) .

Key Lake Operations (KLO) is owned by Cameco Corporation (83%) and AREVA Resources

Canada (17%). Cameco Corporation is one of the world’s largest uranium producing companies whose assets include the world’s highest grade uranium ore deposits located within the

Athabasca Basin geologic formation in Saskatchewan, Canada. At KLO, uranium mining and milling operations began in 1983; however mining operations ceased at both the Deilmann and

Gartner open pit in 1997. Milling at Key Lake has continued as the operation currently mills uranium ore from the McArthur River mine.

Currently KLO operates the world’s largest uranium milling facility with a capacity of producing

18.7 million pounds annually from uranium ore transported from McArthur River mine. In

2013, KLO registered a world record production of 20.1 million pounds of uranium (U3O8 -

Triuranium Octoxide).

1.2 A Brief History of the Above Ground Tailings Management Facility

In 1982 the AGTMF and associated utilidor was constructed to store and transport tailings produced from the milling of Gaertner and Deilmann ore. Figure 1.3 – Location of The AGTMF at Cameco Key Lake Operations (Courtesy of Cameco Corporation). The AGTMF at Key Lake

is an engineered, designed and constructed above-ground facility where uranium mill tailings are safely stored.

The AGTMF is approximately 0.5 square kilometres (128 acres) in area. The AGTMF has an outside dimensions of approximately 720 m x 720 m and an embankment height of up to 20m. It was designed to hold approximately 5.8 million m3 of tailings (Cameco, 2010a).

The AGTMF is contained within an above ground, engineered and constructed containment system designed to produce a fully drained and consolidated impervious tailings mass (see

Figure 1.4. General Arrangement of AGTMF (Courtesy of Cameco Corporation)). The AGTMF was constructed five meters above the groundwater table. A 200 mm modified bentonite liner was used to seal the bottom and isolate the tailings from the surrounding soil infrastructure. A sand filter blanket averaging one meter in thickness was placed over the bentonite-till liner. A drainage consisting of drain pipes were installed to collect and transmit seepage from the overlying tailings to discharge to a concrete sump downstream of the east embankment.

Contaminated water from the AGTMF is collected and treated in the mill effluent treatment system (Cameco, 2010a). Above-ground facilities use earthworks to contain the tailings and runoff is managed to ensure contaminants are contained. These facilities could safely be decommissioned in place and remain protective of environment for very long periods.

The engineered design of the AGTMF incorporates a filter blanket under the entire area of the stored tailings and is designed to continuously collect all free draining supernatant fluids as well as pore fluids squeezed during the consolidation process.

2 KEY LAKE

FIGURE 1.1

LOCATION MAP FOR KEY LAKE OPERATION COURTESY OF CAMECO CORPORATION

FIGURE 1.3

LOCATION OF AGTMF AT CAMECO KLO COURTESY OF CAMECO CORPORATION

A bentonite layer in the embankments and under the filter blanket is present to confine seepage and direct it to the seepage collection system (see Figure 1.5. AGTMF Embankment Sections

Sheet 1 (Courtesy of Cameco Corporation) and Figure 1.6. AGTMF Embankment Sections Sheet

2 (Courtesy of Cameco Corporation).

Figure 1.7 AGTMF Plan illustrates the internal dyke that separates the east and west cells of the

AGTMF and the location of contaminated waste landfill. The tailings were deposited as slurry at about 35% solids density (wt/wt) to achieve the maximum dewatering efficiency and minimum separation of fine grained solids in order to ensure maximum consolidation and low permeability

(hydraulic conductivity). The tailings were deposited in the AGTMF which consist of the east and west cells and these cells are separated by internal dyke. The AGTMF currently contains approximately 4.59 M m3 of tailings; of that 1.60 M m3 is considered frozen (as per Cameco

Geo-Environment Dept). Table 1.1 provides the tailings volume in terms of frozen and un-frozen tailings. Prior to fully decommissioning the AGTMF, the tailings must be fully thawed and consolidated.

1.3 Purpose for Decommissioning the AGTMF

There are several factors that are critical to why decommissioning has to be carried out at the

KLO AGTMF. If left uncovered fugitive airborne contaminants from the AGTMF have the potential to be released to the atmosphere and transported to the environment through erosion and leaching. The primary reason for decommissioning will be to protect the regional biota and the community (people) who use this area from these contaminants of concern.

Table 1.1: Tailings Volume Frozen and Un-Frozen

Tailings Units East Cell West Cell

Total Non-Frozen (Mm3) 1.26 1.73

Total Frozen (Mm3) 1.4 0.2

Total Volume (Mm3) 2.66 1.93

Frozen Fraction % 52 10

By decommissioning the AGTMF the long-term adverse effects are minimized, the reclaimed landscape is stabilized and is self-sustaining nature. Currently it is proposed to decommission the AGTMF with an engineered cover that would be constructed to ensure long-term geochemical and geotechnical stability of the facility. Disturbed land areas will be contoured into the local landscape and re-vegetated where possible.

The principal radiation risks are gamma radiation, in particular from radium decay; windblown radioactive dust dispersal; and radon gas and its radioactive progeny, which are known to cause lung cancer. The hazards from the tailings arise not only from its radioactivity but also from the presences of heavy metals and other contaminants of concern in the tailings. These heavy metals and other contaminants of concern are a potential source term and can lead to surface and groundwater contamination. Tailings have been acknowledged to become potentially hazardous to have high environmental impact (Balkau F, 1998).

7 FIGURE 1.4

GENERAL ARRANGEMENT OF AGTMF COURTESY OF CAMECO CORPORATION FIGURE 1.5

AGTMF EMBANKMENT SECTIONS SHEET 1 COURTESY OF CAMECO CORPORATION FIGURE 1.6

AGTMF EMBANKMENT SECTIONS SHEET 2 COURTESY OF CAMECO CORPORATION FIGURE 1.7

AGTMF PLAN COURTESY OF CAMECO CORPORATION

The AGTMF needs to be decommissioned according to current regulations and the scope may include restoring the area as close as possible to the original state. Any decommissioning options proposed by the company has to comply the regulations and have approval prior to decommissioning activity. One important item to be borne in mind is that decommissioning activity is not generating income and this makes it less tempting for any industry to carry through with decommissioning activities until it is required at closure.

1.4 Origin of Tailings Stored in the AGTMF

The uranium mining and milling activities at KLO generated the uranium tailings that were deposited in the AGTMF and contain heavy metals and various radionuclides that remain after uranium is extracted in the Key Lake milling process. The tailings produced by milling all the

Gaertner ore and Deilmann ore were deposited in the AGTMF, which is located south west of the mill facility. The tailings within the KLO AGTMF contain several elements of concern (e.g. radium, thorium, nickel, cobalt, arsenic, molybdenum, selenium among others) and typically contain metals such as arsenic, cadmium, cobalt, copper, molybdenum, nickel, lead, selenium and zinc. The tailings were deposited in AGTMF from 1983 (initial uranium mining/milling at

Key Lake) and continued operation until 1997 when the Key Lake Operation began depositing mine tailings in the Deilmann in-pit tailings management facility.

1.5 Previous Investigations

The decommissioning of the Key Lake AGTMF has been the subject of a number studies within the KLO. Some of the related studies were carried on baseline hydrogeological conditions, long term pore water (seepage) quality, the modelling of various capping scenarios, cover design and

decommissioning as well the geochemical characterization of the tailings in AGTMF. The characteristic components of project management and operational challenges in decommissioning of the AGTMF at Key Lake have never been linked to the studies undertaken so far which will be focused herein.

1.6 Objective

The Key Lake AGTMF has become an environmental issue of concern with the regulatory bodies as well as northern stakeholders in regards to the long-term decommissioning plans for this facility. The objective of decommissioning the AGTMF is to permanently decommission and restore the AGTMF as a requirement under both federal and provincial regulations.

The specific objective of this thesis is to identify and overcome the constraints in project management and operational challenges in order to effectively implement the decommissioning programs for the AGTMF in an environmentally sustainable manner. Thesis aims to provide an insight into the literature and common practices in project management for a sustainable approach for an in-situ decommissioning based on: i) the current site conditions, ii) previous research conducted on the AGTMF, iii) past practice in regards to in-situ decommissioning of related industrial waste facilities.

Thesis aims at overcoming the challenge by applying due diligence to properly manage decommissioning and closure of the AGTMF in an environmentally sustainable manner. This will be accomplished through the use of proven techniques through the application of project

management tools, technical knowledge, lessons learned from related projects and adhering to the applicable current and forecasted future environmental regulations.

1.7 Scope of the Thesis

The thesis will focus on methods to overcome the project management and operational challenges related to decommissioning the AGTMF in an uranium industry as these are the key areas of liability for Cameco and similar uranium industries worldwide. The scope of the thesis is limited primarily to accomplish the goals and regulatory requirements for decommissioning of the KLO AGTMF. Additionally, the scope of this thesis is to provide some insight gained from decommissioning similar facilities within uranium mining and milling industry globally. The information presented in this report could be used as a basic approach for knowing more about decommissioning tailings management facilities and the different factors that affect the economics of decommissioning projects. The thesis has the following limitations:

Similar studies related to commissioning a tailings facility similar to the AGTMF are rare and therefore this study is intended to explore the best practices that can be applied in the field instead of providing one specific solution. There are not many successful experiences and technical discussions from literature review on identical in-situ decommissioning of above ground tailings management facility. Therefore references are more on the decommissioning experiences related to uranium tailings management facility that are not identical to decommissioning of AGTMF.

1.8 Decommissioning Strategies

Cameco had developed two possible strategies for the decommissioning of the AGTMF (Cameco,

2013);

 Mining the Tailings - Mining the tailings deposited at the AGTMF to recover the nickel

(Ni) and cobalt (Co) contained within the tailings.

 In-Situ Strategy - The decommissioning for the AGTMF proposed by Cameco Corporation

will be based on in-situ decommissioning technology where the consolidated tailings will

encapsulated by placing an engineered cap over the tailings body.

The in-situ strategy is the current preferred option.

1.9 Value and Originality of this Thesis

The thesis is based on decommissioning the AGTMF considering the option in-situ strategy and will have great significance for the uranium mining industry, environment and the indigenous people of this region. Overall this thesis will offer insights on: i) A comprehensive overview of in-situ decommissioning of the AGTMF. ii) Approaches to overcome project management and operational challenges to lower the cost. iii) Solutions on in-situ decommissioning of the AGTMF in an environmentally sustainable

manner. iv) Discussions to understand best practices and experiences gained domestically and

internationally on in-situ decommissioning.

v) Benefit from lessons learned from in-situ decommissioning projects worldwide.

1.10 Research Method

A qualitative research method is chosen as an appropriate approach to focus on project management and operational challenges in the in-situ decommissioning of the AGTMF. A qualitative approach becomes more suitable in order to fulfill the purpose of this research, because the thesis focuses on how to overcome the challenges in-situ decommissioning of the

AGTMF while understanding and utilizing the experience gained from similar limited case studies which is otherwise difficult to measure in a quantitative way. The benefit of applying a qualitative method is that it allows exploring an overall picture of in-situ decommissioning processes which cannot be provided by quantitative method where it relies on statistics and numbers.

“The beauty of qualitative research is unpacking the black box and getting at the Why?”

Dr. Prudence L Carter.

In qualitative methodology, case study is widely used to collect descriptive data through the intensive examination of an outcome in a particular situation and are particularly useful for studying rare or complex occurrences like in-situ decommissioning of AGTMF. More importantly case studies present how things occur in reality and practice and therefore can be used as more practical solutions for complex issues. Qualitative research provides a more realistic feel of the decommissioning processes and helps in better understanding of the issues and improving the process to considerably lower the risk involved in decommissioning the

AGTMF.

Siggelkow (2007) argues that a single case analysis can be a very powerful example and can be used to fill in the gaps in existing theories. Boodhoo R and Purmessur R.D (2009) demonstrates that qualitative research has been carried out on the failure of giant corporations like WorldCom or Enron to find out the causes of corporate failures and better understand of the business environment and improve the corporate structure of the firm related to the internal policies, corporate governance and management.

The research strategy adopted for the thesis involves evaluation of the information, organising and presenting the information achieved through collection and review of literature, analysis of facts from uranium mining and milling industry, utilizing observed techniques from similar in-situ decommissioning projects worldwide. This allows expanding knowledge on in-situ decommissioning facilities and helps in understanding the history of in-situ decommissioning facilities, what ideas have been developed and changed, the pros and cons of different approaches to decommissioning and their applicability to overcome the current challenges at the AGTMF.

The literature review supported identifying existing technologies to maximize resolving the site related current problems/issues at decommissioning the AGTMF. Studies and literature deemed applicable to the thesis are identified from various researches and studies completed both nationally and internationally and are provided in reference.

Qualitative methodology adopted for the thesis provides some insight on the in-situ decommission program of the AGTMF including addressing the following tasks: i) to develop an environmentally sustainable in-situ decommissioning program,

ii) to identify and overcome the operational and project management challenges iii) to discuss the best practices and experiences gained domestically and internationally on

similar in-situ decommissioning facilities. iv) to compile the experiences gained from lessons learned from in-situ decommissioning

nationally and globally.

Literature Review

2.1 Regulatory Framework

Cameco will require approval of the decommission plan from the Canadian Nuclear Safety

Commission (CNSC) prior to beginning decommissioning of the AGTMF. As part of Cameco’s application for this approval, a detailed decommissioning and monitoring plans will be required to be developed. When an application for decommissioning is submitted to the CNSC, an environmental assessment is required prior to initiating the licensing process. The CNSC assesses the decommissioning plan, associated costs and the environmental assessment and when satisfied that all of its requirements are met, a decommissioning license may be issued. This section attempts to present an overall understanding of the regulatory and legal framework within which the decommissioning of AGTMF will occur.

From a statutory perspective, regulation of the uranium industry is shared between two senior levels of government, but in practice it has become a tripartite system between Canada,

Saskatchewan and the local communities affected by mining (Parsons and Barsi, 2000). The regulatory framework in Canada lies with the federal government who has statutory authority over mining, milling and disposition of radioactive materials, fisheries, and migratory birds, some aspects of the environment and welfare of aboriginal people. The province has responsibility for management of the mineral and forest resources, wildlife, land use and the environment. Uranium mining in Canada is regulated federally by the CNSC, the federal nuclear regulatory agency because of the presence of nuclear substances.

The involvement of the local communities has increased in regards to collaborating with regulators and mine operators to provide oversight of environmental management practices, mostly on the socio-economic aspects that affect the community (Clifton Associates, 2002). A mining company that operates in Saskatchewan is required to meet the statutory and regulatory requirements of the provincial and federal governments while maintaining social approval within the affected communities. It is the responsibility of the mining company to comply with the environmental regulations and supply government authorities with all the information about the decommissioning options and to recommend the best feasible option. The ultimate responsibility for decommissioning rests with Cameco (the licensee), however the final decision on how the

AGTMF should be decommissioned lies with government authorities.

2.1.1 Federal Regulations

The Nuclear Safety and Control Act (NSCA) establishes the regulatory framework for nuclear matters in Canada. The CNSC regulatory documents provide greater detail on requirements set out in the NSCA.

The CNSC licensing process for uranium mines and mills follows the stages laid out in the

Uranium Mines and Mills Regulations, proceeding progressively through site preparation and construction, operating, decommissioning, and abandonment (or release from licensing) phases.

The CNSC regulatory process requires that a licence applicant plan for and commit to future decommissioning before irrevocable decisions are made, and throughout the life of a uranium mine. This is to ensure that every aspect of uranium mining and milling is subject to licensing from the CNSC and are operated in accordance with international standards.

In the Uranium Mines and Mills Regulation SOR/2000-206 CNSC (2015), the Uranium Mines and Mills Regulations is administered by CNSC and it sets out the requirements for site preparation, construction, operation, decommissioning, and abandonment of uranium mines and mills. This regulations prescribes the requirements for licence applications, record keeping and other licensee obligations, such as codes of practice, operating procedures and ventilation systems and additionally sets out the time periods within which the Commission shall review an application for a licence to prepare site and construct and render a decision. Businesses involved in uranium mining or milling must meet the requirements set out in this regulation.

The CNSC’s framework consist of laws passed by Parliament that govern the regulation of

Canada’s nuclear industry, and regulations, and licences to regulate the nuclear industry. The

CNSC’s documents fall under two broad categories as provided in the CNSC’s regulatory framework fact-sheet:

a) Requirements are mandatory for licensees or applicants to obtain or retain a license to use

nuclear materials or operate a nuclear facility.

b) Guidance provides direction to a licensees and applicants on meeting the requirements set

out in CNSC’s documents comprising of regulations, regulatory documents and licences.

Figure 2.1 below presents the CNSC’s elements of the regulatory framework.

Figure 2.1 CNSC’s Elements of the Regulatory Framework

The CNSC is committed to reviewing its regulations on a regular basis. Some of the regulations that support the Nuclear Safety and Control Act and are listed below.

Table 2.1: Nuclear Safety Act ACT REGULATION/GUIDELINE RESPONSIBLE AGENCY General Nuclear Safety and Control Regulations Nuclear Non-Proliferation Import and Export Control Regulations Nuclear Security Regulations Nuclear Substances and Radiation Devices Nuclear Safety And Regulations CNSC Control Act Packaging and Transport of Nuclear Substances Regulations Radiation Protection Regulations Uranium Mines and Mills Regulations CNSC Cost Recovery Fees Regulations

Some of the relevant CNSC’s statutory requirements and policies for decommissioning are listed below:

Table 2.2: CNSC Regulatory Guides/Policies for Decommissioning Guides/Policy No. Guides/Policy RESPONSIBLE AGENCY

G-206 Regulatory Guide for Financial Guarantee Guide for the Decommissioning of Licensed Activities;

Regulatory Objectives, Requirements and R-104 Guidelines for the Disposal of Radioactive Wastes – Long Term Aspects (June 1987) Radiation Protection Requisites for the Exemption of Certain Radioactive Materials R-85 from Further Licensing Upon Transferred for Disposal (August 1989) CNSC Regulatory Policy for Protection of the P-223 Environment Regulatory Guide for Assessing the Long Term G-320 Safety of Radioactive Waste Management Regulatory Guide for Decommissioning G-219 Planning for Licensed Activities Regulatory Document for Management of RD/GD-370 Uranium Mine Waste Rock and Mill Tailings Regulatory policy for Managing Radioactive P-290 Waste

The Canadian Environmental Assessment Agency is responsible for the Canadian Environmental

Assessment Act, 2012 (CEAA 2012). It sets out the duties and procedures the environmental assessment of projects involving the federal government. The CNSC is required by the CEAA and its Regulations to conduct environmental assessments before proceeding with its licence process. When a decommissioning plan is received, specific conditions of the CEAA require

regulators to conduct a Comprehensive Study of the initiative. Upon completion of the

Comprehensive Study, the CEAA administers a formal public review of the study and makes recommendations to its federal Minister on the findings. The Minister’s response to these findings is forwarded to the CNSC. The CNSC cannot make any irrevocable decisions which would allow the project to proceed until the environmental assessment process is complete.

Some of the regulations under CEAA 2012 are listed below:

Table 2.3: Canadian Environmental Assessment Act ACT REGULATIONS RESPONSIBLE AGENCY Regulations Designating Physical Activities Canadian Environmental Prescribed Information for the Description of a Canadian Assessment Act, 2012 Designated Project Regulations Environmental Agency (CEAA 2012) Cost Recovery Regulations

Other Federal Legislative Requirements

Listed below are few federal legislative requirements associated with decommissioning activities and they are listed below.

Table 2.4: Federal Legislative Requirements ACT REGULATIONS RESPONSIBLE AGENCY Ministry of Fisheries Fisheries Act Metal Mining Effluent Regulations (MMER) & Oceans Canada Navigable Waters Ministry of Transport Protection Program Navigation Protection Act

2.1.2 Provincial Regulation

The Ministry of Environment, Government of Saskatchewan is the responsible provincial regulatory agency for any decommissioning activities within the province. The Ministry of

Environment is provincial regulator responsible for environmental protection, provide environmental regulations of all mining activities and develops legislation and guidelines for the province of Saskatchewan. There are two provincial acts and regulations related to decommissioning of the AGTMF in the province of Saskatchewan. These are found in the

Guidelines for Northern Mine Decommissioning and Reclamation, Nov 30, 2008 (Version 6)

EPB 381 and are summarised below:

Table 2.5: Saskatchewan Legislation ACT REGULATIONS/GUIDELINES RESPONSIBLE AGENCY Project Specific Guidelines for the Preparation of an Ministry of Environmental Environmental Impact Assessment (EIA) Environmental Environment , Assessment Act Impact Statement (EIS) Saskatchewan Unauthorised Discharges and Environmentally Impacted Sites (Unauthorized Discharges and Obligation to Report, Site Assessment Corrective Action Plan, Registry of Environmentally Impacted Sites) Environmental General Rules Respecting Permits, Environmental Ministry of Management and Environment , Protection Plans and Notices Protection Act, (2010) Saskatchewan Protection of Water - Aquatic Habitat Protection Permit Waste Management (Beverage Container Program; Stewardship Programs; Solid and Liquid Waste Management) Air Quality Regulations for Construction, ETC, of Pollutant Control Ministry of Facility Ministry of Environmental Regulations for Operation of Pollutant Control Facility Environment , Protection Saskatchewan Regulations, 1996 Regulations for Temporary Closure of Pollutant control Facility

Regulations for Decommissioning and Reclamation Plan and Assurance Fund Regulations for Review, Revision and Use of Plan and Fund Regulations for Exploration The Hazardous Regulations to remove, abandon, dispose, or Substances and Waste permanently close any storage facility for hazardous Ministry of Dangerous Goods substance and waste dangerous goods. Environment , Regulations Saskatchewan (HSWDGR) Supervision of Workers General Safety Requirements Design of Mines, Underground Mines, Open Pit Mines, Work Practices and Procedures Shaft-Sinking Operations Shaft Safety and Shaft Inspections Hoist and Hoisting The Occupational Storage, Transportation and Use of Explosives Ministry of Health and Safety Act Lung Function Tests Environment , 1993, (The Mines Saskatchewan Regulations 2003) Lighting in Mines Air Quality and Ventilation Underground at a Mine Haulage Use of Diesel Engines Underground Fire Prevention and Control Control of Underground Water Emergency Response and Mine Rescue Underground at a Mine Abandoning Workings Repeal and Coming into Force The Reclaimed Industrial Sites Act - An Act respecting the Monitoring and Maintenance of Industrial Sites after Reclamation- Chapter R-4.21 of The Statutes of Reclaimed Industrial Saskatchewan, 2006 (effective March 1, 2007), as Ministry of Sites Act and The amended by the Statutes of Saskatchewan, 2014, c.E- Environment , Reclaimed Industrial Saskatchewan Sites Regulations 13.1. The Reclaimed Industrial Sites Regulations - Chapter R- 4.21 Reg 1 (effective March 21, 2007) as amended by Saskatchewan Regulations 109/2010.

2.1.3 Decommissioning and Licensing Process for AGTMF

Figure 2.2: Flow Diagram for Decommissioning & Licensing Process for AGTMF

Cameco is required by law, during all phases of the operation, to plan for and commit to decommissioning and to provide sufficient information to satisfy the CNSC that the AGTMF can be decommissioned effectively. The long term objective of in-situ decommissioning of the

AGTMF is to leave the AGTMF in a state that is physically safe and provides secure, long term storage of the tailings with no unacceptable predicted future environmental impacts. As a 27

requirement by law, Cameco will be required to follow the steps presented in Fig 2.2 above for the decommissioning and licensing process for the AGTMF.

Conceptual Decommissioning Plan – Cameco will submit a conceptual decommissioning plan, which is a general, all-encompassing design for the decommissioning and reclamation of the

AGTMF and must consider all past and current activities related to the AGTMF. The decommissioning plan will provide all details of the proposed decommissioning activities for the

AGTMF and will have to demonstrate that it is technically feasible and environmentally acceptable to decommission. The plan will have a schedule to carry out the decommissioning activities.

Financial Assurance for Decommissioning – Cameco will require to estimate the cost to implement the decommissioning plan based on the selected decommissioning option and commit a financial assurance to implement the approved decommissioning plans.

Environmental Assessment – CCEAA require CNSC to conduct or request and environmental assessment in the form of comprehensive study of the final decommissioning proposal. The environmental assessment will provide the associated environmental impacts and identifies any mitigative measures for the in-situ decommissioning of the AGTMF. The environmental assessment process will include inputs from all stakeholders, including federal and provincial regulators; Environmental Quality Committees (comprising of stakeholders from local communities, environmental interest groups; and Cameco).

CNSC Review – CNSC together with other responsible federal agencies such as Department of

Fisheries and Oceans, and Environmental Canada will review the environmental assessment.

Saskatchewan Environment will conduct a comprehensive review as part of their licensing process for the AGTMF decommissioning. Once all the regulatory concerns and comments are addressed, the final decommissioning plan will be developed by Cameco and submitted with the decommissioning licence application. The final decommissioning plan for the AGTMF will encompass specific details on engineering, quality control and monitoring issues and will include an assessment of the short and long term environmental impact of the decommissioning of

AGTMF, post- decommissioning environmental quality criteria, a risk analysis and the various institutional controls. If it is accepted, then a license is issued to decommission the AGTMF based on the approved decommissioning plan.

2.2 Types of Decommissioning for Above Ground Tailings Management Facility

Decommissioning of the tailings management facility is a key environmental concern associated with uranium milling and mining. The tailings are a source of radiological and hazardous materials requiring isolation from the environment with a goal to minimize the need for ongoing active management or maintenance. The CNSC regulatory document G-320 (Assessing the

Long-Term Safety of Radioactive Waste Management) and Draft IAEA document DS355 Safety

Case and Safety Assessment for Radioactive Waste Disposal, both recommend that management options should be selected with minimal institutional control.

2.2.1 Decommissioning Options for AGTMF

Several decommissioning options are practiced widely for decommissioning an uranium mill and mining tailings management facilities and some of them included relocation of the tailings to a pit/engineered disposal cells, reprocessing of the tailings and decommissioning in place. The

widely practiced decommissioning options for tailings management facilities are presented in

Table 2.6 and the pros and cons for the different options are presented in Table 2.7.

a. Decommissioning by Relocation of Mill & Mine Tailings

The relocation of mill and mine tailings from its current location to an engineered disposal cells, an underground caverns or remote locations or moving into worked-out open mine pits are few other methods of decommissioning by relocation. By moving the mill and mine tailings from its current’s location and disposing them to new locations elsewhere creates a new set of issues with regard to contamination and pollutions and therefore not reckoned as not a permanent solution.

b. Decommissioning by Reprocessing of Mill & Mine Tailings

Reprocessing of mill and mine tailings is a viable option as mining techniques improve and ultimately result in better rates of return on metals that are recovered. By reprocessing, additional minerals are recovered from the tailings which was once considered waste. The waste tailings that were once considered of no economic value can be reprocessed to recover minerals followed by permanent disposal of the remaining waste. At the Kaltails project, Kalgoorlie, Western

Australia, the tailings dumps from the Boulder and Lakewood areas were hydraulically mined, re-processed and stored in an engineered impoundment located 10 km south of Kalgoorlie.

Approximately 60 million tonnes of tailings was moved and 695,000 ounces of the gold was recovered (Kaltails, 1998). Reprocessing of the tailings for mineral recovery appears to be economically unattractive under the present market conditions for commodities prices however when the spot prices of the commodities improves reprocessing might be economically attractive.

c. Decommissioning in Place

This is one of most preferred options however this should be only based on detailed technical studies including the hydrological, hydrogeological characteristics and contaminant transport modelling. This decommissioning process involves placement of an adequate cover/engineered cover on top of the tailings. This cover will provide a protective barrier for reducing radon gas migration and a physical barrier eliminating access to the mill tailings for an extended period of time. A tailings cover consist of a thick zone of low-permeability material may control or reduces the amount of contaminants that may leach into the groundwater.

Table 2.6 Decommissioning Options for Tailings

Environmental Options Method Example Concerns

Relocation of Moab uranium mill tailings pile Water contamination / By moving the mill and mine (10.8 M tonnes) by rail to Radon inhalation; tailings from its current’s an engineered disposal cell Relocation external radiation; location and disposing them constructed at Crescent incorporation of to new locations elsewhere. Junction, Utah, about 30 contaminants miles from the Moab tailings pile. Impact on groundwater The Cooke tailings dump however the and the Cooke 1, 2 and 3 Reprocess the mill and mine concentration of mines of Rand Uranium tailings to extract Reprocessing contaminants is (South Africa) plans to recoverable minerals present diminished from the recover uranium, gold and in the tailings. tailings by extracting the sulphur from the tailings recoverable minerals. dump. A cover is designed to be placed over the tailings to Example for Dry In-situ minimize both radon Homestake Mining exhalation and the Impact on groundwater/ Company - New Mexico – infiltration of precipitation. radon inhalation; USA In-situ Two Methods include: external radiation; Example for Wet In-situ

a. Dry in-situ stabilisation incorporation of Denison TMA: Elliot Lake- (slimes dewatering, capping, contaminants. Ontario, Canada water treatment) b. Wet in-situ stabilization

Table 2.7 Comparison of Decommissioning Options

Options Pros Cons

Most expensive option - High cost for transportation of the tailings and for designing and constructing an engineered disposal cell that is environmentally robust.

Elimination of the need for perpetual The relocation requires separate care. disposal of more hazardous waste in

Relocation addition to potential occupational Enhanced level of security regarding exposures during excavations. environmental protection. By moving the mill and mine tailings from its current’s location and disposing them to new locations elsewhere creates a new set of issues with regard to contamination and pollutions.

Able to extract recoverable minerals Highly expensive for reprocessing. Not present in the tailings that was sustainable for current commodities considered of no economic value. market’s spot price. Reprocessing

Reduces the contaminants in tailings Still has to contain the tailings after the after extraction of recoverable minerals. recoverable minerals are extracted.

Comparatively less expensive than the The need of expensive geotechnical and above two options mentioned. hydrogeological investigations to design No new footprint and is no larger than and select an adequate cover and design what is currently there. monitoring wells.

Better option environmentally for The need for perpetual care related containment of the pollution within the monitoring and maintenance – With regard existing contaminated site. to the collection and treatment of In-situ Better option to minimize both radon contaminated water as well as maintenance exhalation and the infiltration of of the soil covers, surface water drainage precipitation. channels, dewatering system, monitoring

wells need to be maintained for hundreds of Borrow materials for cover is easily years. available within the vicinity.

Limits the exposure to oxidation of the This has become a significant burden i.e., tailings and prevent their escape to the the long term operation and maintenance of environment. seepage intercepts and water treatment

systems.

Minimizing seepage of contaminated water from the tailings storage facility to surface and groundwater.

Provides a stabilized surface cover to prevent erosion from tailings storage facility.

2.2.2 In-situ Decommissioning - Experiences of Cover Capping

In-situ decommissioning of uranium mill and mine tailings, capping is the preferred method of choice in United States and Canada as it outweighs other options in terms of cost and practicality to provide isolation and control of radiological, oxidation, and/or leaching effects explained in

Table 2.7. There are many examples to demonstrate capping using either dry in-situ stabilization or wet in-situ stabilization for uranium mill and mining tailings. Some of the examples are presented in Table 2.8.

Dry In-situ Stabilization – A typical dry cover is constructed over the tailings to prevent dust migration and physical access to the tailings body. Generally the placement of a dry cover over the uranium tailings will vary for each site and a cover needs to be developed based on site specific performance criteria. It is influenced by potential risk of environmental contamination

(management of contaminated pore water and surface water drainage over the cover) and geotechnical conditions (consolidation, stability, thawing and, long term settlement of tailings).

The cost and availability of materials used for capping is critical too. A dry cover placement generally consist of a multi-layer system and has two construction phases for stabilization and covering of tailings. An interim cover usually consist of mine waste rock thickness varying from

1m-2m is placed over the tailings. The final cover is placed over the interim cover after the consolidation of the tailings.

Homestake Mining Company in United States where both large tailing and small tailings bodies are capped with an interim soil cover consisting of clayey, sandy clays and clayey sands. This is overlain with the placement of a radon cover of 1’ - 3.8’thickness generally classified as clayey sands and sandy clay placed after flushing the tailings with water (Arcadis, 2013). In Germany dry soil cover of thickness 1m was placed over the uranium tailings at IAA Helmadorf and IAA

Culmltzach A uranium mill tailings facility (Jakubick and Hager, 1998). At Eagle Mine

Superfund Site, in Colorado, a dry multi-layer cover placement of thickness 0.6 m – 4 m was placed over the fine uranium mill tailings (Neukrichner & Lord, 1998). In Canada, the tailings management area at Cluff Lake was decommissioned by covering 2.6 M tonnes of tailings material with a minimum 1m glacial till cover in 2006. Similarly tailings at Stanrock & Can-

Met, Elliot Lake, Ontario, Canada was decommissioned using dry cover of acid depleted tailings over the saturated tailings.

Wet In-situ Stabilization – Wet (water) covers are generally used when the tailings are potentially acid generating. Caution must be exercised for selection of wet covers as they are not suitable if water cover would result in too much of contaminated seepage or when the embankments are not stable and/or could not be economically stabilized and when water balance for water cover cannot be sustained (Christopher, Andrew & Alex). The tailings are submerged under water by flooding the tailings impoundment or by relocating the tailings to an abandoned open mine pit and flooding it. It significantly reduces the potential for air to move into the tailings and protects against oxidation of the tailings (Dave et al, 1997).

Rio Algom Limited’s preferred option was to use a water cover of minimum 0.6 m over the 62

M tonnes of tailings stored at Quirke WMA (waste management area) and Panel WMA of Elliot

Lake, Ontario. This option of water cover was considered based on the saturation of wastes, climate and, limited availability of impervious material in the vicinity. The water cover was a barrier to radioactive emissions and eliminates dust emissions from surface to the tailings. A minimum water cover of 0.9m over the 63 M tonnes of tailings was the preferred option used at

Denison Mines Elliot Lake, Ontario.

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 1 of 6)

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 2 of 6)

Decommissioned Tailings Management Facility by Cover Capping Height Quantity Area Operations Decommission Other Decommissioning/Monitoring Name of Mines Background Tailings Tailing Decommission Method References Methodologies Used/Current Status Acres Ft Tonnes/M From To From To Arco Uranium New Mexico -USA Arco encapsulated both the tailings area. The cover Radioactive tailings the main tailings disposal cell is a two layer system predominantly consisting of designed to encapsulate and protect the sandy material from acid contaminated materials. leaching and carbonate- Acid Tailings 354 NA 23 M 1957 1982 1989 1995 The cover consists of a low permeability radon License terminated in 1997 http://www.lm.doe.gov/Bluewater/bluewater- leach tailings which were barrier ( first layer of 1.7' - 2.6' thick radon barrier Site under DOE long-term care/custody factsheet.pdf deposited at two different placed over the compacted contaminated sandy mill locations to avoid any tailings). overlain by topsoil that was seeded with chemical reactions from native grasses, and a 4' - 12 " thick riprap erosion occurring. Carbonate Tailings 54 NA 1.3 M 1957 1982 1989 1995 protection layer over entire disposal cell.

Rio Algom-Ambrosia Lake Disposal of tailings The initiation began in 1989 the consolidating the top generated during uranium surface of the tailings. Both mill tailings ponds were ore processing operations. covered with final radon barriers in 1995 and 1996. http://www.nrc.gov/info- A portion of Pond was 260 NA 30 M 1958 2002 1989 1995 The most significant geotechnical issue for long-term License terminated in 2011 finder/decommissioning/uranium/rio-algom- used for by-product stability of the disposal cell would be settlement of ambrosia-lake.html material disposal. the materials which could potentially affect the Pond I integrity of the cover. Pond 2 90 35' 3M 1958 2002 1989 1996 Cluff Lake TMA -Saskatchewan, Canada

Decommissioning the TMA area involved the following primary work items (Gerry & Bob 2004): • Covering all tailings materials with a minimum 1m Tailings and contaminated glacial till cover http://ceaa.gc.ca/41B79974-docs/report_e.pdf Tailings water generated during the • Backfilling the Liquids Pond Institutional care in place. Management Area operational life of the Mine 2.6 M 1980 2002 2004 2006 • Buttressing the main dam (TMA) and Mill are held behind an • Construction of storm water management earthen dam. structures • Removal of buildings and surface infrastructure, and • Revegetation

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 3 of 6)

Tailings and contaminated Decommissioning the WMA area involved the water generated during the following primary work items: 1956 1961 Quirke WMA operational life of the 781 46 M 1990 2000 • Covering tailings with a minimum water cover of 1968 1990 The water cover will require long-term Canadian Environmental Assessment Agency, Mines and Mills were held 0.6 m over the tailing was the preferred option as monitoring and maintenance to ensure 1996. Area - Report of the Environmental in the WMA this suited for the climate of Northern Ontario, most the continued viability and safety of the Assessment Panel on Decommissioning of the wastes were saturated and the availability of WMA. Uranium Mine Tailings Management Areas in impervious materials in the immediate vicinity was the Elliot Lake limited. Additionally the water cover act as a barrier to radioactive emissions and eliminates dust Tailings and contaminated emissions from the surface to the tailings. water generated during the 1958 1961 Panel WMA operational life of the 304 16 M 1990 2000 1979 1990 Mines and Mills were held in the WMA. Elliot Lake Denison Mines -Ontario, Canada Decommissioning the TMA area involved the following primary work items: Tailings and contaminated Canadian Environmental Assessment Agency, • Covering tailings with a minimum water cover of water generated during the The tailings are on long-term care and 1996. Area - Report of the Environmental 0.9 m over the tailing was the preferred option as Denison TMA operational life of the 638 63 M 1957 1992 1990 2000 maintenance and will continue to be into Assessment Panel on Decommissioning of this suited for the climate of Northern Ontario, most Mines and Mills were held the future. Uranium Mine Tailings Management Areas in the wastes were saturated and the availability of in the TMA the Elliot Lake impervious materials in the immediate vicinity was limited. Tailings and contaminated Canadian Environmental Assessment Agency, Decommissioning the TMA area involved the water generated during the The tailings are on long-term care and 1996. Area - Report of the Environmental Stanrock & Can- following primary work items: operational life of the 128 5.7 M 1957 1964 1990 2000 maintenance and will continue to be into Assessment Panel on Decommissioning of Met • Using a dry cover of acid depleted tailings Mines and Mills were held the future. Uranium Mine Tailings Management Areas in overlying the saturated tailings. in the WMA the Elliot Lake

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 4 of 6)

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 5 of 6)

Beaverlodge Uranium Mine, Uranium City , Canada Disposal of tailings generated The initiation began in 1989 the consolidating the top during uranium ore processing surface of the tailings. Both mill tailings ponds were operations. 3 Tailings covered with final radon barriers in 1995 and 1996. 1. Tailings Disposed in TMA - Site under monitoring and maintenance http://ccsn.gc.ca/pubs_catalogue/uploads/joint_c Management Area NA NA 5.8 M 1950 1982 1982 1985 The most significant geotechnical issue for long-term 5.8 M phase. onvention_2009_third_national_report_e.pdf (TMA) stability of the disposal cell would be settlement of 2. Tailings disposed underground - the materials which could potentially affect the 4.3 M integrity of the cover.

Gunnar and Lorado Mines, Saskatchewan

Mill tailings were originally discharged from the mill at 32% solids through a 1,500 ft. Long, 10 in. diameter wooden stave pipe. In total, it has been Gunnar Main Plans to install an appropriate cover on the exposed http://www.src.sk.ca/resource%20files/gunn estimated that the Gunnar Mining 40 46 4.4 M 1955 1963 2010 Contd. Site not adequately decommissioned yet Tailings mill tailings and waste rock. ar%20screening%20project%20proposal.pdf Limited mill discharged a total of 4.4 million tonnes of tailings during operations (BBT, 1986).

Mill tailings were originally Nero Lake was treated with lime to reduce the discharged from the mill at 32% acidity of the lake water and cause aluminum solids through a 1,500 ft. Long, hydroxide to precipitate out of the water and settle to 10 in. diameter wooden stave the lake bottom. pipe. In total, it has been 227,000 Construction work began on an engineered sand and The tailings cover must have been http://www.src.sk.ca/about/featured- Nero Lake estimated that the Gunnar Mining 35 1957 1960 2011 Contd. m3 soil tailings cover. completed in 2015. projects/pages/lorado-mill-site.aspx Limited mill discharged a total of This will reduce the radiation exposure risk and stop 4.4 million tonnes of tailings run-off flowing over the tailings surface and into during operations Nero Lake. (BBT, 1986).

Table 2.8 Decommissioned Tailings Management Facility by Cover Capping (Page 6 of 6)

Decommissioned Tailings Management Facility by Cover Capping Height Quantity Area Operations Decommission Other Tailings Tailing Decommissioning/Monitoring Name of Mines Background Decommission Method References Methodologies Used/Current Acres Ft Tonnes/M From To From To Status

Gunnar and Lorado Mines, Saskatchewan Mill tailings were originally discharged from the mill at 32% solids through a 1,500 ft. Long, 10 in. diameter wooden stave pipe. In total, it has been http://www.src.sk.ca/resource%20files/g Gunnar Main Plans to install an appropriate cover on the exposed Site not adequately decommissioned estimated that the Gunnar Mining 40 46 4.4 M 1955 1963 2010 Contd. unnar%20screening%20project%20propos Tailings mill tailings and waste rock. yet Limited mill discharged a total of al.pdf 4.4 million tonnes of tailings during operations (BBT, 1986).

Cameco Rabbit Lake Mine - Above Ground Tailings Management Facility

A staged approach of decommissioning of the The cover has been designed not This AGTMF was designed to facility was developed by O'Kane Consultants in only to provide generic physically contain the tailings 2012. An engineered cover of 1 m and a layer of environmental and radiation https://www.cameco.com/sustainable_d solids between two constructed glacial till has been placed over southern portion of protection, but also to promote evelopment/2014/clean- Above Ground dams, the north dam and south the above ground tailings facility, again to better consolidation of the tailings mass. environment/waste/case-study Tailings dam with natural ridges providing 131 NA 6.5 M 1975 1985 1992 2012 store and release surface runoff and reduce Waste rock is being used in the Management containment on the east and groundwater infiltration. This 1 m thick till cover will cover to provide geometric shaping Facility west sides of the facilty. Used reduce the infiltration from 160 mm/yr to 85 mm/yr. and pre-loading to accelerate for storage of contaminated The tailings in northern portion will be covered with normal waste from Mill and Mine. 30 cm till cover which will reduce the infiltration by consolidation processes and Cameco, 2012. Assessment of Rabbit Lake 40%. minimize future settling. AGTMF Decommissioning on Weir 3 Effluent Loadings Interoffice Memo Dated Dec 21, 2012

2.2.3 Decommissioning Options Selected for AGTMF at Key Lake Operation

Cameco’s Preliminary Decommissioning Plan 2008 – Final Report discusses that the AGTMF has been the subject of a number of studies in the past by Cameco. Most of the decommissioning studies have focussed on baseline hydrogeological conditions, long-term pore water (seepage) quality, the modelling of various capping scenarios, groundwater modelling for groundwater flow and transport modelling, impact of seepage on surface water, cover design and decommissioning and groundwater monitoring and contingency plan. Several decommissioning strategies were considered for the decommissioning of the AGTMF which has been the subject of a number of studies. Based on the evaluations, Cameco preferred two options for the decommissioning of the AGTMF and they were reprocessing of the tailings and in-situ decommissioning.

i) Reprocess of tailings within AGTMF

The reprocessing of the tailings includes mining of the tailings deposited at AGTMF to

recover (nickel (Ni), cobalt (Co) and copper (Cu) contained within the tailings. These are

elements of economic value. The proposed plan is to process the tailings from the AGTMF

through a Ni/Co recovery circuit. The resulting tailings from this process will be disposed

in the existing engineered Deilmann In-Pit Tailings Management Facility (DTMF) or be

deposited in a purpose built in-pit tailings management facility. The separate disposal of

more hazardous waste in addition to potential occupational exposures during excavations

and re-processing the tailings leads to substantial costs and relocating the waste moves the

problem to a new area. This option is driven by cost/ benefit economics. Initial studies

indicate that this option was not technically and economically feasible. ii) In-situ decommissioning with a cover system over the AGTMF tailings.

Cameco carried out an extensive tailings research program at Key Lake AGTMF to

evaluate the cover design and decommissioning options (Cameco, 1991). The following

options were investigated:

i) Engineered cover - No preliminary measures prior to installing the cover,

ii) Engineered cover – Active Thawing of Frozen Tailing Using Warm-Water

Injection to enhance consolidation (prior to installation of the cover),

iii) Relocation of Tailings – Engineered Cover on Suitable Replacement Fill.

Based on the research it was understood that complete active thawing of ice lens within the

tailings is a prerequisite to allow full control of tailings consolidation prior to cover

placement at the time of decommissioning.

Some of the close-out criteria (mentioned below a to j) for decommissioning the AGTMF

during the design stage are compiled in Knight & Piesold’s Design Report (1981) and

further a couple of additional design objectives (k to m) were added on in Moffet report for

Saskatchewan Environment and Public Safety 1991. They are summarised as follows:

a) Use only passive or natural barriers

b) Limit surface water recharge to direct natural precipitation (no ponding)

c) Design for maximum long-term durability and minimum maintenance

d) Provide long-term performance and economic guarantees

e) Limit access to closed-out site

f) Control releases of seepage to less than those experienced during operation phase.

g) Reduce radon emanation through the cover to less than 2 to 10 pCi/m2-sec.

h) Maintain gamma radiation at less than 10 to 50 uR/hr at 1 m above cover surface.

i) Avoid particulate emissions originating from the cover

j) Perform detailed pathway analysis for closed-out site.

k) Achieve a stable moisture regime throughout the full depth of tailings prior to

decommissioning.

l) Limit leachate generation to that resulting from infiltration (long-term infiltration

should be less than 5% of average annual precipitation).

m) Ensure that primary settlement is complete within two to five years after

decommissioning.

The above mentioned criteria is incorporated into the final decommissioning design objectives of AGTMF. An evaluation of the following alternatives for engineering covers were investigated by O’Kane Consultants Inc. in 2007 and they include the following options:

i) No cover – No Special Measures

ii) Engineered Cover – 1.0 m till, vegetated

iii) Engineered cover – 1.5 m till, non-vegetated

iv) Engineered Cover – 1.5 m till, vegetated

v) Engineered Cover – 0.5 m waste rock, 1.0 m till, vegetated

vi) Engineered Cover – Geosynthetic Clay Liner, 1.5 m till, vegetated

vii) Engineered Cover – 0.7 m waste rock, 0.3 compacted till-bentonite, 1.0 m till,

vegetated.

The latest cover system proposed for AGTMF is an in-situ decommissioning technology that included consolidation of the tailings which will be encapsulated by placing an engineered cap over the tailings body. Based on O’Kane’s evaluation of the above alternatives and assuming it is pertinent to carry out active thawing as part of the decommissioning for consolidation of the tailings, the following cover design was recommended as illustrated in Figure 3 below.

The above cover as proposed by O’ Kane Consultant Inc 2007 will ensure prevention of the release of radon gas and gamma radiation to the atmosphere, the infiltration of precipitation and subsequent leaching of the tailings and transport of elements of concern to groundwater, and the transport of waste materials to surface water through runoff. The proposed engineered cap will direct surface runoff away from the tailings mass to reduce infiltration rates and reduce the environmental risk of transport of elements of concern from the tailings to the regional biota.

Cameco Corporation proposed this preferred option of in-situ decommissioning of the

AGTMF with a dry cover system to the Saskatchewan Ministry of Environment (SMOE).

Figure 2.3: Proposed AGTMF Cover Design

Vegetation -Native Grass & Legume

Growth Medium/Moisture Store and Release Layer Silty-Sand Till (1.5 m)

Geosynthetic Clay Liner (GCL) GCL Support Layer Outwash Sand (0.3 m)

Tailings

The proposed In-situ decommissioning plan encompass the following goals:

i. to produce a fully consolidated tailings mass (including a rigorous thawing

program to melt ice lenses within the tailings mass),

ii. to cap the tailings mass to reduce water infiltration,

iii. to meet both federal and provincial regulatory requirements with respect to

containment and reducing the risk of contaminant migration from

decommissioned tailings system.

Decommissioning Framework

This chapter presents a set of processes in the decommissioning framework that will aid for performing the various tasks associated with the in-situ decommissioning of AGTMF. Following the cessation of operations and decommissioning have to be planned carefully because if anything goes wrong it can be more costly and difficult to fix it than doing it successfully in the first place.

The decommissioning process are broadly classified under three categories, namely technical, operational and project management.

3.1 Technical Related Process in Decommissioning

3.1.1 Characterization of the Tailings

The characterization of the tailings at the AGTMF includes the seepage samples and stabilization/consolidation of tailings and this will involve investigating and monitoring subsurface to characterise and remediate sub surface land as part of decommissioning and remediation. Few tasks identified and not discussed in detail herein are:

 Characterize the physical and geochemical properties of the tailings as they relate to long-

term management of decommissioning of the AGTMF.

 Assess the decommissioning options based on the characterization of the tailings and

choose the preferred decommissioning option.

 Characterization of the tailings will help in the design and construction of the preferred

decommissioning option.

Some of the general characterization of the AGTMF tailings are presented below in Tables 3.1 to

3.3. The information for these tables were collected from Cameco Geo-Environmental

Department.

The general geotechnical tailings characteristics of the AGTMF tailings are summarised in Table

3.1 below. Generally the tailings are very fine-grained in both east and west cells of the AGTMF however there is an indication that the tailings are finer at lower elevation in the east cell and the tailings are coarser in the west cell at lower elevation. The installation of the divider berm in 1992 would have limited the lateral flow distance of tailings during deposition, thus limited the potential for segregation.

Table 3.1 General Geotechnical Tailing Properties

General Geotechnical Characteristics of the AGTMF Tailings

AGTMF Areas Particles Average Tailings Samples Tailings East/West Elevations Size Passing Analysed Grain Size Cell (mm) %

Very Fined Upper 0.425 92% Grained East Cell 56 Lower Finer 0.038 66%

Very Fined Upper 0.425 88% Grained West Cell 35 Lower Coarser 0.038 44%

Table 3.2 below presents the general mineralogy of the tailings of the AGTMF.

Table 3.2 Overall Tailings Mineralogy

Overall Tailings Mineralogy

Abundance Minerals % weight Quartz 56-72 Gypsum 11-22 Chlorite 5-10 Illite 2-7 Kaolinite 2-9 Ettringite 3.7-18 Iron Oxyhydroxides 3.2-4.1 Carbonates 2.3-5 Accessory Minerals (<2%) included trace metal sulphides, arsenides, arsenates, barite.

The importance of characterization of the tailings is to provide the measures to prevent and/or mitigate the potentially adverse effects of tailings on the receiving environment to safeguard human and environment health and safety during the decommissioning operations and long-term closure of the tailings management facility. Table 3.3 below presents the general characteristics of the tailings solids at AGTMF.

Table 3.3 Characteristics of the Tailings Solids

Tailings Solids Characteristics from Gaertner & Deilmann Pits

Below 542 m Above 542 m Parameter Units Gaertner Ore Deilmann Ore Aluminum mg/kg 39556 48992 Arsenic mg/kg 9748 7122 Barium mg/kg 174 92 Beryllium mg/kg 9.4 9 Boron mg/kg 134 210 Cadmium mg/kg 1.9 1 Calcium mg/kg 79311 56077 Chromium mg/kg 42 65 Cobalt mg/kg 683 671 Copper mg/kg 407 485 Iron mg/kg 11691 14138 Lead mg/kg 1561 1535 Magnesium mg/kg 12022 16054 Manganese mg/kg 159 117 Molybdenum mg/kg 31 132 Nickel mg/kg 14642 5554 Phosphorus mg/kg 386 376 Potassium mg/kg 2822 5477 Silver mg/kg 5.2 3.4 Sodium mg/kg 312 652 Strontium mg/kg 206 184 Titanium mg/kg 133 156 Vanadium mg/kg 326 339 Zinc mg/kg 770 356 Zirconium mg/kg 44 60 Mercury mg/kg 0.085 0.09 Selenium mg/kg 27 23

3.1.2 Delineation of the Radioactivity Tailings

For the delineation, a thorough understanding of the contamination from the mill tailings and their radioactive nature need to be assessed through extensive gamma surveys and soil sampling. A database will be required to be developed to assist data analysis and improve overall data management of the gamma surveys and soil samples. Based on the results of field gamma surveys and soil sampling data, the areas of contaminant concentrations could be delineated and this will aid in determining an effective solution in capping these contaminants. Some of the data will include:

 Field gamma survey data and soil sampling data

 Samples collected initially for background baseline.

 Any samples or gamma survey data collected from 1997 (when the mill tailings deposition

at the AGTMG ceased) to the year of decommissioning.

The above data will allow an examination of the historical soil sampling results collected to support the gamma correlation and background assessments evaluation in the development of the gamma guideline value to aid in the site characterization and on the selection of the best physical cover for the AGTMF and institutional controls.

3.1.3 Contamination from the Tailings

The contamination occurs in an uranium tailings management facility mainly through five pathways; radon inhalation, dust migration, surface water runoff, ground seepage into aquifers, and radioactivity absorbed in food chain, IAEA-TECDOC-1403, 2004. The environmental

problems associated with tailings are radon emanation, leaching of contaminants, including radionuclides, heavy metals and arsenic, into surface water and ground water. The exposure pathways for health and environmental risk of uranium mill tailings, the pathways, causes, impacts and relevance to AGTMF in terms of its hazards and risk is listed below in Table. 3.4.

Table 3.4 Exposure Pathways of AGTMF Uranium Mill Tailings

Exposure Relevance to AGTMF Description of Exposure Potential Impacts Pathways Hazardous Risk Tailings materials Diffusion of When tailings are used as Breathing Radon Gas never been used for NO Radon gas (air) construction materials/backfill. Develops Lung Cancer construction materials - No hazard Inhaling & Ingesting the Diffusion of radon gas and blown radon Radon gas emanating from Radon gas (air) & particles from the Tailing Hazardous Medium to High tailing into the atmosphere. particles Piles - Develops Lung Cancer Exposure to gamma Radioactive radiation within the vicinity Gamma radiation from decay Decay of Tailings of tailings - Develops cancer Hazardous Medium to High of radioactive tailing materials. materials induction and cause genetic damages. Inhaling & Ingesting radioactive and toxic materials - Develops internal Carry radioactive and toxic Dispersal of irradiation and/ or chemical materials from the tailings into Hazardous Medium to High Tailings by Wind toxicity to develop the food chain. increased cancer risk, lung cancer, liver damage or kidney damage. Carry radioactive (includes Potential impact to human Adequate seepage radonuclides-radium-226, and animals from drinking collection system in Dispersal of lead-210, uranium) and toxic water contaminated from place at AGTMF for Tailings by Water materials by surface water Low radioactive and toxic collecting the seepage. and Leaching runoff, ground seepage into materials. Develops cancer aquifers used for drinking and organ damages. No Hazard. waters

The effectiveness of any decommissioning options for the AGTMF must ensure curtailing the above mentioned five contamination pathways to mitigate any contamination to the environment.

3.1.4 Recognizing the Unknowns

There exist some unknowns that are critical to the decommissioning of the AGTMF. It is critical to identify the unknowns like the leaking contaminants which has increased concentrations of pH, molybdenum, selenium, Ra226 in the seepage and supernatant at the AGTMF discussed by

Saskatchewan Environmental Society, Comments on Cameco’s Re-Licensing Proposal for Key

Lake, August, 2015. Another unknown is the time required for thawing the frozen tailings within the AGTMF. Identifying the unknowns will be beneficial in designing an adequate decommissioning system and establishing an acceptable monitoring system for post decommissioning at the AGTMF.

3.1.5 Management of Low Level Radioactive Waste (LLRW)

Tailings are historic waste from contaminated residues from mining and milling from Key Lake operational processes and that is currently stored at the AGTMF. These are generally low-level radioactive waste awaiting long-term management for decommissioning. It is therefore pertinent to assess the radioactive nature of the tailing prior to in-situ decommissioning involving the covering for the tailings to reduce acid generation and the release of radiation and radon gas. The management of LLRW contained in these tailings has to be investigated for its detrimental impact on consolidated and permeability of the tailings mass.

3.1.6 Climatic Conditions

The seasonal patterns of the climate should be analysed with respect to soil-water balance study.

The infiltration and soil moisture content of the soil will fluctuate and this could be a challenge for designing the soil cover and often this will depend on the availability of accurate weather data on the temperature and precipitation.

3.1.7 Environmental Issues

The tailings in AGTMF constitute an increasing environmental problem and is one of the greatest potential impact on the natural environment of all the mill and mining activities due to the toxic chemical and radioactive waste that are long lived and low-level radioactive. The environmental impairment/exposure pathways from tailings could be from impact groundwater/ radon inhalation; external radiation and incorporation of contaminants. Radon and radium are two radioactive elements in the tailings that are of particular environmental concern. The tailings therefore pose serious environmental issues and need to be contained in such a manner that the radon and radium are reduced to or as near background levels as can be reasonably achieved. The primary exposure pathways include; external exposure from the tailings and inhalation of the dust particles from the tailings.

During post decommissioning period, institutional continued surveillance and maintenance will be required to evaluate for any environmental impacts and to eliminate/reduce any environmental impacts from the encapsulated AGTMF tailings. Environmental monitoring will be required for contaminant components as well as geotechnical and subsidence parameters during the post decommissioning period and this could be another challenge.

3.1.8 Characterize the Geochemical, Geotechnical, and Hydrogeology

The grain size distribution plays a major role in the physical stability, consolidation and hydraulic properties of the tailings. The geochemical nature of the tailings need to be fully understood. The hydrogeological conditions will have to be studied in detail to understand the downstream impacts from any potential seepage of contaminated water from the base of the AGTMF to downstream receptors like the Wolf Lake and Fox Lake needs assessment for acceptability. Any change in the local hydrology will contribute to change in directions of groundwater flow and needs to be evaluated by adequate modelling techniques.

These above mentioned characteristics of the tailings requires to be evaluated to provide insight for the right engineering solutions for the decommissioning, long term care and maintenance and institutional control with its objective to minimize/reduce environmental impact..

3.2 Operational Related Process

The operational process for in-situ decommissioning the AGTMF include the following:

3.2.1 Radioactive Nature of Tailings

The uranium mill tailings retain the majority of the radioactivity of the ore from they are derived and their radioactivity is very long lived. The levels of radiation present in the tailings will determine how complex and costly the decommissioning program will be. The radioactive nature of tailings offers and constitutes the principal source of hazard to health of these wastes. Exposure of alpha, beta and gamma radiations from mill tailings can all cause cancer or genetic damage through ingestion or breathing. However the major threat to health comes from breathing air

containing radon decay products exposing the lungs and other internal organs to the alpha radiation.

3.2.2 Thawing Process for Consolidation

The frozen tailings within the AGTMF hinders the consolidation process. The stabilization of tailings requires thawing to be carried out at the AGTMF. Sheng etal (1998) presents in their paper that this goal can be achieved if the bearing capacity of the tailings be significantly improved. The consolidation of the tailings mass by eliminating the frozen ice lenses within tailings mass. This is critical and requires to be carried out prior to the final cover placement. This ensures safety to minimise contamination, erosion and radon gas emission. Previous studies undertaken at Key Lake

AGTMF indicates the time frame for completely thawing the frozen tailings in the AGTMF could range from a minimum of 8 years to a maximum of 12 years based on past experience from thawing programs in 1992 and 1993 (Cameco 2008).

3.2.3 Non-Radioactive Nature of Tailings

The highly toxic chemicals and heavy metals offer and constitute the principal source of hazard to health of these tailings stored in the AGTMF. The non-radioactive toxic chemicals such as arsenic, lead, selenium, mercury, sulphates, and nitrates are usually present in the mill tailings. They may contain sulfidic minerals which are prone to generate acid mine drainage. The non-radiological contaminants may cause harm depending on the toxicity of the tailings.

3.2.4 Dusts

The tailings solids as well dusts created from fine grained solid within the AGTMF have the potential to be created during the decommissioning process. The radon emission results from free circulation of air across the tailings and dump surfaces within the AGTMF. The dust dispersion of the tailings has significant health risks and need to be addressed to ensure the dust levels are safe for decommissioning personnel.

3.2.5 Proven Technology and Other Resources

Technological solutions for decommissioning need to be available and affordable. Technologies that ensure safe containment of hazardous material should be sought for decommissioning to prevent environmental disasters barring unpredictable scenarios. Some would think a high cost in technologies could be a barrier but relatively small investment today can prevent future liabilities and environmental losses. High cost may be incurred while applying higher factors of safety in the design of waste covers and hydraulic structures to ensure public safety and environmental impacts. For some instances a strategy of allowing time for radioactive decay reduces the need for costly technologies. It is critical to recognize and define the current status of the facility in terms of its constraints, physical and radiological nature, quantity and toxicity to select the appropriate technological solutions for decommissioning.

3.2.6 Experienced Decommissioning Contractors

Considering the complexity of decommissioning with the hazardous nature of the tailings, the selection of the right workforce and equipment is critical for accomplishing safely the in-situ decommissioning program for the AGTMF. Contractors whose staff lacks expertise and are

inadequately trained and skilled will be a serious concern for managing the health and safety aspects in decommissioning. Financial standing of the contractor will have to be considered during the selection process. It is important to ensure appropriate levels of contractor control, supervision and training are essential.

3.2.7 Protection of Decommissioning Personnel

It is anticipated that lots of activities will be ongoing at the same time especially during decommissioning. The working personnel will be put at a greater risk than during projects with less time pressure and scope of work. Concurrent operations require good management to make sure that the operations cannot interfere with each other, creating conflicts and hazards. The in- situ decommissioning activity provides exposure to significant radiological and chemical toxicity that poses a potential hazard to environment, public health and safety. Therefore it is important to prioritise overall risk management during the whole project.

3.2.8 Pore Fluids.

The contaminated pore seepage emanating from beneath the AGTMF is collected through the toe- drains to the collection well/sump. The contaminated tailing pore fluids are collected at the pumping collector sump in the east side of the AGTMF and the pore fluids transferred to the mill for processing. This will have to be continued through the in-situ decommissioning process and cease only after institutional controls confirm no more pore seepage emanates from beneath the decommissioned AGTMF. This will allow in the dissipation of the excess pore water pressure and promotes consolidation of the tailings during the decommissioning process and post

decommissioning period. Table 3.5 below presents the general characteristics of the porewater at

AGTMF (Cameco, Geo-Environment Department).

Table 3.5 Characteristics of the Porewater

General Porewater Characteristics at AGTMF

Parmeter Units Unsaturated Tailings Saturated Tailings

pH units 7.6 8.1 Eh mV 410 300 Sulfate mg/L 1575 1876 Aluminum mg/L 0.05 0.08 Arsenic mg/L 10.3 4.8 Barium mg/L 0.024 0.04 Cadmium mg/L 0.004 0.002 Calcium mg/L 550 615 Cobalt mg/L 1.2 0.006 Copper mg/L 0.021 0.059 Lead mg/L 0.102 0.01 Molybdenum mg/L 8.9 7.7 Nickel mg/L 2.6 0.082 Selenium mg/L 0.17 0.124 Uranium mg/L 6.49 0.024 Vanadium mg/L 0.078 0.12 Zinc mg/L 0.121 0.174 Radium-226 Bq/L 51 45 Lead-210 Bq/L 2.34 2.28 Polonium-210 Bq/L 0.72 0.58 Thorium-230 Bq/L 0.4 0.48

3.2.9 Funding for Decommissioning

Both the federal and provincial governments have introduced legislation and/or regulations requiring mining companies to provide financial guarantees, prior to mine start-up that will be available to cover the full cost of all decommissioning activities. The financial guarantee is intended to ensure that uranium mine and mill sites can and will be decommissioned at no cost to tax payers. The amount of the financial guarantee required by government is based on the requirements outlined in the conceptual decommissioning plan. The plan is subject to regular review to ensure that it reflects existing site conditions.

3.3 Project Management Process

Some of the project management process identified include the following:

3.3.1 Implement a Project Planning Process

The overall in-situ decommissioning program for the AGTMF will be primarily derived from the mission, corporate objectives, strategy, culture, and policies of the company. That being said the responsibility for putting in place an appropriate management structure and for providing assurance to the corporation and its communities of interest that tailing facilities will be managed and decommissioned responsibly comes from the CEO/COO of the company. In the planning phase the roles and responsibilities, reporting relationship should be assigned as well as the budget authority to decommission the AGTMF. The implementation of project planning process for the in-situ decommissioning program will have to support and take into account the complex nature of decommissioning the AGTMF.

C.R Bayliss & KJ.F Langley, 2003 suggest that this will necessitate a prior rigorous evaluation of what exactly the liabilities are in the decommissioning process to determine the technical, safety, value of money and regulatory aspects of the in-situ decommissioning program. In essence a decommissioning program will have the following four main elements:

a) Program Formulation - Determining long-term what has to be done and laying down the

policies, strategies, and priorities.

b) Developing the program with plans – Putting together the portfolio of tasks that needs

to be accomplished within the given time, funds and resources available.

c) Monitoring and controlling progress and spend – To accommodate the variance from the

budgeted schedule and make the best use of available funds and other resources.

d) Reporting – On the stewardship of funds and on the overall progress with the program.

3.3.2 Selection of viable decommissioning options

The decommissioning options and its selection depends on several factors including proven technology , economic viability, occupational radiation dose to reduce operator exposure, safety and environmental aspects, regulatory acceptance, risk assessment and risk reduction, stakeholder acceptance and institutional controls and their period. According to A.Rahman, 2008, overall decommissioning options to be considered based on stakeholder acceptance including regulatory bodies are listed in Table 3.6.

Table 3.6 Decommission Options

Relevance Option Description Pros Cons to AGTMF (Y/N) May be least acceptable No financial to regulatory authorities Effectively means implication in the (Saskatchewan No Action decommissioning kept in immediate future if Environment & N "Wait & See" abeyance. acceptable by Canadian Nuclear regulatory authorities Safety Commission CNSC) Temporary Process Allows safe storage Safe storage of facility Requires for short periods. Under care and decontamination of Applicable for short maintenance program active components for Safe-Store lived radioisotopes N i.e., facility is placed, short term storage. that will decay and maintained and safely Not a long term allow for the facility secured. solution. to be dismantled later. Not applicable for Applicable for facility that has facility that has short longevity radioisotopes. lived radioisotopes. Entombment structure Encasing and maintaining Lower cost as needs long term the contaminants in a safe decontamination and maintenance. Entomb Y and structurally sound dismantling is Long term surveillance material enclosure. minimized. required. Occupational Ensure during radiation dose is maintenance and care lowest. period it is safely secured.

Complete removal of all radioactive and non- Applicable for those radioactive contaminants short lived and to the required permitted longevity radioactive Decommissioning levels and releasing the High cost implications Y contaminants. site. It may include the Result in permanent safe-storage or solution entombment as the way to achieve decommissioning.

3.3.3 Safety Factors

The radioactive and non-radioactive toxic tailings materials could be hazardous to the decommissioning workers. These have potential health and safety impact to workers or public.

Radon gas and activity of U-238 series nuclides such as thorium-234 and protactinium-234 have some long-term hazard generated from uranium mill tailings that needs to be managed and addressed particularly for safety purposes prior to decommissioning. Therefore a cover needs to be designed for providing maximum protection against gamma radiation is critical. If this is not met the selected option may not be feasible and acceptable.

3.3.4 Develop a Scope Meeting Regulatory and Public Acceptance.

A scope needs to be developed that meets with regulatory and public acceptance is an important project management challenge. Nuclear related decommissioning projects in Canada are regulated by Canadian Nuclear Safety Commission (CNSC), Federal and Provincial regulations, national laws and industry standards as well as that the authorities have to approve the plans.

Application for decommissioning has to be presented to the CNSC, Federal and Provincial agencies for approval where the decommissioning plan for the project is presented. Safety is emphasized especially strongly in the plans, because health, safety, and environment are very important to the authorities. Injuries to personnel and contaminations in any form to the environment are not acceptable. The plans have to be approved before the work can commence.

Regulations concerning how decommissioning operations are supposed to be performed need to be planned and devised for the decommissioning activities for the AGTMF.

3.3.5 Cost Factors

The cost of decommissioning of uranium mill tailings depends on several factors including regulatory standards for protection, quantity of tailings deposited, and type of deposition, type of containment for deposition, climatic factors and type of decommissioning proposed. It is important to have structure/breakdown the costs in cost groups/cost items/cost factors and clearly define the scope of each of these items (WM’99 Conference).

As in the case of AGTMF, the cost is dependent on the remoteness of the area and due to its remoteness the cost of carrying out any construction activities is almost 2- 3 times higher than elsewhere. Furthermore the construction season in areas up north is reduced to 4-5 months every year due to artic winter conditions. Various alternatives must be considered during the early stages of project planning to optimize the design for decommissioning whereby the cost could be significantly reduced.

The AGTMF occupies an area of 128 acres and has about 5.8 M tonnes of uranium mill and mine tailings. By applying the unit cost ranges of decommissioning estimated by Chung.T in 1994 and computing these values to 2016 using Samuel H.W computation method, an attempt is made to present the cost of decommissioning tailings at AGTMF by determining the relative project value ranges in 2016 from the relative project value ranges for tailings decommissioning cost estimated in 1994 and is presented in Table 3.7. The decommissioning cost per ton of tailings for 2016 ranges from $0.85 to $6.43. The total cost for decommissioning 5.8 M tonnes of tailings would be ranging from $4.93 M to $37.29 M. Based on the cost per acre, the cost will range from $13,400 to $140,000 per acre. The total cost of the tailings decommissioning for 128 acres of

decommissioning area is estimated to range from $1.71M to $17.92 M. These estimates only provide a range of decommissioning cost for AGTMF decommissioning and may not be accurate.

This variance in decommissioning cost represents the challenges to cost accurately.

Table 3.7 Cost of Decommissioning Tailings based on Past Project Value

3.3.6 Manage and Obtain Consensus from Various Stakeholders

Meaningful and timely public participation should occur throughout the life cycle of a decommissioning project, so that the public is both informed about and can comment upon any decisions made that could affect the their community (NRC, 2012). All stages of permitting should be transparent advisory reviews and stakeholders entails appropriate consultation with them as they have a significant impact on the decommissioning option and this. Stakeholder’s valuable opinions needs to be assessed for a decommissioning program. Managing and obtaining consensus

from various stakeholders on the approach and requirements for decommissioning the facility is complicated and multifaceted.

The regulatory agencies emphasis on the public involvement in any decommissioning activity and recognizes the opportunities for the communities to make their opinion known whereby it is perceived that their safety concerns can be resolved in timely and practical manner safely. It is important to recognise the requirement to educate the public that the risks associated with decommissioning are manageable and could be mitigated. Gaining their acceptance and consensus becomes instrumental in moving forward with the accepted decommissioning program. Some of the stakeholders identified are regulators (CNSC, Federal, and Provincial Government), local indigenous communities, work-force including contractors, environmental groups, and press/media.

3.3.7 Evaluate Social Attributes to Reassure the Stakeholders

Consulting with communities and taking into account their consideration relating to the tailings facility decommissioning and closure is of prime importance. Engage the stakeholders

(communities mainly) effectively on a continued basis during the decommissioning process to minimise or remove any unacceptable impacts from decommissioning activities. Ensure genuinely how to stop socially and environmentally destructive activities during decommissioning. The engagement of the stakeholder will enable them evaluate how Cameco recognise and takes responsibility for the negative impacts the decommissioning that may have on societies and ecosystems.

This engagement will help them identify and better understand the concerns and expectations from the decommissioning activity. Adequately communicating and teaming with the stakeholders during all the stages of the decommissioning activity on the environmental parameters that cause impacts to factors associated with physical, chemical, biological and social-economic issues.

3.3.8 Implement a Project Schedule

It is critical to have a fully established project schedule based on a work breakdown structure approach as this is one of the most efficient project management tool to monitor the progress of a project from start to end in relation to its scope, cost and schedule as it ties up project resources, costs and task duration simultaneously. Past experiences in executing projects have indicated that the project schedule allows the project manager to quickly identify tasks that need immediate attention and allows the project manager to bring it back into track to ensure the overall success of the project schedule and plan.

According to Colin Bayliss & Kevin Langley, Sept 2003, a decommissioning program should be based upon what needs to be done by a licensee to implement long–term plans and manage its responsibilities in a way which is safe, environmentally sound, economic and publicly acceptable.

This requires prioritising the activities in a way to understand what needs to be done initially, which activities need to be brought forward, which activities can be postponed and which activities can be rescheduled. This requires scheduling based on certain key drivers like safety and security, environmental, regulatory, cost and public acceptability.

Developing procedures for scheduling for the different work break down structures and to sequence the activities requires understanding the complexities of the decommissioning processes.

A project schedule considering the complexity of decommissioning will involve a series of activities, of which some need to be sequential while others could be performed in parallel. Based on dependencies between activities and the duration estimates as project schedule can be developed. The project schedule ties project resources, costs and tasks durations together and becomes most significant management tool to ensure the project arrives at the anticipated end- state, at the anticipated time and for the anticipated cost.

3.3.9 Manage Project Cost and Set Project Controls.

It has been observed from past experiences that cost and schedule has often overrun due to poor and inadequate project cost and schedule controls during decommissioning of a nuclear facilities.

This has given a perception to the stakeholders that the overall process is uncontrollable and unpredictable. Estimating the budget and managing the cost during decommissioning is complex due to complex nature of decommissioning activities. Adding quality assurance is seen as a significant project control measure where the safety management objectives are identified and kept with expected performance.

However in the recent years it has been proved that the use of project cost and schedule controls at the very outset of a project for decommissioning helps in managing the cost effectively based on well-defined scope with the desired end point. Implementation of cost controls for a decommissioning program minimise project budget and schedule overruns. Additionally project

controls allow for the routine small changes in scope, direction and progress that occur repeatedly during a decommissioning project.

Project controls consider the baseline against the present condition for each component of the decommissioning project. This helps in reporting details needed on task-specific performance, resources and costs expended to the management to focus on reallocation of resources or funds to assure the overall project stays on schedule and budget.

3.3.10 Define Roles and Responsibilities to Assign Decommissioning Tasks

The regulatory authority demands that the licensee submits an organisational structure for approval. The organisation planning is critical for regulatory approval as the regulatory authority scrutinises to ensure the project personnel proposed are skilled to decommission in a safe and secure way. The decommissioning organization structure should minimum include competent staff in the following areas: Project management, Safety personnel well versed in both radiological and industrial safety aspects, engineering, regulatory & licensing specialist, quality assurance, waste management, environmental and emergency preparedness. The decommissioning staff will then be augmented with support from consultants, construction contractors and speciality contractors depending on the nature of the work. Clear authority and responsibilities should be defined for the above mentions organization structure. Additionally attention should be given to retain key personnel familiar with the facility operations and history.

3.3.11 Set Communication Strategy.

Project management is fundamentally driven by individuals who possess the ability to think critically, to respond to changed circumstances, to negotiate with individuals or solve unforeseen problems. For this it is pertinent to set communication strategy and implement proper documentation. The more complex the decommissioning project is, the higher are the requirements to plan and develop project communication system for the control of overall decommissioning process. Poor communications lead to risk arising from interfacing with stakeholders including external regulatory organisations.

3.3.12 Manage Risk.

As projects become larger and more complex, other categories of risk start to dominate and become critical (Asbjorn etal, 2010). Asbjorn etal suggests that these strategic and contextual risks (often consider outliers and either ignored or “assumed away”) are typically outside the responsibility of the project team and not usually not included in contingency. These uncertainties expressed in terms of volatility, have significant potential impact on the project’s outcome as overruns on cost and schedule. Asbjorn etal indicates that this is because the organization’s focus is on definition and performance risks and too little attention is given to organization and background risks.

Typically the tailings contain relativity low activity, but they are perceived to constitute a serious hazard based on their very large volume. The sheer volumes of tailings waste at AGTMF poses a serious hazard and potential risk to human health and the environment. The actual risk, of course, depends upon the nature and amount of radioactivity materials to which the public can be exposed.

The decommissioning of AGTMF may have serious impacts on the public safety, the environment and Cameco as an operator. The public may have significant concerns on the decommissioning of

AGTMF. This is particularly related to managing the risks related to environmental protection and public safety.

The risk management process involves assessment of potential failure modes and consequences; and how the risks could be reduced for an economic consequences, public safety and environmental damages. Project risk management associated with decommissioning includes performing risk identification, risk assessment and risk quantification, risk response planning, risk analysis, and risk monitoring and control for their application to provide realistic solutions to all uncertainties embedded in the decommissioning of the AGTMF. The main take here is not about avoiding the uncertainties but rather recognising its existence and managing it accordingly by applying the appropriate mitigating risk strategies;

a) Avoid risk when there is high impact and high probability,

b) Reduce risk when there is minor impact and high probability,

c) Retain risk (accept) when there is minor impact and low probability and

d) Transfer risk where there is high impact and low probability.

3.3.13 Procurement Process for a Decommissioning Contractor

To set a defined procurement process it requires overall understanding who are the competent decommissioning contractors, are they specialized in similar type of decommissioning projects,

what are their financial stability, what are their average benchmark costing and contracting best practices and be aware of any known challenges to contracting within the decommissioning industry. The lack of skilled decommissioning contractor could be challenging to set a defined procurement process for decommissioning vendors/contractors. This entails planning project procurement management process to ensure the competent vendor is selected and appropriate contract procedures are in place for contracting and hiring decommissioning contractors.

3.3.14 Review and Use Lessons Learned

Past and present lessons learned from other decommissioning projects can provide valuable insight and help to guide future decommissioning choices. An attempt should be made for lessons learned and include both positive and negative discussions with an aim to providing useful site-specific examples or best practices or unsuccessful experiences that could be shared to avoid recurrence.

Improvements are made by learning the lessons of experience and using them to avoid repeating mistakes of the past.

The lessons learned will provide an opportunity to identify the causes for success and failures in the decommissioning projects, and with respect to failures how this can be mitigated in future with available improved technology for the design, construction and closure including cost effective risk reduction for decommissioning projects. The benefit gained from lessons learned from decommissioning projects will include strong safety, environmental management systems and assurance processes going forward.

3.3.15 Develop and Implement Training.

Decommissioning in the past was not included during the mine planning, engineering or operations; and was devoid of adequate techniques and technologies to predict an environmentally sustainable and safe decommissioning process including prediction of long term, post decommissioning environmental performance. This necessitates a need to develop and implement the required training and skills for the project team to exercise their oversight duties effectively for executing complex decommissioning project. This will require all decommissioning personnel attend training for the facility orientation and safety procedures to ensure safe and effective conduct of the decommissioning activities.

3.3.16 Develop and Implement Quality Assurance Program

In the past many decommissioning activities related to uranium mining has been completed without a quality assurance program and this has always been a challenge for the acquisition and retention of the records pertaining to the decommissioning activities for future references.

Particularly records management for a decommissioning facility is a critical component of quality assurance which will shed light on records for retention period and storage locations for monitoring, inspection and acceptance testing during the post decommissioning stages.

It is critical to record accurately all information pertaining to each stage of decommissioning as an essential function for ensuring the success of the decommissioning project. Some of the records that need to be maintained include calibration records of the instruments, inspection and certification tests of equipment, personnel training records and decommissioning procedures.

Therefore a quality assurance program need to be developed and approved for use by the

decommissioning team prior to any decommissioning operations commence. Additionally a well- developed QA program ensures compliance with the regulatory authority requirements for decommissioning and establishes control process for any change in work scope, cost and schedule.

3.3.17 Typical Decommissioning Management Concerns

To summarise some of typical management concerns encountered in decommissioning are:

 Inadequate lead time to establish decommissioning project team with their roles defined

 Poorly defined scope, cost and schedule to manage the decommissioning process

 Scope creep impacting the cost and schedule with no approved change orders

 Lack of flexibility to incorporate the on-going changes as project progress

 No desired end state defined

 Inadequate controls for monitoring cost and project progress

 Inexperienced, unqualified and untrained decommissioning personnel

 Inadequate quality assurance program for decommissioning

 Lack of integration and collaborative between team and stakeholders

 Lack of established project management technique and contract management process.

Decommissioning Challenges

Decommissioning of any uranium facility represents a challenge to overcome in ecological and economic terms and is dependent on the amount of wastes from production, environmental impacts and the complexity of various tasks to be performed. Decommissioning projects can be very challenging due to its uncertainties and even more challenging in a uranium industry considering its radioactive nature. Identifying these challenges and uncertainties and addressing them appropriately requires very careful planning.

Some of the challenges that are encountered are technical, project management and operational challenges and this thesis will dwell mainly on the project management and operational aspects of in-situ decommissioning of the AGTMF. The other challenges in decommissioning include how to make it less expensive, less time-consuming, and safer as well as addressing the environmental issues satisfactorily. This can probably be reached by making the process more standardised to some extent and making use of new technologies. This chapter discusses the processes and challenges involved in decommissioning of any uranium facility like the AGTMF.

4.1 Technical Challenges

The challenge of how safely and economically can the AGTMF be decommissioned is still largely unanswered because of the many technical challenges envisaged. Some of the technical challenges are as follows:

4.1.1 Characterization of the tailings

Adequately characterizing the tailings within the AGTMF with regards to seepage, geochemical, stabilization and consolidation of tailings will be a challenge considering the long term deposition of the tailings and the availability of these data. These are critical in the selection of the decommissioning options, design of the engineered cover and long term management of the post decommissioning of the AGTMF. If information is found to be not sufficient this will require more expensive investigations to be undertaken to unfold the missing required data.

4.1.2 Delineation of the Radioactivity Tailings

Delineation of the radiation emanating from the tailings materials is necessary to ensure the decommissioning effort is appropriate for the decommissioning of the AGTMF. An analysis of the surface materials is required to ascertain the radiation emanating from the mill tailings deposited at the AGTMF. These include the radionuclides of concern within the AGTMF.

The waste management facilities could be devoid of baseline/historical database on the radioactivity nature of the stored tailings as the radioactivity of the tailings are assumed to be as low as reasonably achievable (ALARA). However this may not be true and there is a requirement to delineate and understand the actual radioactivity levels within the stored tailings at AGTMF.

Decommissioning restrict or prevent manual access operations due to the radioactive nature of the tailings.

This data is very important for the selection of the decommissioning options as well as to understand what protection measures would be required for those decommissioning workers. This

is a challenge to overcome considering the long term depositional nature of the tailings and lack of the data related to the deposition of the tailings.

4.1.3 Contamination from the Tailings

Need to understand the various contamination emanating from the tailings and their five exposure pathways and potential impacts to health and environment. It is a challenge to identify these for effectively selecting the decommissioning options that curtails the exposure pathways due to lack of baseline and historical data on various contaminations.

4.1.4 Recognizing the Unknowns

There exist various unknowns with regard to nature of the tailings that will be important on the selection decommissioning options, implementing the in-situ decommissioning and establishing an adequate post decommissioning monitoring system for the AGTMF. Recognizing the various unknowns and mitigating the risks from these unknowns is a challenge. Some of the unknowns include the higher concentrations of the leaking contaminants and thawing nature of the frozen tailings within the AGTMF.

4.1.5 Climatic Conditions

The decommissioning of the AGTMF must take in to consideration the short and cool growing seasons and extreme free-thaw cycles. The construction season must be optimised to complete the decommissioning during the short and cool growing seasons. This could be a challenge for the construction of an engineered cover and the related earth works.

4.1.6 Environmental Issues

Some of the reasons why uranium mill tailings are of particular environmental concern are: radioactivity is very long lived, contain a range of bio-toxic heavy metals, contain sulfidic minerals and generate acid mine drainage, granular and slimy nature of tailings are readily leachable, erodible or collapsible and their surface disposal increases the risk of release of radiation flux, radioactive and geochemically toxic dusts. It is a challenge to identify these environmental concerns and evaluate what may significantly cause impacts to environmental factors such as flora, fauna, and air quality.

4.1.7 Characterize the Geochemical, Geotechnical, and Hydrogeology

The geochemical characteristics of the mill tailings may pose serious challenges to the decommissioning processes with respect to engineering aspects. The geotechnical settings of the

AGTMF need to be characterized for understanding the long term stabilization of uranium mill tailings, structural integrity of the tailings and recommend appropriate decommissioning options.

The hydrogeological regimes within the study area need to fully understood and integrated with the local hydrology to design the post decommissioning options. If the above mentioned information is not available then the challenge would be to conduct expensive detailed field investigations to reveal the inherent geochemical, geotechnical and hydrogeological characteristics of the tailings in relation to its settings.

As in the case of in-situ decommissioning of the AGTMF , the construction of soil covers on very weak, compressible fine tailings often present a formidable challenge due to the lower shear strength, poor traffic ability, and high settlement of these under-consolidated tailings at the time

of reclamation (Wels, C.A. Robertson, et al.2000). Hence a good understanding of the geotechnical properties of the tailings are essential indicators for the selection of most appropriate cover placement.

4.2 Operational Challenges

Some of the operational challenges that is anticipated for the in-situ decommissioning are as follows:

4.2.1 Radioactive Nature of Tailings

The introduction of radioactivity increases the challenges of decommissioning significantly along with the associated liabilities. To overcome this challenge the goal is to reduce the health risks by instituting control measures to provide effective protective measures to workers while carrying out the in-situ decommissioning activities.

4.2.2 Thawing Process for Consolidation

There a number of challenges with regard to the stabilization of tailings impoundments including the removal of supernatant water, increase in shear strength by pore water removal using vertical drains. The thawing process is anticipated to take longer duration (8 to 12 years) and certain amount of uncertainty exist on the duration of thawing to achieve total consolidation of the tailings. Hence the thawing is a challenging task and are both time-consuming and expensive.

Therefore it is important to explore the other innovative technologies that can maximize achieving complete thawing and ensuring overall consolidation of the tailings mass in a shorter duration of time. This thawing and consolidation process will be a challenge to overcome.

4.2.3 Non-Radioactive Nature of Tailings

The toxicity from these non-radioactive tailings would be a problem to human only if the source potable water is contaminated and consumed. However these could be more harmful to aquatic organisms than man and its effect could be lethal or non-lethal, IAEA-TECDOC-1403, Aug

2004. The challenge will be to determine these toxicity from the non-radioactive tailings and how they could impact human and aquatic organisms.

4.2.4 Dusts

The challenge is to reduce/minimize exposure from inhalation of these dusts emanating during the construction process for the in-situ decommissioning process as this could have significant health risks for decommissioning personnel.

4.2.5 Pore Fluids.

The contaminated pore seepage emanating from beneath the AGTMF from the existing infrastructure including the toe-drains, pumping collector sumps and the piping will be able to convey the pore seepage to the mill for treatment in the mill process. There will be no additional cost required for a state of art water treatment plant to treat the pore seepage. However the challenge is to ensure these existing structures are warranted for prolonged use during the post decommissioning of the AGTMF.

4.2.6 Proven Technology and Other Resources

The rapid technological advances made in decommissioning of uranium tailing in the past decade is a technical challenge, as it is yet to be proven in real situations to ensure commercial

interest in the restoration and remediation of the uranium mill tailings. As long as there is little will to try the new concepts, it is not likely that many of them will be fully realised. This is a challenge because the mining industry wants to carry out their projects as cost-effective as possible.

4.2.7 Experienced Decommissioning Contractors

Finding experienced contractors for the decommissioning work could be a challenge as the availability of resources such as a competent and experienced decommissioning workforce is limited for uranium mining industry.

4.2.8 Protection of Decommissioning Personnel

One of the greatest challenges in the in-situ decommissioning of the AGTMF is the detrimental effects on the safe working environment as it may restrict or prevent manual access operations brought about by radiations and radon particles. Therefore it is important to prioritise overall risk management during the whole project.

4.2.9 Funding for Decommissioning

Most difficult challenge would be getting the funds for the decommissioning project. As the cost of project is expected to be very high with no monetary return for the Company, releasing the funding commitment will be one of the major challenges. Despite the existence of legislation for mining companies to provide financial guarantees for decommissioning there is often a tendency to defer the decommissioning process and this could be challenging especially during economically unstable market conditions.

4.3 Project Management Challenges

Some of the project management process identified include the following:

4.3.1 Project Planning Process

The project planning for decommissioning an uranium tailings facility like AGTMF will require detailed and rigorous planning considering the timescales of in-situ decommissioning dictated by safety and technical components, logical linkages of the various decommissioning work components and their complex interrelationship and availability of resources. This could be a challenge in the absence of stewardship from the top management of the company to drive and provide a responsible decommissioning of the facility.

4.3.2 Selection of viable decommissioning options

A significant challenge exist to choose an option while integrating all the related factors to devise a cost effective decommissioning option while meeting the regulatory requirement. The challenge is to select an option that requires considering all measures to close pathways for movement of tailings components to the surrounding environment. This requires effective planning and adequate designs to ensure the pathways are blocked in the long term.

4.3.3 Safety Factors

A critical project management challenge is to overcome the potential harm to decommissioning worker’s health, safety and security while working at this decommissioning facility. The selected decommissioning option shall ensure having established controls in place to minimize the hazards to the workers in compliance with the legal and regulatory requirements. If this

criterion is not met for ensuring the risks are as low as reasonably achievable (ALARA), the selected decommissioning option may not be acceptable.

4.3.4 Cost of Decommissioning

Woodhouse Publishing (2012), P.J. McIntyre explains decommissioning will be rarely seen as an investment, it is actually a delayed capital cost of building and operating the facility in the first place. Costs of decommissioning are very high and funds may not be available to complete the decommissioning project as a result in nuclear industry decommissioning is often carried out in a piecemeal as funds become available rather than as a project aiming to deliver completion to time and cost. This potentially increases the total cost of decommissioning program. The decommissioning cost could be challenging and is significantly dependent on the selected decommissioning option. The cost for decommissioning needs to be reasonable, appropriate and cost effective and this could be challenging. Hence it is a challenge to cost accurately.

4.3.5 Develop a Scope Meeting Regulatory Acceptance.

It is an important project management challenge to develop a scope that meets with regulatory and public acceptance. Therefore it is important to understand that a poor scope definition

(baseline combination of scope, schedule and cost) will impact the desired end state of decommissioning project and this could be a challenging concern. There are not always sufficient and specific decommissioning guidelines for decommissioning an AGTMF. Although there are laws treating decommissioning they are no decommissioning guidelines for AGTMF.

As long as there is no clear guides on how to carry through the decommissioning operations, the other regulations have to be followed as far as possible and this could be a challenge.

4.3.6 Manage Stakeholders and Obtain Consensus

Managing and obtaining consensus from various stakeholders is considered to be vital and could be challenging and demanding as the stakeholders may have strong views on the proposed decommissioning option. This requires extensive public consultations with stakeholders to engage and involve them in constructive decision making process. Engage the stakeholders

(communities mainly) effectively on a continued basis during the pre and post decommissioning process to reassure them that company is obliged and committed to the “triple bottom line” and doing business in a responsible way.

4.3.7 Project Schedule

Developing and implementing a project schedule considering the unpredictable decommissioning components could be challenging. These are dependent on several factors and need to be adjusted in view of the changing conditions like stakeholders’ needs, regulatory demands, budgetary constraints etc. It is a challenge to implement a project schedule considering the complexity of decommissioning as it involves a series of activities and in some exist uncertainties on their duration like for the thawing program for the frozen tailings in the

AGTMF.

4.3.8 Manage Project Cost and Set Project Controls.

Estimating the project budget and managing the cost during decommissioning is complex due to complex nature of decommissioning activities. This could be challenging to cost estimate and establish realistic unit rates due to its complex nature with lots of uncertainties. The complexities in decommissioning offers the project management team to struggle to meet the

cost and schedule commitments. An example of cost overruns in the decommissioning of the

Olkiluoto Nuclear Power Plant in Finland where it was initially budgeted for 3.2 Billion Euro however the current budget was 8.5 Billion Euro (Charles D, 2014). Similarly the Flamanville

Nuclear Power Plant, France was initially budgeted for 3 Billion Euro in 2012 however it will not start until 2018 at a cost of 10.5 Billion Euro (Michael S, 2015). According to George

Jergeas (2008) there are several factors that can cause cost and schedule overruns including unrealistic or overly optimistic original cost estimates and schedules and incomplete scope definition.

This same tendency can be observed for other type of projects as referred by Asbjorn etal (2012).

For example, the final cost of the Sydney Opera house was almost 14 times the original budget and it was completed 10 years late while the Denver Airport was opened 16 months behind schedule at a cost almost three times the original budget. This would make us think are there a better way to think about the causes of these overruns, and a better way to manage them so there are no surprises when the project is completed?

Hence developing a reliable costs and schedules at the outset of a decommissioning project and managing the budget and schedule controls is considered a challenge and is vitally important for a safe and effective decommissioning programme.

4.3.9 Define Roles and Responsibilities

Defining roles and responsibilities to assign decommissioning tasks is tricky. The lack of experienced decommissioning personnel for decommissioning task offers a challenge to identify

and deploy skilled decommissioning personnel and provide an organisational structure for approval.

4.3.10 Manage Risk.

With the increasing complexities in in-situ decommissioning due the sheer volumes of tailings waste at AGTMF it poses a serious hazard and potential risk to human health and the environment. Managing this risk related to environmental protection and public safety is a challenge considering the uncertainties involved in the decommissioning activities and to minimise Cameco’s liability and transforming public resistance to public support.

4.3.11 Lessons learned

There is limited lessons learned and use of experience on in-situ decommissioning projects with respect to decommissioning of AGTMF in the nuclear industry. This is a challenge to review the best practices that can overcome cost, safety and security for the current problem/issues in the in- situ decommissioning of the AGTMF.

Lessons Learned

A literature review of the lessons learned presents a significant amount of decommissioning experience within the global mining industry in uranium tailings management. This provides valuable insight for devising management tools and procedures to overcome the current operational and project management challenges in-situ decommissioning the AGTMF. The combination of knowledge gained and practical experience contributes to the global mining community in regards to decommissioning of similar tailings management facilities.

In the words for Greek philosopher Aristotle, “What we have to learn to do, we learn by doing”.

Thus it is extremely important to use the lessons learned gained from operator, regulators, and government organizations to implement proactive measures to assure the safe decommissioning of AGTMF. The experiences both good and bad provides an opportunity for learning (IAEA

Vienna, 2007). The experiences when things go wrong is often the most important lessons that can be learned. Some of the lessons learned are discussed below:

5.1 Early Planning for Decommissioning

A proactive approach with scientific research, geotechnical engineering and detailed project planning is required when developing scope, schedule and budget for decommissioning of a large uranium mill tailings facility such as the AGTMF. It is fundamental to decide on the end state of decommissioning early in the planning process (IAEA Vienna, 2007). A very important lesson learned was inadequate planning at early stages for decommissioning resulted in extended delays and excessive decommissioning costs. The early planning provides detailed information for a facility owner to include in the scope during the tender and thus more comparable and

comprehensive the bids will be received. It is recognised that decommissioning aspects of tailings management facility should commence at the start of mining and milling activities

(IAEA Vienna, 2007).

During initial planning certain tasks to be considered include historical site assessment that includes site characterization and options considered for remediation. The operator should consider also consider early regulatory submittals of plans for decommissioning.

 Knowledge gained from the decommissioning activities at the 300 Area Facilities

Disposition Project at Hanford, USA showed that deficiencies occurred during the

organizational transitions from the Waste Management Project to the River Corridor

Project in 1999 where temporary shielding in a valve pit was not included in the quarterly

survey in the River Corridor Project (IAEA, 2009). This was due to a difference in

documentation requirements between these projects. Documentation and reporting

requirements should have been captured in early stages of planning to ensure continuity

during organizational transition to confirm that conditions existing under one set of

procedural requirement do not become deficiencies under a different project’s

requirements.

Some of the best practices (NRC, 2012) identified for early planning include the following:

i) The planning for decommissioning for uranium processing and mining sites

should follow three broad principles: Closure planning should be anticipatory;

iterative and adaptable and recognise the need for and limits for long-terms

stewardship.

ii) It is learned from experience the best practice requires a complete life-cycle

approach during the planning phase to include all aspects of the process – closure,

site remediation, and return of the affected area to as close to natural conditions as

possible prior to the initiation of the project.

iii) It is a good operating practice for site and waste remediation to be carried out on a

continuous basis during the mining operations, whereby the time and costs for

final decommissioning remediation is; and reclamation is reduced.

iv) From experience it is understood that a meaningful and timely public participation

should occur through the life cycle of a decommissioning project, so that a

transparency will exist for gaining the trust of the stakeholders including the

community.

v) Decommissioning of uranium facilities should be based on the specific

requirements of each site however they should use/adapt the best practice

documents produced by international institutions associated to Uranium Mining

Industries to develop the decommissioning projects.

vi) The monitoring strategy for post decommissioning should be subject to annual

updates and independent reviews to incorporate new knowledge and changes in

regulatory levels.

5.2 Communications

Communication is an important element in all decommissioning projects. Building public confidence and trust is fundamental for decommissioning projects and requires interaction with stakeholder. It is essential to build trust with the regulators and stakeholders. Owners of the

facility should make efforts to establish confidence with regulators and stakeholders. Early and frequent discussions with all key stakeholders including the regulators both federal and provincial, communities and facility owners is important (IAEA Vienna, 2007). Engaging the key stakeholders in an interactive dialogue at early phases of planning, scoping, environmental and socio-impact phases add values for building understanding, cooperation and ownership. It is important to keep the regulators and stakeholders (community) abreast of any issues arising during decommissioning. This increases and establishes confidence within the stakeholders.

This initiative of engagement by the owner at the outset of planning entails the stakeholders have ample opportunity influence the conduct of a decommissioning project and additionally enhances the public acceptance (IAEA Vienna, 2007). The continued interaction between the owner and stakeholders should be maintained through meetings and workshops right from commencement to completion of the decommissioning. Good communications between the different stakeholders helps to develop optimal technical solutions and to identify best practices. In decommissioning projects of any size co-operation of all stakeholder is critical and communication plays a vital role to gaining this co-operation.

 At the Hanford site (Washington, USA), sampling of tritium at the 324 Facility exhaust

stack was discontinued during plasma arc furnace testing without the approval from the

regulators (IAEA, 2009). The process of communicating with the regulators broke down.

The regulators issued a notice of violation because of less than adequate communications

regarding the testing and about discontinuing sampling. The lessons learned is that the

facility owners should ensure that they receive confirmation from regulators before

changing monitoring and sampling processes listed in the permits. Clear, precise, and

complete communication with the regulatory agencies is paramount.

 The optimal way to manage the communication with local stakeholders may vary

depending from the social habits and attitudes of the public in the area. A flexible

approach, mainly driven by local region initiative, has revealed to be the most efficient as

lessons learned from communications at local level in Italy (IAEA, 2009).

 In one of the Electric Power Research Institute (EPRI)’s plant decommissioning, it is

estimated that if EPRI had selected litigation over negotiation for settlement purposes

then the overall project completion would been delayed up to two years (EPRI, 2007). An

assessment of the costs and benefits of litigation over negotiations show that litigations

will be longer and more expensive. Negotiation is often better than litigation where

communicating strategically and leading both parties for a win-win situation is beneficial

and cost effective solution.

5.3 Decommissioning Strategies

In the past the target of decommissioning projects was returning the sites to ‘a green field” status

(IAEA Vienna, 2007). This could be extraneous and it could be more appropriate to reuse the existing sites for new nuclear facilities rather than returning the sites to a green field. One of the benefits of reusing the existing sites will be reducing the footprints in the new areas from any radioactive contaminations and pollutants.

Decommissioning of a facility immediately after the operation ceases will be the general preferred strategy however in most cases decommissioning is seen to be deferred due to various reasons including lack of funds, social and political reasons (IAEA Vienna, 2007). The advantages of

decommissioning immediately is the availability of existing equipment, workforce, their skills and knowledge of the facility that could contribute towards the decommissioning works in reducing costs and eliminating any unknowns. Through experience it is learnt that an important strategy in decommissioning is to identify and set the end state of decommissioning at very early stages of the project or even before as this allows making key decommissioning decisions.

5.4 Regulation of Decommissioning

It is important to understand the regulation involved in decommissioning especially with respect to the regulatory submittals (permits and application for decommissioning), environmental assessments, standards for protection of workers and public, the site release criteria and limits, and plan decommissioning components accordingly.

 Lessons learned in US with regard to radionuclide concentration allowable limits for

different areas is different based on its setting. In US, a resident farmer scenario has

relatively lower radionuclide concentration limits whereas industrial use scenario it is

relatively higher concentration. Understanding the regulations is critical in

decommissioning (EPRI, 2008).

 It is learnt from Australian Nuclear Science and Technology Organisation (ANSTO), that

undertaking decommissioning activities such as inspections, surveys, modifications and

the removal of all redundant nuclear materials very early on in a decommissioning

project will help improve decommissioning planning and minimise/reduce any

safeguards/non-proliferation issues from regulatory agencies (IAEA, 2009). Additionally

the early removal will minimise future administrative burden and costs.

5.5 Environmental Concerns

Some of the lessons learned related to environmental concerns are as follows:

 In Whiteshell Laboratory decommissioning, Canada a requirement for detailed

environmental analysis raised as a result of public and regulatory concern during the

environmental assessment process, added real value to the decommissioning project. This

is because there was existence of adequate data to justify the proposed end state for

contaminated sediments at the process water release point to the Winnipeg River met

with public and regulatory resistance (IAEA, 2009).

 It is pertinent to gather an in-depth assessment of the operating impact on site in terms of

site contamination for both radiological and non-radiological pollutants within the site.

Lessons learnt is that the scope of historical site assessment should be broad and include

tasks in identifying areas that may pose threat to human health and ecologically sensitive

habitants, an assessment of the likelihood of contaminant migration, and the

identification of any permits that may require modification during the decommissioning

process (EPRI, 2007).

 EPRI has taken up to 2 years in some cases for preparing historical site assessments for

decommissioning utility projects. It is important to recognise and plan accordingly

considering this duration will have a major impact on the planning and scheduling of all

subsequent decommissioning activities (EPRI, 2007).

 Another lessons learned from ERPI related to environmental concerns of a

decommissioning facility is historical track on radiological and non-radiological waste

storage over the period of operation of the facility. A robust and comprehensive record

keeping system and database throughout the operating life of the facility will be

invaluable in site characterization efforts and related environmental site investigations

(EPRI, 2007).

 Some of the lessons learned identified for decommissioning by United States Nuclear

Regulatory Commission (USNRC) are:

a) Long-term stewardship including post closure groundwater monitoring ensures

long-term performance is maintained by the licensee/owner.

b) Established regulatory framework essential to avoiding contamination.

c) Groundwater flow and transport modelling key to identifying remediation

strategies and long-term performance.

5.6 Covers for tailings

Lessons learned on the use of conventional covers over tailings at reclaimed uranium mill tailings in arid and humid climates has been a focus of research for U. S Department of Energy

(DOE). Jody Waugh, 2008 in his study for DOE discusses that some conventional rock covers create habitat for deep-rooted plants, root intrusion and soil development increase the permeability of compacted soil layers, high percolation rates have raised concerns about long- term groundwater protection, and conventional cover will likely require high levels of maintenance or renovation to sustain long-term performance. These root intrusion and soil development could increase permeability and percolation 100 times to 1000 times greater than design target which impact the long-term stabilization at reclaimed uranium tailings management facility, as well as increase uranium contamination in groundwater as in the case of Durango and

Blue water sites in U.S. Hence it is important to benefit from these lessons while designing the covers for tailings as well deciding on the vegetation over the covers.

Sheng Y etal (1998) points out that the following issues need be considered and addressed during the design stage:

 Accessibility of heavy duty earth moving equipment to the tailings area,

 Optimal design parameters for improvement of tailings bearing capacity; and

 Optimal capping structure for effective suppression of radon gas emission.

Advances in the science of cover performance and lessons learned from monitoring conventional covers contributed to the development of alternative to the low-conductivity designs for uranium mill tailings (W.J. Waugh, etal 2008). It is important to consider the three dominant factors;

Climate, Soils and Vegetation that influencing the cover performance. Some important lessons learned at Monticello, Utah Disposal site follows (W.J. Waugh, etal 2008):

a) The covers need to be designed successfully to limit percolation through the cover.

b) The percolation is a key cover performance monitoring parameter.

c) Continuous monitoring is necessary to understand how covers are influenced by

fluctuations in climate and other environmental factors.

d) Performance evaluations of covers should use field measurements from lysimeters.

e) For the successful design, performance monitoring and maintenance of cover the soil

edaphic properties must be considered.

f) Adequate understanding of the plant ecology and ecophysiology is required for the

successful design, performance monitoring, and maintenance of covers.

The experiences gained from dry in-situ capping of uranium tailings indicate that a thorough understanding of geotechnical properties of the tailings using consolidation and slope stability modelling analysis contribute significantly in the selection strategy for an appropriate cover placement. This requires extensive hydrogeological and geotechnical investigation to provide the rationale behind the design and selection strategy for the cover type. Additionally it is important to provide suitable run off conditions for the surface water on the top of the final cover to drain away from the capped tailings.

Similar in-situ decommissioning carried out in the mining industry suggest on the requirements for a detailed environmental study to be included in the pre-decommissioning phase. This will benefit in the appropriate selection and design of the cover for the tailings. It is also recommended to develop cover performance criteria on a case-by-case basis and with due consideration of the short-term and long-term impacts on the receiving environment (Kane and

Wells, 2003). In Kane and Wells’s paper, it suggest performing an impact analysis that quantifies the relationship between cover performance criteria and environmental impacts, however the specific environmental impacts will depend on the objectives of the proposed cover system design and pertaining environmental regulations. Some of the environmental impacts evaluated ideally for a cover design include impacts on surface water quality, groundwater quality, air quality, vegetation and on wild life.

Considering the exceptional endurance required for an engineered cover, the goal should be focused to design covers to accommodate long-term ecological processes with the goal of sustaining performance with as little maintenance as possible.

5.7 Funding of Decommissioning

Decommissioning activity does not generate any revenue and decommissioning activities normally begin at a time when the revenue from the mining operations ceases. The burden is on the facility to demonstrate that the amount of the financial surety is sufficient. Thus funding for decommissioning becomes challenging for the mining companies in the past.

Over the years both Government and Industry have learned and recognised the need to plan funds for decommissioning activity virtually beginning at time of start-up of the mining operation so that the facility will have financial capability to proceed with the decommissioning.

This is essential to ensure funds are available for safely completing the decommissioning to protect the people and environment. This is the primary responsibility of the licensee/owner. It is also recognised that planning for funding the decommissioning activity is a long term and continuous ongoing process throughout the life cycle of mining and milling operations period to complete shutdown. In United States the lessons learned with respect to funding requirement for decommissioning is to ensure adequate financial assurance is necessary to prevent orphaned sites.

In Slovakia, the State Decommissioning Fund was created for all Slovak nuclear installations on the basis of revenue earned from power and electricity (IAEA, May 2004). It is also established that a legal basis is required for creating decommissioning funds, and assurance the funds will not be squandered for other purposes (IAEA, Nov 2005) as a result various government agencies have formulated policies to collect and safeguard these funds until they are needed to start decommissioning to ensure adequate funding for decommissioning. It is also important the

funds be periodically reviewed and updated to respond to any changes in the requirements for the remediation of the facility as they occur (IAEA, Nov 2005).

Abrupt changes in policy due to fundamental leadership changes in government can be highly disruptive of innovative programmes such as reindustrialization, as demonstrated at Oak Ridge

(IAEA Vienna, 2008). Where both the new businesses and community were adversely affected by the significant changes in the government policy. The lessons learned here is that the decommissioning programs need to be carefully evaluated by the communities that are designed to benefit as to their economic viability and ability to be self-sustaining in the long term in the absence of government funding.

5.8 Estimation of Decommissioning Cost

Decommissioning for five of the six conventional mills studied, the tailings decommissioning cost represented and ranged from 52%- 64% of the total site decommissioning costs (Chung.T,

1994). Hence estimation for decommissioning is very critical and needs to be carried our prudently considering the several cost factors. Groundwater restoration is an important and a potentially costly component of the decommissioning of the mill/mine tailings. In 1994, Chung indicates the cost for tailings reclamation averaged $32,000 per acre of tailings, with a range of

$9,000 to $57,000 per acre. He also estimated an average of $1.13 per ton of tailings and ranged from $0.57 to $2.62 per ton for tailings reclamation. Table 5.1 presents the comparison of the relative cost value for tailings decommissioning in US$.

Samuel H W, 2016, defines, *Historic opportunity cost of a project is measured by comparing its relative cost using the cost index of all the output in the economy. This measure use the GDP

Deflator, “is the implicit price deflator and is a measure of the level of prices of all new,

domestically produced, final goods and services in an economy. **Economy Project Cost of a project is measured by using the relative share of the project as a percent of the output of the economy. This measure indicate the opportunity cost in terms of the total output of the economy.

The viewpoint is the importance of the item to society as a whole, and the measure is the most inclusive. This measure uses the share of GDP.

Table 5.1 Comparison of the Relative Cost Value for Tailings Decommissioning in US $

Year 1994 2016

Ranges Unit Lowest Range Historic Highest Range Highest Cost per Unit Average of the Ranges Acre/Ton of Project Opportunity Cost* Economy Project Cost** US $ Value US $ Tailings US $ US $

NA NA $1.00 $1.49 $2.45 $1.97

Low Range Value Ton $0.57 $0.85 $1.40 $1.13

Average Range Ton $1.13 $1.68 $2.27 $1.97 Value

High Range Value Ton $2.62 $3.90 $6.43 $5.17

Low Range Value Acre $9,000.00 $13,400.00 $22,100.00 $17,750.00

Average Range Acre $32,000.00 $47,600.00 $78,600.00 $63,100.00 Value

High Range Value Acre $57,000.00 $84,000.00 $140,000.00 $112,000.00

The estimates for a realistic cost is of high importance for any decommissioning projects and achieving this is a challenge. Lessons learned indicate that the cost estimates need to be realistic.

This can be achieved only if the planning for the decommissioning scenarios and selected options are carried out diligently and rationally to capture all associated costs for a reliable cost estimates. This is often dependent of on how best the decommissioning components are wholly understood while defining the scope based on the available facts related to components to be

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decommissioned, knowing the end state of decommissioning, the regulatory goals to meet the regulatory commitments and the principal cost drivers.

Some of the components for cost estimating include defining the scope of work, decommissioning strategies, collection of information, scheduling each activity, the duration and the sequencing of activities. An important lessons learnt is that cost estimate and schedule are an integral part of the planning for the project and should be on-going process from the concept to final implementation. This lays importance on the need for cost estimates to be reviewed and updated throughout the life cycle of the project to ensure that they accurately reflect the costs and resources that are required. Uranium decommissioning processes will require longer duration and in some cases it extends to a couple of years and often requires a staged approach considering its radioactivity nature, achieving compactness after thawing of ice lenses and availability of specialised contractors and equipment.

In some cases, the active thawing of the ice lenses within the tailings for consolidation it will be unrealistic to estimate the cost as it is difficult to predict the duration required for the thawing and this is dependent on the seasonal changes with long periods of winter season.

Another lesson learnt is that the mining companies will require to make the changes to the detailed cost estimates according to the changes encountered in the operations and decommissioning plans. These factors need to be considered in the estimating process.

One another important lessons learnt in cost estimation is that there is potential for making errors and also difficulty in performing quick cost comparisons with other decommissioning projects.

This could lead to misinterpretation if the numbers taken at face value without regard to context.

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As Asbjorn etal (2010) suggests, is there a better way to think about the causes of these overruns, and a better way to manage them so there are no surprises when the project is completed?

5.9 Management of Radioactive Waste from Decommissioning

It is learnt that early planning for the management of radioactive waste from decommissioning is vital for the success of the decommissioning project. As in the past the lack of waste disposal facilities is not a reason for delaying decommissioning in particular in the case of legacy sites

(IAEA Vienna, 2007). Measures should be in place to isolate the radioactive waste with the monitoring of the migration and attenuation of the radioactive waste. The treatment of radioactive waste is an integral component of management of radioactive waste. It is recognised the need for well-established and internationally accepted policies for controlling release of materials from decommissioned facilities for disposal. Also is learnt to minimize the amount of radioactive waste and the impacts of its disposal. With technologies advanced the waste stream generating from mining and milling activities could be curtailed to reduce the generation of wastes. It is also learnt to recognise that radioactive waste disposal should be seen in the context of entire life cycle of the mining and milling cycle. The management of tailings pore water released from the tailings are of critical importance to achieving decommissioning goals. This requires a treatment facility to ensure the pore water are treated is ongoing for the long term of the post decommissioning operations. It is important to understand that issues related to waste management do not stop with decommissioning and consideration need to be given to the eventual clearance of the site. Lessons learnt suggest that a continued containment and storage of waste is an integral part of any site-wide strategy for decommissioning.

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5.10 Selection of Technologies for Decommissioning

There are quite a number of available new and innovative technologies for decommissioning related uranium mining and milling facilities. It is pertinent to use proven methods that will provide secure planning and costing to achieve the desired objective of decommissioning the facility or site. The decision making for the selection of technologies for decommissioning is multi-parameter process and the most important parameters are cost and safety. However from lessons learned it is understood the new and innovative technologies need to be tested and demonstrated for their suitability prior to implementing them. This requires provision to be considered during the planning stages of decommissioning. Additionally it is also important to know the availability of contractors who are familiar in the application and the development of the selected decommissioning technologies. Therefore selection of technologies for decommissioning should primarily consider the desired objectives of decommissioning and its applicability for the site. The selection process for decommissioning technologies is an important aspect of decommissioning. The selected methods have a large impact on the decommissioning process including radiation protection, environmental protection, and radioactive waste management and on the cost of decommissioning and these form the key drivers for the selection of the decommissioning technologies.

5.11 Decommissioning Workforce

It was recognised during the decommissioning of the Tower Shielding Facility, USA that inadequate supervision of the subcontractor led to release of contaminated material offsite. The lessons learned is that oversight of subcontractor work is essential to ensure that all contractual

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obligations, including radiation protection requirements and proper radiological procedures are strictly enforced (IAEA, 2009).

The work force of nuclear power plant at Hinkley Point, United Kingdom, lacked skills for the long decommissioning project. The lessons learnt here is that existing work force is of high average age and not necessarily have skill required for a long decommissioning project. The length of the decommissioning is long enough that the training new young staff is required to contribute to the decommissioning project and to the community (IAEA, 2008).

5.12 Safety during Decommissioning

The safety is a very important component of the decommissioning process and it is learnt from previous experiences that a detailed assessment of the hazards associated with decommissioning need to be evaluated early in the planning stages and assessed throughout the life cycle of the decommissioning process. The assessment should consider the specific dose and risk targets for the decommissioning process. According to Colin & Kevin, Sept 2003, the safety methods proposed for decommissioning should consider the potential hazards to workers, the community and the environment and should be in accordance with ALARP (as low as reasonably practicable) principle. A risk assessment need to be performed to address the consequences of if something going wrong as well the prevention/minimising the consequences of the occurrence happening. There is a need to consider the exposure routes during the decommissioning process such as contaminated dust, export of contaminated items of equipment and direct radiation of radioactive wastes. This entails an inventory of all radioactive and non-radioactive hazardous materials during the very early stages of planning. A safety plan for the decommissioning

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process should present an overview of the decommissioning project and specify the safety requirements to be considered for the individual phase/tasks.

5.13 Social Aspects

The public involvement during the design and implementation of decommissioning and monitoring program is valuable to build credibility and ensure that stakeholders’ concerns are adequately addressed. The early involvement of relevant stakeholders in planning for decommissioning and the definition of a clear endpoint for decommissioning are important. This contributes to building public confidence, staff motivation and consideration of the social impacts related to decommissioning. In this context, it is learnt that the uranium mining company should partner with the local communities to conduct independent monitoring through the funds made available by the mining company. Additionally all communications regarding the data and reviews should be transparent and the public have access in order build credibility. Lessons have been learnt on the meaningful and timely public involvement and stresses on the benefit of keeping these public participation at all stages of the decommissioning project.

5.14 Understanding Unionised Environment

In Oak Ridge Site, Tennessee there was picketing by their unionised workers after the company decided to procure the services of a specialist contractors to perform decommissioning activities faster and at lower cost (IAEA Vienna, 2008). Bringing in an outside contractors upset the company employees that led to undesirable consequences. The lesson learned, is the workforce strategy to be used needs to be finalized before procurement activities begin. There is a requirement to address the issues in a timely manner to avoid future debate and conflict that potentially harm both the project and the parties involved. During the bidding stages to select

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decommissioning contractors, there is a need to respect and consider the local unionised environment, understand existing rules under services contract and construction contract and its consequences if one of them does not fall under the requirements of the act.

5.15 Decommissioning Cost – Justified or Not

Parker F.L, 2004 wondered whether it makes sense to spend hundreds of millions of dollars now to protect the future generations while allowing so many local members of the populations to live below the poverty level. This was based on his reservations on the benefits relative to the cost of the U.S. mill tailing program where he was struck by the hundreds of millions of dollars being spent to protect a population that might be there in 200 to 1000 years in the future from statistical deaths. He wondered if our intergenerational concerns had not blinded us to our intra- generational concerns. He was further struck by the fact that because of the long term buildup of thorium and radium daughter products that the maximum doses would not occur for thousands of years and how this huge cost in decommissioning could be justified.

5.16 High Cost

Hagen, M. 2007, indicates the estimated cost for clean-up at Wismut in Saxony and Thuringia by

Federal Republic of Germany is 6.2 billion euros over 15 years to safely isolate and control the enormous quantity of uranium production residue, 312 x 106 m3 of waste rock, 1,518 ha of waste rock pile area, 161 x 106 m3 of tailings volume, and a tailings pond area of 724 ha. This enormous cost despite the background doses as small as 0.26 mSv/a and reported cases of 5,500 occupational radiation-induced cancer of the lung. Hulka, 2003 thought to spend over 10 million euros on the remediation of uranium tailings program based on radiological grounds was

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unnecessary. Hulka has stated that a great deal of remediation work is unnecessary on radiological grounds; however it is carried out for political, aesthetic or other reasons.

The decommissioning cost of for six conventional mills (Ambrosia Lake, Sweetwater, Bear Creek,

Grants, Gas Hills and Church Rock) studied in US, where the tailings cost represented the largest factor in decommissioning cost (Chung.T, 1994). Chung presented the cost ranges for decommissioning of the tailings for five sites. The relative project cost value for tailings decommissioning is presented in Table 5.1 based on unit rates for ton and area of tailings.

5.17 Community Environmental Quality Committee

An important way to accomplish this is to involve the stakeholders (Community Environmental

Quality Committee as in the case of permits) in the monitoring process. This can be achieved through established monitoring system (radiation, air, and water and dust quality). This could provide them the benefit of understanding the monitoring systems including the reduced risks and hazards that come from selected decommissioning option for the AGTMF. The transparency and credibility thus established from real time monitoring levels at the pre-decommissioning, during decommissioning and after decommissioning stages further reassures the best interests of the community is taken in socially responsible manner.

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Project Management of In-situ Decommissioning Method

The selected plan is to in-situ decommission the AGTMF owing to the large volumes and low activity levels of the tailings. In-situ decommissioning will involve encapsulating the consolidated tailings by placing an engineered cap over the tailings body. The engineered cap will direct surface runoff away from the tailings mass to reduce infiltration rates and reduce the environmental risk of transport of elements of concern from the tailings to the regional ecosystem. This chapter discusses the in-situ decommissioning project management process for the decommissioning the AGTMF and assumes this needs to commence in the immediate future.

This thesis has given due importance to project stakeholder management the newly added knowledge area in PMBOK (2013) and stresses the benefits of continuously engaging the stakeholders in key decisions for the in-situ decommissioning activities.

6.1 Project Objectives

The in-situ decommissioning involves a long term planning and covers several phases. The project objectives for the overall in-situ decommission encompass the following:

 to produce a fully consolidated tailings mass (including a rigorous thawing program to melt

ice lenses within the tailings mass),

 to cap the tailings mass to reduce water infiltration,

 to meet both federal and provincial regulatory requirements with respect to containment

and reducing the risk of contaminant migration from decommissioned tailings system.

 to establish monitoring and maintenance care during the post decommissioning

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6.2 Policy and Commitment of In-Situ Decommissioning of AGTMF

The decommissioning and the closure of the AGTMF need to be carried out in compliance with regulatory requirements and in conformance with sound engineering practice and company standards. This is to ensure the decommissioning is implemented as per the requirements laid down in the Guidelines for Northern Mine Decommissioning and Reclamation by Saskatchewan

Ministry of Environment (SMOE) and CNSC approved decommissioning plan. This entails understanding a number of provincial acts and regulations for developing and implementing a decommissioning plan for AGTMF. The acts and regulations are provided earlier in Section 2.1.

6.3 Project Management Planning for In-Situ Decommissioning

Failing to plan is planning to fail (A.Rahman, 2008), hence project planning is crucial to the management of an in-situ decommissioning project. Planning provides the basis of the execution of the in-situ decommissioning plan, and execution will lead to updates to the original plan as the in-situ decommissioning progresses. However it is important to manage and restrict changes and updates to the original in-situ decommissioning plan to a minimum. Failing of which would result in scope creep, increased cost and hinder in-situ decommissioning project progress. Importance has been considered on the four new planning management processes (scope, schedule, cost and stakeholder) which have been added to PMBOK (2013) to reinforce the concept and integration of each of these for the overall project management plan. These are essential project management tools to deliver results. A number of basic planning principles for developing and implementing in-situ decommissioning for the AGTMF is presented in the following sections. The project planning is vital for managing the implementation of in-situ decommissioning and achieving the

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objectives discussed earlier in Section 6.1. Additionally adequate project planning for the in-situ decommissioning helps achieving the triple constraint namely, the budget, schedule, and scope.

The project management plan for the in-situ decommissioning project sets out the description of objectives, methodology, organisation, timescale and budgetary provisions to complete the project.

The following sections sheds light on the project planning for the in-situ decommissioning and are included in the conceptual and detailed decommissioning plans. Once the in-situ decommissioning plan is approved by the regulators this becomes the approved guide to both project implementation and control. The approved decommissioning plan will be as required in the Regulatory Guide G-

219 Decommissioning Planning for Licensed Activities.

6.3.1 Conceptual Decommissioning Plan

The conceptual planning falls under the pre-decommissioning stage and covers all activities carried out in preparation of the actual in-situ decommissioning. This will include all the planning activities in the preparation of the preliminary decommissioning plan, the predicted impacts of the in-situ decommissioning of the AGTMF on the surrounding ecosystems, a description of how the impacts will be mitigated and what the residual impacts will be, a general overview on how the AGTMF will be decommissioned and the final in-situ decommissioning objective, which will be based on the residual impacts of the project and covers AGTMF characterisation, proposal for a decommissioning strategy. A couple of stakeholder consultation including public consultation and public inquiry and stage gate reviews are included in the feasibility phase under the pre-decommissioning stage. All the activities and tasks are included in the Feasibility Phase I under the Pre-Decommissioning Stage in the Section 6.5.1 where

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detailed descriptions are provided for each tasks. A report conforming to all the activities will constitute the conceptual decommissioning plan.

6.3.2 Detailed Decommissioning Plan

The decommissioning plan will include all the activities that will be required to prepare the final decommissioning plan for submission to the regulatory authorities for approval prior to the in- situ decommissioning of the AGTMF. The final decommissioning plan will include the provision of a financial security or assurance and is developed on a “decommission tomorrow” by Cameco

Corporation that provide the technical details for the in-situ decommissioning of the AGTMF.

The detailed decommissioning plan will include the following:

 Proposed end use of the AGTMF site

 Predicted timelines for reclamation of the AGTMF site,

 Discussion of the in-situ decommissioning activities,

 Identification of the preferred procedures for in-situ decommissioning of the AGTMF

 Time frame and the sequence for the in-situ decommissioning activities,

 Environmental assessment with mitigation and reclamation measures

 Post decommissioning including monitoring and maintenance activities

 Cost estimates for the in-situ decommissioning activities.

The final decommissioning plan will include all the technical details obtained from AGTMF site characterization, detailed design, environmental assessment and other activities included in

Section 6.5.2 to Section 6.5.5.

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6.4 Project Life Cycle of In-Situ Decommissioning

To achieve the desired objectives for the in-situ decommissioning project, it requires to go through specific process called, “life cycle”. During the entire life cycle of in-situ decommissioning, the project management is essential for control of safety, adherence to procedures, and quality assurance. The project life cycle for in-situ decommissioning of the AGTMF will be undertaken on a staged approach encompassing 3 stages. Each stage will involve a number of phases/phase and each phase will have a number of activities or tasks. The stages and phases in the in-situ decommissioning process for the AGTMF is as follows:

 The Pre-Decommissioning stage comprise of two phases;

o Phase I - Feasibility and

o Phase II - Detailed Engineering.

 The Decommissioning stage will comprise of two phases;

o Phase III - Thawing Program and

o Phase IV - In-situ Decommissioning.

 The Post-Decommissioning stage will include one phase;

o Phase V - Monitoring and Maintenance care

It is critical to define the stages and phases in the life cycle of in-situ decommissioning project cycle. Furthermore it important to have a well-defined scope to understand the extent of work that needs to be carried out within the boundary limits to have the expected outcomes. This helps the project team and key stakeholder to be project focused, keep the project on track, within budget, and in control.

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Each phase will have many tasks under them and they are grouped as work breakdown structures

(WBS). Although it’s painstaking process, WBS is a project management tool that adds value in providing;

a) Clarity to the detailed steps to build and deliver a project,

b) Basis for developing a schedule and budget, and

c) Assigns task and holds accountable in its completion.

6.5 Project Scope for In-Situ Decommissioning

The project scope for in-situ decommissioning will include the following tasks under each phase of the project stages:

6.5.1 Pre-Decommissioning Stage - Feasibility - Phase I

Phase I- Feasibility – The following tasks/WBS has been identified for feasibility phase of this pre-decommissioning stage and is planned to be completed in nine months:

 Identify the project manager, project team members, stakeholders including

engineering consultants, contractors, sub-contractors, community members and

regulators from both the federal and provincial agencies.

 Engage stakeholder consultation with both external (the communities, regulators) and

internal (sponsor, operations, maintenance, environment, radiation, safety and

decommissioning project teams).

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 Preparation of the project charter and authorised fund expenditure (AFE) for

feasibility phase. From experience it is learnt obtaining an AFE approval for each

phase of project is beneficial than obtaining AFE approval for the whole project in

one go.

 Carry out project planning, safety and risk assessment for the pre-decommissioning

stage of the AGTMF.

 Carry out literature review and evaluate all the previous studies and drilling

investigations held at AGTMF since its inception to end stage to ensure all site

characterisation is completed for performing a detailed design for the engineered

cover.

 Perform radiation surveys, sampling, and analysis and data management for the

tailings at AGTMF.

 Identify any missing data gaps related to the AGTMF, the underlying tailings

materials and their characterization, the guideline values and the regulatory

compliance for adequately decommissioning.

 Engage external stakeholder consultation to communicate what is the current baseline

from the findings from literature review, surveys and what the missing data gaps are?

Additionally provide information to the external stakeholders what works will be

taken in future to address the concerns.

 Preparation of bids for the selection of consultants for the field investigation and the

detailed engineering of the cover.

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 Consultants to review available data and recommend further field investigations that

may be required to source the missing data gaps.

 Project team to prepare the bids for the selection of contractors for the field

investigations in coordination with the consultants.

 Perform stage gate review (I) with key stakeholders to obtain consent to proceed for

the field investigations based on the initial findings.

 Carry out field investigation to obtain the missing data for the tailing materials within

the AGTMF pertaining to the radiological, non-radiological hazardous constituents,

hydrogeological, geotechnical and geochemical.

 Provide field supervision and analyze the drilling and water sample collected to

ensure site characterization of the tailings materials shed light into the tailings

deposition layers and ice lenses within the AGTMF. Present an overview of the

principal radiological, chemical and physical conditions that currently exist and

identify areas of significant uncertainty

 Identify the existing radioactive and non-radioactive materials stored at AGTMF in

the NW area of east cell within the contaminated waste landfill.

 Recommend measures for their disposal prior to decommissioning of the AGTMF.

 Identify existing utility structures for toe-drain for the seepage beneath the tailings at

AGTMF to the collection wells that will remain part of the in-situ decommissioning.

 Review the existing thawing program to consolidate the tailings mass based on the

outcome of the investigation carried on the tailings stored within the AGTMF.

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Evaluate the thawing program progress made this far and its effectiveness to

consolidate the tailings materials.

 Establish the design criteria for slope stability, geotechnical and hydro-technical.

 Prepare and update the preliminary decommissioning plan as required in the

Regulatory Guide G-219 Decommissioning Planning for Licensed Activities which

includes the following items:

i) Discuss the preferred decommissioning strategy, scope, project boundaries,

and end-state objectives.

ii) Overview of the hazards and protection strategies, an estimate of cost; and the

method(s) of guaranteeing financing for the decommissioning activities).

iii) Plan for the environmental assessment.

iv) Prepare the draft regulatory filing for the selected decommissioning strategy

v) Develop the decommissioning work packages, preliminary schedule, and cost

estimates.

 Engage external stakeholder consultation to communicate the outcome of the field

investigations and thawing program undertaken this far and update on the preliminary

decommissioning plan completed.

 Perform stage gate review (II) with key stakeholders to obtain consent to proceed for

the detailed engineering phase II based on the outcome of the feasibility phase I.

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6.5.2 Pre-Decommissioning - Detailed Engineering –- Phase II

Phase II – Detailed Engineering - The following tasks has been identified for the pre-

decommissioning Phase II – Detailed Engineering and is planned to be completed in 15

months:

 Preparation of the project charter and authorised fund expenditure (AFE) for detailed

engineering phase.

 Perform project planning, safety and risk assessment for the detailed engineering

phase.

 Based on the evaluation of the existing thawing program recommend the future

thawing program required to expedite the consolidation of the tailings materials.

 Perform hydrogeological, hydrological modelling to quantify the seepage.

 Provide analysis and design for an appropriate engineered cap of low infiltration

barrier.

 Design instrumentations required for performance monitoring system for an

engineered cover

 Engage external stakeholder consultation to communicate the outcome of the design

for the thawing program and an engineered cover.

 Perform stage gate review (III) with key stakeholders to present the findings for the

thawing program and an engineered cover.

 Selection of the soil cover materials for placement over the engineered cap to provide

a growth medium for vegetation,

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 Identify the burrow areas suitable for cover materials.

 Design the permanent drainage channels to manage post decommissioned inflows and

surface water management.

 Evaluate the existing structural integrity of the toe-drain structures for the collection

of seepage for its merit for extended future use during the post decommissioning

stage.

 Design the other monitoring instrumentation system for the in-situ decommissioning.

 Carry out the water balance study and the modelling studies.

 Preparation of draft design engineering report

 Review of the draft design engineering report for In-situ Decommissioning by an

independent 3rd party Expert to ensure the design is complete to meet the best

engineering standard practices and the regulatory requirements.

 Preparation of the final design engineering report.

 Preparation of thawing program work packages for bidding.

 Preparation of in-situ decommissioning construction work packages for bidding.

 Engage external stakeholder consultation to communicate the outcome of the final

design for the thawing program and an engineered cover.

 Perform stage gate review (IV) with key stakeholders to present the findings for the

final thawing program and an engineered cover.

 Perform an environmental assessment for the in-situ decommissioning.

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 Complete the draft final decommissioning plan as required in the Regulatory Guide

G-219 Decommissioning Planning for Licensed Activities

 Submit the Draft Decommissioning Plan to CNSC and other regulatory agencies for

review and comments.

 Incorporate comments provided by CNSC, Saskatchewan Environment and other

agencies.

 Submit Final Decommissioning Plan and application to CNSC.

 Engage external stakeholder consultation to communicate the outcome of the

environmental assessment and final decommissioning plan.

 Perform stage gate review (V) with key stakeholders to present the outcome for the

detailed engineering and obtain approval to proceed to next stage and phase.

 Prequalify the bidders to select competent decommissioning contractors for the in-situ

decommissioning works.

 Bidding process for Thawing program - will involve preparation of the bid

documents, verify the bid contents for contractual and legalities, bid announcement

for pre-qualified contractors, bid submission, bid clarifications, bid evaluation and

awarding the bid.

6.5.3 Decommissioning Stage – Thawing Program – Phase III

Phase III - Thawing Implementation - The following tasks has been identified in this

implementation phase for the thawing program which is envisaged for eight years:

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 Preparation of the project charter and authorised fund expenditure (AFE) for thawing

program.

 Project team engagement & award the bids.

 Perform project planning, safety and risk assessment for the thawing program.

 Implement the recommended thawing program (8 Years) to consolidate the tailings

mass based on its outcome of the investigation carried on the tailings stored within

the AGTMF.

 Supervise the thawing program.

 Monitoring the thawing process, progress and its outcome.

 Re-assess the consolidation of the tailings required for placement of an engineered

cover and refine the design if necessary for the cover based on the final results of the

thawing program/consolidation of the tailings mass.

 Engage external stakeholder consultation to communicate the outcome of the thawing

program on yearly basis for thawing program for 8 years.

 Perform stage gate review (VI) with key stakeholders to present the outcome for the

thawing program on a half yearly basis for the 8 year of thawing program (Cameco,

2008).

6.5.4 Decommissioning Stage – In-situ Decommissioning – Phase IV

Phase IV – Implementation of In-situ decommissioning – In-situ decommissioning is by

encapsulating the tailings with an approved engineered cap of low infiltration barrier and this

is the most cost-intensive phase of the project. This will involve the following tasks:

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 Engage external stakeholder consultation to communicate the in-situ

decommissioning as per the decommissioning plan approved by CNSC and other

regulators.

 Preparation of the project charter and authorised fund expenditure (AFE) for the in-

situ decommissioning.

 Perform project planning, safety and risk assessment for the in-situ decommissioning

program.

 Pre-qualify the bidders to select the most competent decommissioning contractor.

 Bidding process will involve preparation of the bid documents, verify the bid contents

for contractual and legalities, bid announcement for pre-qualified contractors, bid

submission, bid clarifications, bid evaluation and awarding the bid.

 Construction management team for supervising the in-situ decommissioning.

 Mob/Demob the decommissioning contractor.

 Removal and disposal of the existing radioactive and non-radioactive materials other

tailings itself from the AGTMF as per approved decommissioning plan.

 Excavate from burrow pits for the approved materials (volume - 884,000 m3) and

haul the materials for the cover placement (Cameco, 2008).

 Install the outwash sand layer (volume - 221,000 m3, thickness-0.3 m) and contour

the surface (Cameco, 2008).

 Engage external stakeholder consultation to communicate the works carried out this

far as per the decommissioning plan approved by CNSC and other regulators

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 Supply and install a Geosynthetic Clay Liner (GCL) for an area of 442,000 m2.

 Install the sand/till over (volume-663,000 m3, thickness - 1.5 m).

 Contour the existing embankment (2660 m3) to fit the cover placement.

 Engage external stakeholder consultation to communicate on the works was carried

out for installing the GCL and sand/till cover.

 Supply rip-rap materials (volume – 50,000 m3) for installing the drainage channels

and drainage chutes (Cameco, 2008).

 Construct surface drains/diversion works (3000 m) both for AGTMF and for the

embankment to provide positive runoff drainage and prevent ponding. The runoffs

will conform to the natural topography.

 Install the survey pins for monitoring settlement.

 Install the permanent drainage channels (volume - 114,000 m3) for surface water

from the AGTMF to the creek including the rehab of the creek, springs and Wolf

Lake.

 Install performance monitoring system for the covers. Includes the monitoring

instrumentation system for the established monitoring and maintenance care system

for the post decommissioning stage

 Hydroseed to establish the vegetative cover. This area will be vegetated by

hydroseeding, tree and shrub planting.

 Rehab/Upgrade the toe drains, sumps for the collection of seepage.

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 Rehab/Upgrade the pumping system for the seepage and supernatant lines to mill

treatment system.

 Submission of the turnover package and QA documents for the in-situ

decommissioning.

 Engage external stakeholder consultation to communicate on the works completed for

the in-situ decommissioning.

 Perform stage gate review (VI1) with key stakeholders to present the outcome for the

in-situ decommissioning program

 Submit the final in-situ decommissioning report.

6.5.5 Post Decommissioning - Monitoring and Maintenance - Phase V

Phase V – Post Decommissioning Activities – This phase will include a well-established periodic monitoring and maintenance care program in compliance with regulatory requirements of both

Federal and Provincial governments. The monitoring system will be primarily cover onsite monitoring for cover system, groundwater and storm water, and offsite surface water, sediment and radiation. These will be monitored periodically to ensure the intended purposes of in-situ decommissioning of the AGTMF are served. All the monitoring systems required for post decommissioning stage will be completed in Phase IV during the implementation of the in-situ decommissioning process. The monitoring and maintenance phase is currently planned for 5 years. However this will be assessed and evaluated at the end of the 5 years for future periods required for monitoring and maintenance care.

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 Engage external stakeholder consultation to communicate on the works that will be

undertaken during the post decommissioning stage during the initial stage and

thereafter an yearly external stakeholder meeting will be held to share the outcome of

the annual reporting on the monitoring and maintenance care.

 Preparation of the project charter and authorised fund expenditure (AFE) for the post-

decommissioning stage comprising of monitoring and maintenance care.

 Perform project planning, safety and risk assessment for the post-decommissioning

phase.

 Site environmental monitoring and analysis for seepage, surface water and

groundwater. This will be carried out on a quarterly basis for 5 year period duration

or as approved in the decommissioning plan.

 Site geotechnical instrumentations monitoring including survey pins for settlements.

This will be carried out on a quarterly basis for 5 year period duration or as approved

in the decommissioning plan.

 Monitor the meteorological instrumentations. This will be carried out on a quarterly

basis for 5 year period duration or as approved in the decommissioning plan.

 Monitor the parameters required for performance monitoring system for the covers

and prepare monitoring reports. This will be carried out on a half yearly basis for 5

year period duration or as approved in the decommissioning plan.

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 Carry out any maintenance required based on the outcome of monitoring reports. This

will be carried out on a yearly basis for 5 year period duration or as approved in the

decommissioning plan.

6.6 Project Management Team for In-Situ Decommissioning

The management of a project involves planning, organising, controlling and directing resources to accomplish a clearly defined objectives (A.Rahman 2008). In a nuclear decommissioning project like the in-situ decommissioning of the AGTMF the demands are more as it requires more careful and diligent management of safety considerations for the protection of workers, public and the environment from both the radiological and non-radiological hazards resulting from the stored AGTMF tailings. Therefore the project management team requires an extensive knowledge and expertise from project planning to managerial skills, financial management, adequate understanding of the nuclear safety and applicable regulations for nuclear related institutions. It is important to understand the required skill sets for the project management team for decommissioning project which is quite different from one for managing other projects.

Therefore the project management team must be staffed with critical skill sets for decommissioning and is not limited to project management, contract management and risk management.

The decommissioning projects are spread for a longer period and is often viewed as multi-year program and not as series of large projects. Hence decommissioning projects are often difficult to manage with extended project durations. In a technically complex work like decommissioning of AGTMF, it is pertinent to get a project team with the right skill set to be involved from the

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very start. From lessons learned, it is recognised that for a successful decommissioning the project team must have a direct line of communication with corporate leadership and a plan in place for some level of continual institutional oversight.

6.6.1 Develop the Project Team

J.Adaira (1999) indicates three criteria that need to be taken into consideration when evaluating potential team members; competence, motivation, and personal traits. A project team fully skilled and qualified for in-situ decommissioning project need to be developed for the in-situ decommissioning project. An in-situ decommissioning project’s success largely depends on when and who makes critical decision for the project success. The success largely depends on the critical decisions that were made from the available data which are complete and accurate. It is a critical requirement to have the project manager and his team involved earlier in the in-situ project and be involved in the decisions even prior to the commencement of the project.

The project manager need to have clear understanding of the strategy of the organization and possess integrity and strong leadership qualities. The project manager requires to take on a much more inclusive role than just managing schedule and identifying risks. Project manager need to have all the authority to manage and work responsibly. The project manager needs to be involved and informed of business decisions made externally on the project. The early involvement of the project manager and his team could positively impact the business decisions by highlighting what the impacts are and how the business decisions for continual changes in the project could have long term huge impact on the project negatively.

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The project management team for the in-situ decommissioning of the AGTMF in minimum will consist of a project manager, project engineer, project planner, project cost controller, project administrator, document controller and a contract administrator.

The design engineering will be performed by design engineering consultants who are skilled in designing similar in-situ decommissioning project. However their deliverable will be reviewed by

Cameco Corporate engineering team and final design engineering report will be reviewed by an independent 3rd party consultant. Cameco Corporate geo-environmental team will provide support on technical related issues on in-situ decommissioning. Additionally Cameco Corporate supply chain management team will provide support in the contracts, procurement and contract administration. The Key Lake Operations will provide support with regard to overall safety, radiation and environmental issues related to the in-situ decommissioning.

The construction management team (CMT) will provide oversight for the construction activities during implementation of the in-situ decommissioning. The CMT will consist of 2 construction managers, 2 construction civil superintendents and 2 QA/QC personnel who will work on 2-week on and 2-week off schedule.

The projectized organization chart for the in-situ decommissioning is presented in Figure 4.1.

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Figure 6.1 Projectized Organization Chart for In-Situ Decommissioning

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6.7 Project Schedule for In-Situ Decommissioning

The project schedule is an important tool that assists in improving project team communication, collaboration and effectiveness in managing projects and resources effectively and this requires engaging all the team members in developing the schedule. This provides an opportunity for each team member to become more invested and accountable to the project milestones.

The scope for the in-situ decommissioning is clearly mentioned in Section 6.3 and this provides adequate information for the activities for preparing a schedule. A project schedule maps the in- situ decommissioning activities and sequences it with a generic maturity and quality matrix for in- situ decommissioning activities of the AGTMF. Based on the dependencies between the activities and the duration estimates, a project schedule can be developed for the in-situ decommissioning of AGTMF. The basic aim of the project schedule is to put the activities together in a way that is easy to understand and is effective for monitoring and control.

The schedule must reflect the same WBS elements used in the cost estimates and needs to be integrated as to the period of performance as well as the resources required to accomplish the project on the desired schedule. The scheduling method utilised here is top down planning using key project events, high level milestones and is semi detailed. The degree of project definition utilised here is 1% to 15%. The levels of project definition used for classifying schedules correspond to the typical phases and stage gates for evaluation, authorization, and execution by the project key decision makers during a project life cycle. The overall preliminary schedule for in-situ decommissioning of the AGTMF as bar charts is presented in Table 6.1. Separate schedule bar charts for each of the phases is presented from Table 6.2 to 6.6.

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Table 6.1 Overall Preliminary Schedule for In-Situ Decommissioning of AGTMF

PRELIMINARY SCHEDULE ESTIMATE FOR YEAR AGTMF IN-SITU DECOMMISSIONING Item STAGE PHASE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 No. Pre- 1.0 Phase 1 - Feasibility Decommissioning

Pre- Phase II - Detailed 2.0 Decommissioning Engineering

Phase III - Thawing 3.0 Decommissioning Program

Phase IV - In-situ Cover 4.0 Decommissioning Placement

Post- Phase V - Monitoring, 5.0 Decommissioning Maintenance & Care

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Table 6.2 Preliminary Schedule for Feasibility Phase I of AGTMF

PRELIMINARY SCHEDULE ESITMATE FOR IN-SITU DECOMMISSIONING Months FEASIBILITY - PHASE I Equipment /Materials/ Item No. Work Break Down Structure Description Units Quantity Jan Feb Mar Apr May Jun Jul Aug Sep Labour

1.0 PRELIMINARY SCHEDULE ESTIMATE FOR PRE-DECOMMISSIONING STAGE - PHASE I - FEASIBILITY PHASE - 9 MONTHS

Selection of the Project Team and organise the project Project Manager 1.1 month 2 activities Project Engineer Community 1.2 Engage external stakeholder consultation day 1 Stakeholder/Regulators ◊ Preparation of Project Charter and Authorized Fund 1.3 Project Team month 1.5 Expenditure for Pre-Decommissioning Stage

1.4 Project Planning and Risk Assessment Project Team month 1.5

1.5 Carry out Literature Review Project Engineering Team month 1.5

Perform radiation surveys, sampling, analysis and data 1.6 Project Team month 1.5 management for site characterization Identify missing data gaps & areas of significant 1.7 Project Team month 1 uncertainty. Community 1.8 Engage external stakeholder consultation day 1 Stakeholder/Regulators ◊

1.9 Prepare bids & selection for consultants Project Team month 1.5

Consultants to review available data and recommend field 1.1 Consultants month 1 investigations Project Team & 1.11 Prepare bids for selection of contractor month 1.5 Consultants Key Stakeholders & 1.12 Stage Gate Review - I day 1 Project Team ◊

Carry out field investigation for site characterization and obtain missing data pertaining to the radiological, non- 1.13 Contractor month 3 radiological hazardous constituents, topographic surveys, hydrogeological, geotechnical and geochemical

Consultant & Project 1.14 Field Supervision & Analyse the field investigations month 3 Engineering Team Identify the existing radioactive and non radioactive Consultant & Project 1.15 month 0.5 materials stored at AGTMF Engineering Team Recommend measures for their disposal prior to Consultant & Project 1.16 month 0.5 decommissioning of the AGTMF. Engineering Team Consultant & Project 1.17 Identify existing utility structures within the AGTMF month 0.5 Engineering Team Consultant & Project 1.18 Review and evaluate the existing thawing program month 1.5 Engineering Team Establish the design criteria for slope stability, geotechnical Consultant & Project 1.19 month 0.5 and hydro-technical Engineering Team Consultant & Project 1.2 Update the preliminary decommissioning plan and report month 1.5 Engineering Team Community 1.21 Engage external stakeholder consultation day 1 Stakeholder/Regulators ◊ Key Stakeholders & 1.22 Stage Gate Review -II day 1 Project Team ◊

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Table 6.3 Preliminary Schedule for Detailed Engineering Phase II of AGTMF

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Table 6.4 Preliminary Schedule for Thawing Program Phase III of AGTMF

PRELIMINARY SCHEDULE ESITMATE FOR IN-SITU DECOMMISSIONING YEAR THAWING PROGRAM - PHASE III Equipment Work Break Down Structure Item No. /Materials/ Units Quantity 1 2 3 4 5 6 7 8 Description Labour

3A PRELIMINARY SCHEDULE ESTIMATE FOR DECOMMISSIONING STAGE - PHASE 11I - THAWING PROGRAM - 8 YEARS

Preparation of Project Charter and 3A.1 Authorized Fund Expenditure for Thawing Project Team month 1 Program Project Team Engagement & Awarding the 3A.2 Project Team month 1 Bids

3A.3 Project Planning and Risk Assessment Project Team month 1

Implement the recommended thawing 3A.4 Contractor year 8 program

3A.5 Project & Operations Management (8 yrs) Project & Ops month 96

Monitoring the thawing process, progress and Project 3A.6 Quarterly 32 its outcome Engineering Team ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

3A.7 Re-assess the consolidation of the tailings Consultant yearly 8 ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

Community Engage external stakeholder 3A.8 Stakeholder/ yearly 8 ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ consultation Regulators

Key Stakeholders half 3A.9 Stage Gate Review -VI 16 & Project Team yearly ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

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Table 6.5 Preliminary Schedule for In-Situ Decommissioning Phase IV AGTMF

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Table 6.6 Preliminary Schedule for Post Decommissioning of AGTMF

PRELIMINARY SCHEDULE ESITMATE FOR IN-SITU DECOMMISSIONING YEAR MONITORING & MAINTENANCE - PHASE V Equipment /Materials/ Item No. Work Break Down Structure Description Units Quantity 1 2 3 4 5 Labour

4.0 PRELIMINARY SCHEDULE ESTIMATE FOR POST DECOMMISSIONING STAGE - PHASE V - MONITORING & MAINTENANCE - 5 Years

External & Internal 4.1 Engage external stakeholder consultation Stakeholders - Each one Day 10 ◊ ◊ ◊ ◊ ◊ day/year

Preparation of Project Charter and Authorized Fund 4.2 Project Team month 1 Expenditure for Monitoirng and Maintenance

4.3 Project Planning and Risk Assessment Project Team month 1

Site environmental monitoring and analysis for 4.4 PMT & Env Dept Quarterly 20 seepage, surface water and groundwater ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

Site geotechnical instrumentations monitoring including 4.5 Operations Env Dept Quarterly 20 survey pins for settlements. ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

4.6 Monitor the meterological instrumentation Operations Env Dept Quarterly 20 ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊

Monitor the parameters required for performance half 4.7 monitoring system for the covers and prepare Consultant 10 yearly ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ ◊ monitoring reports.

Carry out any maintenance required based on the Contractor & Project 4.8 yearly 5 outcome of monitoring reports. Management

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6.8 Project Cost Estimates for In-Decommissioning

The cost estimating is described as the “predictive process used to quantify, cost, and price the resources required by the scope of an asset investment option, activity, or project” (ACE

International). A good cost estimate need to be credible, well-documented, accurate and comprehensive. The Department of Energy formulated a 12 key essential steps to produce a high quality cost estimates and are as follows (Department of Energy, USA):

1. Define the estimate’s purpose

2. Develop an estimating plan

3. Define the Project (or Program) characteristics

4. Determine the estimating structure [e.g., Work Breakdown Structure (WBS)]

5. Identify ground rules and assumptions

6. Obtain data

7. Develop a point estimate and compare to an independent cost estimate

8. Conduct sensitivity analysis

9. Conduct risk and uncertainty analysis

10. Document the estimate

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11. Present the estimate for management approval

12. Update the estimate to reflect actual costs and changes

For the purpose of estimating for decommissioning of the AGTMF the project team will require to carry out the above steps and follow a plan for preparing an appropriate cost estimate. This will include and is not limited to defining the purpose of estimation, integrating the teams members for active participation in preparing estimates, defining the scope and identifying the individual tasks for decommissioning, engaging stakeholders for the scope review and approval, creating work breakdown structures (WBS) as detailed as possible. This allows a provision to refine them as the work proceed and more defined, and gathering historical data from similar works directly related to the scope’s performance characteristics must be sought wherever possible to benefit this project and allow provision of mitigation cost for any uncertainties and risk in the project.

An activity based or detailed cost estimates is used to arrive at the preliminary Class 3 cost estimates for estimate. This is based and depends on the accuracy of available information for the decommissioning activities for the AGTMF. The decommissioning activities for the AGTMF is well defined and broken down into manageable pieces of work as work breakdown structures

(WBS). Each WBS is task oriented detailed items of work/tasks to be performed. This is further broken down as labor hours, material costs, equipment costs, and other costs that are itemized and quantified. The WBS is the primary planning and analysis tool as it addresses two issues related to any projects; what is to be accomplished and what is the necessary hierarchical relationship of work effort? (A.Rahman, 2008).

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The preliminary estimate may be revised as known details are refined. The activity based detailed cost estimates allows to be monitored and report the performance accurately. The quantities provide the basis for an earned value measurement of the work within the activities and the WBS.

Some of the benefits an activity-based detailed cost estimating method provides are: greater level of confidence, better monitoring, facilitates change control, provides more accurate metrics and better resource basis for schedule. The disadvantage include more time required to develop the estimates and therefore it is costly.

For the ease of planning, managing and control of the AGTMF decommissioning cost, the project is categorised and broken into different stages and phases.

a. The pre-decommissioning stage consist of 2 phases – Feasibility Phase I and

Detailed Design Phase II.

b. The decommissioning implementation stage consist of 2 Phases – Thawing

Program Phase III and In-situ decommissioning Phase IV.

c. And finally is the post decommissioning stage which consist of the Monitoring and

Maintenance Phase V.

d. The last cost component added is the miscellaneous cost for flights,

accommodation, fuel supplies, safety and training and general supplies which is

spread throughout the decommissioning project.

e. A contingency of 15% is included in the preliminary cost estimates for each of the

tasks.

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The preliminary cost estimate summary for decommissioning for the AGTMF is presented in the

Figure 6.1 and Table 6.7. The detailed cost breakdown for the AGTMF is presented in Table 6.8.

The major cost components included for the AGTMF decommissioning are data collection, investigations, staffing, cover installations, equipment, materials and other costs as detailed in

Table 6.8 for each of the activities. The activities that impact costs are analysed based on similar decommissioning experiences. For the preliminary cost estimates, efforts are taken to understand the major components and technical factors that impact the decommissioning cost estimates. These insights to the activities is gathered from available data from previous similar completed and ongoing decommissioning projects in Canada and internationally. This includes preliminary studies undertaken by Cameco Corporation for the Key Lake AGTMF since 1996.

From the Table 6.7 it is understood that the major costs categories for decommissioning of

AGTMF are during the decommissioning implementation stage (79.33%) which includes the thawing program phase (21.96%) and in-situ decommissioning phase (57.38%). The remaining cost (20.67%) is for feasibility (3.79%), detailed design (3.11%), monitoring and maintenance

(5.92%) and miscellaneous expenses (7.84%).

The miscellaneous expenses for the in-situ decommissioning will include the cost for the safety training, fuel supplies, general supplies, transportation, flights and site accommodation for the in- situ decommissioning project. The total miscellaneous expenses for the project of $3,750,000 will be broken down for each phase as follows:

 Pre-Decommissioning Stage - Feasibility - Phase I - $1,810,200

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 Pre-Decommissioning Stage – Detailed Engineering - Phase II - $1,488.400

 Decommissioning Stage – Thawing Program –Phase III - $10,498,400

 Decommissioning Stage – In-Situ Decommissioning – Phase IV - $27,435,300

 Post-Decommissioning Stage – Monitoring and Monitoring – Phase V - $2,832,800

 Miscellaneous Expense - $3,750,000.

Obtaining a detailed cost breakdown for similar type of in-situ decommissioning project was not available probably due to confidentiality considerations and the preliminary cost estimates for each of the activities is generally based on the construction works carried out at Key Lake Operations

Cameco Rabbit Lake and other northern artic regions. This was estimated involving discussions with the construction management team at Cameco Key Lake Operations and hence the specific rates for earthworks relates to the Key Lake site.

The decommissioning activities have been based on previous similar studies undertaken for the decommissioning of the mill and mine tailings. However this thesis has particularly emphasized the importance of including stakeholder’s consultation as an ongoing process during all the decommissioning stages of the AGTMF. Another important component that is added on is the stage gate process at different stages and phases of the decommissioning project. Both the stakeholder consultation and stage gate components are of primary importance to the decommissioning project as it is recognised as an important tool for communications for getting stakeholder consensus all through as the project proceeds and for decision making process. The key stakeholders includes the regulatory authorities both federal and provincial, community,

Cameco Corporate Leaders and Key Lake Operations management and the project team. 140

Figure 6.2: Preliminary Cost Estimates for Each Phase of AGTMF Decommissioning

Preliminary Cost Estimates (CAD$ Millions) for Each Phase

Miscellaneous Expenses

Monitoring and Maintenance-Phase V

In-situ Decommissioning-Phase IV

Thawing Program-Phase III

Detailed Engineering - Phase II

Feasibility-Phase I

$- $5 $10 $15 $20 $25 $30 MILLIONS

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Table 6.7 Summary of Preliminary Cost Estimates for Each Stage & Phase of Decommissioning of AGTMF

PRELIMINARY COST ESTIMATES FOR IN-SITU DECOMMISSIONING - ABOVE GROUND TAILINGS MANAGEMENT FACILITY

Item Stage Phase Years/Month Duration Total Cost No.

1.0 Pre-Decommissioning Stage Feasibility-Phase I Months 9 $ 1,810,200

2.0 Pre-Decommissioning Stage Detailed Engineering - Phase II Months 15 $ 1,488,400

3A Decommissioning Implementation Stage Thawing Program-Phase III Years 8 $ 10,498,400

3B Decommissioning Implementation Stage In-situ Decommissioning-Phase IV Years 3 $ 27,435,300

4.0 Post Decommissioning Stage Monitoring and Maintenance-Phase V Years 5 $ 2,832,800

5.0 Miscellaneous Expenses $ 3,750,000

GRAND TOTAL $ 47,815,100

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Table 6.8 Preliminary Cost Estimates for In-Situ Decommissioning of AGTMF

PRELIMINARY COST ESTIMATES FOR IN-SITU DECOMMISSIONING - ABOVE GROUND TAILINGS MANAGEMENT FACILITY

Equipment Item Work Break Down Structure Description /Materials/ Units Quantity Unit Cost Cost Total Cost No. Labour

1.0 Pre-Decommissioning Stage - Feasibility-Phase I

Selection of the Project Team and organise Project Manager 1.1 month 2 $ 50,400 $ 100,800 $ 100,800 the project activities Project Engineer External 1.2 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Preparation of Project Charter and 1.3 Authorized Fund Expenditure for Feasibility Project Team month 1.5 $ 50,400 $ 75,600 $ 75,600 Phase Project Planning, Safety and Risk 1.4 Project Team month 1.5 $ 50,400 $ 75,600 $ 75,600 Assessment Project 1.5 Carry out Literature Review Engineering month 1.5 $ 66,400 $ 99,600 $ 99,600 Team Perform radiation surveys, sampling, 1.6 analysis and data management for site Project Team month 1.5 $ 38,400 $ 57,600 $ 57,600 characterization Identify missing data gaps & areas of 1.7 Project Team month 1 $ 38,400 $ 38,400 $ 38,400 significant uncertainty. External 1.8 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders 1.9 Prepare bids & selection for consultants Project Team month 1.5 $ 50,400 $ 75,600 $ 75,600

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Consultants to review available data and 1.10 Consultants month 1 $ 44,000 $ 44,000 $ 44,000 recommend field investigations Project Team & 1.11 Prepare bids for selection of contractor month 1.5 $ 44,000 $ 66,000 $ 66,000 Consultants Key Stakeholders 1.12 Stage Gate Review - I day 1 $ 15,000 $ 15,000 $ 15,000 & Project Team Carry out field investigation for site characterization and obtain missing data pertaining to the radiological, non- 1.13 Contractor month 3 $ 250,000 $ 750,000 $ 750,000 radiological hazardous constituents, topographic surveys, hydrogeological, geotechnical and geochemical Consultant & Field Supervision & Analyse the field Project 1.14 month 3 $ 44,000 $ 132,000 $ 132,000 investigations Engineering Team Consultant & Identify the existing radioactive and non- Project 1.15 month 0.5 $ 44,000 $ 22,000 $ 22,000 radioactive materials stored at AGTMF Engineering Team Consultant & Recommend measures for their disposal prior Project 1.16 month 0.5 $ 44,000 $ 22,000 $ 22,000 to decommissioning of the AGTMF. Engineering Team Consultant & Identify existing utility structures within the Project 1.17 month 0.5 $ 44,000 $ 22,000 $ 22,000 AGTMF Engineering Team Consultant & Review and evaluate the existing thawing Project 1.18 month 1.5 $ 44,000 $ 66,000 $ 66,000 program Engineering Team

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Consultant & Establish the design criteria for slope Project 1.19 month 0.5 $ 44,000 $ 22,000 $ 22,000 stability, geotechnical and hydro-technical Engineering Team Consultant & Update the preliminary decommissioning Project 1.20 month 1.5 $ 44,000 $ 66,000 $ 66,000 plan Engineering Team External 1.21 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Key Stakeholders 1.22 Stage Gate Review -II day 1 $ 15,000 $ 15,000 $ 15,000 & Project Team

1.23 Sub-Total $ 1,810,200

Pre-Decommissioning Stage- 2.0 Detailed Engineering - Phase II Preparation of Project Charter and 2.1 Authorized Fund Expenditure for Detailed Project Team month 1.5 $ 50,400 $ 75,600 $ 75,600 Engineering Phase Project Planning, Safety and Risk 2.2 Project Team month 1 $ 30,000 $ 30,000 $ 30,000 Assessment Consultant & Design thawing program to expedite the Project 2.3 month 1.5 $ 56,800 $ 85,200 $ 85,200 consolidation of the tailings materials Engineering Team Consultant & Perform Hydrogeological & Hydrogeological Project 2.4 month 2 $ 56,800 $ 113,600 $ 113,600 Modelling to quantify the seepage. Engineering Team Design an appropriate engineered cap of low Consultant & 2.5 infiltration barrier including the cover month 2 $ 56,800 $ 113,600 $ 113,600 Project analysis.

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Engineering Team Consultant & Design an instrumentations required for Project 2.6 performance monitoring system for an month 1 $ 56,800 $ 56,800 $ 56,800 Engineering engineered cover. Team External 2.7 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Key Stakeholders 2.80 Stage Gate Review -III day 1 $ 15,000 $ 15,000 $ 15,000 & Project Team Consultant & Project 2.9 Selection of the soil cover materials month 0.5 $ 56,800 $ 28,400 $ 28,400 Engineering Team Consultant & Identify the burrow areas suitable for cover Project 2.10 month 0.5 $ 56,800 $ 28,400 $ 28,400 materials Engineering Team Consultant & Project 2.11 Design the permanent drainage channels month 0.5 $ 56,800 $ 28,400 $ 28,400 Engineering Team Consultant & Evaluate the existing structural integrity of Project 2.12 month 0.5 $ 56,800 $ 28,400 $ 28,400 the toe-drain structures and collection sumps. Engineering Team Consultant & Design the other monitoring instrumentation Project 2.13 month 1 $ 56,800 $ 56,800 $ 56,800 system Engineering Team Carry out the water balance study and Consultant & 2.14 month 1.5 $ 56,800 $ 85,200 $ 85,200 modelling Project

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Engineering Team Consultant & Preparation of Draft Design Engineering Project 2.15 month 1 $ 56,800 $ 56,800 $ 56,800 Report Engineering Team Review by an independent 3rd party expert Independent 2.16 the Design Engineering for In-situ 0.5 $ 56,800 $ 28,400 $ 28,400 Consultant Decommissioning Consultant & Preparation of Final Design Engineering Project 2.17 0.5 $ 56,800 $ 28,400 $ 28,400 Report Engineering Team Consultant & Preparation of thawing program construction Project 2.18 month 0.5 $ 56,800 $ 28,400 $ 28,400 work packages for bidding. Engineering Team Consultant & Preparation of in-situ decommissioning Project 2.19 month 1 $ 56,800 $ 56,800 $ 56,800 construction work packages for bidding. Engineering Team External 2.2 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Key Stakeholders 2.21 Stage Gate Review - IV day $ 1 $ 15,000 $ 15,000 $15,000 & Project Team Consultant & Project 2.22 Perform an environmental assessment month 2.5 $ 56,800 $ 142,000 $ 142,000 Engineering Team Complete the draft final decommissioning 2.23 Project Team month 1.5 $ 66,400 $ 99,600 $ 99,600 plan

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Submit the Draft Decommissioning Plan to CNSC & Sask 2.24 month 2 $ 15,000 $ 30,000 $ 30,000 CNSC and other regulatory agencies Environment Incorporate comments provided by CNSC, 2.25 Saskatchewan Environment and other Project Team month 1 $ 66,400 $ 66,400 $ 66,400 agencies Submit Final Decommissioning Plan and 2.26 CNSC month 1 $ 15,000 $ 15,000 $ 15,000 application to CNSC External 2.27 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Key Stakeholders 2.28 Stage Gate Review- V day 1 $ 15,000 $ 15,000 $ 15,000 & Project Team Prequalify the bidders to select competent 2.29 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 decommissioning contractors 2.30 Bidding process for Thawing program Project Team month 0.75 $ 66,400 $ 49,800 $ 49,800

2.31 Sub-Total $ 1,488,400

3A Decommissioning Stage -Thawing Program-Phase III (8 years)

Preparation of Project Charter and 3A.1 Authorized Fund Expenditure for Thawing Project Team month 1 $ 66,400 $ 66,400 $ 66,400 Program Project Team Engagement & Awarding the 3A.2 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 bids Project Planning, Safety and Risk 3A.3 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 Assessment Implement the recommended thawing 3A.4 Contractor year 8 $ 500,000 $ 4,000,000 $ 4,000,000 program 3A.5 Project & Operations Management (8 yrs) Project & Ops month 96 $ 35,000 $ 3,360,000 $ 3,360,000

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Project Monitoring the thawing process, progress 3A.6 Engineering Quarterly 32 $ 66,400 $ 2,124,800 $ 2,124,800 and its outcome Team 3A.7 Re-assess the consolidation of the tailings Consultant yearly 8 $ 56,800 $ 454,400 $ 454,400 External 3A.8 Engage stakeholder consultation day 8 $ 15,000 $ 120,000 $ 120,000 Stakeholders Key Stakeholders half 3A.9 Stage Gate Review -VI 16 $ 15,000 $ 240,000 $ 240,000 & Project Team yearly

3A.10 Sub-Total $10,498,400

3B Decommissioning Stage -In-situ Decommissioning-Phase IV (3 years)

External 3B.1 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Preparation of Project Charter and 3B.2 Authorized Fund Expenditure for In-situ Project Team month 1.5 $ 66,400 $ 99,600 $ 99,600 Decommissioning Stage Project Planning, Safety and Risk 3B.3 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 Assessment Prequalify the bidders to select competent 3B.5 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 decommissioning contractors 3B.6 Bidding process & Award Project Team month 3 $ 66,400 $ 199,200 $ 199,200 3B.4 PMT & CMT team for Supervision Project Team month 30 $ 123,200 $ 3,696,000 $ 3,696,000 Mob/Demob the Decommissioning 3B.7 Contractor month 1 $ 800,000 $ 800,000 $ 800,000 Contractor Removal & Disposal of the existing 3B.8 radioactive and non-radioactive materials Contractor month 1.5 $ 200,000 $ 300,000 $ 300,000 other than tailings itself from the AGTMF

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Excavate Burrow Pits the Approved 3B.9 Materials for the Cover (Excavate & Haul - Contractor m3 884,000 $ 9 $ 7,956,000 $ 7,956,000 12 months) 3B.10 Install the outwash sand layer - 5 months Contractor m3 221,000 $ 3.00 $ 663,000 $ 663,000 External 3B.11 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Supply & install a Geosynthetic clay liner 3B.12 Contractor m2 442,000 $ 8 $ 3,536,000 $ 3,536,000 (GCL) -3 months 3B.13 Install the sand/till cover -9 months Contractor m3 663,000 $ 3 $ 1,816,620 $ 1,816,620 Contour the existing embankment to fit the 3B.14 Contractor m3 2660 $ 8 $ 21,280 $ 21,280 cover placement - 2 months External 3B.15 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Supply rip-rap materials for installing the 3B.16 Contractor m3 50,000 $ 60 $ 3,000,000 $ 3,000,000 drainage channels and drainage chutes. Construct surface drains/ diversion works 3B.17 Contractor m 3000 $ 30 $ 90,000 $ 90,000 both for AGTMF and for the embankment. 3B.18 Install the survey pins for monitoring Contractor LS 1.0 $ 70,000 $ 70,000 $ 70,000 Install the permanent drainage channels for surface water from the AGTMF to the Creek 3B.19 Contractor m3 114,000 $ 30 $ 3,420,000 $ 3,420,000 including the rehab of the creek, springs and lake. Install performance monitoring system for 3B.20 Contractor LS 1 $ 250,000 $ 250,000 $ 250,000 the covers 3B.21 Hydroseed to establish the vegetative cover Contractor acre 128 $ 2,750 $ 352,000 $ 352,000 LS

Rehab/Upgrade the toe drains, sumps for 3B.22 Contractor 1 $ 250,000 $ 250,000 $ 250,000 collection of seepage.

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Rehab/Upgrade the pumping system for the 3B.23 seepage and supernatant lines to mill Contractor LS 1 $ 500,000 $ 500,000 $ 500,000 treatment system. Submission of Turnover Package & QA 3B.24 documents for the In-situ Decommissioning Contractor month 1 $ 75,000 $ 75,000 $ 75,000 Phase IV External 3B.25 Engage stakeholder consultation day 1 $ 15,000 $ 15,000 $ 15,000 Stakeholders Key Stakeholders 3B.26 Stage Gate Review-VII day 1 $ 15,000 $ 15,000 $ 15,000 & Project Team Submission of the Final In-Situ 3B.27 Project Team month 2 $ 66,400 $ 132,800 $ 132,800 Decommissioning Report

3B.28 Sub-Total $27,435,300

4.0 Post Decommissioning-Monitoring and Maintenance-Phase V (5 Years)

External & One day/ 4.1 Engage stakeholder consultation Internal 10 $ 15,000 $ 150,000 $ 150,000 year Stakeholders Preparation of Project Charter and 4.2 Authorized Fund Expenditure for Monitoring Project Team month 1 $ 66,400 $ 66,400 $ 66,400 and Maintenance Project Planning, Safety and Risk 4.3 Project Team month 1 $ 66,400 $ 66,400 $ 66,400 Assessment

Site environmental monitoring and analysis 4.4 PMT & Env Dept Quarterly 20 $ 45,000 $ 900,000 $ 900,000 for seepage, surface water and groundwater

Site geotechnical instrumentations Operations Env 4.5 monitoring including survey pins for Quarterly 20 $ 5,000 $ 100,000 $ 100,000 Dept settlements.

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Operations Env 4.6 Monitor the meteorological instrumentation Quarterly 20 $ 5,000 $ 100,000 $ 100,000 Dept Monitor the parameters required for half 4.7 performance monitoring system for the Consultant 10 $ 20,000 $ 200,000 $ 200,000 yearly covers and prepare monitoring reports. Contractor & Carry out any maintenance required based on 4.8 Project yearly 5 $ 250,000 $ 1,250,000 $ 1,250,000 the outcome of monitoring reports. Management

4.9 Sub-Total $ 2,832,800

5.0 Miscellaneous Expenses

5.1 Safety & Training LS 1 $ 500,000 $ 500,000 $ 500,000 5.2 Fuel Supplies LS 1 $ 750,000 $ 750,000 $ 750,000 5.3 General Supplies LS 1 $ 500,000 $ 500,000 $ 500,000 5.4 Transportation LS 1 $ 500,000 $ 500,000 $ 500,000 5.5 Flight & Site Accommodation LS 1 $ 1,500,000 $ 1,500,000 $ 1,500,000

5.6 Sub-Total $ 3,750,000

5.7 GRAND TOTAL $47,815,100

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6.8.1 Assumptions for Project Schedule & Cost Estimates

The following assumptions have been made for the in-situ decommissioning of the AGTMF:

1. The proposed in-situ decommissioning plan will be approved by the regulatory agencies and

the funds will be available to complete the in-situ decommissioning of the AGTMF as per the

approved decommissioning plan.

2. The scenario considered for decommissioning is that Canadian regulatory authorities (CNSC

and Saskatchewan Environment) is requesting Cameco Corporation to pursue immediately

the proposed in-situ decommissioning of the AGTMF.

3. The in-situ decommissioning will include a full decommissioning project life cycle i.e., a

feasibility phase, detailed design phase, thawing program phase, implement in-situ

decommissioning phase and monitoring and maintenance phase.

4. The final end state expected is to meeting the objectives of the decommissioning of AGTMF

including cease permanently any release of contaminants and seepage from the AGTMF

tailings to the environment.

5. No major changes are anticipated in the current environmental regulations regarding the

decommissioning of the AGTMF.

6. The scope for the in-situ decommissioning is well defined although it is preliminary and

heading towards feasibility phase, the estimates provided herein is AACE Class 3 Cost

estimates.

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7. The quantities for construction phase are currently taken from previous studies carried out by

Cameco and these will be revised accordingly based on the outcome of pre-decommissioning

stages including the feasibility and detailed design phase.

8. The cost estimates is based on pursuing a full project life cycle for the in-situ

decommissioning the AGTMF which will include a feasibility phase, detailed design phase,

thawing program phase, implement in-situ decommissioning phase and monitoring and

maintenance phase.

9. The decommissioning of the AGTMF will have a staged approach and based on the outcome

of stakeholder consultation and stage gate approvals at each stage the project will proceed to

the next stage incorporating any approved changes.

10. The pre-decommissioning stage will have a feasibility study that will take 9 months and a

detailed design study that will take15 months to complete.

11. It is anticipated that no pilot studies or field studies will be required for in-situ cover

decommissioning hence the cost for pilot studies and field studies are not included in these

cost estimates but if this is required from the outcome of the feasibility and detailed design

studies this will be included as a change order.

12. It is assumed that 8 years will be required to thaw the ice within the AGTMF tailings based

on previous studies/investigations carried out at AGTMF Cameco.

13. The in-situ decommissioning is assumed to be completed in 3 years considering the short

construction season and long winter season.

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14. The monitoring and maintenance is proposed initially for 5 years from the period the in-situ

decommissioning is completed. Further monitoring and maintenance will be evaluated based

on the results obtained from the 5 year monitoring and maintenance period.

15. It is assumed that all the approved materials (sand, till and rip-rap materials) for the backfill

cover, drainage channels, and embankments will be available from burrow pits within Key

Lake Lease or vicinity area.

16. The preliminary cost estimates does not account for any economic escalation cost that may

arise considering the long duration of the project especially with 8 years of thawing program

prior to in-situ decommissioning of AGTMF.

17. The construction escalation cost is excluded however the preliminary cost estimates is will be

required to be revisited and updated prior to advancing at each stage of the project.

18. A 15% contingency is included in the preliminary cost estimate for each of the tasks.

19. Separate miscellaneous expenses for each phase is estimated depending on the tasks each

phase entails.

20. The construction will be carried out during the construction season will be from May to late

September or early October.

21. The in-situ decommissioning work will be done by competent contractors on a 14-day in, 14-

day out rotation.

22. The current camp residence will be available to the contractor employees.

23. During all the phases of the in-situ decommissioning, it is deemed all safety, environmental

and radiation assistance will be provided by the Key Lake Operations team.

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6.9 Project Controls for Decommissioning

The objective is to provide a practical approach to manage cost controls for the decommissioning of the AGTMF to minimise project budget and schedule over-runs. An important tool recognised to minimise project budget and schedule overruns is through cost controls using an earned value management systems (EVMS). Through monitoring, analysing, reporting and exercising controls over the schedules, commitments and expenditures a reliable cost control will be achieved.

The WBS defines the scope of work into appropriate elements for cost accounting and work package authorisation. Thus the WBS is the foundation of the EVMS cost control system. A control account identifies a defined works scope from the WBS system, with accounting charge numbers to track costs. The control account is where the project cost, schedule, resources and work scope are integrated, planned and managed by the project cost controllers for the project manager.

A well-established project control system for decommissioning project will be beneficial to manage resources (both manpower and equipment) and accommodate project constraints on budget and schedule. Additionally having a well-established project controls system is required for performance measurement where budget and schedule performance data can be obtained for reporting the progress assessment to senior management and understand whether the project is delivering to meet the project objectives.

6.10 Project Quality Management

The quality program for a project should commence at the early stages of the project and is continuous and runs through all the stages of the project. The quality management is a requirement to ensure accomplishment of the project objectives. The quality management for project should

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cover all aspects of the project and will not be limited to procurement control, document control, control of purchases, handling and storage, inspection, corrective actions, QA records and audits.

The quality control (QC) monitoring process ensures the standards required are met in compliance with the Cameco’s quality policy and project contract specifications. These will help to eliminate causes for unsatisfactory performance. The project team members responsible for construction activities related to the in-situ decommissioning will observe the performance of the contractor’s workmanship and the quality of materials used while comparing it to the standards specified and taking necessary actions to correct any deviation. Vigilant quality control measures and oversight will prevent increased cost from construction interruptions and rework due to corrective actions.

Some of the quality control tools the project management team will use include inspections, testing, control charts, trend analysis and flow charts.

6.11 Project Communication System

Project communication system is critical for success of any projects especially in large size projects where large teams are isolated from other teams and communicate knowledge and information only within their team. These communication system aids in managing key communications channels to keep the project on time and on track and this depends upon a set of crucial communication skills and techniques. It is the communication and human interaction that make or break a project. The objective of project communication system is to communicate the messages regarding the in-situ decommissioning process of the AGTMF during the various stages and phases of the project.

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Jerzy K (2011) indicates that a strong co-operation as well as knowledge and information transfer between team members leads to no artificial barriers where each team member was or could be a team leader depending on the need and situation. This will create condition conducive to the seamless flow of knowledge between project participants and strengthen the team’s synergy whereby an effective communication system is built in addition to developing mutual trust within the team. Additionally PMBOK (2013) stresses on greater consistency on project data information.

Some of the important factors for communication are how the project will be managed, including how the information will flow into and out of the project. It is key responsibility of the project manager to provide regular and consistent feedback such as progress status reports, issue logs, risk logs, meeting notes and where project information could be found for the team members to do their task. It is important to foster openness and transparency in communication system. The key to successful communication is to keep information flowing in the right directions and at the same time to refrain from allowing too much communications to flow that could hamper the amount of work that gets done.

The communication system for the in-situ decommissioning project will include a communication strategy, kick off meeting, roles and responsibility of the project team members, progress reports, project status meetings and frequency of such meetings, change control communications, project review meeting, stage gate meetings during transition from each stage and phase of the in-situ decommissioning project, and closure meeting. One important communication management strategy is the phase-gate approach/stage gate approach, where the project is broken down into a number of phases along a timeline. Stage gates are set control points to make decisions to proceed

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next phase of the project. This is an important tool to ensure all conditions are met before proceeding to next phase/stage and, it empowers the management to make a decision whether to cancel/rework or seek new approval or provide funding for the next phase/stage.

6.12 Managing Stakeholders

Jeffrey Donaldson quotes, “In the past, decommissioning as a process has been shrouded in secrecy and if we are to increase public confidence in the process then we want it to be more transparent”. This is critical to head off any major issues or problems. Managing stakeholders helps the project team to better understand those who will be affected by the project. Managing stakeholder through public engagement/consultation form an important tool for project communication system in addressing their issues and problems. The more the stakeholders are engaged the more the risk is minimised by unfolding the potential impacts.

Engaging the stakeholders provide a better understanding of the in-situ decommissioning processes and how it ensures protection of workers and the public during the entire in-situ decommissioning process. This is very critical because the impacts from in-situ decommissioning of AGTMF need to be vetted within the stakeholders including the local community. The stakeholder management will enhance and improve their relationship with Cameco to strengthen their social license to operate at various sites both domestically and internationally.

The stakeholder’s involvement/engagement at all stages of the in-situ decommissioning will address the safety concerns the community may have and aid in resolving them in a timely and practical manner. Lessons learned has recognized that engaging the local community is a good

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practice and addresses any concerns that a community may have. It is observed that a window is provided for the community to address local concerns with and without strict process defined by the regulations and as a result the level of trust is improved (Brehaut.H,1998).

As part of managing stakeholders, meetings and consultation forums will be required to be held frequently to assure the public that Cameco is making sound and balanced decisions on the in- situ decommissioning of the AGTMF to ensure public health and safety and environment protection. This will provide a fair and equal opportunity to the community to comment on the

Cameco’s in-situ decommissioning and license termination plans. This offers the community to review and provide comments on Cameco’s in-situ decommissioning plans. Cameco will be announcing the venue and provide assistance for the community to attend the community engagement forums during various stages and phases of the in-situ decommissioning project.

Some important process for stakeholder engagement/consultation will include the following:

 Public Information

 Public Inquiries

 Public Consultations

 Public Hearings

 Consideration of the result of public consultations/hearing

According to Richard Newton (2013), engaging stakeholders and making the stakeholders an integral part of the project team will ensure that project gets best out of them and stakeholders get best out of the project whereby either parties are benefited mutually to reduce risks, unfolds risks, increased perception of success and easier project closure.

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6.13 Project Risk Management

The risk management is a comprehensive and systematic ways of identifying, analysing and responding to risks to achieve in-situ decommissioning project objectives. The risk management process is a continuous process throughout the life of a project and in the best interests of its objectives. An adequate risk management will reduce not only the likelihood of an event occurring, but also the magnitude of its impact.

The benefits of the risk management process include identifying and analyzing risks, and improvement of the in-situ decommissioning project management process and effective use of resources. Especially in projects like in-situ decommissioning that can be extremely complex and fraught with uncertainty. Risks and uncertainty can potentially have damaging consequences for the in-situ decommissioning project. Therefore risk management plays an important role to deal effectively with uncertainty and unexpected events and to achieve in-situ decommissioning project success. Asbjorn etal (2010) notes that the nature of projects creates a foundation for significant unpredictability and suggest that the reality of unpredictability presents great opportunities. Asbjorn etal (2010) recommends the importance of embracing the degrees of freedom that is required for managing uncertainty. This creates increase in business value in capital investments. They have recommended that the leaders should be adaptive; willing to change the scope, adjust the plan, and even change the goals in order to increase the business value of the asset they are creating whereby the risk is turned to opportunity.

Managing risks in in-situ decommissioning of AGTMF is a very important process in order to achieve project objectives in term of time, cost, quality, safety and environment compliance.

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Therefore it is important to include a risk management process that includes the risk identification, risk assessment, risk mitigation and risk monitoring for the in-situ decommissioning project.

Risk identification involves two main steps i.e., to identify the source and type of risks. This is important because it develops the basis for the risk analysis and control of risk management to ensure effective risk management for managing successful projects. Risk identification is an iterative process because new risks may be become known as the project progresses through its life cycle.

Risk assessment is an evaluation process which involves description of each risk and its impacts in terms of both risk impact and probability of its occurrence. Usually the project team will find answers what caused the risk and how this risk will impact the project. There are two broad categories of risk assessment, namely, the qualitative and quantitative analysis. The qualitative analysis assess the impact and likelihood of the identified risks and develops prioritized lists of the risks for further analysis or direct mitigation whereas the quantitative analysis attempts to estimate the frequency of risks and the magnitude of their consequences by different methods such as the decision tree analysis cost risk analysis, and Monte Carlo simulation.

Risk mitigation is defined as taking steps to reduce adverse effects and there are four alternative risk mitigation strategies (risk avoidance, risk transfer, risk mitigation and risk acceptance). This includes assessing the possible remedies to manage the risk or possibly, prevent the risk from occurring. Basically it is finding the answers to the following two questions;

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a) What can be done to reduce the likelihood of this risk?

b) What can be done to manage the risk, should it occur?

Risk monitoring and control process is applied to monitor the identified risks, identify new risks, ensure the proper execution of planned risk responses and evaluate the overall effectiveness of the risk management plan in reducing risks.

The risk could be internal or external risks. Some of the internal risk identified for the in-situ decommissioning will include uncertainty in the thawing of ice lenses within the AGTMF tailings, delays in thawing program, the consolidation and settlement of the AGTMF tailings, delays in the implementation of the in-situ cover, interference from ongoing operations, environmental pollutions, design failures, and the availability of the specified materials for backfill and cover fill within the vicinity of the AGTMF.

Some of the external risk identified will include social like a disagreement from the community, economic and political scenarios, weather related issues, natural calamities/disasters, change in regulatory framework and governing authority etc.

The above identified risks are presented in Table 4. 9 below and these may cause decommissioning delays, increase cost, and not meeting the regulatory obligations and commitment that lead to project failure or undesirable project results. Therefore it is of utmost importance to ensure the risks are managed adequately to reduce/mitigate as part of the risk management process.

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6.14 Project Procurement Management

The in-situ decommissioning project will require product and services for accomplishing the project objectives. This will require the project procurement management to carry out procurement and contract activities which ensures appropriate contract procedures are in place for procurement of materials, contracting and hiring services including decommissioning contractors, third party design reviewers, and design engineering consultants. This includes evaluating management options for different types of contract, availability of resources, identification of companies interested in making a tender for decommissioning operations, drafting of tender specifications, researching the qualification of companies interested in making a tender, auditing their quality system and technical capability, technical and financial analysis of tenders of contractors, examination of capability and acceptance of subcontractors and final selection of contractor and signing of contract.

It is pertinent to consider that the quality of services and products purchased shall be of top priority to serve the best interest and long term benefit of Cameco. Any failure not to comply with top quality of service and materials may lead to increased cost and not meeting the desired project objectives in the long run. This requirement imposes a burden on the project management team to be familiar with the procurement and tendering processes and lack of these skills or unfamiliarity may cause project delays, legal problems and will escalate costs. Therefore for the in-situ decommissioning project the project team will be required to be supported by a highly skilled and experienced personnel within the supply chain management office that will lead the procurement and contract process with their established standardised procedures and processes to negotiate and prepare the final contract agreement adequately.

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Table 6.9 Project Risk Assessment Management for In-Situ Decommissioning

Project Risk Management - In-Situ Decommissioning for AGTMF

Risk Identification Risk Assessment Risk Mitigation Impact Probability Risk Risk Risk Monitoring/ Control Risk Type Risk Source Risk Mitigation Risk Acceptance (1-5)* (1-5)** Avoidance Transfer

Ensure the risk responses have been implemented as Reduce the Likelihood/ planned and are effective. Uncertainty - On the extent of ice lenses Minimize the negative consequence by carrying out Ensure assumptions are still valid and no changes in and the extent of time required to thaw 5 4 further detailed field investivations and exploring newer risk trends/variance. these ice lens within the AGTMF tailings. technologies to reduce the thawing period cost If any changes need to reassess the risks. effectively. Perform risk audits

Reduce the Likelihood/ Delays - In carrying out the thawing Minimize the negative consequence by exploring newer program and will it overrun the proposed 5 4 Same as above technologies to reduce the thawing period cost design period of 8 years. effectively. Consolidation and Settlement - Of the Improved thawing program increases the consolidation 5 4 Same as above AGTMF tailings and settlement of the AGTMF tailings. Select highly skilled and result oriented project management and construction management team. Delays - In the implementation of the in- 4 3 Select a very competent contractor. Same as above situ cover Internal Risks Ensure materials are procured and available for the construction. Acknowledge the existence Interference - From ongoing operations or of interference risk, and Ensure periodic risk reviews is undertaken. other site projects simultaneously being 2 2 make a deliberate decision to Carry out risk response planning carried out. control it to reduce their interference.

Ensure the risk responses have been implemented as planned and are effective. Environmental - Delay in EIA, Minimize the chances that environmental risk will occur Ensure assumptions are still valid and no changes in 3 2 contaminants and pollution spill to delay the EIA or a spill. risk trends/variance. If any changes need to reassess the risks. Perform risk audits

Minimize the chances that radiation risk will occur by Radiation - Radiation levels on the 4 3 ensuring the workers stay under the approved radiation Same as above decommissioning workers exceeds. levels. Impact 1 (very low) - 5 (very high) Probability 1 (very low) - 5 (very high)

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Project Risk Management - In-Situ Decommissioning for AGTMF

Risk Identification Risk Assessment Risk Mitigation Impact Probability Risk Risk Risk Monitoring/ Control Risk Type Risk Source Risk Mitigation Risk Acceptance (1-5)* (1-5)** Avoidance Transfer Ensure the design consultants are competent and Ensure the risk responses have been implemented have experience in similar designs. as planned and are effective. Design - errors and omissions, longer Ensure the consultant have a recent liability Ensure assumptions are still valid and no changes in design duration, delays in late changes, 5 2 insurance coverage. risk trends/variance. failure to comply with the contract. A third party review of the final design packages If any changes need to reassess the risks. will reduce the errors and omissions. Perform risk audits Legal expertise reviews the contractual agreement. Reduce the material risk by ensuring and sourcing Materials - Non-availability of the 5 4 the materials that are readily available within the Same as above specified materials for backfill and cover fill vicinity during the feasibility phase. Organizational - Inexperienced workforce, Reduce the organizational risks by providing more staff turnover, delayed deliveries, radiation 3 2 Same as above control and oversight. Internal management Risks Project Management- Failure to comply Reduce the project management risks by ensuring with contractual quality requirements, 4 3 competent and skilled personnel are selcted for the Same as above scheduling errors, contractor delays, project management team. internal conflicts Reduce the construction contractor's risk by ensuring competent and skilled personnel are selected in the contractor's team. Construction - Construction cost Competent construction management team overruns, contractual 4 4 Same as above provides appropriate oversight. contradictions/disputes, change orders, Cost controllers are included in the project management team to monitor the cost and schedule of the construction activities.

Social - Disagreement from the Reduce/minimize the social risk by ensuring that the community, public objections, new 3 3 stakeholder engagement and consultation is Same as above stakeholders emerge and request changes. ongoing process right from the conceptual stages.

Acknowledge the economic External and political risk and make a Risks deliberate decision to watch Economic and political - Scenario and monitor the changing Ensure periodic risk reviews is undertaken. changes on laws, economically feasibile to 3 3 scenarios closely and manage Carry out risk response planning extract minerals from tailings. them by developing contingencies to minimize the negative consequneces.

Impact 1 (very low) - 5 (very high) Probability 1 (very low) - 5 (very high)

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Project Risk Management - In-Situ Decommissioning for AGTMF

Risk Identification Risk Assessment Risk Mitigation Impact Probability Risk Risk Risk Monitoring/ Control Risk Type Risk Source Risk Mitigation Risk Acceptance (1-5)* (1-5)** Avoidance Transfer Natural calamities/disasters - Ensure periodic risk reviews is undertaken. 5 3 Acknowledge the risk. earthquakes, forest fires Carry out risk response planning Ensure the risk responses have been implemented Reduce the Likelihood/ as planned and are effective. Change in regulatory framework and Minimize the negative consequence by making a Ensure assumptions are still valid and no changes in External governing authority- Change in deliberate decision to watch and monitor the 4 2 risk trends/variance. Risks environmental laws related to the current changes in regulatory framework and governing If any changes need to reassess the risks. regulations. authority by developing contigencies to minimize Perform risk audits the negative consequences.

Interference from ongoing operations - Reduce the interference from ongoing operations The milling facility is still generating revenue by assigning personnel as key focal point from from the milling operations and will be a 3 2 Same as above operations side to minimize or reduce the priority over the decommissioning activity interference. of AGTMF Impact 1 (very low) - 5 (very high) Probability 1 (very low) - 5 (very high)

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Conclusions

7.1 Summary

The decommissioning of the stored uranium tailings within a tailings management facility is an important topic with regard to the challenges posed by tailings impoundments, waste dumps and its consequence on the environment. The greatest long-term source of potential environmental containments from the stored tailings in any tailings management facility is of significant concern to the public and regulators. Therefore it calls for a reliable and safe in-situ decommissioning of the AGTMF to prevent or reduce the contaminant levels that environment can handle.

Overall, the thesis have been able to provide enhanced understanding of the complexity of in-situ decommissioning of AGTMF. Through the review of the literature, the objectives for this thesis were identified and this include identifying the challenges and addressing the challenges while providing a sound project management in-situ decommissioning process to overcome these challenges. The selection of in-situ decommissioning of AGTMF have been discussed herein recognising the most efficient cost-benefit approach and the following challenges:

 the radioactive and hazardous nature of the tailings,

 compliance requirements to meet the stringent environmental regulations,

 the health and safety risks to human and ecosystems,

 lack of proven technologies,

 project management challenges,

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 operational challenges to overcome uncertainties and ability to adapt concepts and

techniques from other industries.

7.2 Findings

The thesis have presented the following significant findings to advance knowledge in the in-situ decommissioning process of mill and milling tailings for the uranium industry.

a) The implementation of the decommissioning requires the stewardship of the company’s

Chief Executive Officer and need to be aligned to the visions, values and missions of the

company.

b) Decommissioning need to be considered as an integral stage within the life cycle of the

uranium operations as presented in Figure 7.1 below.

Figure 7.1 Mining/Milling Life Cycle of Uranium Operations

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c) Consolidation of the frozen lenses of tailings is crucial for the in-situ decommissioning

of AGTMF. It is imperative to consolidate the tailings mass to ensure the stability related

to the capping of the tailings. d) Significant need to develop an acceptable and a well thought out in-situ

decommissioning management program for the AGTMF is reinforced. e) Developing a well-defined scope of work for the in-situ decommissioning activities

recognising each activities within each stage/phase is of prime importance for planning

the decommissioning. f) Ensure adequate project management processes are in place to ensure that the

appropriate actions are taken in the right sequence. g) Gain from lessons learned captured from similar decommissioning process both from the

successes and failures. h) Select a project team consisting of the right people to work and whose skills,

qualifications and experiences are tested and proven in the decommissioning industry. i) Ensure established communication process exist among the project participants and key

stakeholders during all the stages of the decommissioning. j) Engaging stakeholders at all times during each of the decommissioning stages. k) Recognize stage gate meetings as a vital tool for making rational decision to whether or

not to proceed the next phase/stage based on the actual facts on the project activities. l) Stage gates provides an opportunity to the decision makers to approve/release the

required funding for the next phase/stage project.

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m) Managing the risk, uncertainty and complexity in decommissioning in a flexible,

adaptive and collaborative manner enhances project leaders to turn them to opportunities

and reducing risks. n) Decommissioning cost need to be accepted as part of an allocated capital cost for

investment to run the uranium operations and generate revenue. o) The elevated levels of technical risk, political risk, resource risk and environmental risk

in the in-situ decommissioning need to be recognised from the very onset of the

development of any uranium mining and milling operations and continued as an ongoing

process throughout its life cycle. p) The cost of decommissioning could be extensively reduced/saved should the industry

recognise to decommission those facilities within the operational phase that becomes no

more in use or is discontinued without having them deferred/postponed until the whole

facility is to be decommissioned. q) Research and development (R&D) required to look into newer technology including

improved thawing technology to reduce the period for the thawing program for the

frozen tailings within the AGTMF. r) A provision for collecting the cost for decommissioning uranium mining and milling

operations should be considered during its revenue (production) generating life cycle

period i.e., a percentage of revenue generated for each pound of uranium produced

should be allocated for the cost of decommissioning activities in future. This funding

program for decommissioning reduces the financial burden on the operators/ tax payers

and enhances the industry to fund and promote decommissioning without any deferment.

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7.3 Recommendations

Collective collaboration between the uranium mining operators needs to be encouraged to promote safer solutions and allows maximizing savings in similar decommissioning program.

As recommended by Asbjorn etal (2010) more emphasis on the open, flexible, and adaptive style of project management enhances achieving extraordinary results and reducing risks.

More emphasis should be placed on the best practices demonstrated and lessons learned within the decommissioning of uranium mining industry as this will provide valuable insight for devising decommissioning programs that are more cost effective and safer.

An increase in nuclear decommissioning activity has been associated more with nuclear reactors/plants and there is a need to overcome the limitation in-situ decommissioning of tailings management facility experience base and as such there is still much to learn and accomplish on a larger scale for in-situ decommissioning.

The uranium industry should keep emphasizing in the importance of training personnel and consider tailings decommissioning an area that would require experienced personnel to facilitate complex in-situ decommissioning operations.

More research and development is required to explore more viable, cost effective and environmentally sustainable solutions. This requires large financial support from uranium mining operators globally as well as from the government/international agencies to institutionalise a research and development for this purpose.

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7.4 Further Research

The research that has been undertaken for this thesis has identified a number of topics on which further research would be beneficial. Some of the topics lacking information were addressed in this thesis but others remain. Therefore further studies are recommended to address those topics to achieving a cost effective, safe and environmental outcome. There is an urgent need to research and evaluate how safe are the current practices for uranium mill and mine tailings decommissioning?

In particular, there is lack of any studies in addressing some of the challenges and the many uncertainties in the in-situ decommissioning of AGTMF. The levels of uncertainty associated with the consolidation of the tailings, thawing methods of the frozen tailings and the duration required for thawing the frozen tailings need to be further investigated using data from other mining companies in the artic region and improvised technologies for the thawing processes.

Future studies might look into gathering information on established process for decommissioning

AGTMF in areas having similar climatic conditions. Another one to be researched would be examination of the realistic time period for decommissioning of similar tailings facilities worldwide and look into how realistic is it to reduce this time period for future decommissioning.

There still needs clarity on whether AGTMF needs to be decommissioned now or later when all the milling operations at KLO lease ceases i.e., 30-40 years from now. It will be an interesting topic to research on how the impacts and risks from decommissioning the AGTMF now or later would be beneficial to Cameco subject to regulator’s approval.

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Another interesting field to research, does the improvised technologies help in reducing the time period for decommissioning the AGTMF? Little research has been conducted to assess the impact on regulatory changes and would this allow more feasible options in future in terms of cost and its sustainability?

Further research could also target a sample of companies that are known to conducting decommissioning activities and evaluate their capabilities, strength and weakness. Additional research may include looking into training programs applicable for decommissioning and identifying new decommissioning strategies. There are also several areas for further development, for example looking at other decommissioning options like reuse/recycle the tailings to extract more minerals beneficially with improvised technology.

7.5 Conclusion

I have presented the means and ways on how to overcome the significant challenges in in-situ decommissioning of AGTMF based on the experiences drawn from numerous projects and organizations through the literature review carried out. I have recognised the need for fresh thinking and advancing knowledge for delivering a sound project management for in-situ decommissioning process to minimize risk to the personnel, environment and compliance with the environmental regulations. I have emphasised on the open, flexible, and adaptive style of project management to overcoming the challenges, achieving extraordinary results and reducing risks in in-situ decommissioning. I have a confidence of very great significance that this thesis delivers a meaningful understanding of an in-situ decommissioning process for the AGTMF.

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