Integration of (Federal) Responses to Comments Recieved Through Review of February Draft 2010 and Acceptance of Addendum Road Map

Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

CNSC-14 incomplete Type II Atmospheric modelling - Acceptable Figure 4.2-1 provided in Appendix temperature as a variable XIV CNSC-15 incomplete Type II Atmospheric modelling - power Acceptable remove reference to diesel power gen sets generation being main source of power CNSC-17 incomplete Type II Stack Emissions Adequate Appendix XII CNSC-19 Acceptable Yes Selenium NR

CNSC-21 Acceptable Yes Selenium NR CNSC-22 (1) unacceptable Type I Mink Arm Sediment Adequate Section 3.2.2.2.3 unacceptable Type I Midwest water treatment Adequate Main Document, Section CNSC-22 (2) 3.5.1.2.2, Figure 3.5-2. unacceptable Type I Midwest special waste and Adequate CNSC 22 (4) dewatering system NR CNSC-25 (2) incomplete Type II Traffic on proposed road Adequate Section 7 CNSC-26 requires clarification Type II Traffic wildlife interactions Adequate NR CNSC-27 incomplete Type II Mink Arm dewatering Adequate Section 3.2.1.1.2 CNSC-29 Acceptable Yes Phyto/Zooplankton monitoring NR EEM TAP CNSC-A incomplete Type II Appendix XII Adequate chemicals/reagents, hazards and transport Appendix XII, Section 3.5. CNSC-B acceptable Type II Yes Appendix V S/V TEMS acceptible with condition NR enhanced removal CNSC-C incomplete Type II Appendix XI Kd - arsenic and review of September 2010 new reponse provided in radium addendum found response addendum and discussed with unacceptable comment provider CNSC-D incomplete Type II Appendix XI porewater arsenic acceptable and uranium Section 3, Figure 3.5-8. DFO-1 (2010) New Mink Arm data acceptable Update Figure 4.4-6; Update Tables 4.4-38, 4.4-40 & 4.4-41; and update Section 4.4.6.1.1 and 4.4.7.1 DFO-2 (2010) New Mink Arm data acceptable Section 4.4.7.1 DFO-3 (2010) New Mink Arm dewatering acceptable section 3.2.1.1.2 and 6.4.3.1 DFO-4 (2010) New Too Small Lakeflushing rate Acceptable Table 4.2-13

1 Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

has not demonstrated that the No response required - relates to addition of whitefish to Too Too Small Lake and/or Sue E/Sils Small Lake would be successful Lake DFO-3 (AppIII-2010) New

has not demonstrated that the No response required - relates to addition of whitefish to Too Too Small Lake and/or Sue E/Sils Small Lake would be successful Lake DFO-4 (AppIII-2010) New Too Small Lake and/or Sue E/Sils supplement the stickleback Lake DFO-5 (AppIII-2010) New Too Small Lake and/or Sue E/Sils WSV and WSA Lake DFO-6 (AppIII-2010) New hydraulic connection between Too Small Lake and/or Sue E/Sils the Sue E pit and Sils Lake Lake DFO-7 (AppIII-2010) New of water volume available for Too Small Lake and/or Sue E/Sils overwinteringjy Lake DFO-8 (AppIII-2010) New volume of the Sue E pit between No response required - relates to 2 metres and 48 metres depth Too Small Lake and/or Sue E/Sils should be considered Lake

2 Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

Regulator Comments Adequacy of Response Type Future Follow-up Issue Response following EIS Integration Addressed In September Provided in Draft EIS Requirments September 2010 2010 Addendum (received via submission of Addendum review of February 2010 Draft EIS) q DFO-9 (AppIII-2010) New from the proponent that the No response required - relates to berm will be completely Too Small Lake and/or Sue E/Sils removed Lake DFO-10 (AppIII-2010) New refer to response to DFO-6 (2010), accepted by DFO May 9th detailed fish salvage plan 2011 DFO-11(AppIII-2010) New Fish should not be released into compensatory habitat until the No response required - relates to habitat can support all species Too Small Lake and/or Sue E/Sils and life stages Lake DFO-12(AppIII-2010) New addressed in appendix III addendum proponent states (Page 49) that fish removed from Mink Arm will be counted and weighed DFO-13(AppIII-2010) New absence of “boulder” as a cover type in Table 7.1-1 would appear to contradict its No response required - relates to documented presence as a Too Small Lake and/or Sue E/Sils substrate type Lake DFO-14(AppIII-2010) New has incorrectly assumed (Page addressed in appendix III 14) that since no change in fish addendum biomass is anticipated as a DFO-15(AppIII-2010) New DFO requests that the No response required - relates to proponent re-check the Too Small Lake and/or Sue E/Sils calculations provided in the Lake EC-1 (2010) New Advice-Mink Arm dewatering NR EC-2 (2010) New Advice-mine waste disposal in NR fish bearing waters EC-3 (2010) New Advice-Lake dewatering offset NR contingency subject to MMER

EC-4 (2010) New Wildlife radiological dose NR EC-5 (2010) New Mink Arm cross contamination acceptable NR

EC-6 (2010) New Site layout acceptable NR EC-7 (2010) New Road Stream Crossings Acceptable NR EC-8 (2010) New Mink Arm dewatering review of September 2010 NR Addendum resulted in additional requests - further response deemed acceptable

3 Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

EC-12 (2010) New water quality monitoring protocol acceptable NR

EC-13 (2010) New water quality monitoring protocol Acceptable NR

EC-14 (2010) New S/TEMS and McClean Lake review of September 2010 NR water quality Addendum resulted in additional requests - AREVA requested dicussion and triage

EC-15 (2010) New Advice-decommissioning and review of September 2010 NR clean-up Addendum resulted in additional requests - AREVA requested dicussion and triage - has been removed Jan 6/2011

EC-16 (2010) New conventional waste acceptable NR management EC-17 (2010) New Figure 4.4-1 acceptable update Figure 4.1-1 EC-18 (2010) New benthic invertebrate VEC acceptable NR selection EC-19 (2010) New Mink Arm benthic communities acceptable reference to AREVA (2009) and to section 4.4.6.1.1 of MW EIS have been added EC-20 (2010) New Mink Arm monitoring acceptable P. 4-47 of Section 4.4 EC-21 (2010) New monitoring downstream of Mink review of September 2010 NR Arm Addendum resulted in additional requests - further response deemed acceptable

EC-22 (2010) New Water quality monitoring acceptable Table 4.4-3 will be updated EC-23 (2010) New Water quality monitoring response to A and C are acceptable a) reference to Figure 4.4-1 will be added to Section 4.4.1.2.2 for clarity; b)NR; c)NR

4 Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

EC-29 (2010) New Mink Arm dewatering acceptable NR EC-30 (2010) New Water/Sediment qualtiy acceptable NR EC-31 (2010) New Mink Arm dewatering acceptable NR EC-32 (2010) New S/V TEMS benthics review of September 2010 NR addenum resulted in a new comment - clarification of table location

EC-33 (2010) New MMER acceptable NR EC-34 (2010) New MMER acceptable NR EC-35 (2010) New MMER review of September 2010 NR addenum resulted in a new comment - AREVA has requested a discussion with EC EC-36 (2010) New S/V TEMS benthics review of September 2010 NR addenum resulted in a new comment - AREVA has requested a discussion with EC EC-1 (New - October 2010) New MMER requirements during provided EC the response dewatering of Mink Arm in advance, they have deemed it acceptable

HC-5 advice-revise Human Health Adequate Section 8.1 HC-8 offer to review spill response Review of September 2010 NR Addendum required follow up by CNSC

HC-13 offer to review handling of wastes Review of September 2010 NR Addendum required follow up by CNSC

HC-17 offer to review ALARA Adequate NR

5 Integration of (Federal) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

HC -19 rating system for risk Comment provided following review of September 2010 Addendum - removed Jan 6/2011

HC-22 explanation requested dietary arsenic, uranium Adequate NR HC-23 advice-revise? TRVs Adequate NR HC-24 advice-revise arsenic exposure adequate Section 8.3.2.2; Table 8.3-10; Section 8 Reference List HC-30 rationale requested Mink Arm dewatering -mercury Adequate

HC-31 adequate Yes Monitoring program NR NRCan-10 Dewatering Well System Sufficient NR monitoring NRCan-11 request to be informed WROVP Sufficient NR NRCan-45 (2010) New double liner under special waste Sufficient as indicated in CNSC-22(1) and stockpile CNSC-22(4) NRCan-46(1) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-46(2) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-46(3) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-46(4) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-46(5) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-46(6) (2010) CNSC response Tailings CNSC response is sufficient response provided by CNSC NRCan-47 (2010) New Yes Midwest groundwater extraction Sufficient NR

TC-1 (2010) New Mink Arm dewatering impacts nothing further NR

TC-2 (2010) New Haul Road Transportation nothing further NR

6 Integration of (Provincial) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

Regulator Comments See Also Adequacy of Response Issue Response EIS Integration Addressed In September Provided in Draft EIS following 2010 Addendum (received September 2010 via review of February submission of 2010 Draft EIS) Addendum

SK-2 additional follow-up required

the effects of suspended sediment are related to both concentration of sediments and time of exposure, the weekly sampling interval may be too long adequate NR SK-3 a) additional follow-up required Dewatering well pipeline secondary NR containment

adequate SK-3 c) additional follow-up required Water treatment monitoring adequate See CNSC-22 (2) SK-6 additional follow-up required Waste rock Management NR

adequate SK-11 additional follow-up required Special waste stockpile adequate section 3.5.2.3 SK-51 additional follow-up required TMF capacity adequate NR E&R-1 (2010) New Figure 3.2.1 Lease adequate update figure 3.2.1 E&R-2 (2010) New Surface Lease adequate NR SME-1 (App. III) Fish Habitat SME-2 (App. III) DFO-31 Too Small Lake BOD from decomposition No response required - relates to Too Small Lake and/or Sue E/Sils Lake SME-4 (App. III) aluminum No response required - relates to Too Small Lake and/or Sue E/Sils Lake SME-5 (App. III) BAT and BAP NR NR

7 Integration of (Provincial) responses to comments recieved through review of February Draft 2010 and acceptance of addendum Road Map

SME-6 a) (App. III) spawning habitat No response required - relates to Too Small Lake and/or Sue E/Sils Lake SME-7 a), b), c) (App. III) Fish Habitat No response required - relates to Too Small Lake and/or Sue E/Sils Lake SME-12 (App. III) dredge size addressed in appendix III addendum

SME-A New DFO-2 (App.III) DFO-2 (App.III) ammonia see repsonse to DFO-2 (AppIII)

SME-B New DFO-9 DFO-9 (App III) SEL NR

8 Response to Federal Comments

1 FEDERAL COMMENTS

Regulator Comment / Response Comment CNSC-1 Comment:

Appendix VII: The basis for not including ingestion of beaver, duck and fish for the Hatchet Lake operator should be provided.

ARC Response:

As noted on Page 5 of Section 2 of Appendix VII, “beaver, duck and fish were not included as they would not be affected by the McClean Lake Operation.” Since Hatchet Lake is far removed from the point of discharge of treated effluent from the McClean Lake Operation and the Midwest Project, the effects would be lower than those predicted in Wollaston Lake (i.e., Hatchet Lake is downstream of Wollaston Lake, and thus, water quality in Hatchet Lake is less affected by treated effluent discharge to Collins Creek than Wollaston Lake). Since the potential effects on the Wollaston Lake Lodge Operator were evaluated to be negligible, the effects on the Hatchet Lake Operator would also be negligible. Therefore, for Hatchet Lake operator, only potential airshed-related effects were evaluated.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-2 (1) Comment:

The reference (PMEL 2007) for the evaluation of the Mink Arm dam is missing (Section 3.2.1).

This missing reference should be submitted for review.

ARC Response:

Document PMEL 2007 has been submitted to CNSC for review.

Document Integration:

No integration required.

Technical Review Response:

Adequate

CNSC staff reviewed the report on the stability assessment of the Mink Arm Dam. The report presents sufficient evidence at this stage that the dam is currently stable, and could be modified in order to isolate Mink Arm from the proposed pit. Before construction, a detailed design should be presented and should include at least:

- several cross-sections through the dams and its foundations.

- proposed monitoring for seepage and stability during and at the end of dewatering of Mink Arm, and during and at the end of excavation of the Pit.

- stability analyses for dynamic loads (earthquakes and blasting).

The comments on the geological and structural framework have been triaged out. However, they are addressed in the revised EIS. A fault exists coincident with the direction of Mink Arm. From a hydrogeological point of view, the hydraulic conductivity seems no different from the surrounding rocks. This assumption should be verified during construction and operation. From a stability point of view, the influence of fracturing should be accounted for in the design of the pit slopes. The design of the pit slopes, supported by stability analyses, should be provided during licensing.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-2 (2) Comment:

Any document that has been extensively referenced in the EA report should be included as part of the submission. Otherwise, reviewers must attempt to locate these essential reference materials that are critical for the review process.

If readily available, provide electronic copies of all primary reference documents at the planned February 2008 meeting.

ARC Response:

The Midwest Project Existing Environment Technical Information Document (AREVA 2006) has been referenced extensively in the Midwest Project EIS. This document (now AREVA 2009) to be submitted to reviewers as per the distribution list.

Document Integration:

No integration required.

Technical Review Response

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-3 Comment:

Although Section 3.4.3 describes briefly the necessary JEB Mill expansion, the potential environmental interactions of constructing that expansion are not included in Table 6.1-1 and the subsequent screening of the interactions AREVA must consider the JEB Mill expansion in Table 6.1-1 (Potential Environmental Interactions) and the subsequent screening of interactions.

ARC Response:

The potential environment interactions of constructing the expansion of the JEB Mill have been included in Section 6.0, Table 6.1-1, Table 6.2-1 and Table 6.3-1.

Document Integration:

Section 6.0, Table 6.1-1, Table 6.2-1 and Table 6.3-1.

Technical Review Response

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (1) Comment:

AREVA is required to assess the alternate alternatives related to waste rock management. These include:

1. A decommissioning scenario of backfilling the Midwest pit to above grade, to eliminate the pit as a potentially contaminated surface water body that may also be a sink for seepage from the surrounding waste rock piles. 2. Evaluation of the environmental impact of adopting the lower grade (425 ug/g) for defining ore to supplement their evaluation of the higher grade (850 ug/g) for defining ore. Consequently, the effect of this range of ore grade is required to be evaluated regarding management of smaller quantities of waste rock with lower contaminant content and management of the larger quantities of tailings, possibly with varying contaminant content. 3. Alteration of Midwest groundwater and surface flow regimes not evaluated e.g. what is the effect of a 143 m deep lake on groundwater and surface water regimes? Will the flooded Midwest pit be an isolated headwater lake or will it be connected to South McMahon? 4. Effect of groundwater and surface water recovery at Midwest not evaluated. What lakes will be fully drained and what may happen when they flood back in terms of contamination from oxidized sediments (e.g. the Key Lake example). If there are problems how will this be mitigated? ARC Response:

Under the proposed decommissiong plan for the Midwest site the clean waste rock piles will be recountoured. For the Midwest pit, a till cap will be constructed over the problematic waste rock and the pit will be allowed to reflood naturally.

As an alternative to this decommissiong plan, the Midwest pit could be entirely backfilled. Under this scenario the problematic waste rock would be placed at the bottom of the pit, as planned under the current waste rock management plan, and a fraction of the clean waste rock would be used to backfill entirely the pit.

The main advantage of this alternative decomisssioning plan would be to eliminate the potential for a long-term water quality issue of the Midwest pit lake. In addition this option would reduce the volume of material to be managed in waste rock piles from approximately 46 Mm3 to 12 Mm3 (lcm). An obvious disadvantage of the fully backfilled pit option is its cost, which is considered to be in the order of 140 MCAD (assuming for instance 34 Mm3 at 4 $/m3).

The fully backfilled pit option is presented as a backup decommissioning plan for the Midwest pit should the pit lake water quality evolve unacceptably and should the water treatment plant be unable to treat the pit lake water.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (1) ARC Response: (continued) Simulation of the Fully Backfilled Pit Option The post-decommissioning flow regime associated with the fully backfilled option was simulated based on the groundwater flow model presented in Appendix IV, Section 3 and in Appendix IX, Section 4. The hydraulic conductivty of all waste rock to be placed into the Midwest pit (i.e., special waste up to elevation 335 mASL and clean waste rock from 335 mASL to ground surface) was assumed to be 10-4 m/s. As indicated in Appendix IX, this value is considered to be on the conservative side. For senstivity analysis purposes, for each of the three cases outlined (See Appendix IV, Section 3), two values were considered for the net infiltration through the top layer of the backfilled pit: 55 mm/year (i.e., a value similar to the average groundwater recharge rate) and 150 mm/year (i.e., a value expected for a non compacted waste rock pile).

Figure CNSC-4 (1) illustrates the steady-state distribution of hydraulic heads in the upper sandstone of the Midwest area as simulated by the model for Case 1 and the fully backfilled option. This figure shows that the groundwater flow conditions for the fully backfilled pit option appear to be very similar to the groundwater flow conditions for the partially backfilled and flooded pit option.

This is consistent with the value of the hydraulic conductivity used to simulate the waste rock to be placed in the upper part of the Midwest pit. The selcted value (10-4 m/s) is approximately two orders of magnitude greater than the hydraulic conductivity of the surrounding rock mass and consequently the backfilled pit tends to act as a drain in a manner relatively similar to the pit lake for the partially backfilled and flooded pit option.

The flow through the clean waste rock and out into the surrounding aquifer is calculated to range from approximately 80 m3/day (Case 3, infiltration of 55 mm/year) to 208 m3/day (Case 1, infiltration of 150 mm/year). A fraction of this flow, especially for Case 1 and Case 2, is expected to report to the surface water receptors located between the Midwest area and Collins Creek. Therefore the fully backfilled pit option could potentially be associated with long term loadings to surface water receptors if the waste rock to be placed in the upper part of the Midwest pit is a source of leachable constituents of concern. This scenario was not simulated because the results of the clean waste rock characterization (Appendix VIII) indicate that there is virtualy no risk of acid generation from this material, even if the rock is stored on land and that the application of robust segregation criteria will ensure that this rock contains low levels of constituents of concern.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (1) Under the fully backfilled pit option the flow through the special waste (i.e., located between the bottom of the pit and elevation 335 mASL) (continued) and out into the surrounding aquifer is calculated to range from approximately 13 m3/day (Case 1, infiltration of 55 mm/year) to 42 m3/day (Case 3, infiltration of 150 mm/year). These values are similar to the ones calculated for the partially backfilled and flooded option. This suggests that the two decommissiong options are not expected to differ significantly in terms of impact of special waste to surface water receptors (i.e., similar incremental loadings and resulting long-term surface water concentrations).

Figure CNSC-4 (1) – Simulated Steady State Distribution of Hydraulic Heads in the Upper Sandstone Case 1- Post-Decomissioning Conditions Fully Backfilled Option

Document Integration:

Main document, Section 3.5.2.3 Appendix IX, Section 4, Figure 4.3

Technical Review Response :

Adequate, given that a proper follow up program demonstrates that the clean waste rock pile meets initial predictions.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment OK - Incorporate into follow-up program.

ARC Response:

June 2010 Future mining at the Midwest Project will include sampling of waste rock for geochemical characterization as outlined in Section 12.5.3.

Document Integration:

No integration required

Technical Review Response: October 2010 Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (2) Comment:

AREVA is required to assess the alternate alternatives related to waste rock management. These include: 1. A decommissioning scenario of backfilling the Midwest pit to above grade, to eliminate the pit as a potentially contaminated surface water body that may also be a sink for seepage from the surrounding waste rock piles. 2. Evaluation of the environmental impact of adopting the lower grade (425 ug/g) for defining ore to supplement their evaluation of the higher grade (850 ug/g) for defining ore. Consequently, the effect of this range of ore grade is required to be evaluated regarding management of smaller quantities of waste rock with lower contaminant content and management of the larger quantities of tailings, possibly with varying contaminant content. 3. Alteration of Midwest groundwater and surface flow regimes not evaluated e.g. what is the effect of a 143 m deep lake on groundwater and surface water regimes? Will the flooded Midwest pit be an isolated headwater lake or will it be connected to South McMahon? 4. Effect of groundwater and surface water recovery at Midwest not evaluated. What lakes will be fully drained and what may happen when they flood back in terms of contamination from oxidized sediments (e.g. the Key Lake example). If there are problems how will this be mitigated?

ARC Response:

Adopting a grade of 425 ug/g U as opposed to 850 ug/g U to define ore would result in lower quantities of special waste to be disposed of in the Midwest pit and higher quantities of tailings to be managed in the JEB TMF. The volumes of special waste have been estimated at 925,000 bcm at the 425 ug/g U cut-off level and 1,382,000 bcm at the 850 ug/g U cut-off level (Appendix VIII Table 3.2). At Midwest, the potential environmental effects associated with the waste rock management plans have been assessed for the most conservative case; that is the 850 ug/g U cut-off level. At the JEB TMF, the additional quantities of tailings that would be generated if a lower cut-off level is used would marginally affect the capacity of the TMF. As outlined in Comment NRCan-16, this licensed facility has been assessed on the basis of the TMF filled to capacity. From a contaminant content perspective, the robustness of the TMF would not be affected because the tailings preparation circuits (see Comment NRCan-33 (1)) would not be modified. In addition, as arsenic concentrations tend to increase with uranium concentrations (Appendix VIII, Table 3.1), using a lower cut-off level for U would result in a lower arsenic content of the additional ore to be processed.

Document Integration:

Appendix IX, Section 4.1

Technical Review Response :

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (3) Comment:

ARC Response:

The effect of the pit lake on the groundwater flow regime was simulated as part of the post-decommissioning flow simulations (App IX, Section 4.2). These simulations constitute the basis for the long-term contaminant transport assessment.

Simulations results suggest that the Midwest pit lake will not be connected to South McMahon and will act as an isolated surface water body connected to the ground water flow system. Once the long term pit lake equilibrium is established, both ground water and precipitation/surface runoff entering the pit lake will leave the pit lake area by groundwater outflow essentially through the overburden and upper sandstone layers and by evaporative losses.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (3) As an example, Figure CNSC-4 (3) shows the calculated steady state distribution of hydraulic heads in the upper sandstone for Case 1 (continued) (see definition of Case 1 in Appendix IV, Section 3.4 and predicted post-decommissioning impacts for Case 1 in Appendix IX, Section 4.5). The pit lake acts as a zone of large hydraulic conductivity resulting in a relatively flat piezometry with a small hydraulic gradient through the pit lake area, as opposed to the surrounding formation. Similar conditions are predicted to occur for Case 2 and Case 3.

Figure CNSC-4(3) Simulated Steady State Distribution of Hydraulic Heads in the Upper Sandstone Case 1 - Post-Decomissioning Conditions Flooded Pit - Plan view

Document Integration:

Appendix IX, Section 4.2.2, Figure 4.1

Technical Review Response

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-4 (4) Comment:

ARC Response:

The impact of mining on lake levels is difficult to predict and the tendency in the Collins Creek basin has been toward an overestimation of the actual impact. For instance limited to no water level changes have been observed in lakes during open pit mining at JEB and Sue C while significant decreases in water levels were predicted at the initial Environmental Assessment stage. In the Midwest area, the predicted extent of the drawdown cone at the end of mining suggests that numerous lakes in the Midwest area are expected to be influenced to varying degrees by the dewatering activities (Appendix IV, Section 4). The three potentially most affected lakes are predicted to be South McMahon Lake, Too Small and Shallow Lake. The maximum impact is predicted for Too Small Lake where under one scenario the lake is predicted to be fully drained after 4 years of pit dewatering. For Shallow Lake and South McMahon Lake the predicted drawdowns range from 0.60 m to 1.60 m, approximately, and these lakes are not predicted to be fully drained.

The proposed mitigation plan (Section 3.5.1.1.4) is to divert clean reverse osmosis permeate from the water treatment process, if required, to ensure surface water elevations are not influenced by mine development beyond the normal range of baseline surface water elevation variation, thus mitigating the potential for fish habitat alteration and the potential for sediment oxidation and associated contaminant mobilization.

Document Integration:

Appendix 4, Section 4.4.2

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response CNSC Technical Response is incomplete. Review Response Effects on lake levels and recovery of any fully drained lakes:

- Too Small Lake under certain circumstances may be fully drained after 4 years Type II - Shallow and South McMahon will be drawn down but won’t be fully drained - mitigation will include pumping of RO water to ensure lake levels within the normal range of baseline – this is not indicated in Fig 3.5-2 nor is the pipeline/discharge for this identified or discussed anywhere

ARC Response: Natural variation in lake elevations occur as a function of lake water balance. Water bodies with little or no surface water and groundwater inflow or outflow generally exhibit water level changes mainly in response to climatic factors (i.e., precipitation inputs and evaporation outputs).

A lake level monitoring program has been implemented at several lakes near the Midwest site, as presented in Section 4.2.3.5, Table 4.2-10. The lakes monitored in the vicinity of the Midwest Project include Too Small Lake, Shallow Lake and South McMahon Lake. This monitoring program establishes a range of baseline lake water elevations to monitor potential future changes in surface water elevations. Between 2003 and 2005, the difference in lake elevation for Too Small Lake, Shallow Lake and South McMahon Lake was about 0.15 m for all three lakes (Table 4.2-10, Section 4). Between 2003 and August 2010, recorded natural lake elevations in the above referenced lakes have varied by up to 0.26 m. When dewatering activities commence, the monitoring program will provide the basis to monitor local lake levels. If lake elevation changes beyond natural variability are observed, then mitigation, as discussed in the initial response to this comment, will be implemented. This contingency provides the ability to maintain lake levels and avoid potential fish habitat disruption. June 2010

The rate of pumping will be commensurate with the rate of draw down. The South McMahon Lake Case 1 scenario predicts South McMahon Lake to be the most susceptible to potential drawdown at 1.65 m over 5 years. Based on the lake characteristics provided in Section 4, Table 4.2-9, and assuming a steady draw down rate, South McMahon Lake elevation is predicted to decrease at a rate of 0.0009 m/day. ,To offset this decrease, 2955 m3/day of RO water would need to be transferred to South McMahon Lake. This volume is approximately 0.05% of the total volume of South McMahon Lake. This relatively small contribution to the total lake volume is not expected to affect surface water quality.

Please refer to the response to comment DFO-7(2010) which provides a discussion on RO water discharge to surrounding lakes and water quality.

Based on the availability of the contingency measure and the conservative nature of the modeling, the potential adverse effects of lake drawdown due to Midwest pit dewatering are not likely to occur and are considered not significant.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration: Figure 3.5-2 needs to be updated to include the pipeline for discharge of RO water into lakes potentially drawn down by dewatering

activities.

Technical Review Response:

October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-5 Comment:

AREVA should assess the impact of clean waste rock piles on groundwater flow in and around the Midwest site and for their contribution to the contaminant source term (based on observations of contaminated seepage at existing clean waste rock piles elsewhere). AREVA also needs to consider potential groundwater depression in the vicinity of the Midwest Pit what would the impact be on flow and water levels in surrounding creeks? Would satisfactory water level and flow remain for the protection of fisheries habitat particularly for incremental stream flow depression during low flow months.

ARC Response:

The clean waste rock piles were included in the modelling of post-decommissioning groundwater flow. The infiltration rate through the waste rock piles was considered to be similar to the rate of groundwater recharge for the drumlin areas, with values ranging from 55 mm/year to 80 mm/year (Appendix IV, Section 3.4.1.2). The impact of the waste rock piles on the post-decommissiong groundwater flow conditions appears to be very limited. The waste rock piles act essentially as a non saturated zone and the water table is established in the overburden layer at the base of the piles (see Figure CNSC-5).

The clean waste rock piles were not included in the contaminant transport model. The results of the clean waste rock investigation (Appendix VIII) showed that the sulphide-sulphur content of the clean rock is very low and there is virually no risk of acid generation if the rock is stored above grade, on land. With respect to metal leaching, arsenic (i.e., the key constituent of concern) was found to be below detection limits in leachate associated with leach tests under oxygenated conditions. By application of the proposed segregation methodology for the Midwest Project the risk of problematic concentrations of arsenic leaching from the surface stockpiles is considered to be very low. As indicated in Appendix VIII it is proposed to construct the surface waste rock stockpiles with perimeter ditches to collect runoff and leachate seepage from the piles. Monitoring of the quality of this water during operations will be conducted to confirm the acceptability of surface disposal as a long term clean waste rock management plan. It is also planned (see Comment CNSC-23) to install piezometers around the waste rock piles to monitor trends in groundwater quality in the vicinity of the piles.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-5 Figure C154 – Simulated Steady State Distribution of Hydraulic Heads (continued) Case 1 - Post-Decomissioning Conditions Flooded Pit – Cross Section

Document Integration:

Appendix IX, Section 4.2.2, Section 4.3, Figure 4.2

Technical Review Response

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-6 Comment:

Section 3.3.4 states that current regulatory standards for the transport of radioactive substances will not be applied to the transport of Midwest ore over the (private) dedicated haul road, but transport procedures currently applied to the transport of Sue within a license area will be used. It is not clear whether the procedures that apply to the transport of Sue ore include emergency response procedures and cleanup criteria for spills and accidents (as outlined in Section 3.7.3) and whether they are appropriate for spills and accidents on the dedicated haul road which is not on licensed property.

Clarify the procedures and criteria for cleanup of spills and accidents along the dedicated haul road (which is not on licensed property).

ARC Response:

AREVA intends to apply for a surface lease to accommodate the private dedicated haul road between the McClean Lake Operation and the Midwest site. As such, the emergency response procedures which apply to the transport of ore between the Sue and JEB sites would also apply to the dedicated private haul road connecting the Midwest and McClean Lake sites.

Document Integration:

Section 3.3.4.

Technical Review Response

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-7 Comment:

AREVA should identify hazards, assess effects and describe controls for any changes to the operation or use of chemicals/reagents associated with milling Midwest Ore and, and the use of supporting infrastructure such as the acid plant.

ARC Response:

Generally, the processing of Midwest ore has not changed the hazards associated with the operation of the McClean Lake mill or the associated supporting infrastructure. The changes to the mill focus on increasing capacities within several process circuits. An assessment of hazards, effects, and controls for the McClean Lake JEB mill has been included for completeness in Appendix XII.

Document Integration:

Appendix XII

Technical Review Response CNSC Technical Review Response is unacceptable and is linked to CNSC-22(2) [Sic], (refers to CNSC-25 (2)) and new comment CNSC-A.. Response

Type II

ARC Response:

June 2010 Please refer to responses to CNSC-25 (2) and CNSC-A

Document Integration:

none required

Technical Review Response:

October 2010 Adequate. Original response was/is acceptable.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-8 Comment:

Section 3.5.1.2.2 (Discharge and Monitoring of Treated Water) of the EIS states the following: The combined permeate and effluent stream is expected to meet CCME water quality guidelines.

AREVA should clarify whether they mean the CCME drinking water guidelines and/or those for the protection of aquatic life. AREVA must document the likelihood that the combined permeate and effluent stream will meet CCME water quality guidelines, and described any instances where this may not occur. Based on this outcome, AREVA may need to clarify the effects, if any, associated with exceedances of these guidelines.

Note: Please refer to Comment AT 03 in subsection “Atmospheric Environment” for an additional action item regarding “Contaminant Identification, Source(s), and Transport”

ARC Response:

The predicted quality of the combined effluent from the Midwest water treatment system has been added to Appendix V as Table 3.4-5b to address the question raised about how the quality compares to CCME guidelines. Predicted mean (arithmetic and geometric), 5th percentile and 95th percentiles COPC concentrations are presented on Table 3.4-5b for two scenarios: the first based on treatment of all of the Midwest site water through the RO and WTP system (as assumed in the EIS); and, the second based on the assumption that only 50% of the dewatering well water (DWW) requires treatment in the RO and WTP system. In the second case, the DWW was assumed to have similar quality as measured at the JEB DWW and to be combined with the treated effluent water for pumping to the S/V TEMS. In both scenarios, the predicted mean quality of the combined flow meets CCME and Saskatchewan guidelines/objectives for protection of aquatic life. Only at the 95th percentile does the predicted quality exceed the guidelines/objectives and then only for ammonia and arsenic in both scenarios as well as for lead and selenium in the second scenario (i.e. partially treatment of DWW). In cases where the 95th percentile was greater than the applicable water quality guideline/objective, the percentile corresponding to the guideline/objective was estimated. These values are presented in the right most column in Table 3.4-5b. The data presented in the table indicate that the degree of exceedance of the guidelines/objectives in both scenarios is marginal. Predicted levels of all COPC are below aquatic toxicity reference values in both scenarios. Hence, it is concluded that no adverse effects on the aquatic environment would result should a spill occur from the pipeline that would be used to transport effluent to the S/V TEMS.

Document Integration:

Appendix V has been revised to include the information requested with the inclusion of Table 3.4-5b.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-9 Comment:

Section 9.3 (pg. 58) Radiological Assessment. The proponent indicated that as fish were removed from Sink Reservoir when it was developed for operational purposes, radiological exposure related to fish consumption is not an issue. This argument is untenable, as subsequent colonization through migration or other means has likely occurred and fish would be a food source for wildlife.

For a follow-up program, AREVA should conduct a community survey and fish tissue chemistry of fish (if found) in Sink Reservoir.

ARC Response:

AREVA conducted work in 2008 and confirmed that fish had re-colonized Sink Reservoir. A community survey has been done and fish tissue chemistry was measured in fish that had been caught in Sink Reservoir. Notwithstanding the discussion in Section 9.3, the radiological doses to aquatic biota in Sink Reservoir (including those received by fishes) were estimated and are included in Table 7.2-7 of the EIS. The doses to wildlife, including piscivores that may reside in Sink Reservoir were also evaluated; the results are provided in Table 7.2-22.

In general, as part of the McClean Lake Environmental Monitoring Program, northern pike and white sucker have been sampled from Sink Reservoir and analysed for COPCs. The concentrations of COPCs in fish from Sink Reservoir are comparable to those found in fish from Vulture Lake. Details of this monitoring data can be found in the McClean Lake Operation Status of the Environment (SOE) reports. These reports are submitted to Saskatchewan Environment every three years.

Document Integration:

No integration required.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-10 Comment:

Reference: Section 8.3 Human Health Risk Assessment - Subsection 8.3.3.1 (pg. 8-27). Identification of Human Receptors: The proponent has included, as one of 11 receptors, the JEB camp worker defined as an on-site employee that is not classified as a nuclear energy worker (NEW). It is assumed that the occupational exposure of a NEW to radionuclides is higher than a non-NEW worker. However, it is unclear if the proponent has assessed the exposure of a NEW worker to non-radionuclides. It is unlikely that exposures of NEW and non-NEWs to non-radionuclides would be identical, given that the work descriptions for the two would be different.

AREVA must address these issues.

ARC Response:

The human health risk assessment discussed in Section 8.3 only assesses effects to non-NEW; however, Sections 8.1 and 8.2 discuss Occupational Health and Safety as well as Radiation Protection and dose estimates which relate to NEW.

Within the McClean Lake Operation health and safety program, the hazardous materials information system addresses material safety data sheets, product labelling, worker training and industrial hygiene monitoring to detect, evaluate and control chemical and workplace hazards. Within this system, evaluations have been conducted on a number of potential workplace hazards including kerosene, barium chloride and arsenic to assess worker exposures and develop recommendations where appropriate, to limit workplace exposures through engineering and administrative controls and the use of personal protective equipment. In the particular cases evaluated to date, workplace exposures have been found to be a fraction of recommended exposure limits.

Document Integration:

No integration required.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-11 Comment:

Reference: Section 8.3 Human Health Risk Assessment - Subsection 8.3.1.3 (pg. 8-30) Water, Air and Soil Intakes. Exposure via water for three receptors (Rabbit Lake worker, Midwest/McClean Lake worker and Points North worker) were not considered because they are expected to drink treated water. The proponent should clarify what is precisely meant by treated water. For example, if raw water is obtained from a contaminated water body and treated for the purpose of disinfection, then exposure to radionuclide and non-radionuclide contaminants through drinking water would not be excluded.

Further in the same subsection (Constituent Concentrations), while arsenic is considered for exposure assessment other non-radionuclides are not. There are a number of other non-radionuclide contaminants associated with the project effects (e.g. lead, molybdenum, etc). A clarification is needed.

It is also unclear in the same subsection (pg. 8-31) if the assessment of exposure via food sources considered non-radionuclide contaminants other than arsenic.

AREVA must address these issues.

ARC Response:

The Rabbit Lake worker is expected to drink water obtained from Collins Creek; this source is evaluated in the exposure assessment. It should be noted that the treatment system employed at Rabbit Lake is not expected to remove Constituents of Potential Concern (COPCs) that occur in Collins Creek as a result of the effluent discharge from the McClean Lake Operation, including the Caribou Project. The JEB Worker receives their drinking water from unaffected Pat Lake, upstream of the McClean Lake Operation effluent discharge area and this is not considered in the assessment. At Points North, drinking water is obtained from a commercial supplier and is hauled to site; thus, this exposure pathway is not evaluated in the assessment. The Wollaston Lake resident and Lodge Operator gets water from Wollaston Lake and the Trapper gets 75% of his water from Wollaston Lake and 25% from Collins Bay. This is discussed in Appendix VII and is presented in Table 2.0-1 of the Midwest EIS. The water quality in Collins Creek does not exceed Canadian Drinking Water Guidelines. A new Table 2.0-2 has been added to Appendix VII and presents the water quality data in Collins Creek at the water intake for the Rabbit Lake Operation. Table 2.0-2 also includes the relevant Saskatchewan Surface Water Quality Objectives (SSWQOs) and the Guidelines for Canadian Drinking Water Quality.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-11 With regard to the second part of comment CNSC-11, arsenic is not the only non-radionuclide considered in the exposure assessment. (continued) AREVA has examined multiple COPCs and their possible effects on human health. These constituents are listed in Subsection 8.3.1.2 Human Exposure Pathways (Exposure Characterization) and include cobalt, copper, molybdenum, nickel, lead, selenium, uranium and zinc. Subsection 8.3.2.3 now summarizes the assessment of non-carcinogenic effects related to the intake of these non-radionuclides for Wollaston Lake residents and trappers. The results of this assessment are presented in Tables 8.3-10 to 8.3-13 of the Midwest Project EIS Main Document. Assessment of exposure to non-radionuclides and potential non-carcinogenic effects required estimating the total intake of constituents from all sources, including food (market and local food), air, water and soil, as the toxicity benchmarks for these constituents are based on total exposure. All pathways considered in the human health assessment are found in Appendix VII Table 2.0-1 of Appendix VII.

Document Integration:

Changes are reflected in:

 Appendix VII, Table 2.0-2  Section 8.3.1.1  Tables 8.3-1, 8.3-2, 8.3-5 and 8.3-8  Section 8.3.1.3

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-12 Comment:

Reference: Appendix VI (Integrated Risk Assessment) - Section 8.4 (pg. 53) Toxicity to Humans. It is indicated that only the oral pathway was considered in the assessment. It is unclear why inhalation of airborne contaminants such as SO2, NOx, radon, LLRD, etc. were not considered. Also in the same section, Table 8.5-3, which provides exposure limits relating to oral exposure, was not found in the document.

AREVA must address these issues.

ARC Response:

Exposure to the standard air quality pollutants (SO2 and NOX) entails comparison to the appropriate air quality guidelines, which are based on protection of human health (HHRA). As these pollutants do not accumulate in the body, they are not carried through a human health risk assessment. Inhalation of radon and radioactive dust is included in the radioactivity exposure assessment. Inhalation of metals is not considered in the exposure assessment, however, as this pathway is generally found to be a minor contributor to total intake of metals. Ingestion of water, food and soil is the primary pathway of exposure for metals. The toxicological benchmarks for the metals are provided in Appendix VII. All pathways considered in the human health assessment are listed in Table 2.0-1 of Appendix VII. All components of the HHRA have now been added to Appendix VII of the Midwest EIS.

Document Integration:

Appendix VII – Human Health Risk Assessment has been moved from Appendix VI into Appendix VII. All table references have been updated accordingly.

Changes are also reflected in:  Section 8.3.1.2;  Section 8, Table 8.3-2.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-13 Comment:

Reference: Appendix VII (Human Health Risk Assessment) - Section 1 (pg. 1) Human Receptor Groups and Assumptions. It is indicated that Wollaston Lake residents generally go to the area north of Wollaston Lake to hunt caribou, as this area is considered to be unaffected by emissions from the McClean Lake facility. This assumption is questionable because caribou are not limited to the unaffected area where hunting will occur, and may have foraged in contaminated areas where forage (e.g. lichens) was available.

In the same section, a Wollaston Lake Lodge Operator is assumed to not ingest local vegetables whereas others in the same area are. A clarification is needed.

Also in the same section, the effects of the Rabbit Lake operations on the Rabbit Lake worker were not considered. Workers at the camp could also be exposed to contaminants such as, but not limited to, non-radionuclide contaminated dust, LLRD, etc.

AREVA must address these issues.

ARC Response:

The assumption made in Appendix VII is based on knowledge of the limited interaction of the barren ground caribou with the McClean Lake Operation. Only three times in the last twenty-seven years have barren ground caribou been observed in the vicinity of the McClean Lake/Midwest sites, therefore incremental exposure to McClean Lake Operation emissions, through migration, is very low. Any exposure barren ground caribou could have received while temporarily foraging within the project area, would be negligible. The barren ground caribou consumed are almost exclusively harvested outside of the regional study area and brought back to the community. Supporting information on Caribou migration and residency frequency in the local assessment boundary can be found in the Midwest EIS Main Document, Section 4.5.3.2 Ungulates-Barren-ground Caribou. More information on Caribou in the local assessment boundary and the regional assessment boundary can also be found in the McClean Lake Operation Existing Environment Technical Information Document (COGEMA 2003), Section 5.3.1.1.4.

The dietary values used in the human health risk assessment for the Wollaston Lake community members are based on a survey conducted on the Hatchet Lake Band by CanNorth (2000) which included data on consumption of berries and local garden produce. The survey found that only a small amount of garden produce is grown locally and that most vegetables and fruits are imported. As the Wollaston Lake Lodge operator is only in the study area for the summer months, this receptor was assumed to import all fruits and vegetables other than berries which the operator was assumed to harvest locally while in season.

The effects of the Midwest Operation on the Rabbit Lake Camp Cook were evaluated in the assessment, with the primary pathway of exposure being consumption of drinking water obtained from Collins Creek downstream of the S/V TEMS discharge. The risk assessment for human health only evaluates the effects on non-NEW workers. The combined effects to the non-NEW of multiple operations (e.g. McClean Lake Operation, Caribou mine) are considered in the cumulative effects assessment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-13 With respect to mitigative measures, it is noteworthy that the effluent treatment system proposed for the Midwest Project in based on the (continued) current state-of-the-art in effluent treatment technology. The implications of this mitigative measure are substantial reductions in the COPC discharge loads from those presented in previous assessments on the Midwest Project. The overall effects on receiving water and sediment quality of the combined discharges from McClean Lake and Midwest are shown to not result in adverse effects downstream of the S/V TEMS.

REFERENCES:

Canada North Environmental Services Limited Partnership (CanNorth). 2000. Hatchet Lake Dietary Survey. Field Report. March. Prepared for the Atomic Energy Control Board, Ottawa, Ontario.

COGEMA. 2003. McClean Lake Operation. Existing Environment Technical Information Document.

Document Integration:

No integration is required for Section 7. Section 6, Environmental Effects of the Project, which identifies mitigation measures and identifies residual effects has been updated.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-14 Comment:

Various atmospheric parameters are used to assess the dispersion of air emissions from a facility. As mentioned in Section 4.3, wind speed, wind direction, temperature, precipitation, etc. are important and used in dispersion models. But, if these parameters are site-specific and local, the models are more accurate in comparison to usage of regional data. For example, use of data from McClean Lake may be considered to be valid and acceptable. However, data from La Ronge and even Key Lake may not be acceptable such as temperature data from Key Lake. Additionally, locations such as Collins Bay, Thompson Airport, Cree Lake, etc. are not even on the maps provided. When data are simply not available locally, conservatism is usually applied since the models are then not considered to be accurate as possible. Therefore, use of data from these locations is not acceptable.

AREVA should explain the rationale of using these data as presented in the EIS. AREVA should list the level of conservatism used with the use of regional data. AREVA should also justify on the use of data from different locations and provide the reasons in the document. Finally, AREVA should plan to install equipment to obtain data for the parameters currently not measured at McClean Lake Operation on-site station (e.g., evaporation data, temperature, etc).

ARC Response:

Information on climatology and meteorology for the McClean Lake study area is provided in Appendix XII, which has been added to the Midwest Project EIS submission. This appendix summarizes the surface meteorological data gathered at the McClean Lake on-site meteorology station including wind speed, wind direction and temperature data. As well, this appendix presents a summary of data used in the assessment that are based on measurements made at other stations in the general study area on precipitation (Collins Bay), evaporation (La Ronge and Cree Lake in northern Saskatchewan and Thompson, Manitoba), and cloud cover and ceiling height (Key Lake). The locations of these stations and the rationale for their inclusion in the assessment are presented in Appendix XII.

Document Integration:

Appendix XIV, Air dispersion analysis of nitrogen oxides, sulphur dioxide, radon-222, dust, metals and radioactive elements has been added to the Midwest EIS. This appendix includes information on climatology and meteorology for the Midwest Project area.

Technical Review Response: CNSC Technical Response is incomplete. Review Response The information is found in Appendix XIV, not Appendix XII – as discussed in the response to this comment.

AREVA did not discuss temperature in Section 4.2 other than wind speed and stability (the other two important parameters). Please include temperature information in the final EIS. Type II

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

AREVA acknowledges that the information referred to in our response to the comment is found in Appendix XIV, not Appendix XII, as stated in the regulatory response. Our apology for providing an incorrect reference

While Appendix XIV presents the results of atmospheric dispersion modeling for the Midwest Project it does not include a section on local climatology. The most recent summary of climatological data is provided in the 2009 McClean Lake Status Of the Environment (SOE) report. Climatic data are presented in the SOE covering the 2000 to 2008 period.

Climate stations referenced in the Midwest EIS are shown in Figure 2 (attached below). The Collins Bay climatological station operated by AES is within 13 km of the McClean Lake climatological station and has a longer and more reliable precipitation record than the McClean Lake station. In addition, Cameco Corporation operate a second climatological station adjacent to the AES station which provides an independent set of data to confirm the data collected at the AES station. Given these considerations, the use of precipitation data from the Collins Bay station is justified to augment the McClean Lake station record.

Temperature, wind direction and wind speed data collected at the McClean Lake station were used in the atmospheric dispersion modeling undertaken for the Midwest Project EIA and the McClean Lake SOE. A summary of the hourly data collected at the McClean Lake station over the 2000 to 2008 period is provided in Section 2.1 (Part A) of the McClean Lake SOE. As noted above, precipitation data from the nearby Collins Bay station were used in place of the McClean Lake station data due to short comings in the data record at McClean Lake. June 2010

As lake evaporation data is not collected at the McClean Lake climatological station, data collected at three other stations in the north (i.e. at Cree Lake and La Ronge Airport in Saskatchewan and Thompson Airport in Manitoba) were examined. The data collected at Cree Lake are considered to be the most representative of conditions in the McClean Lake Operation study area and were used in the Midwest assessment. The Cree Lake station, located approximately 223 km to the southwest of the McClean Lake site, was closed in 1993 and moved to Key Lake.

Atmospheric stability is also an important factor in determining how quickly emissions disperse and mix in the atmosphere. The stability class distribution for the McClean Lake site station was calculated using CALMET model. CALMET calculates Pasquill-Gifford stability classes based upon Turner method. Ceiling height and cloud cover from surface data were used in calculation. As ceiling height and cloud cover are not recorded at McClean Lake, observational data from the Key Lake climatological station, located 156 km southwest of McClean Lake, were used. The CALMET model was also used to derive estimates of seasonal mixing heights for the McClean Lake and Midwest sites. The mixing heights under different stability conditions are estimated through different methods based on either surface heat flux (thermal turbulence) and vertical temperature profile, or friction velocity (mechanical turbulence) (Scire et al., 2000). The annual average mixing height at McClean Lake was estimated to equal 370 m.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

While it is preferable to use local climatological data to develop a dataset for use in atmospheric dispersion modeling, it is important to recognize that there are numerous calculations that go into defining the dataset. Furthermore, atmospheric dispersion modeling is usually only undertaken for a typical set of conditions (i.e. a typical year or a five-year period). Hence, the key question is whether the climatological dataset is representative of conditions in the study area. In this regard, we believe that the data used to characterize dispersion conditions at the McClean Lake and Midwest sites are acceptable for assessment purposes.

It should also be noted that regionally representative datasets, created from an amalgam of data from different locations, are required to be used in Ontario (for example) for this type of work because of data quality issues like those outlined above.

Reference:

Scire J.S., F.R. Robe, M. E. Ferneau, and R.J. Yamartino, 2000. A User’s Guide for the CALMET Meteorological Model. Earth Tech Inc.

Document Integration:

Updated Figure 4.2-1 provided in Appendix XIV.

October Technical Review Response: 2010 Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments FIGURE 2: CLIMATOLOGICAL STATIONS IN NORTHERN SASKATCHEWAN, ALBERTA AND MANITOBA

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-15 Comment:

The project will develop a transportation route connecting Midwest site to the existing McClean Lake Operation with potential of fugitive emissions from road construction and eventually road dusts.

AREVA should provide data whether the fugitive dusts have been considered in this analysis.

ARC Response:

Assessment of the effects of vehicular traffic on the haul road connecting the Midwest and McClean Lake sites on TSP and standard pollutant levels along the haul road corridor has been specifically carried out and is presented in Appendix XII Air Dispersion Analysis of Nitrogen Oxides, Sulphur Dioxide, Radon-222, Dust, Metals and Radioactive Elements, of the Midwest Project EIS. The results of the assessment of fugitive dust emissions showed that there may be periods with occasional exceedance of the 24-hour air quality standard for TSP very close to the road unless measures are taken when conditions dictate to reduce dust emissions. TSP levels are predicted to decline quickly with distance from the road. As the road will be constructed on undeveloped lands, there are no residents in the area that would be affected. Nonetheless, AREVA proposes to undertake to reduce emissions when conditions dictate by watering of the haul road following practices and procedures currently employed at the McClean Lake Operation. Effects of vehicle traffic along the haul road on sulphur dioxide and nitrogen oxide levels in the study area are predicted to be well below regulatory standards.

Document Integration:

The updated Appendix XIV Air Dispersion Modeling Assessment has been added to the Midwest EIS.

Technical Review Response CNSC Technical Review Response Response is incomplete.

In Appendix XIV, AREVA did not consider the conservative approach of merging the mining equipment emissions of standard pollutants (SO2, NOx) to power generation sets emissions of standard pollutants into one and assess the effect. The rationale was provided to Type II consider them separately since the power generation sets will last for one year. So, we like to know what will be the effect during that first year? Since the emissions are not high at least for SO2 but NOx is around 28.7 g/s, there is a potential that the effect could be significant for NOx with at least 1-hour average numbers exceeding 400 ug/m3.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

A one year period of onsite power generation was proposed in the original project schedule to fill a gap which existed based on the ability of SaskPower to provide electricity to the Midwest site. With the delay in the Midwest Project schedule, this gap no longer exists; SaskPower will be able to supply electrical power, and continous on-site power generation will no longer be required. Diesel generators however, will be part of the Midwest site infrastructure to supply emergency backup power, similar to the emergency backup power system that exists at June 2010 the McClean Lake Operation. Based on emergency power requirements at the McClean Lake Operation, emergency power at the Midwest site is anticipated to be required infrequently, for short periods of time up to several hours.. Thus the sporadic contributions of emergency power generation to atmospheric emissions are considered inconsequential relative to mining equipment emissions and are not considered in the assessment.

Estimates of GHG produced by the generators will be included in regulatory (NPRI) reporting as is done at the McClean Lake site.

Document Integration:

References to diesel power generation as the main source of power for the Midwest Project have been removed from the pertinent sections of the Main Document.

References to diesel power generation sources to air dispersion modeling at the Midwest site have been removed from Appendix XIV.

Technical Review Response:

October 2010 Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-16 Comment:

Reference: Main Document Page 4-72. Benthic invertebrate indices, including, density, richness, SDI, and Evenness were calculated for the data collected in 2003 and are also reported in Table 4.4-30. Molluscs account for close to 30% of the benthic species found in the MacLean Lake operations. Perceval et al. (2006) showed that bivalves are very sensitive to acid mine drainage despite circumneutral pH of the water and despite good fishing success. This is one of the reasons that the Environment Canada EEM program suggests the use of caged bivalves as an alternative if the routine BI monitoring program is not feasible or as an investigative monitoring tool. Hence, a discussion of the results from the BI monitoring program specific to sphaerids would be of value in this section.

Present a discussion of the BI monitoring program results relative to bivalves.

ARC Response:

Benthic invertebrate communities are the assessment endpoint in this EA and also form an important component of the environmental monitoring program. As indicated in the comment, the benthic invertebrate community endpoints are summarized in Section 4.0. Based on the reference provided, AREVA agrees that a comparison of the current status of sphaerid populations is warranted. AREVA conducted benthic invertebrate community monitoring in 2008, and an evaluation of the current status of sphaerid populations in the McClean Lake area has been included as part of the SOE report (AREVA 2009). No statistical differences in sphaerid populations were seen between reference and exposure area populations.

REFERENCES:

AREVA. 2009. McClean Lake Operation. Status of the Environment Report. Assessment Period 2006-2008.

Document Integration:

No integration required.

Technical Review Response

Acceptable.

CNSC staff reviewed the latest SOE. It shows Sphaerid clams represented a significant portion of the exposure (approx 20 to 50%) and reference communities (20 to 50%, though Mallen was outlier at approx 2%).

Variation through the years needs to be investigated further, however, this will be addresses as part of the CNSC review of the McClean SOE.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment CNSC-17 Comment:

Reference: Main Document - Section 7. The assessment should have addressed process chemical such as flocculants and organics as part of the determination of potential contaminants of concern. If operational data on the concentrations of process chemicals in released effluents are not available, they should be estimated. These estimations should be based on knowledge of the industrial chemical processes involved and designed to produce conservative estimates of effluent concentrations. The conservative estimates can then be used in the COPC screening process.

Complete a COPC screening for process chemicals that may be released to liquid effluents or from stack emissions.

ARC Response:

A screening of process chemicals to identify constituents of potential concern has been conducted and documented in Appendix XII. No additional COPCs were identified.

Document Integration:

Appendix XII CNSC Technical Technical Review Response: Review Response The response is acceptable from liquid effluent perspective. The conservative screening process in Appendix XII is acceptable. COPC screening for stack emissions is not addressed in the response. This should be addressed.

Type II

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

ARC Response:

In the JEB mill process, four organic reagents are employed; flocculant, kerosene, isodecanol and a tertiary amine. Atmospheric release of organic reagents from the JEB mill occurs through two processes; combustion and volatization.

Flocculants consumed in the Yellowcake Calcining process are combusted to carbon dioxide and nitrogen oxides in the calcining hearth, during the process in which the yellowcake product is converted from ammonium diuranate to uranium oxides. Under the hearth conditions, complete oxidation of flocculant will occur.

A screening assessment of the atmospheric emissions associated with volatile organic compounds (VOC) in the JEB mill Solvent Extraction (SX) process is provided below.

Atmospheric emission of volatile organic compounds from the JEB mill to the receiving environment.

CNSC Technical The JEB mill SX process is responsible for extracting soluble uranium from the acidic solution produced in the leaching process. The Review aqueous solution, enriched in uranium and other dissolved metals, is contacted with an organic solution which preferentially removes the Response uranium from the aqueous solution. The organic solution matrix is composed of three organic components:

 92-95% kerosene;

Type II  2-3% isodecanol, and  3-5% tertiary amine.

Kerosene is used as an organic carrier. Isodecanol is a phase modifier and also used to mitigate the effects of dissolved salts. The tertiary amine, with a high affinity for uranium, is responsible for sequestering uranium to the organic phase.

Organic losses in the SX process are primarily due to organic carryover to the raffinate waste stream, which is treated in the Tailings Neutralization and Preparation process. A very small portion of organic, primarily kerosene, is lost to the atmosphere due to volatization.

In determining the environmental impact of volatile organic compound (VOC) losses from the McClean Lake mill SX process to the surrounding environment, due to organic volatization, results from an Occupational Health and Safety monitoring program were used. The program assessed the kerosene concentrations in the atmosphere that personnel working in the SX facility were exposed to. The mill operators working in the SX facility were chosen for monitoring as they occupy the facility for the greatest duration of time, and are required to handle the solvent directly as part of their routines.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

To achieve a representative indication of personnel exposure, both day and night shift personnel were monitored for a period of two weeks in July 2004. Sampling and analysis followed the National Institute for Occupational Safety and Health (NIOSH) validated method, 1550. This method consists of drawing a measured volume of atmosphere through a filter tube containing activated charcoal. Volatized kerosene is filtered from the sampled air onto the charcoal media. The sampling equipment is worn by the operator for the entirety of their shift in the SX facility in order to collect a time weighted average. The sampling apparatus is then processed at an accredited analytical laboratory (Schlecht & O’Connor, 2003). Figure 1 summarizes the results from this program.

Figure 1. Kerosene exposure rates to personnel in the JEB mill SX facility through atmospheric volatization.

110

100

NIOSH REL exposure limit: 90 10 hour time weighted average = 100 mg/m3 )

3 80

50 45.5 41.8 40

29.6

Kerosene exposure (mg/m 30 23.2 20 15.1 15.4 16.4

10 7.7 6.3

0 ABCDEFGHI Personnel kerosene exposure during an 11 hour period

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Results of this monitoring program indicate that kerosene exposure via inhalation is below the NIOSH time weighted average exposure limit of 100 mg kerosene per cubic meter of atmosphere. These results are indicative that kerosene volatization within the SX facility is minimal. This can be ascribed to tanks and vessels containing kerosene being sealed during routine operations. To further minimize kerosene volatization, equipment is operated in a manner as to minimize agitation of the solvent solution to prevent aerosolization.

The lowest observable toxic affects due to kerosene exposure through an inhalation pathway has been determined as 2,500 mg/m3/2 hours (Volkova et al., 1998). The SX sampling program determined that personnel working in the SX facility are below both the acute toxicity and NIOSH TWA limits.

Considering that the measured VOC concentrations were obtained from individuals working within close proximity to the cells and vessels containing kerosene, it can be expected that VOC exposure outside of the facility is significantly lower. Based on this screening assessment, it can be concluded that atmospheric emissions of VOCs from the JEB mill process have negligible interaction with the receiving environment.

Midwest Project atmospheric emissions - elements of concern.

The atmospheric emissions which are carried forward in the assessment are presented in the Midwest Project Environmental Impact Statement main document, Section 7.2.1; Predicted affects on air quality. Predicted metal, metalloid and radio-isotope concentrations from the Midwest Project site and the McClean Lake Operation are presented in Table 7.2-2, for seven receptor locations.

References:

Schlecht, P.C. and O’Connor, P.F. National Institute for Occupational Safety and Health manual of analytical methods. Fourth edition. 2003.

Volkova, N.V. et al. 1998. “Vrednie chichescie veshestva. Prirodnie organicheskia soidinenia”. Hazardous substances. Nature Products. Sankt-Peterburg. 1998.

Document Integration:

Appendix XII Technical Review Response: October 2010 Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-18 Comment:

Reference: Chapter 7 Assessment of Residual Effects and Appendix VI Table 4.2-3. It was noted that the transfer factor for water lead concentration to bottom feeding fish flesh was based on one whitefish from the Beaverlodge Lake area. This is an inadequate database for the development of a transfer factor.

The use of data from a single fish is inappropriate. A literature value developed from a replicated database should be used for this transfer coefficient.

ARC Response:

The TF for lead to bottom-feeding fish was set to a lognormal distribution with a geometric mean of 30 L/kg(FW) and a range of 0.76 to 1200 L/kg (FW). The following generic literature values were obtained: • U.S. NCRP 1996: 300 L/kg (FW) • IAEA 1994: 100-300 L/kg (FW) • Bird and Schwartz 1996: 40 L/kg (DW) or approximately 6 L/kg (FW)

All references are provided in Appendix VI. It is noted that the TF for lead provided by Bird and Schwartz (1996) is based on information on fish in Canada. Considering the distribution used in the assessment and the range of generic TFs available from the literature, it is determined that the TF used is appropriate. It is also noted that the SI values for ecological receptors that consume fish (mink, merganser, eagle) are well below the acceptable threshold and small changes to the fish TF would not result in any change to the conclusions.

REFERNCES:

Bird, G.A. and W. Schwartz. 1996. Nuclide Concentration Factors for Freshwater Biota. AECL. Technical Record TR-703.Cameco Corporation 2002. Key Lake Operation, 2001 Aquatic Monitoring Program, Key Lake Mine Site, Saskatchewan. Prepared by Golder Associates. April.

Document Integration:

No integration required.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-19 Comment:

Reference: Reference: Chapter 7 Assessment of Residual Effects and Appendix VI Table 4.2-3. Additional information is required on the generation of the transfer coefficient used for modeling water concentrations to benthic foraging fish. A CNSC staff review of data from exposure sites in the Key Lake and Beaverlodge areas provides Bioaccumulation Factors of approximately 6000 to >16,000.

Present the data and the justification for the selection of these data used in the calculation of the transfer coefficients for selenium.

ARC Response:

The transfer factor (TF) used in the assessment for selenium for benthic foraging fish was calculated assuming a lognormal distribution with a geometric mean of 3100 L/kg (ww) and a range of 200 L/kg to 48,000 L/kg (ww). A summary of the data used to calculate the selenium TF based on data from the Key Lake and Beaverlodge study areas has been added to Appendix VI as Table 4.2-3b. Also shown in this table are generic TFs from literature sources. The values reported in the literature were found to fall at the low end of the distribution of values reported above. The TFs that were calculated based on Key Lake and Beaverlodge data are in good agreement with the distribution applied in the assessment. The range of TFs is large and encompasses the range of concentrations that may reasonably be expected.

Document Integration:

No change required to calculations. Table 4.2-3b has been included in Appendix VI.

Technical Review Response

The response is acceptable pending incorporation into follow-up program.

Reviews of recent northern Saskatchewan studies indicate a reasonable range for a Se BAF is between 900 to 6000 depending on the fish species (Cameco 2009). Hence, the value used by AREVA adequately captures this range. The documentation of the Saskatchewan data in the Appendix also shows that the BAFs vary substantially on a site-specific basis. However, the Saskatchewan data consistently demonstrates that Se bioaccumulation in fish within the northern Saskatchewan environment tends to be substantially elevated relative to other environments.

Hence, Se behaviour within the aquatic receiving environment merits specific inclusion in the site environmental management system and associated monitoring program should the project move to licensing.

Cameco 2009. Key Lake Operation Mo/Se Reduction Update Supporting Studies. October 2009.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

Acknowledged

Selenium fish tissue (i.e., flesh, bone, liver, kidney) analysis is currently included in the environmental monitoring program (EMP) at the McClean Lake Operation (AREVA 2008) and will be incorporated into the Midwest site EMP where appropriate. Selenium fish tissue concentrations will continue to be monitored and reported in Status of the Environment Reports every three years. Please refer to main document Section 12 - Follow-up and Monitoring for an outline of the proposed monitoring program.

Reference

AREVA Resources Canada Inc. (AREVA). 2008. McClean Lake Operation Environmental Monitoring Program. Locations, Frequencies and Parameters. Version 7. September 2008.

Document Integration: No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-20 Comment:

Reference: Chapter 7 Assessment of Residual Effects and Appendix VI Table 4.2-3. The inclusion of shiners, stickleback and dace in the database used to develop the selenium transfer coefficient from water to predator flesh does not seem appropriate. Indeed, the term predator here is incorrect as all the fish modeled, including the benthic foraging fish are predators. The northern pike in this risk assessment is serving as a representative piscivore (fish eating fish). Hence, shiners, dace and stickleback, which are not piscivores, should not be included in this dataset. This distinction is especially important when modeling Se uptake as diet is the primary contaminant pathway.

Present the data and the justification for the selection of these data used in the calculation of the transfer coefficients for selenium. What effect does removing shiners, dace and stickleback from the transfer coefficient have on the modeling?

ARC Response:

The TF used in the assessment for selenium for predatory fish was a lognormal distribution with a geometric mean of 1500 L/kg (ww) and a range of 96 L/kg to 22,000 L/kg (ww). We agree that shiners, stickleback and dace do not fit the definition of a predatory fish and thus the data used to calculate the selenium TFs was re-examined without the Elliot Lake information. This is shown in the Table 4.2-3b; also shown in this table are the generic TFs from literature. The calculated TFs using the Beaverlodge and Key Lake data were found to be in good agreement with the distribution applied and therefore the distribution is appropriate.

In addition, it is noted that a “hockey-stick regression” type model was developed for selenium uptake by fish based on measurements collected from the McClean Lake and Rabbit Lake areas, similar to a Toll-Brix model. This is discussed in detail in the Rabbit Lake Solution Processing Project EIS (AREVA and Cameco 2008). The use of this model leads to a transfer factor of 2300 L/kg (ww).

REFERENCES:

AREVA Resources Canada Inc. (AREVA) and Cameco Corporation (Cameco). 2008. Rabbit Lake Solution Processing Project Environmental Impact Statement (EIS).

Document Integration:

No change required to calculations. Table 4.2-3b has been included in Appendix VI.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response

The response is acceptable.

A recent review of the Saskatchewan field data indicates that the use by AREVA of 1500 L/kg is likely to be a conservative representation of the BAF for a piscivorous predator such as northern pike (Cameco 2009).

Cameco 2009. Key Lake Operation Mo/Se Reduction Update Supporting Studies. October 2009

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-21 Comment:

Reference: Main Document Chapter 7 - Page 7-33. Reviewers have not been able to locate a table of predicted benthic and piscivorous (sic predator) fish selenium tissue levels for Sink, Vulture, McClean, and Kewen Lakes. These should be provided once the previous comments with respect to the selenium transfer coefficients have been addressed.

The report does indicate that predicted predator and bottom feeding fish flesh in McClean Lake east basin range from 1.0 to 2.0 µg/g wet weight. These would convert to 5 and 10 µg/g dry weight (using 80% moisture) which places fish in McClean Lake in the proposed threshold range indicating potential effects. Predicted tissue levels in sink and Vulture are assumed to be higher. Hence, the risk assessment would indicate the potential for selenium fish effects that would require further follow-up. As indicated in the first paragraph of page 34 AREVA already recognizes this issue and is presently pursuing selenium investigations at the site.

The text at the bottom of page 33 should be modified to indicate that there is the potential for selenium tissue levels to exceed threshold levels. These exceedances are not predicted to be substantial and are presently being investigated.

ARC Response:

AREVA has recognized the potential for selenium fish tissue concentrations to exceed threshold levels and has conducted targeted research in the aquatic receiving environment at the McClean Lake site, including the immediate receiving water bodies, to gain a better understanding of the potential for selenium effects (Muscatello and Janz 2009). The data presented in Section 7.2.5.3 of the Midwest EIS has been updated to capture this new information.

In addition, measured Se concentrations have been added to Table 4.4-44 for benthic fish species and to Table 4.4-46 for piscivorous species, as described in the disposition to Comment HC-28. Current Se concentrations of 1.7 µg/g ww and 1.9 µg/g ww have been measured in northern pike and white sucker, respectively, from Vulture Lake (AREVA 2009). These tissue concentrations are below regional benchmarks for Se in fish muscle tissue that have been developed based on data collected at the Key Lake Uranium Milling Operation (Muscatello et al. 2006). Selenium concentrations in fish tissues will continue to be measured as part of AREVA’s monitoring programs.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-21 Predicted Se levels in the tissues of benthic and piscivorous fishes in Vulture, McClean and Kewen Lakes, are as follows: (continued) Predicted Mean Predicted Mean Selenium Concentration Selenium Concentration Location in Predator Fish Tissue in Benthic Fish Tissue (µg/g ww) (µg/g ww) Vulture Lake 5.8 11.5 McClean Lake East Basin 1.0 2.0 Kewen Lake 0.7 1.4

In general, evaluation of measured and predicted Se data for benthic and piscivorous fishes indicates elevated levels in Vulture Lake. This is not unexpected, since Vulture Lake is located in the immediate aquatic receiving environment as part of the Sink/Vulture Treated Effluent Management System (S/V TEMS). The predicted tissue concentrations are considered conservative. Fish tissue concentrations will continue to be monitored and compared to proposed tissue effects thresholds as part of the McClean Lake Operation environmental monitoring program and Status of the Environment reporting requirements.

REFERENCES:

AREVA 2009. Status of the Environment Report: McClean Lake Operation, Assessment Period 2006-2008.

Muscatello, J.R. and D.M. Janz, 2009. Assessment of larval deformities and selenium accumulation in northern pike (Esox lucius) and white sucker (Catostomus commersoni) exposed to metal mining effluent. Environmental Toxicology and Chemistry, 28: 609-618.

Muscatello, J.R., P.M. Bennett, K.T. Himbeault, A.M. Belknap and D.M. Janz, 2006. Larval deformities associated with selenium accumulation in northern pike (Esox lucius) exposed to metal mining effluent. Environ. Sci. Technol., 40: 6506-6512.

Document Integration:

Chapter 7 of the Midwest EIS has been updated to include available information on targeted research that has been done on Se in benthic and piscivorous fishes at the McClean Lake Operation and the appropriate reference has been added. Predicted Se fish tissue concentrations provided in the disposition to comment CNSC-21 above for Vulture Lake, McClean Lake east basin and Kewen Lake have also been incorporated in Chapter 7, Section 7.2.5.3.

In addition, measured Se concentrations have been added to Tables 4.4-44 and 4.4-46 for benthic and piscivorous fish species, respectively.

Technical Review Response

The response is acceptable pending incorporation into follow-up program.

Specialized Se monitoring and investigation programs will be required within the follow-up program which will be incorporated into any

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment future licensing should the project move forward.

ARC Response:

Acknowledged.

Selenium fish tissue (i.e., flesh, bone, liver, and kidney) analysis is currently included in the environmental monitoring program (EMP) at the McClean Lake Operation (AREVA 2008) and will be incorporated into the Midwest site EMP where appropriate. Selenium fish tissue concentrations will continue to be monitored and reported in Status of the Environment Reports every three years. Please refer to main document Section 12 - Follow-up and Monitoring for an outline of the proposed monitoring program.

Reference AREVA Resources Canada Inc. (AREVA). 2008. McClean Lake Operation Environmental Monitoring Program. Locations, Frequencies and Parameters. Version 7. September 2008.

Document Integration: No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-22 (1) Comment:

3. Description of the Project

there is no description of how the 2 to 7 m deep sediments from Mink Arm will be removed and handled. Since the sediments have elevated levels of some contaminants storage and management of the solids and decant water from these sediments could be a significant undertaking with potential impacts to the environment if not handled properly

ARC Response:

The construction and development of the Midwest mine has been optimized to minimize environmental interactions. The 2 to 7m deep sediments from Mink Arm will be mined frozen in the winter to minimize the potential leakage of decant water. Sediments will be segregated from the clean waste rock stockpile and will form the base of the special waste stockpile.

The special waste stockpile area is located at the south end of the Midwest pit and will be naturally graded toward the pit. A site collection runoff area for the special waste stockpile will be positioned adjacent to the perimeter road approximately 75 meters from the pit. As the sediments melt, and decant water is released, the surface runoff will be directed and collected at the site runoff collection area and transferred to the site runoff pond for treatment at the Midwest Water Treatment Plant (WTP). The special waste area and site runoff collection area will be hydraulically contained within the footprint of the pit. Ground water flow from this area will be intercepted by the mine sump for treatment at the Midwest WTP.

At the completion of mining the special waste stockpile and any contaminated based materials will be excavated and placed at the bottom of the Midwest pit and capped with a till cover.

Document Integration:

Section 3.2.2.2.3, Section 3.2.5.3

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response

Response is unacceptable – the management of Mink Arm sediments is not sufficiently described and assessed; an alternative plan or contingency may be required

CNSC Technical Management of Mink arm sediments Review Response - will be mined in winter to minimize potential leakage of decant water, however this probably won’t work as sediments are 2-7 m thick and will be covered by about 0.5 to 1 m water so only the top will freeze - if sediments don’t completely freeze and can’t be mined within a reasonable time period, what are the alternatives and what would the impacts of these alternatives be? Type I - runoff will be collected in site runoff collection area, which is unlined, so potentially contaminated runoff from the sediments could seep into the groundwater and possibly contaminate groundwater dewatering wells

- document integration referred to in the response do not include the information provided in the response - a geotechnical assessment of placing sediments with high slimes content as the base for a special waste rock pile should be completed to justify this sediment management approach; a contingency plan should be proposed and assessed in the event there are problems with the sediment providing an adequate base (eg. delayed thawing, sediments don’t dewater, etc)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

The previously stated 2 to 7 meters is the approximate depth of the total overburden and sediment thickness based on historical drilling investigations. Initial soundings and historical lake sediment thicknesses in the area suggest that a thickness approaching 1 meter is the appropriate average to use for the lake bottom sediment. The surface area of the lake to be de-watered and mined approximates 515,000 m2 generating a volume of 515,000 m3 of sediments.

Past experience in mining these types of sediments at the McClean site (Sue E), Cluff Lake site (Claude) and at the Rabbit Lake site confirm that this material can be successfully mined in both winter or summer months. Depending on the moisture content of the material various means of excavation and loading techniques have been used to either selectively segregate or mix the sediments with the underlying overburden material. “Tailgating” or under-loading of the haulage units is commonly used in wetter material to retain the load in the truck and minimize the spillage from the loads. If sediments are mined during winter months, efforts will be made to minimize the frost penetration. It is anticipated that the sediment excavation will occur over a period of approximately two months using a conservative production schedule, as such adequate flexibility in mining schedule exists to allow mining in the most optimal conditions. All sediment will remain within the brow of the lake perimeter until it is mixed with overburden such that decant water will be contained within the active mining areas.

June 2010 Currently a geotechnical analysis is underway to develop a mixing strategy for sediment and overburden material to generate a competent base for the special waste stockpile while minimizing permeability. Based on previous geotechnical testwork and performance of the Sils Lake sediments in proximity to the Sue E pit, it is anticipated that a mix of 1:1 of sediments and overburden material will generate material that will form a competent 4.4 meter base for the special waste stockpile. If more sediments are encountered the height of the base can be easily extended to accommodate. The special waste pad base design could be further supported through buttressing and drainage included as part of the perimeter road design. The results of these analysis and designs will be provided prior to licensing.

The sediment chemistry results indicate that the concentrations of contaminants are low as detailed in Table 4.4-7 in Section 4. When compared to Canadian Soil Quality Guidelines (CSQG), all contaminants of potential concern (COPC) are below CSQG with the exception of arsenic, and therefore present a very low risk when excavated and stored on the surface. The sediment will be mixed with overburden and any concentration of COPC in the sediment runoff leachate will have lower concentrations than those currently measured in the sediments. The wastewater treatment facility is designed to treat all dewatering well water so if sediment run-off influences the quality of dewatering well water, it will be managed.

As discussed above, a geotechnical assessment is underway to characterize the properties of the sediment. Operational controls will be put in place to ensure the stability of the stockpile and minimize the permeability of the base through the development of an appropriate overburden mixing strategy.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration:

Section 3.2.2.2.3

Technical Review Response:

October 2010 Adequate. Additional information provided. Geotechnical analysis of lake sediment as a base for special waste pile needs to be provided with license application

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-22 Comment: (2) There is no satisfactory description in this chapter or elsewhere of how Midwest off-spec water from the chemical water treatment plant will be handled. Since there is no monitoring pond compliance with discharge standards is determined as the effluent is discharged to the McClean pipeline. On the one hand it is stated that the McClean pipeline only need be single-walled because the effluent will be clean but on the other hand the proponent allows for the possibility that if the effluent does not meet spec that it can be handled in the S/V TEMs. Aside from this being contradictory the risk is not with occasional off-spec effluent but rather with prolonged periods of effluent non-compliance – the rationale for a single- walled pipe in this instance is not valid so the proponent needs to address this.

ARC Response:

The effluent from the chemical water treatment plant is pumped to one of three monitoring ponds prior to discharge to the pipeline which will convey the combined effluent from the Midwest site to the Sink/Vulture Treated Effluent Management System (S/V TEMS). In a similar manner as in place at the McClean Lake Operation JEB WTP, a composite water sample taken during pond filling will be analyzed to confirm that the pond contents meets discharge limits. Upon confirmation of the suitability for discharge, the monitoring pond will be pumped to the effluent surge tank for discharge to S/V TEMS. Water that does not meet the discharge criteria will be recycled to the water treatment plant feed for re-treatment. The pond discharge water will be automatically sampled at the designated MMER discharge points to ensure that water being released to the combined discharge pipeline to the S/V TEMS is consistently within the regulatory limits. Figure 3.5-2 clarifies the water management from the chemical water treatment and the proposed criteria for approved release of dewatering well water and treated effluent.

Document Integration:

Main Document, Section 3.5.1.2.2, Figure 3.5-2.

Technical Review Response Response is unacceptable – the wastewater treatment process at Midwest is not sufficiently described and assessed; a contingency plan may be required CNSC Technical Wastewater treatment at Midwest Lake Review Appendix V indicates that the estimated quantity of reject brine from the RO membranes would be 1680 m3/d and the RO permeate would be Response 23,320 m3/d. This would indicate a reject ratio of less than 7%. This reject ratio is considered to be very low and no information is provided to justify

the low reject quantities and volumes of water for chemical treatment.

Type I Sufficient information is not provided on the pretreatment processes to be used for the RO plant, nor is this stage indicated on Figure 3.5-2. If multimedia filters are used in this pre-treatment, no provision is noted for the handling of any backwash water required. Table 3.4-5 assumes the same water quality from the Midwest conventional chemical treatment plant as for the JEB WTP. This assumption is questioned as no high pH process for improved removal of uranium and some heavy metals are identified as a component of the proposed Midwest chemical treatment plant.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

It is indicated that the sludge from the chemical treatment plant will be stored and trucked to the JEB mill for processing in the tailings neutralization circuit. No contingency is noted for situations where the mill process may be shut down.

Overall water balance and mass loading of contaminants in effluent and sludge, pretreatment rejects should be better identified.

Figure 3.5-2 doesn’t match with some text statements and is incomplete - does not identify the capacity of pretreatment (sec 3.5.1.2) - does not identify the capacity of chemical WTP (2000 m3/d too small?) - does not allow inputs to chemical WTP other than through the RO (eg. special waste runoff pond, mine sump) - does not identify the permeate discharge to Too Small Lake to maintain water levels (sec 3.5.1.2.2 / CNSC 4(4))

From NRCan-15 RO capacity of 25,000 m3/d may not be enough – contingency?

Areva says it should be enough but this assumes full treatment capacity can be obtained – what if it isn’t reached or is intermittent? No contingency was provided as requested

ARC Response:

Process Description

3 The Midwest Water Treatment Plant (WTP) has been designed to treat 25,000 m /d of contaminated water from the Midwest open pit mine (5,000 June 2010 m3/d) and perimeter dewatering wells (20,000 m3/d). In addition, the plant also receives a small amount of seasonal site run-off, truck wash from the Midwest mine maintenance shop, and other waste streams (special waste run-off). The treated effluent will be discharged to Sink Reservoir.

The selected water treatment is a multi-stage, integrated treatment process comprised of chemical pre-treatment, reverse osmosis (RO), followed by chemical treatment of the RO reject water. The pre-treatment stage consists of a pH 11 precipitation, clarification, pH adjustment, sand filtration and cartridge filters. The chemical treatment plant with a capacity of 1,500 m3/d replicates the three-stage treatment process of the existing JEB WTP which includes a pH 11 precipitation to remove most heavy metals, a pH 4.5 precipitation with addition of ferric sulphate and barium chloride to remove arsenic, molybdenum, Ra-226 and selenium, then finally a pH 8 polishing step. Both the RO permeate and the treated water from the chemical treatment will be monitored for compliance with the regulatory limits prior to discharging via a 21 km single-walled HDPE pipeline to Sink Reservoir.

Any solid and liquid wastes produced from the water treatment plant will be thickened by a centrifuge and stored in an agitated sludge mix tank in the plant. This sludge, estimated at 300 m3/d, will be trucked to the JEB mill, where it will be stored in a 50 m3 sludge storage tank for blending with the mill tailings in the tailings neutralization circuit. There is approximately 2-3 day contingency storage for the sludge within the WTP (there are 2 Sludge Holding Tanks and a Master Holding Tank). A 20m3 tanker truck based at McClean Lake will be used to haul the sludge using the dedicated haul road between the Midwest WTP and McClean site.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

The primary and secondary RO systems will remove over 99% of all dissolved contaminants in the feed water. Their respective permeate recovery rates are 90% and 75-80%. Permeate from both RO systems is collected in a permeate holding tank where caustic will be added to adjust the water pH to 7. Some of the permeate is used for filter backwashing, RO flushing and reagent make up. The remainder is pumped to an effluent surge tank and discharged via pipeline to Sink Reservoir.

Effluent from the chemical treatment will be discharged to one of three effluent monitoring ponds. Each pond will be designed for a retention time of 24 hours. This retention time allows sufficient time for the fill, monitor, and discharge cycle. While one pond is being filled, the second pond is discharged, and the third is awaiting analysis. If the effluent meets the discharge criteria, it is pumped to the effluent surge tank where it is combined with the permeate, and discharged to Sink Reservoir. Water that does not meet the discharge criteria is recycled to the settling pond for re-treatment.

The Midwest WTP has a nominal capacity of 25,340 m3/d with a design safety factor of 10% for peak flows. Furthermore, a contingency pond is installed for any upsets to the system or unexpected shutdowns of the WTP. The contingency pond has a holding capacity of 37,500 m3, equivalent to 36 hours of plant feed storage. This pond can also be used as contingency storage (approximately 125 days) of sludge from the chemical treatment plant in case the JEB mill is shut down and unable to receive the sludge.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS

Addendum

Response to Federal Comments

A block diagram of the Midwest Water Treatment system is shown in Figure 1.

Contingency to Offset Local Lake Drawdown

Clean Water Bypass X Effluent De-watering X Sink Surge Wells Reservoir Tank X Permeate Tank Permeate

Permeate X X X Secondary Pre-settling Settling Primary Pre Reject Secondary Primary RO Pre- Pond Pond treatment RO treatment Effluent Reject X Pit Sump Sludge Effluent Recycle Chemical X Monitoring Treatment Ponds Off-spec Site Run-off

Sludge Contingency Pond Trucked to JEB Tailings Sludge Neutralization

Legend Main flow Intermittent or alternate flow X Sample point for process control or chemical analysis

Figure 1: Block Diagram of the Midwest Water Treatment System

AREVA Resources Canada Inc. September 2011

Midwest Project – EIS Addendum

Response to Federal Comments

Effluent Monitoring Measures  Each RO system is comprised of parallel RO units containing membrane housing arrays. Pressure and flow are monitored within units.

 A conductivity meter is located on the discharge of each RO system to monitor permeate for any sudden upsets. A failed RO unit can be quickly taken off line for inspection and remediation. Both primary and secondary RO systems are designed with sufficient capacity to handle additional hydraulic loading when one unit is bypassed for maintenance.

 The pH of the permeate stream entering the permeate tank is monitored and controlled for any necessary pH adjustments. The pH of the water exiting the permeate tank is also monitored to ensure compliance with environmental regulations.

 12 hour composite samples of the combined permeate will be taken by an automatic sampler for chemical analysis to ensure the permeate remains high quality.

 A 24 hour composite sample is taken from each monitoring pond fill for chemical analysis to ensure the effluent from the chemical water treatment plant meets regulatory requirements prior to blending with the permeate for discharge to Sink Reservoir.

 A 24 hour composite sample is taken from the discharge of the effluent surge tank to Sink Reservoir will be taken to ensure the discharge stream meets the effluent discharge criteria. Internal action levels will be established for the final effluent.

Document Integration

Main Document, Section 3.5.1.2.2, Figure 3.5-2.

Technical Review Response :

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-22 (3) Comment:

There is no complete listing of the types of materials and frequency of all traffic on the proposed new road i.e. ore, treatment plant sludges, garbage, what else and how often in one table please.

ARC Response:

Acknowledged, AREVA has included a table of materials, frequency of activities and vehicle types.

Document Integration:

Main Document, Section 3.3.4 and Table 3.3-3.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC 22 (4) Comment:

The description of the Midwest special waste handling is incomplete i.e. what kind of liner, how will collected leachates/runoff be handled, how long after the pit is done before these wastes are put into the pit?

ARC Response:

A liner is not planned for the special waste stockpile at the Midwest Site. The special waste area will be managed similarily to the McClean Lake Operation in that the special waste stockpile will be hydraulicly contained within the footprint of the Midwest pit.

The special waste stockpile area is located at the south end of the Midwest pit which is naturally graded toward the pit. A site collection runoff area for the special waste stockpile will be positioned adjacent to the perimeter road approximately 75 meters from the pit. Surface runoff will be directed and collected at the site runoff collection area. The special waste area and site runoff collection area will be hydraulically contained within the footprint of the pit and subsequently ground water will be intercepted by the Midwest pit mine sump for treatment at the Midwest water treatment plant.

At the completion of mining the special waste stockpile and contaminated based materials will be excavated and placed at the bottom of the Midwest pit and capped with a till cover. Section 3.10 indicates that the decommissioning phase of the Midwest project is estimated to take two years.

Document Integration:

Section 3.5.2.3

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response The response is unacceptable – the relationship between dewatering wells and Mink Arm sediments associated with the special waste facility are not sufficiently described and assessed.

Description of Midwest special waste handling - no information is provided on where the dewatering wells would be located in relation to the special waste handling area. They are not CNSC Technical Review shown on Figure 3.2-8 General Site Layout Alternate Option 3. This general layout plan shows the Special Waste Stockpile and the Pre- Response sedimentation Ponds in close proximity to the pit crest. The Special Waste Stockpile won’t have a liner so seepage will report to the pit. If the dewatering wells are located between the Stock Pile and the pit, the dewatering wells could become contaminated and the volume of those contaminated waters could exceed the currently envisioned capacity of the Midwest wastewater treatment facility. Leachate from the Pre-Sedimentation Ponds could add to the problem. Type I - a geotechnical assessment of placing frozen and partially frozen sediments with high slimes content as the base for a special waste rock

pile should be completed to justify this proposed practice

- Areva should provide a schedule of development to indicate the time estimated to remove and stockpile all Mink Arm sediments, at what point special waste material could be encountered and need to be stockpiled, and the expected schedule of when different types/quantities of contaminated water would be expected from all sources

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

The dewatering wells are shown on the attached drawing, 240C030 and in Appendix 4, Figure 4.4.

The base of the special waste stockpile will be constructed with low permeability native material to reduce the risk of impacting the dewatering wells, discussed further in response CNSC-22(1). The pre-sedimentation ponds will also be constructed to ensure minimal permeability. The dewatering wells located in the southern portion of the dewatering well ring will not be screened through the overburden such that leachate from the ponds and the special waste stockpile will be minimized. Given that the Special waste stockpile and underlining base will be removed from surface and placed in the final pit at completion the opportunity for significant migration of leachate towards the dewatering wells will be limited. In the event of such an occurrence the Midwest wastewater treatment facility has been designed in a conservative manner, in that it will have the capacity to treat 100% of all dewatering well water and in-pit sump water at the maximum pit depth. June 2010

A geotechnical assessment using sediment as base material is underway and further explained in response CNSC 22(1)

The mining of Mink Arm sediments is expected to take approximately 6 to 8 weeks. It is anticipated that the first areas of potential Special waste material will occur below the 430 masl of the pit. Based on currently anticipated mining rates this level of pit development will be

achieved approximately 7 months after the start of mining allowing for adequate time for the construction of the special waste pad.

Appendix 4, Figure 4.3 presents the predicted water inflow rates over 5 years. For this analysis, it was assumed that the dewatering well pumping rate would remain constant at 20,000 m3 per day. As discussed, the Midwest wastewater treatment plan will be designed to accommodate all water generated from the start of the dewatering wells and in-pit sump pumping. The approach to the designed capacity

of the wastewater treatment plant is conservative since the maximum inflow will only be reached at the end of mining and, based on the experience at the JEB TMF where none of the dewatering wells discharge required treatment, it is anticipated that at a minimum some of the dewatering well water will be of suitable quality that treatment will not be required.

Document Integration:

None Required

Technical Review Response:

Adequate

October 2010 AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

AREVA Resources Canada Inc. Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CSNC-23 Comment:

3.7.1.2 Leakage from External Ponds Page 3-81. There is no mention of piezometers at or around ponds to monitor groundwater for contamination.

ARC Response:

Piezometers will be installed around the Midwest pit and the waste rock piles to monitor the groundwater flow regime during mining. At this time it is planned to install a ring of piezometers around the Midwest pit (for instance between the dewatering wells and the pit) to monitor the efficiency of the dewatering wells. It is also planned to install piezometers around the waste rock piles and the water treatment ponds to monitor trends in groundwater quality in the vicinity of these facilities. The monitoring locations and frequencies will be established during the licensing process.

Document Integration:

No integration required.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-24 Comment:

Section 4.4.3.2.2 At Cluff Lake Zooplankton diversity was significantly reduced during operations in Island Lake. Could zooplankton monitoring in receiving water bodies (i.e. S /V TEMS and downstream) be an effective method of determining aquatic ecological changes during operational and decommissioning phases? Are there any data existing for these water bodies?

ARC Response:

Baseline monitoring data for zooplankton does exist for some lakes in the McClean Lake Operation and Midwest Project areas (Tables 4.4- 16 to 4.4-20, and Figure 4.4-3). Table 4.4-16 of the Midwest EIS summarizes the zooplankton sampling that has been completed in lakes in the vicinity of the Midwest site from 1978 to 2003, while Tables 4.4-17 to 4.4-19 summarize some of these data. More detailed results can be found in the Midwest Technical Information Document (TID) (AREVA 2009) and the Midwest Uranium Project EIS (MJV 1991). More data, including baseline and operational data, can be found in the McClean Lake TID (AREVA 2004). The Midwest Project TID has been submitted to the appropriate reviewers and is now available.

Currently, zooplankton sampling is not part of the Environmental Monitoring Program at the McClean Lake Operation although some monitoring has been done in the past and baseline data is available. There are no plans to include zooplankton community monitoring in conjunction with the proposed development of the Midwest Project. In addition, as noted in the response to Comment DFO-7, the benchmark applied would be protective of benthic invertebrates, as well as zooplankton.

REFERENCES:

AREVA. 2004. McClean Lake Operation. Technical Information Document.

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

Midwest Joint Venture (MJV). 1991. Midwest Uranium Project Environmental Impact Statement.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response

The response is acceptable.

The Aquatic Effects Technology Evaluation Program concluded that the seasonal and highly variable nature of phytoplankton and zooplankton populations and community compositions limited their use as routine monitoring tools for evaluating environmental performance of a facility. Hence, there is presently no need to incorporate monitoring of these biota within the routine monitoring program.

They do however; retain the potential for use in non-routine investigative assessments and/or research (e.g., Se investigations). It is recognized that AREVA is presently proposing to utilize periphyton monitoring at the McClean Lake operation as part of their MMER Investigation of Cause monitoring program. The results of this activity should be used to inform the next review of the ERA in the next version of the sites Status of the Environment Report (i.e., 2009 to 2011 reporting period).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-25 (1) Comment:

6. Environmental Effects of the Project Effect of residual contamination in the Midwest pit walls is not evaluated re: water quality in the decommissioned flooded pit Incomplete evaluation of the type and frequency of materials transport from Midwest to McClean on the new road (see above).

ARC Response:

Appendix IX Section 4.5.1 outlines the modeling approach and modeling results of the decommissioned flooded pit and the potential for the pit to form a permanent chemocline. Response to Comment CNSC-4 (1) outlines the pit water pump and treat option to establish stable water quality in the flooded pit, and outlines the alternative decommissioning plan to completely backfill the Midwest pit.

Document Integration:

The pump and treat pit lake water quality contingency and the alternative Midwest pit backfill contingency has been added to Section 3.5.2.3.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-25 (2) Comment:

6. Environmental Effects of the Project

Effect of residual contamination in the Midwest pit walls is not evaluated re: water quality in the decommissioned flooded pit Incomplete evaluation of the type and frequency of materials transport from Midwest to McClean on the new road (see above). ARC Response:

Please refer to comment CNSC-22 (3)

Document Integration:

Main Document, Section 3.3.4, Table 3.3-3

Technical Review Response: CNSC Technical Review The response is incomplete. Response Incomplete evaluation of all traffic on new road - traffic accident risk assessment for all traffic to wildlife, spills, public?

Type II

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

To clarify, the proposed haul road between the Midwest site and the McClean Lake site is not a public road. At the Midwest site, operational control on the haul road will be similar to that currently in place at the McClean Lake Operation JEB to SUE site haul road. Both roads are very similar in their function and structure; hauling ore, transporting workers, distance, and materials transported. Access to the McClean Lake Operation is controlled by gate security at the lease entrance and access to the Midwest site near Points North is controlled by gates on the road. Because access points for the haul road are within the site leases control of access to the lease will also control, in some part, access to the haul road. Once approved traffic has gained access to the lease via site security, traffic access to the road will be controlled at each end by the site operators. Traffic on the haul road will be planned and closely monitored via regular radio contact. Work instructions will be developed for travel on the Midwest haul road and will be similar to those applied to the Sue to JEB haul road (McClean Lake Operation Work Instruction – SUE to JEB haul road Procedures, Document No.: 303-05). These work instructions comply with the Saskatchewan Mines Regulations 324 (Traffic control plan) and the Saskatchewan OH&S Regulations (Risk from vehicular traffic). Work instruction safety procedures, such as traffic speeds and radio contact, reduce the potential risk of accidents along the haul road.

The haul road is not easily accessible at points other than the Midwest and JEB access points and all efforts to control access to the road by the public will be made. Please refer to the response to comment HC-9 in this Addendum for details on the prevention of public access to the haul road. Because the haul road will be a controlled private road, the risk of a traffic accident to the public is extremely low.

Traffic accidents on the Sue to JEB haul road have been very low and this is expected to be similar for the Midwest haul road. Sue to JEB haul road operational data for the 2000 to 2010 period estimate the combined distance travelled annually by all vehicle types to be approximately 662,651 km. Over this ten year period, there have been 4 accidents; 2 vehicle only accidents and 2 vehicle-wildlife collisions. This equates to 1 accident every 1,656,528 km, 1.65 accidents every million kilometres travelled, 1 accident every 2.5 years or 0.4 accidents every year. The accidents on the haul road did not result in injury to the driver, a rollover or spill of material but did result in two wolf mortalities. Vehicle only accidents on the Sue to JEB haul road average 1 accident every 3,120,395 km, 0.8 accidents every million kilometres travelled, 1 accident every 5 years or 0.2 accidents per year. Accident frequencies along the Sue to JEB haul road are lower than those on public highways in northern Saskatchewan as discussed below. The risk of an accident along the haul road is reduced because of the operational controls outlined above.

Expected traffic frequencies between the Midwest Project site and the McClean Lake mill site are summarized in Table 3.3-3 of the Revised EIS (February 2010). In summary, it is anticipated that the number of trips per day between the two sites will equate, on average, to approximately: 76 round trips/day between the sites. The distance one way on the dedicated haul road between the sites is estimated to equal approximately 17 km, irrespective of which of the two possible routes identified in the EIS is implemented. The combined distance travelled annually by all vehicles moving between the sites equates to approximately 943,000 km. Of this traffic volume, approximately 1/3 is attributable to the movement of large trucks (i.e. 1 trip/day of multiple axial chemical supply trucks and 25 trips/day of ore haulage trucks).

Based on accident statistics reported for semi-trailers in northern Saskatchewan (SENES 1999) disclose that the reportable accident frequency equalled 0.66 accidents per million vehicle kilometres travelled. The rollover rate equalled 0.066 rollovers per million vehicle kilometres travelled as compared to a provincial rate of 0.11 rollovers per million vehicle kilometres travelled. These statistics are inclusive of all goods hauled and not specific to the transport of hazardous materials. Applying the accident statistics for semi-trailers on northern Saskatchewan roads to the Midwest Project, the accident frequency for the large haulage trucks equals 0.2/year (i.e. 0.66/1,000,000*943,000*0.34).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

This is the same rate of vehicle only accidents that has been observed on the Sue to JEB haul road. Therefore 1.2 accidents involving semi-trailers on the haul road would be expected over the 6 year duration of the Midwest Project. The expected frequency of accidents resulting in a rollover and a potential spill from the large trucks is 0.02/year, or 0.12 accidents for the duration of the Project. Over the six year life expectancy of the Midwest Project, the accident frequency equates to 1.2 accidents with a 10% probability of the accident resulting in a rollover and potential spill. It is noted that this estimate conservatively assumes that the traffic volume between the sites is sustained over the five-year period whereas, it is expected that ore haulage will occur only over a two-year period. The traffic volume in other years should accordingly be lower.

Based on Saskatchewan Government Insurance (2007) statistics for all vehicles travelling on highways #102, #905, #165, #914 and #2 in northern Saskatchewan, there were a total of 659 accidents resulting in property damage (582 incidents), personal injury (76 incidents) or fatality (1 incident) for a total distance travelled of 384,030,000 km. This equates to approximately 1.8 accidents per million kilometres travelled, or about twice the rate quoted above for semi-trailers. For an estimated total traffic flow of 943,000 kilometres per annum for all vehicles moving between the Midwest and McClean Lake sites, the annual accident frequency equates to approximately 1.7 reportable incidents per year. Based on the SGI accident statistics noted above, the number of accidents that would be expected to result in personal injury or fatality equal 0.2 and 0.003 per year respectively.

The above statistics include vehicle-wildlife collisions. Accident statistics reported by Saskatchewan Government Insurance (SGI 2003) indicate that the Annual Average Daily Traffic (AADT) volumes for highways #905 and #102 were approximately 45 and 600 vehicles per day, respectively. In the same period 9 and 18 vehicle-wildlife collisions were reported respectively on highways #905 and #102 from 1988 to 2002. The number of collisions in 2002 was 2 and 0 collisions for highways #905 and #102 respectively. Using the statistics for highway #905, with a maximum of 76 trips per day on the haul road between the Midwest and McClean Lake mine sites, the number of vehicle- wildlife collisions is expected to be less than 4 per year on the haul road. These types of collisions are not expected to cause a rollover and consequently spill from a heavy low-speed truck carrying ore or chemical reagents. The lower speed limit and the safety procedures in place on the haul road are expected to reduce further the predicted number of accidents on the haul road as the accident statistics used for the predictions are from roads where vehicles are able to travel at higher speeds than haul road speeds.

References:

Saskatchewan Government Insurance (SGI) 2007. Saskatchewan Traffic Accident Facts. Saskatchewan Government Insurance (SGI) 2003. Saskatchewan Traffic Information System Database. SENES Consultants Limited (SENES) 1999. Environmental Assessment of a Credible Transportation Accident Scenario, McArthur River Project. August. Prepared for Cameco Corporation.

Document Integration:

Predicted traffic accident frequencies will be included in Section 7.

Technical Review Response: October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-26 Comment:

6.3 ID Mitigation Measures

For Midwest site and road the proponent says that the extent of land disturbance will be small in the local and regional context so the effect on habitat and species will be small, and in any case will be restored through reclamation at the end of the project. CNSC would have expected the proponent to have identified a Lands Management policy, or components thereof (e.g. wildlife management), that address what the company will do during construction and operation to minimize their impact on the local and environment. This would be a description of what AREVA is currently doing at McClean e.g. controls on fishing, no hunting or harassment of wildlife, minimizing surface disturbance wherever possible (e.g. during exploration), etc. Reality is not indiscriminate disturbance and reclaim later – there is control during construction and operation.

Where is the influence of habitat dissection on wildlife covered such as predator -prey interactions and effects on population success?

Possible additional effects identified after comments above considered?

ARC Response:

AREVA Resources Canada Inc. recognizes that continued economic and social development depend on a healthy environment and incorporates environmental considerations into all company activities to ensure sustainable development. AREVA is committed to continually improve approaches and technology to minimize the effects of its activities on the environment. The McClean Lake Operation is governed by an Integrated Quality Management System including wide-ranging Environmental Codes of Practice. This same IQMS will govern the Midwest Project.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-26 To meet the above commitment, AREVA shall: (continued) • comply with all applicable environmental legislation; • minimize adverse environmental impacts of its activities by reducing consumption of natural resources, controlling releases and optimizing waste management; • prevent pollution by using processes, practices, materials or products that avoid, reduce or control pollution; • deal proactively with environmental issues by identifying potential impacts and implementing mitigating actions and/or developing effective contingency plans; • develop internal objectives and targets to achieve continual improvement; • measure performance against established goals; • conduct employee training, internal assessments and periodic reviews to ensure these operations and activities are conducted in compliance with documented procedures; • communicate environmental requirements and corporate initiatives to employees and contractors to encourage their participation and compliance; • involve the public, with particular focus on impact communities, in initial planning, ongoing operations and decommissioning of AREVA activities through an open and transparent public involvement program. This policy is made available to the public.

The Integrated Quality Management System at McClean Lake is very broad covering most activities at site. Furthermore, the system is established to meet the needs of regulators and selected ISO standards as well as McClean Lake Operation.

The Environmental Management System (EMS) that is within the IQMS is designed to meet the requirements of the CNSC, Saskatchewan Ministry of Environment, Environment Canada and ISO 14001, as well as internal requirements.

The main elements are: • Environmental Policy • background studies • ISO 14001 Environmental Management System • implementation • response to non-conformances • operational control • communication • management review

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-26 Specifically addressing the comment on fishing at McClean Lake; fishing is allowed on designated lakes within the McClean Lake Operation (continued) area with certain restrictions. Fishing is allowed on Pat Lake, Dwarf Lake, Torwalt Lake and Moffat Lake. Only one boat is allowed on each lake at a time, barb-less hooks must be used, and only one fish can be kept per person per week. All personnel fishing in the area of the operations must hold a valid fishing license, except where exempted by law. Fishing activities on all other lakes are regulated by the Saskatchewan Ministry of the Environment (The Fisheries Regulations under The Fisheries Act). All regular requirements, such as catch and possession limits, apply. Special fishing restrictions are applied to certain lakes in the area by the Ministry of the Environment. Lakes with catch and release limits in the project area include Collins Creek (CR1), Henday lake (CR1), Wollaston Lake (CR1), Waterbury Lake (CR2), Hatchet Lake (CR3), Moffat Lake (CR3), Towalt Lake (CR3), Dwarf Lake (CR3), Pat Lake (CR3) and Waterfound Bay (CR3) Please see the 2008 Saskatchewan Angler’s Guide for more details on catch and release limits (http://www.environment.gov.sk.ca/Default.aspx?DN=97149a2f-298c-435b-969e-025bd7a0cbdb&l=English).

The issue of wildlife harassment is outlined specifically in the AREVA Resources Canada Inc. Safety Manual, which is provided to all employees and contractors during orientation. Personnel must not harass wildlife in any manner, feed wildlife, or in any way encourage the presence of wildlife in any area near residences or work places.

As stated above, the McClean Lake Operation Environmental Management System and Exploration are ISO 14001 certified. The minimization of land disturbance is one of AREVA’s objectives within its ISO 14001 environmental management programs. Specifically, AREVA’s objectives are to minimize land disturbance, maintain the ratio of disturbed and undisturbed portions of the McClean Lake surface lease, and to ensure that any new disturbance does not exceed 110% of the design area. In relation to the protection of land, any areas posted as "rare plants", contain plant species considered rare and endangered in Saskatchewan. Personnel must not enter these areas (AREVA safety manual).

AREVA’s IQMS is part of its licencing requirements and as such this document will be included during the licencing process for the Midwest Project. The IQMS implemented at the Mclean Lake Operation will be carried over to the Midwest Project. Within Section 6 of the Midwest Project EIS, Table 6.2-1: Mitigation Measures Related to the Development of the Midwest Pit, contains all identified mitigation measures that will be implemented at the Midwest site to minimize all types of disturbances.

Road density in a landscape, expressed as length of road per unit of landscape, gives some approximation of possible road effects on the land-use (Forman et al., 2003). Road density appears to affect many species of large wildlife, however most species populations can persist in the presence of at least some roads. Numerical responses of large mammals to roads are generally interpreted as a road density threshold necessary for sustainable populations and coexistence. For example, wolves in Minnesota and Michigan and mountain lions in Utah appear to thrive only where the road density is less than 0.6 km/km2. The road-density effect maybe primarily due to road-kill, disturbance avoidance, or human access to remote areas or a combination, depending on the species and landscape. Simulation modeling based on data from northern Alberta boreal forest suggest that declines in woodland caribou would occur when the density of linear features exceed 1.22 km/km2 (Weclaw and Hudson 2004). Linear feature density in the Midwest Project local assessment boundary is estimated to increase to 0.1288 km/km2 with the addition of the north haul road or 0.1311 km/km2 with the addition of the south haul road – much lower than the thresholds identified by Weclaw and Hudson (2004). Within the regional assessment boundary, the road density will be substantially less. The addition of the dedicated haul road is not predicted to significantly affect wildlife populations.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-26 Within the local assessment area, few animals have been killed by vehicles. Traffic speed and numbers of vehicles, two factors that (continued) influence animal mortality on roads, will be controlled and so the risk of animal mortality on the proposed road is very low. Because traffic will be minimal, noise from the haul road will be kept to a minimum and so noise from traffic should have a negligible effect on wildlife movement in the area. The haul road is not a public road, and access to the road will be controlled within the lease areas, thus limiting human access. Increased road density can increase predator access to prey (Forman et al., 2003) as some predators use roads as easy travel routes. However if the roads are frequently used by humans, as this road will be during its existence, predators will tend to avoid roads. It is not predicted that the road will contribute to increased predation in the local assessment boundary.

At the end of operation, the road will undergo reclamation activities and it will be returned to a terrestrial environment reflective of that which existed before development.

Woodland Caribou are protected under SARA and the provincial Wildlife Act and these management tools will continue to be utilized to protected and conserve woodland caribou populations in the region.

AREVA believes that all potential effects of the Midwest Project have been identified and are presented in the EIS. Section 6 Environmental Effects of the Project has been revised and re-written as per the suggestions provided in the EIS comments, and is presented in Revision 2 of the Midwest EIS. All potential project-environment interactions are clearly presented in Table 6.1-1 and all potential residual effects from the Midwest Project are presented in Table 6.3-1. AREVA believes that Section 6 now better facilitates the presentation of potential Midwest Project effects.

REFERENCES:

Forman, R.T.T., Sperling D., Bissonette, J.A., Clevenger A.P., Cutshall, C.D., Dale, V.H., Fahrig, L., France, R., Goldman, C.R., Heanue, K., Jones, J.A., Swanson, F.J., Turrentine, T., and Winter, T.C. 2003. Road Ecology: Science and Solutions. First Edition. Island Press, Washington, DC, USA.

Weclaw, P. and R.J. Hudson. 2004. Simulation of conservation and management of woodland caribou. Ecological Modeling: 177:75-94.

Document Integration:

 Mitigation measures have been integrated into Table 6.2-1 of Section 6.  Potential effects have been included in Table 6.3-1.

Technical Review Response CNSC Technical Review The response requires some clarification Response Actions to reduce disturbance during construction - explanation of what is currently in place at McClean that will extend to Midwest is lengthy and not particularly to the point

Type II - unclear what influence AREVA will have over contractors doing the road construction - response says that traffic on road will be minimal yet Table 3.3-3 shows quite a bit of activity especially during ore haul AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment

With respect to woodland caribou request clarification: - were exploration, cutlines and other linear disturbances included in the calculations of cumulative linear feature density when arriving at the values of 0.1288 to 0.1311 km/km2 in the local assessment boundary?

-AREVA states that Weclaw and Hudson (2004) simulations “suggest that declines in woodland caribou would occur when the density of linear features exceed 1.22 km/km2”. Since there is population decline at this level it is not clear what density is protective for this at risk species. What threshold is acceptable to ensure species protection? June 2010 ARC Response:

At the Midwest site, policies to protect wildlife and minimize land disturbances will be similar to those in place at the McClean Lake Operation. AREVA construction and site management will provide oversight of all contractors during the construction and operation of the Midwest Project. An environmental monitor will be a member of the management team during site and road construction.

For the determination of road density, proposed roads and roads currently in use were considered in the analysis presented. Other linear features such as trails, historic exploration cut lines and other linear features present on the landscape were not included as these are only infrequently used to access far-field sites and are at various stages of successional revegetation. Road density within the LSA was compared to the threshold levels modeled by Weclaw and Hudson (2004). Weclaw and Hudson (2004) made several assumptions about the model inputs (e.g., linear features, length of time, avoidance behavior, predation, immigration of caribou, population sizes, reproduction rates, and moose populations) for various runs of the model. Weclaw and Hudson did not make any assumptions on what road density threshold would be acceptable to ensure species protection. Because of the spatial and temporal complexities of road interactions, the question of what an acceptable threshold would be is difficult to answer (Forman et al., 2002). AREVA is aware of the potential for unused linear features to contribute to enhanced predator mobility and is actively working with the SMA to develop best management practices (BMP) to minimize wildlife linear feature interactions.

AREVA is also working through the SMA to contribute to the Environment Canada initiative to identify critical habitat for woodland caribou and are actively contributing to a number of local, provincial and federal initiatives to gain a better understanding of the interactions of our projects and activities with woodland caribou habitat. These initiatives includethe contribution of recently acquired habitat information to the Saskatchewan Ministry of the Environment (SMOE) to support the development of a joint provincial-Environment Canada recovery strategy for boreal woodland caribou (Rangifer tarandus caribou) in Saskatchewan.

AREVA will continue to support the development of a comprehensive management strategy as this initiative progresses.

It is noted that during extensive baseline field investigations, no caribou were observed and limited caribou sign was evident within the Midwest Project local assessment boundary (Main document, Section 4.5.3.2; AREVA 2009).

AREVA will continue to minimize project disturbances and to adopt best management practices minimize project-wildlife interactions.

References

Response to Federal Comments Regulator Comment / Response Comment Press, Washington, DC, USA.

Weclaw, P. and R.J. Hudson. 2004. Simulation of conservation and management of woodland caribou. Ecological Modeling: 177:75-94.

Document Integration:

No Integration required

Technical Review Response: October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-27 Comment:

7.2 Predicted effects during construction and operations (Page 7-29, 7-30) No summary information is provided on the effects on the aquatic environment from the dewatering of the Mink Arm or the potential contingency treated water discharge to the McMahon Lake, Smith Creek systems.

During the1988-1989 Mink Arm dewatering, the quality of water pumped from Mink Arm to South McMahon Lake posed no problem other than for turbidity and suspended solids. Therefore, it is anticipated that as Mink Arm dewatering progresses, total suspended solids (TSS) could become an issue which would require attention and management. No SSWQO exists for TSS; however, Newcombe and MacDonald (1991) outline considerations regarding the effects of suspended sediments on aquatic ecosystems. Using this type of information it is anticipated that an appropriate TSS criterion can be developed at the time of licensing to negate potential effects on fish and habitat associated with Mink Arm dewatering while maintaining water management flexibility. It is proposed that a weekly grab sample analysed for Class C parameters will provide the information necessary to effectively manage potential water quality effects that may be associated with Mink Arm dewatering. If turbidity and suspended sediment concentrations increase, this water can be directed to a settling pond prior to discharge or it can be treated at the Midwest water treatment plant prior to release. If turbidity and/or suspended sediments do increase in concentration, it would only be for a short period only. Because the effect of suspended sediments is reliant on both concentration and exposure duration, a short duration will help minimize any effect from an increase in concentration (Newcombe and MacDonald, 1991).

Fish habitat surveys have been carried out in the above-mentioned lakes and habitat areas have been characterized for use by lake whitefish, lake trout, northern pike, white sucker, arctic grayling, and longnose sucker. The results of these fish habitat surveys have been summarized in Figures 4.4-11 to 4.4-16 and a brief discussion of the habitat survey results can be found in Section 4.4.7.1. Some highly and moderately suitable habitat exists in the above-mentioned water bodies for some of the fish species. Because of the contingencies and mitigation measures in place, it is not anticipated that the dewatering activities will have a significant impact on spawning or rearing areas in these water bodies. If it is possible, the dewatering of Mink Arm will be carried out during a non-sensitive time period for fish reproduction. The timing of the dewatering activity will also depend on many factors including the timing of the environmental assessment approval, license acquisition, operational constraints, etc.

REFERENCE:

Newcombe, C.P. and D.D. MacDonald. 1991. Effects of suspended sediments on aquatic ecosystems. N. Am. J. Fish Manage. 11: 72-82.

Document Integration:

No integration required.

CNSC Technical Review Technical Review Response Response AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

The response is incomplete. Type II No summary information on effects of Mink Arm dewatering on aquatic environment - response ok as long as water quality good; if not, then treatment capacity at Midwest may be an issue - AREVA’s response that “If it is possible, the dewatering of Mink Arm will be carried out during a non-sensitive time period for fish reproduction.” does not reflect a commitment to minimize potential effects on fish habitat that might accrue from TSS or spawning run interference. Also AREVA’s response “that an appropriate TSS criterion can be developed at the time of licensing to negate potential effects on fish and habitat associated with Mink Arm dewatering while maintaining water management flexibility” is not satisfactory to determine if or at what level adverse effects could occur in the receiving water body or if sufficient treatment capacity will be available to handle a high volume of high TSS water. AREVA should look at a range of possible TSS levels to determine at what level wastewater treatment capacity could become an issue.

SK-2 - if TSS too high then contingency is to use precipitation ponds and/or WTP – how would this work as there is no direct feed to chemical WTP in Fig 3.5-2 and the WTP appears to have a very limited capacity of 2000 m3/d

June 2010 ARC Response:

During Mink Arm dewatering, a daily water sample will be collected and measured for pH, TSS and conductivity. It is anticipated that the majority of the water in Mink Arm will be suitable for release directly to South McMahon Lake. However, based on the 1988/1989 dewatering experience, AREVA expects that the water may become high in TSS during the latter stages of dewatering activity. Although there is no SSWQO for TSS, a CCME guideline on total particulate matter is available. However, the guideline is based on studies in flowing systems (streams, river) and is not easily applicable to lake settings such as South McMahon Lake. AREVA proposes that the TSS limit at which Mink Arm water will be treated at the Midwest WTP and released to S/V TEMS is 29 mg/L: this is 25 mg/L above the ambient conditions in South McMahon Lake (4 mg/L; Table 4.4-3). This is partially derived from the CCME guideline on total particulate matter for a short-term exposure in clear flow. In the event that TSS increases above 29 mg/L, the Midwest WTP would be utilized and water directed to the S/V TEMS. This TSS limit is also similar to Schedule 4 of the Metal Mining Effluent Regulations where TSS maximum authorized concentrations are 15 mg/L, 22.5 mg/L and 30 mg/L in a monthly mean, composite and grab sample, respectively. Because the effect of suspended sediments is reliant on both concentration and exposure duration, a short duration will help minimize any effect from an increase in concentration (Newcombe and McDonald 1991).

The Midwest WTP is capable of treating up to 25,000 m3/d of water through the pre-treatment and RO facility. The chemical treatment stage, limited to 2000 m3 per day, is only intended for the treatment of reject brine produced by the RO process and would not be required for the treatment of high TSS Mink Arm water. The Midwest WTP has been designed to allow the RO membrane stage to be bypassed, allowing Mink Arm water to be treated in the primary pre-treatment stage. At this stage, a series of clarifiers will reduce the TSS levels to that of less than 1 mg/L, as per the plant design. This water would be directed to the S/V TEMS for release. As such, the dewatering of AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Mink Arm and control of TSS is well within the capability of the facility.

Dewatering techniques and timing will minimize potential effects of dewatering on fish populations and fish habitat in South McMahon Lake. For instance, the inflow with Mink Arm water will be directed away from the shoreline and littoral areas where fish spawning occurs. DFO’s operational protocol for Saskatchewan In-Water Closed Construction Timing Windows states that for waterbodies in northern Saskatchewan with no lake sturgeon present, no in-water works are to occur from May 1st to July 15th without site- or project- specific review by DFO. If release of Mink Arm water to South McMahon Lake occurs from May 15th to July 15th, AREVA will work with DFO to develop acceptable criteria for water release.

Reference:

Newcombe, C.P. and D.D. MacDonald. 1991. Effects of suspended sediments on aquatic ecosystems. N. Am. J. Fish Manage. 11: 72-82. Document Integration:

Section 3 will be updated to indicate that Mink Arm water with TSS >29 mg/L will require treatment at the Midwest WTP prior to release to South McMahon Lake.

October 2010 Technical Review Response

Adequate. Additional information is provided. AREVA has added a commitment to sample daily and treat TSS > 29 mg/l. However, a constant discharge of 29 mg/l over a long period could be harmful and is not evaluated. Mink Arm was safely dewatered in late 1998-early 1999. Regulatory controls and monitoring similar to those used during the 1988-89 Mink Arm dewatering operation, as described in Section 3.2.1.1.1, will be imposed if necessary to prevent any sustained high TSS level adverse effects. Sections 3 and 12.4.1 of the revised EIS need to be updated to add that sampling will be done daily for pH, conductivity, and TSS.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-28 Comment:

Tables are provided of the predicted effluent quality values used in the environmental impact analysis for the Midwest WTP, the Midwest RO permeate and the pit dewatering systems on Table 3.4-5 of Appendix V. Tables should be provided of the water quality predictions for the Mink Arm dewatering and the combined well water, RO permeate and Midwest chemical treatment effluent for assessment of these systems.

ARC Response:

For clarification, effluent quality data are provided on Table 3.4-5 (Appendix V) for three sources originating from the McClean Lake Operation: the JEB WTP treated effluent; the Sue WTP treated effluent; and, the Dewatering Well System (DWS) at the JEB TMF. The two sources applicable to the Midwest Project include: Midwest RO permeate; and, Midwest WTP effluent. For the purposes of the EIA, it was assumed that all dewatering well water pumped to surface at Midwest will be processed through the reverse osmosis (RO) system together with contaminated pit sump water and site surface runoff. While the text of the EIS and Appendix V discusses separation of clean dewatering well water from contaminated well water, the assessment, as noted above, was based on the assumption that all well water from the Midwest site will be treated. For comparison purposes, a second scenario was assessed in which it was assumed that only one- half of the dewatering well water requires treatment. In this scenario, the clean Midwest DWW was assumed to have similar characteristics as the JEB DWW. All treated and untreated water was assumed to be mixed and pumped to the S/V TEMS in this scenario. Table 3.4-5b has been added to Appendix V to demonstrate the quality of the combined water to be pumped from Midwest to the S/V TEMS for both scenarios. The values shown in the table were determined from 10,000 probabilistic trials using Crystal Ball software in which both the flow and quality of the two sources were varied. The summary statistics shown on Table 3.4-5b include the arithmetic mean, median (geometric mean), 5th percentile and 95th percentile values for each constituent. In cases where the 95th percentile was greater than the applicable water quality guideline/objective, the percentile corresponding to the guideline/objective was estimated. Further discussion of the results of this analysis is presented in the response to Comment CNSC 8.

Document Integration:

Table 3.4-5b has been added to Appendix V.

Technical Review Response

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-29 Comment:

9.2 Significance of Predicted Effects Pg 9-8 Section 9.2.4.1 This section states “Thus the predictions demonstrate that the commitment to achieve SSWQO’s in Collins Creek downstream of the McClean Lake east basin can be maintained with the mining and milling of the Midwest ore deposit”

In previous EIS’s wasn’t the location for meeting SSWQO’s at the outlet of McClean Lake East not further ‘downstream of the McClean Lake east’ where additional water from base flow may dilute contaminants of concern? If there is a change in water quality sampling location please provide justification for the change (e.g. mixing distance under variable flow conditions such as laminar vs. turbulent flow) and provide a specific UTM sampling location.

Page 9-9 section 9.2.4.2. Will there be satisfactory monitoring programs in place to determine ecological change in phytoplankton and zooplankton populations in the S/V TEMS?

ARC Response:

The prediction to meet the 1988 SSWQO at the McClean Lake outlet was made by Total Minatco Limited in the McClean Lake Project 1991 Environmental Assessment. This initial EA of the project was reviewed by the Joint Federal – Provincial Panel on Uranium Developments in Northern Saskatchewan, and subsequently received federal and provincial government approval, with conditions. During the subsequent licensing process, the Environmental Monitoring Program (EMP) for the McClean Lake Operation was developed in consultation with regulatory agencies. Within the EMP surface water quality monitoring locations, frequencies and parameters were established. The surface water quality monitoring station WQ12E was established in Collins Creek downstream of McClean Lake outlet at a location just outside of the McClean Lake Operation Surface Lease. This location was established in consultation with the regulatory agencies involved in the EA and licensing processes, and is the location at which the commitment to meet SSWQO is evaluated. As outlined in the Midwest Project EIS and re-iterated in this comment, it is predicted that the proposed development of the Midwest Project will not compromise the ability to meet this commitment at this location.

The current McClean Lake Operation EMP and Environmental Effects Monitoring (EEM) programs are designed to evaluate the potential effects of treated effluent release and are subject to periodic review during licensing processes and regulatory technical advisory panel review. These programs focus on water and sediment quality, benthic invertebrate community composition, and fish tissue and fish population characteristics downstream of treated effluent release. No additions to these programs are anticipated in relation to the proposed development of the Midwest Project. Document Integration:

No integration required. Technical Review Response

Acceptable

The monitoring of plankton populations in S/V TEMS was not addresses but will be reviewed as part of JRG/TAP review of

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments McClean’s environmental monitoring program.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-A (new) Technical Review Response This is incomplete. Appendix XII The description and analysis is for McClean site only - reagent usage and hazards at Midwest (see Table 3.3-3 for reagents shipped to Reagent Usage Midwest) are not addressed

Type II ARC Response:

Please refer to the response to comment CNSC-25(2) for a discussion of the transportation risks associated with transporting reagents to the Midwest site.

Midwest Water Treatment Plant Reagent Usage and Hazards The Midwest water treatment plant will utilize a number of reagents in the chemical treatment stage to process the collective brine produced by the membrane filtration process. A number of these reagents are classified as dangerous and hazardous products. The safety of plant personnel is a key consideration in the design and operation of the Midwest water treatment plant reagent storage and distribution system. The Midwest water treatment plant is designed to contain solutions in the event of a leak or spill. For example, tanks are enclosed with berms to contain 110% of the tanks volume. Steeply graded floors direct spills into sumps to contain them and minimize worker contact with hazardous materials.

Reagents will be transported by truck from both Saskatoon and McClean Lake to the Midwest site. Where possible, reagents that are used at McClean Lake will also be used at the Midwest water treatment plant. All liquid reagents will be stored in agitated tanks, unless the reagent is shipped in totes. A minimum of one week of storage for reagents that are not mixed on-site will be provided.

The reagents used in the Midwest water treatment process are as follows:

Anti-Scalant Solution Anti-scalant solution, unique to the Midwest water treatment plant operation, may be required for the feed to the primary and secondary membrane filtration system to prevent membrane fouling, thereby increasing the lifespan of the membranes. The solution is supplied by the vendor of the membrane filtration system or purchased from a specialty chemicals company. Anti-scalant solution will be delivered in contained totes shipped directly from Saskatoon. The solution will be metered directly from the totes into the membrane filtration system as required.

Barium Chloride Barium chloride is used to precipitate radium. Barium chloride will be mixed to a solution strength of 15% at the JEB mill facility and transported to the Midwest water treatment plant, where it will be transferred to a storage tank. Barium chloride will be metered into the AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments second stage of the conventional chemical treatment stage.

Ferric Sulphate A 45% ferric sulphate solution is used to remove arsenic, molybdenum, selenium and other transition metals through chemical adsorption and precipitation processes. The solution will be transported by truck from the JEB mill facility and offloaded to a storage tank at the Midwest facility. Ferric sulphate will be metered to the second stage of the conventional chemical treatment stage.

Flocculant Polymer A flocculant polymer is used to control suspended solids in solutions. Totes of pre-mixed flocculant polymer solution will be transported from Saskatoon directly to the Midwest water treatment plant facility. The solution will be metered directly from the totes to the clarifiers in the conventional chemical treatment stage.

Lime

Lime slurry (15% Ca(OH)2) is produced from quicklime (CaO) in a lime slaking mill at the JEB site. The slurry will be transported to the Midwest facility and offloaded to a storage tank. Slaked lime solution is used to precipitate heavy metals and is used in the pre-treatment settling pond and the conventional water treatment process.

Magnesium Chloride A 30% magnesium chloride solution, unique to the Midwest water treatment plant operation, will be used to control silica concentrations in the conventional water treatment plant feed. A metering pump system will supply the solution to the treatment stages prior to the membrane filtration process. The solution will be transported to the Midwest facility directly from Saskatoon to the Midwest site and offloaded to a storage tank.

Membrane Cleaning Solution Periodically, the filtration membranes require cleaning to prevent build-up of salts and membrane fouling. A cleaning solution, unique to the Midwest water treatment plant operation, will be supplied by the vendor of the membrane filtration system or purchased from a specialty chemicals company. The cleaning solution will be transported in totes from Saskatoon directly to the Midwest facility. The spent cleaning solution will be trucked to the JEB mill for disposal in the Tailings Preparation process.

Sodium Hydroxide Sodium hydroxide is used to neutralize the primary and secondary membrane filtration feed and permeate to approximately pH 7, as required. A 50% caustic solution will be trucked directly from Saskatoon to the Midwest site and offloaded directly to a storage tank.

Sulphuric Acid Concentrated sulphuric acid (93%) is used as required in the water treatment system for pH adjustment. Sulphuric acid will be used in the second stage of the conventional chemical treatment stage. Sulphuric acid will be produced at the JEB mill acid plant facility and transported directly to the Midwest facility, where it will be offloaded to a storage tank.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Reagent Hazards

Each chemical reagent has specific engineering and administrative controls in place to ensure hazards to personnel are ameliorated. Each chemical and its controls are listed below.

Anti-Scalant Solution The anti-scalant solution added to the membrane filtration process can irritate both the eyes and skin through exposure. To minimize this risk, the feed system will meter solution directly from the storage totes to the to the membrane filtration feed lines. At the Midwest water treatment plant, eye wash and safety showers will be available in the vicinity of the storage and metering locations, in event that exposure to the solution occurs.

Personnel who could potentially come into contact with anti-scalant solutions will be required to wear rubber boots, safety glasses or chemical goggles, and chemical gloves. Personnel are also required to wear a two-way radio in case of an emergency. The Operations Code of Practice will include an anti-scalant handling procedure that documents the use of the metering system protocol.

Barium chloride Barium chloride is toxic upon ingestion. It can cause dermal and eye irritation upon exposure. Inhalation also causes irritation. To reduce personnel exposure to barium chloride solution, metering systems inject barium chloride solution directly into reaction vessels. At the Midwest water treatment plant, eye wash and safety showers will be located in close proximity to the barium chloride storage tank and secondary chemical treatment process where barium chloride is used.

Administrative controls require personnel who may contact barium chloride to wear rubber boots, chemical gloves, disposable coveralls and a full face respirator equipped with appropriate cartridge for filtering of barium chloride. All personnel are required to wear a two-way radio in case of emergency situations. The Operations Code of Practice includes a barium chloride offloading procedure that documents the entire protocol.

Ferric sulphate Ferric sulphate is a corrosive liquid which is an irritant to both the eyes and skin. It is irritating if inhaled or ingested. Hazards to personnel are limited by directly offloading ferric sulphate to the water treatment plant storage tanks. All ferric lines are composed of high density plastic or stainless steel to ensure the lines do not corrode from chemical exposure. Ferric sulphate is directly injected into sealed reaction tanks to avoid personnel exposure. Eye wash and safety showers will be located in the Midwest water treatment plant in the event that exposure to ferric sulphate occurs.

Individuals who could contact ferric sulphate are required to wear rubber boots, chemical gloves, full face shield, chemical pants and jacket. Personnel are also required to wear a two-way radio in case of an emergency. The Operations Code of Practice includes a ferric sulphate offload procedure that documents the protocol.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Flocculant polymer Flocculant can irritate the eyes and skin upon direct contact. Flocculant solutions can be very slippery if spilled. These hazards are controlled by metering flocculant solution directly from storage totes and avoiding the risk of spillage associated in solution transfer to a holding tank. Hazard signs will be posted around flocculant addition areas to warn personnel of slip hazards.

Personnel who could potentially contact flocculant solutions are required to wear rubber boots, safety glasses or chemical goggles, and chemical gloves. If repeated contact with the flocculant is likely, a chemical resistant suit is also required. Personnel are also required to wear a two-way radio in case of an emergency. The Operations Code of Practice will include a flocculant procedure that documents the use of the metering system protocol.

Lime Lime is a caustic solid that is slaked into aqueous solution. Contact with skin and eyes, ingestion or inhalation of lime will produce chemical burns. The contact hazards associated with lime are controlled by offloading slaked lime directly into holding tanks, minimizing personnel exposure. In the event of contact with lime, eye wash and safety showers are located in the JEB mill Reagent area and Midwest water treatment plant facility.

Administrative procedures include requiring personnel who may contact lime to wear rubber boots, chemical gloves, neoprene pants and jacket and chemical goggles. Personnel are also required to wear a two-way radio in case of an emergency. The Operations Code of Practice includes a lime offload procedure that documents the protocol.

Magnesium Chloride Magnesium chloride solutions can irritate the eyes upon contact. Inhalation or ingestion may cause irritation or vomiting, respectively. These hazards are mitigated by offloading magnesium chloride solutions directly to facility storage tanks. Eye wash and safety showers will be located in the Midwest water treatment plant facility in the event of exposure to magnesium chloride solution.

Administrative procedures will require personnel who may contact magnesium chloride solution to wear rubber boots, chemical gloves, a full face shield or chemical goggles. Personnel are also required to wear a two-way radio in case of an emergency. The Operations Code of Practice will include a magnesium chloride offload procedure that documents the protocol.

Membrane Cleaning Solution The membrane cleaning solution is composed of alkaline and phosphate compounds, making it very caustic. Exposure to eyes, skin, ingestion and inhalation of the liquid will cause serious chemical burns. These hazards are mitigated by implementing an automated system that meters the cleaning solution directly from totes, minimizing the exposure potential to personnel during membrane regeneration stages. Eye wash and safety showers will be located in the Midwest water treatment plant facility in the event of exposure to the cleaning solution.

Administrative controls will require that personnel who may come into contact with the membrane cleaning solution to wear rubber boots, chemical gloves, protective pants and jacket, and chemical goggles. All personnel are required to wear a two-way radio in the event of an AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments emergency. A membrane regeneration protocol will be implemented that documents the entire handling procedure for cleaning solution.

Sodium hydroxide Sodium hydroxide is an extremely caustic liquid. Exposure to eyes and skin, ingestion and inhalation of sodium hydroxide will cause severe chemical burns. Exposure hazards with sodium hydroxide are mitigated by offloading the caustic solution delivered to the water treatment plant directly to storage tanks. The caustic feed system is automated to minimize personnel exposure. Eye wash and safety showers will be located in the Midwest water treatment plant in case of contact with sodium hydroxide.

Administrative controls require that personnel who may contact sodium hydroxide wear rubber boots, chemical gloves, chemical pants and jacket, and chemical goggles. All personnel are required to wear a two-way radio in the event of an emergency. Finally, the Operations Code of Practice includes a sodium hydroxide offload procedure that documents the protocol.

Sulphuric acid is a strong mineral acid. Contact with the skin and eyes, ingestion or inhalation of sulphuric acid is extremely hazardous. To ameliorate these hazards, engineering controls are in place. They include storing sulphuric acid at a concentration of 93-98% to reduce its corrosive properties. Lines, valves and tanks subjected to acid are composed of stainless steel or alternatively, coated with an acid resistant liner. Protective sleeves will be provided to pipe flanges. Eye wash and safety showers will be clearly marked in areas where sulphuric acid is employed.

Administrative controls require that personnel who may contact sulphuric acid to wear rubber boots, chemical gloves and goggles, full face shield, chemical jacket and pants. All personnel are required to wear a two-way radio in the event of an emergency. The Operations Code of Practice includes a sulphuric acid offload procedure that documents the protocol.

Midwest Water Treatment Plant Site Hazardous Materials The Midwest water treatment plant operation also utilizes materials that are not used as reagents in the chemical treatment process, such as diesel, gasoline and propane. These chemicals are ancillary to the process. These specific products are classified as hazardous materials. The Midwest mine site and water treatment plant facility will have designated facilities for storage of these products, with personnel safety the foremost consideration in their design. Commensurate design parameters include containment to ensure that chemical exposure to the environment is minimized.

Material Hazards Each hazardous material has specific engineering and administrative controls in place to minimize personnel hazards and environment implications. Each chemical and its controls are listed below.

Diesel and Gasoline Diesel and gasoline are highly flammable liquid fuels. Along with being fire hazards, these fuels can contaminate soils and aquifers should they spill. To reduce this risk, the diesel and gasoline fuel tanks will be located on a concrete pad to prevent the potential cumulative effects of ongoing small spills during fuel transfers. The fuel tanks themselves will be composed of double wall construction to contain leakage should the primary vessel fail. Diesel and gasoline tanks will be surrounded with spaced concrete pillars to prevent vehicle AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments collision with the fuel tanks.

Protocols require all vehicles to be turned off during the refuelling process, and no source of ignition is to be within 15 meters of diesel or gasoline fuel tanks.

Propane Propane is a highly flammable gaseous fuel which is stored under pressure. Any vehicle being refueled with propane is to be turned off during the process. No sources of ignition are to be within 15 meters of a propane fuel tank.

Eye and skin exposure to propane can cause cold burns and permanent eye damage. As such, propane refuelling is only to be performed by personnel with a certified propane filling ticket. Gloves and eye protection must be worn during the transfer procedure.

Engineering controls in place on all propane tanks will include double wall construction to contain leakage from the primary vessel. All tanks will be equipped with pressure relief valves to prevent tank pressure from exceeding tank specifications. Propane tanks will be surrounded with spaced concrete pillars to prevent vehicle collision with the fuel tanks.

Document Integration:

Appendix XII, Section 3.5.

October 2010 Technical Review Response :

Adequate. Additional information provided - the evaluation of the effect of volatile organic losses on the environment assumes that levels experienced inside the building will be similar to that vented outside, which is incorrect. The SX tanks are covered and under negative pressure so levels vented outside will be higher. The impact of volatile organic losses would not normally be expected to be an environmental issue, especially with a newer plant like McClean.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment CNSC-B (new) Technical Review Response This is acceptable, pending inclusion into follow-up program. Appendix V Section 3.4.4 Figure 3.4-6 generally indicates that the model currently over predicts the levels of contaminants of concern in water and sediments of Sink and Vulture lakes. This suggests that current modeling in the Environmental Assessment limits the environmental contamination footprint to Page 27 last Sink and Vulture. The licensee explained these poor predictions by a hypothetical high precipitation rates near the release point. Therefore, paragraph Lakeview predicts higher sediment concentration because it models removal as an average across each water body.

“The comparison Another reason for this poor agreement between predicted and measured contaminant in sediments and contamination being mostly in Sink of measured and and Vulture lakes (e.g. predicted small environmental contamination footprint) may be the choice of settling velocity values, particle nature predicted COC and density as well as the choice of the Kd values for each lake. Currently, the suspended solids concentrations are adjusted higher in Sink levels in the (20 mg/L) than in Vulture (10 mg/L) and the settling velocity is also estimated higher in Sink (196 m/yr) than in Vulture Lake (60 m/yr) and the sediment does Kd values are estimated as equal in both lakes. However, depending on the type of particle, the water temperature, the concentration of not indicate as particles and their affinity with other particles (aggregation tendencies), and the hydraulic residence time, settling velocity can vary widely in good agreement, the S/V TEMP and is perhaps the reason why the model predicts more metals in sediments than was actually measured in sediments. The which is believed SOE also suggests that iron oxides form in the lakes and depending on their size (colloidal versus particulate) their settling velocity may to be due to change drastically as indicated by Chapra (Surface water quality modeling; 1997) who provides a lengthy discussion on settling velocities on enhanced page 301. removal occurring in close proximity This is an important implication because as it stands now, the LAKEVIEW model will tend to reduce the future environmental footprint of the to the effluent McClean Lake operation as it is seen in Figure 4.3-1 (Base Case) and 4.4-2 (Cummulative case). As a result, the adjusted and estimated site- discharge specific TSS concentrations, settling velocities and Kd values need further explanation and comparison with the open literature to reassure locations in Sink CNSC staff that the binding of metals on particles is not over-estimated which would result in better chances of the releases meeting surface Reservoir. water quality objectives downstream of Sink and Vulture Lakes. In addition, the modeled vs predicted comparisons for sediment and water were only done for Sink and Vulture Lake. These predictions should also be verified downstream of Sink and Vulture lakes.

Type II The specifics mentioned above related to the modeling will initially be addressed within the CNSC’s detailed review of the recently submitted McClean Lake SOE report and the associated re-modelling. Should this indicate that performance predictions (surface water and sediment) are very sensitive to estimated settling velocity, particle nature (suspended solids vs oxides) density and Kd values then a re-assessment of the MidWest predictions will have to be incorporated into the follow-up program to ensure adequate treatment is in place.

ARC Response

Acknowledged. Pending regulatory review of the McClean Lake Status of the Environment Report (Areva Resources Canada Inc. 2009).

It is noted that the monitoring data will continue to be collected and incorporated into subsequent modelling evaluations on a schedule consistent with Status of the Environment reporting.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

June 2010 Document Integration:

No integration required October 2010 Technical Review Response:

Acceptable with condition. Upon review of the SOE, CNSC staff confirms the previous comment with this EA. Comparisons in the SOE of predicted and measured concentrations in sediment in Sink and Vulture Lakes indicate that the metal and radionuclides concentrations in the Sink and Vulture sediments are currently lower than the 2008 EA predictions. This suggest that metals were not retained as effectively as predicted in the SV reservoir and that greater than predicted concentrations of some contaminants are occurring in McClean Lake and downstream.

CNSC Staff expects ARC to confirm within the follow-up program that the higher sediment concentrations in McLean lake and downstream will result in negligible impacts to the benthic community, fish, wildlife inhabiting McClean Lake and downstream. If impacts are measured, improvement to the JEB WTP would be required depending on the temporal, spatial and reversibility of those potential impacts.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment CNSC-C (new) Technical Review Response This is incomplete. Appendix XI AREVA used the lowest Kd value from the range of measured values for As (e.g. 1 to 100 L/Kg). For Ra-226, AREVA decided to use 50 Distribution L/Kg instead of using the lowest value of 3.8 L/Kg provided by COGEMA 1997. CNSC staff seeks an explanation for this inconsistency. coefficient, page 14 This is possibly addressed in the follow-up program is AREVA can satisfy CNSC staff in the short term that this will not greatly modify predictions of significant adverse effects. ARC Response: Type II A radium-226 distribution coefficient of 50 mg/L was measured for collected samples of altered sandstone. Distribution coefficient values available in the literature range between 3.8 mg/L to 105 mg/L within the Athabasca basin. The measured values when compared to other reported values for sandstone materials were deemed reasonable for use in transport simulations. June 2010

In comparison, a distribution coefficient of 1 mL/g was measured for arsenic in sandstone. Fewer analyses were available for comparison purposes than for radium-226. Distribution coefficients values available in the literature range from 1.0 mL/g to 128 mL/g within the Athabasca basin.

Document Integration:

No integration required.

October 2010 Technical Review Response

Unacceptable. CNSC staff re-state the question: Why did AREVA used the lowest Kd value for arsenic and for radium-226, AREVA used a mid-range value? Also, CNSC staff assumes from AREVA response that distribution coefficients are in L/Kg or mL/g and concentrations are in mg/L.

In order to finalize the EIS, AREVA should communicate with CNSC as soon as possible to determine an acceptable response to this comment. October 2010 ARC Response:

AREVA contacted the comment provider and the was to correct the typo regarding the units (should have been L/kg not mg/L), define the term distribution coefficient, describe how it affects partitioning, and explain what a high value or low value means.

Partitioning of solute between liquid and solid phases along the pathway may be described in terms of a distribution coefficient (kd). The

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments distribution coefficient is the slope of a linear sorption isotherm and represents the ratio of the amount of solute sorbed to solid phase to the concentration of dissolved solute for an instantaneous and fully reversible sorption process.

Assuming linear, reversible, local sorption equilibrium the distribution coefficient is defined as:

q K  D C

where,

q = mass of solute species adsorbed or precipitated on the solids per unit bulk dry mass of the porous medium (mg/kg)

C = solute concentration in matrix solution (mg/L).

Larger distribution coefficients result in a higher adsorption of the the solute species to the porous medium. Sorption behaviour acts to reduce the rate of solute migration with respect to the rate of groundwater movement during transient transport conditions, in which concentrations at a point along the pathway change with time. Therefore, sorption behaviour simply delays the breakthrough time of solute at a receptor, but does not affect the steady-state concentration or mass flux where decay does not occur along the pathway. In the case of decay of the solute along the pathway, greater sorption will result in reduced mass flux to the receptor since more mass is lost due to decay over longer transport times.

In the literature, distribution coefficients for radium-226 within the Athabasca Basin range between 3.8 L/kg to 105 L/kg. Distribution coefficients used for solute transport analysis were experimentally derived using laboratory sorption tests on sandstone samples collected from the JEB site. A radium-226 distribution coefficient of 50 L/kg was measured. The measured value, when compared to the values from literature for sandstone materials, was deemed reasonable for use in transport simulations.

In the literature, distribution coefficients for arsenic within the Athabasca Basin range between 1 L/kg to 128 L/kg. A value of 1 L/kg was also found to be consistent with the lowest default value recommended for arsenic for environmental assessment (Thibault et al. 1990). The distribution coefficient for arsenic on sandstone from the JEB site was not experimentally determined. Instead, based on information from the literature, a conservative value of 1 L/kg was used to simulate sorption of arsenic during transport.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment CNSC-D (new) Technical Review Response This is incomplete. Appendix XI and associated Figure 3.5-8 only shows data to 2006, however, recent results have shown increases in porewater As and U in the JEB TMF.

Section 3 Based on present increased concentrations, AREVA should indicate if predicted Long-term Solute Source Concentrations in Tailings Pore Water values for As, U and other metals as presented in Table 3.1 of Appendix IX are still accurate and if not, discuss the implication of these new developments on their long-term modeling and if an human and ecological risk assessment is still not required as explained in Appendix XI. Type II This is possibly addressed in the follow-up program if AREVA can satisfy CNSC staff in the short term that this will not greatly modify

predictions of significant adverse effects.

ARC Response:

Figure 3.5.8 has been updated to include quarterly arsenic pore water concentrations to the end of 2009. This figure shows that arsenic

concentrations in the tailings pore water have been consistently below 2 mg/L for the entire operating life of the JEB TMF. In the first half of 2010 2009, average arsenic concentrations increased due to operational changes in the mill, which were quickly corrected. Predicted long term water quality in receiving waters is modelled with an average solute concentration of 1.9 mg/L therefore this short term increase will have no effects on the long term modelling results. Long term solute source concentrations for other constituents of concern were updated with results from the 2008 TMF sampling campaign (Table 3.1 Appendix XI).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Quarterly Action Level - Tier 1 Action Level - Tier 2 9 A

5 [As] mg/L 4

9 2 3 4 5 7 9 -9 -0 -0 -0 -0 -0 n n n an-01 an an-0 an an Ja Jan-00 J J J J Ja Jan-06 Ja Jan-08 J Date

Document Integration:

Main Document, Section 3, Figure 3.5-8. October 2010 Technical Review Response :

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-1 Comment:

Section 3.2.1.1.2 – Proposed Mink Arm Dewatering Operations – indicates that the dewatering of Mink Arm using the 10-year flood threshold will occur over a period of 14 to 24 weeks, whereas Figure 3.2-4 indicates that dewatering will occur over a period of 14 to 24 months.

ARC Response:

Acknowledged, Figure 3.2-4 has been changed to reflect dewatering duration in weeks.

Document Integration:

Main Document, Section 3, Figure 3.2-4

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-2 Comment:

Section 3.2.1.1.2 indicates that during the discharge of water from Mink Arm to Midwest Creek, 1 in 10 year flows could be present in the creek for 14 to 24 weeks. Streamflow of this magnitude and duration could degrade the creek channel and floodplain to a greater extent than would result from a natural 1 in 10 year flow event.

The proponent has indicated that when 1 in 10 year flows are diverted to Midwest Creek, the creek will be monitored and, in the event of excessive channel erosion, pumping rates would be reduced. However, an adequate assessment of likely impacts resulting from this flow regime, mitigation measures to be adopted in the event of resultant negative impacts, or a description of monitoring to be undertaken, has not been provided. DFO is particularly concerned with channel and floodplain erosion and loss of riparian vegetation that would exceed the level normally resulting from a natural 1 in 10 year flow event.

DFO requests that a further assessment be conducted of possible impacts to the channel and floodplain of Midwest Creek resulting from the discharge of water from Mink Arm, as well as a description of monitoring to be undertaken and mitigation measures to be adopted to reduce potential impacts.

ARC Response:

Thank you for your comment. As per your recommendation, field survey was conducted on Midwest Creek on 5 June 2008 (Golder 2009). During this time, stream and floodplain topography were surveyed along thirteen cross-sections of the stream. In doing so, streambed and bank material were also examined, along with riparian vegetation and the underlying soils on the floodplain adjacent to the channel. Stream discharge was measured coincidentally with the topographic survey.

Midwest Creek may be described as a stable, low sinuosity stream of moderate gradient, with cobble- and boulder-sized material dominating the streambed and along much of the banks. In the central area along the channel length, the flow branches around an area of cobble and boulder material that has been vegetated with birch and spruce trees. It is estimated that the right channel contains most of the discharge. The stream branches approximately 20 m downstream of the outlet of South McMahon Lake and the confluence of the branches occurs approximately 70 m downstream of the outlet. A smaller channel also connects the two branches approximately 30 m downstream of South McMahon outlet. The total length of the stream is approximately 94 m from the outlet of South McMahon Lake to the inlet of North McMahon Lake. The longitudinal slope of the main channel is approximated at 2% for the initial 30 m, and approximately 6% to 7% for the remaining channel length. Channel substrate is mainly comprised of boulders and cobble, whereas the floodplain is comprised of grass, moss and various mature stands of both coniferous and deciduous trees. There is a large amount of woody debris that has fallen and collected both within the channel itself and on the floodplain.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-2 In order to estimate the extent of flow within the floodplain during the 1 in 10 year event, the HEC-RAS modeling program was utilized (US (continued) Army Corps of Engineers 2008). Based on HEC-RAS modelling for a 1 in 10 year flood event, on average the water elevation was predicted to increase by approximately 10-15 cm from the surveyed water elevation along the length of the stream. The average velocities within the channel range between 0.05 m/s and 0.94 m/s. There are twelve cross-sections for which the model predicts water elevations that are outside of the defined channel banks (as defined on 5 June field survey). The estimated flow velocities in the floodplain at these locations are were calculated, along with shear stress within each cross-section (as predicted by the model). These values are based upon the following formula:

where τ is shear stress, γ is the unit weight of water, R is the hydraulic radius, and S is the frictional slope of the channel. Assuming that these values are bed shear stress at incipient motion, the Shields’ formula may be used to estimate the median stone size of incipient motion, as follows (Smith 1995):   971d c m Where τc is the critical shear stress [N/m2] and dm is median stone size [m]. Predicted values for median stone sizes values ranged between 0.8 mm and 263.5 mm.

Due to the extent of the armouring in Midwest Creek, it is estimated that there will not be significant sediment transport within the stream during flows with a 1 in 10 year return period. Shear stresses on the floodplains were estimated to range between 0.33 N/m2 and 20.08 N/m2. At the locations of predicted floodplain flow, the floodplains are comprised of moss, grass, and stands of mature trees. Smith (1995) provides estimates for classification of vegetation (grasses) and associated permissible shear stresses. These grasses are classified as very highly erosion-resistant (with a very high retardance rating) to very low erosion-resistant (with a very low retardance rating) (Golder 2009). The permissible shear stresses range from 25 N/m2 to 270 N/m2. Assuming a safety factor of 1.5, the permissible shear stress for a very low erosion-resistant grass (a conservative assumption) is slightly lower than the highest predicted shear stress on the floodplain (17 N/m2 compared to 20 N/m2 predicted by the model). However, due to the presence of various grasses, roots, mature trees, willows, and fallen debris, it is not likely that the floodplain would be eroded during the 1 in 10 year flood event. At the time of the survey, no floodplain erosion was evident along Midwest Creek

The stream channel (including the streambed and banks) and floodplain were surveyed using a total station, in order to acquire enough information to support the HEC-RAS model. More than 400 x-y-z values were collected during the survey. Stream discharge was measured near the inlet to North McMahon Lake. The discharge was calculated to be 0.084 m3/s on the date of the survey. By comparison, the 1 in 10 year discharge has previously been estimated to be 0.30 m3/s (Midwest EIS Main Document). Therefore, the water levels corresponding to the measured discharge are somewhat lower to those that would be predicted for the 1 in 10 year flow event.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-2 Due to the armouring present in the channel of Midwest Creek, it is not anticipated that the channel would degrade during a sustained 1 in (continued) 10 year flood event. The predicted water surface during the 1 in 10 year flood event does extend into the floodplain at some sections of the stream; however, the extent of various grasses, roots, mature trees, willows, and fallen debris is such that the predicted velocities and shear stresses would not result in degradation of the floodplain or loss of riparian vegetation. However, in order to reduce the likelihood of channel and floodplain degradation occurring, a monitoring program will be implemented during the periods of increased flow. This may consist of weekly visual inspections along the stream, and measurement of stage and discharge. Additional monitoring may also be required during large precipitation events, as precipitation may result in increased natural flow to the channel. Development of a stage- discharge relationship would also be beneficial for the stream. This would allow for discharge to be estimated from an established relationship to stage by measurement of stage alone.

The fallen woody debris within the channel provides an obstruction to flow and results in water elevations that are higher than would be expected in the absence of debris. In order to improve channel hydraulics and assist in keeping water within the main channel (and hence out of the floodplain, which has more potential of being eroded), it is recommended that some of the fallen large, woody debris that is located within all branches of the Midwest Creek channel be cleared away. Fallen debris that is located at the South McMahon outlet may also be causing a minor backwater effect, thus increasing the depth of water at this location. In some cases, large trees completely span the channel and are well above the expected high-water level. These can be left in place, as they do not affect hydraulics, but will at some point rot through and drop into the stream channel.

REFERENCES:

Golder Associates Ltd. 2009. Response to regulatory comments on Midwest environmental impact statement.

Smith, C.D. 1995. Hydraulic Structures. University of Saskatchewan Printing Services and Universal Bindery, Saskatoon.

US Army Corps of Engineers. 2008. HEC-RAS River Analysis System Version 4.0.0.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-3 Comment:

Within Section 3.3.1.6.2 – Option B (Alternate) – stream crossing options are presented for Crossings S5 and S6 that do not meet DFO fish passage guidelines. Please note that crossings at these locations must be designed to meet DFO fish passage guidelines.

ARC Response:

It is likely that the preferred haulage road option (i.e., along the proposed northern route) will be feasible and the haulage road will not cross at Crossing S5 (Collins Creek) or Crossing S6 (tributary to Collins Creek). In the unlikely event that it becomes necessary to pursue the alternative road haulage option along the proposed southern route, equivalent bridges will be developed for the S5 and S6 crossings.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-4 Comment:

Most of the channel widths presented in Table 3.3-1 are not the same as those presented in Table 4.4-51.

ARC Response:

Thank you for your comment. The channel widths presented in Tables 3.3-1 and Table 4.4-51 are not the same because they are do not represent the same measurements. To clarify, the channel widths listed in Table 3.3-1 are the average of numerous bankful widths taken near the crossing to produce a typical channel configuration in the vicinity of each stream crossing. Where possible the bankful width was measured at the centreline and every 10m from the crossing for the first 50m, and at 75m and 100m upstream and downstream (Appendix III, Sub-appendix B).

The channel widths listed in Table 4.4-51 are the bankful widths measured at the centreline of the proposed crossing only.

For example, crossing N4 has an average bankful width of 3.9m (Table 3.3-1) and the bankful width at centreline of 3.6 m (Table 4.4-51).

Document Integration:

Changes made to Table 3.3-1 (Section 3, Midwest EIS main document)

 Table heading corrected: ‘Bank-to-bank width’ changed to ‘Bankful width’  Footnote added to describe derivation of bankful widths

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-5 Comment:

Section 4.4.6.1.1 – Evaluation of Midwest Baseline Data – states that stickleback were captured in Mink Arm in 2003; however, Table 4.4- 42 shows that stickleback were not captured in Mink Arm.

ARC Response:

Table 4.4-42 has been reviewed and confirmed to be correct. There were no ninespine stickleback captured in Mink Arm in 2003 as noted in both Table 4.4-42 and in the corresponding text in section 4.4.6.1.1 - Evaluation of Midwest Baseline Data.

To clarify, during the 1979 and 1988 fish surveys, Mink Arm was connected to South McMahon Lake. Lake whitefish, longnose sucker, northern pike and white sucker were captured in Mink Arm of South McMahon Lake and burbot, lake whitefish, longnose sucker, northern pike and white sucker were captured in South McMahon Lake proper in 1979 and 1988. Before test mining in 1989, a dam was constructed separating Mink Arm from South McMahon Lake to facilitate the draining of Mink Arm. After test mining, an equalization culvert was installed in the dam which allowed some water flow, and a very limited opportunity for fish to move between Mink Arm and South McMahon Lake. Following construction of the dam, Mink Arm was essentially isolated from the rest of South McMahon Lake.

In 2003 fish surveys were conducted in both Mink Arm and South McMahon Lake. In 2003, burbot, lake chub, longnose sucker, northern pike, trout-perch and white sucker were captured in Mink Arm. Lake chub, longnose sucker, ninespine stickleback, northern pike, trout- perch and white sucker were captured in South McMahon Lake. Please note ninespine stickleback were collected in South McMahon Lake, but not in Mink Arm in 2003.

Document Integration:

Text added to Section 4.4.6.1.1 to clarify that when the 2003 survey was conducted, Mink Arm and South McMahon Lake were separated by a dam (built in 1989). Changed table heading (Table 4.4.-42) from ‘South McMahon Lake, Mink Arm’ to ‘Mink Arm’ for clarity.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-6 Comment:

Table 4.4-42 shows that gillnetting and boat electrofishing were conducted to determine the fish species composition of Mink Arm. Considering the mesh size of gill nets employed, of the two sampling methods used only electrofishing was suitable for sampling the small- bodied fish population.

The EIS, however, provides no details as to the date(s) electrofishing was conducted, the level of effort expended, sampling methodology, environmental conditions during sampling, etc. Therefore, it is not possible to determine if the electrofishing conducted was sufficient to determine the species of small bodied species present in the lake.

DFO requests that the proponent provide information necessary to demonstrate that the small-bodied population of Mink Arm has been adequately sampled.

ARC Response:

AREVA acknowledges that this information was not included in the Midwest Project EIS and has provided it below.

Mink Arm was fished using an electrofishing boat, which consists of a Zodiac Grand Raid MK II (4.2 m) and a Smith-Root 2.5 GPP Portable Generator Pulsator Electrofisher. The entire periphery of Mink Arm was fished from 5:15 to 5:55 pm for a total of 1670 seconds on Sept 4, 2003 and from 10:25 to 11:40 am for a total of 3676 seconds on Sept 5, 2003. Weather conditions measured at a local weather station at Wollaston Lake on 4 Sept 2003 were as follows: maximum temperature of 19.4 degrees Celsius, minimum temperature of 6.6 degrees Celsius, mean temperature of 13 degrees Celsius and zero precipitation. Weather conditions on Sept 5, 2003 were as follows: maximum temperature of 18.1 degrees Celsius, minimum temperature of 4.5 degrees Celsius, mean temperature of 11.3 degrees Celsius and 7 mm of precipitation.

The total CPUE for electrofishing was 40.9 fish/hour (38.4 fish/hour for large-bodied fish and 2.7 fish/hour for small-bodied fish).

The Midwest Project Existing Environment Technical Information Document (AREVA 2009) contains all the details of the fish surveys conducted in Mink Arm including dates, effort, time of fishing, CPUE, and methodology. The dates and times fished, as well as the electrofishing effort, are presented in Appendix IV.5, Table IV.5-4.

REFERENCE:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

Document Integration:

No integration required. The Midwest Project Existing Environment Technical Information Document (AREVA 2009) has been submitted to reviewers as per the distribution list.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-7 Comment:

In Table 7.1-6, acute toxicity data for benthic invertebrates are presented that were used to derive toxicity benchmarks considered in the EIS. These benchmarks are included in Tables 7.1-6 and 7.2-6. However, three of the test species listed as benthic invertebrates – Cladocera sp. (for un-iodized ammonia), Calanus sp. (for arsenic), and Cyclops (for cobalt), are not benthic invertebrates, but rather are zooplanktonic organisms. Therefore, the EIS does not include an assessment of the effects on benthic organisms of un-iodized ammonia, arsenic and cobalt present in surface waters or sediment within Vulture Lake or areas downstream, as a result of the project. DFO is particularly concerned that Section 7.2.3.1 – Predicted Effects on Water Quality – states that predicted mean and maximum 95th percentile concentrations of total ammonia, arsenic, molybdenum and selenium in Vulture Lake are expected to exceed stated water quality objectives, but an assessment of the likely impacts of un-iodized ammonia and arsenic levels on benthic invertebrates has not been presented.

DFO requests that a further assessment of the effects on benthic invertebrates of predicted levels of these constituents in the water and sediment of Vulture Lake and areas downstream be provided by the proponent.

ARC Response:

Although AREVA agrees that it is most often best to derive benchmarks for a group of organisms based on toxicity data from organisms of the same group, good data for benthic invertebrates are not always available. Zooplankton organisms tend to be easier to culture and use in experiments and are often more sensitive to toxicants than benthic invertebrates and thus provide conservative estimates of potential effects. Zooplankton toxicity data are often used when benthic invertebrate data are lacking.

The un-ionized ammonia benchmark for benthic invertebrates used in the Midwest Project risk assessment is referenced in the Priority Substance List 2 (PSL2) (Environment Canada and Health Canada 2001) (Table 7.1-6). The benchmark is based on the lowest LC50 value for all invertebrate species (Cladocera sp.). Although the benchmark is not based on toxicity data from a benthic invertebrate, the benchmark is based on the lowest available toxicity value and is therefore considered to be conservative and protective of benthic invertebrates.

The benthic invertebrate benchmark for arsenic is based on another zooplankton organism, Calanus sp. This benchmark is considered to be conservative because it is based on a 14-d 20% Effects Concentration (EC20), whereas most benchmarks are derived from EC50s. This benchmark is based on a Borgmann et al. (1980) study cited in the Canadian Council of Ministers of the Environment Canadian Environmental Quality Guideline (CEQG) publication (CCME 1999). Many of the benchmarks and water quality guidelines used in the Midwest Project EIS are based on information used in CCME publications. The arsenic benchmark is considered to be conservative and is based on the lowest toxicity data available.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-7 The cobalt benchmark for benthic invertebrates is based on data used by the Ontario Ministry of the Environment (MOE 1996). The test (continued) species, Cyclops, had the lowest toxicity value for all test invertebrate species and is the same as a value for a mayfly, which is a benthic invertebrate. Again, because the value is based on the lowest available data (including benthic species), AREVA considers the cobalt benchmark used for benthic invertebrates to be conservative and protective.

Because the benchmarks used for benthic invertebrates for ammonia, arsenic and cobalt are based on the most conservative toxicity data available, AREVA believes that an adequate assessment of the effects on benthic invertebrates has been done for these elements downstream of the treated effluent release.

Section 7.2.3.3 Predicted Effects of Non-radionuclides on Aquatic Ecology of the Midwest Project EIS, discusses the potential impacts of contaminants of concern on aquatic organisms. The screening index approach is used, and values greater than one indicate that the measurement endpoint (benchmark) for a VEC is exceeded by the predicted concentration. The results of the integrated assessment indicated that within the McClean lake east basin and the downstream receiving environment, negligible effects on aquatic VECs are anticipated from treated effluent release based on water and sediment exposures. A discussion of the significance of residual effects or the impacts of these constituents of concern (COCs) in water and sediment downstream of the treated effluent discharge, on aquatic biota, is included in Section 9.2.4 and 9.2.5 of the Midwest Project EIS. An assessment of the likely impacts of un-ionized ammonia and arsenic levels on benthic invertebrates can be found in Section 9 of the Midwest EIS.

REFERENCES:

Borgmann, U., R. Cove, and C. Loveridge. 1980. Effects of metals on the biomass production kinetics of freshwater copepods. Canadian Journal of Fisheries and Aquatic Sciences 37:567–575.

Canadian Council of Ministers of the Environment (CCME). 2007. Canadian water quality guidelines for the protection of aquatic life: Summary table. Updated December, 2007. In: Canadian environmental quality guidelines, 1999, Canadian Council of Ministers of the Environment, Winnipeg.

Environment Canada and Health Canada. 2001. Ammonia in the Aquatic Environment. Priority Substances List Assessment Report. Canadian Environmental Protection Act, 1999.

Ministry of the Environment (MOE). 1996. Scientific Criteria Document for the Development of a Provincial Water Quality Objective for Cobalt (Stable Isotope). PIBS 3361e, 44 pp.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-8 Comment:

Section 7.2.3.5 (changed to 7.2.5.5 during editing) – Predicted Effects on Sediment Quality and Benthic Ecology – states that sediment toxicity benchmarks are presented in Section 7.1.9. However, the EIS does not include a Section 7.1.9.

ARC Response:

AREVA acknowledges that the reference to Section 7.1.9 is in error. There is no Section 7.1.9 in the document. The correct reference is Section 7.1.3.3, Sediment Quality Guidelines and Sediment Toxicity Benchmarks, and this correction has been included in the Midwest Project EIS Version 1-Revision 2. This correction is found in Section 7, sub-section 7.2.3.5.

Document Integration:

The reference to Section 7.1.9 has been corrected to Section 7.1.3.3. This correction is located in Section 7, sub-section 7.2.5.5.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-9 Comment:

Tables 7.1-5 and 7.2-8, in conjunction with Section 7.2.3.5, indicate that – based on CCME and CNSC benchmarks - predicted levels of arsenic, molybdenum and nickel in the sediment may result in harmful effects to benthic organisms in McClean Lake East, and that benthic organisms at Kewen Lake Inlet may be negatively affected by molybdenum concentrations. However, Section 9.2.5 – Sediment Quality and Benthic Ecology – states: …based on regionally derived benchmarks, effects on sediment dwelling benthic invertebrates are unlikely in McClean Lake east basin and the downstream receiving environment. The maximum mean predicted arsenic, molybdenum and nickel concentrations in sediments in McClean Lake east basin are expected to be below the range of the no effects-low effects benchmarks over the operational life of the project.

DFO requests that the proponent provide an explanation for this apparent contradiction.

ARC Response:

To clarify, Sections 7.2.3.5 (in updated version this section is now 7.2.5.5) and Section 9.2.5 do not contradict each other. The same basic statement is made in each section. Section 7.2.3.5 states that “Within McClean Lake east basin and downstream locations, the maximum predicted mean and 95th percentile concentrations are not expected to elicit benthic invertebrate community effects based on regionally- specific toxicity benchmarks and the CNSC SEL working benchmarks. The more conservative CCME TEL and CNSC LEL working benchmarks suggest potential effects associated with the maximum mean predicted arsenic, molybdenum, and nickel sediment concentrations in McClean Lake east basin and molybdenum sediment concentrations at Kewen Lake Inlet.” Section 9.2.5 also states that: “based on regionally derived benchmarks, effects on sediment dwelling benthic invertebrates are unlikely in McClean lake east basin and the downstream receiving environment. The maximum mean predicted arsenic, molybdenum and nickel concentrations in sediment in McClean Lake east basin are expected to be below the range of the no effects-low effects benchmarks over the operational life of the project “. The predicted effect is different depending on which guideline or benchmark is being used as stated in Section 7.2.5.5. The CCME sediment quality guidelines are conservative by design as are the CNSC benchmarks. Regional toxicity benchmarks are available for arsenic, molybdenum, nickel, and uranium (Liber and Sobey, 2000). When available it is considered good scientific practice to utilize the most relevant data available. These benchmarks are considered to be more realistic for use in the Midwest Project risk assessment because they were determined specifically to evaluate the toxicity of contaminants of concern in sediment within the region under consideration to relevant organisms. As well, these benchmarks evaluated sensitive endpoints such as growth. Because these benchmarks are considered to represent a more real world scenario and to be more accurate in predicting effects, they are used in Section 9.2.5 to conclude that “based on regionally derived benchmarks, effects on sediment dwelling benthic invertebrates are unlikely in McClean lake east basin and the downstream receiving environment.” Where regional toxicity benchmarks are not available, CNSC SEL benchmarks are considered appropriate. AREVA provides multiple benchmarks to characterize a range of potential effects and outline potential sensitivities in the assessment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO-9 (continued) REFERENCE:

Liber, K. and S.L. White Sobey. 2000. Toxicity of Uranium, Molybdenum, Nickel, and Arsenic to Hyalella azteca and Chironomus tentans in Water-only and Spiked-sediment Toxicity Tests. Toxicology Centre, University of Saskatchewan. Draft manuscript.

Document Integration:

No integration required.

Response from Province: A study conducted by P.A. Thompson et al., Derivation and Use of Sediment Quality Guidelines for Ecological Risk Assessment of Metals and Radionuclides Released to the Environment from Uranium Mining and Milling Activities in Canada, 2010 indicates that SEL working benchmarks are not reliable predictors of impacts on benthic invertebrate communities. AREVA should determine if LEL working benchmarks are available since they would more accurately predict impacts.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response: As outlined in Section 7.1.3.3 of the main document, a wide variety of available sediment quality benchmarks are utilized to assess potential effects to benthic communities; the assessment is not based on Thompson et al. (2005). Please refer to Table 7.1-5 for a list of the sediment benchmarks used in the assessment and to Section 7.1.3.3 of the main document for a discussion of the sediment quality guidelines and sediment toxicity benchmarks. Table 7.2-9 in the main document presents predicted average and 95th percentile screening index values for the Midwest Project base case. The screening index values are presented for CCME (1999) Interim Sediment Quality Guidelines (ISQG) and Probable Effects Levels (PEL), Thompson et al. (2005) LEL and Severe Effect Levels (SEL), and Liber and Sobey (2000) No Observed Effects Concentration (NOEC), Lowest Observed Effect Concentration (LOEC), 25% Inhibitory Concentration (IC25) for growth and 50% Inhibitory Concentration (IC50) for growth. Discussions of predicted effects are included in Sections 7.2.5.5 and 7.3.2.3 of the main document.

2010 REFERENCES CCME. 2002. Canadian Interim Sediment Quality Guidelines. Update. Canadian Council of Ministers of the Environment. Winnipeg.

Thompson, P.A., J. Kurias, and S. Mihok. 2005. Derivation and Use of Sediment Quality Guidelines for Ecological Risk Assessment of Metals and Radionuclides Released to the Environment from Uranium Mining and Milling Activities in Canada. Env. Mon. and Assess. 110:71-85.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment DFO – 1 (2010) Comment:

Appendix lll of the revised EIS dated February 2010 makes reference to gillnetting, fish egg searches and larval fish trawling conducted NEW within the Mink Arm of South McMahon Lake during 2009. However, although the EIS main document presents the results of historical fish sampling over a multi-year period, it does not reference surveys conducted in 2009. The main document (e.g., Pages 4-81 and 4-92, Table 4.4-38, Figure 4.4-6) should be revised to include and discuss data collected in 2009.

ARC Response:

Details on the Mink Arm 2009 fish and fish larvae community surveys have been added to the Midwest EIS.

Document Integration:

 Updated Figure 4.4-6 to illustrate that Mink Arm was surveyed in 2009.  Added text to Section 4.4.6.1.1 (~ page 4-81 and 4-82) and Section 4.4.7.1 (~ page 4-92) to summarize results of the Mink Arm 2009 survey.  Updated Tables 4.4-38, 4.4-40 and 4.4-41 to include results from the Mink Arm 2009 survey.

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO – 2 (2010) Comment:

The presence/absence of lake whitefish within Mink Arm needs to be clarified within the EIS. The addendum of the EIS (response to DFO- NEW 17 comment) states that, based on surveys conducted in 2003 and 2009, whitefish are not currently present within Mink Arm. Appendix lll of the EIS (Page 26) also states that lake whitefish are not present within Mink Arm. However, Pages 4-91 and 4-92 of the EIS state that the fish community of South McMahon Lake, including Mink Arm, includes lake whitefish.

ARC Response:

Lake whitefish are absent from Mink Arm.

Although lake whitefish were present in Mink Arm in the past (captured during 1979 and 1988 surveys; Table 4.4-41), this was prior to construction of the Mink Arm dam in 1989 and separation of Mink Arm from South McMahon Lake.

Based on more recent and extensive surveys in 2003 (boat electrofishing for 1.49 hours and gill netting for 2.17 hours) and 2009 (gill netting for 107 hours), it has been found that lake whitefish are absent from Mink Arm (Table 4.4-40). To further assess whether lake whitefish were present and reproducing in the Mink Arm, larval tows were undertaken in 2009 and no larval or juvenile lake whitefish were captured. These results suggest that lake whitefish currently do not reside in Mink Arm.

Document Integration:

Section 4.4.7.1 has been clarified to explain that lake whitefish have not been found in Mink Arm during recent surveys.

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment DFO – 3 (2010) Comment:

DFO expressed concern (DFO-2 comment in the addendum) that the discharge of water to Midwest Creek during the dewatering of Mink NEW Arm could degrade the creek channel and floodplain, and requested that the proponent describe monitoring to be undertaken and mitigation measures to be adopted if necessary to reduce impacts. The proponent replied that a monitoring program would be implemented during periods of increased flow within the creek, but failed to commit to a particular monitoring strategy. DFO requests that the proponent describe the monitoring program that will be adopted, including the frequency of monitoring and information/data that will be collected (e.g., stage, discharge, stage-discharge relationship). DFO also requests that the proponent provide a commitment that, in the event of a wet year, pumping into Midwest Creek will not occur when streamflow exceeds the 1 in 10 year level. Pages 3-12 and 6-8 of the EIS state that in the event of a wet year the 1 in 10 year flood level could be adopted as the flow constraint, but no commitment is given that pumping into the creek will not occur when streamflow exceeds this level. DFO remains concerned that, due in part to the relatively high channel slope (6% to 7%) throughout most of the channel, degradation of the channel could result from sustained pumping to the creek in the absence of a reasonable streamflow constraint, adequate monitoring and the implementation of mitigation measures where appropriate.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

The dewatering of Mink Arm will be managed to ensure that dewatering activities do not augment Midwest Creek flows beyond a flow rate of 0.3 m3/s (the 1 in 10 year flood level). Pumping rates will be managed based on the time of year, precipitation events and flows measured at Midwest Creek. Section 3 includes text to verify AREVA’s commitment: “In the event that a wet year is encountered, the 1 in 10 year flood level would be adopted as the flow constraint with the implementation of additional monitoring.” The use of the word ‘could’ in the previous paragraph in Section 3 (and in Section 6) is a typo and will be corrected.

As described in the response to comment DFO-2, a field assessment of Midwest Creek was conducted in 2008 by Golder Associates. Due to the armouring present in the channel of Midwest Creek, it is not anticipated that the channel would degrade during a sustained 1 in 10 year flood event. The predicted water surface during the 1 in 10 year flood event does extend into the floodplain at some sections of the stream; however, the extent of various grasses, roots, mature trees, willows, and fallen debris is such that the predicted velocities and shear stresses would not result in degradation of the floodplain or loss of riparian vegetation.

Stream and floodplain topography, streambed and bank material, and stream discharge were assessed and the 1 in 10 year flood flow for Midwest Creek was estimated to be 0.30 m3/s. During Mink Arm dewatering activities, stream stage will be monitored daily using a pressure transducer and manual discharge measurements will be obtained weekly. From this data, a stage-discharge rating curve will be used to determine daily flow values for Midwest Creek. This data combined with dewatering rates will allow AREVA to manage flows below the 1 in 10 year flood event.

Routine visual monitoring of the Midwest Creek channel will be conducted weekly throughout the dewatering period. Inspections will be conducted daily during large precipitation events. During visual inspections, any debris blocking streamflow in the channel, at South McMahon Lake outlet and North McMahon Lake inlet will be removed. In the event that observational data suggests erosion of the stream banks and/or scour may begin to occur, the pumping rates will be reduced as required.

REFERENCES:

Golder Associates Ltd. 2009. Response to regulatory comments on Midwest environmental impact statement.

Document Integration:

Update text in Section 3.2.1.1.2 and 6.4.3.1 of the EIS from: “In the event of a wet year, the 1 in 10 year flood level could be adopted as the flow constraint…” to “In the event of a wet year, the 1 in 10 year flood level will be adopted as the flow constraint…”

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment DFO – 4 (2010) Comment:

The flushing rate of Too Small Lake needs to be clarified. Table 4.2-13 of the EIS indicates a flushing rate of 1.30 times per year whereas NEW the addendum (response to DFO-32 comment) indicates a flushing rate of 0.92 times per year.

ARC Response:

The flushing rate for Too Small Lake was re-evaluated during formulation of the fish habitat compensation options. An outflow estimate of 0.019 m3/s was determined for Too Small Lake using a unit-area runoff approach. This indicates that Too Small Lake in its current state has an approximate flushing rate of 0.92 times per year for its drainage area, therefore, Table 4.2-13 will be changed to reflect a flushing rate of 0.92 times per year.

Document Integration:

Update flushing rate value in Table 4.2-13 to 0.92 times per year.

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment DFO - 5 (2010) Comment:

One of the factors that will determine the amount of fish habitat compensation that will be required by DFO is the time interval between the NEW loss of Mink Arm as fish habitat and the point where the compensatory habitat is fully functional. It is noted, however, that Section 3.10 and Figure 3.10-1 of the EIS (project schedule) do not reference the draining of Mink Arm or the construction and completion of the preferred habitat compensation project. DFO requests that the project schedule indicate the time during which Mink Arm will be dewatered and the time during which the habitat compensation project will be constructed and become fully functional, relative to other pre-development or development activities. DFO assumes that the compensatory habitat will be fully functional at some point after fish have been stocked within the habitat. ARC Response:

When AREVA applies to DFO for authorizations under the Fisheries Act, additional information will be needed. This will include an estimate of any time lag between habitat loss in Mink Arm and implementation of the chosen fish habitat compensation plan.

The draining of Mink Arm is discussed in Section 3.10; however Figure 3.10-1 will be updated to include pre-development activities.

Document Integration:

Update Figure 3.10-1 to include proposed schedule for pre-development activities (as described in Section 3.10)

Technical Review Response:

In order to conclude the federal EA, DFO must be advised of the approximate time interval between the loss of Mink Arm as fish habitat and the point where the productive capacity of compensatory fish habitat will become fully functional as a result of the implementation of the fish habitat compensation plan. As per DFO policy, the time interval referenced above will be considered by DFO in its determination as to the amount of compensation required.

October 2010 As per DFO policy, a compensation ratio (amount of compensation:amount of loss of productive capacity) in excess of 1:1 would normally be required where there is uncertainty as to the success of the proposed compensation, the replacement habitat is inferior to the habitat being lost, there is a time lag between time when habitat will be lost and the time when the compensatory habitat will be fully functional, etc.

Once DFO has determined that mitigation measures and compensation have been provided to the extent that the loss of productive capacity of fish habitat resulting from the loss of Mink Arm has been offset, DFO may then make a determination as to the significance of adverse environmental effects as presented in the EA. Therefore, the time interval referenced above must be provided at the EA stage rather than at the authorization stage.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

Based on further discussions with DFO and Provincial fisheries personnel, the fish habitat compensation plan has been revised. The preferred compensation plan is to restore connectivity at Montreal River weir through the construction of a Newbury riffle. The Too Small Lake and Sue E Pit/Sils Lake alternatives will be presented in Appendix III as alternatives which were considered prior to arriving at the preferred plan.

As discussed with DFO, AREVA’s decision to proceed with the Midwest Project is ultimately linked to market conditions and therefore, an absolute date for construction of the Newbury riffle cannot be stated. In terms of timing, it is anticipated that compensation will occur within an approximate two-year timeframe of the habitat loss, contingent on the prevailing river flow regime and construction logistics, as agreed to by DFO and AREVA.

Document Integration:

Appendix III will include a discussion of project timing as outlined in the comment response above.

DFO Technical Review Response (April 29, 2011):

Acceptable.

ARC Response (May 5, 2011):

Acknowledged.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment DFO -6 (2010) Comment:

NEW DFO previously indicated (DFO-9 comment in the addendum to the EIS) that the EIS should include an analysis of the effects of the transfer of fish from Mink Arm to South McMahon Lake on fish populations in the lake. The proponent has not included the requested analysis in the EIS, but has advised that data required to estimate the carrying capacity of South McMahon Lake will be collected prior to or during the draining of Mink Arm. DFO, however, will require that the requested analysis be undertaken prior to the draining of Mink Arm and transfer of fish, in order to ensure that the carrying capacity of South McMahon Lake will not be exceeded by the addition of what will likely be a significant number of fish from Mink Arm. DFO requests that Section 3.2.1.1.2 of the EIS include a commitment that, prior to the draining of Mink Arm and transfer of fish into South McMahon Lake, an analysis of the effects of such a transfer will be undertaken and provided to DFO and the province of Saskatchewan. The analysis should include options for mitigating potential negative effects on fish populations resulting from the transfer of fish. ARC Response:

In response to DFO-9 (App III) submitted as part of the February 2010 addendum, AREVA committed to measuring the length, weight, age of a representative number of fish from Mink Arm (not South McMahon Lake). This data would be used to estimate the productivity of Mink Arm. AREVA did not propose to determine the carrying capacity of South McMahon Lake and apologizes if the response to DFO-9 (App III) was unclear.

As noted in section 3.2.1.1.2 Proposed Mink Arm Dewatering Options of the Draft Midwest EIS, “A suitable option for the disposition of the remaining fish in Mink Arm will be determined through discussions with local communities, the province and DFO.” AREVA understands that additional information will be needed at the time of the application to DFO for authorizations under the Fisheries Act, prior to the draining of Mink Arm and the transfer of fish or disposition.

Document Integration:

No integration required.

Technical Review Response:

DFO will require that the EIS include an analysis of the effects of the transfer of fish from Mink Arm to South McMahon Lake on fish populations within the lake. The analysis must provide information as to whether or not the transfer of fish will negatively affect fish or fish October 2010 populations within the lake; limits to fish transfer, if any; acceptable transfer rate; stocking methodology; etc., and include options for mitigating potential negative effects of the transfer.

This information is required within the EIS and prior to the transfer of fish, in order to ensure that there will be negligible impacts to fish and fish habitat within South McMahon Lake resulting from the input to the lake of what will likely be a significant number of fish, and to conclude the federal EA.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

AREVA has re-evaluated the options for managing fish in Mink Arm prior to dewatering. AREVA’s preference is to seek an authorization to destroy fish by means other than fishing. It is AREVA’s intention to engage local communities to provide the opportunity for local participation in a fish salvage operation; any fish not utilized by local communities will be landfilled. As part of the fish salvage operation, AREVA will collect length, weight, and age data from a subset of the fish salvaged Mink Arm as a means of documenting the fish population measures for scientific purposes.

Document Integration:

Update fish salvage plans in Section 3.2.1.1.2 Proposed Mink Arm Dewatering Options as outlined in the comment response above.

DFO Technical Review Response (April 29, 2011)

DFO will not issue an authorization to destroy fish by means other than fishing and will require that AREVA transfer the live fish from Mink Arm into South McMahon Lake prior to it being dewatered. Details regarding fish salvage activities will be developed in consultation with the Saskatchewan Ministry of Environment and AREVA.

DFO has concluded that it is unlikely that the introduction of fish from Mink Arm will have significant long-term negative effects on fish populations within South McMahon Lake. Therefore, the EIS will not need to include an analysis of the effects of the transfer of fish on fish populations within South McMahon Lake.

DFO will require confirmation in writing that AREVA intends to undertake this fish transfer and that it will be conducted as agreed to by DFO and the Saskatchewan government.

ARC Response (May 5, 2011):

Upon further discussion with DFO, it was determined that the transfer of fish from Mink Arm to South McMahon Lake was a practical solution to address the fish that are currently isolated from the main portion of South McMahon Lake. A fish transfer procedure will be undertaken to move fish from Mink Arm to South McMahon Lake.

AREVA proposes to use non-lethal sampling techniques (e.g. boat electrofishing and trap nets) over a number of days to capture fish in

Mink Arm prior to dewatering; it is anticipated that the majority of fish will be removed with these techniques. When dewatering proceeds, non-lethal fish collection will be conducted intermittently: as the volume of water in Mink Arm decreases, the fish remaining in the water body will become concentrated and easier to locate and capture. All captured fish will be transferred to South McMahon Lake in such as way as to minimize stress (e.g. provide time for recovery in a holding tank, keep holding times as short as possible, gently introduce fish to South McMahon without excessive disruption of sediment). Further details on the fish transfer procedure will be decided in consultation with DFO and Saskatchewan Ministry of Environment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment DFO – 7 (2010) Comment:

The August 2007 draft of the EIS indicated that local lakes, including Too Small Lake, could be drawn down due to dewatering of the NEW Midwest Pit. The proponent proposed that if this were to occur, lake levels could be maintained by pumping reverse osmosis (RO) permeate into the lakes. In response (DFO-10 comment in the addendum to the EIS), DFO stated that the impact of discharging RO permeate into fish habitat was uncertain, in that natural runoff and groundwater typically provide nutrients that are beneficial to aquatic productivity, but the replacement of these natural inflows with RO permeate may have unintended negative impacts. In response to DFO’s stated concerns the proponent indicated that because water from the RO plant could contain reduced nutrient concentrations, nutrient levels in receiving lakes could be monitored seasonally in the event that augmentation of the lake volume was required, and consideration could be given to nutrient augmentation. The proponent, however, has not described monitoring that will be undertaken or mitigation measures that will be implemented in the event that fish or fish habitat would be negatively affected by drawdown or the addition of RO permeate. DFO therefore requests that the proponent undertake the following: 1. identify fish-bearing water bodies that could be affected by the dewatering of the Midwest pit and will be monitored for water body level/volume and nutrient levels; 2. describe monitoring to be undertaken, including a rationale for the monitoring approach; and, 3. identify thresholds/benchmarks related to water level and nutrient status that would indicate when negative impacts would occur as a result of drawdown or volume augmentation, and describe mitigation measures that would be taken to prevent or reduce negative impacts. ARC Response:

Open pit dewatering will result in the development of a sink in the groundwater regime and may induce water movement from nearby water bodies. The impact of mining on lake levels is difficult to predict and the tendency in the Collins Creek basin has been an overestimation of the actual impact. The Midwest open pit is estimated to be actively dewatered for approximately a 5 year period. Computer simulation modelling of the predicted impacts of mine dewatering on lakes in the Midwest area is included in Appendix IV, Section 4.4 of the Midwest EIS.

Model predictions indicate that Too Small Lake, Shallow Lake, and South McMahon Lake may experience lake level drawdown. Other lakes potentially affected by dewatering include North McMahon Lake, Pig Lake, Deborah Lake, Henday Lake (east basin), Lake C1, Lake W1, and John Pond. Fish species found within these lakes and others within the local assessment boundary are included in Table 4.4-40. The potentially affected lakes are currently equipped with staff gauges for the purpose of monitoring water levels. During active mine dewatering, changes in lake level will be monitored. In the event that a drop in lake level is attributable to dewatering activities, water quality monitoring will be initiated to assess nutrient levels thus providing a means to evaluate the effect of RO permeate on the water body. Natural runoff will continue to provide nutrients that are beneficial to aquatic productivity. As outlined in response to CNSC-4(4), the volume of water required to offset the potential effects of lake drawdown are a relatively small proportion of total water volume, therefore potential effects on nutrient status are anticipated to be negligible.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

DFO remains concerned that, in the event that lakes are drawn down due to the dewatering of the Midwest Pit, the discharge of RO permeate into these lakes to compensate for losses due to dewatering could have unintended negative impacts. For example, natural runoff and groundwater typically provide nutrients that are beneficial to aquatic productivity, but such nutrients may not be present at desirable concentrations in the RO permeate.

October 2010 In the event that drawdown will result in negative effects, it is important that mitigation measures be implemented as soon as possible to prevent or reduce negative effects. In order to identify when negative effects will occur and implement appropriate mitigation measures as soon as possible, the following information will need to be provided before the federal EA can be concluded:

1. thresholds/benchmarks related to water level and nutrient status that would indicate when negative will occur; 2. a rationale for these thresholds/benchmarks; and, mitigation measures that will be taken to prevent or reduce negative impacts.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

As outlined in Section 4.4 of Appendix IV, conservative pit dewatering modeling results indicate Too Small, Shallow and South McMahon lakes may experience lake level drawdown. Case 1, the most conservative dewatering scenario, suggests that over a 5 year period, Too Small Lake may be fully drained while Shallow and South McMahon lakes may be drawn down by 0.60 m to 1.60 m, respectively.

Section 4.2.3.5, Table 4.2-10 of the Midwest EIS provides the results of the baseline lake level monitoring program. Between 2003 and 2010, recorded natural lake elevations in Shallow and South McMahon lakes varied by 0.22 m and 0.26 m, respectively. Based on a monitoring record between 2003 and 2008, Too Small Lake surface water elevation has varied by 0.15 m. These ranges in surface water elevations are consistent with longer-term surface water level variations measured at 19 locations at McClean Lake Operation from 1995- 2001/2002: 0.57 m ± 0.3 m (mean range in lake elevation ± SD) (COGEMA 2003). Based on these measures of variability, we feel that 0.4 m threshold is appropriate.

Based on this assessment of natural lake level variation, the following monitoring and mitigation program will be implemented:

 During the open water seasons of Midwest pit dewatering, AREVA will measure monthly surface water elevations in Too Small, Shallow and South McMahon lakes.  Lake level data will be compared to pre-mining data (where available) and/or to reference lakes at McClean Lake Operation. o The proposed statistical method for examination of lake level trends is the Kendall’s tau-b test, which is a non-parametric test used to compute correlation coefficients between two variables. Kendall’s tau-b will be used to evaluate trends in lake level by examining correlations between time and water level values. Kendall’s tau-b ranges from -1 to 1 and the null hypothesis will be that there is no change in open water period water level over time. For water level trends, a positive value indicates that there is an increasing trend over time and a negative value signals a decrease.  The threshold at which mitigation (addition of RO permeate) will be triggered is when the Kendall’s tau-b test generates a significant (p < 0.05) negative (decreasing water level) trend in Too Small, Shallow and/or South McMahon lakes’ surface water elevation beyond natural variability. If the lake level trend analysis indicates lake level fluctuations are occurring in a manner inconsistent with reference lake levels, and beyond the range of natural variation (0.4 m), AREVA will notify the regulatory agencies, and implement the contingency measure outlined.

Two nutrients, nitrogen and phosphorus, generally govern aquatic productivity. Phosphorous tends to be the least abundant nutrient and commonly limits biological productivity in aquatic ecosystems particularly in northern oligotrophic lakes (Schindler 1977, Wetzel 1983, Chambers et al. 2001). It is widely recognized that the phosphorous cycle in aquatic environments is complex (Clapman 1983, Wetzel 1983, Doerr 1996). In freshwater lakes, the mobile phosphate pool is very small and it may be absorbed by one organism as quickly as it is excreted from another; the average turnover time for phosphorous to proceed through the organic cycle is 10 minutes (Clapman 1983). Inorganic phosphate that is not immediately used by living organisms can become bound onto and released from sediments (Clapman1983, Chambers et al. 2001).

Given that the majority of the lake nutrient inventory resides in biota and sediment, the concern raised with respect to lake nutrient status does not appear well justified. It is unclear if lake drawdown (if it occurs) would result in a decrease, an increase, or no change in the lake water column nutrient status. While it is acknowledged that natural runoff and groundwater inputs can contribute nutrients to support aquatic productivity, the lakes potentially affected by drawdown have small local watersheds from which to receive nutrient inputs. The current nutrient status of these lakes reflects their evolution over an extended period of time. Relative to the five years that these small headwater lakes could potentially be influenced by dewatering activities, potential changes in nutrient status would appear to be inconsequential.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response (cont.):

AREVA has a number of reservations with regard to the hypothesis upon which this comment is based, the suggestion that a meaningful threshold could be developed, and that a mitigation plan to add nutrients would be an environmentally desirable strategy. That being said, AREVA proposes the following monitoring program:

 At the time of licensing, a baseline phosphorous monitoring program will be initiated at Too Small, Shallow and South McMahon lakes. o Phosphorous concentrations in northern Saskatchewan lakes (refer to Table 4.4-3) tend to be below the detection limit of most analytical laboratories in Canada (i.e. the total phosphorous method detection limit is 0.01 mg/L at Saskatchewan Research Council). AREVA will locate a laboratory with the ability to detect total phosphorous in water below 0.01 mg/L. The water samples from Too Small, Shallow and South McMahon lakes will be analyzed at this lower detection limit in order to develop a temporal record of baseline water column phosphorous concentrations.  If lake levels are affected by dewatering activities and RO addition occurs, AREVA will regularly monitor water quality in the lake(s). Analysis will include total phosphorous with a method detection limit <0.01 mg/L.  These results will be presented to DFO and other regulators to evaluate trends in nutrient status and advise if mitigation should be considered.

References:

Chambers, PA, M Guy, ES Roberts, MN Charlton, R Kent, C Gagnon, G Grove, and N Foster. 2001. Nutrients and their impact on the Canadian Environment. Agriculture and Agri-Food Canada, Environment Canada, Fisheries and Oceans Canada, Health Canada and Natural Resources Canada. 241 p.

Clapman, WB. 1983. Natural Ecosystems. Macmillan Publishing Company, New York, USA.

COGEMA. 2003. McClean Lake Operation existing environment technical information document. September 2003. Saskatoon, Saskatchewan.

Doerr, SM. RP Canale and SW Effler. 1996. Development and testing of a total phosphorous model for Onodaga Lake. Lake and Reservoir Management 12: 141-150.

Schindler, DW. 1977. Evolution of phosphorous limitation in lakes. Science 19:260-262.

Wetzel, RG. 1983. Limnology. Second Edition. CBS College Publishing, Philadelphia, USA.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EnvCan-1(1) Comment:

Environment Canada recommends that should this approach be used at Midwest, that AREVA undertake periodic audits of the mine waste piles to evaluate the segregation plan. It is noted that the segregation approach can be confounded by factors such as moisture content. AREVA should ensure that all tests are conducted as correctly as practical. The Department recommends that such verification can be made through direct measure of solid concentrations and, more importantly, from the measured values in the drainages from the benign waste piles.

ARC Response:

Acknowledged , no response required.

Document Integration:

No integration required.

Regulator Comment / Response Comment EnvCan-1 (2) Comment:

The application does not provide a discussion on Woodland Caribou movement in relation to the haul road and the associated effects that operation of the haul road would have on movement and perhaps mortality of the species. Environment Canada does not know whether the Province considers this a deficiency in the report or not. The Responsible Authorities should consult with the Province on whether supplementary information on caribou movement and potential mortality rates are required.

ARC Response:

Aknowledged, no response required.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EnvCan-2 Comment:

The clean rock is to be placed in piles abutting the pit. The final configuration of the piles is yet to be defined pending the results of negotiations with adjacent properties. The final configuration of the piles should reflect need to monitor drainages from the pile as noted above, and space to implement any necessary contingencies should they be necessary.

ARC Response:

Acknowledged , no response required.

Document Integration:

No integration required.

Regulator Comment / Response Comment EnvCan-3 Comment:

Water would be segregated for management based on their origin. Waters in direct content with the mine wastes or the pit would be treated for potential contaminants. Based on the proposed system, for the purposes of the Metal Mining Effluent Regulations (MMER) of the federal Fisheries Act, the regulatory compliance point would be at the discharge of the water treatment system, before it is combined with the ‘clean’ groundwater. Further, the proponent is reminded that ‘dirty’ waters cannot be combined with the clean diverted groundwater for the purposes of meeting the discharge criteria (i.e. dilution). Any waters leaving the site from operational areas would also be subject to the MMER.

ARC Response:

Acknowledged, figure 3.5-2 has been updated to illustrate the waste water management at the Midwest site. Water from the chemical water treatment plant and the Reverse Osmosis water treatment plant will be monitored as two separate and distinct streams. Separate MMER final points of discharge will be established for the chemical and RO water treatment plant prior to being combined and released to the Sink Vulture Treated Effluent Management System. Water from the chemical water treatment plant will be directed to monitoring ponds and tested prior to being combined with clean groundwater and RO Permeate. If water quality from the chemical water treatment plant does not meet water quality objectives it will be recycled for treatment.

Document Integration:

Main Document, Section 3, Figure 3.5-2.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EnvCan-4 Comment:

AREVA proposes to modify the mill at McClean Lake to accommodate that Midwest ore in addition to ore from other ore sources. A molybdenum recovery in the product line and, potentially, a nickel and cobalt recovery circuit in the waste stream may have implications to receiving waters. It is important that in undertaken these process changes, other contaminants are not made more mobile.

ARC Response:

Acknowledged

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC -1 (2010) Comment:

NEW Section 3: Description of the Project

Waters released with the dewatering of Mink Arm may be considered effluent for the purposes of the Metal Mining Effluent Regulations. At this time, EC can not provide a definitive opinion, but will follow up with the proponent as the project proceeds. ARC Response:

Acknowledged.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 2 (2010) Comment:

NEW 3.1.4.1 Expansion of the Surface Lease at Midwest Site (The preferred site layout, alternative 3, (Figure 3.2-8) is dependent on acquiring the additional surface lease area from the province.)

The proponent's preferred site configuration ("layout 3") requires use of a portion of property to which it states is dependent on acquiring additional lease from the province. Although fundamentally the proposal review considered the wastes and their impact, encroachment into any fisheries waters (such as John Pond or the bays of South McMahon Lake) for purposes of providing mine waste disposal storage would require an amendment of the Metal Mining Effluent Regulations. This formal process would require vigorous assessment of waste management alternative to justify the decision to use these waters. ARC Response:

Acknowledged.

The preferred site layout (alternate #3) will not require the infilling of John Pond. Reconfiguration of the waste rock stockpile to extend off of the surface lease onto the mineral lease held by Fission Energy Corporation, has been proposed to accommodate for the loss of storage space in John Pond. The approval of this surface lease expansion is a Provincial decision and is recognized by AREVA as a potential risk.

Document Integration:

No further integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 3 (2010) Comment:

NEW 9.2.3 Surface Hydrology and Lake Levels

The Proponent proposes to discharge treated mine water of high quality into local lakes should their water levels decline excessively due to mining activity. The proponent should be aware that such a mitigation action would constitute a release of effluent, and require the discharge point to be declared under the Metal Mining Effluent Regulations. The effluent and receiving waters would be subject to the requirements of those Regulations, including monitoring and reporting. ARC Response:

AREVA recognizes that the discharge of treated mine water of high quality into local lakes, should their water levels decline excessively due to mining activity, may constitute a release of effluent. In the event of such mitigative action, a discharge point will be declared under the Metal Mining Effluent Regulations and the effluent and receiving waters will be subject to the requirements of those Regulations.

Document Integration:

No integration required.

Regulator Comment / Response Comment EC – 4 (2010) Comment:

NEW Section 8.2.4.2

The consideration of radiation impacts (for example from dusts, mine wastes and radon gas) to local or potentially future resident wildlife at the Midwest site is largely absent in the document, particularly in the decommissioning of the facility. Although review includes McClean Lake, information on the radiation doses to wildlife is not discussed with regard to the Midwest site proper. The discussion is focused on human health in "near by" community and a radiation worker. It is noted that chemical exposures to wildlife are described.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

The Midwest Environmental Impact Statement Section 8 Effects of the Project on Human Health provides information on human health. Radiological assessment of potential adverse impacts from the Midwest Project to Valued Ecosystem Components (VECs) including wildlife are presented in Appendix VI Integrated Risk Assessment (see Appendix VI, section 9.3 Radiological Assessment for a sample calculation) and summarized in Section 7 Assessment of Residual Effects. The air dispersion model includes sources from ore stockpiles, mining activities, waste stockpiles, mill emissions and roads to air which subsequently move into water, soil, lichen, terrestrial vegetation, berries and, through the food web, to various VEC consumers. Direct air pathways for aquatic birds, terrestrial birds and terrestrial animals were considered insignificant and only considered in the assessment of human exposure (Figure 7.1-3).

For radon-222, the Radiation Protection Regulations of the Canadian Nuclear Safety Commission (CNSC 2000) provide two alternatives for assessing the radon-222 attributable to a licenced facility. These are an incremental, i.e., above baseline (background) level of 60 Bq/m3 of Rn or exposure to 4 working level months (WLM) of radon progeny (short lived radon decay products). In order to provide a context for Rn levels, predicted in the air quality assessment, the 60 Bq/m3 (incremental) value was adopted. The predicted incremental annual radon concentrations in the vicinity of the Midwest Project site meet the CNSC level of 60 Bq/m3 for radon attributable to licensed activities.

Reference:

CNSC (Canadian Nuclear Safety Commission Regulations). 2000. Nuclear Safety and Control Act, Radiation Protection Regulations. Canada Gazette Part 2 134(13).

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 5 (2010) Comment:

NEW P. 3-2, Section 3.1.1.1

It is indicated that “an earth-fill dam separates the southern reach of Mink Arm from the main lake and was built to facilitate dewatering of Mink Arm during the test mining period.”

The Proponent should clarify if any contingency measures will be put in place to prevent over flow of lake water across the earth-fill dam and if any contingency measures will be put in place to prevent cross-contamination of lake water potentially seeping through the earth-fill dam.

ARC Response:

See response to Comment CNSC-2(1). As outlined in Section 3.2.1, “The existing dam will be upgraded as required to ensure slope, stability, control seepage and ensure a suitable full supply level to provide adequate protection from over-topping for the mine in the event of a probable maximum precipitation (PMP) flooding event.” Further information regarding the existing dam and the PMP design criteria are provided in Section 3.2.1.

As outlined in Section 3.2.5, The preferred Midwest pit water management option consists of a combination of perimeter dewatering wells and in-pit dewatering. The operation of these dewatering systems will depress the groundwater table in the vicinity of the Midwest pit resulting in groundwater movement toward the pit. This system minimizes the potential for contamination of lake water. All water captured by the perimeter dewatering wells and in-pit dewatering system will be subject collection and treatment if required.

Document Integration:

No integration required

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 6 (2010) Comment:

NEW P. 3-3, Section 3.1.1.2

The Proponent should provide the reasoning for no longer considering the original site layout and the alternative site layout #2 as a potential option for the Midwest project.

The Proponent indicates that alternative site layout #3 is the preferred option (p. 3-4). The Proponent should describe the differences between site layout #3 and the preferred site layout.

ARC Response:

As discussed in Section 3.1.1.2 the original site layout proposed in the 2005 Project Description, which involved moving the dam, was replaced with alternatives that limit disruption of fish habitat in Mink Arm to an area previously altered during test mining.

Also discussed in Section 3.1.1.2 alternative #2 was removed due to regulatory constraints and the unfavorable view of infilling John Pond with clean waste rock.

Alternative site layout #3 is the preferred site layout, largely due to the removal of the infilling of John Pond and the reconfiguration of the waste rock piles to accommodate this removal.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 7 (2010) Comment:

NEW P. 3-4, Section 3.1.2

The Proponent indicates that a haul road will be constructed. Two potential locations have been suggested for this road.

The Proponent should indicate which mitigation measures will be put in place to minimize potential environmental adverse effects that could result from this road crossing various water bodies.

ARC Response:

The proposed north and south haul road stream crossings are discussed in detail in Appendix III. Within Appendix III, Sub Appendix A details stream crossing fish habitat assessments conducted at each proposed haul road crossing. Sub Appendix B details conceptual designs for road crossing structures as well as best management practices and best available technologies that will be utilized to minimize the impact of construction to fish habitat. Sub Appendix C contains further detailed assessment on the potential impact on fish habitat at haul road crossing locations and methodologies to minimize HADD. Also included in Sub Appendix C are proposed drainage structure designs for individual haul road stream crossing locations to satisfy Navigable Water Protection Program guidelines while minimizing disturbance to fish habitat.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 8 Comment: (2010) P. 3-11, Section 3.2.1.1.1 NEW The Proponent indicated that the pH, flow rate, conductivity, turbidity and temperature of the Mink Arm was measured daily during dewatering.

The Proponent should have provided a summary of this data in order to get a broader picture of the types of environmental conditions that can be expected to result from the dewatering of the Mink Arm as a result of Midwest site preparation ARC Response: A summary of the available 1988/1989 Mink Arm dewatering quality is provided below.

Mink Arm dewatering quality (monthly mean of daily samples, 1988) MONTH November December Mean 0.3 0.1 Flow (m3/min) Max 0.3 0.2 Min 0.2 0.1 Mean 22.4 25.4 Conductivity (µS/cm) Max 66.0 31.0 Min 14.0 18.3 Mean 4.5 4.1 Turbidity (NTU) Max 5.6 8.0 Min 2.0 2.8 Mean 1.5 1.7 Temperature (ºC) Max 3.5 4.9 Min 0.6 1.1 Mean 7.9 7.6 pH Max 8.7 8.8 Min 7.3 6.8

Source: Midwest Joint Venture, Denison Mines Ltd. (Operator), ANNUAL ENVIRONMENTAL REPORT (1989)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Mink Arm dewatering quality at final point of control (weekly composite 1989) Parameter Jan Feb Mar Apr May June July Aug Sept Oct TSS (mg/L) 4 0 2 8 0 20 16 8 9 5 <1 19 5 9 33 6 8 7 11 3 10 <1 20 6 14 24 8 5 7 2 9 9 13 6 17 9 7 5 7 3 Conductivity (µS/cm) 34.4 0 2470 46 0 36 48 57 80 48 39.3 59 49 45 44 206 43 67 74 59 46 52 46 49 24 67 43 47 61 45 44 37 58 24 61 73 45 53 26 50 Turbidity (NTU) 5.7 0 0.3 4.7 0 4.1 3.6 2.2 3 1.6 7.9 5 1.5 6.2 4.2 3.2 1.9 0.76 2.5 1.9 5.7 3.6 1.9 2.9 6.9 4.5 2.1 2 2.4 2.1 2.7 5 2.2 7.6 1.6 2.8 2.4 2.1 4.1 2.1 pH 7.20 0.00 2.42 6.45 6.32 6.50 6.68 6.63 6.20 6.26 6.90 6.64 6.16 6.43 5.98 10.65* 6.63 6.76 6.12 6.29 6.70 6.70 6.43 6.64 5.95 6.66 6.74 6.59 6.50 6.24 6.66 6.74 6.59 6.01 6.38 5.94 6.78 6.38 6.50 * suspect error in pH reading. Source: Midwest Joint Venture, Denison Mines Ltd. (Operator), Annual Environmental Report (1989)

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments November Technical Review Response: 2010 The table labeled “Mink Arm dewatering quality at final point of control (weekly composite 1989)” shows that various weekly composite water samples had high levels of acidity. In specific, two samples were below the CWQG for pH of 6.5 – 9 (pH was measured as 2.42 and 6.16); two samples exceeded the guideline in May (pH was measured as 5.98 and 5.95); one sample exceeded the guideline in June (pH was measured as 6.38); one sample exceeded the guideline in July (pH of 5.94); three samples exceeded the guideline in September (pH of 6.20, 6.12 and 6.38); and all the samples from October exceeded the guideline (pH of 6.26, 6.29 and 6.24). There was also one composite sample in March 1989 with high conductivity (2470 μS/cm).

The Proponent indicated on p. 3-13 of the EIS that “water pumped during the latter part of the dewatering activity is expected to be of higher turbidity.” However, from the information provided as part of the Proponent’s response to this IR, it can be expected that pH and conductivity levels may be in exceed the CEQGs throughout the whole life cycle of the facility.

The Proponent should ensure that on-going monitoring of all relevant water quality parameters (e.g. pH, temperature, DO, conductivity, TSS) will be conducted during the dewatering of Mink Arm in order to immediately identify water requiring treatment.

AREVA Response:

The data in the above table is from the Denison Mines Ltd. 1989 Annual Environmental Report. It appears the table contains certain data that can be considered outliers (e.g. conductivity 2,470 μS/cm; pH 0.00; pH 10.65). Despite these apparent outliers, the various weekly composite samples from Mink Arm dewatering indicate a number of pH values were below the CEQG of 6.5. However, data from Mink Arm and other lakes in the Midwest Project area indicate that natural, unimpacted waterbodies in northern Saskatchewan have pH values below the CEQG pH value of 6.5. This is discussed in greater detail in Midwest EIS Section 4.4.1.1 Limnology.

During Mink Arm dewatering (which is anticipated to take up to 48 weeks), a daily water sample will be collected and measured for pH, TSS and conductivity. In the event that TSS increases above 29 mg/L, the Midwest WTP would be utilized and water directed to the S/V TEMS (please see response to CNSC-27).

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 9 (2010) Comment:

NEW P. 3-12, Section 3.2.1.1.2

The Proponent indicated that the rate of dewatering of the Mink Arm will be constrained by the stream flow capacity of Midwest Creek.

The Proponent should also monitor stream flow capacity at Smith Creek, downstream of North McMahon Lake. Water quality monitoring at Midwest Creek, South McMahon Lake and Smith Creek should be conducted periodically during dewatering activities. ARC Response:

A summary of stream flow and stream stage data collected near the Midwest site (Smith Creek (SC-1), Midwest Creek (SC-2), John Pond Creek (SC-3), and Boulder Creek (SC-4)) is presented in Midwest EIS Tables 4.2-1 to 4.2-3. Measurements of stream flow were collected from 1979 to 1994 and thereafter stream flow and stream stage measurements were collected until 2005. Stream flow and stream stage monitoring will recommence at these locations during Mink Arm dewatering activities. In addition, water quality samples will be collected at Midwest Creek, South McMahon Lake and Smith Creek during dewatering.

Stream flow monitoring at Smith Creek is warranted and will be done during dewatering as noted above. However, based on assessment of the drainage area (presented below), AREVA expects that the dewatering of Mink Arm will have little effect on Smith Creek flow or channel stability:

Smith Creek is a much larger channel than Midwest Creek, carrying flows from a drainage area nearly an order of magnitude larger than Midwest Creek. The drainage area for Smith Creek at the North McMahon outlet is 108 km2, while the drainage area for Midwest Creek is 10 km2. Smith Creek drains North McMahon Lake, which in addition to the Midwest Creek inflows, also receives flow from Boulder Creek (which drains the Henday Lake watershed). Estimated mean peak flows for Smith Creek are 2.05 m3/s, compared to 0.19 m3/s for Midwest Creek. Dewatering releases into Midwest Creek would have little influence on Smith Creek. For example, under the mean peak flow scenario, if natural flows in Midwest Creek were increased to the 1:10 year peak flow level (0.3 m3/s), with the additional influx of 0.11 m3/s of dewatering water, that same additional volume would increase flows in Smith Creek from 2.05 m3/s to 2.16 m3/s. Thus, the dewatering of Mink Arm would have little effect on Smith Creek flow or channel stability. Refer to response to comment DFO-2 (submitted as part of February 2010 Addendum).

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 10 (2010) Comment:

NEW P. 3-25, Section 3.2.4.2

The Proponent should describe the containment measures that will be put in place in order to isolate any special waste stockpiles from surface water runoff.

ARC Response:

As detailed in AREVA’s response to CNSC 22(1) - The special waste stockpile area is located at the south end of the Midwest pit and will be naturally graded toward the pit. A site collection runoff area for the special waste stockpile will be positioned adjacent to the perimeter road approximately 75 meters from the pit. The special waste area and site runoff collection area will be hydraulically contained within the footprint of the pit. Ground water flow from this area will be intercepted by the mine sump for treatment at the Midwest WTP.

Document Integration:

Section 3.2.5.3

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 11 (2010) P. 3-53, Section 3.5.1.13

NEW It is indicated that there are two possibilities for management of treated effluent: on-site and off-site treatment. Within the off-site management of treated effluent option, it is indicated that there are two possible locations for water treatment facilities: . water treatment facility at the Midwest site, with subsequent transfer of the combined treated effluent and clean dewatering water for ultimate discharge at S/V TEMS; or, . pumping the combined sources of water via dual containment pipe line to a new and expanded JEB WTP, with treated effluent released to the S/V TEMS. The Proponent should provide water quality information for wastewater treated and released at S/V TEMS. The Proponent should indicate if fish habitat and community studies been conducted to assess the quality of the communities in the environments receiving discharge from S/V TEMS. ARC Response: Please refer to Midwest EIS Section 4.4.1.2.2 Summary of McClean Lake Operational Data for a discussion of S/V TEMS and McClean Lake water quality (and refer to associated references for additional details). Predictions of the potential impacts of treated effluent release on water and sediment quality within S/V TEMS and McClean Lake are presented in Midwest EIS Appendix V Assessment of Operational Effects Related to Waste Water Management.

Detailed Sink Reservoir habitat descriptions are provided in the McClean Lake Operation Status of the Environment Report Assessment Period 2006-2008, Appendix E Sink Reservoir Habitat Description. Vulture Lake and McClean Lake habitats are described in the McClean Lake Technical Information Document, Appendix IV.8 Fish Habitat Data.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments November 2010 Technical Review Response:

Response is insufficient.

EC has reviewed appendix v for the impacts of the treated effluent release to water and sediment quality within S/V TEMS and McClean Lake and find that the data presented is incomplete. Water temperature, pH and hardness information is not available. These core parameters affect the toxicity of many of the constituents monitored. For example, the concentration of unionized ammonia is dependent on total ammonia, water temperature and pH. Also the toxicity of many heavy metals is dependent on water hardness and in some cases pH. Although EC did not have the McClean Lake Operation Status of the Environment report Assessment Period 2006-2008 report or the McClean lake Technical Information Document to review, section 4 of the EIS did indicate a variety of fish species found at the primary exposure water bodies, namely Vulture Lake and McClean Lake. Nevertheless, the relevant details regarding the aquatic habitat quality for the associated water-bodies in the S/V TEMS area should be included in the EIS. EC recommends that additional information on pH, temperature and hardness is required before the data presented in table 4.4-1 of Appendix V, regarding the water quality at the Sink Reservoir, Vulture Lake and McClean Lake, can be evaluated adequately.

Response:

Addressed by CNSC (March 17, 2011 letter Dourado to Ejeckam)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 12 (2010) Comment:

NEW P. 3-56, Section 3.5.1.2

It is indicated that the preferred water management scenario will involve: . on-site treatment of contaminated water using a RO process, followed by a conventional chemical water treatment to treat the resulting brine solution; . potential on-site release of clean water (e.g., clean dewatering well water, clean permeate), within the constraints of local (e.g. Midwest Creek) flows; and . transfer and off-site release of waste water at S/V TEMS.

The Proponent should provide the water quality monitoring protocol that will be followed for water quality monitoring of treated and “clean” water prior to discharge to the receiving environment.

ARC Response:

Figure 3.5.2 provides a schematic of the proposed Midwest Project waste water management plan and identifies the location of the MMER monitoring locations of treated effluent and clean dewatering water monitoring locations. The water quality monitoring protocols applied at these locations will follow the McClean Lake Operation work instructions that are currently in place at the McClean Lake Operation and meet the requirements of the MMER, and the CNSC and Provincial licenses.

Document Integration:

No integration required

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 13 (2010) Comment:

NEW P. 3-58, Section 3.5.1.2.2

It is indicated that the clean dewatering well water, clean RO permeate and treated effluent will be combined in the effluent surge tank prior to being transferred via a pipeline to the Sink Reservoir. It is indicated that the combined clean DWS water, RO permeate and chemical water treatment plant effluent stream is expected to meet CCME water quality guidelines.

The Proponent should provide the sampling protocol for the water in the effluent surge tank. ARC Response:

Please see response to Comment EC-12 (2010). As noted in Figure 3.5.2, the MMER final points of discharge are upstream of the effluent surge tank, therefore monitoring is not required at this location. If during the federal and provincial licensing process monitoring is deem necessary at this location, the sampling protocol would be developed in consultation the respective licensing agencies.

Document Integration:

No integration required

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 14 (2010) Comment:

NEW P. 3-61, Section 3.5.1.4.2

It is indicated that the S/V TEMS consists of the waterbodies Sink Reservoir and Vulture Lake and that pipelines from Sink Reservoir discharge to the east basin of McClean Lake. It is also indicated that during periods of high flow, water can be stored in Collins Creek, downstream of McClean Lake.

The Proponent should provide water quality and habitat quality information for Sink Reservoir, Vulture Lake and McClean Lake. ARC Response:

Note that water can be stored in Sink Reservoir, not in Collins Creek as stated in the comment.

Please refer to Midwest EIS Section 4.4.1.2.2 Summary of McClean Lake Operational Data for a discussion of S/V TEMS and McClean Lake water quality (and refer to associated references for additional details). Predictions of the potential impacts of treated effluent release on water and sediment quality within S/V TEMS and McClean Lake are presented in Midwest EIS Appendix V Assessment of Operational Effects Related to Waste Water Management.

Document Integration:

No integration required.

November 2010 Technical Review Response:

Response is insufficient.

Please refer to comment for EC-11.

Response:

Addressed by CNSC (March 17, 2011 letter Dourado to Ejeckam)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 15 (2010) Comment:

NEW P. 3-67, Section 3.5.2.3

The Proponent indicated that: “Once the Midwest pit is fully developed, the special waste rock will be placed into the mined-out pit, and a till cover will be placed and the pit left to re-flood naturally. This in-pit disposal approach is consistent with what has previously been approved for waste rock management at the McClean Lake Operation. An alternative option was considered where, once the special waste rock is placed into the mined-out pit, the pit would be entirely backfilled using a portion of clean waste rock. The fully backfilled pit option is presented as a backup decommissioning plan should the pit lake water quality evolve unacceptably and should the WTP be unable to treat the pit lake water.”

The Proponent should aim to minimize the potential need for future clean-up. ARC Response:

Acknowledged

Document Integration:

No integration required

November 2010 Technical Review Response:

Response requires clarification.

It is not clear to EC what ARC’s response “acknowledged” actually means. It is EC’s position that the main purpose of an environmental assessment is to select the best option for a proposed project. The alternative means assessment exercise should be robust enough to justify the project selected – the management of special waste rock in the Midwest Pit. In this case, it is not clear what justification exists for not selecting entirely backfilling of the Midwest Pit. In light of the potential for water quality issues as identified in this section, it seems to EC that reflooding the Midwest Pit may not be the best option. Therefore, EC recommends that ARC present clear justification for the option selected with the perspective that to the best of its knowledge based on sound scientific evidence, the option selected will have the least potential for the need of a future clean-up.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments AREVA requested follow-up discussion with EC.

 AREVA does not agree that the main purpose of an EA is to select the best option for a proposed project, the purpose is to develop a project with no significant adverse effects on the environment; sometimes the “best” option is not economically feasible, but doesn’t have significant adverse effects on the environment  Issues with problematic waste are minimized by the implementation of a robust waste rock segregation program  We interpret this comment as suggesting that partial backfilling of the pit with special waste rock then allowing the remainder to flood could result in water quality issues in the future, requiring future clean-up/transfer of the waster rock  However, potential water quality issues are addressed in the EIS, with a contingency to entirely backfill the pit if such a need arises  EIS already contains a robust discussion of the options

Further follow-up requirements were removed.

No further action required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 16 (2010) Comment:

NEW Table 3.5-6 – Conventional Waste Management

The Proponent should provide information on the quality of treated contaminated waste after treatment in the Tailings Management Facility.

ARC Response:

The material placed into the landfill includes any conventional waste material from mining, milling or water treatment that may be chemically or radiologically contaminated (e.g. used sample containers, used disposable coveralls and PPE). To clarify, no treatment is conducted within the Tailings Management Facility (TMF). The chemically or radiologically contaminated waste in the JEB Contaminated Materials Management Area is contained through the hydraulic containment adjacent to the JEB TMF and will be contained in the TMF when the area is decommissioned.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 17 (2010) Comment:

NEW P. 4-1, Section 4.1

The Proponent should have separately indicated the location of the Smith Creek watershed and the Nicholson Creek watershed and should have differentiated each other on Figure 4.1-1.

ARC Response:

The key watersheds have now been clearly labeled in Figure 4.1-1 to clarify.

Document Integration:

The updated Figure 4.1-1 will be added to Section 4 of the Midwest EIS.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 18 (2010) Comment:

NEW P. 4-46, Section 4.4

The Proponent should provide its reasoning for choosing Chironomidae as the only VEC benthic invertebrate. While the species is an important food source for fish, it is a taxa that is fairly tolerant to pollution and therefore not a very good indicator of sediment contamination. Other taxa such as Ephemeroptera, Plecoptera and Trichoptera are the most sensitive to pollution.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

Valued ecosystem components (VECs) are selected through an ongoing stakeholder consultation process; the origins of the VECs resides with the Joint Federal/Provincial Panel Review (Joint Panel 1992; Minatco 1991; COGEMA 1995).

Benthic invertebrate communities are also part of ongoing monitoring and evaluation of potential effects through the approved Benthic Macroinvertebrate and Sediment Quality Monitoring program, as part of the McClean Lake Operation Environmental Monitoring Program (EMP) (AREVA 2008) and the MMER Environment Effects Monitoring (EEM) requirements. Both programs use recommended EEM monitoring protocols (Environment Canada 1998; 2002) and include quantification of Ephemeroptera, Plecoptera and Trichoptera, amongst other types of benthic invertebrates. In doing so, field surveys are conducted at control and exposure stations using aspects of both Before-After-Control-Impact (BACI) and gradient study designs to compare invertebrate community health in areas of varying contaminant exposure. Based on these data, benthic invertebrate indices, including density, richness, Simpson’s diversity index (SDI) and evenness, are tabulated. Results for the benthic surveys are reported in EEM reports for the McClean Lake operation (e.g., CanNorth 2006).

A discussion of the benthic invertebrate community composition is provided in Section 4.4.5 of the Midwest EIS.

References:

CanNorth, 2006. McClean Lake Operation environmental effects monitoring 2005 interpretive report. Final report. Project No.

COGEMA, 1995. Midwest Project Environmental Impact Statement. Main and supporting documents. August 1995.

Environment Canada, 1998. Pulp and paper technical guidance for aquatic environmental effects monitoring. Environment Canada. National EEM Office, Science Policy and Environmental Quality Branch, Ottawa, Ontario.

Environment Canada, 2002. Metal mining guidance document for aquatic environmental effects monitoring. Environment Canada. National EEM Office, Science Policy and Environmental Quality Branch, Ottawa, Ontario.

Joint Panel, 1992. Guidelines for the preparation of Environmental Impact Statements and government information requests for the Cigar Lake and McArthur River projects. Joint Federal/Provincial Panel on Uranium Mining Developments in Northern Saskatchewan.

Minatco (Minatco Limited), 1991. McClean Lake Project Environmental Impact Statement. Main and supporting documents. Prepared by Terrestrial and Aquatic Environmental Managers Ltd. and SENES Consultatnts for Minatco Limited. August 1991.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments November 2010 Technical Review Response

Response is acceptable. The VECs have been determined as part of an earlier stakeholder consultation process but relevant species information will still be collected as part of the EEM project as has been done for the McClean Lake operation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 19 (2010) Comment:

NEW P. 4-47, Section 4.4

The Proponent indicated that in 2006 “additional supplemental fish habitat data were collected to enhance the characterization of fish habitat in Mink Arm and to complete the baseline characterization of the aquatic environment within the local assessment boundary.”

The Proponent should clarify the reason for not collecting additional information for the benthic invertebrate and fish communities during the 2006 field study. ARC Response:

In 2003 and 2004, AREVA initiated a number of environmental investigations aimed at updating and supplementing previous information to provide a comprehensive description of aquatic and terrestrial environments in the vicinity of the Midwest Project (AREVA 2009). These studies included characterization of: hydrology; water and sediment chemistry; vegetation, plankton, benthic invertebrate, fish, amphibian, birds and mammalian communities; and fish and wildlife habitat.

As noted in Section 4.4 of the Midwest EIS, the purpose of the 2006 fish habitat survey was to provide additional fish habitat data to supplement data that had been collected in 2003/2004. Specifically, a survey was conducted in Mink Arm, John Pond and the south bay of North McMahon Lake to measure water depth and substrate type at designated points along transects in each of the water bodies. The objective of the survey was to provide information on habitat in the entire water bodies to provide insight in support of the development of fish habitat compensation plans (FHCPs) for areas that may be directly impacted by mining activities. In addition, in the spring of 2006, searches for northern pike eggs were conducted in John Pond, Mink Arm, South McMahon Lake and North McMahon Lake to identify pike spawning habitat. Through this work, it was possible to enhance the characterization of fish habitat in Mink Arm, while completing baseline characterization of the aquatic environment within the local assessment boundary. The 2006 data complemented the 2003/2004 field survey, which included characterization of benthic invertebrate and fish communities. Results of the 2003/2004 Midwest Baseline data (including the data on benthic invertebrate and fish communities) are summarized in Section 4.4.6.1.1 of the Midwest EIS and are described in detail in AREVA (2009).

Reference:

AREVA, 2009. Midwest Project: Existing Environment – Technical Information Document, Version 01/Revision 00. December 2009.

Document Integration:

References to AREVA (2009) and to Section 4.4.6.1.1 of the Midwest EIS have been added to the text to clarify where the data on the Midwest Project baseline characterization can be found.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments November 2010 Technical Review Response

Responses acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 20 (2010) Comment:

NEW P. 4-47, Section 4.4

The Proponent indicates that the McClean Lake Operation has a well-established environmental monitoring program that evaluates temporal and spatial changes in sediment chemistry, benthic invertebrate communities, fish tissue chemistry and fish population structure relative to pre-development baseline data and reference area conditions.

The Proponent should clarify if this monitoring program includes sampling of Mink Arm. The Proponent should also clarify if the environmental monitoring program included a water quality component. Lastly, since the data provided is for multiple years of sampling, the Proponent should clarify if sampling bias have occurred across the years of sampling and should highlight any differences in the sampling protocol between years.

ARC Response:

The Environmental Monitoring Program (EMP) for the McClean Lake Operation is defined in AREVA’s approved Locations, Frequencies and Parameter document (AREVA 2008). Lists of the water bodies routinely sampled, along with the sample type, parameters measured and sampling frequency are provided in Tables 14 to 17 of the EMP (AREVA 2008) for surface water elevation, surface water quality, sediment chemistry, fish tissue monitoring/fish health and benthic macroinvertebrates/sediment quality, respectively.

Surface water grab samples are taken in Mink Arm (South McMahon Lake), once in June and September each year. This regular monitoring regime was added to the EMP in December 2008.

In general, monitoring data are collected using standard protocols between years, in compliance with AREVA’s Integrated Quality Management System (IQMS) to facilitate temporal trend analysis.

References:

AREVA, 2008. McClean Lake Operation Environment Monitoring Program: Locations, frequencies and parameters (Version 8). December 2008.

Document Integration:

Section 4.4 of the Midwest EIS will be reworded to clarify that the water quality in Mink Arm is routinely monitored, as of 2008, as part of the McClean Lake Operation EMP (AREVA 2008) and the reference to the EMP (COGEMA 2003b) will be updated to AREVA (2008).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 21 (2010) Comment:

NEW P. 4-51, Section 4.4.1.2.1

a) The Proponent indicates that “because no noticeable differences were observed in the parameter concentrations between seasons (AREVA 2009), mean values for the spring and fall data, as well as for each station, were combined, and overall mean values for each water body provided.”

In the future, the Proponent should not pool water quality data collected from each sub-sampling station. b) As opposed to what is indicated on the EIS, Figure 4.4-1 does not display the actual location of each sampling station.

c) The Proponent should clarify the reason for not collecting information on sampling stations M1, M16 and on Smith Creek, downstream of Stomach Lake (see Figure 4.4-1). Also, Midwest Creek does not seem to be displayed on Figure 4.4-1. d) The Proponent should provide more updated water quality information for Reference and Exposure stations of Midwest Mine. ARC Response:

a) In general, it is reasonable to conduct a statistical analysis of data and to pool data where no significant difference is discernable, as was done here. Pooling of data in this way can strengthen the power of the statistical analysis. AREVA continue to evaluate water quality data and analyze as appropriate. b) Acknowledged, due to the large scale of the map Figure 4.4-1 illustrates the general locations of the water sampling stations. Global Positioning System (GPS) coordinates are taken at the sampling stations and were used to produce the figure. The symbols in the figure have been reduced in size to more accurately represent the sampling stations. c) Water quality data for M1 (Mink Arm) and M16 (Too Small Lake) are provided in Table 4.4-3 of the Midwest EIS. Water quality data for Smith Creek (M6) are provided in Table 4.4-3 of the Midwest EIS and data for Stomach Lake (M5) are available in the Midwest Technical Information Document (TID) (AREVA 2009). Midwest Creek is denoted by Station No. ‘M4’ in Figure 4.4-1 (Table 4.4-3 of the Midwest EIS provides both station names and numbers). Due to the small size of Midwest Creek and the broad scale of Figure 4.4-1 (which is meant to depict the locations of the monitoring locations across the McClean Lake Operation study area), it is difficult to label Midwest Creek other than by location number. That said, Figure 3.5-1 clearly labels Midwest Creek. d) AREVA is not proposing to update water quality data in the draft EIS at this time. In addition, there are no new surface water quality data for the majority of locations at the Midwest site. The only exception is Mink Arm: regular sampling in June and September of each year was added to the McClean Lake Operation Environmental Monitoring Program in December 2008.

References:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration:

a) No integration required. b) Sizes of symbols in Figure 4.4-1 have been reduced. c) No integration required. d) No integration required.

November 2010 Technical Review Response:

A) The response is acceptable. The Proponent should ensure that records of the unpooled data will be maintained for future reference. Has the Proponent identified any temporal trends in the unpooled data? B) Has this figure been provided (i.e. Fig. 4.4-1)? C) The proponent should consider including in the EIS the water quality information for Stomach Lake that has been indicated to be part of the Midwest TID. D) The Proponent should consider including the results of the 2008 water quality sampling of Mink Arm into Table 4.4-3

Response:

a) Raw, unpooled data will be maintained for future reference. Temporal trends in the unpooled baseline data have not been examined in the Midwest EIS. b) Figure 4.4-1 will be provided as part of the revised EIS. c) Stomach Lake water quality data has been added to Table 4.4-3. d) Ongoing water quality data collected as part of the McClean Lake Operation license will be provided to the CNSC and Province at the time of licensing.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 22 (2010) Comment:

NEW Table 4.4-3

The Proponent should clarify the reason for not collecting pH measurements at Mallen Lake (WQ1C), Collins Creek (WQ2C) and McClean Lake West Basin (WQ15C).

ARC Response:

Table 4.4-3 represents a compilation of available data that have been historically measured in water bodies in the vicinity the Midwest Project. Measured pH values for some lakes were inadvertently missed and these have now been updated with available data. Some pH values could not be recovered from the original data source.

Document Integration:

Table 4.4-3 will be updated to include missing pH data where available.

November 2010 Technical Review Response

Responses acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 23 (2010) Comment:

NEW P. 4-53, Section 4.4.1.2.2

a) This section should have referred back to a figure where the Reference and Exposure sampling stations would be clearly identified from each other. The body of this section does not clearly identify which stations were part of the Reference Area and which ones were parts of the Exposure Area.

b) The Proponent should have provided a summary of the water quality information being discussed in this section for the McClean Lake Operation.

c) The Proponent should also have provided the uranium concentration for the different sampling stations. ARC Response:

a) A reference to Figure 4.4-1 Location of water quality sampling stations in the local assessment boundary was included in the previous Section 4.4.1.2.1. This figure illustrates the locations of water quality sampling stations and indicates which lakes are exposure water bodies (green star) and which lakes are control water bodies (red square) in the McClean Lake area. Station names ending with an “E” are exposure water bodies and station names ending in “C” are control water bodies, McClean Lake Reference Areas are also identified in Table 4.4-3 of the Midwest EIS. b) References to documents which include all of the discussed data are included in Section 4.4.1.2.2. The reference documents provide data summaries, data interpretation and proposed future work. c) Uranium concentrations for the McClean Lake reference lakes are included in Table 4.4-3. As stated above, all water quality data for the McClean Lake Operation can be found in the referenced documents.

Document Integration:

a) A reference to Figure 4.4-1 will be added to Section 4.4.1.2.2 for clarity. b) No integration required. c) No integration required.

November 2010 Technical Review Response

Responses to A and C are acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 24 (2010) Comment:

NEW Section 4.4.2

a) It is indicated on Table 4.4-4 that the 2003 sediment samples for Boulder Creek and Smith Creek were collected by means of an Ekman sampler. The sediment samples for the rest of the study areas were collected by means of a corer.

In order to ensure consistency and comparison of sediment chemistry results between Reference and Exposure areas, the same sediment sampling devices should be used in future sampling programs.

b) The sediment sampling results for Midwest Project indicate that various potassium, sodium, mercury, selenium and total cyanide) were not measured for all sediment samples.

The Proponent should provide a reason for not measuring these parameters.

c) The Proponent indicated that various metals were elevated at Mink Arm (cobalt, nickel, uranium). The Proponent indicated that possible reasons for these effects are exploration, dewatering and/or test mining activities.

The Proponent should indicate the water treatment protocol to be followed for this water, prior to discharge.

d) Mean uranium concentrations in the sediment of Sink Reservoir and Vulture Lake were higher than reference areas. Since processing of Midwest’s water will take place at S/V, it is likely that there will be further deviations in sediment quality at this location.

The Proponent should indicate which contingency measures will be implemented at this site in order to prevent further increases once Midwest Mine is in operation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response: a) In general, monitoring data are collected using standard protocols between years, in compliance with AREVA’s Integrated Quality Management System (IQMS) to facilitate temporal trend analysis. However, changes to sampling programs are sometimes made in order to improve sampling programs or to comply with regulations. During the 2003 sampling program, lotic areas were sampled with an Ekman dredge and lentic areas were sampled with a corer.

b) As data and information become available, the list of parameters that are analyzed in sediment samples is adjusted to meet the needs of the sampling program. As parameters such as potassium, sodium, mercury and total cyanide are not constituents of potential concern (COPC) nor do they influence other parameters to a great degree, these parameters are not measured in all samples all of the time. In the same way, selenium wasn’t initially measured in sediment samples, but now that selenium is a COPC and is measurable in the laboratory, it is included in the list of analytes measured. As well, laboratory analysis packages and methodologies change and therefore sometimes parameters of less importance are not measured. AREVA ensures that all COPCs, influencing factors and other parameters of interest are measured and a complete data set is developed in order to interpret the results of the sampling programs.

c) To clarify, cobalt, nickel and uranium are elevated in Mink Arm sediment (Table 4.4-7) compared to reference sediment, not in Mink Arm surface water (Table 4.4-3). Mink Arm surface water COPC are below SSWQO and therefore would not require treatment before discharge.

d) AREVA has modeled future sediment quality in the S/V TEMS for the operational, decommissioning and post decommissioning time periods for the McClean Lake Operation. The milling of the Midwest Project ore at the JEB mill, with associated effluent discharge at S/V TEMS, is included in these predictions. The modeled sediment chemistry results for S/V TEMS and downstream are presented in Appendix V, with discussions of the assessment effects in Section 7.

Document Integration: No integration required.

November 2010 Technical Review Response:

a) response is acceptable. EC had stated its opinion with regards to sampling protocol b) response is acceptable c) EC misinterpretation is noted d) The proponent should note that the predicted concentrations of uranium at Sink Reservoir sediment are predicted to have elevated 95th percentile concentrations (1208ug/g) with the potential to extend further downstream into the system. The proponent should aim to minimize the concentration of uranium in the sediment fo this part of the study system.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 25 (2010) Comment:

NEW Section 4.4.4

Figure 4.4-4 does not display the sampling stations for the qualitative macrophyte survey conducted in 2003. The Proponent should provide a figure with this information. ARC Response:

Figure 4.4-4 has been updated to display the sampling stations for the qualitative macrophyte survey that was conducted in 2003.

Document Integration:

Figure 4.4-4 has been replaced with the updated figure in the Midwest EIS.

November 2010 Technical Review Response:

Acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 26 Comment: (2010) Section 4.4.5 NEW a) The Proponent indicates on TB. 4.4-26 that various streams were sampled in the vicinity of Midwest Mine. While various sites were sampled in the 1970’s (Smith Bay inlet, Hatchet Lake; Nicholson Bay inlet, Waterbury Lake; North McMahon Lake inlet; North McMahon Lake outlet; Lake C1 outlet; Lake W1 outlet), only two locations were sampled in 1988, 1994 and 2003 (Boulder Creek and Smith Creek). The Proponent should clarify the reason for not collecting any recent benthic invertebrate samples from the locations sampled in the 1970’s.

b) The Proponent indicates that various different sampling gears were used to collect the benthic invertebrate samples for the 1978 and 2003 surveys. The Proponent should indicate its reasoning for using different sampling gear across stations and across sampling years. The collection of samples by means of different sampling gear limits the comparison of results between sampling stations.

c) The Proponent should clarify if the benthic invertebrates were subsampled. If this was the case, the Proponent should indicate what the sub- sampling precision was.

d) The Proponent should provide information on current speed and bottom substrate for the sampling stations.

e) The Proponent should provide a summary table with the results of benthic invertebrate surveys at the exposure area of the McClean Lake operation.

The Proponent should provide radionuclide information for North and South McMahon Lakes.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

For a detailed discussion on benthic invertebrate sampling conducted at the Midwest Project local study area, please refer to the Midwest Technical Information Document (TID) (specifically, Section 4.7.2.2 Stream Benthic Invertebrate Communities). As noted in the TID, 2003 sampling was based on EEM guidance.

a) As noted in the Midwest TID, during the 1978/79 baseline investigations, benthic invertebrate samples were collected to determine baseline species composition of the benthic fauna in the Midwest Project local study area (Canada Wide Mines Ltd. 1980). In 1988, benthic invertebrate samples were collected in areas near to, or downstream of, the test mine facilities (MJV 1988). Studies were conducted in 1994 (Golder 1995) and 2003 to supplement and update information on benthic invertebrate communities in the Midwest Project local study area. In addition, benthic invertebrate samples were collected for radionuclide analyses in 1994 (Golder 1995). For clarification, in 2003 benthic invertebrates were sampled at three sites along Smith Creek and one site in Boulder Creek.

b) The recommended benthic invertebrate sampling methods change over time as science and regulations evolve. For instance, the 2003 benthic invertebrate community surveys were completed following the recommended methodologies for EEM (Environment Canada 2002). AREVA has recognized in the TID and Midwest EIS Section 4 that it may be difficult to compare data from various years since different methodology or equipment were used. In addition, laboratory methods, taxonomic methods and taxonomic classifications have also changed. The variance in collection and analytical methods needs to be considered when evaluating the data.

c) Three areas were sampled in Smith Creek and one area was sampled in Boulder Creek. Five stations were sampled in each area and one sample was collected per station. Since one Neill cylinder sample was collected per station, no sub-sampling done and therefore precision data is not available.

d) Please see table below:

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Habitat Characteristics of the Stations Sampled in Smith Creek and Boulder Creek at the Midwest Project Area, September 2003. Depth Velocity Waterbody Station Sample Substrate (m) (m/s) Comments Boulder Creek 1 1 ~90% cobble/gravel, 10% sand 0.28 0.23 2 ~90% cobble/gravel, 10% sand 0.28 0.15 ~70% cobble, 25% gravel, 5% 3 sand 0.25 0.22 ~70% cobble, 20% gravel, 10% 4 sand 0.225 0.28 ~70% cobble, 25% gravel, 5% 5 sand 0.215 0.2 Smith Creek 1 1 ~80% cobble/gravel, 20% sand 0.3 0.32 (at Hatchet Lake) 2 ~80% cobble/gravel, 20% sand 0.3 0.3 3 ~80% cobble/gravel, 20% sand 0.325 0.37 4 ~80% cobble/gravel, 20% sand 0.225 0.22 5 ~90% cobble/gravel, 10% sand 0.23 0.32 Smith Creek 2 1 5% boulder, 95% cobble 0.23 0.21 (at North McMahon 2 10% boulder, 90% cobble 0.225 0.04 Velocity taken behind a boulder Lake) 3 5% boulder, 95% cobble 0.35 0.29 4 5% boulder, 95% cobble 0.32 0.27 5 100% cobble 0.31 0.21 Smith Creek 3 1 5% boulder, 95% cobble 0.37 0.58 (at Stomach Lake) 2 5% boulder, 95% cobble 0.325 0.3 3 5% boulder, 95% cobble 0.25 0.77 4 5% boulder, 95% cobble 0.31 0.26 5 5% boulder, 95% cobble 0.3 0.25

e) Please refer to the McClean Lake Operation Status of the Environment report Assessment period 2006-2008 and the McClean Lake Operation Environmental Effects Monitoring 2008 Interpretative Report for the most recent benthic invertebrate community data at McClean Lake exposure areas.

Benthic invertebrates from North McMahon Lake and South McMahon Lake have not been analyzed for metals or radionuclides. Radionuclide results for water, sediment and fish tissue at North and South McMahon lakes are presented in the TID and summarized in Midwest EIS Section 4.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration:

No integration required.

November Technical Review Response: 2010 The Proponent indicates that some of the information requested through EC’s comments has been included in the Midwest Technical Information Document (TID). The Proponent should have ensured that this information would be provided as part of its response or that the document was readily available to the review team. A) Response is acceptable. B) Response is acceptable; however, the Proponent needs to ensure that future benthic invertebrate sampling studies will be consistent in their selection of sampling gear and sampling protocol to ensure that cross-year and cross-sampling station comparisons will be possible. C) Response is acceptable. D) Response is acceptable. E) The Proponent should have ensured that the study reports mentioned in its response would be readily available to the review team.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 27 (2010) Comment:

NEW Section 4.4.6

a) The Proponent indicated that various sampling gears were used for the collection of fish samples. The Proponent should aim to use the same gear across sampling stations in future surveys in order to allow comparison of endpoints between Reference and Exposure sampling stations.

It is indicated on p. 4-84 that “the results from the 2002 survey indicated slimy sculpins captured downstream of the effluent discharge point were generally younger, had smaller gonads, obtained greater lengths and weights, and had larger livers than individuals captured upstream of the treated effluent discharge point. When examined within the context of slimy sculpin captured in reference lakes, however, no significant differences were noted.” The Proponent should clarify this statement since it would be our understanding that fish collected at an “upstream” location could be considered to have been collected at a “reference” location. ARC Response:

To clarify, the statement outlines that the differenced noted in the upstream (reference) versus downstream (exposure) comparisons were not evident in the multiple lake (references) versus downstream (exposure) comparisons. Differences in habitat type are noted.

Document Integration:

No integration required

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 28 (2010) Comment:

NEW Section 4.4.7, Table. 4.4-51

The Proponent should specify the sampling protocol and sampling timing for the fish surveys conducted along the various transects of waterbodies to be potentially crossed by the North and South Road options.

ARC Response:

Details are available in February 2010 Draft Midwest EIS Appendix III, Sub Appendix A.

Document Integration

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 29 (2010) Comment:

NEW Section 6.4.3.1

It is indicated that “Mink Arm dewatering rates may also be managed by diverting Mink Arm surface waters to the S/V TEMS, as opposed to Midwest Creek, once the WTP and effluent transfer pipeline are in place to prevent erosion or scour.”

The Proponent should assess the potential effects downstream of S/V TEMS to result from increased discharge at S/V TEMS. This potential effect should be considered for further analysis.

ARC Response:

The Sink/Vulture Treated Effluent Management System (S/V TEMS) is operated according to the McClean Lake Procedure 718, Sink/Vulture Treated Effluent Management System Operation of the Integrated Quality Management System and the associated work instructions. The S/V TEMS controls the release of effluent to the environment at the outlet of Sink Reservoir, while allowing water treatment plants and dewatering facilities to discharge freely. Management of the S/V TEMS is in place to ensure that discharge from the operation does not further exacerbate any naturally occurring flood condition and potential erosion in Collins Creek. Discharge criteria require that no water be discharged from Sink Reservoir when Collins Creek flows exceed 4.52 m3/s. These specifications will continue to be met if Mink Arm dewatering water is released to the S/V TEMS.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 30 (2010) Comment:

NEW Section 6.4.3.2

The Proponent indicates that water quality differs little between Mink Arm and South McMahon Lake, however, Table 4.4-7 indicates that the water quality of these two waterbodies does differ significantly, especially with respect to uranium sediment concentrations. This potential effect should be further evaluated for potential adverse effects.

ARC Response:

To clarify, the water quality data presented in Table 4.4-3, not Table 4.4-7, illustrates that there is little difference in surface water quality between Mink Arm and South McMahon Lake.

Table 4.4-7 presents sediment quality data. As proposed in Section 3 of the Draft Midwest EIS, prior to mining, Mink Arm will be drained and the sediments will be stockpiled on the surface. The elevated uranium concentration in Mink Arm sediment (16.7 µg/g) is well below the CCME Canadian Soil Quality Guideline (CSQG) for uranium of 300 µg/g, therefore this potential effect does not require further evaluation. Please refer to the response to comment CNSC-22(1) for a discussion of sediment handling.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable. EC misinterpretation is acknowledged

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 31 (2010) Comment:

NEW Page 6-10

The Proponent indicated that “the intake in Mink Arm will be situated in the deepest part of the water body off the bottom and will be designed to prevent fish entrapment and entrainment of suspended particulates.”

The Proponent should provide further information on fish entrapment avoidance structures to be used at the site.

ARC Response:

Under Section 30 of the Fisheries Act, water intakes from Canadian fisheries waters must provide for a fish guard or screen to prevent the passage of fish into the intake. DFO (1995) provides a guideline document that describes a process for estimating the end of pipe screen size to prevent the entrainment of fish in the pipe or impingement of fish against the intake screen. This guidance is included in Appendix II of Sub Appendix B of Appendix III. AREVA will ensure that pump intake screens are appropriately sized to federal and provincial guidelines to prevent entrainment of fish during the dewatering of Mink Arm.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 32 (2010) P. 7-44 and 7-45, Section 7.2.5.5

NEW The Proponent indicates that there is a potential for effects on the benthic invertebrate community as a result of elevated arsenic and nickel levels within Sink Reservoir and Vulture Lake.

The Proponent should have assessed the cumulative/long-term effects on the aquatic ecosystem as a result of these elevated concentrations.

ARC Response:

As outlined in Appendix V, and Section 7.2, Tables 7.2-5 and 7.2-6, the long-term cumulative effects on benthic invertebrate communities in Sink Reservoir and Vulture Lake as a result of exposure to elevated arsenic and nickel levels have been assessed. Details of the water and sediment modelling (Lakeview model) downstream of the treated effluent discharge can be found in Appendix V and Section 7.2. Within Section 7.2, the mean maximum screening index values are presented for benthic invertebrates. This represents the year with the highest value for that COPC and therefore the highest risk to benthic invertebrates. All years are modelled and the risk assessed, but for presentation and interpretative purposes only the highest risk is presented in Section 7.2. The Midwest Project Base Case results are presented in Section 7.2 as the risk associated with the Midwest Project Cumulative Case (i.e., Midwest water treatment plant continuing to run after the Midwest Project is complete) is negligibly different from the Base Case.

Document Integration:

No integration required.

November 2010 Technical Review Response:

Further clarification required.

Section 7.2, Tables 7.2-5 and 7.2-6 are not presented in Appendix V like the Proponent indicated on its response to this comment. This information or the correct reference should be provided.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Response:

Tables 7.2-5 and 7.26- are associated with Section 7.2 of the main document, not Appendix V.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 33 (2010) Comment:

NEW P. 9-9, Section 9.2.7.1

The Proponent indicated that “in Sink Reservoir and Vulture Lake, predicted levels exceeded the water quality objectives for some COCs. Specifically, within the S/V TEMS, the detailed assessment in Section 7 predicted total ammonia, arsenic, cobalt, molybdenum, selenium and uranium concentrations to exceed their respective water quality objectives under the Midwest Project 27/27 base case scenario. This is not surprising, since the S/V TEMS represents a localized area that serves as a mixing zone in the immediate effluent receiving environment.”

The Proponent should be aware that Section 36 of the Fisheries Act does not make a provision for mixing zones, therefore, water quality guidelines must be met at the point of discharge.

ARC Response:

AREVA is aware that mining and milling effluent must meet MMER Schedule 4 authorized limits at the final discharge points. McClean Lake Operation effluent is monitored at the final discharge points and is in compliance with Schedule 4 limits before it is discharged.

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 34 (2010) Comment:

NEW P. 9-10, Section 9.2.7.2

The Proponent indicated that “potential effects to phytoplankton and zooplankton are also predicted based on uranium, nickel and arsenic concentrations. The effects of nickel and uranium are known to vary as a function of water hardness, with higher water hardness reducing the effects of these COCs. Therefore, the elevated hardness of the waters in Sink Reservoir should minimize or ameliorate the potential effects of these COCs on phytoplankton and zooplankton populations at these locations.”

The Proponent should be aware that Section 36 of the Fisheries Act does not make a provision for mixing zones, therefore, water quality guidelines must be met at the point of discharge.

ARC Response:

See response to comment EC-33 (2010).

Document Integration:

No integration required.

November 2010 Technical Review Response:

acceptable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 35 (2010) Comment:

NEW P. 9-13, Section 9.2.7.3

The Proponent indicated that resulting sediment contamination will result in effects to the benthic invertebrate community as evidenced by reduced benthic invertebrate community richness, but no loss in benthic invertebrate abundance.

The Proponent should clarify its reasoning behind its conclusion of no changes to benthic invertebrate abundance.

The Proponent should also note that benthic invertebrate effects may be considered of significance under the Metal Mining Effluent Regulations and as a result, any such effects may have to be mitigated in advance of facility decommissioning.

ARC Response:

To clarify, AREVA predicts a reduction in the number of sensitive benthic invertebrate species within the S/V TEMS during the operational and decommissioning period of the McClean Lake Operation. The hypothesis stated suggests richness may be reduced because of the loss of sensitive species, with a corresponding increase in the abundance of tolerant species. Therefore no change in abundance is predicted. This assessment is based on historical data and professional judgment. Based on CEAA guidance criteria (magnitude, geographic extent, duration, frequency, reversibility, likelihood, ecological considerations) these predicted changes are not considered significant. Please refer to Table 13.0-1 for further details of this evaluation.

The McClean Lake Operation currently conducts benthic invertebrate monitoring as part of its comprehensive environmental monitoring program. As well, the McClean Lake Operation falls under the MMER and as such has conducted EEM studies. To date, two EEM interpretative reports (AREVA 2005, 2008) as well as a proposed investigation of cause study design (AREVA 2009) have been submitted to Environment Canada. Comments on the proposed study design (AREVA 2009) have been received from the technical advisory panel (TAP) and the study design is currently being finalized.

REFERENCES Environment Canada. 2002. Metal Mining Guidance Document for Aquatic Environmental Effects Monitoring. June 2002.

Areva Resources Canada Inc. 2005. McClean Lake Operation Environmental Effects Monitoring 2005 Interpretative Report.

Areva Resources Canada Inc. 2008. McClean Lake Operation Environmental Effects Monitoring 2008 interpretative Report.

Areva Resources Canada Inc. 2009. McClean Lake Operation Proposed Study Design for the McClean Lake Uranium Mine Environmental Effects Monitoring Program 2010 Investigation of Cause.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration:

No integration required.

November 2010 Technical Review Response:

Response is unacceptable.

EC agrees that during the operational and decommissioning period of the McClean Lake Operation, without further mitigation, there will likely be a reduction in the number of sensitive benthic invertebrate species and a corresponding increase in the abundance of tolerant species within the S/V TEMS. The resulting no change in abundance due to the replacement of sensitive species as predicted is however adverse effect on the benthic invertebrate community (loss of species richness). The loss of benthic invertebrate species richness may lead to upper trophic level community changes including fish communities within the S/V TEMS. To EC’s knowledge, Sink Reservoir, Vulture Lake and McClean Lake remain Canadian Fisheries Waters as defined under the Fisheries Act, as such the effluent from McClean Lake operations is regulated under the Metal Mining Effluent Regulations as it enters Sink Reservoir. Furthermore the changes to benthic invertebrate communities and potentially fish communities due to water and sediment quality degradation may extend many decades after decommissioning takes place resulting in a long term adverse effect on the affected aquatic ecosystem. Reversibility seems to be the key criteria that ARC is using to determine significance but this is not appropriate since the original Guidelines to the EIS indicates that all of the criteria for significance should be considered. Additionally reversibility (permanence) has not been singled out in the Guidelines as over-ruling or more important than any of the other significance criteria. Hence, other significance criteria should be given due consideration. In this case, the magnitude has been determined to be High, the Spatial extent includes complete lakes (Sink, Vulture, McClean) which are Canadian Fisheries Waters, Duration has been determined to be medium-term, the temporal extent has been characterized as continuous, likelihood is High and ecological context has been characterized as Level II meaning population and community level changes in the aquatic ecosystem. Therefore, EC recommends strongly that the adverse effects on the aquatic VEC’s in the S/V TEMS should be classified as a significant effect. Also as a significant effect, additional mitigation should be presented for review. Response:

Addressed by CNSC (March 17, 2011 letter Dourado to Ejeckam)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 36 (2010) Comment:

NEW P. 9-22, Section 9.4.7 and Section 9.4.8

The Proponent indicates that the expected adverse effects on the benthic invertebrate and aquatic ecosystem at Sink Reservoir and Vulture Lake are expected to be local and reversible as a result of sediment and surface water quality.

The Proponent should note that these potential effects are of significance and should be further evaluated to determine appropriate mitigation measures.

It is likely that these effects will be intensified as a result of exploration of the Caribou deposit, as opposed to what is indicated on page 10- 10: “the predicted water and sediment quality associated with the Midwest Project cumulative case is indistinguishable from the Midwest Project 27/27 waste water management base case.”

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

To clarify, both the base case and the cumulative case scenarios include the development of the Caribou deposit. The cumulative case however considers the potential future identification and development of deposits within and adjacent to the Midwest site. For the cumulative case, the effects of continued Midwest Project waste water effluent discharge until the end of McClean Lake milling, in the year 2045, are considered. For the base case, flows from the Midwest Project are considered to end when the mining of the Midwest Project is completed.

The predicted effects on benthic invertebrates are for the entire life of the McClean Lake Operation and any effects resulting from the development of the Caribou Project are predicted to be indistinguishable.

The significance of the effects of the Midwest Project on benthic invertebrates was evaluated under the following CEAA guidance criteria:  Magnitude  Geographic extent  Duration  Frequency  Reversibility  Likelihood  Ecological Considerations

This evaluation determined that the potential effects on benthic invertebrates were not significant. For details of this evaluation please refer to Table 13.0-1 of the main document.

Please also see the response to comment EC-35.

Document Integration:

No integration required.

November 2010 Technical Review Response:

Response is unacceptable.

Please see comment to EC-35.

Response:

Addressed by CNSC (March 17, 2011 letter Dourado to Ejeckam)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment EC – 37 (2010) Comment:

NEW Section 7: Assessment of Residual Effects, page 7-34 and 7-35

The proponent states "It is anticipated that construction activities for the Midwest Project would be completed outside of the breeding and migratory period for bird species (i.e. April 15 to July 31). However, if construction activities extend into the breeding and migratory period, appropriate mitigation practices would be implemented to reduce potential effects to breeding and migratory bird species. Mitigation practices may include the clearing of vegetation prior to the spring thaw to avoid disruption of breeding activities For construction activities within the breeding period, a monitoring program would be developed and implemented prior to and during the construction period. For example, a pre-construction bird survey for migrants and early nesting species would be completed to document the use of habitat within the Midwest Project footprint. Nest searches would be completed prior to and during the construction period, and if found, the Proponent would consult with the Canadian Wildlife Service (CWS) as to the appropriate mitigation practices."

EC provides the following comments:

a) For activities that must proceed during the summer Environment Canada recommends that the proponent undertake all efforts to preclear (ie preclear the vegetation outside the migratory bird breeding season) the site before proceeding, as searching for nests in a forested environment is deemed unreliable during the nesting season.

b) For song birds EC recommends a minimum 30m no disturbance setback from active nests.

c) For waterfowl and waterbirds EC recommends a minimum 100m setback from nests.

d) For the SARA listed Rusty Blackbird, Olive Sided flycatcher, and Common Nighthawk EC recommend a 100m no disturbance setbacks from active nests.

e) For Short Eared Owl and Yellow Rail EC recommends minimum 200m setbacks from active nests. ARC Response

Acknowledged

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Integration

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment EC – 1 (October Comment: 2010) The proponent has addressed EC comments with the exception noted below. NEW In our response to AREVA (through CEAA), we would like to be clear on the application of the Metal Mining Effluent Regulations (MMER) during the development of the Midwest uranium mine. It is Environment Canada’s view that the start of the dewatering activity (commencement of water removal from a dam-isolated Mink Arm) constitutes the start of construction of the open pit mine under the MMER. Dewatering would occur over a period of 14 to 46 weeks. This water discharged from the bay would be considered effluent for the purposes of the MMER.

AREVA in its response acknowledged EC’s earlier comment on status of dewatering of Mink Arm (EC-1, 2010). With the release of 50 m3 of effluent in any given day, the MMER would apply to all site effluents.

The MMER effluent limits for Total Suspended Solids (TSS) are 15 mg/L monthly average, 22.5 mg/L in a composite sample, and 30 mg/L in a grab sample. However, in its response CNSC-27 (on page 72), AREVA is proposing a limit for TSS of 29 mg/L as a site-specific release limit for the water being discharged during the dewatering of Mink Arm. This is not acceptable limit for an effluent administered by the MMER. The correct MMER limit would apply.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response

Mink Arm was initially drained in 1988-1989 in order to reduce the potential for inflows to an underground test mine adjacent to Mink Arm. Mink Arm was segregated from the rest of South McMahon Lake with the construction of a dam and was subsequently drained. Mink Arm sediment was not impacted by these test mining activities. Upon completion of test mining, a culvert was installed in the dam to re- establish natural drainage between the two waterbodies. Furthermore, water quality monitoring at Mink Arm indicates similar water chemistry to South McMahon Lake (Tables IV.1-32 and IV.1-33, Midwest TID, 2009).

Environment Canada’s view that the start of the Mink Arm dewatering activity constitutes the start of construction of the open pit does not appear to be supported by the definitions of a “mine”, “new mine”, or a “mine under development” outlined in the MMER. Furthermore, the application of Environment Canada’s interpretation would unnecessarily complicate a relatively straightforward dewatering activity. This is illustrated in Environment Canada’s view that because MMER applies, the dewatering water would need to be treated to ensure pH is maintained between 6 and 9. Natural waters in the vicinity of the Midwest Project, and in South McMahon Lake and Mink Arm, are known to range below 6.0 (Appendix IV.1, Midwest TID, 2009). The requirement to treat such waters, which would be required in Environment Canada’s view, would not serve any environmental protection purpose, but rather result in the unnecessary addition of water treatment reagents to what are essentially natural surface waters.

Applying these definitions to the dewatering activities, MMER would not apply until such point that total suspended solids (TSS) become elevated due to entrained sediment as the water level in Mink Arm is lowered. Bathymetric measurements indicate that over half of Mink Arm is deeper than 4 m and the shoreline slopes steeply to its maximum depth of 6.5 m (Figure 2.1, Midwest EIS). It is anticipated that the majority of Mink Arm dewatering water (potentially up to 75%) will be suitable for direct release with the utilization of best available technologies. These include the use of a floating pipeline with the inlet situated over the deeper area and near the water surface. Once the water level is drawn down, it will become increasingly difficult to prevent the entrainment of sediment, thus elevated TSS concentrations may result. Adjustment of the pumping rate will minimize suspension of sediment to a degree; however, other factors such as wave action may cause sediment suspension in the water column. If water quality monitoring indicates an exceedance of MMER limits, dewatering water will be diverted and treated to reduce TSS prior to release. This volume of water potentially requiring treatment is expected to be minimal compared to the total volume of Mink Arm.

AREVA is committed to a water quality monitoring program during dewatering activities in order to identify any dewatering water that would require treatment. Water quality monitoring during dewatering is proposed as follows:  a daily sample will be obtained from the dewatering discharge line and measured for pH, TSS, and conductivity;  a weekly grab sample will be analysed for Class C and MMER Schedule 4 parameters; and,  calculation of monthly mean concentrations compared to MMER schedule 4 limits.

Due to the short duration and high effluent quality, AREVA may apply for an authorization to discharge this treated effluent to South McMahon Lake or, alternatively, it may be released to the S/V TEMS, an approved MMER discharge point.

References:

Metal Mining Effluent Regulations, November 1, 2010. McClean Lake Operation Environmental Monitoring Program, December 2008 - Version 8. Midwest Project Existing Environment, Technical Information Document, AREVA. 2009.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-1 Comment:

The EIS is often inconsistent, presenting different options and numbers at different points in the document (e.g., use of jet-boring, volumes of rock and uranium to be extracted, locations of ore storage pads, disposition of water from dewatering wells and in-pit sump, mill feed grades, etc.). These inconsistencies, combined with continued switching between the Midwest and McClean Lake project data and expected outcomes, created confusion and made it difficult to review and interpret the results of the report.

RA note: This comment is consistent with those from the CNSC and others. AREVA is to revise the EIS so that it is easier to understand the assessment.

ARC Response:

Aknowledged, the EIS has been revised for consistency and integrates changes to accommodate responses to federal and provincial comments.

Document Integration:

No integration required

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-2 Comment:

Humans are identified as Valued Ecosystem Components (VECs) in Table 4-1-2, however are not included in the list on page 4-3; please indicate the reason for the omission.

ARC Response:

List in Section 4.1.1 has been updated to include humans.

Document Integration:

Humans have been included as a VEC in table in Section 4.1.1.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-3 Comment:

The document provides limited justification for the changes to the previously approved project which have triggered this revised EA. Health Canada suggests that a side-by-side comparison of potential impacts to workers and local residents, similar to, or included as part of, the information provided in Table 1.2-1 be included for the various mining methods.

The current EA evaluates only advantages of open-pit mining as compared to conventional underground mining. Radiation protection was considered one of advantages of jet-boring in the previous EA submission. The EA does not consider the increase in radiation doses for certain workers with open-pit methods as compared to the previously approved jet-bore technology, nor other considerations like greater fugitive dust emissions, associated with open pit mining.

Nonetheless, in sub-section 3.2.2.3, Mining Alternatives (page 3-20), the proponent indicates jet-bore technology may be used in conjunction with open pit mining at Midwest. A rationale should be provided as to why the current EA does not evaluate the effects of combined open-pit and jet-boring methods as they relate to human health.

The waste rock management and pit decommissioning plans indicate future consideration of Midwest pit as a tailings management facility (TMF) (see sub-section 2.3, Appendix IX); however, this scenario is not considered in the EIS. HC suggests that this scenario be included in the EIS and be assessed for potential human health impacts.

RA Note: Information has been provided in terms of the project that was proposed, alternative means of carrying out the project and potential or hypothetical future projects that may occur at Midwest. The proposed project and its alternatives should be described and a rational for selecting the preferred option be presented. Any future projects or likely future evolution of the proposed project should be considered in the assessment of cumulative effects. It is not required to explain how the Midwest proposal evolved historically.

ARC Response:

Section 3.2.2.2 of the Midwest EIS main document presents the rationale explaining why the open pit mining method has been chosen over the alternatives.  The open pit mining method is a proven and reliable mining method;  a number of pits have been successfully mined (JEB, Sue C, A, E and B), at the nearby McClean Lake Operation;  the mineralization is relatively close to surface so that open pit mining methods can be economically feasible under current market conditions;  potential radiation exposure to workers can be minimized due to natural ventilation and increased distances from ore using the open pit mining method versus conventional underground methods;  water inflows are more easily controlled and can be readily isolated to prevent radon exposure to workers; and  surface mining is more advantageous than underground mining in terms of recovery, grade control, flexibility of operation, safety, and the general working environment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-3 (continued) The details of the atmospheric modelling of dust emissions are presented in Appendix XIV of the Midwest EIS. Please see the responses to comments CNSC-15 and MH-3 for the discussion on fugitive dust modelling results for the Midwest Project.

The Midwest assessment does look at exposures to workers in an open pit mining scenario. The EIS presents data from the McClean Lake Operation where AREVA has mined a number of ore bodies using open pit mining methods. Open pit mining is a proven and reliable mining method, and AREVA has substantial experience with this type of mining. In open pit mining, water inflows are more easily controlled than in underground mining and can be readily isolated to prevent radon exposure. Natural ventilation also reduces radiation exposure. Predicted radiation doses to workers during the mining of the Midwest pit are presented in Section 8.2.5.4 of the Midwest EIS. Predicted radiation exposures for mill and mine workers are presented in Tables 8.2-2 through 8.2-4.

As stated in the above comment and in the Midwest EIS, Section 3. 2.2.3, AREVA is currently carrying out a Mining Equipment Development (MED) program to develop and evaluate an underground jet-boring technology to be deployed from surface to extract ore from small ore bodies that cannot be economically recovered using conventional open pit and underground methods. MED jet-boring technology would actually provide more protection to workers from radiation than doses from open pit mining. The MED program is still in its development and a decision on whether or not it is a viable mining method will be made in the future. If the MED Program is deemed successful, it may be deployed at the bottom of the Midwest pit to extract ore. Mining using MED technology would decrease the exposure of workers to Constituents of Potential Concern (COPCs) such as radon and radiation as this technology allows access to ore without exposing it to the surface/atmosphere. Assessing health risks to workers through opening pit mining only, assesses the most conservative case. Assessing the use of both open pit and the MED jet-boring methodologies would be a less conservative estimate and therefore this scenario was not considered in the assessment. The MED project at the McClean Lake Operation is ongoing and has an associated radiation protection program including procedure MED 740 Radiation Protection Plan and work instruction MED 740-01 Dose Control for MED. This radiation protection program will be transferred to any other projects where MED technology/practices are put into use.

As stated in the project description, Section 3.5.2.3 Waste rock disposal plan, the Midwest pit will be utilized for special waste storage. Special waste will be placed in the bottom of the pit at the end of pit development, a till cover will be placed and the pit will be left to re-flood naturally. Tailings produced from the milling of Midwest ore will be placed in the JEB TMF at the McClean Lake Operation. The JEB TMF, as described in the project description, has been assessed and is a licensed facility. The Midwest pit is not being considered for use as a future TMF and therefore this assessment is not presented. If it is to be considered as a TMF in the future, another EA will be required.

Document Integration:

No integration required.

Technical Review Response: The proponent’s response indicates that the open pit and the MED jet boring methodologies were not assessed together as it is unknown the results would be less conservative and it is unknown if jet boring is viable. The response does not indicate the probability of utilizing 2010 underground mining (UGM) at the pit bottom should jet boring not be deemed viable. If UGM is a possible method for the pit bottom, it should be reflected in human exposure assessments.

The response also indicates that that the pit will be allowed to re-flood naturally after filling with “special wastes”. HC advises that the environmental monitoring programs be designed to consider the potential of the entry of food fish into the pit (via flooding, breaches, man or AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment bird). Should an unintended stocking of fish occur in the pit, an assessment of fish for food safety and the potential for consumption by humans is recommended.

No further response from AREVA is required, as the 2007 Midwest EIS does not involve underground mining

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-4 Comment:

The cumulative effects evaluated in section 10.1 include only projects related to AREVA operations at McClean Lake site, despite active involvement by AREVA’s partners Cameco and Denison Mines in the immediate vicinity (along with other uranium exploration activities at Henday Lake).

A cumulative effects assessment is needed to account for all projects currently under exploration including Millennium, Dawn Lake, Collins Creek, Virgin River and Henday Lake sites. Currently, only cumulative effects on waste streams reporting to McClean Lake are included; effects related to anticipated use of the Midwest pit, haul road or other project components in support of other projects should also be considered. Please include an assessment of cumulative effects for the above projects combined with the proposed project for human health exposures.

RA Note: Cumulative effects are defined as the effects on the environment which results from effects of a project when combined with those of other past, existing and imminent projects and activities. The effects of other projects must therefore overlap in both time and space with effects of the Midwest project. For an assessment of cumulative effects, AREVA is required to establish the foot print of predicted environmental effects from the Midwest project and consider those projects that may also pose environmental effects in the same foot print as those posed by the Midwest project. Projects with environmental effects outside of this footprint should not be considered in the assessment of cumulative effects.

ARC Response:

In Section 10 Cumulative Effects, AREVA has outlined the projects that may or will overlap in time and space with the effects of the Midwest Project. These projects include; past, current, planned and imminent activities at the McClean Lake Operation including: the mining and milling of the JEB, Sue C, A, E and B deposits, mining and milling of the McClean underground deposit and the Caribou deposit, milling, tailings and waste rock management associated with the Cigar Lake Project. These activities are expected to occur during the operational life of the McClean Lake Operation and within the Midwest Project Local Assessment Boundary. These projects are existing, on-going, or imminent. Possible future projects such as Millennium, Dawn Lake, Collins Creek, Virgin River and Henday Lake are not considered as these activities are not considered imminent. Therefore, these activities were not included in the cumulative effects assessment for the Midwest Project.

Document Integration:

No integration required.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-5 Comment:

The proponent indicates that during the public consultation, human health concerns were not raised substantively (EIS pg.8-2). However, it is noted that concerns were raised about water quality in Mink Arm, leaching of contaminants from the waste rock and management of the special waste rock (see EIS Table 5.4.2), all issues that may have implications for human health. These concerns should be noted appropriately as a result of public consultation.

ARC Response:

During public consultation activities, AREVA responded to questions raised by the public. Table 5.4-2 summarizes all comments that were raised during the public consultation. The above concern was not raised during public consultation: therefore, AREVA did not address this in Table 5.4-2. Information on the human health risk assessment (Appendix VII and Section 8), completed by AREVA was provided for public review and comment.

Document Integration:

No integration required.

Technical Review Response:

Table 5.4-2 summarizes the substantive concerns, including those regarding human health, arising from Areva’s public consultation activities. These concerns include the potential for “leaching of contaminants from waste rock”, the lack of “discussion on the human health 2010 impact with regard to gas emissions, vehicle use, air quality”, fate of the lake and “potential impact to the surrounding communities”. HC advises that the proponent revise the Section 8 – Effects of the Project on Human Health (pps. 8-1 to 8-2) to recognize the substantive concerns raised by the public and reference points of discussion/mitigation in the EIS as appropriate.

ARC Response:

June 2010 Acknowledged; AREVA will update Section 8 as requested to note the human health concerns raised during public consultation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Document Integration:

Add the following text to Section 8.1:

Human health concerns raised during public consultation included potential for leaching from waste rock, human health impact with respect to gas emissions, vehicle use and air quality. Also general concerns were raised about potential impacts to the surrounding communities in the long-term. The two major short-term effects of the project are liquid effluent release and atmospheric emissions. The concerns raised on human health during public consultation are addressed in the Midwest EIS. Human health risk assessment involves four steps, namely: receptor identification, exposure characterization, effects characterization, and risk characterization (details in Appendix VII and summary

provided in Section 8). Plausible scenarios of people working and/or living nearby are represented by twelve human receptors

The main text of Section 8 provides summary results for the Wollaston Lake residents (adult, child and toddler) as well as for the Wollaston Lake Trapper (adult and child) who are present on Collins Creek for 25% of their time and the other 75% of their time at Wollaston Lake. The results for the Wollaston Lake Lodge Operator (adult and child), the Rabbit Lake Camp worker, the JEB Camp worker and the Points North Worker are presented in Appendix VII. As seen in these sections, the incremental effects due to the Midwest Project and the McClean Lake Operation generally account for <0.1% of exposure to these receptors.

Technical Review Respons: October 2010 Response is Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-6 Comment:

The sandstone in the area of the Midwest pit is noted to be fractured and faulted and to have areas of enhanced permeability (see sub- section 4.2.2.1, page 4-14) that may increase the likelihood of groundwater contamination under the current proposal or if Midwest is put into use as a TMF in the future. The current design for the Midwest pit does not include a base drain in combination with a natural surround (as is currently in use for the JEB TMF at McClean Lake) or a pervious surround (as is in use at the Rabbit Lake TMF). Please provide a consideration of the potential for groundwater contamination due to this type of sandstone and discuss any related human health implications for groundwater use under all likely Midwest pit use scenarios.

ARC Response:

The Midwest pit was assessed as a special waste disposal facility, as described in the project description. It is has not been proposed to be used as a tailings management facility, and therefore the pit does not have a drain nor a pervious surround. The waste will be placed at the bottom of the pit, a cap will be placed on the waste and the pit will be allowed to flood. If in the future, the Midwest pit is considered for any other purpose, an EA will be required and this option would be assessed.

Post-decommissioning effects associated with the disposal of waste rock at the Midwest site derive from the release of soluble constituents from the waste rock to the groundwater system and subsequent transport to surface water receptors. The key components that control the release and transport of constituents include the chemical and physical properties of the waste rock and the groundwater flow regime in the Midwest area.

Appendix IX, Waste Rock Characterization, examines the above key components and provides estimates of post-decommissioning effects to surface water receptors resulting mainly from in-pit disposal of problematic waste rock. Summaries of the data, methods, and calculations used to assess the long-term environmental effects of waste rock management at the Midwest site are provided in Appendix XI. This assessment includes characterization of waste rock geochemical properties (i.e., source term), identifying pathways through which constituents from the waste rock may migrate, mainly groundwater flow, and determining constituent loadings to the receiving surface water bodies. The predicted long-term surface water quality in the receiving surface water bodies (Collins Creek, South McMahon Lake, and Shallow Lake) is estimated to be below surface water quality objectives; therefore no human health assessment is required.

Part of the proposed decommissioning of the Midwest Project involves allowing the Midwest pit to re-flood naturally. This option is assessed in Appendix IX, Sections 3 and 4. Also, see response to Comment CNSC-4 which outlines an alternative to completely back fill Midwest pit.

Document Integration:

No integration required.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-7 Comment:

There is no estimate of the time required to re-flood the pit to a depth of 143 m and these data should be provided. If the pit is not re- flooded completely prior to decommissioning, it may constitute a worker safety hazard as there may be instability of exposed pit walls, falling debris and/or steep slopes. In addition, the waste-rock piles adjacent to the pit could pose a safety hazard to the workers during the operation of the mine. Strategies to address these potential physical hazards should be discussed.

ARC Response:

Integral to the development of an open pit is a monitoring regime for continually evaluating the stability of pit walls and slopes. In

conjunction with monitoring, strategies to protect workers from falling debris, such as blocking, berming, and traffic control, are in place

throughout the life-cycle of the operation. Worker safety requirements for open pit mining are codified within the Saskatchewan Mines

Regulations to which supervisors are trained, tested, and certified. These hazards are addressed within the McClean Lake Operation

OHSAS 18001 certified safety management system and programs are in place to mitigate risk. Generally, the management of occupational

hazards is addressed during the licensing process and oversite is provided by both the CNSC and the Mine Safety Unit of the

Saskatchewan Ministry of Advanced Education, Employment and Labour.

Document Integration:

No integration required.

Technical Review Response: 2010

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-8 Comment:

Subsection 8.4.1.1 of the EIS indicates that Emergency Response Plans are in place to respond to accidents on and off the project site. No information is provided regarding the proposed methods to undertake an emergency response and clean up on site, or on route to the final destination. It is unclear as to how the potential release of concentrate (i.e. accidents, leaks, spills, etc) on the ore haulage road and on provincial roads would be handled and reported in order to minimize human exposure to radiation and/or other contaminants.

RA Note: The project is required to address this concern in terms of ore haulage on the dedicated haul road. Transportation from the JEB mill is currently is currently authorized and not a component of this EA.

ARC Response:

An overview of the response to spills during ore haulage is provided in Section 3.7, Malfunctions and Accidents. Detailed spill response and reporting procedures are established, tested, and evaluated routinely by the CNSC and Saskatchewan Environment. An “Emergency Response Assistance Plan” is filed with Transport Canada to address off-site emergencies involving the transportation of radioactive materials.

Document Integration:

No integration required.

Technical Review Response:

It is noted in the proponent’s response that detailed spill and accident response and reporting procedures are not provided in the EIS but have/will be provided to CNSC, Saskatchewan Environment and to some extent Transport Canada. Thus, HC is unable to provide a review 2010 of this component.

Please notify HC should review of any of the proponent’s existing and proposed detailed plans for health or safety considerations (within our areas of expertise) be desired. ARC Response:

Acknowledged

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

Note To RA:The proponent states that a detailed spill response and reporting procedures are established, tested, and evaluated routinely by the CNSC and Saskatchewan Environment. An “Emergency Response Assistance Plan” is filed with Transport Canada to address off- October 2010 site emergencies involving the transportation of radioactive materials. Potential accidents and spills involving radiation may result in some dose to the workers involved, and possibly to the general public. For a comprehensive assessment of potential risk due to accidents and spills, HC advises that information regarding these doses be estimated and provided. Please advise if HC’s review of the aforementioned plan will be requested when the document becomes available.

Note: AREVA has been instructed by CEAA to respond Response – provided by CNSC – UMMD

The Emergency Response Plan for activities on the project site will fall under CNSC licensing and approval. A detailed and extensive emergency response program with supplementary procedures will be submitted and reviewed by CNSC emergency response specialist during the licensing process of the project. This will include but is not limited to HC comments regarding the proposed methods to undertake an emergency response and clean up on site.

Emergency response on provincial roads falls under the requirements of Transport Canada and the Transportation of Dangerous Goods Act, 1992. TC will have to approve an ERAP (Emergency Response Plan Assistance Plan) are required under the Act with provisions to ensure the protection of the public and environment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-9 Comment:

Two options for a dedicated haul road of approximately 17 km have been presented in Section 8.4, with the north option running through the selected Treaty Land Entitlement lands of the Peter Ballantyne Cree Nation. While security gates are proposed for the Midwest and McClean Lake route end points, additional mitigation may be required if trappers, hunters, fishers, gatherers or other individuals can gain access at points along the route using off road vehicles, watercraft, or on foot. Public safety may be a concern where the new road may increase the potential for resource user/project interactions (e.g. hunting). Similarly, an increase in the harvest and consumption of country foods along this route may not have been fully taken into in the account in the current EIS if the control of access is less effective than planned.

ARC Response:

AREVA is proposing to expand the surface lease to include the haul road, therefore access to the proposed haul road will be located within the site security gates both at the McClean Lake site and the Midwest site. It is expected that it will not be designated a public road. Access to the road by members of the public will require prior permission, as is the current practice for the existing site access road at McClean Lake Operation. Access to the road from any other point along it will be difficult due to the terrain. Trails and other transport corridors leading to the proposed haul road will be restricted using a variety of physical barriers suitable to the situation (rock pile, berm, etc.) as is current practice at the McClean Lake Operation. Although the road will cross some navigable waters, the streams and lakes adjacent to the proposed road are not known to be travelled. Due to these haul road restrictions, the potential for resource user/project interactions is anticipated to be negligible. Additional mitigation will be considered as required.

Note that the TLE selection previously made by PBCN is no longer in effect.

Document Integration:

No integration required.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-10 Comment:

Information is lacking on whether the 600+ exploration bore holes will remain on site after development of the project. If so, they may represent a physical hazard.

ARC Response:

Development of the Midwest pit will eliminate the exploration bore holes. Therefore, they will not remain to represent a physical hazard.

Document Integration:

No integration is required

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-11 Comment:

It is unclear if the landfill for domestic waste (see sub-section 3,5,5,1, page 3-78) will be fenced to keep dangerous animals out, (e.g. wolves, bears). The increased presence of food–seeking dangerous animals on the project site may present a safety risk to the workers. Please indicate if the landfill will be fenced, and if not, provide a rationale and other mitigative measures to minimize human contact with wildlife.

ARC Response:

The domestic landfill is not fenced; However, the McClean Lake Operation uses an onsite incinerator for all kitchen wastes significantly reducing the potential for wildlife attraction to the landfill area. To date, wildlife interactions connected with the McClean Lake landfill have not been problematic. Also, please see response to Comment CNSC-26.

Document Integration:

No integration is required

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-12 Comment:

In the preferred site design (see Figure 3.2-6)(Figure 3.2-8 in edited EIS), mined ore is to be stored on an 8 ha lined ore transfer pad on top of the lower lift of clean waste rock stockpile A and surrounded by a runoff ditch (sub-section 3.2.4.3). This liner is noted to be impervious, though no description of its construction is given. The storage of ore on top of the waste rock and the potential for contamination of both liner and waste rock does not appear to be considered in Appendix IX, Waste Rock Management. Additionally, the document appears to refer to an alternate site layout option (sub-section 3.2.2.2.3) where ore is stored on land in between the two waste rock stockpiles. The proponent should ensure that proper procedures are in place for handling potentially contaminated waste rock and decommissioning of the liner to mitigate any potential human health effects related to wind-blown respirable contamination and impacts to current or future drinking water sources.

ARC Response:

The detailed design of the liner will be provided during the licensing phase and will be consistent with ore storage area liners currently approved and in service at the McClean Lake site. Workplace monitoring for respirable contamination is a standard practice conducted during the mining phase, and would continue through the decommissioning phase, as warranted. The locations and frequency of workplace monitoring are defined within Procedure 740 – Routine Radiological Monitoring Schedule and administrative and action levels are established within the Radiation Protection - Code of Practice. The decommissioning of a uranium mine site would be subject to separate cycle of environmental assessment and licensing.

Document Integration:

No integration required.

Technical Review Response:

It is noted in the proponent’s response that details regarding the monitoring of workplace related respirable contaminants are defined within Procedure 740 – Routine Radiological Monitoring Schedule and administrative and action levels are established within the Radiation Protection - Code of Practice. As specific information in this regard has not been provided as part of the revised EIS, HC is unable to 2010 provide further review.

Please notify HC should review (within our areas of expertise) of any of the proponent’s proposed health or safety monitoring procedures be desired.

ARC Response:

Acknoweledged

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

Note to RA: The location and storage methods used for mined ore could potentially affect worker dose (and therefore human health) on the Midwest site.

October 2010 It is noted in the proponent’s response that details regarding the monitoring of workplace related respirable contaminants are defined within Procedure 740 – Routine Radiological Monitoring Schedule and administrative and action levels are established within the Radiation Protection - Code of Practice. As specific information in this regard has not been provided as part of the revised EIS, HC was unable to provide further review. Please advise if HC’s review of the aforementioned plans will be requested when available.

Note: AREVA has been instructed by CEAA to respond Response – Provided by CNSC – UMMD

“This liner is noted to be impervious, though no description of its construction is given” As part of the site licensing phase the ARC will provide the detailed design of the liner for CNSC staff approval prior to any work being completed. Potential contamination of the liner and waste rock will considered in the decommission plan proposed by ARC during the licensing phase in addition to a separate license required for decommission of the proposed site.

As part of the licensing phase of the project, ARC will provide a Radiation Protection Program and an Environment Monitoring Program with supplementary procedures that will need to satisfy CNSC staff prior to receiving a license.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-13 Comment:

Sub-section 3.1.3, notes that the McClean Lake area waste management (upon which the Midwest waste management plan is based) includes contaminated reusable materials, though no description of decontamination procedures is included in sub-section 3.5.5. While Health Canada encourages the reuse of materials as a principal of sustainable development, care must be taken to prevent the human exposures to contaminated material used on or off the project site. The EIS should indicate the methods of handling, storage, decontamination and disposal of reusable materials proposed to mitigate human exposures to radionuclides etc.

ARC Response:

Section 3.5.5 notes that the waste management program is documented within the overall quality management program. The control of radioactive contamination is an element within the radiation protection program. Procedures are in place for handling, storage, decontamination, segregation, disposal reuse, and recycling of materials as well as the associated measurement and monitoring of radionuclides. The procedures exist within the quality management system and are reviewed and approved within the overall site licensing framework. AREVA follows internationally accepted standards for the clearance of materials for off-site release.

Document Integration:

No integration required.

Technical Review Response:

It is noted in the proponent’s response that details regarding the handling, reuse or disposal of contaminated materials is documented in the waste management program of the overall quality management program. As specific information in this regard has not been provided as 2010 part of the EIS, HC is unable to provide further review.

Please notify HC should review of the proponent’s existing/proposed detailed plans for contaminated waste management for health or safety considerations be desired. ARC Response:

Acknowledged

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

Note to RA. It is noted in the proponent’s response that details regarding the handling, reuse or disposal of contaminated materials is documented in the Waste Management Program of the overall Quality Management Program. As specific information in this regard has not been provided as part of the EIS, HC is unable to provide further review. October 2010 The handling, reuse, and disposal of radioactive contaminated materials could potentially affect the dose to workers and the general public. HC advises that this information be provided as part of a comprehensive review. Please indicate if HC’s review of the aforementioned plan(s) will be requested when available.

Note: AREVA has been instructed by CEAA to respond The EIS should indicate the methods of handling, storage, decontamination and disposal of reusable materials proposed to mitigate human exposures to radionuclides etc.”

Again, the proponent will be required to provide a detailed waste management program during the licensing phase of the project to CNSC staff. Consideration for human and environmental exposure to radionuclides and hazardous contaminates will be monitored through the RPP and EMP which also falls under the overall quality management system.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-14 Comment:

In Sub-section 3.2, the description of the ore is vague and imprecise. Further details about the ore body, such as the presence of other contaminants, and particularly those with acid-generating potential, should be provided. This information is needed to ensure the proper management of tailings and other wastes, and to identify human health risks associated with ore characteristics.

The total estimates of uranium (U) production are not presented consistently (14 113 tonnes U; see sub-section 8.2.5.3, pages 8-23 to 8- 24), which does not correspond to either the estimate of 14 400 tonnes U provided in the 2005 proposal (see par. 29, Tracking Report, Appendix II) or the current estimate of 16 500 tonnes U (see sub-section 3.2.2.2.3, page 3-17). As the projected radiation dose calculations related to Midwest mining activities are scaled based on U production estimates, the proponent should confirm that the correct U production estimates have been used to calculate radiation exposures throughout the report as this could affect the final results for human health risks.

Radiation doses to ecological receptors were calculated based on an average mill feed grade of 1.7% (see page 6, sub-section 2.2, Appendix VI). These include fish and terrestrial receptors consumed by humans (moose and caribou). However, when calculating exposures to mill workers an average feed grade of 6.9% was assumed (see step 4, sub-section 8.2.5.1). Please clarify why different values of average mill feed grade were used in the calculations for ecological vs. human receptors and confirm that the calculated exposures to humans related to consumption of country foods (i.e. ecological receptors) are correct.

ARC Response:

A more detailed description of the Midwest ore deposit mineralization is provided with the addition of Appendix XIII. The ore characteristics are not anticipated to affect the management of the tailings, as the tailings preparation circuit has been proven to be robust in the consistent manufacture of key tailings characteristics from a variety of ore types irrespective of ore source (see responses to Comment NRCan-16 and NRCan-33). A detailed description of AREVA’s tailings management approach can be found in Section 3.5.3 of the Midwest EIS. Similarly, the JEB WTP process has been proven to be robust in producing treated effluent of consistent quality during the milling of a variety of ore types. Therefore, at the McClean Lake Operation, treated effluent quality is not dependent on the ore characteristics.

The estimates of U production are subject to changing market conditions, including the U price. At the time of the original EIS submission (August 2007), the high market price of U resulted in project economics supporting the mining and milling of lower grades of ore, thus increasing the estimated overall production of U to 16500 tonnes.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-14 The estimation of worker doses during mining is based on the experience acquired during the mining of 5 open pits at the McClean Lake (continued) operation. AREVA has used measures of dose per unit of production to calculate the anticipated doses for workers during mining of the Midwest open pit. This is a very conservative assumption because the stripping ratio for Midwest, i.e. the ratio of the amount of barren material removed to the amount of mineralized material, is approximately twice the ratio at Sue open pits. This has made the collective dose calculations conservative, perhaps by a factor of 2, in the Midwest assessment. The forecasted ore production level has increased by approximately 15% since the completion of the radiation dose assessment. While one might have expected a similar increase in the collective effective dose, the opposite is anticipated, since the stripping ratio has also increased in order to recover this ore. An increase in the stripping ratio will increase the proportion of worker time spent mining barren, non-radioactive rock. AREVA believes that the dose assessment is adequately conservative to evaluate human health risks and that the change in the production level is not material to the assessment.

Appendix VI presents the integrated risk assessment and includes pathways modelling analysis of ecological receptors to emissions from the Midwest Project and McClean Lake Operation. Atmospheric and aquatic emissions from the Midwest Project and the McClean Lake Operation were used to predict doses and intakes to human receptors in the local assessment boundary. For reference, Appendix VI Integrated Risk Assessment and Appendix VII Human Health Risk Assessment have been re-organized and the details of the human health risk assessment (HHRA) are now consolidated in Appendix VII. Radiation doses to ecological receptors and human receptors in the area were calculated based on an average mill feed grade of 1.7% and this value was based on an estimated U production of 16 500 tonnes U. Radiation exposure from the Midwest Project and the McClean Lake Operations to VECs in the surrounding area is based on air emissions, which would result from the mining of the ore that is fed to the mill and is estimated to have a total U production of 16 500 tonnes U at a mill feed of about 1.7%. Radiation dose to mill workers is based on the mill feed within the mill. During milling, Midwest ore will be blended with higher grade Cigar Lake ore, which will be received in slurry form; therefore, the mill feed within the mill will be 6.9%, which is much higher than what is being input from the Midwest Project alone. The dose assessment for the mill workers is insensitive to the change in mine production level. The drivers for the mill worker dose assessment are mill production level and feed grade. Radiation doses to mill workers were estimated based on the higher blended mill feed of 6.9%. Radiation doses to ecological and human receptors (i.e.: Wollaston Lake Resident, Wollaston Lake Trapper) in the surrounding area that are considered in the pathways analysis, are calculated using a mill feed of 1.7%, based on the estimated Midwest Project uranium production alone.

Document Integration:

Appendix VI and VII re-organized and additional information provided. Appendix XIII Midwest Deposit Mineralization added to the EIS documentation.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-15 Comment:

Section 4 describes existing environmental conditions (baseline data), including radiological parameters. On page 4-52, it states that there are no Canadian Water Quality Guidelines (CWQG) or Saskatchewan Surface Water Quality Objectives (SSWQO) for these radionuclides. Existing federal CWQGs do have Maximum Allowable Concentrations (MACs) for most of the radiological parameters. Please include the MACs for the radionuclides for comparisons to data as part of the analysis.

ARC Response:

The CWQGs MACs have been included in Table 4.4-3. All water quality measurements of radionuclides are well below the MACs for each radionuclide. Section 4.4.1.2.1 has been modified to include this comparison.

Document Integration:

CWQG MACs have been included in Table 4.4-3. The text in Section 4.4.1.2.1 has been modified as discussed in the above response.

2010 Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-16 Comment:

In Section 4.3.2.2 Radon: The proponent has measured radon concentration around the mining sites, and other locations where the uranium ore will be stored and processed (Table 4.3-7). These measurements are essentially outdoor background measurements; most of these measurements are well below the typical indoor background range radon levels in Canada ranging from of 30 to 100 Bq/m3 (Section 4.3.2.1). When the actual uranium mining starts, the radon levels are likely to be much higher in the open-pit mine and near the stock-piled ore (Figure 7.1-1). Hence, Health Canada recommends that the proponent is advised to continue monitoring during the actual mining operations to ensure that the workers and the nearby residents are not exposed to undue high levels of radon (Table 4.3-8).

On Page 4-43, the proponent mentioned the existing radon guidelines of 800 Bq/m3; these guidelines have been revised as of June 2007 and now it is 200 Bq/m3 for home setting and high occupancy dwellings. This correction should be made.

ARC Response:

Dust and radon monitoring will be undertaken during mining to ensure workers and nearby residents are not exposed to undue high levels of radon.

The revised indoor guideline is acknowledged.

Document Integration:

The radon guideline in Section 4.3.2.2.1 has been changed from 800 Bq/m3 to 200Bq/m3.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-17 Comment:

In Sub-section 3.4.2.1 on Radiation Protection, "design objectives" for gamma radiation fields, radon and radon progeny exposure rates and concentrations of long-lived radioactive dust are described. On the average, a worker works for 2,000 hours in a year. If one were to multiply those exposure rates with the hours worked, then higher radiation doses will be obtained and will be closer to the CNSC regulatory limits. Please clarify if these design objectives are approved by the CSNC.

ARC Response:

The design objectives for the McClean Lake mill were derived from commitments made within the 1995 EIS, and were most recently re- evaluated and approved for the construction of the JEB mil expansion to receive high grade ore slurry from Cigar Lake. They are primarily used as a basis for designing shielding and ventilation features. Exposure of workers for 2000 hours per year at the design criteria levels will result in doses of less than 14 mSv/a.

Document Integration:

No integration required.

Technical Review Response:

The proponent’s design criteria levels estimate worker exposures to result in doses of less than 14 mSv per year. A dose of 14 mSv per year is within the CNSC regulatory limits of 100 mSv over a 5-year period with a maximum of 50 mSv in any one 2010 year.

However, a dose of 14 mSv per year is an elevated dose even though below regulatory limits. HC advises that the ALARA principle should be followed to reduce this dose further, if possible ARC Response:

Acknowledged

Technical Review Response:

October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-18 Comment:

On pg. 8-16 it states "The average annual worker dose was 1.2 mSv, which is about half of the predicted value of 2.9 mSv." The lower actual dose is attributable to a lower ore grade (1.7% uranium) than was assumed in the initial dose estimation (6.9% uranium). However, under Sub-section 8.6, Summary of Human Health Considerations, a higher set of doses is mentioned for different groups of workers. The average doses are estimated to be 3.4 mSv/year, with a maximum dose of 9.4 mSv/year (Table 8.2-3). Please clarify the reasons for these discrepancies and provide one list of workers with average and maximum doses indicated if this accurately reflects the situation. For the estimated doses, Health Canada notes that the doses are below the regulatory limits, but somewhat on the higher side. Health Canada suggests the use of an “As Low As Reasonably Achievable (ALARA) program to reduce doses, where feasible.

RA Note: This comment warrants the same response to comment CNSC RP-1

ARC Response:

The topic discussed under Section 8.2.4.1 is an initial assessment of program performance conducted in 1999 which was intended to evaluate the effectiveness of the radiation protection design features and compared actual doses to the theoretical doses predicted during project development. While Section 8.2.4.1 was included to provide context, its inclusion in this section was not necessary and could understandably cause some confusion.

The updated dose assessment, whose methodology is described in Section 8.2.5, is based on operational experience gained at the McClean Lake Operation. Table 8.2-3 and Table 8.2-4 provide one list of worker categories for milling and mining, respectively, with average and maximum doses which reflect the current situation.

The evaluation of doses must be conducted in the context of the production parameters. A useful parameter to evaluate doses in mining is “collective effective dose per tonne U.” On this measure, under the proposed operating scenario, McClean Lake will have amongst the lowest radiation dose per unit of production.

The ALARA process of dose optimization is integral to the Radiation Protection program at McClean Lake, and is a subject area regularly evaluated by the CNSC.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

The proponent has adequately responded to the concerns presented in HC original comment.

2010 HC acknowledges the proponent’s inclusion of the ALARA principle to the Radiation Protection Program at McClean Lake. A more detailed description of how the principle will be applied for worker radiation protection would be beneficial to understand how the predicted doses limits will be achieved.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-19 Comment:

Sufficient details of the malfunctions and accidents relating to different aspects of the operations are described in subsection 3.7. However, the probabilities and thus the calculation of the significance of these incidents were not provided. Please include the event occurrence probabilities, and assess significance to human health.

RA Note: If event occurrence probabilities are not known, an indication of the ‘likelihood’ of the event (e.g., past experience at similar facilities) is needed.

ARC Response:

AREVA uses a process of hazard identification and risk assessment to characterize risks to human health and safety as an integral part of its OHSAS 18001 certified safety management system. A comprehensive risk register is maintained and risk factors for each identified hazard are used to facilitate risk reduction and elimination activities. The potential malfunctions and accidents associated with environmental assessment of the Midwest Project have been evaluated in a manner congruent with the methodology routinely used at McClean Lake. The probability of each event has been rated on a 5 point scale. A score of 5 indicates the event is probable to occur over the life of the activity; a score of 1 indicates the event is unlikely to occur. Similarly, the severity rating indicates the potential impact on human health and safety. A severity rating of 5 indicates the potential for a fatal incident while a rating of 1 indicates the potential for a first aid incident.

Value Probability Potential Severity 5 Probable Fatality 4 Possible LTA 3 Unusual Modified work injury 2 Rare Medical Aid 1 Unlikely First Aid

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-19 The significance of the malfunctions and accidents is summarized in the table below in terms of a calculated risk factor. Generally, (continued) incidents involving a loss of containment or a spill have low severities in terms of human health and safety, and have low risk factors. For incidents with higher risk factors, mitigative measures are in place to minimize the risk. For example, traffic control plans and procedures are created to reduce the risk transportation incidents, and training is provided to site personnel; sufficient monitoring and alarms are in place to identify a malfunction in the acid plant, and protective equipment, plans and procedures are in place to protect workers.

Malfunction or accident Probability Severity Risk Factor Hazardous Substance Storage 2 2 4 Leakage from External Ponds 2 1 2 Spills from External Pipelines 4 1 4 Release of Off-Specification Effluent 4 1 4 Pit Slope Failure 1 5 5 Release of Contaminants from Surface Ore Stockpiles 3 1 3 Spillage during Ore Haulage 3 1 3 Ruptures and Spills from Mill and Effluent Treatment Process Tanks and Pipes 2 1 2 Spills from Tailings Transfer Pipelines 2 1 2 Stack Scrubber Failure 3 1 3 Acid Plant Malfunction 3 4 12 Power Outages 5 1 5 Fire in Process Plant 1 5 5 JEB TMF Pit Slope Failure 1 5 5 Transfer of Effluent - Midwest WTP to S/V TEMS 3 1 3 Sink/Vulture Treated Effluent Management System 3 1 3 Transportation Accidents 2 5 10

Document Integration:

No integration required.

Response:

The proponent has provided a good explanation of how the risk is determined for each accident and malfunction scenario. However, it is suggested that the rating system for risk be integrated into the revised EIS along with a discussion of each of the accident or malfunction scenarios found in the summary table. AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment Technical Review Response:

October 2010 HC suggests that the rating system for risk be integrated into the revised EIS. HC also suggests the EIS provide discussion of how the risk level for each malfunction and accident was determined including the probability and severity of each scenario. AREVA requested further adequacy review of AREVA responses to date.

 AREVA agrees to integrate the risk rating table into section 3.7 of the EIS, as this fulfills the requirement of the PSGL to use a risk- based approach to identify situations where mitigative measures or contingency plans may be needed.  AREVA feels that the additional table, and the existing text relating to the scenario context, are satisfactory for the purposes of identifying situations which may require mitigative measures or contingency plans. The details of such measures and plans are designed in consultation with regulatory agencies during licensing process.

 We are concerned about introducing substantial detail on an additional assessment process for malfunctions and accidents with a different purpose, i.e. prioritization of mitigation/contingency plans rather than significance of effects, within the EA.  Risk of environmental incidents and workplace accidents is more thoroughly addressed by the existing, operational programs, including the ISO 14001 environmental management system and the OHSAS 18001 certified safety management system.

Request for further follow-up has been removed.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-20 Comment:

The material provided in support of the HHRA is inadequate for evaluation and interpretation of the results. Primarily, an appendix or other documentation with the HHRA calculations that support the Human Health Assessment (Section 8.3 of the EIS) for the Midwest project should be provided for verification. Also, it should be made clear that Appendix VII – Human Health Risk Assessment is not the HHRA for the Midwest Project. It would be better to indicate on the title page that it is for the Sue C EA especially since it is notated “Midwest Project EIS- AREVA Resources Canada Inc. -- August 2007) on the title page to avoid confusion.

ARC Response:

The human health Appendix VII has been revised to improve traceability. Sample calculations are provided in the updated version of Appendix VII. To clarify, all information in Appendix VII applies to the Midwest Project assessment and is presented within the Midwest Project EIS, therefore it was named as such. The beginning of the document notes that the information presented here is unchanged from what was presented in the Sue E EIS (COGEMA 2004). Appendix VII has updated as indicated.

REFERENCE:

COGEMA Resources Inc. (COGEMA). 2004. McClean Lake Operation Sue E Project Environmental Impact Statement. November.

Document Integration:

Appendix VII has been updated to improve traceability and sample calculations have been added to Section 6 of Appendix VII.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-21 Comment:

HHRA - Receptor Characterization and Screening Consistent identification of human receptors throughout the EIS would be helpful to avoid confusion. For example, on Figure 7.2-3 Air Quality Receptor Locations, Receptor 5 is indicated as the JEB worker, whereas the same receptor in Figure 2.7-1 Human Receptor Locations Considered in Pathways Analysis is indicated as McLean Lake Camp.

Health Canada recommends the inclusion of the toddler (age 7 mo to 4 yr) rather than the child (6-11 yr; see sub-section 8.3.1.1) as a more sensitive age-group for evaluation of potential human health effects. Please provide justification for the use of the child instead of the toddler as the most sensitive receptor.

RA Note: See comment CNSC RP-2

ARC Response:

The inconsistent labelling between Figure 2.7-1 and Figure 7.2-3 has been corrected. The McClean Lake Camp receptor in Figure 2.7-1 of Appendix VI, has been re-named as the JEB Camp Worker, in order to be consistent with Figure 7.2-3 of Section 7 and the rest of the EIS document.

With regard to the second part of the comment above; the difference between a child and a toddler in terms of exposure is that a toddler has a higher intake of soil as well as a lower body weight In this analysis, it has been assumed that a child has the same soil ingestion rate as a toddler so that the soil ingestion pathway would not be underestimated. In fact, the nominal soil ingestion rate for a child was considered to be 100 mg/d as opposed to the Health Canada recommended value of 80 mg/d. The range of soil intakes were from 50 mg/d to 150 mg/d (representing a pica child). Nonetheless, a calculation is provided for a toddler at the Wollaston Lake location in the updated Appendix VII.

Document Integration:

Figure 2.7-1 of Appendix VI has been updated as indicated in response.

Required discussions and information regarding the inclusion of a toddler in the human health risk assessment can be found in the following sections of the Midwest Project EIS:  Section 8.3.1.1,  Section 8.3.1.3  Section 8.3.1.4.  Table 8.3-1, 8.3-2, 8.3-6, 8.3-9, and 8.3-13. ,  Appendix VII, Section 6.2 (calculations)

Technical Review Response: 2010 adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-22 Comment:

HHRA - Estimating Exposure In section 8.3.1.3, in the estimation of exposure to Chemicals of Potential Concern (COPCs) from market foods, it was noted in the EIS that metals data for market foods are not readily available, with the exception of arsenic. Health Canada, in fact, publishes Total Diet Study data for all of the metal COPCs that were included in the EIS, except nickel, selenium, and zinc, on the Health Canada website and/or in related publications. The use of the Total Diet Study data should be considered.

ARC Response:

Market food intakes from this source as well as others were used to update the Market Food Intakes and the exposure and risks were re-calculated.

Document Integration:

Changes are reflected in:  Appendix VII, Table 3.0-4  Section 8.3.1.3 of the Midwest EIS Main Document

Technical Review Response:

It is unclear how the dietary intake of arsenic from supermarket foods was calculated (Table 3.0-4) using the Protocol for the Derivation of Canadian Tissue Residue Guidelines for the Protection of Wildlife that Consume Aquatic Biota as a reference. Please explain the approach 2010 used.

With respect to the daily intakes of uranium in Table 3.0-4, HC requests a rational for using the Canadian Drinking Water Guidelines report in lieu of the Canadian Total Diet study, and a description of how these values were calculated.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

Arsenic comment: The reference provided for EC 1999 was the wrong reference. The correct reference is Environment Canada 1999. Canadian Soil Quality Guidelines for Arsenic. Scientific Supporting Document. National Guidelines and Standards Office, Environmental Quality Branch, Environment Canada. Ottawa.

Uranium Comment: At the time that this assessment was undertaken, we were not able to obtain uranium intakes related to food. Therefore, the daily intakes of uranium were based on the drinking water guidelines which reports data for adults of 0.001 µg in air; 2 µg in food and 0.6 µg in water. Based on a 70 kg adult, the total daily intake is 0.037 µg/kg-d ((2 + 0.001 + 0.6)/70) of which an intake of 0.028 µg/kg-d was from supermarket foods. These values are provided in Table 3.0-4 in Appendix VII. For the child, the uranium intake in air for 3 June 2010 an adult (0.001 µg) and the water intake (0.6 µg) were scaled using an inhalation rate of 12 m /d a drinking water intake of 0.9 L/d for a child to obtain a daily intake from air of 0.0006 µg and from water of 0.35 µg. The adult food intake of 2 µg was scaled according to the dietary intake ratios for different age groups for arsenic, cadmium, cobalt, and lead from a study carried out in Port Colborne. (Table A4-2 from Ontario Ministry of Environment (MOE) 2002. Soil Investigation and Human Health Risk Assessment for the Rodney Street Community, Port Colborne. Human Health Risk Assessment Appendix 4. Estimating Daily Intakes of Metals from Supermarket Food. http://www.ene.gov.on.ca/envision/techdocs/4255e_b5.pdf). The ratio for the child was 0.88 and for the adult was 0.85 which results in a daily food intake rate of 2.07 µg which corresponds to a total food intake of 0.077 µg/kg-d and not 0.029 µg/kg-d as reported in Table 3.0-4 in Appendix VII. Based on information from Robert Dabeka of Health Canada, the dietary intake of uranium for a child for the years 2003 to 2007 was 0.089 µg/kg-d. Thus the extrapolated value for a child is similar to the value provided by Dabeka. The total intake of uranium for a child is thus 0.09 µg/kg-d as reported in Table 3.0-4 in Appendix VII.

Document Integration:

No integration required. Technical Review Response:

October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-23 Comment:

Toxicological Reference Values (TRVs)

The TRVs attributed to Health Canada in Tables 8.4-3 (Appendix VI) and Table 8.3-6 (Section 8) were not properly referenced; however, these appear to be an in-house Health Canada reference source for the Chemical Health Hazard Assessment Division (CHHAD), Foods Directorate (Health Canada 2007) . The table lists the values of various parameters which have been used by CHHAD at various times in connection with the safety assessment of metals in foods only. Note that the Foods Directorate documents are not a primary source for TRVs, estimated daily intakes, or nutritional reference values. As such, please confirm and justify that the application of TRVs developed for safety assessment of foods are appropriate for a multi-media exposure HHRA for the project.

The provisional Tolerable Daily Intake (TDI) of 2 µg/kg-day for arsenic (see pg 53, Appendix VI; also p-34, sub-section 8.3.2.3, Tables 8.3-6 to 13), attributed to Health Canada (1996), is incorrect. Health Canada (1996, 2004) considers arsenic to be a carcinogen and does not provide any TDIs. This value may have been obtained from the above mentioned in-house reference source from the Health Canada Foods Directorate; however, the most recent version of this information provides a TDI of 1 µg/kg/day for arsenic (Health Canada 2007). Please confirm the numerical value and reference source for the arsenic TDI and justify that the application of this TRV developed for safety assessment of foods is appropriate for a multi-media HHRA for the project.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-23 ARC Response: (continued) It is acknowledged that the TRV tables were not appropriately referenced in the document and that the table will be replaced by the following information:

Pathway of Carc. vs Value Units Health Effect Refb Exposure Non-Carc.a

Health Canada oral carc. 2.8 (mg/(kg-d))-1 Skin cancer Arsenic (2004) Health Canada oral non-carc. 0.002 mg/(kg-d) Not reported (2002) Health Canada Copper oral non-carc. 0.25 mg/(kg-d) Not provided (2002) Health Canada Lead oral non-carc. 0.0036 mg/(kg-d) Not provided (2002/2004) Increased uric IRIS (U.S. EPA, Molybdenum oral non-carc. 0.005 mg/(kg-d) acid levels 2006) Nickel (assumed to be nickel Health Canada oral non-carc. 0.05 mg/(kg-d) Not provided sulphate) (2004b) Pathway of Carc. vs Value Units Health Effect Refb Exposure Non-Carc.a Health Canada Selenium oral non-carc. 0.012 mg/(kg-d) Not provided (2002) Health Canada Uranium oral non-carc. 0.0015 mg/(kg-d) Not provided (2002) Health Canada Zinc oral non-carc. 0.7 mg/(kg-d) Not provided (2002) Notes: a Carcinogenic (non-threshold) vs. non-carcinogenic (threshold) effect. b IRIS - Integrated Risk Information System on-line database (U.S. EPA 2006). Health Canada 2002 – Toxicological Reference Doses for Trace Elements from Toxicology Evaluation Section of Health Products and Food Branch of Health Canada. Health Canada 2004 – Health Canada Toxicity Reference Values for Use at Contaminated Sites.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-23 Arsenic is considered to be a non-carcinogen as well as a carcinogen and was evaluated for both endpoints for the Midwest Project. The (continued) non-carcinogenic end point was evaluated using the Provisional Tolerable Daily Intake provided by the Health Canada Food Directorate as indicated above. This value was considered to be appropriate for use in the evaluation as the majority of the arsenic exposure came from the food pathways. The 2002 PTDI was used as the evaluation was carried out before the 2007 value became available.

Document Integration: The TRV table references have been corrected and the appropriate references included in the reference sections of Section 8 and Appendix VII. References have been corrected in Table 5.1-1 of Appendix VII (formerly Table 8.4-3 of Appendix VI). The human health risk assessment information that had been included in Appendix VI is now included in Appendix VII. References have been corrected in Table 8.3-7 of Section 8.

Technical Review Response:

Some of the toxicological reference values (TRVs) cited by the proponent are no longer recommended. The TRVs currently used by HC’s Chemical Health Hazard Assessment Division for copper, nickel and selenium are 0.125 mg/kg bw/day, 0.025 mg/kg bw/day and 0.75 mg/kg bw/day, respectively. Please note that these values may be revised when appropriate and that they should not be employed without a thorough understanding of them and the studies upon which they are based.However, utilizing current TRVs would not be expected to impact the human health risks associated with the consumption of country foods given the low contribution of project-related exposures 2010 reported.

Health Canada’s position regarding inorganic arsenic is currently under review, and a TDI for the non-cancer effects is not supported at this time

The proponent indicates that the average background intake of total arsenic from the diet for a child exceeds the TDI based on an inappropriate comparison with an inorganic arsenic TDI. However, as indicated, the Food Directorate of HC no longer supports a non- carcinogenic TDI for inorganic arsenic. ARC Response:

AREVA concurs with Health Canada that the toxicological reference values (TRVs) used in the human health risk assessment are not the most up to date since the initial evaluation was conducted in 2006. However, they represented the best available science in 2006. AREVA also agrees with Health Canada’s conclusion that utilizing current TRVs (as per the values in Appendix VII, Table 5.1-1) is not expected to June 2010 impact the human health risks associated with the consumption of country foods given the low contribution of project- related exposures reported. As indicated above, at the time of the assessment, the most current TRVs were used and Health Canada had a tolerable daily intake (TDI) for the non-carcinogenic effects of inorganic arsenic and this was used in the assessment. The withdrawal and current Health Canada review of inorganic arsenic tolerable daily intake (TDI) has occurred after this assessment. In addition, as stated in the previous response above arsenic was evaluated as both as a carcinogen and a non-carcinogen. It should be noted that the slope factor used to assess the carcinogenic endpoint of arsenic was 2.8 (mg/kg-d)-1 as indicated in the Table above; Health Canada has since revised that

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment value to 1.8 (mg/kg-d)-1.and thus the assessment of the carcinogenic effects of arsenic are overestimated in the Midwest Project EIS.

Document Integration:

No integration required. Technical Review Response:

The proponent indicated in the addendum that Health Canada has revised the cancer slope factor for inorganic arsenic from 2.8 (mg/kg bw/d)-1 to 1.8 (mg/kgbw/d)-1, but did not indicate the source of this value. It should be noted that Health Canada’s Food Directorate does October 2010 not employ either of these slope factor values and is currently reviewing the carcinogenic potency of inorganic arsenic. Please reference the source of this value.

As the incremental cancer risks associated with project effects are expected to be marginal and can be considered as conservative since they are based on dietary exposures of total arsenic, rather than inorganic arsenic, HC has no further concerns. Response:

The reference for the cancer slope factor for inorganic arsenic of 1.8 (mg/kgbw/d)-1 is:

Health Canada. 2009 (draft). Federal Contaminated Site Risk Assessment in Canada, Part II: Health Canada Toxicological Reference Values (TRVs), Appendix A. Version 2.0, January.

This draft document was developed by Health Canada Contaminated Sites division.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-24 Comment:

Carcinogenic Effects

Health Canada could not verify the proponent’s estimate that ‘the incremental risk associated with trace amounts of arsenic naturally present in water and in many foods range from seven in ten thousand (7 in 10,000) to one in one thousand (1 in 1,000) Environment Canada 1993)” (see page 8-33). No such estimate was provided in the referenced document. Please provide more information documenting the derivation of this statement and the other cancer risk estimates presented for the project so that the values can be verified.

Comparison of cancer risks from arsenic to those related to sunlight (see section 8.3.2.2, page 8-33 and Table 8.3-9) is not appropriate for an EA. The cancer risks related to the project itself are the only issues under consideration.

ARC Response:

Environment Canada (1993) provides a typical daily intake for an adult of 1.0 x 10-4 mg/(kg d) to 7 x 10-4 mg/(kg d). These ages are adjusted for a 50 year exposure over a 70 year exposure and then multiplied by the slope factor of 2.8 (mg/(kg d))-1 to determine the risks for an adult living in Canada. For example 7 x 10-4 x 50/70 x 2.8 results in a risk of 1.4 x 10-3 or 1 in 1000.

The comparison of risk of skin cancer arising from arsenic exposure to skin cancer arising from sun exposure is appropriate as it puts into context the values that are being presented so that members of the public can understand.

REFERENCE:

Environment Canada. 1993. Canadian Environmental Protection Act. Priority Substances List Assessment Report – Arsenic. Document Integration:

No integration required.

Technical Review Response:

The proponent’s comparison of risks of skin cancer from arsenic exposure (see section 8.3.2.2 and Table 8.3-10) versus ultraviolet rays (e.g. sunlight) exposure is not a valid comparison as it diminishes the perception of potential risk associated with the health impacts of the project and is not appropriate for this EA.

2010 HC continues to advise that the reference to risk from exposure to ultraviolet rays be removed unless additional information is provided regarding the incremental exposure of all receptors and the subsequent calculation of cumulative risk of all identified pathways. This approach could bring UV exposure into context of the EA in regards to the total potential risk of skin cancer due to the project.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

At Health Canada’s request, references to cancer risk from sunlight exposure have been removed from the Midwest EIS.

Document Integration:  Delete the following sentence from Section 8.3.2.2 “In comparison, the incremental risk for skin cancer from exposure to ultraviolet rays is about 1 in 100 (Canadian Cancer Statistics 2004, www.cancer.ca).”  Delete row “Exposure to ultraviolet rays for general Canadian population (annual rate) and estimated risk of developing skin cancer over lifetime = 1 in 100” from Table 8.3-10.  Delete www.cancer.ca reference from Section 8 Reference List.

Technical Review Response:

October 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-25 Comment:

Non-carcinogenic Effects The body of the report indicates daily intake data for non-radionuclides were not estimated for Wollaston Lake Lodge operator, Rabbit Lake Camp worker, JEB camp worker, Points North worker and Hatchet Lake Lodge operator (see sub-section 8.3.2.3, page 8-35), as information relating to diet were considered insufficient. However, project-related cancer risk estimates for these receptors are presented in Table 8.3-9. Please provide daily intake data upon which the cancer risks for these receptors were estimated (similar to those provided for the Wollaston Lake Resident and Trapper [adult and child] in Tables 8.3-10 to 13) or provide further details and justification on how these cancer risk estimates (see Table 8.3-9) were estimated.

ARC Response:

For reference, Appendix VI Integrated Risk Assessment and Appendix VII Human Health Risk Assessment have been re-organized and all details of the human health risk assessment (HHRA) are now located in Appendix VII. Appendix VII has been revised and information on total daily intake of non-radionuclides and exposure to COPC for the remainder of the human receptors, are presented in Appendix VII, Tables 6.1-1 to 6.1-5 and Section 6.1.

Document Integration:

Information in relevant tables have been moved from Appendix VI into Appendix VII

As discussed in the above response changes have been made in Appendix VII:

 Tables 6.1-1 to 6.1-5  Section 6.1

Changes have also been made in:

 Section 8.3 in the Midwest EIS Main Document.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-26 Comment:

Health Canada has some concerns about possible metal contamination in the re-flooded Midwest pit and the subsequent contamination of fish. People may consume the contaminated fish and/or other traditional game species (e.g. avian game species, terrestrial mammals) that may frequent the water body. Steps should be taken to ensure that people and wildlife do not consume potentially contaminated fish from the Midwest pit.

ARC Response:

At the end of the Midwest Project, a till cap will be constructed over the wastes in the pit. The final thickness of the till cap, and the effectiveness of the till cap, will be further assessed during environmental assessment of decommissioning activities. The Midwest pit will be allowed to re-flood naturally. The re-flooded Midwest pit will remain isolated from South McMahon Lake and the dam between the lake and the reflooded pit will not be breached. The re-flooded Midwest Pit will not be connected to any other fish bearing water bodies and the pit lake will not be stocked with fish, therefore the Midwest pit will not be a fish bearing water body. See also response to Comment CNSC- 4 (1)

Document Integration:

No integration is required.

Technical Review Response:

The proponent’s response is adequate assuming the (naturally) re-flooded pit will not be unintentionally re-stocked with food fish (e.g. 2010 though seasonal flooding, dam breeches, or human or bird activities).

No further clarification is requested.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-27 Comment:

In addition, the proponent should provide a discussion concerning the potential harvest of, and effects on, traditional foods from alongside the proposed roadway corridor that would link the McClean and Midwest project sites. The proposed road would serve as a route by which to haul ore, transport treated effluent, and run power lines. Traditional foods that may grow along the roadway corridor, such as berries and Labrador tea, would be of particular concern, particularly if dust from the metal ore is released during transport and/or if there is a leak or burst in the effluent pipeline. Health Canada notes that the proposed roadway corridor linking the two sites may increase the use of the areas adjacent to the roadway for the harvest of traditional foods.

ARC Response:

See response to Comment HC-9. Access to the proposed haul road will be located within the site security gates both at the McClean Lake site and the Midwest site. It is expected that it will not be designated a public road. Access to the road by members of the public will require prior permission, as is the current practice for the existing site access road at McCLean Lake Operation. Access to the road from any other point along it will be difficult due to the terrain. Because of the control of access to the road as well as is difficult to access at other points outside to the Midwest and McClean Lake sites, the haul road is not expected to increase the use of the areas adjacent to it for the harvest of traditional foods. Mitigation measures are in place for ore transport or pipeline leaks. Please refer to Section 3.7, Malfunctions or Accidents, of the main document which considers potential malfunctions or accidents related to all aspects of the proposed Midwest Project.

Document Integration:

No integration is required.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-28 Comment:

Health Canada recommends collecting additional baseline data for all of the metals that were identified as COPCs in individual traditional foods or specific parts of traditional foods (i.e. certain animal organs) that are consumed with high frequency and/or magnitude by local First Nations.

While some baseline data has been collected for various traditional foods, several deficiencies have been identified in the baseline data set presented in the EIS (see below):

• The EIS identified selenium and uranium as COPCs, but no baseline data on these metals in fish was presented. The reference sites for the McClean Lake operation are likely suitable for comparison for baseline and project data from the Midwest Project, as the two project locations lie within 15 km of each other. As Health Canada was not provided with a list of all available fish data collected from reference sites, we are uncertain if all the metals considered to be COPCs in the EIS were analyzed in the tissues of several game fish species. Please clarify. Health Canada requests confirmation that the fish tissue sampling from reference sites includes all metals considered to be COPCs for the Midwest project.

The only small mammals for which baseline data have been collected for the Midwest site are red-backed voles and the data are limited to two (of the nine) metallic COPCs. Please provide a discussion as to the appropriateness of using the red-backed vole data as a surrogate for other small game animals and how uncertainties related to the use of the surrogate data may impact calculations for human health risks.

No baseline data were collected for any species of game bird despite the fact that exposures to COPCs from this type of traditional food were included in the assessment of human health risks.

RA Note: This note clarifies certain elements of HC-28 - The RAs agree that AREVA must report upon uranium in the EA given the existing database for this COPC. Selenium data, for the purposes of the EA, must also be reported on and should draw from other nearby data sources such as the McClean Lake data from the AREVA-funded University of Saskatchewan research; databases for Cameco facilities (Rabbit Lake, Key Lake and McArthur River); and, Cameco/AREVA-funded community monitoring program associated with the seven nearest communities of the Athabasca basin. In addition to the above, AREVA is to address these aspects and those pertaining to game birds in the context of an EA Follow-up program.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-28 ARC Response: (continued) In many assessments, measured COPC data for wildlife species tissues are not available. Often, as was done for the Midwest Project EA, environment modelling is conducted to predict expected exposure of wildlife to COPCs on the basis of conservative assumptions.

Fish tissue does not form part of the COPC selection methodology. Rather, COPC selection is based on screening measured and/or modeled effluent discharge water concentrations against surface water quality guidelines or objectives, as well as a comparison of measured and/or modeled constituent levels in sediments to sediment quality guidelines. This ensures that COPCs relating to the operation are selected and monitored. The COPCs used in this assessment were based on information from the Previous EAs, including those assessments presented in the Caribou EIS and the Sue E EIS. Since the Midwest deposit is in the same area, it is expected that the COPCs selected in the previous projects would also apply to the Midwest Project. The COPCs considered in the assessment were radionuclides (Th-230, Pb-210, Ra-226, Po-210) and arsenic, cobalt, copper, lead, molybdenum, nickel, selenium, uranium and zinc. With the exception of Se, the fish tissue data originally summarized in Section 4 provided concentrations of all these COPCs, including U, in addition to other constituents. The information has been updated to include available selenium data as well (See response to Comment CNSC-21).

With respect to Se, AREVA acknowledges that fish tissue chemistry data for Se were missing from the previous Midwest Project EIS submission. To address this, Tables 4.4-44 to 4.4-47 in Section 4, Existing Environment, have been updated to include Se concentrations in fish tissues. As part McClean Lake Operation Environmental Monitoring Program (EMP), fish tissue chemistry sampling was completed in the fall of 2008. Both Se and U were measured in fish tissue samples, along with the other COPCs. This information is summarized and presented in the 2008 McClean Lake SOE Report, which has been submitted to regulatory agencies. Monitoring of COPCs, including Se, in fish tissues will continue as part of the McClean Lake Operation Environmental Monitoring Program and subject to Status of the Environment Reporting requirements (AREVA, 2009a).

To clarify the discussion of small mammals in Section 4.5.3.8 of the Midwest EIS document, as noted, small mammals were trapped to obtain baseline data on their abundance and habitat preferences. In general, for assessment purposes, small mammals, such as voles, are selected for baseline monitoring since they have a very limited home range with relatively high exposure to soil (which can represent a source of COPCs) compared to other wildlife species. Therefore, voles can represent one of the most exposed terrestrial receptors.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-28 The measured baseline data for vole tissues collected in 1995 and 1996 showed that COPC concentrations are similar between voles (continued) captured at a potential exposure site (JEB) and at the reference site (Mallen Lake), suggesting the variation in baseline exposure to COPCs do not vary widely. Baseline vole tissue data from the Midwest Project does suggest Ni tissue concentrations may be somewhat elevated relative to the McClean Lake area; however, as noted in Section 4.5.3.8, these differences in tissue type measured (e.g., whole body versus liver), or potential differences in analytical techniques. These data are summarized in Table 4.5-13 of the Midwest EIS Main Document, (See also AREVA 2009b). The data collected on voles at the Midwest site provide a measure of reference conditions at this site. It is noted that the small mammal data are not used in the human health assessment. That said, it is expected that contaminant transfer to small mammals would provide a conservative estimate of transfer to other wildlife species with more extensive home ranges which integrate contaminant exposure over a wider spatial range. Appendix VII of the Midwest EIS provides predictions of human exposure to COPCs via key pathways, including the consumption of wild game.

As indicated in the results of the integrate risk assessment (Section 7.0), on the potential incremental effects on many VECs is negligible and monitoring of the concentration of COPCs in tissues is unwarranted. VECs for which predicted incremental risk is evident are, with the exception of migratory periods for waterfowl, largely confined to within the lease area where hunting is restricted throughout the operational period, negating the need for consideration with respect to traditional harvesting. Thus, game bird tissue monitoring is not being considered as a follow-up component to this assessment. In addition, as noted above, game birds, such as ducks, are migratory, spending a relatively large proportion of the year away from the McClean Lake site, thereby reducing total annual COPC transfer to such species.

As in the past, AREVA will continue to work cooperatively with provincial health agencies, the Saskatchewan Ministry of the Environment, the Northern Mines Monitoring Secretariat and the University of Saskatchewan Toxicology Centre to facilitate baseline data collection for traditional foods.

REFERENCES:

AREVA Resources Canada Inc. (AREVA). 2009a. Status of the Environment Report. McClean Lake Operation. Assessment Period 2006- 2008.

AREVA Resources Canada Inc (AREVA). 2009b. Midwest Project. Existing Environment Technical Information Document.

Document Integration:

Section 4, Tables 4.4-44 to 4.4-47 have been updated to include more data on fish tissue chemistry, including Se. The table titles and the list of tables have been updated to reflect the changes in the data presented. References to these tables have been added to Section 4. Reference to Tables 4.4-44 to 4.4-47 have been added to Section 4.4.6.2.2.

2010 Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-29 Comment:

An assessment of human health effects due to consumption of caribou is suggested. The caribou were considered to be potentially affected by the project (Example 4: Radiological Assessment for Aquatic Plants and Terrestrial Animals, Appendix VI); however, risks to people eating caribou were not assessed. In addition, the cumulative effects assessment (i.e. Midwest project plus other projects in the vicinity) should include country foods exposure from eating caribou.

It is suggested that the use of the consumption rates of meat from the Hatchet Lake survey would better reflect local consumption rates rather than the rates in (Thomas, 1999). Also, it appears that the EA used data from the Uranium City herd to characterise background exposures, rather than the Wollaston herd data, which would be more relevant to the geographic area of the Midwest project. Data pertaining to the Wollaston area herd are also available in Thomas et al. (2005) and Thomas and Gates (1999).

ARC Response:

Risks to people consuming caribou that are potentially affected by the project were not assessed in the Human health assessment or the cumulative effects assessment because people in the area consume caribou that are hunted outside of the Midwest LAB. Data from caribou representing natural background exposure were used. Assumptions made about the consumption of caribou are based on knowledge of the limited interaction of the barren ground caribou with the McClean Lake Operation. Only three times in the last twenty- seven years have barren ground caribou been observed in the vicinity of the McClean Lake/Midwest sites, therefore incremental exposure to McClean Lake Operation emissions, through migration, is very low. Any exposure barren ground caribou could have received while temporarily foraging within the project area, would be negligible. The barren ground caribou consumed are almost exclusively harvested outside of the regional study area and are brought back to the community. Supporting information on barren ground caribou migration and residency frequency in the local assessment boundary can be found in the Midwest project EIS Main Document, Section 4.5.3.2 Ungulates- Barren-ground Caribou. More information on caribou in the local assessment boundary and the regional assessment boundary can also be found in the McClean Lake Operation Existing Environment Technical Information Document (COGEMA 2003), Section 5.3.1.1.4.

It seems that there is some confusion about the background information related to caribou. No background chemistry in tissues is presented in Section 4. The description in Section 4 relates to the numbers of caribou found in the study area. Table 3.3-1 in Appendix VI (not VII) presents a summary of the concentrations of various constituents in barren-ground caribou muscle. As indicated in the footnote to the Table, the concentrations presented are an average of concentrations of caribou collected in the Wollaston Lake area in 2000 and 2001 and for caribou caught in Uranium City in 2000. The reason why average values were computed using data from both the Wollaston Lake and Uranium City herds was because the tissue concentrations of the various constituents were similar from the three campaigns. For example uranium concentrations were <0.001 µg/g from Uranium City (2000), <0.002 µg/g from Wollaston Lake (2000) and 0.0009 µg/g from Wollaston Lake (2001) and molybdenum concentrations were all <0.05 µg/g for all the campaigns. Based on a comparison of the data for all COPC it was concluded that there was little difference between the two herds, which is not surprising given that they have a large home range.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-29 (continued) The Thomas reference, as used in the EIS is only referring to radionuclide and metal levels in caribou flesh not consumption rates. The dietary values used in the human health risk assessment for the Wollaston Lake community members are based on the Hatchet Lake Band survey conducted by CanNorth (2000) which included data on consumption of meat, poultry, berries and local garden produce (Table 8.3-3, main document). As the Wollaston Lake Lodge operator is only in the study area for the summer months, this receptor was assumed to import all fruits and vegetables other than berries which the operator was assumed to harvest locally while in season. The overall dietary characteristics and assumptions on what and how much local food is consumed by each receptor is summarized in Section 8 Table 8.3-5 of the main document, with additional details in Appendix VII, Section 2.

In terms of the caribou background exposure data used, Table 3.3-1 in Appendix VI presents a summary of the concentrations of various constituents in barren-ground caribou muscle that were utilized in this assessment. As indicated in the footnote to Table 3.3-1 in Appendix VI, the concentrations presented are an average of concentrations of caribou collected in the Wollaston Lake area in 2000 and 2001 and for caribou caught in Uranium City in 2000. The reason why average values were computed using data from both the Wollaston Lake and Uranium City herds was because the tissue concentrations of the various constituents were similar from the three campaigns. For example uranium concentrations were <0.001 µg/g from Uranium City (2000), <0.002 µg/g from Wollaston Lake (2000) and 0.0009 µg/g from Wollaston Lake (2001) and molybdenum concentrations were all <0.05 µg/g for all the campaigns. Based on a comparison of the data for all COPC it was concluded that there was little difference between the two herds, which is not surprising given that they have a large home range.

REFERENCES:

Canada North Environmental Services Limited Partnership (CanNorth). 2000. Hatchet Lake Dietary Survey. Field Report. March. Prepared for the Atomic Energy Control Board, Ottawa, Ontario.

COGEMA. 2003. McClean Lake Operation. Existing Environment Technical Information Document.

Document Integration:

No integration required.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-30 Comment:

Mercury (Hg) was not considered to be a COPC and thus risks to human health as a result of Hg exposure were not evaluated in the EIS. Hg levels in some species of fish are already naturally elevated in the Midwest mine region: the limited baseline data for Smith Bay and Henday Lake reported for Hg in fish (see Table 4.4-46) approach Canada’s 0.5 ppm standard for total Hg in fish sold at the retail level. Health Canada’s First Nations and Inuit Health Branch (FNIHB) suggest that fish consumed by subsistence populations should contain no more than 0.2 ppm total Hg.

Potential risks to human health due to accumulation of Hg in fish as a result of the project should be discussed, particularly with respect to First Nations peoples subsisting on fish from the project area. Health Canada recommends that additional baseline data for total Hg in fish at both project and reference sites be collected, and follow-up monitoring performed to determine if the project is increasing the Hg concentrations in fish. It is suggested that game fish species in South McMahon Lake be included in the baseline sampling as an additional reference site, given its proximity to the project and its potential for direct dewatering discharge (see s3.2.1.1.1; pages 3-11 and 3-12).

In particular, baseline fish tissue Hg concentration data in lakes selected for fish habitat compensation are needed, along with modelling and/or fish sampling to assess Hg levels in fish following expansion to provide information on possible implications for human health.

It is suggested that future sampling programs to assess impacts of mining include the sampling of fish kidney and liver, in addition to flesh and bone, if local resource users indicate that these portions are typically consumed. The 2005 fish sampling results presented in Table 4.4-48 indicate these tissues may be a better indicator of accumulation of metals by fish (prior to increases in edible tissues), and routine monitoring may therefore be useful to better monitor the impacts of mining activities and plan mitigative actions before fish flesh is significantly affected.

RA Note: Hg investigations and associated health risk assessments would be required if the presence of Hg in the environment results from the Midwest project. If indeed Hg is a COPC – this comment must be addressed. If Hg is not a COPC – the rational for it not being a COPC must be provided.

ARC Response:

Under the Metal Mining Effluent Regulations (MMER) Environmental Effects Monitoring (EEM), promulgated under Fisheries Act, the McClean Lake Operation has, through the consistent demonstration of the absence of Hg detection in its effluent discharge, been exempted from the requirement to monitor Hg levels in treated effluent or in fish tissue (See EC 2002). Mercury in treated effluent at the McClean Lake Operation has consistently been non-detectable (laboratory detection limit = 0.05 µg/L). This is not predicted to change with the processing of Midwest ore. Therefore, under the MMER, AREVA is not required to monitor Hg in fish tissue, and Hg is not considered a constituent of potential concern (COPC).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

HC-30 None the less, although Hg is not considered a COPC, Hg is included in the fish tissue chemistry analyses done on fish collected at the (continued) McClean Lake Operation. The results of these analyses are presented in the McClean Lake Operation SOE Reports, the most recent submitted in 2009 (AREVA 2009) Results of mercury concentration measurements taken in fish from reference and exposure lakes are indicative of baseline levels and no temporal or spatial trends are evident.

REFERENCES:

AREVA Resources Canada Inc. (AREVA). 2009. Status of the Environment Report. McClean Lake Operation. Assessment Period 2006- 2008.

Environment Canada (EC). 2002. Metal Mining Guidance Document for Aquatic Environmental Effects Monitoring. Environment Canada. National EEM Office, Science Policy and Environmental Quality Branch, Ottawa, Ontario.

Document Integration:

No integration required.

Technical Review Response:

The proponent’s response does not address the original concerns expressed by HC that the dewatering discharge from Mink Arm could impact contaminant concentrations (mercury in particular) in fish tissues from receiving water bodies within proximity of the Midwest project. The proponent is asked to provide a rationale and/or modelling to address the potential for increased contaminant concentrations of food fish tissue resulting from dewatering Mink Arm.

2010 It is noted in the 2009 Status of the Environment Report 1 that mercury has increased in the sediment at the reference lakes and other lakes near the McClean operation where fish could potentially be harvested for human consumption; the proponent indicates that the increase could be attributed to natural variation. In addition, recent tissue analysis of fish from these lakes has confirmed concentrations of mercury greater than 0.5 ppm, which is higher than Health Canada’s guideline for total mercury in fish sold at the retail level. In light of these findings, adequate monitoring of game fish from accessible lakes in proximity of the project is advised since fish consumption advisories may be required.

1 AREVA Resources Canada Inc. 2009. Status of the Environment Report: McClean Lake Operation Assessment Period 2006-2008 ARC Response: Mercury (Hg) concentrations in water and sediment in Mink Arm are comparable to reference sites in the Midwest local study area. Hg in Mink Arm water is below the detectable a limit (0.05 µg/L) which is the same for all lakes in the study area (Areva, Table 4.2.2-9, 2009), and Mink Arm sediment is 0.082 µg/g Hg which is less then the study area average of 0.097 µg/g (Areva, Table 4.3.3-9, 2009). Furthermore, June 2010 both water and sediment Hg concentrations are below MMER and ISQC guidelines, respectfully. Therefore, dewatering of Mink Arm is not expected to increase the Hg concentration of South McMahon Lake. Mercury levels will be monitored during dewatering.

The Midwest project average Hg content in fish flesh is 0.15 ppm, which is below the Health Canada guideline of 0.2 ppm for subsistence

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments populations and far below the retail guideline of 0.5 ppm. In addition, Hg concentrations in liver, kidney, and flesh were all similar with only one sample of northern pike having higher Hg in kidney and liver compared to flesh; furthermore, bone samples had appreciably lower Hg concentrations compared to flesh (Areva, Table IV.5-31, 2009). Therefore, consumption of liver and kidney or whole fish would not increase the risk for high Hg content anymore then eating only flesh.

Rough Notes 1) At the Midwest site Hg concentrations in flesh, kidney, and liver were similar with only one sample of northern pike having higher Hg in kidney and liver compared to flesh. (Areva, 2009) 2) Human Hg content is highest in the liver, kidneys and brain. Hair is used to test for Hg content, with no clinical effects below 50 ppm. (Hydro Quebec, 2006) 3) Daily intake corresponding to 3 to 7 ug of Hg per kg of body weight for adults, (Health Canada in Hydro Quebec, 2006) 4) Fish Hg levels from highest to lowest are Liver, Kidney, Muscle, and Heart. Liver is a third higher then kidney and muscle, and heart has half the concentration of kidney or muscle. All other fish organ groups had lower Hg concentrations. (Koli, 1977) 5) One 200 g (6.5 oz) serving of fish per day would be required to reach the Health Canada guideline of 0.47 µg Hg per kg body weight per day with a safety factor of 10.

References:

AREVA Resources Canada Inc. (Areva). 2009. Midwest Project Existing Environment Technical Information Document. December 2009. Saskatoon, Saskatchewan.

Koli, A., Williams, W., McClary, E., Wright, E., & Burrell, T. 1977. Mercury Levels in Freshwater Fish of the State of South Carolina. Bulletin of Environmental Contamination & Toxicology. 17-1.

Hydro Quebec. 2006. Mercury and Fish Consumption. Quebec.

Document Integration:

No integration required.

Technical Review Response:

Since mercury may leach out of soil and rock into water bodies during flooding and subsequently increase the mercury load in the tissues of resident fish, baseline data on the concentrations of methyl mercury in the tissue of game fish species in South McMahon Lake was advised for comparison purposes. However, if the dewatering of Mink Arm is conducted in a controlled manner such that flooding of the October 2010 receiving water bodies is not expected, then the potential for an increase of mercury in fish tissue by this particular mode would not be of concern.

The proponent indicates that the Midwest project average background mercury content in fish flesh is 0.15 ppm. However, it appears as if this value might be an average of all monitored species. Typically, an average and/or a 95th percentile of the mercury concentration would AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments be reported on a fish species basis since concentrations often vary by species.

Limited background sampling of fish from water bodies within the vicinity of the project has demonstrated concentrations of mercury greater than 0.5 ppm in some species, which is higher than Health Canada’s guideline for total mercury in fish sold at the retail level. HC’s Food Directorate would typically provide consumption advice if mercury concentrations in edible fish tissues available at retail market were greater than 0.5 ppm, or for fish that are thought to be frequently consumed and have a higher mercury concentration compared to other commonly consumed products.

If chronic consumption of fish from the sampled lakes at the rates indicated in the EIS are anticipated for local subsistence populations and/or sportfishers, then consumption advice may be warranted for mercury concentrations in fish lower than 0.5 ppm. Additionally, the First Nations and Inuit Health Branch (FNIHB) of HC has previously advised a maximum concentration of 0.2 ppm for mercury in fish caught for subsistence by First Nations peoples. The proponent is advised to contact HC for an interpretation of their guidance value for mercury for subsistence consumers.

The proponent inaccurately states that hair with an Hg content of 50 ppm or less is associated with no clinical effects. Clinical effects have been demonstrated at concentrations lower than 50 ppm (Boischio, 2000, Harada, 2001)1, 2. Please revise the addendum accordingly. Response:

The dewatering of Mink Arm will be conducted in a controlled manner as described in Section 3.2.1.1.2 Proposed Mink Arm Dewatering Operations of the EIS.

The inaccuracy on hair mercury content is acknowledged. Although the addendum is not a revisable document, no reference to hair

mercury content is presented in the Midwest EIS.

AREVA is encouraged that the data collected as part of the Midwest baseline fish tissue monitoring program is of interest to Health Canada with regard to providing potential consumption advice to local communities. AREVA would encourage Health Canada to contact their provincial counterparts to further consider the possible need to provide such advice to local consumers.

Document integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-31 Comment:

The data available for wild blueberries and Labrador tea are dated and not all COPCs identified in the EIS were analyzed for these foods. It is suggested that additional samples be collected for all COPCs identified in the EIS and to confirm concentrations have not changed.

RA Note: AREVA may address this comment under the context of an EA follow-up program.

ARC Response:

AREVA acknowledges that some of the blueberry and Labrador tea chemistry results were excluded from the original Table 4.5-4 and 4.5- 5. These tables have since been updated to include the Mo, Se and Co data from 2005, previously excluded (AREVA 2006). Recent data for blueberry and Labrador tea are now presented. The data for Midwest Project blueberry and Labrador tea is from 1979 and 1984, and therefore not all current COPCs are represented. Data from the nearby McClean Lake Operation is more recent, with the data from McClean Lake reference area assumed to be representative baseline conditions. As part of the McClean Lake environmental monitoring program, sampling and metal analyses of blueberry and Labrador tea at McClean Lake reference and exposure areas was undertaken in 2008 as part of the McClean Lake Operation Status Of the Environment reporting. This report has been submitted to SMOE and the CNSC (AREVA 2009). All contaminants of concern were measured in blueberry, Labrador tea and lichen and are presented in this document.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-31 An environmental monitoring program (EMP), similar to what is in place at the McClean Lake site, will be implemented at the Midwest site. (continued) The McClean Lake Operation EMP (AREVA 2008) provides a template which facilitates the development of an environmental monitoring framework for the Midwest Project. As blueberry, Labrador tea, lichen and soil quality monitoring in reference and exposure areas will be part of the EMP, therefore this will not be required as part of the EA follow-up program.

REFERENCES:

AREVA Resources Canada Inc. (AREVA) 2006. Status of the Environment Report. McClean Lake Operation. Assessment Period 2003- 2005.

AREVA Resources Canada Inc. (AREVA). 2008. McClean Lake Operation Environmental Monitoring Program. Locations, Frequencies and Parameters. Version 7. September 2008.

AREVA Resources Canada Inc. (AREVA) 2009. Status of the Environment Report. McClean Lake Operation. Assessment Period 2006- 2008.

Document Integration:

Tables 4.5-4 and 4.5-5 have been updated to include the 2005 Se, Mo and Co data.

Technical Review Response:

2010 The proponent’s response is adequate if the planned monitoring program at the Midwest site includes sampling of Labrador tea and blueberry from reference and exposure locations for all COPCs identified. ARC Response:

The planned monitoring at the Midwest site will include Labrador tea, blueberry, and lichen sampling. This is consistent with current monitoring in place at the McClean Lake Operation. As outlined in the Environmental Monitoring Program (EMP) (AREVA 2008) and recently reported in the McClean Lake Status of the Environment report (AREVA 2009), soil, blueberry, lichen, and Labrador tea are sampled and analysed for various constituents of possible concern, including Se, Mo, and Co.

June 2010 Please refer to Section 12 for an outline of monitoring and follow-up programs.

REFERENCES Areva Resources Canada Inc. 2008. McClean Lake Operation Status of the Environment Report – Assessment Period 2006-2008.

Areva Resources Canada Inc. 2009. McClean Lake Operation Environmental Monitoring Program – locations, frequencies, and parameters. December 2008 – Version 8 Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-32 Comment:

The EIS would benefit from a clear identification of the sources of drinking water for the human receptors, an assessment of project impacts on drinking water and a comparison of the affected parameters with drinking water guidelines such as the Guidelines for Canadian Drinking Water Quality.

Although the Rabbit Lake worker, Midwest/McClean Lake worker, and Points North worker receptors are consuming treated water, there is a potential for project activities to impact the water treatment process. The source water may have a change in physical parameters (specifically Total Dissolved Solids (TDS), turbidity, pH, temperature, ammonia, Total Organic Carbon (TOC), Dissolved Organic Carbon (DOC) and bromide) that can affect the treatment process. These parameters should be monitored in order to make the necessary adjustments are made to the water treatment protocol.

Please specify the drinking water source of the remaining receptors: Wollaston Lake Resident, Wollaston Lake Trapper, Wollaston Lake Lodge Operator and Hatchet Lake Lodge Operator and clarify if the water pathway was assessed for these receptors in the HHRA for Midwest.

Certain components of the scope of the project (the dedicated haul road between Midwest and the JEB mill, transportation of waste water from the Midwest site to the JEB mill on the McClean Lake site and modifications at the JEB mill and TMF) appear to be omitted from the consideration of potential effects to water quality. Please provide a rationale for this omission or include an assessment of water quality changes due to these components.

ARC Response:

The Rabbit Lake worker is expected to drink water obtained from Collins Creek; this source is evaluated in the exposure assessment. It is noted that the treatment system employed at Rabbit Lake is not expected to remove COPC that occur in Collins Creek as a result of the effluent discharge from the McClean Lake Operation, including the Midwest Project. The JEB Worker receives their drinking water from unaffected Pat Lake, upstream of the McClean Lake Operation effluent discharge area and this is not considered in the assessment. At Points North, drinking water is obtained from a commercial supplier and it is hauled to site, thus this exposure pathway is not evaluated in the assessment. The Wollaston Lake resident and Lodge operator gets water from Wollaston Lake and the Trapper gets 75% of this water from Wollaston Lake and 25% from Collins Bay. This is discussed in Appendix VII and presented in Table 2.0-1. The water quality in Collins Creek does not exceed Canadian Drinking Water Guidelines. An updated Appendix VII, Table 2.0-2 presents the water quality data in Collins Creek at the water intake for the Rabbit Lake Operation. Table 2.0-2 also includes the relevant SSWQO and the Guidelines for Canadian Drinking Water Quality.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-32 Changes to JEB mill are not assessed here, as the mill was previously assessed and approved to receive Midwest ore in the 1995 Midwest (continued) EIS (COGEMA 1995) Likewise, the JEB TMF was assessed previously in the McClean Lake Project EIS (COGEMA 1995). This was assessed by a Joint Panel and approved, with conditions, by the respective federal and provincial governments. Any changes to the JEB mill have been assessed and approved in other EISs, the most recent being the Rabbit Lake Solution Processing EIS (AREVA and Cameco 2008). No changes to the existing tailings preparation process or tailings management facility are required for the Midwest Project.

Haulage of ore from Midwest to the JEB mill is anticipated to potentially result in occasional exceedance of the 24-hour air quality standard for TSP very close to the haul road that AREVA proposes to build between the Midwest Project and McClean Lake Operation. Mitigation measures are taken when conditions dictate to reduce dust emissions. The effects on TSP levels were shown to decrease quickly with distance and to be very localized. As the road will be constructed on undeveloped lands; there are no residents in the area that would be affected. These exceedances are not expected to affect water quality in nearby surface waters. Nonetheless, AREVA will undertake to reduce emissions when conditions dictate by watering of the haul road following practices and procedures currently employed at the McClean Lake Operation. This information is presented in the new Appendix XIV, Air Dispersion Analysis of Nitrogen Oxides, Sulphur Dioxide, Radon-222, Dust, Metals and Radioactive Elements.

The treated effluent in the pipeline is expected to meet SSWQO and would be appropriate for direct release to the environment. None the less, containment ponds will be located at regular intervals along the haulage road to provide temporary containment of water for the purpose of preventing excess erosion in undisturbed areas adjacent to the roadway, and potential sedimentation of water ways. The transfer line will be patrolled on a regular basis to provide early detection of any leaks or rupture. This information is provided in Section 3.7.5 of the main document.

REFERENCE:

COGEMA Resources Inc. (COGEMA). 1995. The Midwest Project Environmental Impact Statement. August.

AREVA Resources Canada Inc. and Cameco Corporation (AREVA and Cameco). 2008. Rabbit Lake Solution Processing Environmental Impact Statement.

Document Integration:

Inclusion of Appendix XIV, Air dispersion modelling.

Changes are reflected in:  Appendix VII, Table 2.0-2  Section 8.3.1.3

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment HC-33 Comment:

Typographical or other document quality issues:

1. Tables 4.4-44 to 47: no map is provided for indicated sampling locations (some of which are not marked on general maps provided). 2. The Table of Contents for Section 4 (4-ii) does not correspond with sections. All entries are indicated that they occur on 4-57 from Section 4.4.2.2 to 4.6.4. 3. Font sizes on several tables are difficult to read (e.g. Table 4.4- 42; font size appears to be less than 6pts Arial)

ARC Response:

1. To clarify, Figure 4.4-6 depicts the locations of the most recent fish community surveys completed in the local assessment boundary. This includes the lakes for which fish tissue chemistry data were presented in Tables 4.4-44 to 4.4-47. It is acknowledged that Lake C1 was highlighted, but was not labelled in Figure 4.4-6. This has been corrected.

2. Acknowledged, the table of contents in Section 4 has been corrected.

3. Acknowledged, several of the tables presented in Section 4 have been reformatted for improved ease of reading.

Document Integration:

Figure 4.4-6 has been corrected and Lake C1 is labelled. Section 4 Table of Contents has been corrected and updated. To the extent possible, Tables have been reformatted to improve ease of reading.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment INAC-1 Comment:

INAC encourages the proponent to continue to consult with First Nations and other Northern communities in a transparent and meaningful manner. AREVA must summarize the results of this consultation in their EIS.

ARC Response:

Acknowledged, a detailed list of public consultation activities completed or planned is provided in Table 5.4-1. In addition, Table 5.4-2 provides a summary of questions and responses arising from the AREVA’s public consultation activities.

Document Integration:

No integration required. Technical Review Response: 2010 adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(1) Comment:

Page 1-10, 4th paragraph — rewording”... issuing a licence for the operation of an explosives factory and/or magazine under the Explosives Act.”

ARC Response:

Acknowledged.

Document Integration:

Section 1.3.2.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(2) Comment:

Page 1-10, 4th paragraph — last line, suggested rewording”... under these three Acts is a ...”.

ARC Response:

Acknowledged.

Document Integration:

Section 1.3.2.

Technical Review Response:

2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(3) Comment:

Page 1-11, last paragraph — Under last sentence, delete “the comprehensive study regulations”.

ARC Response:

Acknowledged.

Document Integration:

Section 1.3.3.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(4) Comment:

Page 1-13 — adjust date for Ministers track report decision.

ARC Response:

Acknowledged.

Document Integration:

Section 1.3.6.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(5) Comment:

Page 1-13 — 3’ paragraph, change last sentence to “Section 21.1 of the CEAA”.

ARC Response:

Acknowledged.

Document Integration:

Section 1.3.6.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(6) Comment:

Page 2-2 - beginning of section 2.2 — Add a line regarding 16(2) factors that are required for a comprehensive study.

ARC Response:

Acknowledged.

Document Integration:

Section 2.2.

Technical Review Response: 2010 Adequate

Regulator Comment / Response Comment NRCan-1(7) Comment:

Page 5-12 — the incorrect CEAR number is provided.

ARC Response:

Acknowledged.

Document Integration:

Section 5.6.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(8) Comment:

Page 5-12 — section title — drop CEAA.

ARC Response:

Acknowledged.

Document Integration:

Section 5.6.

Technical Review Response: 2010 Adequate

Regulator Comment / Response Comment NRCan-1(9) Comment:

Page 5-13. Reword sentence on public consultation on scope to as follows: “Federally, the responsible authorities shall ensure public consultation on a scoping document that meets the requirements of section 21(1) of the CEAA.”

ARC Response:

Acknowledged.

Document Integration:

Section 5.6.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(10) Comment:

Page 5-13. Revise the following sentence — “...., the factors to be considered, the scope of those factors, public concerns....”

ARC Response:

Acknowledged.

Document Integration:

Section 5.6.

Technical Review Response: 2010 Adequate

Regulator Comment / Response Comment NRCan-1(11) Comment:

Footnote 4 — It’s a Track Report, not the CNSC Track Report. As well, the last line in this footnote does not make any sense.

ARC Response:

Acknowledged.

Document Integration:

Section 5.0.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(12) Comment:

Footnote 5 — Federal review comments, though part of the CEAR project file, are not consulted on with the public.

ARC Response:

Acknowledged.

Document Integration:

Section 5.6.

Technical Review Response: 2010 Adequate

Regulator Comment / Response Comment NRCan-1(13) Comment:

Section 6—No mention is made of “construction” when discussing the methodology. This term should be added where appropriate.

ARC Response:

Acknowledged.

Document Integration:

Construction "has been added throughout the main text of Section 6.0, as well as in Tables 6.1-1 and 6.3-1.

Technical Review Response: 2010

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-1(14) Comment:

Page 95 2nd paragraph, and elsewhere in the document- It is COSEWIC, not COS1WIC.

ARC Response:

Acknowledged.

Document Integration:

COS1WIC has been changed to COSEWIC.

Technical Review Response: Adequate

Regulator Comment / Response Comment NRCan-1(15) Comment:

Page 10-3, 1st paragraph: In the second last sentence, change to the following: “That is, the scope of the cumulative effects assessment includes all... .“. The scope of the project is as per Section 2.1.

ARC Response:

Acknowledged.

Document Integration:

Section 2.1 has been added to Section 10.2.1.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-2 Comment:

Page 2-7 – Was the Gunnar mine decommissioning considered in the cumulative effects assessment regional study area?

ARC Response:

The Gunnar mine is located appoximatley 300 kilometers from the Midwest project and was not considered in the cumulative effects assessment.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-3 Comment:

Section 3.3.4 – Please clarify the status of the road further. In the document, it is referred to as a private road. In this section, it says “…it is not expected that it will not be designated as a public road.” What have been the experiences at the existing site access road at the McClean Lake Operation? Has there been any monitoring of this? Has this resulted in increased hunting pressures in the area? Other than the beginning and end points of the road being within site security gates, are there other measures are in place to ensure this is a private road? This type of information should be integrated into the EIS as appropriate.

ARC Response:

AREVA proposes in Section 3.3.4 that the Midwest to McClean Lake Haul road will be a private road with access points controlled by security gates on the McClean Lake Operation and Midwest sites. Berms will constructed to limit access by vehicles at the intersection of non-operational trails and access points along the dedicated haul road.

Daily environmental inspections of the McClean Lake site over its 10 year operating period have documented one animal which may have been shot by a hunter on or near the McClean Lake Site. Road activity along the highway to the McClean Lake gatehouse is not monitored but unauthorized vehicles approaching the gatehouse are recorded. Approximately two unauthorized vehicles per year approach the gatehouse. Typically hunters park on the main road and travel by snow machine or quad and do not utilize the private McClean Lake road. With the access control points and mitigations in place it is expected that there will be a negligible influence on hunting pressure from the introduction of the dedicated Midwest haul road.

Document Integration:

Main Document, Section 6, Table 6.2-1.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-4 Comment:

The mitigation measures presented in Table 6.3.1 provide a summary and do not appear to be inclusive. The Proponent refers the reader to Section 3 for further mitigation detail. This table needs to be restructured to be more inclusive and effective. There should be: 1 the addition of a construction column and associated mitigation column, 2 verification that all identified mitigation measures are captured, and 3 referencing to relevant sections for further mitigation detail.

For example, in Table 6.3.1, for ‘material haulage’, under mitigation for malfunctions and accidents, there is no mention of the spill response, yet this is an integral measure identified in 3.7.3.

ARC Response:

A construction category and associated potential Project-environment interactions, and anticipated residual effects for construction activities have been added to Tables 6.1-1 and 6.3-1. Mitigation measures described in Section 3.0 have been included in Table 6.2-1.

Document Integration:

Anticipated residual effects for construction activities have been added to Tables 6.1-1 and 6.3-1. Mitigation measures have been included in Table 6.2-1.

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-5 Comment:

Table 6.4.1 does not appear to capture any residual effects resulting from construction (i.e., habitat loss). This should be adjusted accordingly.

ARC Response:

A construction category and anticipated residual effects relating to construction activities has been added to Table 6.3-1. Mitigation measures described in Section 3.0 have been included in Table 6.2-1.

Document Integration:

Anticipated residual effects relating to construction activities has been added to Table 6.3-1. Mitigation measures have been included in Table 6.2-1.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-6 Comment:

Table 6.2.1 identifies a negligible effect on wildlife habitat, yet under sections 7.2.1.2 and 9.2.2, there are detailed discussions on the percent of wildlife habitat that will be lost. This table should be reconciled with the subsequent discussions of effects/ significance and vice- versa for all identified effects.

ARC Response:

Habitat loss has been identified in Section 6.0 as having a residual effect on wildlife. Anticipated residual effects to wildlife from habitat loss are discussed in Section 7.0, and the significance of these residual effects is discussed in Section 9.0.

Document Integration:

Section 6.3.4, Section 7.1.1.5, Section 7.2.3.4, Section 9.2.5, and Section 9.4.5.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-7 Comment:

Section 11 – The introductory paragraphs mention determining the significance of residual effects, yet subsequent paragraphs, which discuss effects of the environment on the project do not make any conclusions regarding significance. This should be rectified where appropriate.

ARC Response:

Acknowledged.

Document Integration:

Summarized in Section 13, Table 13.0-1

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-8 Comment:

Assessment of alternatives – general methodology is provided. Subsequently, alternatives are discussed under particular elements and not as a whole. For the purposes of a CSR, a stand-alone section on alternatives will be required.

ARC Response:

AREVA Resources Canada Inc. has provided a section on the summary of alternatives considered for the comprehensive study report.

Document Integration:

Section 3.11

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-9 Comment:

Page 12-3 – 3rd paragraph: follow-up is also intended to determine the effectiveness of mitigation measures. This should be added.

ARC Response:

Acknowledged.

Document Integration:

Section 12.1.2

Technical Review Response: 2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-10 Comment:

Recommendation #1:

a) The Proponent states that the perimeter mine de-watering wells will be routinely tested, but no details such as the frequency or number of wells to be tested are given (Main Document, Section 3.2.5.1). Could the Proponent please provide further details on the planned testing including but not limited to the frequency and number of perimeter mine de-watering wells to be tested during the different phases of the project (i.e., operations, closure, post-closure, etc.)?

ARC Response:

The anticipated monitoring program and frequency at the proposed Midwest Dewatering Well System (DWS) will be consistent with the current DWS monitoring program and frequency conducted for the JEB DWS as outlined in the McClean Lake Operation Environmental Monitoring Program (EMP) (AREVA 2008). As outlined in the EMP, the individual JEB DWS are sampled quarterly for a suite of parameters including general water quality parameters, metals, and radionuclides. Flows (m3) from the individual DWS are measured daily. As stated in Section 3.2.5.1 of the Midwest Project EIS, the Midwest DWS will have the ability to divert water from wells producing clean water away from the WTP. Monitoring for this clean water discharge will be consistent with current monitoring of the JEB DWS which is sampled every 12 hours (12 hour composite sample) and analysed for general water quality parameters, metals and Ra-226. In addition, a monthly composite sample is taken and analysed for a broader suite of parameters. Dewatering discharge, determined to be contaminated, will be directed to the WTP. The monitoring frequency consists of monthly and quarterly (grab samples) samples analysed for general water quality parameters, metals and radionuclides. Flows for both the clean and contaminated discharges will be measured daily.

The Midwest dewatering well design and monitoring program will be finalized and incorporated into the EMP during the CNSC licensing process. A separate EA and licensing will need to be completed for the closure and post-closure phases of the Midwest Project, and as part of these processes, the DWS monitoring program will be revised as needed.

REFERENCE:

AREVA Resources Canada Inc. (AREVA). 2008. McClean Lake Operation Environmental Monitoring Program Locations, Frequencies and Parameters. Version 7. September 2008.

Document Integration:

No integration required.

Technical Review Response:

2010 Follow-up program for impacts to groundwater quantity resulting from Midwest mine dewatering activities.

The Proponent indicates that individual Dewatering Well System wells are sampled quarterly for a suite of parameters including general

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment water quality parameters, metals, and radionuclides

Could the Proponent clarify if all the dewatering wells are to be sampled or just a selection of wells?

Also, as quarterly sampling may not be sufficient at the onset of the Operations phase (i.e., as the operations begin, flow conditions, mixing of waters, and water chemistry may be changing more rapidly at this time and a single sample during this period may not be representative of water quality), it is recommended that the Proponent consider more frequent sampling of dewatering well waters during the first several months of Project operation.

ARC Response:

To clarify, the JEB dewatering wells are currently sampled on a quarterly basis. June 2010 The frequency of dewatering well monitoring at Midwest will be determined and finalized during the licensing process.

Document Integration:

None required

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-11 Comment:

Has the Proponent considered the possibility of treating pore water of the special waste rock in the backfilled open pit to remove contaminants (specifically arsenic and nickel) in order to reduce excessive input of these constituents to the deep groundwater system and surface water receiving environments? The Proponent could examine possibilities for treatment to see if peak arsenic concentrations in Collins Creek (thousands of years past Project decommissioning) can be reduced. It seems unlikely that the existing network of open pit perimeter wells could be used, as they are positioned and designed to intercept inflow of shallow groundwater rather than downward flow of groundwater to the deep flow system.

ARC Response:

Experimental trials for the remediation of the Midwest special waste rock are currently underway at AREVA. To reduce the amount of target contaminants released due to oxidation from the placed special waste. A system of biological reduction is in the initial phases of testing.

The goal of this work is to promote a reducing environment in the flooded pit where the special waste rock will be placed for long term storage. This reducing environment will allow biological reduction of sulphate which, in turn, will incorporate elements of concern into more stable sulphide mineral phases.

AREVA is committed to continued testing of this option that will consist of several stages. Currently, a first stage of testing is looking at the effectiveness of various additives that would optimize pit water conditions for microbiological growth and mineral formation. Similar biological strategies have been used in the past for remediation of various contaminants including metals (for example permeable reactive barriers; Scherer et. al. 2000)).

REFERENCE:

Scherer, M. M., Richter, S., Valentine, R.L. and P.J.J. Alvarez. (2000) Chemistry and Microbiology of Permeable Reactive Barriers for In situ Groundwater Clean up. Critical Reviews in Environmental Science and Technology. 30:3, 363-411.

Document Integration:

No integration required.

Technical Review Response:

Potential impacts to groundwater quality resulting from waste rock mined and stored at the Midwest site.

2010 The Proponent indicated in the Addendum response that experimental trials for the remediation of the Midwest special waste rock are currently underway to reduce the amount of contaminants released from the placed special waste

The Proponent is testing the use of additives to promote a reducing environment that will allow biological reduction of sulphate to convert elements of concern into more stable sulphide mineral phases, similar to technology used in permeable reactive barriers. This initiative is

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment promising. However, existing literature reveals that results can vary depending on local conditions and may or may not be that effective in reducing arsenic concentrations.

NRCan expects that the proponent will keep regulators informed of the progress of this work, and provide details (e.g., scale and methodology, test results, and predictions for its application to proposed projects in terms of pore water chemistry and concentrations of elements of concern in groundwater and surface water receiving environments) as appropriate.

ARC Response:

The experimental trials for the remediation of the Midwest special waste rock are incorporated in the Ongoing Waste Rock Management programs as described in section 12.3.3 of this document. These programs were developed to support the validation of EA predictions at June 2010 the McClean Lake Operation in parallel with operation. Updates regarding the progress of this work will be incorporated in the McClean Lake Operation Annual Report which is prepared according to the Harmonized Annual Reporting Requirement, 2006 document issued jointly by the Canadian Nuclear Safety Commission, Saskatchewan Ministry of Environment, and Saskatchewan Ministry of Advanced Education, Employment and Labour.

Document Integration:

No integration required

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-12 Comment:

Text in Appendix IV states that approximately 20 000 m3/day of groundwater will be extracted from the dewatering wells and that the amount of water reporting to the in pit sump will increase gradually from near zero at the beginning of pit development to maximum values on the order of 5000 m3/day at the end of mining (Appendix IV, Section 6). Does this statement imply that as the water reporting to the in pit sump increases, the volume of water being collected by the dewatering wells will decrease by the same amount?

ARC Response:

The dewatering wells will lower the water table to a certain level in the sandstone. For the upper benches of the pit, the amount of water that is not intercepted by the dewatering wells should be small because the water level in the sandstone can be brought to a level just below the bench elevation using the dewatering wells which will reduce the sump flow to near zero. Near the base of the pit, because of the differences in hydraulic conductivities between the basement rock and the sandstone and well inefficiencies, it is not possible to dewater the sandstone (and basement rock) to an elevation below the deepest benches. This results in larger volumes of water reporting to the sump.

Document Integration:

No Integration required.

Technical Review Response:

2010

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-13 Comment:

Recommendation #2:

a) Considering that there are possible long-term detrimental effects to the S/V TEMS and that the majority of these effects will result directly from the deposition of treated effluent from the Midwest site, has the Proponent considered increasing the level of treatment, particularly for contaminants that will be a concern, at the Midwest water treatment plant or within the S/V TEMS? If feasible, this could reduce contaminant concentrations in the S/V TEMS and downstream receiving environment.

ARC Response:

The treatment system proposed for the Midwest Project incorporates the current state-of-the-art in mine water treatment technology. As discussed in the response to comments CNSC-28 and CNSC-8, the quality of the combined reverse osmosis and conventional water treatment plant discharge is expected to routinely meet provincial and federal water quality guidelines/objectives for the protection of aquatic life. Exceedance of water quality guidelines/objectives is predicted to occur only under extreme circumstances (i.e. at the 80th percentile level or above).

Contrary to the impression that the Midwest effluent will be the primary source of contaminant input to the Sink /Vulture Treated Effluent Management System (S/V TEMS), the effluent discharges from the McClean Lake Operation will continue to be the major source of contaminant input to the S/V TEMS. Experience has shown that the S/V TEMS is an effective component of the treated effluent management system in that supplementary removal of several of the contaminants occurs primarily in Sink Reservoir. The enhanced removal is believed to be attributable to the co-precipitation of several constituents with iron hydroxide that is introduced to Sink Reservoir with the JEB pit dewatering well system.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-14 Comment:

Recommendation #2: b) Considering that molybdenum (Mo) is a constituent of concern in the S/V TEMS and downstream receiving environment, it is recommended that the Proponent consider further Mo recovery and packaging of Mo as a by-product, as mentioned by the Proponent (Main Document, Section 3.4.3.1).

ARC Response:

In general, molybdenum (Mo) bearing minerals are contained within the ores feeding the JEB mill and a considerable quantity of the Mo

from these minerals dissolves during the leaching unit process. As mentioned in the Main Document Section 3.4.3.1, AREVA may install

additional internal process equipment to produce Mo as a by-product. The principle purpose for doing this is to provide improved circuitry

for the removal of Mo prior to uranium precipitation to control Mo concentrations to refinery specifications in the final yellowcake product.

In the current JEB mill and water treatment plant operation a large majority (approximately 99.6%) of this dissolved Mo is removed from

solution and approximately 0.4% is released to the receiving environment. The Mo removed from solution is equilibrium controlled and is

primarily contained within iron rich sludges. These solids are incorporated into other tailings solids for final disposal in the Tailings

Management Facility (TMF).

AREVA has considered the effect these additional processes may have on the Mo content in the final treated liquid effluent. It is concluded

that no further reductions in the Mo content in the final treated liquid effluent are anticipated.

Document Integration:

No integration required.

2010 Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-15 Comment:

Recommendation #2:

c) Has the Proponent considered that the 25 000 m3/day capacity of the Water Treatment Facility at the Midwest site may not be sufficient to treat all sources of water from the site. Is there a contingency plan? Please clarify what the total rate of water collection into the Midwest open pit from all major sources will be at different stages of mining. As the water reporting to the in pit sump increases, does the volume of water being collected by the dewatering wells decrease by the same amount?

ARC Response:

Simulations (Appendix IV, section 4) suggest that during the first three years of mining the dewatering wells will intercept most of the 3 groundwater flow through the pit and that the in-pit sump dewatering effort should be limited. During this period the 25,000 m /day capacity of the proposed water treatment facility is considered to be sufficient to treat all sources of water from the site, including water pumped out from the dewatering wells, in-pit sump water, site runoff and leachate from the waste rock piles.

At the end of mining the dewatering wells may not intercept entirely the groundwater flow especially in the lower levels of pit. Subsequently 3 3 the in-pit sump dewatering effort may increase substantially (i.e., inflows predicted to range from 3,000 m /day to 6,000 m /day). However, it is considered that the capacity of the water treatment plant will still be sufficient to treat all site water because part of the water pumped out from the dewatering wells is expected to be clean groundwater requiring no to limited treatment. Typically, the pre-sedimentation ponds, 3 which are sized to 30,000 m /day, are available to augment water management.

Document Integration:

Main Document, Section 3.5.1.2

Technical Review Response:

2010 Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-16 Comment:

Recommendation #3: Has the Proponent assessed how similar the tailings from the Midwest site will be to tailings from existing operations? Please explain.

ARC Response:

The initial operating licence for the JEB mill and TMF was granted in 1999. This operating licence was preceded by environmental assessments approved by both the federal and provincial Ministers of Environment in 1998 (1995 Midwest Project EIS, 1995 Cigar Lake Project EIS). A requirement for these EAs was to consider the long-term effects in terms of the release of contaminants from the decommissioned TMF to the receiving environment. The EAs considered the potential effects from the TMF filled to capacity with tailings produced from all the ores expected to be processed by the JEB mill. At that time, the foreseeable ore sources included the JEB, Sue A, Sue B, Sue C, McClean underground, Midwest and Cigar Lake ore deposits.

Laboratory tailings were generated from each of these sources using the JEB mill process and the proposed tailings preparation process. The final tailings samples were then subjected to geochemical stability (aging tests) and geotechnical test work. Two key parameters affecting the long-term performance of the TMF were identified: one geochemical and one geotechnical.

The geochemical parameter was the long-term arsenic concentration in the tailings pore water (As source term). It was observed that following the proposed tailings preparation process and aging test protocols that the source term was approximately 1 mg/L As for all the ores tested. The key geotechnical parameter was the hydraulic conductivity, measured under a confining stress to approximate fully consolidated tailings in a TMF filled to capacity. Again, it was observed that the measured hydraulic conductivity from tailings made from each of the ore sources all fell within a narrow range. The values for these two parameters were then incorporated into the design criteria for the TMF.

In summary, the available information on Midwest tailings is equivalent to that obtained for all of the McClean Lake ores for which AREVA is currently licensed to process. This information indicates that the long term effects from tailings produced from Midwest ore will be similar to current and previously produced tailings after final disposal in the TMF.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCAN-17 Comment: Could the Proponent please specify if the drivers of vehicles transporting ore on the dedicated haul road will be trained in emergency spill response procedures?

ARC Response: The McClean Lake Operation maintains comprehensive emergency response capabilities including that for responding to spills of radioactive materials.

Ore hauling vehicles will be equipped with radios and drivers will be trained in basic spill response techniques. In the event of a spill, drivers would be instructed to call for assistance and control the incident scene until help arrives. As necessary, drivers would be instructed to take appropriate measure to contain the spill without putting themselves at risk.

Document Integration:

No integration required

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-18 Comment:

Recommendation #4:

b) Could the Proponent please list the storage location of each of the following reagents used in the JEB mill circuits (Main Document, Table 3.4-2): Sulphuric Acid, Flocculant, Kerosene, Amine, Isodecanol, Ammonia, Sodium Carbonate, Carbon, Sodium Hydroxide, Lime, Barium Chloride, Ferric Sulphate, Cationic Resins, Hydrogen Peroxide, Oxygen.

ARC Response:

A list of the storage locations of the reagents has been prepared and included in Appendix XII. A list of these storage locations, the reagents, and their quantities is maintained within the site Fire Safety Plan, which is a required planning document under provincial regulation.

Document Integration:

Appendix XII, Tables 5 and 6.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-19 Comment:

Section 3.2.3.1 Where will the proponent get their explosives during the initial stages? To the best of NRCan’s knowledge there is an existing Dyno Factory Licence in McClean Lake. Further, NRCan does not issue a “temporary” factory licence for a permanent mine site.

ARC Response:

In effort to remove explosive supply from the project’s critical path, in the event that the new explosives facilities at Midwest are not completely constructed for the commencement of mining, the existing facilities at McClean Lake could be used initially on a temporary basis.

Document Integration:

Section 3.2.3.1

Technical Review Response:

Adequate

Regulator Comment / Response Comment NRCan-20 Comment:

Section 3.2.3.1 Will the packaged explosives in magazines be licensed provincially or federally?

ARC Response:

Federally

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-21 Comment:

NRCan requires the following information (Section 3): • Type of explosives to be manufactured plus maximum quantities of explosives? (Ammonium nitrate fuel oil (ANFO) and/or emulsion and/or watergel?). • The nature and number of mixing vehicles planned for the site? • The documentation indicates bulk storage silos of 260 000 kg capacity. What is the content of the silos? (ammonium nitrate? emulsion?). • Specified location (i.e., detailed site plan), with distances to vulnerable features such as dwellings, roads, camps, railways, bodies of water, etc. Infrastructures should be identified and include: explosives and detonator magazines, fuel storage, ammonium nitrate storage, maintenance/wash area, process trucks and their parking area, any offices, warehouses, buildings, etc. The proponent needs to demonstrate that safety distances required by the Explosives Regulatory Division (ERD) of NRCan have been considered and met. • Fuel, emulsion and ammonium nitrate storage plans. Storage of ammonium nitrate needs to be in conformance with ERD guidelines. • Liquid effluent disposal plans. • Evaluation of the worst case scenario, i.e. accidental explosion. • Spill contingency plans.

ARC Response:

At the McClean Lake Operation, the federal Dyno Facility Licence is issued to a contractor that supplies and prepares the explosives. Details on the factory licence are supplied at the time of licensing but a conceptual description is provided in the following paragraph.

The explosives plant will produce ANFO and Emulsion. Two mixing vehicles will be required (one for dry product only, one for emulsion). The silos will likely be 160,000kg for AN storage and 100,000kg for base emulsion storage. Detailed explosive site layout will be provided consistent with Explosives Regulatory Division. Strained liquid effluent (from wash bay) will be disposed of in our hydrocarbon land farm, solids will be destroyed in boreholes. Spill contingency plans will include precautionary measures during design stage (sloping ground from conditioner tank away from AN silos etc) as well as plans documented in the McClean Lake Operations existing IQMS system.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-22 Comment:

Figure 3.2-6 shows an "explosives mixing site". NRCan has the following comments:

• Will this be the future Factory site? NRCan will need to know the quantity of explosives on this mixing site and distances to vulnerable features. • Will the "cap magazine site" be licensed federally or provincially? • Where will the explosives magazine be located?

For further information on ERD guidelines, please refer to http://www.nrcan-rncan.gc.ca/mms/explosif/over/over_e.htm .

ARC Response:

Yes, this is intended to be the future factory site. It is anticipated that the cap magazine will licensed federally. Refinement of the precise location of the magazines is underway, with the anticipation that validation/verification of site design will be required for licensing. See other responses.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-23 Comment:

2. The methodology and findings of the characterization program are supportive of the project objectives; however, the characterization program does not appear to be rigorous. For instance, geochemical tests, observations and predictions are not supplemented by mineralogical data. There is a clear lack of mineralogical characterization data. This deficiency is not detrimental to the proposed undertaking and no further characterization work would be required in support of this EIS provided that the evaluations are supported by the characterization data available in supporting documents not presented as part of the EIS, and with the understanding that the proposed integrated monitoring and sampling programs during the mining and processing operations would enable early diagnosis of potential issues.

ARC Response:

A discussion of the Midwest deposit uranium mineralization has been added as the Midwest Project EIS Appendix XIII

Document Integration:

Midwest Project EIS Appendix XIII added.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-24 Comment:

3. The characterization work is based on the collection, analysis and testing of more than 6,000 waste rock and ore samples. The samples were collected from over 300 holes drilled for exploration and geotechnical testing purposes. It is not clear, however, how representative these samples are. How were the samples selected? Was there a sampling strategy? Were they selected randomly or with the aim to sample representative “end-member” rock types?

ARC Response:

Appendix VIII, Figure 3.1 shows the location of the boreholes used to collect the samples for the waste rock characterization work.

Initial exploration core samples were collected essentially within and in the vicinity of the alteration halo in the Midwest deposit. This included samples from the weathered basement gneiss, the basal conglomerate, the lower sandstone units and the clay minerals halo.

Samples collected from the 2004 geotechnical holes correspond to material from both the upper and lower sandstone units outside of the alteration halo in the Midwest deposit. Samples collected in 2006 correspond essentially to material from the upper weathered and upper unweathered sandstone above the alteration halo.

Document Integration:

Appendix VIII Section 3.1 Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-25 Comment:

4. If the proposed cut-off level of As is decreased from 200 to 75 ppm (App VIII, p. 27), the volumes of the special wastes would be increased substantially. What effect would this have on the proposed management plans?

ARC Response:

The cut-off level of arsenic (As) used to estimate the volumes of waste rock as part of the Midwest EA is in fact 75 ppm (see for instance, Appendix VIII, Sections 3.2.4 and 3.2.5, Appendix IX, Section 2.5). The assessments presented in the waste rock management plans are based on this 75 ppm As cut-off level.

The wording “proposed” is used to qualify the 75 ppm cut-off level (App VIII, p27) because the value of 200 ppm was used in previous environmental assessments associated with the McClean Lake Operation. As indicated in Appendix VIII, decreasing the cut-off level for arsenic maximizes the amount of material to be disposed in the pit and subsequently ensures the disposal of only clean waste rock in above ground stockpiles, with limited potential effects to the receiving environment.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-26 Comment:

Chemical compositions of the special waste rock indicate mineralogical differences (Table 4-3). For instance, Cu concentrations are significantly high in the first two waste rock samples, yet no Cu minerals are listed (Table 2-1) to account for the high Cu levels in the rocks. Please clarify.

ARC Response:

The minerals listed in Table 2.1 are the prominent minerals found in the ore zone of the Midwest Deposit. The minerals are listed in order of decreasing abundance. A copper bearing mineral in the ore zone of the Midwest deposit is chalcopyrite, a copper iron sulphide (Table 12, Appendix L, Midwest Uranium Project EIS Supporting Document V Volume 2. August 1991). The chemical formula for chalcopyrite is CuFeS2-. Sulphides are found as minor constituents in the ore zone but are the most significant mineralization in the sandstone remote from the high grade ore zone (Page 5-9, Section 5.0, Midwest Joint Venture EIS for a Proposed Uranium Mine and Mill. August 1991). This explains the higher concentration of copper in the special waste solids and lower abundance in the ore zone mineralogy.

The solids content of the constituents in the special waste rock samples listed in Table 4-3 indicate non homogeneous mineralogical differences between samples. One reason for the differences is explained in Section 3.1, where the variability and extensiveness of the Midwest project geochemical database is discussed. Section 2.1 also explains that the ore body core and the dispersion envelopes display distinct mineral-chemical differences.

The solids used for testing were selected to represent the range of reactivity of Midwest Project special waste and contained arsenic concentrations that ranged from 406 µg /g and sulphide concentrations from 0.11 to 1.14% S. Two columns (MWC1 and MWC2) were charged with relatively fresh core material (less than six months old) and two columns (MWC3 and MWC4) were charged with weathered core samples (eight years old). Mineralogical differences can also be seen in the Midwest Special Waste solids content of crushed drill core samples used for sequential leach tests in Tables 4.4 to 4.12.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-27 Comment:

6. Strong correlation between Ni and As (i.e. correlation coefficient of 0.94 based on over 4000 split samples as per Table 3-1) indicates that the sources of Ni and As are dominated by Ni-As minerals. However, the discrepancies between the water leachable As and Ni concentrations (e.g. p.27) are somewhat contradictory with this finding since one would have expected to observe similarities between the As and Ni releases unless the Ni-As mineral(s) dissolved incongruently (i.e. Ni and As releases controlled by the stoichimetry of the Ni-As minerals). Is the reported mineralogical composition based on direct determination (i.e. mineralogical characterization) or indirect (e.g. geochemistry)?

ARC Response:

The Midwest deposit is one of many uranium occurrences associated with the geologic contact and unconformity between the Athabasca sandstone and the basement rocks. The mineralization zone and surrounding rock is geologically similar to other ore bodies found in the region (e.g. McClean site (JEB, Sue Pits) and Cigar Lake). Significant study and research has been completed for the uranium deposits within the Athabasca Basin, and although the reported mineralogical composition of the rock found at Midwest was not determined through direct identification, assessment from the surrounding sites has identified the presence of nickel arsenides including gersdorffite (NiAsS), niccolite (NiAs), and rammelsbergite (NiAs2) (e.g. Watkinson et al., 1975; Donahue, 2000).

The cause for differences in the leachability of arsenic and nickel is not completely known, and was not investigated as part of the waste rock investigations for the Midwest EIS. However, the differences may be due to incongruent dissolution or other geochemical controls that may cause nickel to revert back to the solid phase after initial co-dissolution with arsenic. This is not surprising because the geochemistry of nickel (Ni2+) and arsenic (H2AsO4-) is quite different. Furthermore, numerous tests on similar mineralized samples have shown that nickel is not problematic in the context of special waste management at these uranium deposits.

Reference  Watkinson, D.H., Heslop, J.B. and Ewert, W.D. 1975. Nickel and Sulphide-Arsenide Assemblages Associated with Uranium Mineralization, Zimmer Lake Area, Northern Saskatchewan. Canadian Mineralogist. 13, p198-204.  Donahue, Robert. 2000. Geochemistry of Arsenic in Uranium Mill Tailings, Saskatchewan, Canada. Ph.D Thesis, Department of Geological Science, University of Saskatchewan, Fall 2000.

Document Integration:

Appendix VIII, Section 4.4.1

Technical Review Response:

The response is generally adequate with the consideration that the tests on mineralized samples indicated that Ni behaviour is not problematic. However, there are vague statements in the response such as nickel reverting back to the solid phase and other geochemical controls. What is the solid phase being referred to? What does the proponent mean by “other geochemical controls”?

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-28 Comment:

7. It appears that the As bearing minerals in the ore and waste rock are highly soluble. The reason for the observed correlation between the soluble As concentration and total As concentrations of the rock samples is that the amount of As-bearing minerals exposed on the surfaces of the waste rock fragments is representative of the bulk. In other words, the As mineral grains are about the same size and uniformly distributed throughout the rock. This observation should be taken into consideration during further predictive assessments.

ARC Response:

Acknowledged

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-29 Comment:

8. What is the solubility of Ca arsenate (App VIII, p.23, 3rd paragraph)?

ARC Response:

Calcium arsenate (Ca3(AsO4)2) solubility is pH dependant. The solubility of As in equilibrium with Ca3(AsO4)2(s) as a function of pH is presented in the figure below, and suggests that the lowest solubility is found between pH values of about 11.5 to 12.5 (Nishimura et al., 1985). At neutral pH, arsenic concentrations can be a few hundreds of mg/L, while at pH values around 12, the arsenic concentrations may be constrained to a value near 10 mg/L.

REFERENCE:

Nishimura, T., C.T. Ito, K. Tozawa and R.G. Robins. 1985. The Calcium-Arsenic-Water-Air System. In: Proc. 24th Conference Mettalurgists, Vancouver, August 1985.

Document Integration:

Appendix VIII, Section 5.1, Figure 5.2

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-30 Comment:

9. What is the rationale that the solution to solid ratio of 50:1 was high enough in extraction tests so that the observed As concentrations were not controlled by solubility (App. VIII, p.23)?

ARC Response:

The extraction tests were completed at neutral pH. Based on the solubility of calcium arsenates at this pH range, as discussed in response to Comment NRCan-30, the solubility of As in equilibrium with Ca3(AsO4)2(s) is on the order of 240 mg/L, which is lower than the concentrations observed in the extraction tests. There are no potential solubility constraints for the concentration of constituents observed in these leach tests.

None-the-less, the material evaluated in these extraction tests is now considered special waste based on the segregation criteria proposed for the Midwest Project; this material will be disposed of sub-aqueously in the Midwest pit. Therefore, the additional tests by sequential leaching provide useful estimates for the water quality expected to be associated with the submerged waste.

Document Integration:

Appendix VIII, Section 5.1

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-31 Comment:

10. The reported average As content of the Earth’s crust (i.e., 10 ppm) is too high (App. VIII, p.26)? What is the reference? According to NRCan’s data sources, the average As concentration is only 1.5 to 2 ppm.

ARC Response:

The reported average crustal abundance for arsenic of 10 ug/g (ppm) is a typographical error and should read 1.0 ug/g (ppm) as referenced by Faure and Gunter (1998). All interpretation of arsenic concentrations was based on the value of 1 ppm and not 10 ppm.

REFERENCES:

Faure and Gunter. 1998. Principles and Applications of Geochemistry. Prentice Hall. New Jersey 600pp.

Document Integration:

Appendix VIII-typographical error has been corrected.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-32 Comment:

11. It was stated on p.26 (App. VIII, 2nd par.) that As may not be released from the waste rock. The testing period appears to be rather short for this assessment, however. Please provide a rationale for the testing period chosen.

ARC Response:

The modified humidity cell testing was only completed as a screening evaluation of the dynamic leaching rates that could be expected with the clean waste rock material when stockpiled on surface. It is known that when acid generation is not of concern (ie. neutral conditions), leaching rates are generally the highest after initial deposition, and decrease with time. The material used in the modified tests was initially rinsed to remove any readily soluble metals from the rock. The metal release was then monitored for 20 days. These tests exhibited concentrations of constituents of concern that were near or below detection, with no observable increasing trend, and the testing was therefore terminated. The test period was selected only to provide confirmation that key constituents, such as arsenic, did not continue to leach at important rates after initial rinsing of the clean waste.

Document Integration:

Appendix VIII, Section 5.2.1 & 5.2.2

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-33(1) Comment:

12. Effluent treatment involves Ba chlorite addition to remove Ba-226, ferric sulphate addition to remove As from the solution, and lime addition to control the pH at 7.5-8.5. Elements of concern in the effluents originating from the JEB facility are fixed by precipitation as hydroxides and by ferric adsorption. Specifics of these processes are not provided; therefore, it is difficult to gauge their effectiveness during effluent treatment. Please elaborate on these processes.

ARC Response:

From the nature of the comment, AREVA is assuming that the technical reviewer is referring to the tailings preparation unit process as opposed to the water treatment plant. This process has been previously assessed, approved, licensed (see response to Comment NRCan- 16) and has been operating for the last nine years. For the Midwest Project, no changes to this process are required so only an overview of the tailings preparation process is provided in Section 3.5.3 in the EIS. Further description of the tailings preparation unit process and how it is controlled can be found in the licensing documentation for the McClean Lake Operation (Facility Description Manual, Quality Assurance Manual).

In the JEB mill, the waste solutions, primarily raffinate, and the waste solids, primarily washed leach residue, are treated together in a single tailings preparation process prior to final disposal in the TMF. All the plant waste solutions and solids are first mixed in an agitated feed box. The pH of the combined slurry is generally <1.5. Ferric sulphate and barium chloride are also added in a controlled manner to this tank. Outflow from the feed box reports to the neutralization process which is carried out in two stages. In the first stage lime is added to a single reactor tank to maintain a controlled pH of 4. A second stage of neutralization follows in a second reactor tank to achieve the terminal pH of approximately 7.5 (see Section 3.5.3, Figure 3.5-6).

The principle function of this process is to prepare the final tailings so that the pore water concentration of certain constituents of concern in the placed tailings are controlled to sufficiently low values for the long term. From earlier environmental assessments, (see response to Comment NRCan 16), the principle constituent of concern was identified as arsenic. However, the process also was designed to control nickel and radium. Overall, the performance of the tailings preparation circuit is well known.

Arsenic pore water control begins in the agitated feed box. On a 24 hour composite basis, the total arsenic and ferric iron concentrations are measured in the solution component of the slurry. The ferric sulphate flow rate is then adjusted to achieve an Fe3+/AsTot molar ratio of at least 3. This occurs at pH <1.5 prior to any neutralization. As the pH is raised in the first reactor tank essentially all of the arsenic is precipitated in a chemical phase identified as poorly crystalline scorodite (FeAsO4·2H2O). Under conditions of saturated gypsum, as exists in the tailings preparation circuit, most of the scorodite remains in the pH 7 range. It is emphasized that this process specifically treats for arsenic: as the quantity of arsenic in the ore increases the amount of ferric ion added goes up accordingly. Overall, the process has consistently controlled As concentrations at 1 mg/L or less for the first nine years of operation.

The terminal pH selected for the second reactor tank is the primary parameter for controlling the Ni pore water concentration. Primarily Ni is considered to be removed from solution as an insoluble hydroxide. As the pH is raised above 7, Ni concentrations decrease but As concentrations increase. The terminal pH selected is then “optimized” for the removal of As and Ni so that the pore water concentrations for both elements are consistently controlled to 1 mg/L or less. This typically occurs over a pH range from 7.5 to 7.8.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-33(1) Radium-226 control is effected by the addition of barium chloride. Under conditions of saturated gypsum this promotes the precipitation of (continued) barium sulphate. The radium is incorporated within the barium sulphate crystal and is removed solution. The radium-226 concentrations are generally controlled to <5 Bq/L in the tailings pore water.

Document Integration:

No integration required.

Technical Review Response:

Since the process has already been licensed, the response is acceptable. While the use of “poorly crystalline scorodite” for an amorphous compound is wrong, this is just a technicality considering the performance of the process during its nine years of operation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-33(2) Comment:

13. It appears that there are reduced species of As in the effluents. This ambiguity should be clarified in the EIS. What are the As species and in what proportion do they occur? It should be kept in mind that the ferric coprecipitation process aiming to achieve Fe/As molar ratios of 3 or 4 and greater is based on As occurring as 5+ state. If there is an experimental evidence for the stated control limit of Fe3+/Astotal=3, it should be provided.

ARC Response:

Mill waste solutions at low pH (<1.5) typically have reduced species present. For example, in the agitated feed box at the start of the tailings preparation circuit the As3+/As5+ concentration ratio is generally 0.25 and the Fe2+/Fe3+ value is 0.40. However as the pH is raised during neutralization the reduced As and Fe species become unstable and convert to the oxidized form. We have not observed an oxidation state other than 5+ for arsenic in the neutralized solids.

The optimum value for the Fe/As molar ratio control parameter of 3 to 4 was established through laboratory test work contained in the environmental assessment which supported the initial JEB mill and TMF operating license approximately 10 years ago. Operational experience has since confirmed that the value of this parameter must be at least 3 to achieve arsenic pore water predictions. To ensure that we are being conservative and to remove uncertainty concerning how much ferric sulphate to add, the key arsenic control parameter has been further refined and is now evaluated as the Fe3+/AsTot molar ratio.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-34 Comment:

14. There are statements in reference to amorphous scorodite, poorly crystalline scorodite (ferric arsenate), poorly crystalline annabergite (nickel arsenate) and poorly crystalline theophrastite (nickel hydroxide). It is not known what “poorly crystalline” refers to. Is it based on direct observation or inferred from the geochemistry? A brief explanation including their composition, structure and the characterization techniques employed should be provided.

ARC Response:

At the time of initial licensing for the JEB mill and TMF (1999) uncertainties existed with respect to several key performance parameters for the TMF which could not be resolved by reinterpretation of the existing data, or further bench scale testing. Operational experience coupled with on-going research on production tailings was required to further resolve these issues. As a result, it was required of Cogema (now AREVA) to submit a licensing document called the “Tailings Optimization and Validation Program” (TOVP – March 1999). The TOVP is essentially an open ended research program that provides a major update report every five years to confirm on-going satisfactory results and that long-term projections are meeting the desired objective. The first 5 year report entitled “McClean Lake Operation, Tailings Optimization and Validation Program, Validation of Long-term Tailings Performance Report” was issued in September 2005. In this report AREVA was able to conclude “that the designs of the tailings preparation process and the tailings management facility have been validated with respect to the long-term protection of the receiving environment”. (Both these TOVP documents are available to the public at CNSC offices).

A key component of the TOVP involves mineralogical investigations for the identification of iron, arsenic and nickel mineral phases produced by the tailings neutralization circuit. Ultimately, using arsenic as an example, over the long-term it is the mineral form containing arsenic in the TMF sediments that will control the arsenic concentration in the pore water it is in contact with.

Arsenic fixation using iron has been the topic of numerous studies by researchers for several decades. Despite this, there remains much debate in the scientific community regarding the nature of what occurs on a molecular level under a variety of conditions. Neutralization of strongly acidic iron bearing raffinate solutions typically results in iron rich solids of insufficient long range order to allow direct identification of molecular structure by x-ray diffraction spectrometry techniques. On account of this, the structure of the iron rich solids is frequently referred to as being amorphous. The constituents of arsenic and nickel are incorporated within these solids. The prevalent view in the scientific literature for the past two decades regarding the mechanism for the fixation of arsenic, is that pentavalent arsenic, in the form of arsenate, is adsorbed onto the surface of the mineral ferrihydrite.

Under the TOVP, extensive laboratory studies were carried out over a period of several years to identify and quantify the secondary minerals produced during the neutralization step of the tailings preparation process. This work, as well as that of others reported recently, supports a different position. The evidence indicates that poorly crystalline mineral phases result from the neutralization of acidic hydrometallurgical process streams containing relatively high concentrations of arsenic and iron.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-34 To evaluate the mineralogy of the neutralized solids AREVA used a team approach using mineralogy consultants of global repute from the (continued) Colorado School of Mines, McGill University along with its own internal scientific resources. Several series of raffinate neutralization experiments were completed at the McClean Lake Operation on actual plant raffinate from the JEB mill. The tailings preparation process used in the plant was applied to the laboratory tests except that only the raffinate was neutralized and the precipitated solids were collected at incremental pH values from 2 to the plant terminal pH of approximately 7.5.

The solid samples were sent to the Colorado School of Mines for mineralogical investigation. Arsenic was identified as being present as an amorphous scorodite in all samples. The assignment of arsenic to amorphous scorodite was due to a combination of direct observation (XRD,SEM microprobe) and inference from geochemistry. This work has been published in Applied Geochemistry 22 (2007) 2758-2776. At a later date, samples from these neutralization experiments were sent to the Canadian Light Source Inc. for EXAFS analysis. They found that the orientation of Fe nuclei around As atoms was similar to that of crystalline scorodite. This work has been accepted for publication in Geochimica et Cosmochimica Acta (Feb. 2009).

At the same time, it was observed that arsenic precipitated by ferric ion under conditions that are similar to the JEB mill tailings preparation process exhibited scorodite XRD patterns after sufficient aging. At this point, AREVA internally changed its description of this material from amorphous scorodite to poorly crystalline scorodite. Amorphous scorodite is an apparent contradiction in terms. If a material was truly amorphous then there would be no structure. On the other hand, the samples investigated possessed an iron-arsenic structure similar to scorodite. It is not crystalline scorodite because the co-ordination number and interatomic distances are slightly different likely due to a very small domain size. Since upon aging crystalline scorodite develops, we are of the opinion that poorly crystalline is an appropriate and accurate description of the arsenic mineralization precipitated in the tailings preparation circuit.

Less effort was expended identifying poorly crystalline annabergite and theophrastite. The identification was mostly inferred from geochemistry however microprobe work supported the elemental associations and XRD spectra showed slight but consistent “background mounding” in areas where dominant peaks from the crystalline minerals would be expected.

Document Integration:

No integration required.

Technical Review Response:

The first four paragraphs are descriptive. There are technical problems with the reminder of the response. However, for the purposes of the EIS, the response is adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-35 Comment:

15. The report states that As is present primarily as a chemical precipitate in the form of a poorly crystalline scorodite (p.12-10). How is the stated solubility of 1 mg/L As for this compound established? Ferric arsenate solubility is much higher than 1 mg/L As at all pH ranges. The stated limit is only possible for scorodite at a narrow pH range (i.e. pH 2-3) according to most recent assessment of the solubility data by Langmuir et al. (2006).

ARC Response:

The 1 mg/L solubility value for As in the tailings pore water was established primarily from the long term performance of the tailings neutralization circuit. Initial testing shown in Langmuir et al. (1999) demonstrated that it was feasible to reduce arsenic to these levels through adjusting the Fe:As ratio. This was confirmed through the TOVP, and in additional laboratory testing shown in Mahoney et al. (2007). That paper demonstrates (Figure 4) that concentrations less than 1 mg/L can be attained at pH values of 7. Modeling of that data also indicated that an increase in stability for the “scorodite” was required as the pH increased. With the final two samples requiring a – log Ksp value of 25.55, which certainly qualifies as poorly crystalline scorodite and approaches the crystalline scorodite value of 25.87. Some of the laboratory data described in detail in Mahoney et al. (2007) is also shown in the Langmuir et al. 2006 paper and it also indicates total As concentrations of less than 0.5 mg/L at a pH of 7.32 (Table 5, Figure 11).

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-36 Comment:

16. Why would the pH range of 7.5-8.5 maximize the efficiency of As precipitation by ferric sulphate (p.3-67)? Aren't the solubilities of ferric arsenate and scorodite high at this pH range? Scorodite solubility is around 10,000 mg/L As and that of ferric arsenate is even greater according to the solubility data recently reported by Langmuir et al. (2006).

ARC Response:

The higher pH is primarily required for the removal of Ni and other base metals. As the pH is raised above 7, Ni concentrations decrease but As concentrations increase. The terminal pH selected is then “optimized” for the removal of As and Ni so that pore water concentrations for both elements are consistently controlled to 1 mg/L or less. This typically occurs over a pH range from 7.5 to 7.8.

Data reported in Langmuir et al. (2006) do not support the claim that arsenic concentrations are greater than 10,000 mg/L at pH values greater than 7. Arsenic concentrations greater than 1,000 mg/L (tables 1 and 2) apply only to one data point from Robins 1987 data and that was a low pH sample (pH of 0.5). The high concentrations of arsenic reported by Nishimura and Robins 1996 (listed in table 2) apply to a unique set of experiments that used very small iron concentrations (Fe/As molar values of 0.0001 to 0.00001), and all of those points apply to low pH conditions (pH of 3.29 and less). Greatest arsenic concentration reported from Krause and Ettel was 463 mg/L at a pH of 7.92.

Document Integration:

No integration required.

Technical Review Response:

Response is adequate, as the controlled concentrations are based on the observed values

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-37 Comment:

17. What does “reversibly sorbed” mean (Appendix XI, p. 17)? Wouldn’t the irreversibility be in reference to certain conditions?

ARC Response:

The term “reversibly sorbed” is in reference to adsorption/desorption test work completed in 2001 at the McClean Lake Operation and reported in the TOVP Annual Status Report in the following year (COGEMA 2002), This work was later published (Mahoney et al. 2005). Laboratory studies were performed to measure readily desorbed As using a method known as equilibrium partitioning in closed systems (EPICS). The EPICS method employs a leaching solution that, except for its arsenic concentration, is identical in composition to the pore water in contact with the tailings solids. This sequential dilution methodology was developed and applied to actual tailings produced by the McClean Lake Operation.

The arsenic that could be readily desorbed from tailings solids has been measured using a method that involves successive addition, to a slurry of tailings solids and pore water, of aliquots of the identical pore water, but free of arsenic, and measuring the arsenic released following each addition. The study found that only 0.2% of the arsenic, compared to the total arsenic content in the tailings slurry, was readily desorbed. The remaining arsenic (99.8%) is fixed and is not readily desorbed.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-38 Comment:

18. Figure 3.5-8 shows that the As regulatory limit is 5 mg/L. Is this a typo? Administration level for As is not shown on this figure?

ARC Response:

The arsenic regulatory limit of 5 mg/L in the pore water in the discharge of the tailings preparation circuit is correct.

Document Integration:

Figure 3.5-8 has been corrected so that the administration level is visible on the graph.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-39 Comment:

19. The argument regarding uranium and bicarbonate concentrations in tailings pore water (App. XI- p.18) is not clear. Fig.3.6 is not supportive of the argument.

ARC Response:

AREVA has reviewed the paragraph referenced and it has been updated to reflect the most recent results from the tailings intrusive sampling campaign in 2008. Additional information has been provided. Results from the intrusive sampling campaign have been simulated with the geochemical model PHREEQC. AREVA finds that an accurate overview of what is observed concerning the solubility of uranium in the pore water of tailings placed in the TMF is provided. More details are found in the TOVP documents.

The following may provide additional clarification. Because the uranium leaching efficiency in the McClean Lake mill is approximately 97%, there remains about 3% of the uranium in the leach residue component of the placed tailings which potentially could be in the form of

reduced uranium mineralization (U4+) as found in the original ore. In the oxidizing environment of the placed tailings, the uranium in the

reduced mineralization gradually oxidizes to U6+. This process takes about 3 years and can leave a “foot print” in the uranium pore water concentration. A slight rise and fall in uranium pore water concentration may be observed during this period of oxidation. In the meantime, residual hydrocarbons from the milling process and decaying phytoplankton and algae, are also being oxidized through microbial activity to bicarbonate ion. Bicarbonate concentrations have been shown to increase with tailings age, finally reaching an average plateau of 150

mg/L. Since U6+ forms strong solution complexes with bicarbonate, the bicarbonate concentration affects the uranium solubility in the tailings pore water as described by Figure 3.6 in Appendix XI. This is the basis for the alkaline leach process for uranium extraction. At a bicarbonate concentration of 150 mg/L, the uranium concentration in the tailings pore water is expected to be about 6 mg/L.

Document Integration:

Appendix XI, Section 3.2.2 and Figure 3.6

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-40 Comment:

20. In-pit disposal concept with low hydraulic conductivity tailings surrounded by permeable rock offers many advantages. It is not clear, however, what the differences are between the proposed “natural surround” in-pit disposal concept and the better-known “pervious surround” in-pit disposal concept. The ambiguity arises from the consideration of the pervious surround concept as subaerial and the natural concept as subaqueous. Please clarify.

ARC Response:

The choice between pervious surround and natural surround requires consideration of the site specific hydrogeologic conditions. If the pit wall rock is substantially more hydraulically conductive than the placed tailings than the natural surround design should be considered.

The pervious surround in-pit disposal design requires the construction of a highly permeable lining between the pit walls and the placed tailings. This usually consists of sand, aggregate and drain rock layered against the pit walls. Because the pit walls are usually steeper than the slough angle of the materials required to make the pervious surround, it is not possible to install the pervious surround over all the pit wall surface prior to the placement of tailings. Instead, construction involves the placement of pervious surround in short lifts using the previously placed tailings as a support for the lift. Therefore, the construction of the pervious surround is an on-going activity that occurs over the operating life of the TMF. As a consequence the pit cannot be flooded and tailings are deposited sub-aerially.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-41 Comment:

21. Success of the in-pit disposal concept would depend upon effective segregation of the tailings during placement. The central tailings placement concept aiming to form a volume consisting of coarser particles in the centre and finer particles in the outlying areas is appealing. Are there conditions that would be detrimental for the performance of this tailings placement concept in a large scale operation? Has this concept been rigorously evaluated for extreme winter conditions?

ARC Response:

As mentioned previously (see Comment NRCan-16), the tailings management facility (TMF) is not a design concept. It has been previously assessed, approved, licensed and constructed. Since 1999 the TMF has been fully operational and no changes to the tailings management system are required for the Midwest Project. At the design stage, many mitigative measures were incorporated to ensure that the TMF would function effectively under all foreseeable conditions. Nine years of operation have verified that the process of preparing tailings and placing them in the TMF is robust and relatively trouble free to operate all year round.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-42 Comment:

22. How would the uncertainties in the source term parameters affect the predictions on water and sediment quality? The potential impacts should be quantified and provided. Furthermore, the predictions are based on expected performances of the effluent and water treatment plants. How would the deviations from the expected performances affect the predictions? This is especially the case for ammonia, arsenic, selenium and molybdenum concentrations that are predicted to exceed the guideline levels. Although the proposed site monitoring program will verify the predictions and take corrective actions as per EIS, it is recommended that further research be undertaken immediately after the operations begin to find improved and/or new processes to further reduce As releases to tailings pore water from the predicted 1 mg/L level.

ARC Response:

This comment requires that a number of issues be addressed. The most prominent is to distinguish between short term environmental effects ( those that occur over the life of the project – say 100 years) and long term environmental effects (perhaps thousands of years after the TMF has been decommissioned).

The tailings slurry leaving the tailings preparation circuit in the mill is pumped to the deposition barge in the centre of the TMF. The tailings solids are tremied sub-aqueously on top of the previously placed solids. As the tailings solids settle and consolidate, most of the water in the initial slurry is incorporated into the pond water above the placed tailings. The pond water level is kept constant by pumping from a reclaim water barge to the JEB water treatment plant (WTP). The discharge from the WTP is the principle source of potential short term effects to the aquatic receiving environment. After the tailings have consolidated and the TMF has been decommissioned, constituents dissolved in the tailings pore water can diffuse out of the TMF and be carried by ground water flows to surface recharge areas such as Fox Lake and Pat Lake. The concentration of constituents dissolved in the consolidated tailings pore water becomes the source for potential long term effects.

The potential short term effects, resulting from treated effluent release from the water treatment plant have been quantitatively assessed and the results are presented in Chapter 7, Sections 7.1 and 7.2 supported by Appendix V. The input data used to generate downstream water quality and sediment quality predictions are based on actual water treatment plant performance over several years of operation. In Collins Creek, downstream of McClean Lake, contaminant concentrations (including ammonia, arsenic selenium or molybdenum) are predicted to be maintained below water quality and sediment quality guidelines or be negligibly different from background. Uncertainties in the water treatment plant source data are handled by a probabilistic model in which the source term for each constituent is represented by a distribution of values based on actual plant performance. In this way uncertainty is propagated through the model to produce distributions of output values i.e. 5 percentile, 50 percentile and 95 percentile effect predictions.

The focus on achieving 1 mg/L arsenic in the pore water of the tailings discharging the tailings preparation circuit is primarily to ensure the modeled source term is achieved for the fully consolidated and decommissioned TMF. The potential long term effects from the TMF on local recharge lakes are quantitatively estimated using ground water contaminant transport models and are presented in Chapter 7, Section 7.3 and supported by Appendix XI. The model predicts water quality effects (see Figure 7.3-2) in Pat and Fox Lakes that are negligibly different from baseline at any time in the future. Uncertainties in the estimation are handled by sensitivity analyses in which key parameters are adjusted in a conservative manner, to establish a bounding case of predicted long term effects.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-42 (continued) AREVA’s position is that the concerns raised in this comment have been adequately addressed in the Midwest EIS document.

Document Integration:

No integration required.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-43 Comment:

23. It is recommended that the management strategy be implemented during the early stages of mining to identify potential deficiencies in sampling and rock homogeneity as depicted in the draft EIS and their consequences in terms of acid mine drainage and associated metal releases.

ARC Response:

AREVA agrees with this recommendation.

Document Integration:

Section 3.2.2.2.3 describes the radiometric probing process during mining which closely delineates ore and waste zones.

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-44 Comment:

In Section 11.4, can the proponent please provide further details on the buffer zones that it has identified as a measure to minimize risk from forest fires.

ARC Response:

The buffer zones referenced in Section 11.4 are a potential mitigation to be implemented in the event of a forest fire at the Midwest site. The location of these fire breaks will be detailed in AREVA’s Fire Protection Plan and emergency response procedures for forest fires. All associated mechanisms will be developed for the Midwest Site and comply with current provincial and federal requirements.

Document Integration:

Section 11.4

Technical Review Response:

Adequate

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-45 Comment: (2010) Potential impacts to groundwater quality resulting from waste rock mined and stored at the Midwest site. NEW Consideration should be given to installing a liner at the location of the Midwest Special Waste Stockpile, an approach similar to that used for the Surface Ore Stockpiles which are to be double lined and be equipped with downgradient groundwater monitoring. Lined stockpile can be surrounded by a lined perimeter ditch designed to contain any runoff from the pad, with clean runoff from surrounding areas diverted away from the stockpile and perimeter ditch. The Province of Saskatchewan’s Construction Guidelines for Pollution Control Facilities at Uranium Mining and Milling Operations can be consulted for details.

ARC Response:

The base of the special waste stockpile will be constructed with low permeability material to reduce the risk of impacting the dewatering wells, discussed further in response CNSC-22(1) and CNSC-22(4)

Document Integration:

as indicated in CNSC-22(1) and CNSC-22(4)

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-46(1) Comment: (2010) Possible impacts to groundwater quality resulting from release of contaminants to groundwater from the JEB TMF, resulting from the deposition of tailings from the Midwest site. NEW Can the Proponent justify that hydrodynamic containment is more effective at minimizing elevated concentrations of constituents of concern in groundwater than a lined tailings management facility would be?

CNSC has provided a response to this comment (in a separate document). The proponent should take this response into account when considering NRCan’s comment.

ARC Response:

response provided by CNSC – AREVA has nothing to add

Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC RESPONSE

The figure below from the McClean EA (late 90s) helps to illustrate how the JEB pit design was selected. It is noted that a liner was among the considerations for design. In addition to the dewatering wells and the natural surround concept, there are other methods used to limit transport from the TMF such as physical and chemical pre-treatment of the tailings.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments While the CNSC operating licence for the JEB at the McClean Operation requires tailings to be prepared and deposited as described in the approved licensing documents, there is also a program in place (required by the initial operating licence) called the Tailings Optimization and Validation Program (TOVP). The objective of the TOVP was to develop an improved scientific understanding of the basic geochemical and geotechnical processes governing the long-term tailings performance. The program continues to facilitate continual improvement of the operational processes performed within the mill and the TMF. The first version of the TOVP was accepted by the CNSC in 2000, the second in 2005, and the next one is expected shortly.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment NRCan-46 (2) Comment: (2010) Has the Proponent considered the use of Permeable Reactive Barriers within the JEB TMF to neutralize acid and trap trace metals? NEW

ARC Response:

Tailings materials discharged from the JEB mill are highly oxidized and therefore acid generation is not an issue.

additional response provided below by CNSC Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC Response: Acid generation is not an issue for the JEB tailings, and trace constituents are being controlled, therefore there is no justification to request this of the proponent. As mentioned in response to NRCan 46(1), part of the long term design for the JEB involves the chemical ‘pre-treatment’ of the tailings prior to disposal. In the tailings preparation circuit, acids are neutralized, and metals are precipitated using pH controls. (Other chemicals such as Fe are also added to control As and Ni).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment NRCan-46(3) Comment: (2010) How will the Proponent decide which contaminated materials will be directed to the Midwest pit and which will be directed to the JEB TMF during decommissioning? NEW

ARC Response:

Response provided by CNSC

Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC Response: The CNSC does not completely understand the question. Tailings are directed to the JEB pit, while problematic waste rock is directed to the Midwest pit. Clean waste rock will be placed on top of the JEB pit after tailings deposition has completed. The segregation criteria for waste rock are outlined in the Midwest EA.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment NRCan-46(4) Comment: (2010) What is the predicted duration of time for the JEB TMF to transition from the operational phase to a state where the tailings pore fluids have been expelled, the tailings are consolidated, and the final pressure has been achieved? NEW

ARC Response:

Response provided by CNSC

Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC Response: Geotechnical reports regarding consolidation and segregation methods etc. are submitted to the CNSC on a regular basis, and the progress is closely monitored. The actual time for consolidation can range from years to decades. Predictions have indicated that a significant part of the pore water should be expelled before decommissioning, however it should be noted that an additional settlement will be expected once the clean waste rock is placed on top of the tailings mass at decommissioning.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment NRCan-46(5) Comment: (2010) Are there particular risks to groundwater during this transitional time that the Proponent has examined? Will the JEB TMF NEW cover include a clay cover to reduce infiltration while the vegetative cover is being established (and as a radon gas barrier)?

ARC Response:

In Section 3.8.2.5 the proponent has identified that there will be an increase in water release due to the weight of waste rock, and have indicated that a leachate collection system will be in place to allow consolidation related pore water seepage to be recovered for treatment at JEB WTP.

Additional response provided below from CNSC

Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC Response: CNSC assumes that ‘transitional’ time refers to decommissioning activities, when the pit has reached capacity and a cover will be placed on the tailings. The decommissioning stage involves several steps that will take a few years to complete. The proponent has identified that there will be an increase in water release due to the weight of waste rock, and have indicated that pump, drains, etc will be in place to effectively limit contamination. As part of the licence, decommissioning activities must demonstrate environmental protection. The current decommissioning plan does not use a clay cover-the current design involves placement of a layer of waste rock with a compacted layer of till on top.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment NRCan-46 (6) Comment: (2010) What is the anticipated length of time for the vegetative cover to become established? NEW

CNSC has provided a response to this comment (in a separate document). The proponent should take this response into account when considering NRCan’s comment.

ARC Response:

Response provided by CNSC

Document Integration: No integration required.

Technical Review Response:

October 2010 response is sufficient

CNSC Response: There is no definitive answer to this question. The proponent will typically provide a detailed design plan regarding vegetation. The plan will draw on experience from similar climate, test plots etc. and predict the time to establish and this is closely monitored through annual reports/other reports. For recent assessments in Saskatchewan, vegetation has been shown to establish after 2 years and in other cases longer than that.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment NRCan-47 Comment: (2010) Follow-up program for impacts to groundwater quantity resulting from Midwest mine dewatering activities. NEW As an element of the proposed follow-up program, since there are uncertainties in the rate of water flow into the Midwest open pit and the rate of collected/intercepted groundwater from open pit perimeter wells, actual rates and volumes should be compared to predicted rates and volumes to determine if predictions were correct. This comparison should be conducted in a timely manner in order to adjust procedures if depressed groundwater levels are more significant than anticipated.

ARC Response:

Acknowledged

Document Integration:

No integration required

Technical Review Response:

October 2010 response is sufficient

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment TC-1 Comment:

The Navigable Waters Protection Program Office is waiting for applications from the proponent before they can confirm which areas of the project will require approval and therefore trigger the CEAA. AREVA had send a navigability inquiry in January 2007. In March 2007, Matt Klaverkamp (NWP Officer) responded to AREVA that several specific crossings are navigable and indicated that an application would be required for each one. Based on what TC expects will be triggered, the EIS meets the needs of Transport Canada at this time.

ARC Response:

Aknowledged.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments Regulator Comment / Response Comment TC -1 (2010) Comment:

NEW DEWATERING OF MINK ARM INTO MIDWEST CREEK

“It is anticipated that the pumping duration would range from 28 to 48 weeks by application of the mean annual flood threshold and from 14 to 24 weeks using the ten year flood threshold” What is the impact on the vegetated floodplain as well as the stream bed and bank for this length of time? What is the frequency of monitoring planned so that adjustments can be made to the rate of dewatering of Mink Arm? If physical degradation continues with the reduction in pumping rates what are other possible options? Will the Sink/Vulture Treated Effluent Management System handle the dewatering?

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments ARC Response:

As described in the response to comment DFO-2 (submitted with the February 2010 addendum), a field assessment of Midwest Creek was conducted which included assessment of stream and floodplain topography, streambed and bank material, riparian vegetation, the underlying floodplain soils, and stream discharge. The mean annual flood threshold for Midwest Creek was estimated to be 0.19 m3/s and the 1 in 10 year flood flow was estimated to be 0.30 m3/s. An upper pumping threshold of 0.3 m3/s will be adopted during Mink Arm dewatering activities at which point pumping rates will be reduced.

Due to the armouring present in the channel of Midwest Creek, it is not anticipated that the channel would degrade during a sustained 1 in 10 year flood event. The predicted water surface during the 1 in 10 year flood event does extend into the floodplain at some sections of the stream; however, the extent of various grasses, roots, mature trees, willows, and fallen debris is such that the predicted velocities and shear stresses would not result in degradation of the floodplain or loss of riparian vegetation. However, in order to reduce the likelihood of channel and floodplain degradation occurring, a monitoring program will be implemented during the periods of increased flow. This may consist of weekly visual inspections along the stream, and measurement of stage and discharge. Additional monitoring may also be required during large precipitation events, as precipitation may result in increased natural flow to the channel. Development of a stage- discharge relationship would also be beneficial for the stream. This would allow for discharge to be estimated from an established relationship to stage by measurement of stage alone.

In the event that it is necessary to transfer Mink Arm water via the mine dewatering pipeline to the Sink/Vulture Treated Effluent Management System (S/V TEMS), the pumping rate is anticipated to be lower than that experienced during active mine dewatering (25,000 m3/day). As described in the response to comment EC-29, the S/V TEMS is operated according to McClean Lake Procedure 718, Sink/Vulture Treated Effluent Management System Operation of the Integrated Quality Management System and the associated work instructions. The S/V TEMS controls the release of effluent from the McClean Lake Operation to the environment while allowing water treatment plants and dewatering facilities to discharge freely. System objectives are to ensure that Saskatchewan Surface Water Quality Objectives (SSWQO) are maintained at the outlet of McClean Lake, as described in the McClean Lake Project EIS, August 1991, and the Environmental Code of Practice, and to ensure that discharge from the operation does not further exacerbate any naturally occurring flood condition in Collins Creek. Discharge criteria require that no water be discharged from the reservoir when Collins Creek flows exceed 4.52 m3/s. These specifications will continue to be met if Mink Arm dewatering water is released to the S/V TEMS.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment TC-2 (2010) Comment:

Air emissions, noise and spills along the haul road NEW How will the speed limits be enforced? How many trips will be made per day on the haul road? Will the proposed haul road/culvert/bridge handle the capacity?

ARC Response:

Operational control of travel along the Midwest haul road will be similar to what is currently in place at the JEB site to Sue site haul road at the McClean Lake Operation.

Drivers will be trained on road safety and speed limits will be posted and enforced. Traffic on the haul road will be planned and closely monitored via regular radio contact. Work instructions will be developed for travel on the Midwest haul road and will be similar to those applied to the Sue to JEB haul road (McClean Lake Operation Work Instruction – SUE to JEB haul road Procedures, Document No.: 303- 05). These work instructions comply with the Saskatchewan Mines Regulations 324 (Traffic control plan) and the Saskatchewan OH&S Regulations (Risk from vehicular traffic).

Section 3, Table 3.3-3: Transportation corridor material Transpiration and activity, outlines the type of vehicle, the cargo, and the frequency of each type of trip expected along the haul road. Vehicle traffic on the haul road is estimated to be 76 (round trips) per day during operations (Table 3.3-3, Section 3). These include all vehicles associated with environmental monitoring, operations, passenger transport, and reagent transport and include a variety of vehicle types. Please refer to Table 3.3-3 for more detail.

Please refer to the response to comment CNSC-25(2) for a discussion of potential traffic accident calculations.

The proposed haul road, including culverts and bridges, will be designed and built to handle the capacity of the road traffic. As stated in Section 3.3.1 Transportation Corridor Design Considerations, the road design criteria will be developed from the Transportation Association of Canada Geometric Design Guidelines and the Saskatchewan Highways and Transportations Design Manual, in keeping with good engineering practice.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

2 PUBLIC INTERVENOR

Regulator Comment / Response Comment PI-01 Comment:

Dr. Busby's intervention (section 4.1.1) highlights the absence of a child under 6 in the human receptor assessments. CNSC staff agree that AREVA should model a child under 6 as part of their human receptor assessments.

ARC Response:

Please see the response to comment HC-21. A calculation is provided for a toddler (age 7 months to 4 years) at the Wollaston Lake location (Appendix VII).

Document Integration:

Changes are reflected in:

 Section 8.3.1.1,  Section 8.3.1.3  Section 8.3.1.4.  Table 8.3-1, 8.3-2, 8.3-6, 8.3-9, and 8.3-13.  Appendix VII, Section 6.2 (calculations)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Federal Comments

Regulator Comment / Response Comment PI-02 Comment:

Dr. Busby's intervention (section 4.3) highlights issues with the adequacy of the atmospheric modelling. CNSC staff had noted deficiencies in the atmospheric modeling specific to dust in the federal comments provided to AREVA on July 11, 2008. AREVA should address the intervenor comments when completing the dust modeling already requested by CNSC staff in their review comments.

ARC Response:

AREVA has completed the requested dust modelling. An additional appendix entitled “Air dispersion analysis of nitrogen oxides, sulphur dioxide, radon-222 and dust” has been included in the Midwest Project EIS as Appendix XIV. This appendix was included to address CNSC and intervener comments about atmospheric modeling for the Midwest Project. Please refer to Appendix XIV for information on atmospheric modeling.

Document Integration:

Appendix XIV has been added to the Midwest EIS.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

1.1 Type I Comments

Regulator Comment / Response Comment SK-1 Comment:

Appendix 3 Midwest Project Fish Habitat Compensation Plan was not included in the submission. As a result, a thorough review of the fish and fish habitat component of the Midwest EIS could not be carried out at this time. Ministry staff requires Appendix 3 in order to complete their review of the Midwest EIS.

ARC Response:

Acknowledged and completed. Appendix III was submitted and a letter of acknowledgement was received on 20 March 2008 from Malcolm K. Ross, Project Manager, Environmental Assessment Branch, Ministry of Environment for the Province of Saskatchewan. A revised version of Appendix III is included with the March 2010 submission.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

1.2 Type II Comments

Regulator Comment / Response Comment SK-2 Comment:

1) Page 3-11. Section 3.2.1.1.2. The Proponent expects that a large portion of the Mink Arm dewatering water will be appropriate for direct release to the environment. The dewatering water will need to meet the most recent version of the Saskatchewan Surface Water Quality Objectives (SSWQO). Water not meeting SSWQO will require treatment prior to release.

ARC Response:

Acknowledged. AREVA will manage the dewatering of Mink Arm and monitor the quality and volumes, such that they will fall within the constraints outlined (Volume, Bankful and 1 in 10 year flood) and will maintain the quality of the discharge. In terms of water quality, Mink Arm surface water quality results (Table 4.4-3) indicate that the water quality meets current SSWQOs.

During the1988-1989 Mink Arm dewatering, no issues arose with respect to the quality of water pumped from Mink Arm to South McMahon Lake, other than for turbidity and suspended solids. Therefore, it is anticipated that as Mink Arm dewatering progresses, total suspended solids (TSS) would need to be monitored and managed, as required. No SSWQO exists for TSS; however, Newcombe and MacDonald (1991) outline considerations regarding the effects of suspended sediments on aquatic ecosystems. Using this type of information, it is anticipated that an appropriate TSS criterion can be developed at the time of licensing to negate potential effects on fish and habitat associated with Mink Arm dewatering. It is proposed that a weekly grab sample analysed for Class C parameters (including TSS and turbidity) will provide the information necessary to effectively manage potential water quality effects that may be associated with Mink Arm dewatering. If turbidity and suspended sediment concentrations increase, this water can be directed to a settling pond prior to discharge or it can be treated at the Midwest water treatment plant (WTP) prior to release (as discussed in Section 3.2.1.1.2 of the Midwest EIS Main Document). If turbidity and/or suspended sediments do increase in concentration, it would only be for a short period. Because the effect of suspended sediments is dependent on both concentration and exposure duration, a short duration will help minimize any effect from an increase in concentration (Newcombe and MacDonald, 1991).

Given the mitigation measures to be applied, AREVA the potential effects of Mink Arm dewatering water release can be managed and potential effects minimized.

REFERENCE:

Newcombe, C.P. and D.D. MacDonald. 1991. Effects of suspended sediments on aquatic ecosystems. North American Journal of Fisheries Management 11:72-82.

Document Integration:

No integration required.

2010 Technical Review Response

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

As it is stated by AREVA that the effects of suspended sediment are related to both concentration of sediments and time of exposure, the weekly sampling interval may be too long to note any impacts and as such, monitoring requirements will likely be contingent on the results of initial sampling and analysis with sampling frequency adjusted as effects become better understood. These will likely be considerations that can be addressed in the development to the monitoring program as part of the approval application.

It may be worthwhile to consider using turbidity as an analogue for TSS. A relationship between turbidity and TSS may have to be initially established for this location.

ARC Response:

AREVA agrees that the weekly sampling interval during Mink Arm dewatering may be too long to note impacts for suspended sediments. As noted in response to comment CNSC-27: AREVA is proposing to collect measure pH, TSS and conductivity in daily water samples June 2010 during Mink Arm dewatering. In the event that TSS increases above 29 mg/L, the Midwest WTP would be utilized and water would subsequently be directed to the Sink/Vulture Treated Effluent Management System.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-3 Comment:

2) The Proponent needs to clarify the following:

a. How will the Proponent ensure “clean water” will be kept separated from treated water in order to prevent the unnecessary treatment of “clean” water?

b. How will the Proponent ensure water entering the pipeline that transfers water from the Midwest site to the S/V TEMS meets provincial and federal water quality objectives/guidelines? Would the treated effluent enter a monitoring pond prior to entering the pipeline?

c. How will the Proponent handle water (i.e., dewatering well water, reverse osmosis permeate water, and treated effluent) that does not meet water quality objectives/guidelines?

ARC Response:

a) The clean dewatering well water is expected to be the only source of clean water suitable for discharge and will be managed in the following manner. Water samples will be collected at each well of the interceptor dewatering well system for analysis to provide an initial assessment of intercepted groundwater quality. Similar to the management of dewatering well water at the McClean Lake Operation JEB Tailing Management Facility (TMF) dewatering well system (DWS), based on the dewatering well water quality, the water can be directed to one of two pipelines: the clean dewatering line, or alternatively, the contaminated dewatering well line. As illustrated in Figure 3.5-2, and consistent with current management practice for the McClean Lake Operation JEB TMF DWS, Schedule 3 criteria will be used to manage the discharge from the Midwest pit DWS. Midwest pit DWS water reporting to the clean line will report to a surge tank prior to discharge to the treated effluent line reporting to the S/V TEMS. Midwest pit DWS water reporting to the contaminated line will report to the Midwest WTP for treatment. As illustrated in Figure 3.5-2, The Midwest WTP system consists of two processes: reverse osmosis (RO) treatment, followed by chemical water treatment of the brine. See (b) below for a description of the RO process management. See response to Comment CNSC 22 (2) for a description of Midwest chemical WTP process management.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-3 (continued) b) As illustrated in figure 3.5-2, three streams of water have been identified for release to the S/V TEMS consisting of two treated (treated effluent and RO permeate) and one untreated (clean dewatering well water). See (a) for a description of dewatering well water management.

The outlets of the Midwest reverse osmosis (RO) and chemical water treatment plant are a final point of discharge and both will be regulated by MMER. In addition, the RO permeate and treated effluent is expected to meet Schedule 3 and 1 respectively of the McClean Lake Operation Approval to Operate Pollutant Control Facility IO-205. It is anticipated that the clean dewatering well water will be regulated by Schedule 3 of the McClean Lake Operation Approval to Operate Pollutant Control Facility.

To insure compliance with MMER and Schedule 1, monitoring ponds will receive treated effluent from the chemical water treatment plant for analysis prior to being combined for discharge. In the event that water quality does not meet MMER or Schedule 1 the water will be recycled to the water treatment plant for treatment. See comment CNSC-22 (2) for a description of the Midwest Chemical WTP process management.

Real-time conductivity probes in the effluent surge tank will monitor the combined effluent from the Midwest RO WTP, clean dewatering wells and the chemical water treatment plant. In the event of contamination the contents of the effluent surge tank will be recycled to the water treatment plant. The source of contamination and or malfunction will be isolated and corrective action will be taken. RO permeate is expected to meet CCME guidelines and will be governed by the McClean Lake Operation License Approval to Operate Pollutant Control Facilities, Schedule 3.

Please refer to comment CNSC-28 for further detail on the analysis of predicted quality of combined effluent from the Midwest Water Treatment System.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-3 (continued) c) Please refer to SME-3 (a), (b), CNSC-22(2) and figure 3.5-2 for the waste water management procedures used to insure compliance with regulated discharge limits prior to being combined in the effluent surge tank. To mitigate the release of contaminated water to the pipeline and Sink Reservoir online conductivity probes will monitor the combined water quality of the dewatering well water, treated effluent and RO permeate in the effluent surge tank prior to release. In the event of contamination water from the effluent surge tank will be recycled to the Midwest water treatment plant for re-treatment.

Please refer to comment CNSC-28 for further detail on the analysis of predicted quality of combined effluent from the Midwest Water Treatment System.

Document Integration: Main Document:  Figure 3.5-2  Section 3.2.5.1  Section 3.5.1

Technical Review Response

3a) Dewatering well pipelines should have secondary containment, as outlined in Section 3.1 of the Construction Guidelines for Pollution Control Facilities at Uranium Mining and Milling Operations (EPB 145). AREVA should note in the EIS that secondary containment will be provided. Details of the secondary containment system can be reserved for the construction application.

2010 3c) AREVA does not provide information on their plan to monitor the combined water in the effluent surge tank for parameters that will not be reflected in conductivity. AREVA should provide information on exactly what other parameters will be monitored at this location, or provide justification for only monitoring conductivity.

ARC Response:

3a) As at the JEB pit, AREVA plans to grade low points around the Midwest DWS to allow for draining towards and into the open-pit. June 2010

3c) Refer to response to Comment CNSC-22 (2)

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments Technical Review Response (for consideration – not followup required)

3a) AREVA should note that grading to allow drainage towards and into the open pit does not constitute secondary containment based on the definition provided in EPB 145. For regulatory approval, AREVA would have to, at a minimum, demonstrate that the hydraulic December 2010 conductivity of the drainage works would be at or better than 1 x10-7 cm/s.

3c) AREVA should specify the parameters that will be analyzed.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-4 Comment:

3) Pages 3-58 and 3-86. The Proponent is proposing to transfer water collected from dewatering wells and treated effluent from the Midwest site to S/V TEMS via a single contained, heat traced, HDPE insulated pipeline. The pipeline would travel along the haulage road to the JEB site where it would follow the existing discharge pipe from the JEB WTP to Sink Reservoir. The Proponent expects that the quality of this water will be appropriate for direct release to the environment (i.e., meet CCME guidelines and SSWQO). The Proponent is proposing to have "containment ponds" located at regular intervals for the purpose of preventing excess erosion in undisturbed areas adjacent to the roadway and potential sedimentation or water ways and draining the line in the event of an extended interruption. The ponds would also be unlined and sized to accommodate the volume of water within the pipeline that may drain to the pond. Depending on the controls in place (monitoring and spill detection), ministry staff may consider single containment for portions of the pipeline transferring water from the Midwest site to S/V TEMS.

ARC Response:

Acknowledged, In addition to the mitigation measures outlined, the pipeline and containment ponds will be patrolled and inspected daily by environment personnel for leaks or ruptures. As detailed in section 3.7.1.3 early detection and proper spill response procedures and clean up will serve to mitigate discharge of treated effluent in the event of a leak or rupture.

A detailed addressing the expected water quality through the single walled pipe is presented in CNSC-28.

Document Integration:

Section 3.7.1.3.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-5 Comment:

4) What is the proximity of the proposed “containment ponds” to waterbodies (fish bearing and non-fish bearing) along the haulage road?

ARC Response:

Containment ponds will be constructed approximately 90 meters from any stream and comply with provincial and federal requirements.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-6 Comment:

5) Depending on the site layout that is approved, there is the potential to infill John Pond and the creek that connects it to Mink Arm. There is no information provided regarding the suitability of this creek for fish spawning although information is provided on John Pond itself and Mink Arm. The Proponent should collect this information for the creek in order to determine the extent of habitat destruction in the creek.

ARC Response:

AREVA has removed the infilling of John Pond as proposed option for the handling of waste rock.

Document Integration:

No integration is required in the Midwest EIS.

Technical Review Response:

2010 It is not clear how AREVA is proposing to manage the waste rock that was previously planned for the infilling of John Pond. AREVA should provide information on how this waste rock will now be handled.

ARC Response:

The waste rock piles have been re-configured to account for the loss of area that John Pond would have provided for the placement of clean waste rock. The pile now extends to the west, off the existing surface lease to accommodate the same volume of waste rock. A June 2010 surface lease extension will be required and is discussed in Section 3 of the Midwest EIS.

The new layout is evident in Figure 3.2-6 (preferred layout option) in comparison to Figure 3.2-7 (layout option that involved the infilling of John Pond).

Document Integration:

No further integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-7 Comment:

6) In figures 3.3-1 and 3.3-2, the routes shown for “Option B” do not match. For example, in Figure 3.3-1, the road travels to the east of Torwalt Lake and in Figure 3.3-2, the road travels to the west of Torwalt Lake. The Proponent should identify the correct route for “Option B”.

ARC Response:

To clarify, Figure 3.3-1 presents the preliminary haulage road options that were presented in the Midwest Project Description (COGEMA, December 2005). This figure includes road options A, A1, B, and B2. In the Midwest Project EIS two preferred haulage road options are presented in Figure 3.3-2, and are named the north and south route options. Neither Option B nor Option A or A1 (Figure 3.3-1), correspond with the North or South route options, respectively (Figure 3.3-2). In the project description, four preliminary routing options were presented, but since the submission of the Project Description, these road options, along with several others, have been evaluated and based on the results of the engineering and environmental evaluation, two different road options have been put forward in the EIS. The routes being considered are the proposed North and South routes presented in Figure 3.3-2.

AREVA acknowledges that the text in Section 3.3 is not consistent with the naming of the road options, does not explain why the two figures differ, and that it is therefore difficult to interpret the figures. AREVA has corrected the text in Section 3.3 to clarify the differences between Figure 3.3-1 and 3.3-2 and to make the text consistent with the naming of the road options in the figures.

REFERENCES:

COGEMA Resources Inc. (COGEMA). 2005. Midwest Project Description/Proposal. December.

Document Integration:

The text in Section 3.3 has been changed to reflect the differences between Figure 3.3-1 and 3.3-2 and to be consistent in the naming of the road options. The column headings in Table 3.3-1 have also been changed to be consistent with the naming of the proposed road options.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-8 Comment:

7) Pages 3-34 and 4-95. Crossing N5. The proposed crossing N-5 crosses a large creek between Fox Lake and Pat Lake. On page 4- 95, the Proponent states, “The unnamed tributary flowing from Fox Lake to Pat Lake was classified as fair spawning, rearing and foraging habitat for the species of fish that were known to occur within the reach. The Proponent is proposing to install either one (6010 mm x 3750 mm x 30 m pipe) or two (3200 mm x 31 m) culverts at this crossing. However, either installation would appear to result in higher than acceptable velocities for fish passage (DFO mandate). In addition, a clear span bridge should result in less damage to fish habitat.

ARC Response:

Thank you for your comment. A clear span bridge will be installed, as per your recommendation.

Document Integration:

Section 3.3.1.6.1 of the Midwest EIS has been clarified to confirm that a clear span bridge will be installed at proposed crossing N-5, as per your recommendation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-9 Comment:

Section 3.5.1 Waste Water Management. Water management practices should be in place during construction and operation phases that minimize the amount of freshwater utilized, thereby reducing the amount of water requiring treatment and the chemical loading to the environment. The Proponent needs to discuss how “clean” water will be determined and kept separate from contaminated water requiring treatment. The Proponent should also include information regarding the drainage systems set up to collect contaminated water (e.g. ditches and drainage from stockpiles) and to divert “clean” water away from contaminated areas.

ARC Response:

The drainage system at the Midwest site has been designed with the same operational considerations as those of the McClean Lake Operation JEB and SUE mining areas. As discussed in Section 3.5.1, the overall waste water management objectives at the Midwest site is to minimize the volume of water requiring treatment, treat contaminated water to acceptable levels prior to discharge, and minimize the effects of effluent discharge on the receiving environment.

The components of the drainage system at site include the mine sump, clean and contaminated perimeter interceptor wells, and site runoff collection areas. It is expected that of these four streams of effluent only the clean water from the interceptor wells will be of sufficient water quality for discharge to the Sink Vulture Treated Effluent Management System meeting Schedule 3 limits of the Provincial Operation Approval to Operate Pollutant Control Facilities for the McClean Lake Operation. As with the McClean Lake Operation JEB pit, two dewatering well rings will be constructed around the Midwest pit one for clean dewatering well water and the other for contaminated dewatering well water. Daily and monthly composite samples from interceptor dewatering well system around the Midwest pit will provide data for monitoring and managing the performance of the dewatering system during operation. The clean dewatering well water will be diverted to the clean water collection ring around the Midwest open pit. This will insure that clean dewatering well water bypasses the water treatment plant and is directed to the effluent surge tank prior to being released to the Sink Vulture Treated Effluent Management System (S/V TEMS). Should a dewatering well be the source of contaminated water it will be diverted to the contaminated water collection ring for treatment at the Midwest water treatment plant. Site runoff collection areas will be located at the toe of the clean and special waste stockpiles to collect surface runoff. Water from the site runoff collection areas will be transferred to the site run-off ponds for analysis before being sent to the Midwest water treatment plant. The pre-settling pond will collect mine sump water prior to being transferred to the Midwest Water treatment plant.

The proposed waste water management at the Midwest site is illustrated in Figure 3.5-2. Please refer to SME-3 for further detail on for waste water handling at the Midwest Site.

Document Integration:

Main Document, Section 3:

 Figure 3.5-2  Section 3.5.1.2.2

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-10 Comment:

9) Page 3-58. Section 3.5.1.3 Transfer of Treated Effluent to McClean Lake S/V TEMS. The Proponent proposes to transfer clean dewatering well water, clean reverse osmosis permeate water and treated effluent from the Midwest site to the S/V TEMS for release to the environment. Will the clean dewatering well water be combined with the permeate water and treated effluent?

ARC Response:

Yes, as illustrated in Figure 3.5-2 the clean dewatering well water will be combined with the RO permeate and treated effluent in the effluent surge tank prior to discharge to the Sink Vulture Treated Effluent Management System. Please refer to SME-3 for further detail on the waste water management at the Midwest Site.

Document Integration:

Main Document, Section 3, Figure 3.5-2

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-11 Comment:

10) Page 3-65. Section 3.5.2.3 Waste Rock Disposal Plan. It is not clear whether the special waste stockpile will be lined. In the SERM document (marked as draft), “Construction Guidelines for Pollution Control Facilities at Uranium Mining and Milling Operations” potentially Acid generating rock or special waste stockpiles should at least have a single liner. The Proponent should refer to this document for other construction guidelines (e.g., guidelines for containment ponds, pipelines, leak detection and alarm systems, water and waste management).

ARC Response:

As illustrated in Figures 3.2-6 to 3.2-8 the proposed Midwest special waste stockpile is located on the southern edge of the Midwest pit. The storage of the special waste is only for a temporary period of time (life of the pit, 3-4 years). As such, a liner is not planned for the special waste stockpile at the Midwest Site. This is consistent with the management previously employed at McClean Lake site where the temporary storage location of the Sue C special waste was located on an unlined pad on the brow of the Sue C pit.

The special waste stockpile area is located at the south end of the Midwest pit which is naturally graded toward the pit. A site collection runoff area for the special waste stockpile will be positioned adjacent to the perimeter road approximately 75 meters from the pit. Surface runoff will be directed and collected at the site runoff collection area. During the period of active mining, the special waste area and site runoff collection area will be hydraulically contained within the footprint of the pit by the groundwater drawdown cone of depression. Ground water will be collected by the Midwest pit mine sump for treatment at the Midwest water treatment plant.

At the end of mining the special waste stockpile and contaminated based materials will be excavated and placed at the bottom of the Midwest pit, and capped with a till cover. Section 3.10 indicates that the decommissioning phase of the Midwest project is estimated to take two years.

Document Integration:

Main Document, Section 3.5.2.3

Technical Review Response:

2010 AREVA should state how they will demonstrate that all impacted soil in the area of the proposed special waste stockpile has been placed in the Midwest pit during decommissioning.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments ARC Response:

The soil below the special waste stockpile will be excavated and radiologic measurements will be conducted, followed by the further June 2010 excavation of material (if necessary) and repeated until a defined criteria is reached. These criteria will be established between the regulators and AREVA.

Document Integration:

Section 3.5.2.3

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-12 Comment:

11) Page 3-82. Section 3.7.2.2 Release of Contaminants from Surface Ore Stockpiles. The Proponent plans to have the ore stockpile contained within an engineered lined pad. Will the pad consist of a single or double liner? In the SERM document (marked as draft), “Construction Guidelines for Pollution Control Facilities at Uranium Mining and Milling Operations” Ore stockpiles should have a double liner not a single liner. The Proponent should refer to this document for other construction guidelines (e.g., guidelines for containment ponds, pipelines).

ARC Response:

The surface ore stockpile at the Midwest Site will be double lined and constructed to meet the requirements of the “Draft Construction Guidelines for Pollution Control Facilities at Uranium Mining and Milling Operations”.

Document Integration:

Main Document, Section 3.2.4.3 and Section 3.7.2.2

Regulator Comment / Response Comment SK-13 Comment:

12) Of the three layouts proposed for the Midwest Project, Panel C, as identified in Figure 3.1-4, appears to be the most favourable at this time. This option likely will result in the least amount of environmental disturbance and will minimize fish habitat loss in Mink Arm to that area previously disturbed.

ARC Response:

Acknowledged. An erratum was issued for the Midwest Project EIS, which resulted in changes to Figure 3.1-4. The comment in reference to Figure 3.1-4 Panel C is not Figure 3.1-4 Panel B. The corrected Panel C in erratum differs from the initial Midwest EIS submission. Panel B (Alternative site layout 1) in Fig 3.1-4 (date: 20 Dec 2007) supercedes Fig 3.1-4 (date: 27 Sept 2007) Panel C.

However, upon further revision of the Midwest EIS, the figures and text related to the site layout alternatives may have further changed, due to the removal of alternative 2, which involved the infilling of John Pond with clean waste rock.

Document Integration:

The updated Midwest EIS contains the correct figure layouts and a revision to site layout alternatives being carried through the assessment. On Figure 3.1-4, Panel D, or alternative 3 represents the preferred site layout option. Text in Section 3 (Sections 3.1.1.2 and 3.1.4.1) and

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments has been modified slightly to clarify the site layout options. Please also refer to response to Comment MER-5.

Regulator Comment / Response Comment SK-14 Comment:

13) Page 4-108. Section 4.5.3.1 Furbearer Mammals. The Proponent should provide some assessment of where snowshoe hare and lynx are in their population cycles in terms of how abundance of these species changes over time and how other predator and moose populations can be influenced by these population cycles.

ARC Response:

Information on snowshoe hare populations in the study area has been gathered through field studies completed within the Midwest Project local assessment boundary. In 1979, late winter track counts (March) resulted in an estimate of 2.0 snowshoe hare tracks km/transect track night (AREVA 2009). In 1989, it was determined that snowshoe hare was at the upper end of a population cycle with well-distributed pellet groups. In 2004, a total of 707 hare trails were recorded on winter tracking transects. Hare occurrence had a patchy distribution and hare trail density averaged across all transects was 2.6 trails/km day (Midwest EIS, Section 4.5.3.1). It is suspected that hare densities in the area examined were at a cyclic low during the winter of 2004 (AREVA 2009). In 1990, incidental track observations of lynx and otter were recorded, but densities were not determined (Figure 4.5-5, Midwest EIS, 2008).

The most detailed and scientifically-defensible information on the status of the varying hare cycle in the northern boreal forest of western Canada is long-term monitoring work in northeastern Alberta by Charlebois and Kansas (2007). This study includes annual replicate winter tracking samples from 2002 to 2007. The monitoring showed that 2003 represented a low in the hare cycle and that hare densities increased by an order of magnitude from 2003 to 2007. Parallel monitoring of lynx trails by Charlebois and Kansas (2007) has shown that lynx densities are cycling along slightly behind the hare cycle, in spite of extensive and increasing heavy oil development in their study area. Levels of industrial development in the study region in Alberta far exceed levels in the Midwest Project Area; therefore, it is expected that the Midwest Project will not affect lynx and hare interactions in the assessment area.

As detailed in the Midwest EIS, the assessment did not conclude there to be significant adverse effects to furbearing mammals at an individual level, let alone at the population level. AREVA looked at the impact of constituents of potential concern (COPCs) on individual species and determined that it was negligible for moose, hare, lynx and wolf (Section 7 Assessment of Residual Effects). The spatial footprint of the Midwest operation is small and it was determined that it will not have a significant impact on terrestrial animals or their preferred habitats.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-14 Based on these conclusions, no adverse effects on populations of furbearers are predicted and the population cycling for these animals will (continued) not be significantly affected by the Midwest Project.

REFERENCES:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document (TID).

Charlebois, M.L. and J.L. Kansas. 2007. Monitoring responses of ungulates and mammalian carnivores to oil and gas development and exploration in the Christina Lake area of northeastern Alberta – 2007 Progress report. Prep. For Devon Canada Corporation by URSUS Ecosystem Management Ltd. Calgary, AB.

Document Integration: No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-15 Comment:

14) Pages 4-121 and 4-122. Section 4.5.4.1 Caribou. The Proponent estimated that 65% of the assessment area is suitable caribou habitat. However, it appears the Proponent may have overlooked the following:

a. The potential use of the area during the snow free seasons by woodland caribou; b. The value of lakes of certain sizes at certain times of the year to caribou for resting, travel, predator avoidance or escape, and freedom from insects; and c. The value of stream-side riparian areas where caribou can take advantage of such other important seasonal foods as sedges, evergreen herbs, and the emerging leaves on some shrubby plants.

The Proponent should include the above details in the estimation (note: a greater percentage of the overall area likely would be assessed as valuable caribou habitat).

ARC Response:

AREVA acknowledges that the potential foraging areas for Caribou that are presented in Section 4.5.4.1 are based on snow-covered/winter habitat. The assessment predominantly considered Barren ground caribou that are present in the local assessment boundary during the winter. The ungulate pellet group survey program conducted during the winter of 2003 enumerated spring pellets in addition to winter pellets. Therefore, any caribou use of the area during spring, up to and including most of the month of May, was documented. The field crew was also instructed to search for all old caribou sign, but none was found. Surveys have been conducted to identify woodland caribou and movement in the area, but it was not possible to identify any animals. The occurrence of woodland caribou is, therefore, considered very low in the local assessment boundary, but it is acknowledged that there is the potential for woodland caribou to occur in the area. The inclusion of summer foraging areas, thus, includes woodland caribou summer habitat.

Caribou primarily feed on terrestrial and arboreal lichens during winter, and thus, the abundance of lichens within a given habitat type has an influence on caribou habitat use and distribution. The ecosite phases containing the highest occurrence and abundance of ground lichen were black spruce forests (a2 and g1), jack pine forests (a1 and c1), and shrubby (b2) and treed burns (b1). These habitats have the highest habitat suitability for caribou and represent 65% of the local assessment boundary that has been classified (Figure 4.5-10). The preferred site layout and road option for the Project is expected to interact with 1.8 % or 550 ha of preferred caribou winter habitat. Although lichens are good sources of energy, there are not good sources of protein. During the summer, caribou switch to fresh green vegetation, which is rich in nitrogen. Caribou focus on sedges and newly unfurling leaves of willow and other shrubs, therefore, the analysis of preferred summer habitat loss, also includes riparian habitat types. With the inclusion of riparian habitats as summer habitat, approximately 69% (32,268 ha) were considered to be highly suitable summer habitat, within the area classified in the local assessment boundary. Based on the preferred site layout and road option, the Midwest Project footprint will disturb approximately 562 ha of highly suitable summer caribou habitat, representing about 1.7% of these habitat types available within the area classified in the local assessment boundary. The greater amount of high potential foraging habitat interaction would be at the road stream crossings. There are mitigation measures in these areas to prevent habitat destruction and loss. In considering the inclusion of additional riparian habitat types as caribou habitat, the preferred area increases, but this does not affect the predicted outcome of the assessment. The effect of the project on caribou habitat remains minimal.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments Regulator Comment / Response Comment SK-15 The majority of the area surrounding lakes is included in the original 65%, as it is classified as having high potential for caribou foraging. (continued) The area of the lakes is not included in the calculation of the 65%, as the ecosite phase classification only classified terrestrial habitat; however, caribou habitat was classified according to lichen foraging potential and lakes have no lichen foraging potential. To clarify, although Section 4.5.4.1 and Figure 4.5-10 present information on potential foraging habitat, not necessarily all habitat is used by caribou at all times. The value of certain lakes at certain times of the year was not included in the original assessment. If all lakes are included as having high caribou habitat potential, the amount of high-potential caribou habitat in the local assessment boundary would increase to 82.8% or 84.9% when including all riparian areas as having high habitat potential. With the exception of Mink Arm, these lakes will not be affected by the project footprint and will not interact with the project. Therefore, the Midwest Project is predicted to have no significantly adverse effects on lakes as caribou habitat. As stated in the above comment, the use of certain lakes at certain times of the year by caribou, in certain situations, is extremely variable and not easily quantified.

Figure 4.5-10 has been modified to incorporate the above-mentioned changes to the caribou habitat classification. The three riparian habitat types, treed riparian (r1), shrub riparian r2) and sedge riparian (r3), have been separated out of the original Low-Potential Foraging area group and are presented as a separate group. The reader can now easily identify these areas and how including or excluding these three riparian areas from the High-Potential Foraging area group affects the overall caribou habitat classification and potential interactions of the Midwest Project with caribou habitat.

Document Integration:

The text in Section 4.5.4.1 has been changed to clarify that the 65% of the classified local assessment boundary that was indicated as suitable included all areas classified as being high potential caribou foraging areas. As well, riparian areas, r1, r2 and r3, have been included as areas of high-potential caribou forage areas and the total area increased to 67%. The text in Section 7 has been changed to reflect the inclusion of riparian areas as high-potential caribou foraging areas (Section 7.2.3.4). Figure 4.5-10 has been modified as stated in the draft response.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-16 Comment:

15) Page 4-127.

a. The Proponent includes little information about trapping and what it reflects of the local population. There is a trapping block system where the target block is "N-26 Wollaston" primarily occupied by Dene people from the Wollaston Lake area with a neighbouring block "N-18 Cree Lake" immediately to the southwest primarily occupied by Dene people from the Patuanak area. The Proponent should discuss the history of the block system and what it reflects of traditional land occupancy and wildlife use in the area. b. Furthermore, the Proponent does not clearly state or cite the literature used to assess the trapping density. The information that is provided in the EIS could be misleading in terms of the importance of the area to the trapping community. The Proponent also appears to overlook the fact the trapping density may have been affected by all the industrial activity taking place in the target area since at least the early 1970's. As a result it, the Proponent may be underestimating the effects of the proposed development on trapping.

ARC Response:

To clarify, the majority of Midwest Project local assessment boundary lies within trapping block N-26 and the west side of the local assessment boundary falls into block N-80 (See updated Figure 4.6-6). Information on fur harvests in the area of the Midwest Project (blocks N-18, N-26 and N-80) has been obtained from the Fish and Wildlife Branch of the Saskatchewan Ministry of the Environment and this data is presented in the new Table 4.6-3. This table supplies pelt counts for the three fur blocks in question as well as the total cash value of the pelts each season from the 2002-2003 season until the 2006-2007 season. No data was reported for block N-18 in 2003-2004 and 2006-2007. All count and cash values are obtained from fur dealers and fur export permits (Lois Koback, Saskatchewan Ministry of Environment, personal communication). The number of furs trapped in block N-80 has declined in the past 5 years, but the number of furs collected in blocks N-18 and N-26 appear to be stable and increasing slightly. The recent increase in industrial activity in the Midwest Project area does not appear to be impacting trapping in the larger surrounding area.

The information on trapping density in the area of interest, presented in Figure 4.6-6, was obtained from the Prince Albert Grand Council, as stated in the text in Section 4.6.2 and on Figure 4.6-6. Under an Agreement Respecting the Land and Renewable Resource Use Planning and Management in Northern Saskatchewan – Lake Athabasca Region between the Government of Saskatchewan and Athabasca Basin First Nation groups and communities, traditional land use and occupancy research has been undertaken. Through oral history, living memory and current traditional land use data, land use information, including information previous to industrial activity in the area, can be obtained to assess the impacts of a project. The Prince Albert Grand Council is the custodian of the traditional land use research. To assess the interactions of the Midwest Project with traditional land use, a request was made of the Prince Albert Grand Council to provide thematic maps of traditional land use within an area of interest encompassing the Midwest Project local assessment boundary. The presentation of the trap lines in Figure 4.6-6 is a more detailed representation of trapping activity in the Midwest Project local assessment boundary and surrounding area than is the trapping block system. It also demonstrates that most trapping activity in the area does not occur within or in close proximity to the local assessment boundary.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-16 Document Integration: (continued) Figure 4.6-6 updated to illustrate trapping block system. Table 4.6-3 on Saskatchewan Fur Statistics Information- Wild Fur Harvest and Cash Value in Northern Conservation Blocks N-18, N26 and N-80 (including youth), for 2003 to 2007, has been added to Section 4 of the main document.

The information outlined in the above response has been added to Section 4.6.3.3 of the Midwest EIS Main Document.

Table 4.6-3 on Estimated northern employment in the McClean Lake Operation Workforce-2006, has been re-numbered to Table 4.6-4.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-17 Comment:

16) Pages 4-126 to 4-127. In the references to the traditional harvesting sites, the Proponent appears to have overlooked some historical events that probably influenced the data. In the late 19th and early 20th century there were disease outbreaks that decimated the local Dene population and completely discouraged them from occupying the area for many decades. One could speculate therefore that traditional knowledge of harvesting sites is directly related to where there was good commercial fishing opportunity in more recent times. Consequently any wildlife habitat away from large lakes has been rated as unimportant in terms of harvesting caribou and moose. However, there may have been a time when the smaller lakes and surrounding habitat were at least equally important as barren-ground caribou spend much time in the more sheltered winter habitats. Also, the Proponent suggests that outfitting for big game does not take place in the area either. This is misleading because outfitters in the respective Wildlife Management Zone 76 are free to operate anywhere in the zone. The fact that the Proponent has not encountered outfitters in the target area may be due the industrial activity in the area. The Proponent should recognize that outfitters have the freedom to hunt there as long as its 500 meters from the nearest occupied dwelling and not on a surface lease where hunting is restricted.

ARC Response:

AREVA acknowledges that the effects of colonization in the 19th and 20th centuries on the aboriginal communities in the local assessment area would have affected traditional land-use data. These events and their effects are reflected in the traditional land-use section of the Midwest Project EIS, as the data presented is generated from oral history and living memory information that were gathered by the Prince Albert Grand Council. The effects of disease outbreaks that decimated the local Dene population would be reflected in the oral history and living memory records.

The archeological record in the local assessment boundary does not support the speculation of previous utilization by Dene of small lakes and surrounding area for harvesting barren-ground caribou and moose. Additional information on this topic can be found in the response to comment MHR-1, which provides the findings of the most recent archaeological study completed in the area. With respect to barren- ground caribou spending much of their time in the more sheltered winter habitat (smaller lakes and surrounding habitat), AREVA has now included riparian habitat classes, R1, R2, R3, as high potential foraging area for caribou in Section 4 Existing Environment. The preferred habitat for caribou in the local assessment boundary now includes the possible utilization of riparian areas by barren-ground caribou and has increased the amount of preferred habitat in the local assessment boundary by a small amount. This has been discussed in more detail in the response to SME-15.

AREVA acknowledges in Section 4.6.3.3 that many outfitters and lodges operate within Wildlife Management Zone 76 (13 bear, 10 moose), which includes the Athabasca Region. In addition to these outfitters, there were 16 lodges that offered sport fishing services, seven of these providing outfitting services, in 2002. AREVA does not imply that outfitters are not allowed to operate within the local assessment boundary but would only be allow access within the lease area with permission.

Document Integration:

No integration required; please refer to responses to Comments SME-15 and MHR-1.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-18 Comment:

17) Section 4.5.3 Wildlife. In reference to large mammal observations depicted on the maps in this section it should be noted that the maps only reflect the timeframe when there was considerable industrial activity. This fact may have influenced the distribution and abundance of sign observed. The Proponent should discuss how industrial activity may have influenced the distribution and abundance of sign observed.

ARC Response:

Habitat utilization of the Midwest study area by moose in the winter of 2003 corresponded closely with what was predicted based on habitat suitability of mapped ecosites. Habitat Suitability Index (HSI) models predicted that moose habitat suitability would be highest in shrubby and treed riparian, treed burns, closed jackpine, and white birch-jackpine closed forest. Winter pellet group densities were observed to be relatively high in all but one (i.e., closed jackpine forest = moderate use levels) of these habitats. This indicates that moose were consistently utilizing high quality habitat in spite of industrial use occurring in the region. Long-term monitoring studies of moose in the central (boreal) mixed-wood region of east-central Alberta by Charlebois and Kansas (2007) have documented stable moose abundance (based on pellet group counts, winter tracking transects and aerial surveys) for a six-year period, in spite of intensive and expanding heavy oil and transportation development. The strongest influence on moose populations in the northern boreal forest is likely related to sport and subsistence hunting (Collister et al. 2003).

The average density of winter moose pellet groups for the entire study area during the winter of 2003/04 was 24.9 groups/ha. This density of moose pellet groups is slightly above average when compared to the mean of 21.1 groups/ha from several studies in the boreal forest region of Alberta from 1986 to 2001 (Devon 2006). Given the northerly extent of the Midwest Project area and limited availability of hardwood forage, the pellet group density that was collected during the winter of 2003/04 was indicative of a strong moose population, despite industrial activity levels. Similarly, there is no reason to expect that other large mammals would be significantly affected by the industrial activity in the Midwest Project area.

Although moose populations in the Midwest Project area are demonstrably strong, AREVA acknowledges that the wildlife data reflects the time-frame when industrial activity was already occurring in the assessment area. Because of this, the Midwest EIS also provides traditional land use information (Section 4.6), based on living memory and oral history, that provides some information on pre-industrial land use, including where large and small mammals have been found.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-18 REFERENCES: (continued) Charlebois, M.L. and J.L. Kansas 2007. Monitoring responses of ungulates and mammalian carnivores to oil and gas development and exploration in the Christina Lake area of northeastern Alberta – 2007 Progress report. Prep. For Devon Canada Corporation by URSUS Ecosystem Management Ltd. Calgary, AB.

Collister, D.M., J.L. Kansas, and T. Antoniuk. 2003. Review and assessment of environmental effects information for wildlife and fish indicators in the Regional Sustainable Development Strategy (RSDS) study area within the Athabasca Oil Sands Region. Prep. for Wildlife and Fish Sub-Group of the Cumulative Effects Management Association (CEMA) by URSUS Ecosystem Management Ltd. and Salmo Consulting Ltd. Calgary, AB. 426 pp.

Devon ARL Corporation (Devon) 2006. Jackfish 2 Environmental Impact Assessment. Volume 2 EIA. Submitted to Alberta Environment.

Document Integration:

The information included in the response above has been added to Section 4.5.3.2, along with the relevant references.

Regulator Comment / Response Comment SK-19 Comment:

18) Section 4.5.3 Wildlife. The Proponent refers to the term “forest ecosite phase”. The Proponent needs to clarify whether this approach to assessing wildlife habitat considers the role of succession.

ARC Response:

The Ecosite Classification System used for terrestrial ecological assessment resulted in 21 mapped land units or Ecosite Phases. These land units were distinguished on the basis of vegetation physiognomy, as dictated by the moisture and nutrient regime. Forested habitats comprised 9 of the 21 mapped Ecosite phases. Other habitats included bog (2), fen (5), marsh (1), riparian shrub/graminoid (2) and anthropogenic/disturbed (2). Successional status is, to an extent, inherent in the classification system for treed habitat types. Early successional types are distinguished by age and include recent burn, shrubby burn and treed burn. Other forested Ecosite phases are greater than 60 years old. As one area develops into another Ecosite Class (through succession), different areas will also be developing and will replace the existing area, keeping the area of each Ecosite Class relatively stable, barring a catastrophic event. The overall ratio or area of each habitat classification, therefore, remains relatively constant over time.

Document Integration:

The above information has been added to Section 4.5.1.1 of the Midwest Project EIS Main Document.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-20 Comment:

19) Figure 4.5-9. The Proponent should distinguish among survey years. This distinction is important when considering the validity of the data in terms of assessing the locations and level of impact that could occur from construction through mine operation.

ARC Response:

Figure 4.5-9 has been modified and is included in the Midwest Project EIS Revision 2 document. All “Pre 2003 nest sites” are now individually labeled with the survey year in the figure. All other raptor nest sites were identified during the 2003 survey as indicated in the figure legend.

Document Integration:

Figure 4.5-9 has been modified and is incorporated into the Midwest Project EIS.

Regulator Comment / Response Comment SK-21 Comment:

20) In Table 6.1-1, the Proponent suggests there is no interaction between the terrestrial environment and all forms of waste. This sets the stage for concluding a negligible residual effect as suggested in Table 6.2-1. Ministry staff would suggest there are potential environmental effects as the tailings management area and sewage lagoon and waste rock storage sites are all located on wildlife habitat that has been largely destroyed as part of the project construction. Consequently, there is an initial interaction, and perhaps subtle long-term interactions that do or might occur as a result of some leakage into surrounding habitat, and/or future unforeseen events.

ARC Response:

Document Integration:

Table 6.1-1 and Table 6.3-1.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-22 Comment:

21) Page 8-37. Section 8.4.1.2 Dedicated Ore Haul Road. The Proponent is proposing to locate the dedicated haulage road beyond both the Midwest and McClean Lake site security gates. Not only should the access to the road be controlled at the start and end points, but also at any other access points along the route. The Proponent needs to address how access to the road will be controlled where smaller roads (e.g., old exploration trails) intersect the main haulage road.

ARC Response:

Acknowledged, unauthorized trails and other transport corridors leading to the proposed haul road will be restricted using a variety of physical barriers suitable to the situation (rock pile, berm, etc.).

Document Integration:

Main Document Section 6, Table 6.2-1

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-23 Comment:

22) Section 10. The Proponent’s assessment that cumulative effects of the project will be negligible is based only the presently known potential of future reserves. The assessment does not appear to account for the following:

1) Future improvements in technology; 2) Changes in the economic climate; 3) New deposit discoveries; 4) Ongoing exploration that will take place over a much larger area to find new sources of uranium; and 5) Other potential human activity that could or will be attracted to the area as a result of the development of the Midwest Project.

The Proponent should consider these factors in the assessment.

ARC Response:

Cumulative effects under CEAA is referred to as “any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out” and is consistent with section 8.3 of the project specific Guidelines for the Midwest Project. Further, the Operational Policy Statement Addressing Cumulative Effects Under the Canadian Environmental Assessment Act (OPS-EPO/3-1999) guides Responsible Authorities to consider projects that are certain and reasonably foreseeable in the assessment of cumulative effects. As such, the hypothetical scenarios for future improvements in technology, changes in the economic climate, new deposit discoveries and ongoing exploration that will take place over a much larger area to find new sources of uranium were not considered. In addition, as mining of the Midwest ore body is expected to proceed with the same mining staff currently operating at the McClean Lake Operation only negligeable increases in human activity is expected from traffic along highway 905.

Please refer to comment HC-4 for further discussion on the cumulative effects assessment.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

1.3 Type III Comments

Regulator Comment / Response Comment SK-24 Comment:

1) Page 3.8. Section 3.2.1 Mink Arm Dewatering. In paragraph 2, “fish habit loss” should read, “fish habitat loss”.

ARC Response:

Acknowledged.

Document Integration:

Section 3.2.1.

Regulator Comment / Response Comment SK-25 Comment:

2) Page ii. Section 4.0 Tables of Contents. The page numbering is incorrect. The page number 4-57 is shown for all sections.

ARC Response:

Acknowledged.

Document Integration:

Correction has been previously provided in errata and is corrected in the resubmission of the EIS.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-26 Comment:

3) Page 4-108. Section 4.5.3.1 Furbearer Mammals. The list of furbearers should include weasel, wolverine, coyote and arctic fox, in addition to the animals already described.

ARC Response:

Weasel, wolverine, coyote and arctic fox have now been added to the animals already listed in Section 4.5.3.1.

Document Integration:

Acknowledged; the above mentioned species have been included in Section 4.5.3.1.

Regulator Comment / Response Comment SK-27 Comment:

4) Figure 3.2-3. The Proponent should identify the location of Shallow Lake and Too Small Lake in Figure 3.2-3. On page 3-11 the Proponent discusses these two lakes and directs the reader to Figure 3.2-3 for the location of these lakes

ARC Response:

Aknowledged, Figure 3.2-3 has been modified to show the location of Shallow Lake and Too Small Lake

Document Integration:

Main Document, Section 3, Figure 3.2-3.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-28 Comment:

5) Figure 4.5-6 is incorrect. The Proponent should refer to www.arctic.com or contact the ministry for the correct depiction.

ARC Response:

Aknowledged, Figure 4.5-6 has been updated.

Document Integration:

Main Document, Section 4, Figure 4.5-6.

Regulator Comment / Response Comment SK-29 Comment:

6) Figures 4.5-7. It should be noted on this map that the caribou tracks observed could be tracks from woodland caribou.

ARC Response:

It is not possible to determine from the evidence what the subspecies of caribou made the tracks. As such, the map is correct in plainly refering to the evidence as caribou tracks.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-30 Comment:

7) Page 6-2. Potential project-environment interactions are identified in Table 6.1-1 not Table 6.1-2 as identified in the summary paragraph (margin entry).

ARC Response:

Acknowledged.

Document Integration:

Section 6.1.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

1.4 Advisory Comments

Regulator Comment / Response Comment SK-31 Comment:

The Environmental Impact Statement (EIS) has no description of the ore body, particularly the minerals present and their relative abundance. What are the primary Uranium minerals? What is the concentration of elements that may be present in the ore? What minerals are present including gangue minerals? Are the high nickel cobalt grades associated with high uranium grades? Is a significant nickel cobalt-rich material not being mined? Has consideration been given to mining additional material just for its nickel cobalt content? What are the economics of your selection?

ARC Response:

Section 4.2.1 Geology has been updated to provide a more complete description of the geological setting. In addition, a detailed description of the Midwest deposit metallogenesis has been added to the EIS as Appendix XIII.

The primary uranium minerals in the deposit are pitchblende and coffinite. A detailed description of the deposit metallogenesis, including uranium mineralization, is described in Appendix XIII, along with specifics of host rock and ore mineral formation, and elements present in the ore.

As presented in the paragenetic sequence the main nickel cobalt bearing minerals formed coevally with major uranium bearing minerals during stages 1b and 2. Because of this, all concentrations of nickel and cobalt are expected to be associated with uranium. Further, higher grades of nickel and cobalt will be associated with high grades of uranium. It is possible that uranium from stage 1a paragenesis may be found without any associated nickel or cobalt minerals however the reverse is not indicated by current geological analysis.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-31(continued) Because the deposit is a massive type with localized high grade areas containing both uranium and nickel cobalt mineralization, mining that would extract the high grade uranium ore would also be expected to remove most, if not all, potential nickel cobalt ore. The paragenesis of the deposit shows that all nickel cobalt bearing material was deposited coevally with uranium mineralization so no significant nickel cobalt rich material would be left in situ after uranium extraction was complete.

As indicated previously, the mining of additional nickel and cobalt material above and beyond uranium mining is not feasible because of the paragenetic history of the deposit. Additional nickel and cobalt mineralization not extracted in the initial phases of mining would be either low grade occurring coevally with low grade uranium or uneconomic areas of minor extent. Milling of the nickel cobalt ore extracted in conjunction with uranium mining has been considered in extensive Midwest feasibility studies spanning several years, most recently updated in 2007. Several ore extraction options have been studied by AREVA to further the possibility of processing the nickel cobalt ore, however; at this time the economics do not support implementing this option.

The most recent market evaluation from the 2007 Midwest Feasibility Study shows that at this time the extraction of Ni and Co from the ore is not economically viable. Long term nickel prices between 1970 and 2004 average 4.6$/lb and in order for the process to break even a sustained nickel price of 8.8$/lb -14.1$/lb would be required. Milling of nickel cobalt ore has been included in the EIS so that should the market reach favourable conditions AREVA has the option to move ahead with this process.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-32 Comment: What uranium cut-off grade is being used to determine mining limits? How was the cut-off grade determined? Could a lower cut-off grade significantly increase the amount of uranium produced? How would this affect the project economics?

ARC Response:

Ore cut-off grades are determined on the basis of the producer’s estimated selling price and net profit anticipated for the product. For the Midwest project Uranium cut-off grades comparable to those used in previous open pits at McClean have been used.

The Midwest deposit is a relatively concentrated zone, well defined of mineralization with sharp contacts differentiating ore grade material from waste material. There is minimal internal dilution within the ore body itself. Given the nature of the high grade ore distribution at Midwest the majority of the Uranium associated with the deposit is attributed to ore at grades significantly higher than the cut-off value therefore a lowering of the cut-off grade does not significantly recover additional Uranium.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-33 Comment:

It is noted that the potential of recovering the nickel and cobalt is being considered. These questions relate to the situation were the nickel and cobalt are not being recovered.

 The tailing facility at JEB was designed for ore from other local mines. Are the tailings from Midwest significantly different from the tailings generated from other ore bodies?  Have these differences been taken into account in accessing the capability of the JEB facility to handle ore from Midwest?  Can the tailings with the high nickel cobalt values be segregated within the JEB tailings pond so at a future time the tailings could be reprocessed?

ARC Response:

The first two items in this comment have been addressed with response to Comment NRCan-16. The geochemical and geotechnical characteristics of tailings made from Midwest ore have been evaluated along with tailings made from all the ore bodies expected to be processed by the JEB mill as part of earlier environmental assessments leading up to the initial operating licence in 1999. The evaluation included tailings made from the JEB, Sue A, Sue B, Sue C, McClean underground, Midwest and Cigar Lake deposits. A tailings preparation circuit and disposal facility was specifically designed so that the long term effects from tailings produced from Midwest ore would be similar to current and previously produced tailings after final disposal in the TMF.

The placement of tailings in the TMF is conducted from a floating deposition barge located in the centre of the tailings pond. Using a tremie pipe, the tailings are tremied on top of previously placed tailings in horizontal layers. As such, the Midwest tailings would be confined to a range of vertical elevation within the TMF. However, the nickel/cobalt values are not segregated from the other deleterious substances contained in the tailings solids such as arsenic, molybdenum, selenium and various radioactive isotopes. Furthermore, the mill production schedule currently anticipates that ore from the Cigar Lake Project will be processed in parallel to the Midwest ore. Midwest tailings would then be co-mingled with Cigar Lake tailings. After final placement of tailings has occurred, it is highly unlikely that a successful business case could be presented for the recovery of nickel/cobalt from Midwest tailings.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-34 Comment:

The report should describe the ownership of the mineral rights and the surface rights in the immediate mine area.

ARC Response:

The mineral claims surrounding the Midwest mine area are held by several different companies including; Cameco Corporation, Japan- Canada Uranium Co. Ltd. (JCU), Fission Energy Corporation, Korea Waterbury Uranium Unlimited Partnership, Hathor Exploration Limited, and Terra Ventures Inc.

All mineral claims in the vicinity of the Midwest mine area have been added to Figure 3.2-1 of the Midwest Project EIS main document.

Document Integration:

The mineral claims surrounding the Midwest surface lease have been added to Figure 3.2-1, and Section 3.2 of the Midwest EIS Main Document,

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-35 Comment:

The current project site plan preferred option requires a surface lease expansion onto mineral lands held by Fission Energy Corp. (Fission). The proposed dumps and waste piles may limit access to those mineral lands. How does AREVA intend to address the access to mineral rights by Fission? Since the impingement on Fission rights is based on the amount of the surface used by AREVA, can some of the facilities, such as the explosive mixing site, cap magazine, dry, and offices, be relocated?

ARC Response:

Over the past several years, AREVA has had a number of discussions with Strathmore Minerals (parent to Fission Energy Corp.) seeking their consent for our proposed surface activities on their mineral lease. However at the time of writing, AREVA has not been successful. Referring to Figure 3.1-4, our original preferred development option was Site Layout 1 . Due to our inability to gain Fission’s consent, the detailed engineering of surface facilities that can be re-located e.g. water treatment plant, heavy duty shop, offices, mine dry etc. are proceeding as in Site Layout 3, making site layout 3 the preferred option. In this configuration, only a small portion of the clean waste rock stockpile along the west side will be located on Fission’s mineral lease. AREVA and its joint venture partners previously held the mineral rights under the land in discussion and which are now held by Fission. AREVA’s opinion, based on its exploration activity, is that there is no potential for an economic deposit under this portion of the Fission mineral lease so there would be no impingement of Fission rights. AREVA therefore intends to request a surface lease extension to cover the clean waste rock area above Fission’s mineral lease.

Document Integration:

No integration required.

Technical Review Comment:

December 2010 Areva’s rationale is acknowledged, and the effort to relocate several structures on the Dawn Lake Joint Venture and on a surface lease to be held by Areva is appreciated. However, requiring a surface lease over Fission Energy’s mineral claim remains a recipe for problem. A solution satisfactory to both parties is to be found, or the layout is to be modified to avoid encroachment.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-36 Comment:

Section 4, Page 4.9, refers readers to Appendix IV for a detailed description of the geology. Appendix IV only has a generalized geological description focusing primarily on the hydrogeology. I suggest more description is required, particularly on the nature of basement rocks if present, and any geological structures that could control water flow.

ARC Response:

AREVA has expanded the description of the geological setting in Section 4.2.1 and included a summary of geological and geotechnical information related to the Midwest Area in Appendix IV, Sub-Appendix A.

Document Integration:

Expanded Section 4.2.1 Geology Added Appendix IV – Sub-Appendix A - Supplementary Geological and Geotechnical Information,

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-37 Comment: Energy and Resources’ regulatory requirements

The proposed project will be subject to the provisions of The Mineral Disposition Regulations, 1986. The mineral dispositions under which the project will be carried out should be in good standing.

Proponent must include the disposition numbers for this project. A map showing the dispositions, project boundary and NTS map grid must be included in the report.

The license approval for the production of the Midwest ore and the processing of that ore at the McClean Lake Operation will, however, initiate some primary regulatory issues from our perspective. These include:

• For purposes of forecasting provincial uranium production and revenues, the identified timeline and mine operational life are sufficient. No further detail is required at this time, once the regulators have made the license decision further information will be available. • Any revision to mining/milling capacity and its method affect the calculation of royalty payments, through the project’s capital banks. Once the regulators have made the license decision this issue can be addressed.

ARC Response:

Aknowledged, please refer to figure 3.2-1 for a map of the Midwest mineral disposition.

Document Integration:

Main Document, Section 3, Figure 3.2-1

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-38 Comment:

A single building is proposed to be located adjacent to the Midwest open pit operation. This will include things such as a first aid room, a kitchen etc. According to the EIS, the meals will be prepared at the main kitchen, at the current JEB site, and transported to the Midwest workers for mid-shift meals, similar to the SUE mining site kitchen. The proposed water supply for this building is a groundwater source via a screened well and is to be treated as a potable water treatment plant. However, as part of the remediation protocols the proponent recommended the localized use of potable groundwater not be allowed in the immediate area adjacent to the pit. Consequently, we would suggest some type of record keeping of ongoing monitoring and testing of the well during its operation and some clear statement on how the water will be treated for potable standards.

ARC Response:

Acknowledged, AREVA will apply to the Saskatchewan Ministry of Environment for a permit to operate waterworks at the Midwest site. As with the McClean Lake Operation Permit to Operate Waterworks AREVA anticipates that the treatment, sampling, monitoring, record keeping, inspection and reporting of potable water will be detailed for approval prior to operation. Protocols for monitoring potable water at the Midwest site will be developed consistent with the current McClean Lake Operation procedure 706-Potable Water Monitoring.

Ground water at the Midwest site will be treated to a potable standards by the addition of hypochlorite. This procedure is consistent with the treatement of source water from ground water at the McClean Lake Operation SUE site.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-39 Comment:

There are basically four types of waste rock generated during the mining operation. The overburden soils (organic topsoil and underlying glacial till), clean waste rock (has low contaminant levels and no acid generating potential), special waste rock (has significant contaminant concentration or acid generating potential) and the ore body stockpile.

a. The clean waste rock will be stored into two stockpiles (Stockpile A, located on the north end of the pit and stockpile B, located on the south end of the pit.). Stockpile A will cover an area of 100 ha and be compacted into two (2) twenty (20) m. lifts for a total height of forty (40) m. Stockpile B will cover an area of 75 ha and be compacted into one (1) lift of (20) m. Therefore, given its close proximity to the Points North airstrip, we wish to see more details regarding “appropriate dust suppression measures” for the local airport and related facilities.

b. Both the special waste stockpile and the ore body stockpile are proposed to be located, as well, adjacent to the local Points North Landing airstrip, so again what control measures are proposed for dust suppression for these stockpiles?

ARC Response:

Fugitive Dust emissions from the Midwest Project were estimated for all sources as discussed in Appendix XIV. The list of constituents investigated included standard pollutants (SO2 and NOx), radon-222, and TSP (and associated metals and radionuclides). The assessment was carried out using the ISCST3 model which has been applied and demonstrated on the McClean Lake Operation as well as other uranium mining applications in northern Saskatchewan. The results of the assessment showed that maximum incremental short-term concentrations of TSP, NOx and SO2 (1-hour and 24-hour, depending on available standards) due to mining activities at the Midwest Project site for the worst case (maximum) mining scenario are within acceptable provincial and federal limits at all discrete receptor locations beyond the surface lease boundary. Elevated levels of suspended particulate matter were predicted to occur on-site under certain meteorological conditions if no active measures are taken to reduce dust emissions. To mitigate these occurrences, fugitive dust emissions will be controlled when conditions dictate by watering on-site roads and active working surfaces as per current practices and procedures followed at the McClean Lake Operation.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-39 As well, haulage of ore from Midwest to the JEB mill is anticipated to potentially result in occasional exceedance of the 24-hour air quality (continued) standard for TSP very close to the haul road that AREVA proposes to build between the Midwest Project and McClean Lake Operation. Measures will be taken when conditions dictate to reduce dust emissions. The effects on TSP levels were shown to decrease quickly with distance and to be very localized. As the road will be constructed on undeveloped lands, there are no residents in the area that would be affected. Nonetheless, AREVA will undertake to reduce emissions when conditions dictate by watering of the haul road following practices and procedures currently employed at the McClean Lake Operation.

Document Integration:

An appendix providing the details of the air dispersion modeling has been included in the EIS as Appendix XIV.

A cross reference to Appendix XIV has been included in Sections 7.1.1.6 and 7.2.1of the main document.

The information included in the above response has been added to Section 7.2.1 Predicted Effects on Air Quality, of the Midwest EIS Main Document.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-40 Comment:

The EIS states that a new solvent extraction process may be included for molybdenum. This will produce molybdenum as a by-product of the mining operation. As a result, were there any special protocols/notifications that may need to be given to the communities, or their Emergency Response Organizations, located on the transportation route from the mine?

ARC Response:

It is anticipated that Molybdenum extracted during the milling of uranium will be in the form of a white to grey molybdenum oxide powder. In this form, the molybdenum byproduct will be classified as a toxic inorganic solid, class 6.1, under the Workplace Hazardous Materials Information System (WHMIS) with UN Number UN3288. Molybdenum oxide produced for commercial sale will be transported from the mine site in approved means of containment in strict adherence to Transport Canada Transportation of Dangerous Goods Regulations. As required by Transport Canada, AREVA Resources Canada will develop and Emergency Response Assistance Plan (ERAP) for the transport of molybdenum oxide, which will include appropriate training of emergency response organizations along the transport route.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-41 Comment:

Given the recent events over the lethal wildlife attack of an individual working at the Points North Landing area, who will be responsible for the security and management of the landfill proposed for the Midwest Operations?

Other than some of the issues noted above, we are satisfied that the Midwest Project will not present any adverse environmental health effects on the region. We assume that issues such as those regarding onsite waste water management and worker health and safety will be managed in accordance with the applicable Acts and Regulations of the Ministry of Environment and the Ministry of Advanced Education, Employment and Labour respectively.

ARC Response:

AREVA will be responsible for management and security of the Midwest landfill.

The landfill at the Midwest site will be an industrial landfill used for the disposal of materials such as construction debris. To minimize the risks of wildlife interaction domestic garbage containing food items such as food scraps will be taken to McClean Lake for disposal in the incinerator.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-42 Comment:

While there have been several archaeological surveys in the area, including the haul roads in the 2006 permit year, I would reiterate the comments of my colleague Nathan Friesen of Feb 17, 2006 regarding the AREVA project.

In that correspondence he stated:

"The proposed mine area, while previously affected by an existing mining operation, would appear to expand into many areas that have been previously undisturbed. In particular, the shorelines of the lake and upland margins above the lake are considered to have high potential for heritage resources. Indeed, previous surveys have identified a number of sites along the shorelines of North and South McMahon Lakes. Previous studies have been conducted along the northern half of the Mink Arm of South McMahon Lake. This study was conducted over 25 years ago, and the records are not clear as to the exact areas that were examined. The southern half of the Mink Arm has not been surveyed. Given the known heritage potential of the development area, previously undisturbed portions of the proposed development will require a Heritage Resource Impact Assessment (HRIA).

For more specific heritage requirements, maps of the proposed developments should be submitted to our office for review."

Insofar as no complete HRIA has been done, there would likely be the need for additional heritage work to be done in the area.

ARC Response:

A qualified consultant was contracted by AREVA Resources Canada Inc. to conduct a Heritage Resources Impact Assessment (HRIA) on the proposed Midwest Project, located in the boreal forest of northwestern Saskatchewan (Young 2008). The heritage study area examined as part of this assessment included the shoreline of North McMahon Lake and South McMahon Lake (including Mink Arm), as well as portions of nearby Shallow Lake. This assessment completed under Archaeological Resource Investigation Permit No. 08-129, issued by the Heritage Resources Branch.

Approximately 20 km of shoreline were assessed and 609 shovel probes were excavated. No new heritage resources were identified during this assessment, and despite attempts to relocate eight previously recorded sites in the region, only IbNa 6 (see Section 4.6-1) was positively identified. A subsequent shovel-testing program of the site areas determined that these locales were of limited archaeological value.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-42 Generally speaking, relatively few heritage resources have been identified on the McMahon Lakes. It is notable that six of the sites were (continued) found on North McMahon Lake, which may reflect the greater heritage potential of this lake, with its elevated and sandy shores. In addition, North McMahon Lake is connected by Smith Creek to Hatchet Lake to the north, where the Fond du Lac River enters from the west and various waterways join Wollaston Lake to the east. North McMahon Lake may have had a secondary connection to this more direct and utilized water route to the north.

Based on this assessment, it was recommended that the Midwest Project would meet the conditions for regulatory approval as specified in Section 63 of The Heritage Property Act. The HRIA report, conducted under Investigation Permit #08-129, was submitted to the Heritage Resources Branch of Saskatchewan. A letter has been received from the Heritage Resource Branch,, stating that, with the completion of the HRIA, the office had no further objection to the Midwest Project proceeding as planned.

REFERENCES:

Young, P. 2008. Final Report on Permit No. 08-129 AREVA Resources Canada Inc. Midwest Project Heritage Resources Impact Assessment. July 2008.

Document Integration:

A summary of the results of HRIA report, permit no. 08-129, has been included at the end of Section 4.6-1 of the Main Document of the Midwest EIS.

The relevant references have been added to the Section 4 Reference section.

Table 4.6-1 has been modified to include the HRIA conducted under permit #08-129.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-43 Comment:

The worksites are accessed via Hwy 905; a dedicated (private) haul road links the Midwest and McClean Lake sites.

Sask. Highways recognizes the probability of increased traffic and loadings on Hwy 905, but has no environmental concerns.

ARC Response:

Acknowledged

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-44 Comment:

Community Resources has only one specific concern regarding the socio-economic impact of the Midwest Project for AREVA Resources. The report mentions the expected increase in employment, as well as investment, in section 8 of the report.

However, AREVA's environmental impact statement report does not provide a summary table of the direct economic impact of the Midwest Project over the life of the project, particularly with respect to the incomes generated by the new employment created by the project. Such a table would be a useful addition in assessing the total socio-economic benefits of the project.

ARC Response:

As indicated in Section 8.5.3, the initial construction phase of the Midwest Project will be completed by a temporary contractor workforce that is expected to peak at around 200 employees. It is anticipated that about 80% of the contractor workforce, or about160 employees, will be residents of northern Saskatchewan. Routine mine operation will require an estimated increase to the base McClean Lake Operation workforce of approximately 80 mine workers. It is anticipated that approximately 80% or about 64 of these mine workers will be residents of northern Saskatchewan. Routine mine operation is expected to last four years. The 2005 Athabasca Working Group (AWG) Annual Report (AWG 2005) calculated the average wages and benefits for Athabasca region residents, from uranium mine employment, to be $47,600 per employee per year. For the Midwest Project construction phase, the wages and benefits translate into $7,616,000 per year in northern Saskatchewan. During the Midwest Project mine production phase, northern Saskatchewan residents’ wages and benefits would total approximately $3,046,400 per year.

REFERENCES:

AWG (Athabasca Working Group). 2005. Athabasca Working Group Annual Report, 2005.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-45 Comment:

We note that Section 4.6, Human Component for Athabasca Region describes the regional socio-economic situation, and identifies a treaty land entitlement selection within the area. We recommend that AREVA include Northern Municipal Services of this department as a stakeholder, since the proposal has potential to affect community development and economic opportunities for local people.

ARC Response:

In addition to our normal stakeholders, AREVA will present a proposed Project, and later on the environmental effects of the proposed Project to any organization or group who requests a presentation. In the past we have not had any requests from Northern Municipal Services but would willingly comply once the request is established.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-46 Comment:

The Ministry encourages AREVA, where applicable, to provide employment, economic and training opportunities, to first Nations and Métis people and contractors arising from the project.

The EIS indicates AREVA conducted a consultation program developed to provide information and ensure that environmental and health and safety concerns that may arise as a result of the project are effectively communicated and addressed. The consultation efforts focused primarily on those groups most likely to be affected by the potential environmental effects from the project including; Peter Ballantyne Cree Nation (PBCN); and the communities of La Ronge and Saskatoon. Consulting and building co-operative relationships provides an opportunity for Aboriginal people to have their views shape development initiatives that may impact them and their Treaty and Aboriginal rights.

The Ministry advises that the Provincial Ministries/Crowns undertake a pre-consultation assessment related to understanding what Treaty or Aboriginal rights or traditional uses could be adversely affected by the project. This assessment needs to delineate the provincial duty to consult responsibilities from the federal obligations. Should you wish to discuss this further or require additional information on the Government of Saskatchewan Guidelines for Consultation with First Nations and Métis People, please contact James Froh, FNMR, at 787- 7405.

ARC Response:

Acknowledged

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-47 Comment:

As indicated in the EIS, a review of our files indicates that there is an active Treaty Land Entitlement (TLE) selection located within the proposed development area:

• Peter Ballantyne Cree Nation, FNMR File No. 820.144. – Asamera Selection, (Formerly FNMR No. 820.031.7). The proposed North Route (preferred option) of the haul road/corridor between Midwest and the JEB mill passes within the TLE selection. Under the terms of the Saskatchewan Treaty Land Entitlement Framework Agreement the Province is committed to hold the land and minerals available for sale to PBCN for a period of eighteen months commencing on October 22, 2007 and ending on April 21. 2009.

A further review of our files indicates that there are no other active TLE, Specific Claim selections or Indian Reserves in the proposed development area. As well the project appears to be located in the Métis Nation of Saskatchewan Northern Region 1 area.

ARC Response:

Acknowledged. At the time of resubmission AREVA was informed that TLE previously selected by PBCN is no longer active.

Document Integration:

No integration required.

Regulator Comment / Response Comment SK-48 Comment:

With regard to the Midwest Project, upon AREVA receiving environmental approval for their proposed revised approach to mining the Midwest ore deposits, and subject to the company’s confirmation of the sustained commercial viability of the proposed project, Northern Affairs is prepared to negotiate an amended mineral surface lease agreement with AREVA for the Midwest mine.

ARC Response:

Acknowledged

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-49 Comment:

As contemplated at this time, the amended surface lease would also address the company’s need for an expanded footprint to accommodate additional Midwest facilities and functions, plus land tenure for its dedicated haul road between Midwest and JEB sites and the required road right-of-way. As part of the surface lease negotiation process, and with the support and participation of colleague provincial departments and agencies as required, Northern Affairs will ensure the Province’s duty to consult is fulfilled with nearby First Nations and Aboriginal communities concerning the proposed project and any impacts it might be perceived as having upon their Treaty and/or Aboriginal rights.

ARC Response:

Acknowledged

Document Integration:

No integration required.

Regulator Comment / Response Comment SK-50 Comment:

The Mine Safety Unit has a question regarding the D2 and D4 distances for the powder magazine/Explosives mixing area. It is not clear from the drawings supplied that these distances will meet regulation. All other OH&S issues will be handled with routine inspections.

ARC Response:

EIS presents a conceptual design for the purposes of the environmental assessment and not final design drawings. The placement of the facilities will be addressed at licensing to ensure compliance with all regulations.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-51 Comment:

The project indicated that there will no changes in the JEB Tailing Management Facility (TMF) with the milling of the Midwest ore. The report assessed and evaluated the pore water constituents and identified the solute and mass flux out of the TMF. We suspect there will be negligible impacts to the regional groundwater regime or would be addressed through on-going operations. However, it was unclear in the report on the reduction in the life expectancy of the existing TMF from the additional milling.

ARC Response:

The JEB TMF has a fixed capacity for the final disposal of tailings. The long term effects have been assessed with the TMF filled to capacity. The volume of tailings to be produced from the Midwest ore is the same regardless of the processing rate. If the Midwest ore is processed more quickly than originally planned then at some point the TMF capacity will be reached sooner than predicted. However, this will not affect the prediction of long term effects from the final decommissioned facility.

Document Integration:

No integration required.

Technical Review Response:

Please provide clarification surrounding the life expectancy of the existing TMF including the following:  The current remaining capacity of the JEB TMF.  The predicted volume of tailings generated from each ore source proposed to be milled at McClean Lake, including the remaining 2010 ore at McClean Lake, Midwest ore, McArthur River ore and Cigar Lake ore.

 A proposed timeline identifying the type of ore to be processed in each year, the predicted volume of tailings generated for each Was previously type of ore processed and the anticipated year the TMF storage capacity will be reached. an advisory  A discussion surrounding future tailings storage alternatives once the TMF storage capacity is reached. comment

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments ARC Response:

 At the end of 2010 the remaining capacity of the JEB TMF, consolidated tailings to the 439 mASL, or unconsolidated tailings placed up to elevation 439 mASL will be approximately 599,584m3 o Placement of tailings in the JEB TMF is currently assessed for a consolidated tailings elevation of 434 mASL

 The ability to generate and communicate an accurate tailings production schedule should not be required as part of this EIS, as the schedule is based on business decisions and is further prevented based on the following uncertainties: o The start date for the construction and mining of Midwest is currently unknown and is based on regulatory approvals and economic conditions; June 2010 o There is no confirmed date for the receipt of Cigar Lake ore slurry at the JEB mill; and o The receipt of McArthur River ore at the JEB mill is currently undergoing regulatory review and therefore a start date has not been confirmed  However, it is noted that the Midwest EIS assessment of effects is based on a TMF filled to capacity, as outlined in Appendix XI  Mill capacity and tailings capacity is a licensing issue

 Evaluations are underway regarding a variety of options for the long term management of the TMF and tailings generated at the JEB mill for the next decades. If any future tailings management facilities are required, they will be subject to an environmental assessment.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-52 Comment:

In section 12, the monitoring and follow-up programs are discussed. Included is the on-going hydrogeology program, namely hydrogeological testing and monitoring. The proposed monitoring during and after decommissioning of the site is unclear, considering that contaminant concentrations may increase with time. In particular the long term monitoring and assessment of impacts from the JEB TMF into the groundwater regime to Pat Lake and Fox Lake are of interest.

ARC Response:

The JEB TMF is a licenced and approved facility and an assessment of the JEB TMF has not been undertaken in the Midwest EA. As described in Section 12.4 details of the environmental monitoring program will be provided at licensing.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment SK-53 Comment:

The design of the haul road and potential impacts to the environment from spills was presented along with the mitigation measures in case of a spill. However, a contingency plan for the mitigation of groundwater in the event of a spill was not discussed in the EIS. We suspect this was presented in detail in the accompanying Appendices. It would be convenient for the reader if some discussions were included in the EIS.

ARC Response:

Section 3.7 Malfunctions or Accidents addresses emergency response scenarios, however does not specifically address a contingency plan for the mitigation of groundwater in the event of a spill. However, the development of McClean Lake Operation emergency response plans and procedures have considered the likelihood of spills occurring and the nature and extent of any potential adverse effects. Additionally, effective implementation of spill prevention planning is also an important proactive component for minimizing the risks posed by spills.

Should a spill occur while transporting ore or hazardous substances along the Midwest McClean haul road, current spill response procedures in place at the McClean Lake Operation provide sufficient mitigation to the potential impact to groundwater by minimizing the transfer of contaminants through appropriate response, containment, collection, removal and analysis measures.

Should post-spill monitoring detect contaminated groundwater, a robust clean-up plan will be developed, utilizing qualified AREVA personnel and obtaining support from specialized contractors/consultants and regulators, when required.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments Regulator Comment / Response Comment SK – comment Comment: on DFO-9 A study conducted by P.A. Thompson et al., Derivation and Use of Sediment Quality Guidelines for Ecological Risk Assessment of Metals and Radionuclides Released to the Environment from Uranium Mining and Milling Activities in Canada, indicates that SEL working 2010 benchmarks are not reliable predictors of impacts on benthic invertebrate communities. AREVA should determine if LEL working benchmarks are available since they would more accurately predict impacts.

ARC Response:

see response to DFO-9

Technical Review Response (for future consideration, no follow-up required)

It is important to note that one of the scientists involved in developing the CNSC SEL benchmarks wrote a paper in 2005 entitled, "Derivation and Use of Sediment Quality Guidelines for Ecological Risk Assessment of Metals and Radionuclides Released to the Environment from Uranium Mining and Milling Activities in Canada.” The introduction to this paper states:

"The derived SEL values and corresponding published SQGs (with the exception of Ni) were not reliable predictors (≤60%) of severe impacts on benthic December 2010 invertebrate communities when severe impacts are defined as a reduction in abundance and species richness ≥40%. Most of the severely impacted sites had sediment contaminant concentrations well below the SEL values. It is concluded that LELs derived using the weighted method can reliably be used in ecological risk assessments as concentrations below which adverse effects on benthic invertebrate communities are not expected. In contrast, it is recommended that SELs not be used in assessments of uranium mining/milling activities as concentrations above which adverse effects are anticipated."

AREVA should utilize CNSC LEL benchmarks only where regional toxicity benchmarks are not available.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments Regulator Comment / Response Comment E&R-1 (2010) Comment:

NEW The report should describe the ownership of the mineral rights and the surface rights in the immediate mine area.

The map (Figure 3.2.1) added to the revised document lacks any reference grid and is therefore inadequate.

ARC Response:

Figure 3.2.1 clearly indicates ownership of mineral rights. Figure 3.2.1 has been updated to include AREVA’s Midwest surface lease and a reference grid using SaskGrid, NAD 83 CSSR Extended Zone 13 North (as directed by Bram J. Nelissen) has been applied. The figure has been viewed by Bram Neliessen.

Document Integration:

Figure 3.2.1, to be included in the figures section of Section 3.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments

Regulator Comment / Response Comment E&R-2 (2010) Comment:

NEW The current project site plan preferred option requires a surface lease expansion onto mineral lands held by Fission Energy Corp. (Fission).. The proposed dumps and waste piles may limit access to those mineral lands. How does AREVA intend to address the access to mineral rights by Fission? Since the impingement on Fission rights is based on the amount of the surface used by AREVA, can some of the facilities, such as the explosive mixing site, cap magazine, dry, and offices, be relocated?

In AREVA’s revised submission, AREVA indicates they have had no luck in obtaining Fission’s co-operation. AREVA have opted for relocating their facilities off of land overlying Fission’s mineral rights but leave the waste dump over Fission’s mineral rights. It is AREVA’s opinion, based on their exploration in the affected area, that there is no potential for an economical deposit in the area held by Fission. The Mines Branch retains its opinion that the issuance of surface rights, where the requestor does not hold the mineral rights, may lead to serious issues especially in uranium where joint surface rights are not permissible. ARC Response:

To accommodate potential surface lease constraints resulting from the original site layout proposed in the 2005 Project Description and initial EIS, the dry and offices that were on mineral lands held by Fission have been relocated to mineral lands held by the Dawn Lake Joint Venture and the explosive mixing site and cap magazine have been relocated along the haul road which will be on a surface lease held by AREVA.

With respect to the waste rock placement on a portion of the land above the Fission mineral rights, access by conventional drilling will be restricted. However, it is AREVA view that the stockpiles will not prevent Fission from continuing with its exploration program by utilizing directional/angle drilling methods. Furthermore, AREVA has previously held the mineral rights in question and is of the view that there is any economical deposit on this small area. Finally, if Fission were to discover economical ore and develop a viable mining plan, AREVA would be in the position to hold discussions with the Province and Fission regarding relocating the portion of the stockpiles preventing access to the extract the ore. Fission would also require access to both the Surface Lease held by the McClean Lake Joint Venture (including AREVA) and would require access to the lands above the mineral rights held by the Dawn Lake Joint Venture.

Finally, AREVA has investigated the laws related to mineral rights and has confirmed with representative from the Province of Saskatchewan that holding the mineral rights does not guarantee you access to the surface rights above.

Document Integration:

No integration required

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Provincial Comments Technical Review Response:

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum

Response to Comments

1 APPENDIX III COMMENTS

Regulator Comment / Response Comment DFO-1 (App. III) Comment:

Feb 2010 Page 10 states that the maximum depth of Too Small Lake is 2.1 metres, whereas Figure 2.1 states a maximum lake depth of 3.1 metres

ARC Response:

Typo. Too Small Lake maximum depth is 3.1 m.

Document Integration:

Text changed to 3.1 m

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-2 (App. III) Comment:

Feb 2010 More information on the water quality of the Sink Reservoir and Vulture Lake needs to be provided, as outflows from these water bodies may affect fish habitat downstream. It is noted that water exits these water bodies via deep-water pipes, and that the concentration of some parameters, such as ammonia, increases as water depth increases; however, predicted downstream water quality, as shown in Appendix 5, appears to be based on surface water data. Water quality data at the depth of water release, and predicted impacts on the water quality of McClean Lake and Collins Creek, need to be stated.

In Appendix 5, predicted levels of ammonia are based on an assumed pH of 7.5; however, observed levels of pH are not stated. Observed pHs and corresponding predicted levels of ammonia in McClean Lake and Collins Creek need to be provided. Levels of dissolved oxygen in the Sink Reservoir and Vulture Lake need to be stated. The downstream affect of changes in SO4 concentrations within the Sink Reservoir and Vulture Lake needs to be stated.

ARC Response:

It is noted Sink Reservoir and Vulture Lake form part of the McClean Lake Operation Sink/Vulture Treated Effluent Management System (S/V TEMS) which has been in operation for ten years to manage effluents generated at the site. The design of this facility was the subject of previous environmental assessment and review by the Joint Federal-Provincial Panel on Uranium Mining Developments in Northern Saskatchewan and is part of an existing, licensed facility.

To clarify, water exits Sink Reservoir near the reservoir bottom, but enters Vulture Lake at the water surface via the reservoir control structure. Water from Vulture Lake exits near the lake bottom and enters the east basin of McClean Lake via a diffuser that is located approximately 1 m below the water surface (see Figure 3.5-4 in the Midwest EIS). Ammonia, pH, and SO4 are measured frequently (daily, monthly or quarterly) in surface water samples from the S/V TEMS, in water bodies downstream of the treated effluent release, and at flow control station samples (Stations CM03 and CM04, as shown in Figure 4.4-1 in the Midwest EIS). The frequency and locations of this sampling are included in the McClean Lake Environmental Monitoring Program (EMP), as part of the McClean Lake licensing documentation. The results of these measurements are reported in the monthly and annual reports supplied to the Saskatchewan Ministry of Environment, Environment Canada, and the CNSC.

The assumption that the lake water quality samples are surface water quality samples is correct, except where additional sampling has been done. The 2005 McClean Lake SOE (AREVA 2006) presented under-ice limnology profiles measured in depositional benthic invertebrate sampling areas in April, and included Sink Reservoir, Vulture Lake, McClean Lake east basin and Kewen Lake (Table 46, AREVA 2006). The measurements taken included DO and conductivity at several depths in each lake, as well as surface pH measurements. During the ice cover period, the east basin of McClean Lake can illustrate stratification based on conductivity measurements between 1 and 1.5 meters. None of the other lakes changed markedly with depth in specific conductance,. Sink and Vulture Lakes are homogenous and effluent appears to mix throughout the water bodies. Conductivity was used to delineate the spatial pattern of effluent dispersion at different depth horizons during open-water (October/September) and ice-covered (April, Table 46) seasons (AREVA 2006). Seasonal differences were apparent and based on the use of conductivity as an effluent tracer, under ice cover. During the open-water season, more complete mixing of the water column was demonstrated. In July, August and September of 2007, additional limnology measurements were taken in Vulture Lake. Dissolved oxygen, temperature, turbidity, TDS, conductivity and pH were measured at 0.5 m depth intervals at various locations throughout the lakes. The survey showed that DO, temperature and pH were relatively uniform with depth and DO remained high throughout the water column (>7.5 mg/L). Therefore the assumption of a consistent pH throughout AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment Vulture Lake in the modelling for ammonia in Appendix V is reasonable. The pH was also shown to be relatively stable, ranging from a low of 6.92 to a high of 8.71, with the average being around 7.5, corresponding to the predicted pH that was generated by modelling.

As stated above, DO depth profiles have been completed under ice-covered and ice-free conditions in the lakes in the McClean Lake Operation area. Under-ice conditions represent the lowest or worst-case scenario for DO levels through the year. Under-ice DO levels in the Sink Reservoir ranged from 2.51-5.38 mg/Lin April 2005 and from 1.63-2.80 mg/L in March 2008 (AREVA, 2009, Appendix F, Table 5). Dissolved oxygen in all other lakes, including Vulture Lake, which ranged from 6.31-11.12 mg/L in April 2005 (AREVA 2006) and from 5.94- 10.04 mg/L in March 2008 (AREVA 2009) remain elevated throughout the water column under ice with values ranging from 6.31-11.12 mg/L. Therefore, suppressed winter DO levels do not appear to be a concern for fishes living in the lakes downstream of the treated effluent release. It should be noted that suppressed late-winter DO levels in are not uncommon in small, relatively isolated fish-bearing lakes in northern Saskatchewan. For example, at the Midwest site, Lake C1, Pig Lake and John Pond illustrate suppressed under-ice DO levels (Midwest EIS Tables 4.4.-1 and 4.4-42), but appear to maintain sparse remnant fish populations. Similarly, baseline data collected at Sink Lake revealed under-ice DO levels ranging from 0.6-1.4 mg/L and the presence of fish (Minatco Ltd. 1995). Similarly, baseline data indicated Candy Lake supported fishes and had under-ice DO levels ranging from 1.7-2.8 mg/L (Minatco Ltd. 1991).

The McClean Lake Operation SOE 2005 report (AREVA 2006) compared measured water quality parameters with the 1991 and 1995 predictions. Ammonia and sulphate varied in recent years, but have not exceeded the 1991 and 1995 maximum mean monthly predictions. Looking at temporal trends, ammonia showed a decreasing trend over time at the McClean Lake outlet. Sulfate concentrations are higher in Sink and Vulture, but decline rapidly in McClean Lake. Additional detail can be found in the McClean Lake SOE reports (AREVA, 2006; AREVA, 2009).

The statement that ammonia increases as water depth increases, in the above comment, is a generic statement and is not based on the data available for any of the lakes in the local assessment area. Water quality, including ammonia measurements, is reported in McClean Lake operation monthly and annual reports and the Status of the Environment Reports every 3 years in fulfillment of site regulatory compliance. The Canadian Council of Ministers of the Environment (CCME) and the Saskatchewan Ministry of Environment have set a water quality guideline/objective for un-ionized ammonia of 0.019 mg/L (CCME 2009). This value represents the lower 95% confidence interval surrounding a species sensitivity distribution (SSD) curve for un-ionized ammonia toxicity based on 20% Effect Concentration (EC20)/20% Lethal Concentration (LC20) values (as depicted in Figure 2 in CCME 2009). At this concentration, it is believed that only 5% of all species will be affected by un-ionized ammonia. Un-ionized ammonia concentrations that have been measured in McClean Lake East Basin (at Station WQ11E) have not exceeded the CCME guideline. With the exception of one measurement in August 1998 (0.3 mg/L, an apparent outlier), un-ionized ammonia at Station WQ12E in Collins Creek has consistently measured below 0.019 mg/L.

The methodology applied to evaluating the implications of effluent release on water quality within and downstream of the effluent release is consistent with, and builds upon the methodology that was successfully applied as part of the Sue E environmental assessment (COGEMA 2004) by incorporating additional operational experience and monitoring information into the assessment methodology (Midwest EIS, Section 3.0). These predictions, along with the integrated risk assessment (Section 7.0), provide a comprehensive assessment of residual effects of treated effluent release from the proposed project. AREVA is committed to continual improvement, and reducing ammonia releases in the treated effluent.

References:

COGEMA. 2004. McClean Lake Operation Sue E Project Environmental Impact Statement. November 2004.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

AREVA. 2006. McClean Lake Operation. Status of the Environment Report, Assessment Period 2003-2005.

AREVA. 2009. McClean Lake Operation. Status of the Environment Report, Assessment Period 2006-2008.

CCME (Canadian Council of Ministers of the Environment). 2009. Canadian water quality guidelines for the protection of aquatic life: Ammonia.

Minatco Ltd. 1991. McClean Lake Project. Environmental Impact Statement. Supporting Document II – Aquatic Environment.

Minatco Ltd. 1995. McClean Lake Project. Baseline Investigations 1993-1995.

Document Integration:

As clarified in the ARC Response above, supplementary information on existing licensed facilities has been provided to regulatory agencies in AREVA’s SOE reports.

No integration is required.

Response from Province: A 5% impact to all species is a significant impact. AREVA should provide information on how the species June 2010 impact will relate to individuals of the impacted species.

ARC Response To clarify, the 5% impact to all species is referring to the criteria that the CCME guideline is based on. The CCME guideline is designed to be protective of 95% of all aquatic species. If 5% of species were affected at the CCME guideline, these species would include only the most sensitive species, not all species present. The CCME guideline is based on laboratory test work and most of the sensitive species used to determine the guideline value are not present in northern Saskatchewan waterbodies, therefore this estimated 5% of the most sensitive species would not be present and would not be affected.

As stated above, in the response to the original comment, concentrations of un-ionized ammonia have always been below the CCME guideline below the outlet at McClean Lake (WQ12E). Because the concentrations are below the guideline it is not expected that unionized ammonia will have an effect on aquatic organisms. The McClean Lake Operation is committed to meeting Saskatchewan Surface Water Quality Objectives (SSWQO) in Collins Creek downstream of McClean Lake. The SSWQO un-ionized ammonia objective is the same as the CCME guideline fro un-ionized ammonia. If a 5% decrease in the most sensitive organisms was expected, this 5% impact would not affect populations, therefore any effect would not be classified as significant as defined by the Canadian Environmental Assessment Agency.

Document Integration

No integration required AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-3 (App. III) Comment:

The aluminum concentration of 100 ug/l (0.1 mg/l) in Too Small Lake (Table 4.4-3, main document), reported in 2003, is of concern in that it exceeds the government of Saskatchewan surface water quality objective of 5 ug/l when pH is < 6.5, the calcium concentration is < 4.0, and the dissolved organic carbon (DOC) concentration is < 2 mg/l. The pH was reported to be 5.9, but DOC was not measured. The level of DOC within Too Small Lake needs to be reported and concerns regarding the toxicity of aluminum need to be addressed prior to the acceptance of this lake as compensatory fish habitat.

ARC Response:

Thank you for your question. Too Small Lake is a shallow water body with no inflowing and no distinct outflowing streams. Furthermore, no aquatic sources of contaminants related to the activities at the McClean Lake Operation or the Midwest site influence Too Small Lake. The lake may receive small contributions of dust from atmospheric sources related to site activities, but these sources are not expected to be a significant source to the contaminant load in the lake. On this basis, Too Small Lake serves as a reference lake that is monitored periodically on the Midwest site.

With respect to the Saskatchewan Surface Water Quality Objectives (SSWQOs), including the SSWQO for Al, the province has decided to directly adopt the generic Canadian Council of Ministers for the Environment (CCME) water quality guidelines (WQGs) for the protection of aquatic life (Saskatchewan Environment 2006). At the time the SSWQOs were issued by the province, the CCME WQG for aluminum was set based on site-specific pH conditions, Ca concentrations and dissolved organic carbon (DOC) concentrations, whereby the Al guideline was: 0.005 mg/L at pH <6.5, Ca <4 mg/L and DOC <2 mg/L; and 0.1 at pH ≥6.5, Ca ≥4 mg/L and DOC ≥2 mg/L (CCME 2003a; Saskatchewan Environment 2006). The generic CCME Al WQG upon which the SSWQO had been set (which had been based on pH, Ca and DOC) has since been withdrawn and updated to account for only site-specific pH conditions, whereby the guideline is set at 0.005 mg/L for pH <6.5 and at 0.1 for pH ≥6.5 (CCME 2007a). Therefore, with respect to current guidance, pH is the driving parameter in setting the surface water guideline for Al and a guideline value of 0.005 mg/L was used for Too Small Lake, since the pH of the lake typically falls below the 6.5 threshold set by both Saskatchewan Environment (2006) and CCME (2007a). That said, in 2008, DOC was measured in Too Small Lake in response to this comment, producing a mean value of 8.83 mg/L, with a corresponding mean Al concentration of 0.055 mg/L.

Although Too Small Lake is not influenced by activities on the McClean Lake or Midwest sites and is considered a reference lake (as described above), Al concentrations in Too Small Lake have been reported to exceed the SSWQO of 0.005 mg/L for Al. That said, it is not uncommon for poorly buffered lakes of low pH in baseline areas to have Al concentrations that exceed 0.005 mg/L. For example, comparable Al values have been reported for a number of natural lakes and streams, as summarized in Table 1 below. In addition, similar Al concentrations were measured in Eastern Ontario during a baseline survey of 153 surface waters that was conducted between 2004 and 2006 by Yankovich (pers. comm.). During this survey, Al concentrations of as high as 0.08, 0.22 and 0.23 mg/L were measured during the 2004, 2005 and 2006 sampling campaigns, respectively, for water bodies with pH values of < 6.5.

It is possible that the relatively higher Al concentrations in Too Small Lake may be related to suspended particulates in the water. For AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment example, further examination of available data reveals a statistically significant relationship between Al concentrations in Too Small Lake and the total suspended solids (TSS) in the lake (Figure 1), as follows:

Al (mg/L) = 0.0565 Ln(TSS in mg/L) + 0.0156 r2 = 90.51%; P = 0.0035

A similar relationship was also found for Al concentration in water versus turbidity in Too Small Lake (Figure 2), where:

Al (mg/L) = 0.0334 (Turbidity)1.243 r2 = 82.94%; P = 0.0116

The same general trend can also be discerned in broader comparisons of TSS versus Al concentrations in reference lakes on the Midwest and McClean Lake sites (Figure 3), such that:

Al (mg/L) = 0.0079 (TSS) + 0.009 r2 = 81.6%

It is also important to note that CCME (and SSWQO) guidelines have been developed to serve as highly conservative, generic, screening- level benchmarks, which can be applied to rapidly screen out non-issues, and in situations where these values are exceeded, more realistic guidelines may be applied to determine if effects could be occurring (CCME 2003b; CCME 2007b). For example, Al water quality benchmarks of 0.46, 1.9 and 3.28 mg/L have been proposed by Suter and Tsao (1996) for the protection of aquatic primary producers, aquatic invertebrates and fishes, respectively. By comparison, concentrations that have been measured in Too Small Lake fall below these benchmarks, with values ranging from 0.048 to 0.2 mg/L, therefore, suggesting no effects to resident biota. This conclusion is confirmed when comparing Al concentrations in the surface waters of reference lakes on the Midwest site, including Too Small Lake, to phytoplankton biomass, zooplankton density and benthic invertebrate density (Table 2 – compiled from Tables in Section 4.4 of the Midwest EIS). Briefly, although the mean 2003 Al concentration in Too Small Lake (0.13 mg/L) is higher than those measured in other reference water bodies on the Midwest site (which ranged from <0.005 to 0.064 mg/L in 2003), Too Small Lake shows a relatively higher phytoplankton biomass, zooplankton density and benthic invertebrate density than any of the other lakes sampled (Table 2).

In addition, Too Small Lake supports a healthy ninespine stickleback population compared to other lakes in the area, which suggests that the lake can support fish. It is expected that with the addition of a deepwater basin adjacent to the existing shallow littoral habitat in Too Small Lake, which will provide overwintering habitat, Too Small Lake will support a more diverse fish community than currently present.

References:

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment AREVA. 2009. Midwest Project: Existing environment, Technical Information Document. December 2009, Version 01/Revision 00.

CCME (Canadian Council of Ministers for the Environment). 2003a. Canadian water quality guidelines for the protection of aquatic life: Aluminium. WITHDRAWN.

CCME (Canadian Council of Ministers for the Environment). 2003b. Guidance on the site-specific application of water quality guidelines in Canada: Procedures for deriving numerical water quality objectives. Winnipeg, Manitoba, Canadian Council of Ministers of the Environment.

CCME (Canadian Council of Ministers for the Environment). 2007a. Canadian water quality guidelines for the protection of aquatic life. Summary table, Update 7.1. December 2007.

CCME (Canadian Council of Ministers for the Environment). 2007b. A protocol for the derivation of water quality guidelines for the protection of aquatic life, 2007. Winnipeg, Manitoba, Canadian Council of Ministers of the Environment.

Havas, M. and J.F. Jaworski (eds) 1986 Aluminum in the Canadian Environment NRCC 24759.

Saskatchewan Environment. 2006. Surface water quality objectives. Interim edition. EPB 356. July 2006.

Suter, G.W. II and C.L. Tsao. 1996. Toxicological benchmarks for screening potential contaminants of contaminants of concern for effects on aquatic biota. ES/ER/TM-96/R2. Oak Ridge National Laboratory, Oak Ridge.

Document Integration:

No integration is required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Too Small Lake

0.25

0.20

0.15

( 0.10

0.05

Aluminum Concentration (mg/L) Aluminum Y = 0.0565 Ln(X) + 0.0156 r2 = 90.51%; P = 0.0035

0.00 0 5 10 15 20 25

Total Suspended Solids, TSS (mg/L)

Figure 1: Correlation between aluminum concentrations in Too Small Lake surface waters and total suspended solids (TSS) for samples taken in 1990, 1994, 2003, 2005 and 2008.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Too Small Lake

0.18

0.16

0.14

0.12

0.10

0.08

0.06

0.04 1.243

Aluminum Concentration (mg/L) Concentration Aluminum Y = 0.0334X 0.02 r2 = 82.94%; P = 0.0116

0.00 0.00.51.01.52.02.53.03.54.0

Turbidity Figure 2: Correlation between aluminum concentrations in Too Small Lake surface waters and turbidity for samples taken in 1990, 1994, 2003, 2005 and 2008.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Midwest and McClean Lake

0.25

0.20

0.15

0.10

0.05

Aluminum Concentration (mg/L) Aluminum Y = 0.0079X + 0.009 r ² = 81.6%

0.00 0 5 10 15 20 25

Total Suspended Solids, TSS (mg/L)

Figure 3: Correlation between aluminum concentrations in Midwest and McClean Lake site reference surface waters and total suspended solids (TSS) for samples taken in 1990, 1994, 2003, 2005 and 2008.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Table 1: Typical aluminum concentrations in natural lakes and streams (modified from Havas and Jaworski 1986).

Total Al Location Description pH (mg/L)

Lake Water:

Haliburton (Ontario) Background - 0.002 to 0.01 Haliburton (Ontario) N = 26 lakes 5.5 to 6.0 0.049 Clearwater Lake (Canada) Lake water 4.2 0.4 Sudbury region (Ontario) N = 5 lakes 4.0 to 4.6 0.28 to 0.38 Sudbury region (Ontario) N = 2 lakes 5.5 0.069 George Lake (Sudbury) Lake water - 0.2 to 0.25 Lake Superior (Canada/U.S.A.) Lake water - 0.001 to 0.026 U.S.A. surface waters Suspended - 3.86 U.S.A. surface waters Dissolved - 0.074 U.S.A. surface waters Unfiltered - 0.3 U.S.A. surface waters 0.45-m filtered - 0.077 U.S.A. surface waters 0.1-m filtered - 0.057 Lake Michigan (U.S.A.) October 1969 - 0.015 Lake Michigan (U.S.A.) April 1970 - 0.010 Lake Michigan (U.S.A.) June 1970 - 0.021 Hubbard Brook (New Hampshire) Mirror Lake33 6.6 0.005 to 0.02 Central Norway N = 52 lakes 6.4 6.4 Coastal Norway N = 20 lakes 5.4 5.4 South-central Norway N = 26 lakes 4.76 4.76 Western Norway N = 23 lakes 5.22 5.22 Loch on Island (Scotland) - 4.41 0.050 Loch Enoch (Scotland) - 4.54 0.15 Loch Grannoch (Scotland) - 4.53 0.31

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Total Al Location Description pH (mg/L) Loch Skerrow (Scotland) - 5.25 0.22 Loch Dornal (Scotland) - 5.98 0.085 Black Loch (Scotland) - 6.35 0.025 Freshwater Lakes (Average Values) Median - 0.3 Freshwater Lakes (Average Values) Range - 0.008 to 0.0035

Stream Water:

Canada (various locations) - - 0.050 to 0.14

Table 2: Comparison of Al concentrations in reference surface waters on the Midwest site and biotic indices (AREVA 2009).

Aluminum Phytoplankton Zooplankton Benthic Invertebrate Location (mg/L) Biomass (ug/L) Density (cells/L) Density (#/m2)

Deborah Lake <0.005 1332 87 n.a. Henday Lake 0.006 1900 76 1410 Lake W1 0.007 1352 27 1163 Pig Lake 0.045 1055 180 7240 Lake C1 0.048 1212 130 4332 Shallow Lake 0.064 804 34 949 Too Small Lake 0.130 6274 386 14901

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-4 (App. III) Comment:

It is recognized that it was necessary to limit details of water quality modeling to increase the readability of the EIS; however, it is unclear which parameters were manipulated in the model employed. For example, were changes in flushing times, with associated impacts on particle settling rates, incorporated? The flushing times of the Sink Reservoir and Vulture Lake were not presented, making it difficult to assess whether this factor may influence downstream water quality. It appears that some parameters, including suspended solid concentrations, were artificially manipulated to generate realistic results, reducing the validity of the model and water quality predictions.

ARC Response:

The model employed to predict changes in constituent levels in the S/V TEMS does not consider particle settling velocity as might be incorporated in a stream erosion model. Rather, the particle settling velocity input to the LAKEVIEW dispersion model is combined with suspended solids data to predict the mass flux of TSS and associated constituents removed from the water column in each water body. Suspended solids levels in Sink Reservoir and Vulture Lake are affected by TSS introduced with the Sue and JEB water plant effluents and with the dewatering well water. In addition, suspended solids in the S/V TEMS is influenced by increased biological growth that is a result of introducing nutrients with the effluent streams, in particular the JEB WTP effluent. Excess iron is also introduced to the S/V TEMS with the WTP effluent streams due to the use of iron salt in the treatment processes employed in both WTPs. As well, iron is present in the dewatering well water. Iron precipitates are known to remove many metals and radionuclides as co-precipitates or by adsorption. The adsorption coefficients applicable to removal of iron solids are higher than typically measured on organic solids. Monitoring data gathered on the S/V TEMS has shown that several of the constituents of concern are removed to a greater degree than would be expected in a typical lake environment. Hence, calibration of the LAKEVIEW model on the S/V TEMS was carried out specifically to take into account these effects. We don’t believe that calibration of the model to reflect conditions measured in the S/V TEMS in any way reduces the validity of the model or the water and sediment quality predictions.

Document Integration:

A description of the model is provided in the ARC Response above to clarify model assumptions.

No integration is required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-5 (App. III) Comment:

Section 3.5.2.1 of the main document indicates that contaminated waste rock will be stockpiled (Waste Stockpile “B”) near Shallow and Pig lakes during mining operations, after which it will be backhauled to the mined-out pit for permanent disposal. Some of this waste rock will contain significant quantities of sulphur, arsenic, nickel, and uranium, and will have acid-generating potential. Potential impacts of this stockpile on the water quality of Shallow and Pig lakes should be discussed.

ARC Response:

To clarify, Waste Stockpile B, near Shallow and Pig Lakes is a clean waste rock stockpile and therefore will not contain significant qualities of sulphur, arsenic, nickel or uranium and will not have acid generating potential (Section 3.5.2.3).

Please refer to the response to Comment CNSC 5 in this addendum, for a discussion on clean waste rock modeling and the potential contribution of clean waste rock to the contaminant source term.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-6 (App. III) Comment:

Fishes with relatively high dissolved oxygen requirements (lake whitefish, burbot) are present in South McMahon Lake. However, conditions in the lake do not appear to be suitable for overwintering for most fish species found there. Dissolved oxygen levels in April 2003 varied from 0.17 mg/l to 1.06 mg/l throughout the water column (Table 4.4-1, main document), and the mean depth of the lake is reported to be only 1.8 metres (Table 4.2-9, main document). In contrast, dissolved oxygen levels in Mink Arm varied from 1.73 mg/l to 12.16 mg/l., and the mean and maximum depth of Mink Arm is reported to be 4.0 metres and 6.5 metres, respectively. Low winter oxygen levels and shallow depths in South McMahon Lake suggest that the Mink Arm may provide critical overwintering habitat for fish residing in South McMahon Lake. If this is the case, the destruction of Mink Arm would likely be devastating to fish populations within the lake. The extent to which fish from South McMahon Lake utilize Mink Arm as habitat, including overwintering habitat, needs to be determined. This can likely be achieved in part through fish movement/tagging studies. Impacts to the fishery and to the productive capacity of South McMahon Lake as a whole due to the destruction of Mink Arm need to be characterized and quantified. If the productive capacity of the lake will be reduced as a result of the destruction of Mink Arm, suitable habitat compensation measures that would benefit the lake will need to be identified for review by DFO.

ARC Response:

Please note that based on the most recent fishery survey (conducted in 2003; AREVA 2009), neither lake whitefish nor burbot were documented in South McMahon Lake.

The existing dam at Mink Arm is a barrier to fish movement between the Mink Arm and main basin of South McMahon Lake. The only connection between the two basins is a perched culvert that would only allow fish passage under atypical high water conditions (as discussed in Section 7.1.1 in Appendix III). Therefore, it is unlikely that fish from the main basin of South McMahon Lake move into the Mink Arm on an annual basis specifically to overwinter. Observations made by AREVA in September 2008 suggest that in most years there is not sufficient water in the culvert for fish to move from the main basin into Mink Arm to overwinter. Therefore it is likely that, despite the low under ice DO concentrations, fish are overwintering in the main basin of South McMahon Lake.

Document Integration:

Discussion added to Section 7.1.1 of Appendix III.

No longer applicable

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-7 (App. III) Comment:

Lake C1 is reported to contain northern pike and white suckers; however, dissolved oxygen levels that have been observed in the lake in April 2003 (0.25-0.54 mg/l – Table 4.4-1, main document) would likely preclude overwintering of these species within the lake. This apparent contradiction should be explained.

ARC Response:

It is not uncommon for lakes in the Midwest Project area to have very low dissolved oxygen concentrations in the late winter. For example, DO levels in Lake C1 are similar to those measured in Too Small Lake, the lake in which fish compensation is being considered (Table 4.4- 1).

With respect to northern pike, Inskip (1982) indicated that northern pike are commonly exposed to low dissolved oxygen concentrations due to the nature of their preferred habitat (i.e., shallow, heavily vegetated areas that have high biological oxygen demand [BOD], when vegetation decays through the winter months). Inskip (1982) reported northern pike can tolerate concentrations as low as 0.1 to 0.4 mg/L for several days, although prolonged exposure to less than 1.0 mg/L can cause partial or complete winterkill. Inskip (1982) also notes that tolerance to low dissolved oxygen is inversely related to size (i.e., smaller body size had higher survival rates). Therefore, while to dissolved oxygen levels in Lake C1 fall below CCME criteria, they are within the range noted in the scientific literature for northern pike.

In the case of white sucker, adults avoid areas in reservoirs with DO levels of lower than 2.4 mg/L (Twomey et al. 1984). In addition, white sucker embryos may not survive at DO levels of below 1.2 mg/L and fry growth is reduced at DO levels of less than 2.5 mg/L. Considering this, the presence of white sucker in Lake C1 may be related to the connectivity of the lake to other local lakes. For example, white sucker may not over-winter in Lake C1, but may move into the water body following ice-off when DO levels are expected to be relatively higher. In the case of nearby Too Small Lake (where fish compensation is being considered and that has a similar DO to Lake C1), there are no inflowing or outflowing streams that would allow seasonal fish movement into adjacent water bodies.

Although there is literature to support that northern pike and white suckers can be found in areas with low DO concentrations, as confirmed by their presence in Lake C1, if the Too Small Lake fish compensation option is selected, Too Small Lake will be deepened to increase fish over-wintering habitat, which will prevent winterkills that could be associated with low DO levels. More detailed information on this topic has been included in the updated Midwest Fish Compensation Plan.

References:

Inskip, P.D. 1982. Habitat suitability index models: northern pike. U.S. Department of the Interior, Fish and Wildlife Service. FWS/OBS- 82/10.17.

Twomey, K.A., K.L. Williamson and P.C. Nelson. 1984. Habitat suitability index models and instream flow suitability curves: white sucker. U.S. Department of the Interior, Fish and Wildlife Service. FWS/OBS-82/10.64.

Document Integration:

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-8 (App. III) Comment:

Section 3.2.1.1.2 of the main document indicates that during the dewatering of Mink Arm, water from Mink Arm will be discharged to Smith Creek via South McMahon Lake, Midwest Creek, and North McMahon Lake. Expected flows within Midwest Creek have been projected, and concerns regarding these flows were expressed by DFO in a letter to the Canadian Environmental Assessment Agency dated February 1, 2008. However, expected discharges to Smith Creek from dewatering operations and potential impacts to fish and fish habitat within the creek have not been stated. DFO requests that this information be provided.

ARC Response:

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-9 (App. III) Comment:

During dewatering activities, fish will be transferred from Mink Arm to South McMahon Lake, presumably to limit fish mortality resulting from dewatering. The extent to which fish mortality will be reduced, however, is unclear. If the productive capacity of South McMahon Lake is limited in some way (e.g., by a lack of overwintering habitat, food, etc.), the carrying capacity of the lake may already be reached and the system may be unable to assimilate additional fish without negative impacts to the fish population in the lake. The EIS should include an analysis of the effects of the transfer of fish from Mink Arm on fish populations in South McMahon Lake.

ARC Response:

This is an excellent point. AREVA agrees that moving fish from Mink Arm to South McMahon Lake may not ultimately limit fish mortality and could have potential negative consequences, if fish populations are currently at the carrying capacity of the system. As defined in the fish habitat compensation follow-up plan, AREVA will collect representative data for the fish (e.g. ageing structures, length, weight etc.) prior to or during the draining of Mink Arm to establish suitable endpoints to estimate the productivity of the system. A suitable option for the disposition of the remaining fish in Mink Arm will be determined through discussions with local communities, the province and DFO.

Document Integration:

Changes made to Midwest EIS Main Document, Section 3.2.1.1.2 to reflect plans for fish population in Mink Arm during dewatering.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-10 Comment: (App. III) Appendix 4 indicates that pit dewatering could result in the substantial drawdown of local lakes and negative impacts to fish habitat. Under one scenario it is predicted that, after four years of dewatering, Too Small Lake could be completely drained, and the mean depth of South McMahon Lake could be reduced to approximately 0.7 metres (Appendix 4, Fig. 4.6). If lakes are drawn down as a result of pit dewatering it is proposed to pump reverse osmosis (RO) treated permeate into lakes to replace water that has been lost. The impact of this activity on the biology and fish populations of affected lakes is uncertain. Natural runoff and groundwater typically provide nutrients that are beneficial to aquatic productivity, and the replacement of these natural inflows with RO permeate may have unintended negative impacts. These potential impacts should be discussed in the EIS.

ARC Response:

The predicted impacts on Too Small Lake and South McMahon lake outlined in the EIS are considered to be a worst-case scenario (See response to Comment CNSC-4 (4)). As indicated in Appendix 4 of the EIS, the experience from the JEB and Sue E pits, suggests that many of the lakes in the area have limited hydrological connectivity and actual drawdown associated with the development of the JEB and Sue E pits was less than predicted by the modeling.

The effects of pit dewatering may have on Too Small and South McMahon lakes will be closely monitored during pit development. If water levels are affected, water from the RO plant can be used to augment the water supply naturally present in these lakes. It is anticipated that supplemental water will be a small proportion of the existing volume in any particular affected waterbody, and thus the potential effects on within lake nutrient cycling are anticipated to be negligible. As the water from the RO plant may have reduced nutrient concentrations, the nutrient levels in the receiving lakes can be monitored on a seasonal basis to evaluate changes in nutrient status, and in discuss with regulatory agencies, consideration can be given to nutrient augmentation (Roni et al. 2005). The nutrient addition would be similar to what has been done on a trial basis in BC to stimulate salmon production by enhancing nutrient loading to compensate for the loss of marine- derived nutrients in streams as salmon populations have declined (Koning et al. 1998, Ward et al. 2003).

References:

Koning, C.W., K.I. Ashley, Slaney, P.A. and A.J. Paul. 1998. Stream fertilization as a fisheries mitigation technique for perturbated oligotrophic trout streams in British Columbia. Pages 109-120 in M.K. Brewin and D.M.A. Monita, tech. cords. Forest-fish conference: land management practices affecting aquatic ecosystems. Proc. Forest-Fish Conf. May 1-4 1996, Calgary, Alberta. Nat. Resour. Can., Can. For. Serv., North For. Cent., Edmonton, Alberta. Inf. Rep. NOR-X-356. http://www.for.gov.bc.ca/hfd/library/ffip/Koning_CW1996.pdf

Roni, P., K. Hanson, T. Beechie, G. Pess, M. Pollock and D. Bartley. 2005. Habitat rehabilitation for inland fisheries: Global review of effectiveness and guidance for rehabilitation of freshwater ecosystems. Food and Agriculture Organization of the United Nations. FAO Technical Paper 484.

Ward, B.R., D.J.F. McCubbing and P.A. Slaney. 2003. Stream Restoration for Anadromous Salmonids by the Addition of Habitat and Nutrients. In: Mills, D (ed.) Salmon at the Edge. pg. 233-254. DOI: 10.1002/9780470995495.ch19

Document Integration: AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-11 (App. III) Comment:

Contrary to Section 6.5 of the “Project Specific Guidelines” document, information on habitat use according to fish species, life stage, and time of year has not been provided for local water bodies.

ARC Response:

Detailed information of fisheries and aquatic resources for the Midwest Project study area has been compiled in the Midwest Project Technical Information Document (AREVA 2009). This information has now been incorporated in the revised Appendix III, primarily in Section 6, to clarify. In addition, the Midwest Project Technical Information Document (AREVA 2009) provides supplemental supporting information.

REFERENCE:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

Document Integration:

Appendix III revised.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-12 (App. III) Comment:

Contrary to Section 6.5 of the “Project Specific Guidelines” document, information on the growth rate and condition of fish at various trophic levels has not been presented. If impacts to fish habitat are authorized by DFO and habitat compensation is required, information will be required on growth rates and the condition of fish in Mink Arm and fish of the same species that are present in the compensation habitat (e.g., northern pike, white sucker). Population characteristics of fish present in Mink Arm and the compensation habitat will need to be compared to determine if the compensation habitat is functioning as intended and to ensure that there will be no net loss in the productive capacity of habitat resulting from the project.

ARC Response:

This is an excellent point. In general, to address the broader need that was identified by DFO to develop a detailed Follow-up Program (FUP) to demonstrate no net loss (NNL) following implementation of the Fish Habitat Compensation Plan (FHCP), Appendix III has been substantially restructured to more equally weight the FHCP and the FUP. In doing so, a detailed FUP has been developed, with clearly stated objectives using DFO guidance (e.g., Pearson et al. 2005). In addition, a prominent section explaining the proposed approach to quantify NNL has been provided. As part of this update, the revised Appendix III proposes a standardized sampling approach that will ensure comparable measurements of fish habitat and fish population health can be taken between areas of habitat loss and areas of habitat gain, which is integral to the demonstration of NNL during follow up to habitat compensation.

More specifically, the fish populations in the main basin of South McMahon Lake and the Mink Arm have been sampled three times between 1979 and 2003 (AREVA 2009a). These data will serve as a basis against which to compare. The Mink Arm fish population was also sampled in 2009 and age interpretation was undertaken for fishes that had been collected at that time to estimate size-at-age as a reflection of growth (AREVA 2009b; Appendix III Table 8.2-2). Available data on weight versus length and length-frequency distributions for northern pike, white sucker and longnose sucker in Mink Arm from 2003 and 2009 surveys are presented in Appendix III Figures 8.2-1 to 8.2-6. Based on these data, fish condition factors have been calculated as an indicator of fish health and are provided in Appendix III Tables 8.2-1 and 8.2-2.

As detailed in the revised Appendix III follow-up program (App III, Section 8), the drawdown stage of the Mink Arm provides an opportunity to measure population-level metrics on the total population of fish in the Mink Arm using a standardized approach (as outlined in the revised Appendix III). Such an approach will provide a strong basis against which to compare fish population-level metrics in areas of fish habitat gain. As discussed above, the fish habitat compensation FUP outlines a program to compare estimates of productive capacity within a NNL framework. As outlined in that plan, the fish captured prior to or during the drawdown stage, will be weighed, fork lengths or total lengths measured as appropriate, and ageing structures obtained. Ageing structures will be sent for analysis. Once the ageing data has been integrated into the Mink Arm data set, length-at-age, weight-at-age, condition factor and growth rates will be measured. This information will then be used for comparison during the effectiveness monitoring of the compensation plan (as detailed in Section 8 of Appendix III).

REFERENCES:

AREVA. 2009a. Midwest Project. Existing Environment Technical Information Document.

AREVA. 2009b. Technical Memorandum: Mink Arm 2009 Fish and Fish Larvae Community Surveys. Prepared by Canada North Environmental Services. AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

Pearson, M.P., J.T. Quigley, D.J. Harper and R.V. Galbraith. 2005. Monitoring and assessment of fish habitat compensation and stewardship projects: study design, methodology and example cases. Canadian Manuscript Report of Fisheries and Aquatic Sciences 2729: xv + 124 p.

Document Integration:

As suggested, detailed information on standardized methods to measure productivity in Mink Arm and the compensation area are provided in the fish habitat compensation follow-up program (Section 8) of Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-13 (App. III) Comment:

Page 19 states that a berm will be constructed to isolate Too Small Lake from the area of the new lake basin. After construction and the new portion of the lake has filled in, a portion of the berm will be removed. A final “as built” bathymetric map of the lake should be provided, showing the lake after berm removal. Also, an explanation should be provided as to why the entire berm will not be removed. DFO sees no reason why berm material should remain in the lake.

ARC Response:

As indicated in follow-up program (App III, Section 8), following construction of the new basin a detailed “as-built” drawing will be prepared and integrated with the existing bathymetry of Too Small Lake. This will enable a final habitat balance to be prepared.

With respect to the berm used to separate the existing basin from the new basin: the advantage of leaving a portion of the berm in place is that it would increase the shoreline length of the lake and provide an opportunity to create additional habitat complexity in the lake. In addition, creation of a narrow constriction in the lake would facilitate future studies of fish movement between the existing basin and the deeper constructed basin.

Document Integration:

Integrated into Sections 7.2.1 and 8 of Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-14 (App. III) Comment:

Although Table 3.1 describes 16 distinct spawning habitat units and provides a habitat suitability index (HSI) value that corresponds to each habitat unit, these individual HSI values were not used to compute the weighted habitat units shown in Table 5.1, as they should have been. Rather, average HSI values, shown in Table 3.2, were used to compute the number of habitat units shown in Table 5.1. It appears that logical, distinct habitat units have not been recognized, resulting in the “lumping” of habitat units that should have been individually described and accounted for. For example, it is assumed in the EIS that the value of spawning habitat for northern pike is unrelated to water depth, as water depth was not considered in the calculation of HSI values. All depths of Mink Arm were assumed to be equally important as pike spawning habitat. However, pike clearly prefer shallow areas of flooded vegetation for spawning over deeper, unvegetated areas. Habitat units for pike should therefore be distinguished on the basis of combinations of habitat features such as water depth and vegetation, and assigned appropriate HSI values.

Similar concerns are noted with respect to juvenile rearing habitat. For some fish species present in Mink Arm, complex, shallow-water habitats are more valuable for juvenile rearing than are non-complex, deep-water habitats. However, the EIS does not differentiate between habitat units based on such features. Rather, average HSI values for rearing habitat, shown in Table 3.4, were used to compute the number of habitat units shown in Table 5.1.

ARC Response:

The weighted habitat units for spawning and juvenile rearing have been recalculated using the individual habitat units identified in the EIS mapping (please see response to Comment DFO-17 (App III)). In addition, the water depth has been integrated to delineate the usable area of each habitat unit. For example, spawning and rearing for northern pike is assumed to utilize shallow water areas, less than 2 m in depth. Lake whitefish rearing is assumed to be 10 m or less and over boulder/cobble substrate (Langhorne et al. 2001).

REFERENCE:

Langhorne, A.L., M. Neufeld, G. Hoar, V. Bourhis, D.A. Fernet, and C.K. Minns. 2001. Life-History Characteristics of Freshwater Fishes Occurring in Manitoba, Saskatchewan, and Alberta, With Major Emphasis on Lake Habitat Requirements. Canadian Manuscript Report of Fisheries and Aquatic Sciences 2579.

Document Integration:

Appendix III Table 5.1-5 (previously Table 5.1) has been updated to reflect the different habitat units as per DFO request.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-15 (App. III) Comment: For each species for which HSI values were determined (northern pike, lake whitefish, longnose sucker, white sucker), a Table should be provided that shows the major habitat types that were assessed (spawning, rearing, overwintering); the combination of physical habitat features/attributes (e.g., water depth, substrate type, habitat complexity) that were selected to identify sub-categories within the major habitat types; and the HSI values assigned to each sub-category.

This information has been provided to some extent for spawning habitat (Table 3.1), but the HSI values provided in this Table are invalid as water depth was not considered in the determination of HSI values.

ARC Response:

Thank you for your comment.

Detailed information on fish habitat is provided in the Midwest TID (AREVA 2009). In addition, littoral zone habitat for selected lakes in the Midwest Project area are summarized in Appendix III Table 7.1-1. The information in this table was specifically used to determine Habitat Suitability Index (HSI) values for spawning and juvenile rearing habitat. Appendix III Tables 5.1-1, 5.1-2 and 5.1-3summarize the habitat suitability for overwintering, spawning, and juvenile rearing, respectively.

Species-specific spawning depth has been incorporated into Appendix III Table5.1-5, along with HSI values from Appendix III Table 5.1-2. Specifically, for northern pike and suckers, habitat areas for each unit have been calculated to the 2 m contour. Lake whitefish prefer slightly deeper water for spawning and the habitat areas have been extended out to 10 m contour (Langhorne et al. 2001). For juvenile rearing habitat, the calculations were based on physical characteristics of the shoreline habitat and habitat requirements of the fishes (Langhorne et al. 2001).

For overwintering habitat, it was assumed that depths >2 m contribute to overwintering habitat and this was the basis of calculation presented in Appendix III Table5.1-4. Also please note the overwintering habitat was considered to depend on the volume of available habitat (>2 m) although previously this was presented as hectares (>2 m). AREVA feels the change from water area to water volume provides a more realistic estimate of available overwintering habitat.

REFERENCES:

Document Integration:

 The species depth preferences have been integrated into the calculation of weighted habitat areas for spawning in Appendix III Table 5.1-5 (previously Table 5.1).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-16 (App. III) Comment:

Page 20 states that Table 3.1 indicates that longnose sucker spawning habitat in John Pond was assigned a HSI rating of 0.4; however, the Table includes no such rating.

ARC Response:

Thank you for your comment. To the extent possible, management plans have been designed to prevent or minimize many of the potential project-fish habitat interactions associated with the development of the Midwest Project (refer to Appendix III, Table 3.0-1). AREVA has revised the potential Midwest site layout options to avoid the infilling of John Pond. As such, John Pond is no longer included in calculation of fish habitat loss in Appendix III.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-17 (App. III) Comment:

The value of spawning and juvenile rearing habitat for lake whitefish within Mink Arm is likely greater than reported in the EIS. Page 12 states that spawning habitat within the lake is marginal for all fish species, yet data for whitefish to support this conclusion have not been provided. The EIS states that egg searches for northern pike were conducted; however, no such spawning survey for whitefish was carried out. It is noted that in all fisheries surveys of the lake conducted by the proponent, whitefish was the most abundant species captured. Also, there appears to be an abundance of gravel-cobble substrate within the lake, with small amounts of interspersed sand, which provides good spawning and juvenile rearing habitat for whitefish.

DFO requests that the value of whitefish habitat within Mink Arm be further evaluated, and that weighted suitable area (WSA) calculations for whitefish be revised as necessary. It is noted that Table 3.1 indicates that Habitat Unit 101, which is 4,027 metres in length (Fig. 3.1) and constitutes 95 percent of the length of habitat units assigned to the lake, has been designated as moderately suitable for whitefish spawning. However, Table 3.2 indicates that Mink Arm provides only marginal spawning habitat, and includes a corresponding HSI value of 0.2-0.4. This apparent contradiction should be explained.

ARC Response:

To clarify, based on surveys in 2003 (boat electrofishing for 1.49 hours and gill netting for 2.17 hours, AREVA 2009a) and 2009 (gill netting for 107 hours, AREVA 2009b), lake whitefish are not currently present in Mink Arm. To assess whether lake whitefish were present and reproducing in the Mink Arm, larval tows were undertaken in 2009. No larval or juvenile lake whitefish were captured in the 2009 sampling (AREVA 2009b). These results support the conclusions from previous sampling conducted since the Mink Arm dam was established, which suggest that lake whitefish currently do not reside inside the impounded portion of Mink Arm.

As noted in the comment, the data presented in Table 3.2 did not integrate the size (ha) of each habitat unit along with the associated habitat suitability index value. In the revised Appendix III, the calculation of weighted spawning, overwintering and juvenile rearing habitats accounts for both the habitat area (for spawning and juvenile rearing habitat) or volume (for overwintering habitat) and the habitat suitability index value assigned to each habitat unit. In addition, water depths have been integrated into the calculation of habitat areas for spawning (App III, Table 5.1-5). For northern pike and suckers, habitat areas for each unit have been calculated to the 2 m contour. Lake whitefish prefer slightly deeper water for spawning and the habitat areas have been extended out to 10 m contour (Langhorne et al. 2001). Finally, the species ranking for lake whitefish has been increased from 0.2 to 0.4 in response to Comment DFO-18 (App III).

REFERENCES:

AREVA. 2009a. Midwest Project. Existing Technical Information Document.

AREVA. 2009b. Midwest Project. Technical Memorandum: Mink Arm 2009 Fish and Fish Larvae Community Surveys. Prepared by Canada North Environmental Services.

Response to Comments Regulator Comment / Response Comment

Document Integration:

Summary of HSI values for overwintering, spawning, and juvenile rearing habitats (App. III, Tables 5.1-1, 5.1-2, 5.1-3; previously Tables 3.2, 3.3, 3.4) have been recalculated which also resulted in changes to weighted habitat units calculations in App III, Tables 5.1-4, 5.1-5 and 5.1-6.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-18 (App. III) Comment:

It is noted that in the calculation of WSA for fish species, lake whitefish, longnose sucker, and white sucker were assigned a preference weighting factor of 0.2, while northern pike was assigned a factor of 0.4. DFO feels that it may be inappropriate to rank whitefish equally with suckers, and that a factor greater than 0.2 may be more appropriate for whitefish. For EIS’s conducted for the Snap Lake, Meadowbank Gold and Doris North projects, preference weighting factors were higher for species that were relatively abundant and were considered to have value as commercial or sport species than they were for forage species. Whitefish is apparently the most abundant fish species present in Mink Arm and is considered to have significantly greater commercial, recreational, and subsistence value than white sucker.

DFO requests that further justification be provided for the preference weighting factors that were assigned.

ARC Response:

Thank you for your comment. AREVA has updated the species ranking of lake whitefish from 0.2 to 0.4 throughout Appendix III.

In addition, as noted in Comment DFO-17 (App III), based on recent surveys, lake whitefish are not currently present in Mink Arm (AREVA 2009a, AREVA 2009b).

REFERENCES:

AREVA. 2009a. Midwest Project. Existing Environment Technical Information Document.

AREVA. 2009b. Midwest Project. Technical Memorandum: Mink Arm 2009 Fish and Fish Larvae Community Surveys. Prepared by Canada North Environmental Services.

Document Integration:

Lake whitefish species weighting factor was increased from 0.2 to 0.4 in Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-19 (App. III) Comment:

Page 20 makes reference to Tables 3.3 and 3.5, when Tables 3.2 and 3.4 should be referenced.

ARC Response:

Thank you for identifying the incorrect table reference.

Document Integration:

Reference to tables has been updated and corrected.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-20 (App. III) Comment:

Page 20 states: The surface area of the lake basin below the 4 m contour was used to calculate habitat units of overwintering habitat, implying that areas shallower than 4 metres were not considered as overwintering habitat. However, Table 5.2 indicates that depths over 2 metres were considered to constitute overwintering habitat. This apparent contradiction should be explained.

ARC Response:

Thank you for your comment. The text should have read depths below 2 m contributed to overwintering habitat.

Document Integration:

Text modified to be consistent with the footnote in App III Table 5.1-4 (previously Table 5.3).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-21 (App. III) Comment:

For Table 3.2 to be consistent with Table 3.1 and the HSI ranges presented on Page 11, Table 3.2 should include the following ranges for spawning habitat value: northern pike: 0.2-0.4 for Too Small Lake lake whitefish: 0.0-0.7 for Mink Arm and 0.0-0.4 for Too Small Lake longnose sucker: 0.0-0.4 for Mink Arm and 0.0-0.0 for John Pond

ARC Response:

App III, Table 5.1-2 (previously Table 3.2) and HSI scores have been modified to reflect the individual habitat units in each lake. Each habitat unit was assigned an HSI score based on information in App. III Table 7.1-1 (previously Table 3.1).

Document Integration:

App. III, Table 5.1-2 (previously Table 3.2) has been corrected.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-22 (App. III) Comment:

For Table 3.1 to be consistent with Table 5.1, habitat values in Table 5.1 should be reported as follows: lake whitefish: 0.4 for Too Small Lake longnose sucker: 0.4 for Too Small Lake

ARC Response:

Due to the change in table structure as a result of the request to calculate weighted habitat units based on the individual habitat units (as per Comment DFO-17 (App III)), the column reflecting average HSI values was removed from App. III, Table 7.1-1 (previously Table 3.1). Please refer to Appendix III Figure 5.1-1 for an overview of inputs into the no net loss calculation.

Document Integration:

App. III, Table 5.1-5 (previously Table 5.1) summarizes weighted suitable areas for spawning habitat and uses HSI values from App. III, Table 5.1-2

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-23 (App. III) Comment:

In Table 5.2, an incorrect HSI value (0.7) was used to calculate the WSA/habitat units for the existing basin of Too Small Lake. A value of 0.4 should have been used. A HSI value of 0.7 would only be applicable to the new basin of the lake.

ARC Response:

Thank you for your comment. Weighted overwintering habitat will be recalculated for the existing basin of Too Small Lake using an HSI value of 0.4.

Document Integration:

Table 5.1-4 in App. III (previously Table 5.2) was updated.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-24 Comment: (App. III) Many of the channel widths presented in Table 2 (Appendix 3, Sub-appendix A) differ from those presented in Table 3.3-1 of the main document.

ARC Response:

Thank you for your comment. The channel widths presented in Table 3.3-1 and Table 2 (Appendix III, Sub- Appendix A) are not the same because they do not represent the same measurements. To clarify, the channel widths listed in Table 3.3-1 are the average of numerous bankful widths taken near the crossing to produce a typical channel configuration in the vicinity of each stream crossing. Where possible the bankful width was measured at the centreline and every 10m from the crossing for the first 50m, and at 75m and 100m upstream and downstream (Appendix III, Sub-appendix B).

The channel widths listed in Table 2 (Appendix 3, Sub-appendix A) are the bankful widths measured at the centreline of the proposed crossing only.

For example, crossing N4 has an average bankful width of 3.9m (Table 3.3-1) and the bankful width at centreline of 3.6m (Table 2, Appendix III, Sub-Appendix A).

Document Integration:

Changes made to Table 3.3-1 (Section 3, Midwest EIS main document)  Table heading corrected: ‘Bank-to-bank width’ changed to ‘Bankful width’  Footnote added to describe derivation of bankful widths

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-25 Comment: (App. III) Page 4 states: It is anticipated that the habitat accounting associated with the compensation plan…will be sufficiently conservative to address the relatively small habitat losses associated with the…road. However, it is unclear in Appendix 3 whether or not this will be the case. Habitat loss associated with stream crossings will need to be quantified and described, and suitable compensation identified for habitat losses incurred. DFO notes that if culverts are installed as proposed, rather than channel spanning structures, substantial loss of stream habitat will occur. DFO recommends that channel spanning structures be installed at Crossing N5 (tributary to Pat Lake), Crossing S5 (Collins Creek), and Crossing S6 (tributary to Collins Creek).

ARC Response:

Thank you for your comment. Best available technologies (BATs) and practices (BAPs) will be applied at stream crossings to prevent habitat alteration disruption and destruction, as outlined in DFO (2005). This information has been expanded upon for consideration by DFO in an updated version to Appendix III.

In the case of Stream Crossing N5 (tributary to Pat Lake), a clear span bridge will be installed, as per your recommendation.

REFERENCE:

DFO (Fisheries and Oceans Canada (DFO). 2005. Model class screening report: Embedded culvert projects in small fish-bearing streams on forestry roads in British Columbia. Oceans, Habitat and Enhancement Branch, Pacific Region. March 2005.

Document Integration:

This information has been expanded upon for consideration by DFO in an updated Midwest Fish Compensation Plan.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-26 (App. III) Comment: Modifying Too Small Lake as proposed may only result in a temporary increase in the productive capacity of the lake, and there may be a long-term decrease in productive capacity if the forage base in the lake is decimated by northern pike. At DFO’s Experimental Lakes Area, the large forage base that was present in the lake was extirpated due to the introduction of pike (K. Mills, personal communication). Initially, pike growth rates increased dramatically, but these rates of growth could not be sustained after the loss of the forage base. Subsequently, pike survival decreased due to a lack of food and the productive capacity of the lake decreased due to the introduction of the novel species. It is quite possible that the expansion of Too Small Lake as proposed will not compensate for the loss in productive capacity resulting from the loss of John Pond and Mink Arm.

ARC Response:

AREVA agrees that upon introduction of northern pike, there will initially be fluctuations in the forage base, with initially fast growth of the pike, followed by a reduction in growth. A similar study done in a Shield lake in Eastern Ontario showed the same results with respect to pike growth rates, and a substantial reduction in the numbers of yellow perch and forage fishes (Yankovich and Cornett 2001; Yankovich et al. 2005); however, it should be noted that although the fish community fluctuated initially, it later stabilized with respect to the forage base and the growth rates of northern pike. Follow-up monitoring will be carried out until the fish community stabilizes to quantify the productivity in the habitat gained versus lost at steady state, as outlined in the follow-up program (App. III, Section 8).

Also please note that to the extent possible, management plans have been designed to prevent or minimize many of the potential project- fish habitat interactions associated with the development of the Midwest Project (Appendix III, Table 3.0-1). AREVA has revised the potential Midwest site layout options to avoid the infilling of John Pond. As such, John Pond is no longer included in calculation of fish habitat loss in Appendix III.

REFERENCE:

Yankovich T L and Cornett R J J. 2001. Are the condition and health of fish populations 1168 influenced by exposure to radioactive contaminants? In: Proceedings of 2nd International 1169 Symposium on Ionizing Radiation: Environmental Protection Approaches for Nuclear 1170 Facilities Ottawa: Ontario 8 pp.

Yankovich, T.L., J.M. Casselman and R.J.J. Cornett. 2005. Impacts of species introductions on the health of fish communities receiving chronic radionuclide exposures. Proceedings of the Canadian Nuclear Society Waste Management, Decommissioning and Environmental Restoration For Canada’s Nuclear Activities: Current Practices and Future Needs. Ottawa, Ontario Canada. May 8-11, 2005.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-27 (App. III) Comment:

Although basic bathymetric information has been provided for Too Small Lake after expansion, further information is required to demonstrate that spawning, juvenile rearing, and overwintering habitat will function as desired. Detailed information is required on construction details, including the nature and location of bottom substrates, large woody debris, aquatic vegetation and other habitat features that will be present in the new basin of the lake.

ARC Response:

This is good comment. The habitat requirements of relevant fish species will be used to design and construct suitable habitats for fish spawning, juvenile rearing and overwintering, as discussed in Section 7 of Appendix III. The fish community will be monitored to confirm no net loss following fish introduction, as discussed in the follow-up program (Section 8 of Appendix III).

Document Integration:

Details on habitat structure that will be included in the compensation areas have been added to the revised Appendix III (Section 7).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-28 (App. III) Comment:

The population of ninespine stickleback in Too Small Lake should be assessed and the potential effect of the introduction of northern pike on the stickleback population should be evaluated in detail. A non-lethal fish survey approach, such as that employed in the “Environmental Effects Monitoring Program for Metal Mining”, could provide necessary information.

ARC Response:

Please refer to the response to Comment DFO-26 (App. III).

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-29 (App. III) Comment:

There is concern that a viable population of white suckers cannot be sustained within Too Small Lake, as tributary streams suitable for spawning are lacking. An analysis of the potential for Too Small Lake to provide suitable spawning habitat for this species should be provided.

ARC Response:

In water bodies that lack tributary streams, white sucker are known to spawn in lake margins (Scott and Crossman, 1973). The spawning success of introduced fishes, including white sucker, will be monitored as part of the follow-up program (Section 8 of Appendix III).

REFERENCE:

Scott, W.B. and E.J. Crossman. 1973. Freshwater fishes of Canada. Bulletin 184. Fisheries Research Board of Canada, Ottawa.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-30 (App. III) Comment:

It is unclear how the expansion of Too Small Lake will provide improved connectivity to Collins Creek, as stated on Page 25. The natural outlet of Too Small Lake is a wetland that does not contain a distinct drainage channel, and deepening the lake will likely not increase drainage from the lake or increase the likelihood of fish passage through the wetland.

ARC Response:

Thank you for your comment. The text has been updated to clarify that Too Small Lake will not be connected to Collins Creek.

Document Integration:

The text has been clarified in the revised Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-31 (App. III) Comment:

The EIS reports that phytoplankton and zooplankton densities were higher in Too Small Lake than all other lakes sampled. It is also noted that late winter dissolved oxygen levels in the lake are extremely low. There is concern that high oxygen demand generated in the shallower areas of Too Small Lake will continue to reduce oxygen levels in deeper areas of the lake after lake expansion, rendering the lake unsuitable for overwintering for pike and suckers. An analysis of winter oxygen demand for the deepened area of the lake should be conducted, including a projection of the volume of water that would be required to maintain satisfactory oxygen levels for overwintering fish.

ARC Response:

Thanks for your comment. As discussed in the response to Comment SME-2 (App III), it is expected that the plankton biomass will be reduced through top-down effects, as introduced fishes consume them. Over time it is expected that the system will become self-regulated in terms of food availability, as the number of trophic levels increases.

In addition, as measured in other lakes in the region (e.g., please see Table IV.1-1 in AREVA, 2009) with depths comparable to the proposed expansion of Too Small Lake (maximum depth ~6 m), overwinter DO levels are not expected to limit fish community sustainability. In general, plankton productivity is expected to be significantly lower at depth (Wetzel, 1983).

The expansion of Too Small Lake is expected to result in the addition of approximately 100% more water volume in the lake (~652,300 m3 in current Too Small Lake versus ~677,400 m3 in Too Small Lake expansion = total volume of 1,329,700 m3). The volume of water below 2 m is estimated to be 54,148 m3 in the existing basin of Too Small Lake. The expansion is expected to add an additional 331,900 m3 of water below 2 m depth for fish overwintering.

That said, AREVA’s committed to monitoring winter DO levels in the expanded Too Small Lake to ensure the created habitat remains a viable overwintering area, as detailed in the follow-up program (Section 8 of Appendix III).

REFERENCES:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

Wetzel, R.G. 1983. Limnology. Second Edition. CBS College Publishing, Philadelphia, USA.

Document Integration:

A detailed follow-up program has been added to the revised Appendix III document (Section 8).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-32 (App. III) Comment:

Information is required on the rate of water renewal within Too Small Lake after lake expansion; the length of time required for resuspended bottom and shoreline materials to subside following construction; and the effect of sedimentation on the lake’s oxygen supply.

ARC Response:

An outflow estimate of 0.019 m3/s was determined for Too Small Lake using a unit-area runoff approach. This indicates that Too Small Lake in its current state has an approximate flushing rate of 0.92 times per year for its drainage area. The expansion of Too Small Lake is expected to double the original volume of the lake (~652,300 m3 in current Too Small Lake versus ~677,400 m3 in Too Small Lake expansion for a total volume of approximately 1,330,000 m3). Once construction of the expanded area is complete, essentially all runoff will be directed to flood the new area and depending on seasonal precipitation, it is anticipated to take between 1 and 1.3 years to reach equilibrium.

Once the final lake elevation has been reached in Too Small Lake following expansion, the water quality will be monitored prior to addition of fish species. This is outlined in more detail in the follow-up program (Section 8 of Appendix III). AREVA is committed to monitoring water quality (including dissolved oxygen and TSS) in the expanded Too Small Lake to ensure the created habitat is viable for fish introduction and provides suitable fish habitat.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-33 (App. III) Comment:

Insufficient information is provided in Section 6 to conclude that follow-up monitoring will provide sufficient information to determine whether or not the project will result in a net loss in the productive capacity of fish habitat. A fundamental component of monitoring should be the evaluation of spatial and temporal variation within Too Small Lake relative to expected/desired effects. The monitoring plan should therefore include proposed target biota; sampling locations; sampling methods, frequency, and timing; estimates of expected precision; and supporting rationale. The plan does not provide this information in sufficient detail. For example, it is not stated whether lethal and non- lethal sampling will occur.

A key measure of success will be to demonstrate that long-term secondary productivity within Too Small Lake is at least equal to that of Mink Arm. Therefore, the monitoring plan should indicate how productivity will be measured. The plan should state that population characteristics (e.g., density, biomass, growth rates, condition factor, etc.) of fish within Too Small Lake will be monitored over the long term, and compared with population characteristics of fish from Mink Arm. The monitoring plan should also state that the effects of the project on fish habitat within Smith and Collins Creeks will be assessed, and indicate how this will be accomplished.

ARC Response:

A detailed follow-up program has been added to the revised Appendix III (Section 8).

As Too Small Lake is isolated from other surface waters, the relevance of Smith and Collins Creeks to the fish habitat compensation plan is unclear.

Document Integration:

Section 8 of the revised Appendix III has been updated to include a detailed follow-up program.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-34 (App. III) Comment:

Several factors are considered when determining the appropriate amount of compensation compared to the amount of habitat lost. DFO policy states that compensation ratios (amount of habitat compensation: amount of habitat lost) greater than 1:1 are expected when it is uncertain that the compensation works will function as intended, or there will be a lag time before the compensation works become fully functional. Given the uncertainty that the proposed compensation will function as intended and the time required for the compensation habitat to be fully functional (perhaps several years), a compensation ratio that is satisfactory to DFO and substantially greater than 1:1 will be required.

ARC Response:

The anticipated ratios of habitat gain : habitat loss are 2.0 for Too Small Lake (App. III, Table 5.1-7) and 1.8 for Sue E pit/Sils Lake (App. III, Table 5.1-8)

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO- 1 Comment: (AppIII-2010) DFO previously indicated (DFO-34 comment in the addendum to the EIS) that a compensation ratio (i.e., amount of compensatory habitat required:amount of habitat lost) would need to be substantially greater than 1:1. However, although the proponent has determined that approximately 1,082,958 m3 of water constituting overwintering habitat (i.e., water exceeding 2 metres in depth) will be destroyed due to the loss of Mink Arm, it has been proposed that Too Small Lake be expanded to the extent that only approximately 606,456 m3 of overwintering habitat will be created as compensatory habitat. DFO has further determined that the weighted suitable volume (WSV) of overwintering habitat lost within Mink Arm, considering northern pike, longnose suckers, and white suckers, will be approximately 606,456 m3, whereas the equivalent WSV of Too Small Lake will be only 141,424 m3. If the proponent selects either of the compensation options proposed in the EIS, the amount of compensatory overwintering habitat that is created must offset habitat losses. DFO will advise on the final compensation ratio once the proponent has advised DFO as to the time interval between the loss of Mink Arm and the point at which the compensatory habitat will reach full productive capacity, and the likelihood of success of the compensatory habitat. DFO therefore requests that this time interval be provided for both compensation options, and that a rationale as to when compensatory habitats will be fully functional be provided.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-2 (AppIII- Comment: 2010) The proponent has considered lake whitefish in calculations of habitat gains for overwintering habitat and spawning habitat in Too Small Lake, based on the assumption that whitefish will be stocked within Too Small Lake. However, DFO has determined that it would be inappropriate to consider whitefish habitat in these calculations. The proponent has not demonstrated that the addition of whitefish to Too Small Lake would be successful. Furthermore, since whitefish are not found within Mink Arm, the loss of Mink Arm will not affect whitefish habitat. The proponent has incorrectly claimed habitat “credit” for compensatory habitat proposed to be created for whitefish that is not associated with any loss of whitefish habitat. DFO therefore requests that Tables 5.1-4, 5.1-5, 5.1-6, 5.1-7, and 5.1-8 be revised to exclude lake whitefish and that WSVs and WSAs areas be recalculated as appropriate.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 3 Comment: (AppIII-2010) DFO has determined that it would be inappropriate to stock lake whitefish within Too Small Lake, as it is apparent that the likelihood of their survival in the lake would be poor. Although survey data suggest that lake whitefish were once abundant in Mink Arm, it is not appropriate to target whitefish in the habitat compensation efforts proposed for Too Small Lake. Whitefish are no longer present in Mink Arm, and the habitat that will be impacted is that which supports pike, longnose suckers, and white suckers. Given that it is unlikely a population of lake whitefish could be maintained within Too Small Lake, DFO does not support the proponent’s proposal to stock Too Small Lake with whitefish and requests that habitat calculations not include calculations regarding whitefish habitat.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 4 Comment: (AppIII-2010) Are there plans to supplement the stickleback population in too Small Lake with an additional forage species for northern pike (e.g., fathead minnow)? The pike population to be established in the lake may benefit by the addition of an additional forage species. DFO requests that the proponent provide a rationale concerning forage species to be present in the lake. ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 5 Comment: (AppIII-2010) In order to determine the WSV and WSA of habitat to be lost as a result of the dewatering of Mink Arm, it was necessary for the proponent to quantify the presence of habitat features present within Mink Arm, such as substrate type, cover type, and bottom slope, as shown in Table 7.1-1. Based on the amount of habitat to be lost, compensatory habitat that would provide a particular amount of WSA and WSV was proposed. However, rather than commit to specific habitat conditions, features and types that would demonstrate that the amount of compensatory habitat proposed will actually be created, the proponent has identified possible habitat creation and enhancement techniques that could be employed, such as those described on Pages 25, 34, and 35 of the compensation plan. Neither compensation option has been described in sufficient detail for DFO to determine whether or not the amount and type of compensatory habitat to be created will compensate for habitat that will be lost. DFO therefore requests that the location, type, and amount of habitat features and types to be employed be presented in text, tables and conceptual maps and drawings. Due to low densities of macrophytes in the existing basin of Too Small Lake and the need to accelerate aquatic production to the extent possible, a commitment to plant both macrophytes and riparian vegetation as soon as possible will be required. The proposed bathymetry of Sils Lake and the interconnecting channel between Sils Lake and the Sue E Pit should be provided. DFO is also concerned that because Sils Lake will be completely excavated to lower its bottom elevation, resulting in the destruction of virtually all littoral habitat within the lake, and the natural productive capacity within the lake is apparently low, the amount and type of spawning and rearing habitat that will eventually be created within the lake will be less than what has been projected by the proponent. DFO requests that information be provided that demonstrates that the amount and type of spawning and rearing habitat to be provided by Sils Lake will compensate for the loss of these habitats within Mink Arm.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 6 Comment: (AppIII-2010) The proponent indicates that it could take ten years or more for the Sue E pit to reach a steady state water surface elevation of 450 metres through natural flooding. Therefore, due to the hydraulic connection between the Sue E pit and Sils Lake, the surface elevation of both water bodies will be similar and the lake may not be fully functional as fish habitat until after the final elevation of the Sue E pit has been reached. The proponent has described options to enhance the rate of pit flooding through pumping from nearby lakes or the addition of clean permeate from the Sue water treatment plant, but has not indicated if the pit will be allowed to fill naturally or if the flooding rate of the pit will be accelerated through pumping. DFO requests that the proponent describe how the final surface elevation of the pit will be achieved and when the final elevation of the Sue E pit and Sils Lake will be reached compared to other pre-development activities, including the draining of Mink Arm. DFO would prefer that the pit be filled through pumping of lake water, provided there would be no impacts to the source lake.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 7 Comment: (AppIII-2010) Page 31 indicates that 5.6 million m3 of water is available as overwintering within the Sue E Pit, whereas Table 5.1-4 indicates that 2,450,000 m3 is available. This apparent contradiction should be explained

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 8 Comment: (AppIII-2010) DFO requires further justification as to why the entire volume of the Sue E pit between 2 metres and 48 metres depth should be considered overwintering habitat, and is suitable as overwintering habitat. In order for areas below 2 metres depth to be considered as overwintering habitat, the proponent should provide information indicating that fish to be present in the pit will utilize those areas. DFO notes that potential overwintering habitat may not be utilized by fish. For example, recent studies on a population of lake trout in Ontario indicated that during the period of ice cover, the trout only utilized upper areas of the lake and that their distribution was strongly correlated to the distribution of forage fish, which largely stayed in close proximity to the ice. Furthermore, more information on water quality is required to demonstrate that the pit provides acceptable fish habitat. For example, seasonal dissolved oxygen and pH profiles throughout the water column are required. ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO- 9 Comment: (AppIII-2010) Although the proponent has provided a rationale as to why the berm to be constructed between Too Small Lake and the lake expansion area should not be removed following lake expansion, DFO will require a commitment from the proponent that the berm will be completely removed. Removal of the berm will maximize the likelihood that the compensatory habitat will function as intended, by maximizing the area of in-water habitat, maximizing the likelihood of the free movement of fish between existing and constructed habitats, allowing the lake to freely circulate, maximizing the fetch, etc. In addition, a transition area from shallow to deep water should be excavated to ensure the connectivity of shallow and deep water areas during low water and/or ice conditions on the lake.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-10 Comment: (AppIII-2010) Prior to the draining of Mink Arm and removal of fish from Mink Arm, a detailed fish salvage plan must be completed and approved by DFO and the Saskatchewan government. It is preferable that fish to be placed within the compensation habitat be taken from Mink Arm.

ARC Response:

August 2011 A fish transfer procedure will be undertaken to move fish from Mink Arm to South McMahon Lake. Please see response to DFO-6 (2010), which was finalized with DFO in May 2011.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-11 Comment: (AppIII-2010) Fish should not be released into compensatory habitat until the habitat can support all species and life stages of fish to be released. DFO requests that the proponent indicate how the compensatory habitat will be assessed to determine its suitability for the introduction of fish, including habitat features to be evaluated (e.g., water quality, substrate, benthic community, aquatic vegetation), and standards to be achieved before stocking can commence. DFO assumes that assessments of presence/absence and CPUE undertaken during the initial year that fish are stocked, as shown in Table 8.1-1, will be based on fish being stocked into habitat that is sufficiently functional to support the stocking initiatives. ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-12 Comment: (AppIII-2010) The proponent states (Page 49) that fish removed from Mink Arm will be counted and weighed. DFO feels that counting and weighing all fish salvaged from Mink Arm would be difficult and unduly stress fish, leading to unnecessary mortality. Estimates of fish community composition and biomass based on representative sampling may be preferable. ARC Response:

Appendix III has been revised and AREVA is no longer proposing to measure fish community composition and biomass in Mink Arm during dewatering. This was originally proposed in earlier draft versions of Appendix III because it related to the calculation of habitat loss and gain associated with Too Small Lake and Sue E/Sils Lake alternatives. With the revised Appendix III to restore connectivity at Montreal River weir through the construction of a Newbury riffle the need to quantify the fish community and biomass in Mink Arm

Please see response to DFO-6 (2010), which was finalized with DFO in May 2011.

Document Integration:

Appendix III has been revised and a conceptual plan is presented to restore connectivity at Montreal River weir through the construction of a Newbury riffle.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-13 Comment: (AppIII-2010) The absence of “boulder” as a cover type in Table 7.1-1 would appear to contradict its documented presence as a substrate type. ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment DFO-14 Comment: (AppIII-2010) The proponent has incorrectly assumed (Page 14) that since no change in fish biomass is anticipated as a result of the installation of stream crossing structures, the installation of these structures will not result in the harmful alteration, disruption, or destruction (HADD) of fish habitat. However, the HADD of fish habitat typically results when natural habitat (e.g., natural substrate) is replaced with artificial substrate such as a CSP culvert, or habitat is destroyed (e.g., a channel is infilled to install a smaller sized culvert, or bridge abutments are installed below the normal high-water line). The authorization of such habitat impacts is typically contingent upon efforts to ensure that any changes in habitat productivity, which may be measured as fish biomass, are offset.

ARC Response:

At fish bearing streams where a culvert is necessary to cross the waterway, the culvert has been sized to span the entire width of the stream to avoid loss of fish habitat and to comply with navigability requirements. At large stream crossings where the use of a culvert is insufficient to avoid significant impacts to fish habitat , a clear-span bridge is proposed to prevent disturbance to the natural stream substrate. Clear-span bridges are proposed at crossings N5, S5, and S6.

Culverts will be backfilled with substrate similar to the natural substrate identified upstream and downstream of the crossing. As well, the use of best available technologies (BATs) and best available practices (BAPs) will be utilized to further reduce the impact to fish and fish habitat. In this way, the HADD associated with culvert installations at stream crossings along the proposed haul road will be minimized to the extent possible.

Document Integration:

Text in Appendix III was changed to indicate that a HADD is associated with the haul road crossings - HADD is unavoidable but will be minimized to the extent possible. The surface area of habitat disturbance at stream crossings is presented in Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment DFO-15 Comment: (AppIII-2010) Table 5.1-5 indicates a loss of 2.2 weighted habitat units for northern pike that are associated with Habitat Unit 101, whereas DFO has determined that the loss should be 1.87 units. DFO requests that the proponent re-check the calculations provided in the Tables 5.1-4 to 5.1-8. Numbers should be reported to two decimal places to preclude reporting values close to zero as zero.

ARC Response:

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-1 (App. III) Comment: At present there a number of serious deficiencies in the Proponent’s Habitat Compensation Plan (Plan). Ministry staff are also concerned that this plan is not the best Plan for the proposed draining of Mink Arm. Prior to the initial draining and test mining of Mink Arm, people benefited from the fish resources in this portion of South McMahon Lake. How will creating the Too Small Lake Expansion (new lake) and introducing northern pike and white sucker be beneficial given there will be no public access or commercial value to the new lake?

The Proponent is proposing enhancement of an already pristine environment. Ministry staff find it difficult to see how the Plan could be considered compensation when the habitat being enhanced is not the same as the proposed enhancement.

Ministry staff recommend that the location for habitat compensation be expanded from within the immediate vicinity of the habitat loss to the entire watershed in which Mink Arm is located. This would be the Environment Canada sub-watershed 07LC which also includes Collins Creek within this watershed. The Sub-watershed 07LB should also be included as part of its headwaters (i.e. Nicholson Creek), which is immediately adjacent to Mink Arm. The Proponent should also consider one or more of the following habitat compensation opportunities:

1) Restore habitat access through the identification of stream crossings where fish passage is a concern.

2) Look for restoration opportunities at abandoned mine sites where there are concerns with water quality and fish habitat.

3) Fund a multi-year study of northern waterbodies designed to identify some of the limiting factors of fish productivity. This would be done without the implementation of the above proposed habitat compensation. The money allotted for undertaking the Plan would instead be used as part of the funding for the study.

ARC Response: The focus of this fish habitat compensation plan is to meet DFO’s requirements of No Net Loss (DFO 1986; DFO 1998). AREVA is working with DFO to evaluate the proposed compensation plan with respect to the requirements.

REFERENCES:

Department of Fisheries and Oceans (DFO). 1986. Policy for the Management of Fish Habitat. Department of Fisheries and Oceans, Ottawa, ON.

Department of Fisheries and Oceans (DFO). 1998. Habitat Conservation and Protection Guidelines, Second Edition (1998). Developed from the Policy for the Management of Fish Habitat (1986). Department of Fisheries and Oceans, Ottawa, ON. Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment Response

a) AREVA states that the focus of the fish habitat compensation plan is to meet DFO’s requirement for No Net Loss and refers to the 1986 document describing this policy. AREVA should note in this document that Fish Habitat Restoration (Section 2.3) is described as the second goal for achieving a gain in the productive capacity of fish habitat.

b) Ministry staff do not see any benefit to the habitat compensation proposed. Neither of the options presented will provide any net benefit to the fishery in northern Saskatchewan. The proposed areas for enhancement will be in isolated systems that will not be connected to any stream systems except possibly during periods of extremely high water.

c) AREVA and DFO should continue to explore options for restoring impacted fish habitat. This would include areas adjacent to abandoned mines and segments of stream systems that are upstream of abandoned stream crossings in the north. The proponent is encouraged to Pam provide habitat compensation somewhere else in the province if there are no suitable projects in the north, rather than to essentially damage more pristine habitats. AREVA will need to provide strong justification for this project’s worth and substantiate that all other options have been explored and exhausted.

d) It is not clear why whitefish and the two sucker species are being considered for stocking into Too Small Lake when the habitat for spawning for these species is considered marginal at best. Please provide clarification.

e) Please note that restoring fish passage is an effective way to increase habitat availability and can result in relatively large increases in potential fish production for a nominal cost. (Roni, P. et al., 2002, A review of Stream Restoration Techniques and a Hierarchical Strategy for Prioritizing Restoration in Pacific Northwest Watersheds. North American Journal of Fisheries Management.)

AREVA Response:

AREVA has revised the proposed fish habitat compensation plan in Appendix III to restore connectivity at Montreal River weir while preserving habitat in upstream Montreal Lake.

August 2011  This project is outside of the ecological unit of habitat loss – as per provincial comment c) above: “the proponent is encouraged to provide habitat compensation somewhere else in the province if there are no suitable projects in the north.”  The Montreal River riffle project is based on restoring connectivity as per provincial comment e) above.

Document integration:

Appendix III has been revised and a conceptual plan is presented to restore connectivity at Montreal River weir through the construction of a Newbury riffle.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-2 (App. III) Comment:

Page 7. Section 2.2. Phytoplankton Community. The Proponent needs to consider the possible influence of the high algal biomass in Too Small Lake on the reduction of oxygen in the water during the winter. Has the Proponent considered/determined the volume of water that would have to be available to maintain adequate dissolved oxygen levels in the new lake?

ARC Response:

The phytoplankton biomass in Too Small Lake seems to be naturally high, relative to other water bodies in the area. The current aquatic community in Too Small Lake will be altered over time with the addition of new fish species and the new bathymetry following lake expansion. With these changes, the high algal biomass is expected to be reduced relative to the entire lake volume. As noted in the response to Comment DFO-31 (App III), with the expansion and deepening of Too Small Lake, seasonal DO levels including during the winter are expected to support fish. Follow-up program monitoring will include winter limnological profiling (temperature, DO, pH, specific conductivity) of Too Small Lake (as detailed in App III, Section 8). Any issues with dissolved oxygen will be identified during follow-up monitoring.

Document Integration:

No integration required.

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-3 (App. III) Comment:

Page 9. Section 2.5.1. Mink Arm. Based on the very limited data presented on winter oxygen concentrations in April, it could be assumed that Mink Arm could serve as critical over-wintering habitat for fish in South McMahon Lake. The Proponent does not present any data collected from earlier studies.

ARC Response:

Please see response to comment DFO-6 (App. III).

Document Integration:

Discussion added to Section 7.1.1 of Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-4 (App. III) Comment:

ARC Response:

Thank you for your question. Please refer to the response to DFO-3 (App. III).

Document Integration:

No integration is required.

Comment:

AREVA should provide the pH and the concentration of calcium from the referenced 2008 sampling program. Both pH and calcium play important roles in the toxicity of aluminum to fish species.

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-5 Comment: (App. III) Type I Page 15. Section 4.1. Compensation Approach and Options. Did the Proponent explore habitat compensation options include stream crossings and the possible impediments these crossings cause to fish passage?

ARC Response:

Thank you for your comment. Best available technologies (BATs) and practices (BAPs) will be applied at stream crossings to prevent significant adverse effects, as outlined in DFO (2005). This information is being expanded upon for consideration by DFO in an updated version to Appendix 3 to be submitted in November 2009.

In the case of Stream Crossing N5 (tributary to Pat Lake), a clear span bridge will be installed.

It is likely that the preferred haulage road option (i.e., the proposed northern route) will be feasible and the haulage road will not cross at Crossing S5 (Collins Creek), and Crossing S6 (tributary to Collins Creek).

REFERENCE:

DFO (Fisheries and Oceans Canada (DFO), 2005. Model class screening report: Embedded culvert projects in small fish-bearing streams on forestry roads in British Columbia. Oceans, Habitat and Enhancement Branch, Pacific Region. March 2005.

Document Integration:

This information has been expanded upon for consideration by DFO and provincial agencies in an updated Midwest Fish Compensation Plan.

Response:

AREVA is to be commended for using the best available technologies and practices for the stream crossings on the proposed haul road to McClean.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-6 (App. III) Comment:

Page 18. Section 5.2. Compensation.

a) What provisions will be made for spawning habitat for white suckers in the newly created habitat?

b) What will be the impact to the native stickleback population in Too Small Lake?

c) The Proponent has not identified an alternative option should the newly created lake not have sufficient winter oxygen levels to support northern pike and white sucker populations. In addition, what will be the alternatives should there be sufficient winter oxygen but the introduced fish populations do not become self-sustaining?

ARC Response:

a) Species spawning requirements will be integrated into the construction plans and habitat enhancement (e.g. cobble placement) as discussed in Appendix III, Section 7 and spawning depths are included in Table 5.1-5 calculations. This information was considered in the development of the follow-up plan (App III, Section 8).

b) The fish community in Too Small Lake will be monitored as part of the follow-up program (App III, Section 8).

c) It is well established in the scientific literature (Wetzel 1983) that there are numerous examples of lakes of this depth (e.g. 6m) which maintain sufficient DO levels that sustain fish populations. The seasonal oxygen levels in the deepened Too Small Lake will be measured prior to addition of large-bodied fish species, as detailed in the follow-up program. Once fish have been added to the lake, the fish community will be monitored and reported on, as detailed in the follow-up program in Appendix III. The outcomes and path forward from monitoring results will be discussed with regulatory agencies.

REFERENCE:

Wetzel, R.G. 1983. Limnology. Second Edition. CBS College Publishing, Philadelphia, USA.

Document Integration:

Detailed descriptions on species spawning requirements and a detailed follow-up program have been added to the revised Appendix III.

Comment:

It should be noted that placement of cobble as spawning habitat for white sucker will not ensure that it will be suitable for spawning. The cobble must be kept clear of fine sediments either through currents in streams or wind action. AREVA should clarify if there is sufficient effective fetch in Too Small Lake to ensure that the cobble will be kept clear of fine sediments.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-7 (App. III) Comment:

6) Page 19. Section 5.3. Evaluation of No Net Loss.

a) Some of the assumptions used in Table 5.1 to calculate the weighted suitable habitat area are not justified. In particular, the use of the HSI value of 0.7 for northern pike spawning habitat in Too Small Lake appears to overestimate the amount of habitat created. A review of Table 3.1 indicates that in Too Small Lake Habitat Unit 5 was the only unit that was assessed as being moderately suitable for pike spawning. The other units were either not suitable or marginal. It is noted from Figure 3.1 that Habitat Unit 5 only accounted for 67 m of shoreline out of a total shoreline length of over 3000 m. To attribute the moderately suitable value of 0.7 to the whole shoreline of the lake is not justified. In addition, the extrapolation of the available spawning area to the whole lake area instead of to the area along the shoreline is not justified. It would be more appropriate to use the areas of the 0-2 m contour as the area available for spawning habitat. Casselman and Lewis (1996) in their review of the habitat requirements for northern pike (Table 1) attributed the lowest rank, as spawning habitat to water that was greater than 0.70 m in depth. Their ranking scale ranged from 1 (lowest) to 9 (highest).

b) How does the plan address providing access between Too Small and the downstream segments of Collins Creek or is it the Proponent’s intention to leave Too Small Lake as a relatively isolated water body? This aspect needs to be discussed more thoroughly and needs to include a discussion of the role of immigration and emigration in regulating a fish population.

c) What is the size of the watershed of Too Small Lake? One important habitat component for northern pike is that spawning areas must maintain sufficient water levels that will allow enough time for the eggs to hatch and for the resulting fry to become mobile. Has this habitat component been considered in the development of the Plan?

d) Was any consideration given to restoring Mink Arm after the completion of the mining operation and institution of the decommissioning and reclamation plan for the site?

ARC Response:

a) The calculations were re-done to account for habitat suitability (as described in comment DFO-17 (App III)).

b) It is proposed that Too Small Lake will be left as an isolated water body.

c) The size of the Too Small Lake watershed is 307 ha, please see Figure below. Water levels and fish community in Too Small Lake will be monitored as part of the follow-up program (Section 8 of Appendix III).

d) Mink Arm will not be restored to fish habitat because the open pit will be used to store special waste following completion of mining (Midwest EIS Main Document, Section 3).

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment Document Integration:

No integration required.

Comment

Comment: Pam and Golder a) It is noted that the contour from 0-2 m was used in the recalculations for Habitat suitability for northern pike and white sucker. b) The value of enhancing an isolated water body for habitat for predatory fish species is questionable. c) AREVA should indicate how the water levels in Too Small Lake have been monitored in the past and how it will be determined if the water levels will be adequate to ensure survival of the pike eggs and fry.

ARC Response

No response required - relates to Too Small Lake and/or Sue E/Sils Lake

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-8 (App.III) Comment:

Type II Page 10. Section 2.5.3. Too Small Lake. The data presented in Table 4.4-3 (Water Chemistry Data) in the main document was also reviewed. It is noted in Table 4.4-3 that the detection limits for the following parameters, cadmium, chromium and mercury in the 2003 samples were above the SSWQO for these parameters. Since the detection limits for these parameters are already above SSWQO, how will the Proponent be able to determine if the Plan has affected these parameters?

ARC Response:

Thank you for your question. Too Small Lake is a shallow water body with no inflowing or outflowing streams, and no aquatic sources of contaminants that can be related to the activities at the McClean Lake Operation or the Midwest site. The lake may receive small contributions of dust from atmospheric sources related to site activities, which are not expected to add significantly to the contaminant load in the lake.

As part of the proposed fish compensation plan (as presented in Appendix III of the Midwest EIS), Too Small Lake will be deepened to enhance over-wintering habitat in the lake by increasing the existing lake volume (~653,000 m3) by approximately 404,000 m3. This will involve removal of overburden and potentially blasting of the upper sandstone to create overwintering fish habitat. During blasting, it is expected that particulate material from the natural bedrock will accumulate in the lake bottom, some of which could become resuspended as uncontaminated seepage water potentially augmented with clean surface water from surrounding water bodies is added to the lake, but this material is expected to sediment out over time prior to introduction of the fish and is not anticipated adversely affect water quality. During blasting, a mixture of ammonium nitrate and diesel will be used, along with small quantities of booster and primer to detonate the blast. It is not expected that Cr, Cd or Hg will be introduced to the lake through this process. On this basis, Cr, Cd and Hg are not constituents of potential concern (COPC) either currently in Too Small lake and it is not anticipated that they will become an issue if the Too Small Lake fish compensation is implemented as planned.

In addition, it is expected that if present in water, then Cd and Hg could bioaccumulate and biomagnify, respectively, resulting in detectable levels in fish tissues. However, as discussed in Section 4 (Tables 4.4-44 and 4.4-46) of the Midwest Project EIS, Cd concentrations that have been measured in both bone and flesh of large-bodied fishes from lakes in the vicinity of the Midwest site fell below their respective detection limits. These low fish tissue concentrations are indicative of low concentrations of Cd in the surface water. Additional Cd data for tissues of fish collected in the vicinity of the McClean Lake Operation are available in the McClean Lake Operation SOE reports (AREVA 2009). For example, as reported in the 2008 SOE for the McClean Lake Operation, Cd fell below the detection limit in fish flesh and bone collected from the Sink Reservoir, which receives treated effluent.

Under the Metal Mining Environmental Effects Monitoring (MMEEM) regulations, if Hg levels in the treated effluent (which can be considered a worst-case scenario with respect to aquatic releases under normal operating conditions) are greater than or equal to 0.1 μg/L, the mine is required to conduct a fish tissue survey measuring Hg tissue concentrations (EC 2002). Mercury in treated effluent at the McClean Lake Operation has consistently been below the 0.05 μg/L detection limit, and as a result, under the MMER, AREVA is not required to monitor Hg in fish tissue, and Hg is not considered a COPC. Therefore, given that Hg is not a COPC at end-of-pipe, it is not anticipated to be a COPC in Too Small Lake, which is not expected to be receiving any contaminant contribution from site activities.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment With respect to available measurement techniques, the detection limit for Cd will be lowered to 0.01 μg/L in the near future, which falls below the SSWQO of 0.017 μg/L for soft waters (where the total hardness of Too Small Lake is approximately 6 mg/L).

Similarly, with application of inductively-coupled plasma-mass spectroscopy (ICP-MS), a detection of 0.5 µg/L can be achieved for chromium. This value falls below the SSWQO of 1 µg/L, thus providing the laboratory capability to more fully assess chromium concentrations.

The detection limit for Hg in water that can currently be achieved in a commercial laboratory is 0.05 μg/L, but as discussed, Hg is not considered a COPC even at the end-of-pipe and is not anticipated to be an issue in Too Small Lake either presently or following implementation of the Too Small Lake fish compensation plan, as proposed. That said, AREVA will continue to ensure that the lowest practical detection limits and the best available techniques (BATs) are used for measuring COPCs as part of our environmental monitoring programs.

REFERENCES:

AREVA Resources Canada Inc. (AREVA). 2009. Status of the Environment Report. McClean Lake Operation. Assessment Period 2006- 2008.

Environment Canada (EC). 2002. Metal Mining Guidance Document for Aquatic Environmental Effects Monitoring. National EEM Office June 2002.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-9 (App. III) Comment:

Page 11. Section 3.Evaluation of Fish Habitat. Areas overlying deeper water simply have a larger volume of water that is available to absorb the oxygen demand of the sediments and any decomposing organic material that is still in the water column. It should be noted that a number of factors might influence the development of low or anoxic conditions under the ice in a waterbody. These factors include when the waterbody becomes ice-covered, how much and when snow covers the ice and limits light penetration, what the initial oxygen levels in the water column were after the water body had become iced over, and the primary productivity of the waterbody or plankton standing crop. Since over-wintering habitat is one of the primary considerations for the Plan, the Proponent should provide a more thorough discussion of over-wintering habitat development.

ARC Response:

More information on the factors affecting oxygen levels in the winter has been added to Appendix III.

Document Integration:

More information on dissolved oxygen has been added to Section 7.1 of Appendix III.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-10 (App. III) Comment:

3) Page 18. Section 5.2. Compensation.

a) The Proponent notes that Too Small Lake has a high abundance of plankton, benthic invertebrates and the presence of small-bodied fish species, which could be a potential forage species. The higher abundance of forage fish could be related to the lack of a predatory fish species in Too Small Lake.

b) The Proponent considers the enhancement of Too Small Lake to be a good candidate for compensation as other small shallow lakes such as Lake C1 (Figure 1.1) located to the northeast, which does support northern pike and white sucker populations, despite having relatively low winter DO concentrations (as low as 0.5 mg/L). However, the comparison between Too Small Lake and C1 may be overlooking the connectivity of the latter lake to downstream segments of Collins Creek. The Proponent should note that there are also two lakes upstream of C1, so the upstream watershed of C1 is likely greater than the upstream watershed of Too Small Lake.

c) One should also consider the potential for there to be moving water in Lake C1 as it is downstream of two waterbodies. How extensive was the winter oxygen sampling in Lake C1. What about the potential migration of fish from Lake C1 to better overwintering habitat? Was this considered in the development of the Plan?

d) The proposed development of a new adjacent deep-water basin within the Plan would involve the creation of an approximately 20 ha basin which would be shaped to provide both shallow littoral and deep-water zones. The deepest portion of the new basin would be approximately 6 m in depth and would be approximately 5 ha in area. Based on the measurement provided, the deep water area would have a volume of approximately 300,000 m3. With the addition of the second basin what is the overall increase in the volume of the lake?

ARC Response:

a) This is an excellent point and AREVA agrees.

b) AREVA agrees that the presence of large-bodied fish in Lake C1 (despite low DO levels in late winter) is likely due to the connectivity of the lake to adjacent water bodies (see response to Comment DFO-7 (App. III)). To clarify, it is proposed that Too Small Lake be deepened, which will result in increased DO in the lake throughout the year, including during winter (as described in Section 7.2.1.1 of the revised App. III). It is not perceived that DO will be an issue with the proposed changes to the basin bathymetry in Too Small Lake.

c) It is proposed that compensation be carried out in Too Small Lake, the preferred fish habitat compensation option (as described in Section 7.2.1 of App. III). Please see response to item b) above.

The expansion of Too Small Lake is expected to double the original volume of the lake (~652,300 m3 in current Too Small Lake versus ~677,400 m3 in Too Small Lake expansion = total volume of ~1,330,000 m3). Appendix III Table 5.1-4 and Figure 6.1-1 provides a breakdown of Too Small Lake volumes by depth less than and greater than 2 m. Document Integration:

Sections 4 and 7 of App. III have been revised to clarify.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-11 (App. III) Comment:

Page19. Section 5.3. Evaluation of No Net Loss.

a) The Proponent does not account for the loss of riparian habitat in the plan.

b) Why does the Proponent include lake whitefish and longnose sucker in the habitat compensation analysis? The Proponent does not discuss transferring these species into Too Small Lake and its expanded basin.

ARC Response:

a) The focus of Appendix III is fish habitat compensation. The calculations quantifying loss of fish habitat are based on species-specific habitat use with respect to spawning, juvenile rearing and overwintering. The species selected are considered representative of fish community health. To confirm this, a detailed follow-up plan will be implemented to measure productivity in both areas of habitat loss and gain. This plan is provided in Section 8 of the revised fish habitat compensation document (Appendix III).

b) To clarify, AREVA is proposing to transfer lake whitefish and longnose sucker (as well as northern pike and white sucker) into Too Small Lake (e.g. refer to Appendix III Tables 5.1-4, 5.1-5, 5.1-6, 5.1-7). Lake whitefish and longnose sucker are included in the calculation of no net loss, for both habitat loss and gain, where applicable.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-12 (App. III) Comment:

Page 8. Section 2.4. Benthic Invertebrate Community. In Table 2.5, the mean biomass for benthos is presented as g/0.156 m2, while the density is presented as number of organisms/m2. Why is biomass presented for an area of 0.156 m2 and density presented as an area of 1 m2? This difference in units is awkward and Proponent provides no explanation as to why different areal values are used. In addition, the Proponent did not reference where the collection methods are described in the main document.

ARC Response:

For consistency with other AREVA documents, biomass presented based on Ekman dredge units (g/0.156 m2) have been retained. However, clarification has been added in a footnote and a conversion to g/m2 has been included in Appendix III Table 6.1-4 for comparison purposes as suggested. Details on benthic invertebrate collection methods are available in the Midwest Technical Information Document, Section 4.7 (AREVA 2009).

REFERENCE:

AREVA. 2009. Midwest Project. Existing Environment Technical Information Document.

Document Integration:

A footnote has been added to Appendix III Table 6.1-4 to identify sampling method; and values for biomass per m2 have been included for comparison.

Comment

AREVA should provide information on the size of the Ekman dredge that was used to collect the benthic invertebrate samples.

ARC Response

As noted in the Midwest TID, samples were collected using an Ekman dredge at each study area and each sample was a composite of 2 three dredges. The dimensions of the dredge are 22.8 cm x 22.8 cm. Each dredge has a sample area of 0.052 m therefore the composite of three results in an area of 0.156 m2.

Document Integration

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-13 (App. III) Comment:

Page 10. Section 2.5.3. Too Small Lake. Too Small Lake has a surface area of 40 ha and a mean and maximum depth of 1.17 m and 2.1 m, respectively. However, in the table shown in Figure 2.1, the maximum depth is identified as 3.1 m. Which value is correct?

ARC Response:

Typo. Too Small Lake maximum depth is 3.1 m.

Document Integration:

Text has been changed to 3.1 m.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-14 (App. III) Comment:

Page 12. Section 3.1. Mink Arm. Did the Proponent conduct spawning surveys for species other than northern pike?

ARC Response:

A northern pike (spring) spawning survey was conducted in Mink Arm in 2006. A small number of northern pike eggs (between 8 and 56 eggs) were located in five of the ten areas sampled. These ten areas were considered to be the most likely to support northern pike spawning habitat in Mink Arm (AREVA 2009a).

In addition, larval fish tows were conducted on 23 and 24 June 2009 in Mink Arm (AREVA 2009b) to provide an indication of other types of fish that are spawning in Mink Arm. The tows transect distance totaled approximately 5.1 km and trawling time totaled 2:21 hours. A total of fourteen fish larvae were collected and all fish were identified as burbot (Lota lota).

REFERENCE:

AREVA. 2009a. Midwest Project. Existing Environment Technical Information Document.

AREVA. 2009b. Midwest Project. Technical Memorandum: Mink Arm 2009 Fish and Fish Larvae Community Surveys. Prepared by Canada North Environmental Services.

Document Integration:

No integration required.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments

Regulator Comment / Response Comment SME-15 (App. III) Comment:

Page 19. Section 5.3. Evaluation of No Net Loss. There are errors in the text when reference is made to the attached table numbers showing the summary of the HSI values for each habitat type (spawning, juvenile and over-wintering) and there is no Table 3.5.

ARC Response:

HSI values have been updated and tables have been corrected throughout the revised fish habitat compensation plan to address regulatory comments. Appendix III Tables summarizing HSI values are 5.1-2, 5.1-2 and 5.1-3 for overwintering, spawning and juvenile rearing habitat, respectively.

Document Integration:

Updated Appendix III HSI Tables 5.1-2, 5.1-2 and 5.1-3 and corresponding text.

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment SME-A New Regulator Comment DFO-2 (App. III) and AREVA Response: DFO-2 (App.III) AREVA Response to Comment DFO-2 (App. III), Paragraph 6:

Comment:

A 5% impact to all species is a significant impact. AREVA should provide information on how the species impact will relate to individuals of the impacted species.

ARC Response:

See response to DFO 2 (App III)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Response to Comments Regulator Comment / Response Comment SME-A New Regulator Comment DFO-2 (App. III) and AREVA Response: DFO-2 (App.III) AREVA Response to Comment DFO-2 (App. III), Paragraph 6:

Comment:

A 5% impact to all species is a significant impact. AREVA should provide information on how the species impact will relate to individuals of the impacted species.

ARC Response:

See response to DFO 2 (App III)

AREVA Resources Canada Inc. September 2011 Midwest Project – EIS Addendum – Appendix 3

Comment Comment / Response ALUP 16 Comment:

Section 3.1.2 Transportation and Utility Corridor-The proposed 17km road to McClean Lake adds another road to an existing road that is already in place. The area is highly concentrated with major developments and expansion of mining in the area. Another added road to this will have huge impacts on the barrenground caribou migration routes, wintering grounds and feeding grounds. The barrenground caribou numbers have been decreasing dramatically in the calving grounds and could be at more risk from further developments to the herd during wintering and migration routes. The EIS does not recognize the need to pay special attention to this herd and suggest very little impacts as the caribou herd has been known to winter and feed in the areas for the past five or more years. We understand and are very concerned that further road and mining developments will have huge impacts on the caribou herd, including woodland caribou that is listed under the species at risk.

1 ARC Response: The proposed transportation corridor between the JEB Mill and the Midwest Project will be the only road that directly links the two sites. The proposed road is considered to be a significant improvement to the means of ore transportation between the sites relative to what was proposed in the original 1991 EIS (Midwest Joint Venture 1991) and addresses one of the Joint Panel concerns raised by northern communities during review of the Midwest Project 1991 EIS (MJV 1991) and the 1992 Amendment (Minatco 1992) regarding the originally proposed ore haul: “Concerns were expressed over public safety on Highway 102 and Provincial Road 905. In addition, the Panel noted that the opening of the proposed Athabasca road to Black Lake will likely further increase local traffic on the highways.” (Joint Panel 1997) The 1995 EIS (COGEMA 1995) was approved on the basis that ore transport, in slurry form, would be via specially designed and constructed vessels along Provincial Road 905.

As outlined in the Midwest EIS (Section 3.3, Main Document), the proposed dedicated haul road is considered to be a significant improvement relative to the 1995 proposal, in that:  it addresses public safety issues and concerns with respect to ore haulage on Provincial Road 905, by diverting all mine related traffic to a dedicated road, and  the corridor will provide a utility corridor to transfer treated effluent from the Midwest site to the S/V TEMS, and a potential power line thus reducing the operational footprint associated with waste water management at the Midwest site.

As part of the proposed Midwest Project decommissioning plan, the road will be decommissioned and returned to a state similar to the surrounding environment.

AREVA acknowledges that roads and increased road density can affect wildlife migration (response to comment CNSC-26, Midwest Project EIS Addendum). The addition of the proposed dedicated haul road does increase the road density in the area, but overall the road density in the area is still low. The effects of the addition of the dedicated haul road to barrenground caribou migration is uncertain. However, policies to protect wildlife and minimize land disturbances at the Midwest site and along the haul road will be similar to those in place at the McClean Lake Operation. AREVA’s construction and site management will provide oversight of all contractors during the construction and operation of the Midwest Project. An environmental monitor will be a member of the management team during site and road construction. The additional dedicated haul road could potentially affect individual caribou, but is not expected to have an affect on caribou populations.

A discussion on road density and potential effects to woodland caribou in the area of the proposed Project can be found in the Midwest Project EIS Addendum comment and responses for comment CNSC-26.

AREVA is working through the Saskatchewan Mining Association to contribute to the Environment Canada initiative to identify critical habitat for woodland caribou and through the SMA, are actively working with federal and provincial agencies to gain a better understanding of the interactions of our projects and activities with woodland caribou habitat. These initiatives include the contribution of recently acquired habitat information to the Saskatchewan Ministry of the Environment (SMOE) to support the development of a joint provincial-Environment Canada recovery strategy for boreal woodland caribou (Rangifer tarandus caribou) in Saskatchewan. AREVA will continue to support the development of a comprehensive management strategy as this initiative progresses.

2 ALUP 21 Comment:

Additionally, the long term effects of several contaminants (e.g. selenium, nickel, molybdenum and arsenic) are not clear in the EIS, particularly in regards to bioaccumulation from aquatic plants to aquatic wildlife such as fish, beaver, mink, muskrat and otter, and eventually to humans.

ARC Response:

Within the Midwest ecological risk assessment (ERA), the effects of constituents of potential concern (COPC) are examined both spatially and temporally, including the operating, decommissioning and post-decommissioning periods. The ERA examines how COPC travel throughout the biotic (living) and abiotc (nonliving) ecosystem and how they can affect valued ecosystem components (VECs), including humans. Conceptual diagrams and schematics are provided in Figures 7.1-1 and 7.1-2 of the EIS Main Document, Section 7, and illustrate how the ERA examines the effects of the project, including how contaminants are transferred through the ecosystem. Additional details of the ERA can be found in Appendices V, VI and VII of the Midwest Project EIS. Results of the ERA are interpreted throughout Sections 7, 8 and 9 of the Main Document.

Longer term (beyond the post-decommissioning period) contaminant transport to surface waterbodies from the JEB TMF and special waste rock storage is modeled in Appendices IX and XI. Transportation of COPCs from these sources is modeled hundreds and thousands of years into the future. The assessment of long-term effects from these sources is included in Section 7.3 of the Main Document. Prediction of effects from the JEB TMF are continually being verified in the on going Tailings Validation and Optimization Program, while concentrations of COPCs in surface waters from special waste rock are predicted to be below Saskatchewan Surface Water Quality Guidelines.

3 Comment Comment / Response ALUP 23 Comment:

Terrestrial Habitats

The use and choice of bioindicators for ecotoxicological impacts: copper, lead, nickel and uranium concentrations in soil are used to suggest that “mining and milling operations are having a negligible effect on vegetation and soil metal concentrations” with the exception of lichens. However, no mention of bioaccumulation or biomagnifications across trophic levels is found, except for a mention of selenium. However, the EIS states that selenium take-up will be a concern for mallard, scaup, merganser, muskrat and mink, yet it does not address bioaccumulation or even mitigation regarding this. The impacts of pollutants in terms of bioaccumulation through the food chain are not fully addressed

ARC Response:

Please refer to the response to comment ALUP-21.

4 Comment Comment / Response ALUP 24 Comment:

The EIS (Section 9.2.2.) also indicated that there were no species requiring special management considerations, based on extensive field investigations (this is a case where TEK and local knowledge should have been gathered). However, in Section 7.2.1.2., the rusty blackbird was indicated as a species of a special concern, and terrestrial habitats within the local assessment boundary have the potential to support several rare and endangered species, including species identified as VECs. Woodland caribou is a threatened species (SARA), and a total of 65% of the local assessment boundary is considered to have high habitat potential for caribou, however, there is no indication on mitigation measures planned towards avoiding the impact on caribou and its habitat. In section 4.5.2.1 it is stated that there ARE species at risk in the local assessment boundary, including some that are classified as ‘S1- extremely rare’. There are no mitigation or management measures indicated to protect these. However, on the previous page, it states “Species that are tracked by SKCDC, ranked S1, S2 or S1S2, and that are very likely to be listed in the future under The Wildlife Act, are also included in the provincial interim list. Special management considerations are required for all species on the interim list, and should include appropriate surveys and setbacks on lands where these species have been recorded, or are discovered (SKCDC 2002).” There should therefore be management considerations for these rare species detailed in the EIS.

5 ARC Response: Since the initial submission of the Midwest Project EIS in 2007, the above referenced Saskatchewan Conservation Data Centre (SKCDC) document (SKCDC 2002) has become outdated and is no longer a referenced document from the SKCDC website (http://www.biodiversity.sk.ca/) even though the web link to the document is still active. AREVA has informed the SKCDC of this issue and this problem should be resolved shortly. AREVA acknowledges this outstanding item and the reference has been removed from the main document.

The relevant and current document within which to consider the need for mitigation and management measures are the Wildlife Act and Table 1. Saskatchewan Activity Restriction Guidelines for sensitive species in natural habitats (SKCDC 2003; http://www.biodiversity.sk.ca/Docs/SKactivityrestrictions.pdf). This table provides guidelines to assist proponents during the planning of proposed projects and provides information on the species which have restriction guidelines developed, restricted activity dates, and recommended setback distances by disturbance category. Note that most listed (SARA and the Wildlife Act) and tracked species, both of which are included on the provincial Interim list, do not have activity restriction guidelines, or management plans developed for those species. None of the species within the Midwest local assessment boundary (LAB) are identified in the restriction guidelines as species for which mitigation and management measures are suggested. Please refer to Tables 4.5-9, 4.5-10, and 4.5-11 for lists of rare plants and wildlife that have the potential to occur or that have been observed in the regional assessment boundary or the LAB of the Midwest Project and McClean Lake Operation. None of the species found in the Project area have activity restriction guidelines associated with them, therefore these are not outlined in the EIS. Departments within the federal and provincial governments are responsible for developing management strategies, recovery strategies and identifying critical habitat for species at risk.

Document Integration:

Reference SKCDC 2002 has been removed from Section 4.5.2 of the main document and replaced with SKCDC 2003 (http://www.biodiversity.sk.ca/Docs/SKactivityrestrictions.pdf). The wording in Section 4.5.2.1 has been changed to the following to provide the correct reference, wording and clarity:

Provincially, the first 15 plants and animals in new regulations under the species at risk provisions of The Wildlife Act were officially designated in 1998 (SE 1998). This designation means these plants and animals are protected from being disturbed, collected, harvested, captured, killed and exported. Status determination is based on a review of a status report, containing biological information, by Saskatchewan Conservation Data Centre (SKCDC). Preparation and review of status reports is now in progress for an additional 52 species listed on the “Interim List for Species at Risk Requiring Special Management Consideration” (SKCDC 2010). Species tracked by SKCDC that are ranked either S1, S2 or S1S2, and that are very likely to be listed in the future under The Wildlife Act, are also included in the provincial interim list. Special management considerations have been developed for some of the species on the interim list. These include appropriate surveys and setbacks on lands where these species have been recorded, or are discovered (SKCDC 2003; http://www.biodiversity.sk.ca/Docs/SKactivityrestrictions.pdf). None of the species identified in the Project area have specific guidelines or management strategies associated with them.

6 Comment Comment / Response ALUP 25 Comment:

Information on caribou and their potential for bioaccumulation and ecotoxicological effects is necessary. Especially since caribou feed mostly on lichen, which has been shown to have elevated metal concentrations, and may accumulate in local caribou populations over time. In addition, the EIS considers the effects of chemical constituents of concern but does not address the physical impacts on wildlife, in particular, caribou. The EIS must identify what the mitigation measures are if caribou are found in the project area. This is particularly important because in section 4.5.4.1 it states that 65% of the local assessment area has high habitat suitability for caribou, and in section 4.5.3.2 it states that barrenground caribou have been known to occupy the regional study area in recent years (winter of 2004). It is not clear where this information was obtained or whether local First Nation hunters were consulted. This is of particular importance to the AD, as caribou are the lifeblood of the north. The EIS also mentions that the land is used for traditional purposes, yet none of the data in the EIS uses traditional ecological knowledge as a source. Although the EIS uses maps to identify areas of use, there does not appear to have any First Nation input into the data collection.

ARC Response:

Please see response to ALUP-21. Figure 7.1-3 outlines the sources of exposure and COPC exposure pathways examined as part of the assessment. Based on this valuation potential risks are outlined in Table 7.2-19. As indicated, no risks to woodland caribou are associated with the release of COPCs from the proposed Project. Woodland caribou are considered a conservative representative of barren-ground caribou as they reside in the area year round. A discussion on the physical effects on barren-ground caribou habitat is provided in Section 7.2.3.4, and 7.2.4 and in response to comment CNSC-26.

The maps presented in Figures 4.6-2 to 4.6-7 are based on information gathered from First Nations by the PAGC, and represent a compilation of First Nations land use knowledge based on information provided by interviews conducted with Elders and community members within the region.

7 Comment Comment / Response ALUP 26 Comment:

The EIS states the potential effects of terrestrial biota and waterfowl including the bear, mink, beaver, lynx, caribou, eagle, hare, mallard, merganser, moose, muskrat, scaup, ptarmigan and wolf, based on estimated exposure to predicted concentrations in water, food sources, sediment, and soil, while there is no indication of possible mitigation measures, and if the impact is unavoidable, this should be stated.

ARC Response:

As indicated in Section 7.2.6 and Tables 7.2-10 to 7.2-21, based on average exposure, the release of some COPC over the life of the Project represent potential risks to waterfowl and semi-aquatic furbearers that may reside in Sink Reservoir and Vulture Lake. These potential risks are the residual risks which persist after mitigation measures (i.e., water treatment) have been applied. The methods of estimating these risks were done in a conservative manner. The significance of potential adverse effects associated with these risks is outlined in Section 9.2.8 and Table 9.3-1.

To clarify, potential effects to ptarmigan, hare, lynx, caribou and wolf from exposure and uptake of COPC are not predicted from the ecological risk assessment (Section 7, Tables 7.2-10 to 7.2-21).

8 Comment Comment / Response ALUP 27 Comment:

Migratory species and quality of biological inventories: information on the distribution, abundance and temporal variability in density of birds and other wildlife due to seasonal migration is lacking in the report.

ARC Response:

Information on the existing environment in the site, local and regional study areas is located in Section 4, Existing Environment, of the EIS Main Document. Specifically information on terrestrial habitat and wildlife is located in Section 4.5 of the Main Document. Ecosite phase classification categorized habitat types (ecosite phases) and used wildlife inventory data to describe the ability of different habitat types to support wildlife species and included rare plants, birds and moose and caribou seasonal habitat suitability. Please refer to Sections4.5.1 and 4.5.1.1.

9 Comment Comment / Response ALUP 28 Comment:

Information on flora was limited to fruits of the bog cranberry and blueberry, and Labrador tea. Fauna was limited to large mammals and birds, leaving out key organisms, such as insects and invertebrates, which are invaluable for measuring ecosystem health. This is of concern to the AD, as invertebrates, especially amphibians are key indicator species. By disregarding these species, important impacts may be missed.

Sarah ARC Response:

The information on flora is not limited to bog cranberry, blueberry and Labrador tea. As outlined in response to comment ALUP-27, ecosite phase classification included habitat suitability classification for rare plants as well as incorporating plant survey information. Please refer to Section 4.5.1 and 4.5.2.1 of the EIS Main Document.

Two species of amphibian, the boreal chorus and wood frog, have been identified in the local assessment boundary (LAB). This species has sporadic distribution in the LAB and is a poor indicator species.

10 Comment Comment / Response ALUP 29 Comment:

Upon review, it is recommended that the baseline description be strengthened with aspects of migratory species, invertebrates, ecosystem processes, species interactions for bio-accumulation potential, appropriate use of bio-indicators and references to local TEK. The basis for ecosystem approach management is the identification of vulnerable ecosystems based on plant-animal communities and knowledge of local people, which is lacking.

ARC Response:

Please see responses to comments ALUP-21, 25, 26, 27 and 28.

11 Comment Comment / Response ALUP 32 Comment:

Section 4.3.1-Climate and Meteorology and 4.3.1.3 Precipitation and Evaporation-the EIS utilizes data for the local assessment boundary that is not relevant to the specific area for precipitation and evaporation statistics, but rather uses data from other sources and places not in the vicinity of the proposed mine site. The data sourced is from 1971 to 2001, with no current information to make accurate calculations

ARC Response:

On-site meteorological data, supplemented with local and regional meteorological data, as appropriate, was used to support the assessment.

12 Comment Comment / Response ALUP 33 Comment:

Section 4.3.2.1-Total Suspended Particulate Matter-The concentration of total suspended particulate measured during the exploration phase of 1979 and 1989 data results are used as comparisons for metal levels and radionuclide concentrations that determined to be similarly low. Again, we have data that is outdated to support the EIS to determine if the proposed Midwest Open Pit should move forward. We understand the data that is being used in the EIS is obsolete for the proposed project that new data within the last five years should be reported in the EIS. McClean Lake Operational Licence has been renewed based on the reviews completed by the Canadian Nuclear Safety Commission (CNSC), based on the reviews done by CNSC staff there should be new data that should support new studies and data rather than data that is 20-30 years old for the local assessment.

ARC Response:

Historical data, from the test mining period, is included for completeness (Table 4.3-4, EIS Main Document). Recent data, as outlined in Tables 4.3-3 and 4.3-5, was used to characterize baseline TSP for the purposes of the assessment. Information from the Midwest site as well as the McClean Lake site, which includes a reference Hi Volume air sampler at Vulture Lake, were both used in the Air Quality modelling completed for the assessment (Appendix VI).

C/O Prince Albert Grand Council Cottage 4 Chief Joseph Custer Reserve #201 P.O. Box 2350, Prince Albert, Saskatchewan S6V 6Z1 Phone: (306) 922-7612 Fax: (306) 763-2973

September 17, 2010

Peter Boothroyd, Director Canadian Environmental Assessment Agency Suite 101-167 Lombard Avenue Winnipeg, MB R3B 0T6

ATTENTION: PETER BOOTHROYD

Dear Sir:

RE: MIDWEST MINE ENVIRONMENTAL ASSESSMENT REVIEW

I am writing to you on behalf of the Athabasca Regional Government (ARG) in response to the June 2010 AREVA INFORMATION SESSIONS held with the Athabasca Denesuline First Nation Leadership on the proposed Midwest Open Pit Mine Environmental Impact Statement (EIS).

The Athabasca Lands Office of the Prince Albert Grand Council (PAGC) received funds from the Canadian Environmental Assessment Agency (CEAA) Aboriginal Funding Envelope to participate in the Environmental Assessment (EA) review for the proposed Midwest Mine EIS and that PAGC have reviewed the Midwest Project EIS and we offer our comments below on behalf of the Athabasca Denesuline and the ARG.

Our main concern with the EA process relate to the inadequate consultations and accommodation of the Treaty and Aboriginal Rights which have not been addressed to satisfy the impacted community members. This includes concerns of Denesuline members

of the potential adverse socio-economic effects and adverse impacts the Treaty and Aboriginal Rights of the members of the Athabasca communities and the lack of significant information regarding environmental monitoring, however, we will include our comments on the entire EIS.

Firstly, the impacted communities are Denesuline, and still actively practice our culture and language. To respect this fact, and to ensure greater understanding of the EIS, the executive summary at a minimum, should be translated into Denesuline, our local language. This will ensure that more community members directly impacted by the proposed project would better understand what is being proposed and eliminate the language bearer issues.

Generally, throughout the EIS, there are various subjective terms that are not defined. For example, ‘limited impact’, ‘significant’, ‘negligible’, etc. It is difficult to understand what they mean. For example, in section 4.2.2.2.1, it states that “…the concentrations of radionuclides and additional trace elements increase significantly." Is this statistically significant, or biologically significant, i.e. enough to be dangerous to humans or animals?

In section 4.6.2 Traditional Land Use, it states that “…the Midwest project will have limited interaction with traditional land use.” What is meant by limited? In addition, the information presented is distributed all over the document. For example, mitigation strategies for waste water management are presented in Section 3.5 as well as in Section 7.1.1.1. Waste rock management options are discussed in Section 10.4.4 and 3.5.3. This makes it very difficult to find information and navigate the document.

In addition, within section 1.2.3-Purpose of the Project and Need for the Project- the EIS does not address the negative aspects of nuclear power nor the negative uses of uranium. Only the benefits are mentioned. However, by ignoring the potential negative effects and not addressing them (storing nuclear waste, weapons) it creates the perspective that the EIS is written in a biased manner.

Socio-Economic Effects

Traditional Land Use/Traditional Knowledge It is mentioned in section 3.8.1 that, albeit “limited”, the land for the project is used for fishing, hunting and trapping (e.g. five trapping areas in assessment area). It is stated that after decommissioning the land can be used for those activities again, but how will land users be compensated during the lifetime of the operations and during the decommissioning? Will they be able to use the land during the project life? What were their concerns? Were the trappers specifically consulted on potential adverse effects and their Aboriginal and Treaty Rights?

2 1. How will traditional land users in the mine area be compensated for their loss of land during the construction and operation of the mine? 2. The EIS did not utilize traditional ecological knowledge; it seems that only location maps of traditional use were used. 3. Section 12-Monitoring- makes no mention of using local (traditional) knowledge or local people in the monitoring efforts. Will traditional ecological knowledge be used for monitoring?

Socio-Economic Within the socio-economic section of the EIS, only positive impacts to the social environment are discussed. Not all possible effects are discussed (e.g. changes in migration flows, leisure activities, family level changes, negative social life, pressure on community services, etc.). Negative impacts need to be included in order for the Athabasca Denesuline (AD) to be fully aware and informed of the impacts.

Where employment is discussed, all jobs are cited as temporary. There needs to be a study of the consequences for workers after temporary work is done (e.g. construction). The jobs need to be full time for there to be appropriate benefit to the workers. In addition, if workers must relocate to the mine site, consideration must be made for the duration of the stay, and the subsequent impacts to families and communities that are left behind. Spin-off benefits in the communities must also be identified.

The AD anticipate that there would be social and economic effects on the communities after the project is complete or if the project is scaled back or stopped early due to economic problems or a shift in global attitudes towards nuclear power. These impacts must be included within the socio-economic section of the EIS. In addition, the estimation of economic effects, such as profits, taxes, etc. of the Midwest Project at the local, regional and national level should be provided in the description of the project development.

Local people must also be involved in monitoring activities. This will increase trust and confidence in the results of the monitoring. There also needs to be a comprehensive monitoring program in place to measure the cumulative effects of chemical pollutants in the food chain and how this may affect local people for years to come. Many employees will move back south upon completion of the project, but local communities will remain.

Consultation 1. Section 5.4.2 states that “recorded questions and answers totaled 86 from the northern communities.” However, there are only 23 questions in table 5.4-2. What were the other questions?

3 2. Largely informative, rather than consultative community meetings were held annually in the form of tours, providing little means for follow-up interactions between the proponents and stakeholders. 3. AREVA’s Public Consultation Plan is aimed at merely informing the stakeholders and not identifying potential issues of concern and resolving problems that may arise. The chosen consultation technique and schedule provides with little opportunities for members of the public to submit comments and find out if they were considered. There is no obvious evidence of taking TEK into consideration at any stage of the project. 4. Consultation should extend into the monitoring and decommissioning stages of the project.

Health & Safety

An overall study of cumulative or secondary effects on human health due to the combination of different stress factors (radio- and non-radioactive) is needed. The EIS lacks data on the potential radiation impacts in case of unforeseen circumstances involving radioactive materials and products. Safety procedures and radiation risk levels are determined for employees operating under normal conditions, while probable faults or leakages during the production are not explicitly mentioned.

Local health care and occupational health services are described in two sentences, saying that basic health services and facilities are found in most communities in the Athabasca region. Information about the capacity and capabilities of these facilities is not provided which does not allow for analyzing whether the capacity is adequate for ensuring health and safety of a new labor force, or if there should be an emergency. Nor does it mention what the risks are for human health from exposure to accidents involving radioactive substances.

Section 8 describes safety and training and there is a chart with the number of accidents, but the types of occupational hazards and detailed statistics of accidents per type that show the most frequently occurring accidents is not included. This is important for community members to fully understand what the risks are associated with the job. The EIS should identify the most serious threats/potential accidents as well as the most probable ones, their magnitude, duration and irreversibility.

The fact that the public did not identify human health as an issue of substantive concern during consultation should have indicated that there was a lack of knowledge of the potential impacts, not that there were no concerns.

Environmental Effects

4 The EIS states that the final criteria for mine site layout “will be determined by AREVA’s ability to acquire additional surface lease from the Province of Saskatchewan,” (section 3.1.1.2) even though all four alternatives differ in size and potential impacts. Impacts to the environment should have been taken into consideration as a priority. Unmitigated impacts were not discussed. The maintenance of natural processes and conservation of species was also not discussed. This is of concern to the AD, as impacts to the environment have the potential to directly impact on the ability to use the land as a Denesuline.

Section 3.7.3-Transportation of Ore- a response to large spills requires a detailed plan of the worst case scenarios when cleaning a massive spill, a spill contingency plan must be included in the EIS how minor and major spills will be attended and cleaned up with appropriate regulatory agencies at site to prevent any type human and health risks to works and the environment as a whole.

Aquatic Habitats

In section 4.5.1.3 the EIS admits that there is no baseline data about wetland communities. It is then stated that wetland changes at McLean Lake are monitored and the study is briefly described. However, there is no mention of the location of monitoring, or if obtaining baseline data will occur.

The Fish Habitat Compensation Plan has not been reviewed conclusively by Fisheries and Oceans Canada (DFO), and is being reviewed and possibly changed. This is an area where local residents need to be consulted with, in order to effectively compensate for loss of fish habitat.

Communities must be consulted with in order to determine whether or not significant changes will occur to the availability of plants for traditional and medicinal purposes.

Additionally, the long term effects of several contaminants (e.g. selenium, nickel, molybdenum and arsenic) are not clear in the EIS, particularly in regards to

5 bioaccumulation from aquatic plants to aquatic wildlife such as fish, beaver, mink, muskrat and otter, and eventually to humans.

Mitigation strategies for aquatic habitats did not consider operational, technical, and economic feasibility, or their efficiency. This is a concern to the AD as aquatic habitats are very important to the ecosystems and any impacts are very difficult to mitigate effectively.

Terrestrial Habitats

6 particularly important because in section 4.5.4.1 it states that 65% of the local assessment area has high habitat suitability for caribou, and in section 4.5.3.2 it states that barrenground caribou have been known to occupy the regional study area in recent years (winter of 2004). It is not clear where this information was obtained or whether local First Nation hunters were consulted. This is of particular importance to the AD, as caribou are the lifeblood of the north. The EIS also mentions that the land is used for traditional purposes, yet none of the data in the EIS uses traditional ecological knowledge as a source. Although the EIS uses maps to identify areas of use, there does not appear to have any First Nation input into the data collection.

Upon review, it is recommended that the baseline description be strengthened with aspects of migratory species, invertebrates, ecosystem processes, species interactions for bioaccumulation potential, appropriate use of bio-indicators and references to local TEK. The basis for ecosystem approach management is the identification of vulnerable ecosystems based on plant-animal communities and knowledge of local people, which is lacking.

The EIS does not include any indication of responsibilities, scheduled time frames, and budget consideration or at least estimated cost for implementation of planned mitigation measures.

Abiotic Effects

Wastes

In section 3.5.2.1-Waste Rock Characterization- the EIS states that subaqueous storage of special waste will prevent acid generation, but that this can lead to increased arsenic and nickel concentrations in that water. However, there is no description about what

7 environmental effects those chemicals will create, and there are no mitigation measures presented.

The negative effects of tailings are not described. Due to the design considerations and mitigation measures, it is obvious that the tailings are dangerous, but it is not indicated in what way. The risks of a tailings leak must be indicated, for example how flora and fauna would be affected, including rivulet flows.

Page 3-63, paragraph 2 of the EIS, states that “some of the special waste rock contains significant quantities of sulphur, arsenic, nickel, uranium and other constituents of concern that may affect surface water quality if stored indefinitely on surface stockpiles and that arsenic and nickel are key constituents of concern for potential adverse environmental effects.” Statements of this nature communicates that other key elements of radionuclides are not a factor in considering environmental effects in the EIS, but on the other hand it poses many factors that need to be considered. Air emissions and wind pathways must be all considered including the impacts to wildlife and fish habitat that may enter the food chain to the Denesuline people living within the vicinity of the proposed mine site and the existing McClean Lake mine site.

Atmospheric

There is no consideration of atmospheric impacts associated with preparatory work of the project. What types of air pollutants will likely occur from the construction of the haulage road and building of additional facilities needs to be included within the EIS. The disposition of waste by wind transport is not mentioned; wind can transport particles from waste disposal in different directions, where air samples are not being taken. It is necessary

8 to broaden the scope of the research, in terms of indirect air pollution, and trace its effects on human health and the environment.

Conclusion

As previously stated, the AD are most concerned with the aforesaid matters which include the adverse impacts to their Treaty and Aboriginal Rights with resulting socio-economic effects presented and the omissions or inadequacy of environmental studies in this EIS including adequate consultations.

There has been little or no consultation efforts on the part of the Crown, and no attempt to comply with Athabasca Consultation and Accommodation Protocol. In addition, we suggest that before this project can begin, AREVA as the industrial proponent also needs to more comprehensively address our points above, but most importantly needs to consider and some case mitigate:

1. The adverse social and economic effects on the Athabasca communities after the project is finished or if the scale of the project changes. 2. Adverse social and economic effects to the communities besides job creation (e.g. health care infrastructure, influx of new workers etc.) 3. The drawbacks to mining and using uranium in addition to just the benefits. 4. How AREVA plans to include traditional ecological knowledge into the project (baseline studies, construction, operational, and monitoring phases). 5. Bioaccumulation of harmful chemical constituents through the food chain. 6. The effects on caribou through bioaccumulation of chemicals by lichen ingestion, and mitigation measures regarding encounters with caribou in the project area.

Please address our concerns by either providing us with specific information relating to each topic, or by informing us as to how you plan to address these issues. Please contact myself at 306-922-7612 or 1-306-292-6160.

Sincerely,

Diane McDonald, ALRUPB Coordinator Prince Albert Grand Council

cc: Athabasca Denesuline Chiefs: Napoleon Mercredi Bart Tsannie Donald Sayazie cc: Athabasca Provincial Leaders: Clara Larocque Dean Classen Sandra Hansen Terri Daniels cc: Bruce J. Slusar, Legal Advisor cc: Peter Brook, Prince Albert Grand Council cc: Vice-Chief Donald Deranger, Prince Albert Grand Council cc: Rob Clarke, MP cc: Environment Assessment, MOE

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