Kiggavik Draft EIS Information Requests€¦ · AREVA Resources Canada Inc. ... that is traversed by regional faults and local faults and ... A floor heave analysis was conducted

Kiggavik Draft EIS

Information Requests

Responses to

Canadian Nuclear Safety Commission

January 31, 2013

AREVA Resources Canada Inc. Responses to Kiggavik DEIS Information Requests

Page 1 Responses to CNSC

January 31, 2013

IR Number: CNSC 1

Request Preamble:

Reference:

NIRB 8.1.6 Baseline Geology

Issue:

Tier 3, Volume 5B section 5

Justification:

A regional geological cross section is missing, although detailed cross sections at the deposit scale are provided. This is basic contextual information about the project area.

Request:

Please provide a regional geological cross section.

AREVA Response:

The most recent regional map and cross section are provided on the following page. This map and section are from the 2012-05-26 version of the map from Jefferson et al. (2012). Jefferson, C., Chorlton, L., Pehrsson, S., Peterson, T., Davis, W., Potter, E., Gandhi, S.,

Bleeker, W., Keating, P., Fortin, R., Buckle, J., Miles, W., Rainbird, R., LeCheminant, A., Paulen, R., McClenaghan, B., Hillary, B., Quirt, D., Wollenberg, P., Wheatley, K. Riegler, T., Ramaekers, P., Tschirhart, V., Tschirhart, P., Morris, W., Scott, J.M.J., Cousens, B., McEwan, B., Bethune, K., Riemer, W., Calhoun, L., White, J.C., MacIsaac, D., Leblon, B., Lentz, D., LaRocque, A., Shelat, Y., Patterson, J., Bridge, N., Banerjee, Sharpe, R., Fayek, M., Robinson, S., Layton-Matthews, D., Enright, A., and Stieber, C. (2012): Can targeting criteria from Athabasca Basin be adapted to uranium exploration in Thelon and other northern Paleoproterozoic basins? A progress report. In: Abstracts-Resumes, volume 35, Geological Association of Canada – Mineralogical Association of Canada Joint Annual Meeting, St. John’s, Newfoundland, May 2012, p. 63.



January 31, 2013

IR Number: CNSC 2

Request Preamble:

Reference:

NIRB 6.6.1.1 Geology/mineralogy of ore deposits

Issue:

Tier 3, Volume 5B section 4

Justification:

The information about “lithology and mineralization” and “deposit types and associated bedrock” lack classical descriptions and contextual information (e.g. relative ─ and any absolute ─ ages of major rock units and structural features. Deposit models are not discussed.

Request:

Please indicate which deposit models are being applied. Where possible, please relate local geology (mineralized host rocks) to regional information (e.g. regional geology and table 2.4–1 in volume 5B; are metasediments Paleoproterozoic; are granites Archean or of unknown age).

AREVA Response:

The general deposit model includes lithological and structural features. The host lithology is typically Woodburn Lake Group metasediment (metagreywacke and micaceous quartzofeldspathic gneiss) that is traversed by regional faults and local faults and fracture zones. The mineralization locally crosses lithologies and can also be found in fractures within granite. Orebodies are tabular to irregular in shape, following local structures and/or foliation directions. They are up to 600 m in length and 100 m in width. The deposits have been found from bedrock surface (Kiggavik) to 500 m below the surface (End). Uranium minerals fill voids in breccias and vein stockworks and along foliation planes. Mineralization often occurs at or near structures associated with sites of rheology contrasts (granite-metasediment contacts, quartz breccia units, etc.) and/or at intersections of fault sets. The location of mineralization emplacement is controlled and bounded by conjugate sets of high-angle faults and hydraulic brecciation zones. Fluids associated with the mineralization were guided by earlier ENE/WSW structures, low-angle foliation, and parallel-to-foliation ductile to brittle-ductile shear zones. The precipitation of the relatively low-grade (<2% U) pitchblende mineralization occurred through redox reactions within regions of relatively reduced host material, likely through fluid-rock interaction and the coupled Fe-U redox reaction. Uranium deposition is accompanied by Au enrichment. The mineralization is also associated with hematization and is surrounded by a clay mineral host-rock alteration halo composed of sudoite and illite, with bleaching and quartz dissolution (argillization) features. The metasediments in the Kiggavik area are late Archean in age and belong to the Woodburn Lake Group (pelitic to psammitic gneiss in DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5B, Section 2.4, Table 2.4-1).

The granites in the Kiggavik and Andrew Lake areas are not Archean; rather they are variably Hudson (~1840 Ma) or Nueltin (~1760 Ma) in age (see Table 2.4-1), depending on which granite body is being discussed.



January 31, 2013

IR Number: CNSC 3

Request Preamble:

Reference:

NIRB 8.1.5 Permafrost and ground stability

Issue:

Tier 3, Volume 5B, 6A, 5D

Justification:

Seeking clarification on approach being taken to evaluate stability at planned construction sites (as listed in tier 2 volume 6 table 7.2-1), and considerations being given to variable permafrost conditions.

Request:

Clarify the plan to evaluate slope stability at specific locations (at different facilities) in light of differing permafrost/ground ice conditions in the project area.

AREVA Response:

As noted in DEIS Tier 2, Volume 6, Terrestrial Environment, Sections 5.6 and 7.2.4 slope stability analyses are considered to be an integral part of the plan to mitigate adverse effects during all phases of the project. Section 7.2.7 outlines a monitoring system for permafrost and terrain stability. The detailed implementation of the monitoring system will be provided at the licensing phase. Detailed geotechnical investigations and design will be completed with the detailed design of each facility.



January 31, 2013

IR Number: CNSC 4

Request Preamble:

Reference:

NIRB 8.1.6 Geology, 8.1.7 Hydrology (including water quality) and Hydrogeology

Issue:

Tier 3, Technical Appendix 5B

Justification:

The fault zone that cuts through the pits at Kiggavik will have an important implication to the pits (TMF) design, ground stability, and groundwater flow (inflow) calculation / prediction at the site.

Request:

Provide a figure showing the relationship between the pits at Kiggavik and the regional fault that cuts through the Kiggavik ores (as shown in Fig. 4.1.3).

AREVA Response:

DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5D, Figure 2.4-1 shows the relationship between the pits at Kiggavik and the regional faults. The following reports are also provided which give more detailed views of fractures and faults in the immediate vicinity of the proposed open pits. Golder Associates, 2011. Geotechnical Recommendations for the Proposed Andrew Lake Open Pit. and Golder Associates, 2011. Recommendations for the Proposed Kiggavik Main and Kiggavik Centre Open Pits.



January 31, 2013

IR Number: CNSC 5

Request Preamble:

Reference:

NIRB 8.1.6 Geology, 8.1.7 Hydrology (including water quality and Hydrogeology

Issue:

Tier 3, Technical Appendix 5B

Justification:

The fault zones that cut through the pits and underground mine will have an important implication to the mining and the pit (TMF) design, ground stability, and groundwater flow (inflow) calculation / prediction in the area.

Request:

Provide a description of the regional fault zones that cut through the open pits and the underground mines at both Kiggavik and Sissons, particularly their widths and the nature of the zones and their implications to the preferential ground water flow.

AREVA Response:

DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5D, Section 2.4 provides a discussion of the interaction between the regional faults and the groundwater flow. These faults are approximately 10m in width and assumed to act as enhanced permeability features in groundwater modeling and mine inflow predictions. Based on testing to date, using single borehole techniques, enhanced permeability features have not been observed even though packer testing has been conducted across the faults at the Kiggavik site. It is possible that the fractures are filled by fault breccias, veins, or fault gouge. Hydraulic conductivity values of 1x10-8 m/s to 1x10-6 m/s were used to represent the fault features in the mine inflow predictions. This is in comparison to the base case hydraulic conductivities in Appendix 5D, Table 2.4-1 which were 1x10-8 m/s and lower for those units below the permafrost. The following reports are also provided which give more detailed views of fractures and faults in the immediate vicinity of the proposed open pits. Golder Associates, 2011. Geotechnical Recommendations for the Proposed Andrew Lake Open Pit. and Golder Associates, 2011. Recommendations for the Proposed Kiggavik Main and Kiggavik Centre Open Pits.



January 31, 2013

IR Number: CNSC 6

Request Preamble:

Reference:

NIRB 8.1.4 Terrestrial Environment, NIRB 8.1.5 Permafrost and Ground Stability

Issue:

Tier 3, Technical Appendix 6A

Justification:

The ground-ice content in the permafrost overburden at different construction sites will have an important impact on the terrain, ground stability, design of the infrastructures, and permafrost evolution at the sites, and will then have an implication to the environment effect. A general description of “Ground-ice conditions in the Project area have been characterized as indicated in figure 3.1.2, likely having less than 10% of ground-ice content.” is insufficient for assessing the interaction/impact between the project and permafrost.

Request:

Provide a summary table of the site-specific ground-ice content (average and range) in the permafrost overburden at all planned construction sites.

AREVA Response:

A summary of ground ice conditions is provided in DEIS Tier 3, Volume 6, Terrestrial Environment, Appendix 6A, Attachment J. This file has been provided as part of Appendix A of the IR response package. The assumptions provided for the ground ice content are considered to be reasonable for the preliminary design of facilities. Additional data on ground ice content will be acquired to support the detailed design of specific facilities such as the stockpiles, roads, and mill site to ensure that facilities perform as described in the DEIS. Detailed designs will include this data and be provided prior to licensing.



January 31, 2013

IR Number: CNSC 7

Request Preamble:

Reference:

NIRB 8.1.5 Permafrost and Ground Stability

Issue:

Tier 3, Technical Appendix 6A

Justification:

Geotechnical borehole logs and grain size distribution curves are firsthand information to help better understand the physical properties of the overburden materials and the geological details, and should be provided.

Request:

Provide Attachment A (Geotechnical Borehole Logs) and Attachment B (Grain Size Distribution Curves).

AREVA Response:

The DEIS Tier 3, Volume 6, Terrestrial Environment, Appendix 6A, Attachments A and B are provided in Appendix A of the IR response package.



January 31, 2013

IR Number: CNSC 8

Request Preamble:

Reference:

NIRB 6.0

Issue:

Project Components and Activities Tier 2, Volume 2, Tier 3, Technical Appendix 5B

Justification:

Both Main Zone and Andrew Lake pits will penetrate the permafrost during the mining. The confined ground water pressure beneath permafrost is high and could cause floor heave and/or possible high inflow into the pits, particularly where the cut-through regional faults are preferential flow channels. Depressurization measures and a base liner have been proposed as necessary for the Main Zone mining. However, it is not sure if those measures will be considered for the Andrew Lake mining.

Request:

Clarify if depressurization measures and a base liner will be considered during/after the mining of Andrew Lake ore.

AREVA Response:

The design of the Andrew Lake pits followed the same design as the Main Zone pit. The pit floor depressurization method for the Andrew Lake pit will be the same as described for the Main Zone pit (DEIS Tier 2, Volume 2, Project Description and Assessment Basis, Section 5.4.6.2). A floor heave analysis was conducted and the analysis indicates that depressurization may be required beginning at a depth of 145m below ground surface for the Andrew Lake pit. The underdrain design for the Main Zone pit was discussed as part of the Tailings Management Facility design and is therefore not applicable to the Andrew Lake pit.



January 31, 2013

IR Number: CNSC 9

Request Preamble:

Reference:

NIRB 8.1.5 Permafrost and Ground Stability

Issue:

Tier 3, 5F Mine Rock Characterization and Management

Justification:

The Andrew Lake pit will penetrate permafrost during the mining and then be converted into a waste rock disposal pit and eventually be flooded. Permafrost at Andrew Lake will degrade during the mining, operation, and decommissioning phases which will impact the site hydrogeological conditions, with the corresponding potential to impact the environment.

Request:

Provide information on the thermal behaviour of the Andrew Lake pit during mining, operation and after decommissioning.

AREVA Response:

Although the thermal behaviour of the Andrew Lake pit has not been modeled, the thermal behaviour of the Kiggavik tailings management facility has been modeled in DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5J, Section 4. This analysis includes thermal behaviour both during operation and after decommissioning and also includes consideration of potential climate change. This data can be used to extrapolate the results for a pit filled with tailings to a pit filled with waste rock. In general, a pit filled with waste rock will warm more quickly with a change in climate since the heat capacity is lower than for the tailings material and less energy will be required to reach any given temperature. In addition, the thermal conductivity of the waste rock is higher than that of the tailings material, implying that temperatures will equilibriate more quickly. During the mining and operation of the Andrew Lake Pit for waste rock disposal, groundwater inflow to the pit is predicted to be low (DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5E) and filling of the pit is expected to take as long as 500 years under natural inflow conditions. As such, during the flooding period no water from the Andrew Lake pit will flow to the groundwater system, it will be contained within the pit. Thermal modeling of the Andrew Lake Pit will be conducted prior to licencing to ensure the performance of the facility and will address the degradation of permafrost during operation and decommissioning of the facility.



January 31, 2013

IR Number: CNSC 10

Request Preamble:

Reference:

Section 5.2.4, Failure of Slopes and Ground Control.

Issue:

Distinction needs to be made between prevention measures and construction activities.

Justification:

The wording in paragraph two is unclear; “ground control failures can be prevented by unanticipated poor ground conditions, improper blasting, proper backfill practices and proper rock bolting, screening and shotcreting.”

Request:

Please clarify this paragraph (Section 5.2.4, paragraph 2; see details in justification).

AREVA Response:

This is a typographical error. The sentence containing these words should read as follows: “These can be prevented by anticipating when poor ground conditions may be encountered and by adopting proper blasting, backfilling, rock bolting, screening, and shotcreting practices”.



January 31, 2013

IR Number: CNSC 11

Request Preamble:

Reference:

NIRB 8.1.8 Groundwater and Surface Water Quality

Issue:

Tier 2, Volume 5 ─ Groundwater and surface water quality and Tier 3, Volume 5B

Justification:

Deep groundwater quality was characterized with one groundwater sample and one duplicate of that sample from one borehole at the Kiggavik site. There is no additional sample(s) from other affected areas. A good consistency was achieved between the sample and repeat sample, and isotopic concentrations are consistent with literature. However, one could suggest that the complicated process involved to get a sample could make the sample results questionable. More samples may be needed to demonstrate sufficiency and consistency.

Request:

Justify the sufficiency of geochemical groundwater data. Describe how more samples will be collected to characterize the groundwater and demonstrate consistency.

AREVA Response:

AREVA agrees that additional analysis of the groundwater chemistry is required. The geochemical analysis of groundwater does not impact the viability of the Project at this phase of the assessment. Additional sampling will be completed to provide both baseline water chemistry data and to monitor changes to water chemistry. (See DEIS Tier 2, Volume 5, Aquatic Environment, Section 7.7).



January 31, 2013

IR Number: CNSC 12

Request Preamble:

Reference:

NIRB 9.3 Monitoring and mitigation plans

Issue:

Tier 3, Volume 5J

Justification:

Limited lab testing has been provided for prediction of long-term tailings pore water concentrations (some are still ongoing). The report indicates that further testing/verification will take place under the Tailings Optimization and Verification Program (TOVP); however little information about this program has been provided.

Request:

Describe the activities (lab, field etc) that will take place under the TOVP to verify source term predictions.

AREVA Response:

At AREVA’s McClean Lake Operation in northern Saskatchewan, the Tailings Optimization and Validation Program (TOVP) is an ongoing tailings monitoring and research program in effect for the duration of the project. Its purpose is to verify that key geotechnical and geochemical parameters that control constituent mass flux out of the TMF are being established during the operating period as forecast and to validate that long term predictions of environmental effects to the surface aquatic environment are consistent with what was initially assessed and approved. It is proposed that a similar program be established for the Kiggavik Project. To that end, a rigorous sampling campaign will be developed that will involve regular and systematic sampling of the tailings by drill core from a floating barge. The collected samples will be analyzed for a comprehensive suite of geochemical constituents (both in the pore water and in the solids) as well as for geotechnical parameters such as grains size, hydraulic conductivity and consolidation parameters. This analytical information will be interpreted, summarized and reported in the form of a TOVP Validation Report at regular intervals (for example, every five years for the McClean Lake Operation). Additional technical investigations will be conducted as deemed necessary to study areas of particular interest and to address uncertainties that may evolve. It is anticipated that a TOVP program document will be developed at the time of licensing which will detail the timing and scope of the program for application to the Kiggavik Project.



January 31, 2013

IR Number: CNSC 13

Request Preamble:

Reference:

NIRB 6.6.4.2 Tailings Management Facilities

Issue:

Tier 3, Volume 5J

Justification:

Estimated tailings pore water concentrations are based on (i) geochemical modelling and (ii) concentrations measured from neutralization testing. Controls related to solubility limits and solids (sorption etc) have been modelled, however no solids characterization work has been provided (or planned).

Request:

Provide results, including future plans, of solids characterization work that verify predictions about solids controls on pore water concentrations.

AREVA Response:

Data are available from tailings characterization analyses as well as laboratory tests on submerged tailings to simulate in-pit disposal. The results will be further interpretation and used to confirm the data and assumptions in the DEIS. In the future, solids geochemical characterization will fall under the tailings optimization and validation program (TOVP; see IR CNSC 12). Future tailings work will involve a program of regular sampling using a barge-mounted drill rig. Core samples of tailings will be collected and both the pore water and solids will be analyzed for a comprehensive suite of geochemical constituents. Solids controls on pore water concentrations is a matter of ongoing study in the current tailings program at AREVA’s McClean Lake Operation in northern Saskatchewan and, where necessary, to address uncertainties, work has been done using numerous geochemical techniques, by AREVA, at partner universities and by expert consultants. Over the life of the McClean Lake Operation tailings program techniques such as geochemical modeling, X-ray diffraction, micro-probe and numerous synchrotron techniques have been employed. AREVA anticipates that this type of program will be developed for the Kiggavik Project, where various geochemical techniques will be employed as needed, based on the initial results of the regular sampling. This type of sampling may be further discussed in the technical comments review and also, a TOVP document will be developed at the time of licensing which will detail the timing and scope of the program for application to the Kiggavik Project.



January 31, 2013

IR Number: CNSC 14

Request Preamble:

Reference:

NIRB 6.6.4.2 Tailings Management Facilities

Issue:

Tier 3, Volume 5J

Justification:

Monitoring of radon flux from the tailings management facilities was not included in this section.

Request:

Describe how radon flux from the tailings management area is predicted and will be measured during and after closure.

AREVA Response:

The potential radon flux from the tailings management area was included in the air dispersion modelling. The method used to estimate the emission rate is described in DEIS Tier 3, Volume 4, Part A, Air Quality and Climate, Appendix 4B (Attachment A, page A.1-17). This emission estimate was used within the CALPUFF air dispersion model. Monitoring of radon from the tailings management area will be conducted using radon monitoring devices, such as track etch cups, deployed at the perimeter of the area. Radon monitoring around the site, in proximity to sources of radon, is part of the regiment of routine monitoring that will be conducted at the mine site, and reported on regularly. Monitoring will continue into the post-closure period to demonstrate the efficacy of the decommissioning efforts.


Page 15 Responses to CNSCJanuary 31, 2013

IR Number: CNSC 15

Request Preamble:

Reference:

NIRB 8.1.7 Hydrology (including water quantity) and Hydrogeology

Issue:

Tier 2, Volume 5 ─ Aquatic Environment

Justification:

Hydraulic conductivity data from Neretnieks (1993) and Meadow Bank project data are plotted in figure 5.2–3 to complement hydraulic test results at the project areas. In order to do so, a description of the backgrounds of the quoted sources should be provided. For example, were all or some of the data in shallow grounds from permafrost or unfrozen rocks?

Request:

Provide background information on the hydraulic conductivity data from Neretnieks (1993) and Meadow Bank project data that were used to complement the hydraulic conductivity tests from the project area.

AREVA Response:

The Neretnieks data that were used as a background dataset are available in Figure 2 on the following page. The Meadowbank hydraulic conductivity data are available from the Golden Meadow Project EIS submitted by Cumberland Resources Ltd. The main point of the figure is to illustrate a decreasing trend in hydraulic conductivity with depth. The referenced data were not used for the assessment itself but rather as a way to indicate how Kiggavik data tended to fit a recognized trend. The pattern is as expected, and can be confirmed with other data sets collected in Canadian Shield rock.

Figure 2: Correlation Between Hydraulic Conductivity and Depth (Neretnieks, 1993)



January 31, 2013

IR Number: CNSC 16

Request Preamble:

Reference:


Issue:

Tier 3, Technical Appendix 5B, geology and hydrogeology baseline

Justification:

A better understanding of the hydrogeology is essential to the environmental assessment. The details are needed to evaluate the: appropriateness of the inferred hydraulic conductivity data, the groundwater flow and contaminant transport models.

Request:

Provide interpreted stratigraphic profiles across various sections, along with that of all of the geologic, geotechnical and hydrogeologic test boreholes.

AREVA Response:

Interpreted stratigraphic profiles across various sections are provided in DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5B, Figures 4.2-2 to 4.2-21.



January 31, 2013

IR Number: CNSC 17

Request Preamble:

Reference:


Issue:

Tier 3, Appendix 5D ─ Groundwater Flow Model

Justification:

The following is difficult to understand: “The base of the permafrost was created by mirroring the ground surface topography at the depth corresponding to observed permafrost depths.” Is the thickness of permafrost interpreted based on observed depths or delineated by mirroring/mimicking the ground surface topography?

Request:

Provide details on how the permafrost thickness is characterized. In particular, provide interpreted permafrost profiles across various sections, along with the profiles of all of the boreholes used to interpret the permafrost profiles.

AREVA Response:

The base of the permafrost was created by mirroring the ground surface topography to match permafrost depths observed in the multi-level thermistor strings (see locations in DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5D, Figures 2.3-1 to 2.3-3). It was generated using the 1m contour digital terrain map (DTM) produced from LiDAR data. The DTM was smoothed with a low pass filter, translated vertically and then rotated by 3 degrees dipping south. The rotation was conducted to match the observation of thicker permafrost at End Grid and thinner permafrost at Main Zone south. The figure on the following page shows the resulting permafrost surface in a cross-section along locations of thermistor strings and observed permafrost depths. This surface was used in the model as the base of the permafrost across the entire model domain.



January 31, 2013

IR Number: CNSC 18

Request Preamble:

Reference:


Issue:

Tier 3, Appendix 5D ─ Groundwater Flow Model

Justification:

There are huge uncertainties on the groundwater and contaminant transport modeling, due to the following facts: Only 11 hydraulic conductivity tests were conducted and 4 monitoring wells were actually used to calibrate the groundwater flow model which covers an area of 740 km2. The observation that “Historical and recent observations suggest that flowing artesian conditions exist under the permafrost in several areas at the Project site” is not taken into consideration in the model. This may have huge implication on inflow estimate and the performance of the tailings and waste rock management systems. In fact, the proponent had to further calibrate the model by reducing hydraulic conductivities of all units by 10 times in order to have a better fit of the observed hydraulic heads; even so, the calibrated hydraulic heads for 3 out of the 4 boreholes were still under estimated as shown in figure3.2–2. Higher pressure heads in the unfrozen zone under the permafrost may provide a better and more realistic modeling result. The assumption of hydraulic conductivity in the permafrost being 10–12 m/s needs to be further substantiated, considering the observation that: “One packer test was carried out in permafrost at Main Zone (MZ–08–03). This test resulted in a hydraulic conductivity value less than 1 x 10–9 m/s. Another test was also conducted in permafrost North of Main Zone (GW–11–01), resulting in a low hydraulic conductivity of 9 x 10-10 m/s.” (page 7–3, Appendix 5, Geology and Hydrogeology Baseline).

Request:

Provide additional data and/or a sensitivity analysis for the groundwater and contaminant modeling, especially on how the observed high hydraulic heads in the unfrozen zone under the permafrost would impact the inflow estimate and performance of the performance of the tailings and waste rock management systems.

AREVA Response:

AREVA acknowledges that the value of 10-12 m/s for the permafrost hydraulic conductivity is not directly supported by the two packer tests conducted. Packer testing conducted in permafrost tends to overestimate the hydraulic conductivity due to partial melting of permafrost near the borehole (DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5B, Section 7.2). Literature studies confirm that the hydraulic conductivity of frozen soil is several orders of magnitude smaller than unfrozen soil (Section 4.7). The use of a permafrost hydraulic conductivity value of 10-12 is considered reasonable. The artesian conditions under the permafrost are implicitly included in the numerical model at the calibration stage. AREVA acknowledges that the observed heads are underestimated by the numerical model. It is expected that additional calibration data will improve the model calibration. AREVA agrees that



January 31, 2013

additional calibration data for the groundwater flow model is desired. Additional hydrogeologic testing will be done as part of the monitoring and follow up programs (DEIS Tier 2, Volume 2, Project Description and Assessment Basis, Section 13.5, and DEIS Tier 2, Volume 5, Aquatic Environment, Section 14.2, and DEIS Tier 3, Volume 5, Aquatic Environment, Appendix 5M).



January 31, 2013

IR Number: CNSC 19

Request Preamble:

Reference:

Volume 1, Subsection 8.4.3. Species at Risk

Issue:

The section on Species at Risk does not indicate for marine species which are listed on Schedule 1 as Threatened, (i.e. Atlantic wolfish) and which are Special Concern (i.e. Spotted wolfish). The Recovery Strategy for the Atlantic wolfish identifies the need for monitoring the spatial and temporal abundance patterns of wolfish because of the paucity of information on their distribution. Moreover, as a possible threat to their survival, ocean pollution is listed.

Justification:

Although it is likely that the Regional Assessment Area is at the limit of the range of wolfish, any information on this species that can be gathered whilst conducting monitoring activities related to pollution control would be useful to the recovery strategy.

Request:

Please consider recording any sightings of wolfish as part of a monitoring and follow-up program in fulfillment of the SARA Recovery Strategy.

AREVA Response:

Marine Species at risk (including wolffish) are identified and addressed in DEIS Tier 2, Volume 7, Marine Environment, Section 4.3.1.2. It is uncertain whether the marine monitoring program is likely to result in incidental catches of wolffish species. The RAA is at the limit of their known range, which is why these species were not considered in the assessment; however, as discussed in Section 4.3.1.2, the Hudson Strait is designated as 'probable' range. AREVA will endeavour to record and reported to DFO any sightings or incidental catches of wolffish made during the marine monitoring program, in order to improve current understanding of their distribution, habitat use, and abundance within the RAA.



January 31, 2013

IR Number: CNSC 20

Request Preamble:

Reference:

Tier 3, Technical Appendix 4C, Air Monitoring Plan, Page 2-3

Issue:

Bullet on Waste Management discusses installation of incinerator.

Justification:

The emissions from the incinerator are presented partially in Air Dispersion Assessment and Atmospheric Environment but mention of the most important standards related to mercury and dioxins and furans as per the Canada-wide standards is not present.

Request:

CNSC staff requests the proponent provide all emissions from the proposed incinerator and identify how compliance with several requirements of operating an incinerator such as secondary combustion temperature, mercury and dioxins and furans Canada-wide standards, emissions of HCl, SO2, CO, oxygen, etc. will be ensured. HCl has been stated to be negligible without providing the number (Page 4–18 ─ Atmospheric Environment).

AREVA Response:

Within the DEIS Tier 3, Volume 4, Atmospheric Environment, Appendix 4B, Section 4.1.2.4, emissions from the incinerator that are assessed include particulate matter (TSP, PM10, PM2.5) and combustion products (e.g., NO2 and SO2). Other constituents of potential concern (COPCs) such as dioxins and furans as well as mercury are not included in the list of COPCs to assess in the Final NIRB Guidelines (Guidelines for the Preparation of an Environmental Impact Statement for AREVA Resources Inc.’s Kiggavik Project dated May 2011) and as a result, were not considered in the Air Dispersion Assessment. As outlined in DEIS Tier 2, Volume 2, Project Description and Assessment Basis, Section 14.2.1, the incinerator unit that will be purchased will be designed to meet CWS. This is also outlined in DEIS Tier 3, Volume 2, Project Description and Assessment Basis, Appendix 2S, the Waste Management Plan (WMP), which specifies that the incinerator will meet the CWS for dioxins and furans and mercury and will follow the Environment Canada Technical Document for Batch Waste Incineration to meet the CWS and comply with particular operating requirements such as secondary combustion temperature. Additionally, Appendix 2S illustrates that waste segregation will be achieved to help limit emissions from the incinerator. To demonstrate that CWS are met, the WMP indicates that emissions testing will be conducted periodically. In contrast to mercury and dioxins and furans, HCl was included in the list of COPCs to assess in the Final NIRB Guidelines; however, emissions were considered negligible since the type of waste (i.e., organics) to be incinerated will not contain chlorinated compounds. This will be achieved through proper waste segregation as outlined in Appendix 2S, Section 2.1.



January 31, 2013

IR Number: CNSC 21

Request Preamble:

Reference:

Tier 3, Technical Appendix 4B, Air Dispersion Assessment, page 2-7

Issue:

Constituents of Potential Concern

Justification:

No mention of volatile organic compounds and acrolein release.

Request:

CNSC staff requests the proponent to consider the emissions of volatile organic compounds as well as consideration of acrolein as a toxic compound release and satisfying the health risk assessment of acrolein. Alternatively, the proponent should provide the technical basis used to screen out these contaminants.

AREVA Response:

Within DEIS, Tier 3, Volume 4, Atmospheric Environment, Appendix 4B, Sections 4.1.2.1 and 4.1.2.3, combustion emissions (e.g., NO2 and SO2) from diesel vehicles/equipment and the power plant diesel generators are assessed. Constituents of potential concern (COPCs) such as total VOCs and acrolein from diesel combustion are not included in the list of COPCs to assess in the Final NIRB Guidelines (Guidelines for the Preparation of an Environmental Impact Statement for AREVA Resources Inc.’s Kiggavik Project dated May 2011) and as a result, were not considered in the Air Dispersion Assessment. However, to demonstrate that acrolein meets applicable air quality criteria, an additional screening level assessment of acrolein emissions from diesel combustion was carried out as part of the response to the CNSC’s information request (IR CNSC 21). Since there is no criterion or standard to which model-predicted total VOC concentrations can be compared to, it was excluded from the screening level assessment. This assessment is described below. During the design phase of the Project, several small air dispersion modelling assessments were completed help optimize the location of the Kiggavik mine site’s power plant relative to the Accommodation Complex. This was mentioned within DEIS Tier 2, Volume 4, Atmospheric Environment, Part A, Air Quality, Section 6.1.3. Such assessments involved modelling the power plant independently from all other sources of NOx to examine the impact of diesel power plant emissions at the Accommodation Complex. The results of these assessments showed that the Kiggavik power plant is the source which dominates NO2 concentrations at the Accommodation Complex. In addition, the Accommodation Complex is also the sensitive point of reception having the largest predicted concentration of NO2 during operations (see DEIS Tier 3, Volume 4, Atmospheric Environment, Appendix 4B, Table 6 10). As a result, it is considered appropriate to only examine the impact of acrolein emissions from the Kiggavik power plant at the Accommodation Complex for the purposes of a screening level assessment. Using the results of the final power plant assessment (memorandum to Frederic Guerin [AREVA] and Nicola Banton [AREVA] from S. Music, B. Halbert and H. Phillips, dated February 7, 2011), which has the same source configuration that was used in the final Air Dispersion Assessment, a dispersion factor for the Accommodation Complex receptor (in µg/m³ resulting



January 31, 2013

concentration per g/s emitted) was calculated and applied to emissions of acrolein to predict 1- and 24-hour concentrations of acrolein at this location. The acrolein emission rate from the Kiggavik power plant was estimated using the emission factor from US EPA AP-42 Compilation of Emission Factors (US EPA, AP-42 Compilation of Air Pollutant Emission Factors, Chapter 3.4) along with the average diesel fuel input to the generators which was based on an annual energy output of 155,000,000 kWh. The resulting acrolein emission rate from the Kiggavik power plant is 5.99E-05 g/s. The results of the screening level assessment are outlined in the table below. Calculated concentrations are compared against 2012 Ontario Ambient Air Quality Criteria, which are based on health as the limiting effect. As can be seen in the table, acrolein concentrations are well below the applicable criteria. Even if all other diesel sources were added, their emissions would have to contribute 99.9 percent (or 3.998E-01 µg/m³) to the 24-hour power plant acrolein concentration to reach the 24 hour acrolein criterion. As previously mentioned, prior assessments indicate that the contribution to NO2 concentrations at the Accommodation Complex is dominated by the power plant; therefore, by the same logic, it is not likely that all other diesel sources would dominate and exceed the acrolein concentrations resulting from the power plant. Even by assuming that the contribution from all other diesel sources is equal to the power plant’s contribution (i.e., by doubling the power plant’s acrolein concentrations), the total concentrations of acrolein would still be well below its criteria at the Accommodation Complex.

Table CNSC 21-1 (New) Calculated Dispersion Factors and Resulting Acrolein Concentrations at the Accommodation Complex

Receptor

Easting

UTM

(m)

Northing

UTM

(m)

Dispersion Factor*

(µg/m³ per g/s) Acrolein (µg/m³)

Max 1-hr

Max 24-hr Annual Max

1-hr Max 24-hr Annual

Accommodation Complex 564900 714843

3 1.1E+0

1 3.6E+0

0 1.9E-01 6.4E-04 2.2E-04 1.1E-05

AAQC (µg/m³) n/a n/a n/a 4.5 0.4 n/a

Notes:

n/a = not applicable

*dispersion factor calculated based on a NOx emission rate of 63.2 g/s from the Kiggavik Power Plant



January 31, 2013

IR Number: CNSC 22

Request Preamble:

Reference:

Tier 2, Volume 8, Human Health. Section 4, page 4–1.

Issue:

Baseline radiological conditions

Justification:

Section 8.2.13.1, Baseline Information requires a discussion on current baseline exposure to radiation. The report provides generic Canadian information on background radiation and also includes more specific information for the project area due to consumption of caribou.

Request:

Please provide available baseline background radiation information specific to the project or study area (this would be in addition to the specific information already provided related to the consumption of caribou).

AREVA Response:

Groundshine Terrestrial gamma radiation (groundshine) exposure rates in the Kivalliq region are presented in Figure 4.1-2 (New-IR) on the following pages, as extracted from Natural Resources Canada data (Carson, 2001). Spectral surveys provide estimates of uranium and thorium concentrations in surficial soils, as well as measures of absorbed dose rates. In the local assessment area, background gamma radiation exposure rates averaged 46 nGy/h and ranged to 92 nGy/h. Figure 4.1-3 (New-IR; on the following pages) presents gamma radiation exposure rates with Kiggavik lease boundaries indicated. Similarly, preliminary gamma radiation surveys conducted over the proposed mill terrace averaged 56 nGy/h and range to 129 nGy/h, while pre-drilling background gamma radiation levels at drill pad locations were observed to average 53 nGy/h and ranged to 656 nGy/h (AREVA 2011, AREVA 2012). In the predictions of external gamma radiation exposures, the groundshine model, discussed in DEIS Tier 3, Volume 8, Human Health, Appendix 8A, uses radionuclide concentrations in the soil layers that are calculated in the soil model. The groundshine model accounts for self-shielding by overlying soil layers and the loss of gamma ray flux via radon emanation and subsequent exhalation to the atmosphere. Using this method, prediction of incremental radiation exposure is not dependent on baseline radiation exposure conditions. Internal Radiation Specialized alpha dosimeters were deployed at the Kiggavik and Sissons sites and in the community of Baker Lake for integrated measurements of alpha emissions of short-lived progeny of radon-222 and radon-220, as well as long-lived radioactive decay products of uranium. Data from these monitors deployed from 2008 through 2011 are provided in Table CNSC 22-1 (New) below.



January 31, 2013

Radon monitors were deployed at several locations at the Kiggavik and Sissons sites to determine both average annual radon concentrations, and average summer-season concentrations. In 2010, radon results for the summer-season track etch cups ranged between a lower limit of detection (LLD) of 14.8 Bq/m³ and 55.5 Bq/m³ with an average of 22.2 Bq/m³ (AREVA 2011). Similarly, in 2011, radon results for the summer-season track etch cups ranged between and LLD of 22.2 Bq/m³ and 48.1 Bq/m³ with an average of 24.3 Bq/m³. The results for the annual track etch cups deployed in July 2010 and retrieved in June 2011 ranged between an LLD of 3.7 Bq/m³ and 29.3 Bq/m³ (AREVA 2012). The track etch cup locations are shown in Figure 4.1-4 (New-IR) on the following pages. Sources:

Carson, J.M., Holman, P.B., Ford, K.L., Grant, J.A., and Shives, R.B.K., Airborne Gamma Ray Spectroscopy Compilation Series, Thelon River, Nunavut-Northwest Territories,; Geological Survey of Canada, Open File 4119. 2001. AREVA Resources Canada Ltd., Kiggavik Project Field Program, 2011 Annual Report, January 2012. AREVA Resources Canada Ltd., Kiggavik Project Field Program, 2010 Annual Report, January 2011.



January 31, 2013

Table CNSC 22-1 (New) Summary of Baseline Environmental Alpha Dosimeter Data

BAKER LAKE

2008 2009 2010 2011

EAPRn222

4 5 ND 3 Unit : nJ.m

-3

EAPRn220

5 6 ND 3 Unit : nJ.m

-3

LLRD 0.2 0.3 ND 0.2

Unit : < mBq.m-3

KIGGAVIK

EAPRn222 6 6 8.5 ND

Unit : nJ.m-3

EAPRn220 5 7 9 ND

Unit : nJ.m-3

LLRD 0.3 0.3 0.3 ND

Unit : < mBq.m-3

SISSONS

EAPRn222 6 6 12 5

Unit : nJ.m-3

EAPRn220 5 6 11 4

Unit : nJ.m-3

LLRD 0.3 0.2 0.45 0.2

Unit : < mBq.m-3



January 31, 2013

IR Number: CNSC 23

Request Preamble:

Reference:

Tier 2, Volume 8, Human Health. General.

Issue:

Equivalent dose ─ base case and effects

Justification:

Section 8.2.13.2 Impact Assessment requires predicted radiation exposures to workers and the public during all phases of the project. The CNSC sets dose limits for effective dose as well as equivalent dose. There is no mention of equivalent dose to the skin or extremities.

Request:

Please provide baseline and effects data related to worker exposures with regards to equivalent dose. Alternatively, please justify its omission.

AREVA Response:

Prediction of equivalent doses has been omitted because external radiation fields will result in uniform gamma radiation fields. Non-uniform exposures necessitating a determination of equivalent dose to the lens of the eye, skin, or extremities are not anticipated to occur in the mining or milling environment. Experience in mining has shown that workers monitored using dosimeters measuring deep, shallow and beta doses receive uniform doses. Further, workers are adequately protected from skin and eye doses through the use of standard personal protective equipment such as coveralls, gloves, and safety glasses. All doses are presented in terms of effective dose.



January 31, 2013

IR Number: CNSC 24

Request Preamble:

Reference:

Tier 2, Volume 8, Human Health. Section 6.4.2, page 618

Issue:

Absence of consideration of radon exposure during construction phase

Justification:

Section 8.2.13.2 Impact Assessment requires predicted radiation exposures to workers and the public during all phases of the project. The possibility of increased exposures to radon during the construction phase has not been considered.

Request:

Please provide information to support the assumption that workers will not be exposed to incremental radon levels during the construction phase.

AREVA Response:

Radioactive materials are not encountered until the mining phase, after site preparation is completed. Radon exposures during the construction phase are anticipated to be no different than any other construction project. Radon exposure of construction workers would be a small fraction of the exposures predicted for the mining crew and would resemble the non-NEW site worker evaluated in the study. Radon monitoring has taken place throughout the exploration phase with results similar to the non-NEW site worker. Radon monitoring during site construction activities would be conducted to confirm radon levels.



January 31, 2013

IR Number: CNSC 25

Request Preamble:

Reference:

Attachment A, Kiggavik Project Risk Assessment Result.

Issue:

Absence of consideration of all effects involving the transportation of yellowcake.

Justification:

If an aircraft transporting yellowcake incurred an incident or crash, there would be moderate radiological exposure consequences and major environmental consequences based on AREVA’s rating system. However, the detrimental effects resulting from such an incident involving the transportation of yellowcake are not only severe for the environment, but equally severe radiologically. In the event of yellowcake dispersion, plants and local animals could potentially be directly affected, and humans have the potential to be both directly and indirectly impacted.

Request:

Please re-assess the radiological consequence rating.

AREVA Response:

The methodology described in DEIS Tier 2, Volume 10, Accidents and Malfunctions, Section 3 has been applied consistently in the ranking of risk involving the transportation of uranium concentrates. The criteria for assessing both consequence and likelihood provide reasonable categorization for evaluating risk. The purpose of evaluating risk is to ensure that proper preventative, protective, and mitigative measures are in place in the event of an accident or malfunction. AREVA acknowledges the importance of implementing effective preventative and emergency preparedness measures to the transportation of the uranium concentrates product, and has described these measures within the assessments and management plans. The evaluation has considered the information provided in the DEIS Tier 3, Volume 10, Accidents and Malfunctions, Appendix 10A, and that the activity would only be conducted with an acceptable Emergency Response Assistance Plan, in developing its consequence rating.



January 31, 2013

IR Number: CNSC 26

Request Preamble:

Reference:

TRANSBOUNDARY 2.1 NIRB’S IMPACT REVIEW PRINCIPLES The well-being of residents of Canada outside the Nunavut Settlement Area must be taken into account

Issue:

Tier 1, Volume 1, Section 8.8 Page 147 Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit, Part 1 ─ Public Engagement

Justification:

Transboundary communities clearly have concerns about the Kiggavik Project, notably on caribou and their migrations. Tier 1, Volume 1, section 8.8, summary information appears under the headings:

Terrestrial Transboundary Effects Marine Transboundary Effects

The Terrestrial Transboundary Effects paragraph states that: “Considering that neither the Project nor cumulative effects to caribou are significant, no significant adverse transboundary effects are predicted for caribou.” There is a gap in AREVA acknowledging the concerns of transboundary communities and then concluding that there will not be any significant cumulative effects or significant adverse transboundary effects predicted for caribou. Transboundary communities will want to understand how AREVA’s analysis led to this conclusion.

Request:

Please explain the criteria that AREVA used to arrive at the following conclusion: a) "Considering that neither the Project nor cumulative effects to caribou are significant, no

significant adverse transboundary effects are predicted for caribou." b) “…effects are not expected to result in significant adverse effects on marine populations

or their habitat that occurs in adjacent transboundary waters of Hudson Bay and Hudson Straight.”

AREVA Response:

DEIS Addendum, Section 7.2 provides the definition used for transboundary, the mechanisms that transboundary effects may occur and potential transboundary effects for the terrestrial, marine and human environments. Section 7.2.2 states:

“Transboundary effects can potentially occur through two different mechanisms: Project activities or project effects extend across a territorial, provincial or

international boundary. This might include effects such as air emissions, noise emissions; or changes in surface water quality; or



Where terrestrial or marine biota migrate across a jurisdictional boundary, residual environmental effects from a project on that species or group of species may interact with environmental effects from projects or activities in another jurisdiction or vice versa.

A – No Project activities or project effects extend across a jurisdictional border so no potential transboundary effects could be realized through that mechanism. The second mechanism for transboundary effects would require residual environmental effects on a species or group of species that migrate across a jurisdictional boundary. The assessment demonstrates no significant residual effects on any species. See DEIS Addendum Section 7.2.3 for discussion on the potential for transboundary effects on the terrestrial environment. B – Please refer to DEIS Addendum, Section 7.2.5 for additional discussion of the criteria used to conclude that transboundary effects on marine populations and their habitat are not expected to be significant.



January 31, 2013

IR Number: CNSC 27

Request Preamble:

Reference:

TRANSBOUNDARY Wildlife

Issue:

Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit. 4.3.5 ─ Birds and Egg Harvesting

Justification:

Section 4.3.5, an elder notes that: “Grain-fed ducks returning from Manitoba are hunted…,” which indicates that there is a cross boundary movement of birds.

Request:

Please identify the migratory species that were considered in the EIS, and what impact the Kiggavik project might have on these, in particular on the Manitoba ducks. Please state if any impacts have the potential to contravene the Migratory Birds Convention Act (MBCA).

AREVA Response:

The following is an excerpt from the DEIS Tier 2, Volume 6, Terrestrial Environment, Section 11.6.2, Page 11-12:

Migratory birds are represented by the indicator species lapland longspur (Calcarius lapponicus) and long-tailed duck (Clangula hyemalis). Lapland Longspur was selected as an indicator because of its known abundance in many upland habitats in the study areas. Lapland longspurs are found within the Project footprint and in portions of the RAA. Long-tailed duck is representative of migratory bird use of waterbodies in the study area. This species is commonly observed throughout the study areas foraging in wetlands, and nesting in areas adjacent to wetlands. Both species are readily recognized by local land users, and there is some traditional knowledge of habitats and potential effects of human disturbance.

As stated, the Manitoba ducks are represented by the long-tailed duck. The potential environmental effects on these species were identified in the DEIS Tier 2, Volume 6, Table 11.6-1 (see shaded areas in table below):



January 31, 2013

Table 11.6-1 Measurable Parameters for Terrestrial Wildlife

Wildlife and Bird VEC

Indicator

Environmental Effect

Measurable Parameters

Rationale

Terrestrial Wildlife and Habitat (cont’d)

Muskox (cont’d) Change in health Radionuclide and metal content in tissues

Dust deposition on vegetation could expose herbivores to increased metals

Raptors and Habitat Peregrine Falcon*

Change in habitat availability

Area (km²) of potential nest habitat

There may be limited cliff nesting habitat potential in the Regional Assessment Area

Reduced chick survival Nest Site Productivity

Sensory disturbance near nest sites may affect nesting success.

Change in health Radionuclide and metal content in tissues

Transfer through the food chain

Migratory Birds and Habitat

Lapland Longspur


Area (km²) of habitat by suitability class

Direct and indirect loss of breeding habitat from footprint and sensory disturbance.

Change in health Metal content in tissues

Uptake of contaminants resulting from emissions from the Kiggavik site

Long-tailed Duck





Emissions from the water treatment plant and subsequent bioaccumulation in the aquatic food chain

Species at Risk

Short-eared Owl






Wolverine Change in health Radionuclide and metal content in tissues


Grizzly Bear Change in health Radionuclide and metal content in tissues


Construction activities (i.e., site clearing and pad construction) have the potential to take place when migratory birds are breeding. AREVA will consult with Environment Canada regarding appropriate mitigation strategies and monitoring prior to construction activities commencing to prevent any contravention with the Migratory Birds Convention Act. Mitigation and monitoring strategies identified during this consultation process will be incorporated into the Wildlife Mitigation and Monitoring Plan.



January 31, 2013

IR Number: CNSC 28

Request Preamble:

Reference:

OUTSTANDING QUESTIONS FROM KIVALLIQ COMMUNITIES 2.2 PUBLIC PARTICIPATION AND ENGAGEMENT Another objective of the NIRB Review process is to involve potentially affected Nunavummiut to address concerns regarding any changes that the Project may cause in the environment and the resulting effects of any such changes on the traditional and contemporary use of land/ice and resources. The Proponent must ensure that Nunavummiut have the information that they require in respect to the Project and on how the Project may impact them.

Issue:

Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit.

Justification:

In a number of the interviews with the seven Kivalliq communities, interview participants requested additional or follow up information from AREVA and/or the researchers. The DEIS noted a number of outstanding questions from communities in Tier 2, Volume 3 (Public Engagement and Inuit Qaujimajatuqangit, PART 2)

Request:

Please explain how AREVA has responded to the following outstanding concerns and requests from Kivalliq communities. At community meetings with Baker Lake HTO reps in 2011, AREVA agreed to schedule a future meeting to discuss fish habitat consultation with consultants and DFO – Did this meeting happen and if yes, what was the outcome? If not, why not? (4–9). What is the status of AREVA’s meeting with Baker Lake’s HTO to discuss the management of the Kiggavik road? (4–13). HTO representatives requested to be notified when reports about their Inuit Qaujimajatuqangit (IQ) meetings have been prepared. Has this been done? (4–13). Rankin Inlet focus groups requested that the DEIS consider marine currents, wind and water as part of the impact assessment for the project. (4–14). Where in the DEIS does this discussion occur? What is AREVA’s consultation status with Chesterfield Inlet HTO over marine concerns? (4–6). Rankin Inlet focus groups feel that AREVA hasn’t answered questions about the effects of uranium on the local population’s health and safety. How has AREVA followed up with the information that they seek? (4–15). A Whale Cove resident is concerned that caribou downwind from the Kiggavik mine could get diseases from contaminated blowing dust and that lichen could also become contaminated. Where in the DEIS have these concerns been addressed and has the information been relayed



to the community by AREVA to Whale Cove? (4–27). Repulse Bay residents have said that they continue to give IQ information without getting anything back. Please explain what may have prompted this comment. (4–37). Where in the DEIS does it explain what will happen to the garbage generated by the Kiggavik project, and has this info been passed along to interested communities? (5–1).

AREVA Response:

A and B – On October 27, 2010, AREVA met with the Baker Lake HTO regarding a series of topics that AREVA wished to discuss with the HTO including fish habitat compensation, road management and decommissioning (DEIS Tier 2, Volume 3, Public Engagement and Inuit Qaujimajatuqangit, Part 1, Public Engagement, Section 3.4.3, Table 3.4-3). This meeting was preceded by a letter on the same topics. In February 2011, the Baker Lake HTO held a workshop focused on road options and submitted a report in March of 2011 at the NIRB Guidelines Workshop in Baker Lake. In August 2011, AREVA wrote to the Baker Lake HTO requesting a special meeting on Road Management. An all-day meeting was held with AREVA and the Baker Lake HTO on November 2, 2011 on road management. A meeting on fish habitat has not yet taken place but AREVA plans to host a meeting when the schedules for AREVA, consultants, DFO and the Baker Lake HTO can accommodate. C – Baker Lake HTO attended an IQ validation meeting on February 16, 2011. At this meeting, they provided final comments on the IQ data gathered and they requested they be notified when the IQ reports were prepared. The reports are part of the DEIS submission. D – Marine currents were discussed in DEIS Tier 2, Volume 5, Marine Environment, Section 6.2.2.3.4. The largest effect of currents are the tidal currents at Chesterfield Narrows. Wind is discussed in DEIS Tier 3, Volume 4, Atmospheric Environment, Part A, Air Quality and Climate, Appendix 4B, Section 5. Water is discussed in Appendix 4Bas well as DEIS Tier 2, Volume 5, Aquatic Environment, Section 4. E – The latest meeting AREVA held with the Chesterfield Inlet HTO that included marine concerns was November 3, 2012. This meeting focused on the assessment of marine effects as presented in the DEIS. AREVA has met with the Chesterfield Inlet HTO on six occasions beginning on April 1, 2008 (DEIS Tier 2, Volume 3, Public Engagement and IQ, Part 1, Public Engagement, Table 3.4-4). Marine concerns were discussed at each of these meetings. F – Based on community input requesting information about the effects of uranium, the 2010 and 2012 tours of Kivalliq communities included presentations and information on the uses of uranium and radiation protection. This included bringing specialists on the topic, adding slides to the PowerPoint presentation, posters and a demonstration. Posts on the topic have also been placed on the Kiggavik blog. G – The potential effects on caribou and lichen from contaminated dust are discussed in DEIS Tier 2, Volume 6, Terrestrial Environment, Sections 9 and Section 13. Summaries of the DEIS were presented in the community of Whale Cove by NIRB on May 25, 2012 and by AREVA on November 10, 2012 H – AREVA considers comments received during engagement events to design future engagement events through lessons learned, incorporating feedback received and respecting



preferences for communication. Feedback to date suggests that most participants are pleased their questions have been answered. AREVA does not know what prompted the comment from Repulse Bay. At least 16 engagement events have been held in Repulse Bay regarding the Kiggavik Project since 2007, ten of these events hosted by AREVA (DEIS Tier 2, Volume 3, Public Engagement and IQ, Part 1, Public Engagement, Tables 3.4-9 and 3.5-1). There are many possible reasons for the comment and AREVA is unable to identify a particular reason. IQ interviews and IQ validation meetings were hosted in Repulse Bay as presented in DEIS Tier 2, Volume 3, Part 2, IQ. I – DEIS Tier 3, Volume 2, Project Description and Assessment Basis, Appendix 2S describes what will happen to garbage onsite. Section 2.1-1 describes domestic waste. This was sent to Hamlets and HTO's as part of the DEIS DVD but it has not been specifically highlighted to communities.



January 31, 2013

IR Number: CNSC 29

Request Preamble:

Reference:

METHODOLOGIES 2.2 PUBLIC PARTICIPATION AND ENGAGEMENT The Proponent must provide the highlights of any public engagement within the EIS, including the methods used, the results, and the ways in which the Proponent intends to address the concerns identified.

Issue:

Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit. Section 3

Justification:

Field studies and Focus groups were some of the key methods of collecting specific information from the seven Kivalliq communities. The information collected was used to develop socio-economic and traditional knowledge baseline studies and monitoring programs, etc. More information on methodology used to collect information for the studies would have provided a more thorough context for the questions that were asked.

Request:

1) When interviewing subjects about changes in caribou migration patterns, was there a specific time frame (e.g. 10 years, 30 years…) over which they were supposed to describe changes? 2) When counting interview participants, how was one person accounted for if they fit into more than one category of person (e.g. could an Elder also be a member of an HTO and be counted twice)? 3) Were interview participants always able to communicate in their language of choice?

AREVA Response:

1 – Questions about caribou migration patterns during the IQ interviews did not specify a timeframe to describe changes. Information collected during the IQ interviews is presented in DEIS Tier 2, Volume 3, Public Engagement and Inuit Qaujimajatuqangit, Part 2, IQ as well as Appendix 3B, Inuit Qaujimajatuqangit Documentation reports. 2 – When interview participants were counted (e.g., DEIS Tier 3, Volume 3, Public Engagement and IQ, Appendix 3B, Table II.2.4-1, Page 2-7), the participants in the specific group interviewed were listed. A person could only be counted twice by attending two meetings. An elder who was a member of the HTO could attend two meetings and provide input twice. 3 – Interview participants were always able to communicate in either English or Inuktitut during IQ interviews.



January 31, 2013

IR Number: CNSC 30

Request Preamble:

Reference:

6.0 PROJECT COMPONENTS AND ACTIVITIES 6.1 PROJECT DESIGN General Project design issues discussed in the DEIS shall include: How public consultation and, have influenced the planning and design of the Project.

Issue:

6.1.1 ─ Summary of Project-Related Questions and Concerns. Page 73 Environmental Effects Assessment Section 6 ─ Inuit Qaujimajatuqangit Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit Part 1 ─ Public Engagement Page i.

Justification:

“During interviews and focus group discussions, participants identified a variety of issues and concerns related to the Project. These generally related to the following :a potential bridge over the Thelon River, potential effects of the proposed access road on caribou, potential contamination of lakes, vegetation, wildlife, and people, potential effects of increased marine transportation on marine wildlife, potential effects of Project wage employment on traditional activities, recommendations for monitoring by Elders”

Request:

Can AREVA please provide some specific examples of how Traditional Knowledge/IQ has influenced the planning and design of the Kiggavik Project?

AREVA Response:

DEIS Tier 2, Volume 2, Project Description and Assessment Basis, Section 4.2 provides examples of how engagement and IQ have influenced Project design, including the removal of the south all-season road alternative due to community concerns and the shallow depth of water at the south shore of Baker Lake and the inclusion of Elder advisors at the mine site. Further project design influences can be referenced in the below sections. 4.2.1 Mining in the Arctic 4.2.2 Climate Change and the Project 4.2.3 Uranium Concentrate 4.2.4 Tailings and Mine Rock 4.2.5 Transportation 4.2.6 Health and Safety 4.2.7 Decommissioning 4.2.8 Employment and Benefits A description of the more broad integration and consideration of IQ throughout the DEIS is illustrated in a new figure, Figure 5.1-A on the following page. This figure will be included in the FEIS Tier 2, Volume 3, Public Engagement and Inuit Qaujimajatuqangit, Parts 1 and 2. Refer to DEIS Tier 2, Volume 3, Public Engagement and IQ, Part 1, Public Engagement, Section 5,



January 31, 2013

Table 5.2-1 for additional examples of engagement and IQ integration. The influence of Inuit Qaujimajatuqangit on each discipline assessment is included in the DEIS Tier 2, Volumes 4 through 10, Section 4 Scope of the Assessment under the headings 'Issues and Concerns Identified during Inuit, Government and Stakeholder Engagement', 'Influence of Inuit and Stakeholder Engagement on the Assessment' and 'Influence of Inuit Qaujimajatuqangit on the Assessment'.

Figure 5.1-A: Incorporation of Inuit Qaujimajatuqangit and engagement data into the DEIS

IQ and engagement helped to focus and prioritize baseline

data collection

• Establishing local study areas • Location of known heritage

resources, areas used by humans and animals, patterns of animal movement

• Local people assisted with baseline data collection

Baseline data collection

IQ and engagement helped to identify key issues

• Selection and validation of valued ecosystem and socio-economic components

• Undertaking additional studies based on community feedback

• Concern about environmental degradation, impacts to wildlife, dust, protecting culture

• Opportunities for jobs and training

Identification of issues and

concerns

IQ and engagement feedback influenced project design

• Removed south all-season road option

• Removed dock options on south shore of Baker Lake

• Fly yellowcake off-site rather than ship through Baker Lake

Project design

Assessment addressed key issues identified during IQ

and engagement

• Focused the assessment on biophysical and socioeconomic environments of concern

• Over-estimated potential effects to be conservative and increase confidence and certainty in the assessment

• Conducted comprehensive human health and ecological risk assessments (Appendix 8A)

Effects assessment

Informing future development of

monitoring programs, adaptive management,

communications plan

• Develop wildlife and marine monitoring programs with hunter and trapper organizations

• Contribute to Government of Nunavut’s caribou collaring program

• Continue with information sharing and engagement

Mitigation and Monitoring

Environmental assessment process

How Inuit Qaujimajatuqangit (IQ) and engagement influenced assessment

Examples of how IQ and engagement influenced assessment



January 31, 2013

IR Number: CNSC 31

Request Preamble:

Reference:

7.0 IMPACT ASSESSMENT METHODOLOGY 7.1 PUBLIC CONSULTATION The Proponent shall also describe how communication was facilitated with the public through accommodating regional languages/dialects; not only through translation but through live translation/interpretation at community/public meetings. The Proponent is required to: Continue to provide up-to-date information describing the Project to the public, particularly residents of communities likely to be most affected by the Project; Involve the public in determining how best to deliver that information, i.e., the types of information required, translation and interpreting needs, different formats, the possible need for community meetings; etc.

Issue:

Tier 1, Volume 1, ─ Popular Summary Tier 2 Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit, Part 1 ─ Public Engagement Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit, Part 2 ─ Inuit Qaujimajatuqangit

Justification:

Overall AREVA has demonstrated a willingness to ensure that communities are able to share and receive project-related information, as necessary.

Request:

Were there any instances where it was not possible to provide a translator? If yes, please explain what follow-up was done to ensure that the community has had the opportunity to give or receive the pertinent information.

AREVA Response:

Interpreters (usually two) including one that travels from community to community with the AREVA group have been present at all community open houses hosted by AREVA. A translator is routinely present at Community Liaison Committee (CLC) meetings. At meetings of Hamlet Councils, HTO's and other groups, interpreters are sometimes provided by AREVA and sometimes by the group hosting the meeting. There have been occasions where an interpreter was not available. When this has occurred for a CLC meeting, a bilingual AREVA employee or one of the many bilingual members of the committee have interpreted.



January 31, 2013

IR Number: CNSC 32

Request Preamble:

Reference:

7.2 TRADITIONAL KNOWLEDGE (TK) The Proponent shall, with reference to section 2.3, present and justify its definition of traditional knowledge and shall explain the methodology used to collect TK. Associated issues related to the storage and ownership related to TK.

Issue:

Tier 1, Volume 1 ─ Main Document and Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit.

Justification:

Page 70, AREVA DEIS uses the NIRB’s definition of Inuit Qaujimajatuqangit (IQ): “The Nunavut Impact Review Board (NIRB) defines IQ as follows: [Traditional Knowledge is the] [c]umulative body of knowledge, practice and belief, evolving by adaptive processes and handed down through generations by cultural transmission... and respect and care for the land, animals and the environment (NIRB 2007).”

Request:

a) Please describe how AREVA or its researchers defined and collected ─ Traditional Knowledge ─ from participants outside of the Nunavut Study Area, as specified in section 7.2 of the NIRB Guidelines.

b) At least one community expressed a strong interest in having their TK/IQ sent to Nunavut Tungavik (NTI) for storage. What has AREVA done to arrange this transfer?

c) When IQ was at odds with established scientific practices or policies ─ i.e. status of wildlife counts; number of polar bear tags issued ─, how did AREVA reconcile these information discrepancies?

AREVA Response:

A – DEIS Tier 2, Volume 3, Public Engagement and Inuit Qaujimajatuqangit, Part 2, IQ, Section 3.2 lists the seven Kivalliq communities for the collection of IQ. The focus of IQ for the writing of the DEIS remained within the Kivalliq Region where potential marine and caribou migrations were assessed for potential effects. Given that the caribou assessment did not predict significant residual effects to any caribou herd, the IQ/TK study area did not extend to annual herd range communities outside the Nunavut Settlement Area. AREVA has not hosted any traditional knowledge specific workshops in communities outside the Nunavut Settlement Area to date. Traditional knowledge studies with these communities will be determined on future engagement to better define interests and concerns and therefore the need and focus of any traditional knowledge studies. If conducted, the studies would likely vary according to community interest, preference and protocol. Engagement outside of the Nunavut Settlement Area is presented in the DEIS Tier 2, Volume 3, Public Engagement and IQ, Part 1, Public Engagement, Section 3.4.11 and DEIS Tier 3, Volume 3, Public Engagement and IQ, Part 1, Public Engagement, Appendix 3A, Part 6. These sections detail communication with BQCMB, Fond du Lac, SK, Black Lake, SK, Wollaston Lake,



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SK and Lutsel K'e Dene First Nation, NWT. All ongoing engagement with the communities with a stated interest will be recorded and presented in the FEIS. Please also see the response to IR BQCMB 2.1. B – AREVA has contacted the KIA and NTI regarding transfer of IQ. Upon completion of the FEIS, IQ data gathered as part of the Kiggavik Project will be transferred to NTI and/or KIA for storage. C – Reference to possible discrepancies in polar bear information is mentioned in the Marine Environment Baseline Report (DEIS Tier 3, Volume 7, Marine Environment, Appendix 7A, Section 8.1.3), IQ data suggests that polar bear numbers are increasing in the Chesterfield Inlet area; however, the most recent estimate of the Western Hudson Bay sub-population (as reported by COSEWIC) indicates that overall abundance has declined from approximately 1,294 in 1987 to 935 in 2004. This particular example of a discrepancy is not further addressed in the Tier 2 Volume 7 Marine Environment assessment given that there are no Project-Polar Bear interactions with open water shipping not overlapping with seasonal polar bear habitat (Section 6.1). Please see responses to IR CNSC 30 and IR Makita 2 for information on the integration of IQ and presentation of discrepancies and/or variations in knowledge shared with AREVA.



January 31, 2013

IR Number: CNSC 33

Request Preamble:

Reference:

7.6 VALUED ECOSYSTEM AND SOCIO-ECONOMIC COMPONENTS The Proponent shall provide a rationale for the selection of communities and relevant studies for which baseline data are provided. The Proponent shall describe the interactions between the biophysical and socio-economic environments. If components identified in these Guidelines are not included in the EIS, the Proponent must clearly discuss its rationale for the omission.

Issue:

Tier 2, Volume 3 ─ Public Engagement and IQ Section 3 ─ Approach, Methods, & Efforts

Justification:

3.3.2 Potentially Affected Communities The Guidelines for the Kiggavik Project (NIRB 2011) define a potentially affected community as “A community or communities with the potential to be impacted, either positively or negatively, by a proposed project or development.” In this context AREVA has identified the following categories of potentially affected communities. Category 1 and 2 communities have ties to the project area and/or will experience project activities in or near their community. Category 3 communities are Kivalliq communities located in Hudson Bay that may have potential interest in the Project due to shipping through Hudson Bay but also for employment and business opportunities. Category 4 communities are communities outside the Nunavut Settlement Area that have declared interest in the Project with concerns over Aboriginal rights.

Request:

What sort of studies have been contemplated for Category 4 communities ─ Black Lake, SK; Fond du Lac, SK; Hatchet Lake, SK; Lutsel K’e, NT ─ located outside the Nunavut Settlement Area, who have all stated an interest in the proposed Kiggavik Project due to potential impacts to Aboriginal rights through written submissions to the NIRB and directly to AREVA?

AREVA Response:

Please see the response to IR BQCMB 2.1



January 31, 2013

IR Number: CNSC 34

Request Preamble:

Reference: 7.6.1 Valued Ecosystem Components Component ─ Terrestrial wildlife and wildlife habitat, including representative terrestrial mammals (i.e., caribou, caribou habitat, migration, and behaviour, muskoxen, wolverine, grizzly bears, wolves and less conspicuous species that may be maximally exposed to contaminants); and wildlife migration routes and crossings

Issue:

Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit.

Justification:

A variety of terrestrial wildlife native to the areas around the seven Kivalliq communities was discussed in the IQ interviews.

Request:

Community members expressed concerns about mining-related contaminants being blown into the air and negatively affecting the habitats and health of terrestrial wildlife. Where does AREVA address these concerns in the DEIS?

AREVA Response:

DEIS Tier 3, Volume 8, Human Health, Appendix 8A, provides the modeling results pertaining to the effects from terrestrial wildlife and wildlife habitat being exposed to mine related contaminants via air dispersion. Within this report, specific details pertaining to aid dispersion effects on vegetation (i.e., wildlife habitat) can be found in Section 7.5, while effects to wildlife are presented in Section 8.2. Results from this report were incorporated into the terrestrial environmental assessments on habitat and health for each VEC in the corresponding assessment sections. Please see response to IR AANDC 15 for the communication of DEIS findings to the Kivalliq communities.



January 31, 2013

IR Number: CNSC 35

Request Preamble:

Reference:

9.0 ENVIRONMENTAL MANAGEMENT SYSTEM 9.5.2 Community Involvement Plan The Proponent shall present a Community Involvement Plan which discusses the following: Mechanisms for providing information to the public and potentially affected communities regarding regular updates of Project’s progress, initiatives and future work plans (e.g., training opportunities, hiring information, etc.) Methods and procedures for establishing effective two-way communications for collecting and addressing public concerns.

Issue:

Tier 2, Volume 3 ─ Public Engagement and Inuit Qaujimajatuqangit, Part 1 Public Engagement.

Justification:

AREVA has employed a variety of ways to engage and involve target communities in the planning of the Kiggavik Project. These methods include: community meetings, such as open houses, info sessions interviews with targeted community members (Elders, HTOs, young adults women)blogging, project website radio and print ads to notify of meetings tours of AREVA’s Saskatchewan projects; tours of the Kiggavik Project site, etc.

Request:

Have any communities or demographics asked that AREVA’s web material be translated into Inuktitut text? What challenges has AREVA encountered in communicating with communities and key groups (i.e. elders, youth, hunters, women)?

AREVA Response:

There is no record of requests to translate the web material into Inuktitut. The primary challenge encountered when communicating with communities and key groups has been arranging face-to-face meetings. Severe weather can cause logistical delays preventing people from attending a scheduled meeting, requiring rescheduling. Competing events in communities or conflicting schedules of representatives create additional challenges. Overall, more than 90 percent of meetings scheduled are held with good attendance. Translation is described in DEIS Tier 3, Volume 3, Public Engagement and Inuit Qaujimajatuqangit, Part 1, Public Engagement, Appendix 3C, Section 4.4.1.



January 31, 2013

IR Number: CNSC 36

Request Preamble:

Reference:

Volume 1, Subsection 2.7.4

Issue:

Monitoring and Follow-Up: The structure of the DEIS is such that some of the information on mitigation, monitoring and follow up for particular elements if found within discussions of that element. However, it is difficult to get a whole picture of the plan for Monitoring and follow-up for the project overall. Additionally, the document does not provide any information on the roles and responsibilities of the various parties (as required in the EA Guidelines) for ensuring mitigation, monitoring and follow-up.

Justification:

It would have been helpful if this volume provided more context regarding the areas, or project elements that would be requiring follow-up or monitoring. NIRB Guidelines p.92 states that the Monitoring and Follow-Up section of the DEIS must contain: •“Which elements of the monitoring program described in section 9.3 would be incorporated? • The mechanisms, through which monitoring results will be analysed, and if necessary, adjusted mitigation measures or adaptive plan will be employed. • In addition, how the effectiveness of the new mitigation measure will be assessed and verified. •The roles to be played by the Proponent, regulatory agencies, and others in such a plan, and possible involvement of independent researchers. •The plan shall include quantitative triggers or thresholds that will indicate the need to alter or vary the management plan or mitigation measures.”

Request:

Please consolidate the overall plan for monitoring, mitigation and follow-up in one location that gives a high level response to each of the requirements of p.92 of the NIRB Guidelines.

AREVA Response:

The NIRB Guidelines for the Kiggavik Project, Section 4.3, state that:

…the Proponent’s EIS Main Document (i.e., Volume 1) shall be concise and not exceed 150 pages… to ensure the main document within the EIS report remains manageable for reviewers, communities, and the general public, any data of a detailed nature shall be contained in separate volumes as appendices and technical reports submitted in supporting documents of the main document.

The constraints of the guidelines prevented the high-level overview requested from being included in the DEIS Tier 1, Volume 1, Main Document. To facilitate review of the information requested, the following roadmap is provided. AREVA’s integrated environmental protection approach is discussed in Section 17 of the Project Description and Assessment Basis (DEIS Tier 2, Volume 2). Figure 17.1-1 provides a simplified flow diagram of the environmental assessment process and demonstrates how iterative



January 31, 2013

evaluation of the Project design strives to minimize residual environmental effects prior to operations. Some key outcomes that flow from the environmental assessment process include the development of a framework for a monitoring program incorporating regulatory compliance regimes and receiving environment effects monitoring requirements and a framework for a follow-up program to verify the effectiveness of mitigation measures and the accuracy of the environmental predictions. These elements need to be integrated into the operation of the Project. Please refer to the Integrated Management System (IMS) Attachment to the IR response package Introduction, which outlines how each component and activity is incorporated into the IMS and provided as part of the detailed licensing/permitting/authorization application to ensure that the designs and mitigations meet or exceed those outlined in the FEIS. In addition, monitoring and mitigation plans are discussed in further detail within the following volumes and appendices of the DEIS:

Volume 2, Project Description o Appendix 2C, Explosives Management Plan o Appendix 2H, Ore Storage Management Plan o Appendix 2M, Road Management Plan o Appendix 2N, Borrow Pits and Quarry Management Plan o Appendix 2P, Occupational Health and Safety Plan o Appendix 2Q, Radiation Protection Plan o Appendix 2R, Preliminary Decommissioning Plan o Appendix 2S, Waste Management Plan o Appendix 2T, Environmental Management Plan

Volume 4, Atmospheric Environment o Appendix 4C, Air Monitoring Plan o Appendix 4F, Noise Abatement Plan

Volume 5, Aquatic Environment o Appendix 5M, Aquatic Effects Monitoring Plan

Volume 6, Terrestrial Environment o Appendix 6D, Wildlife Mitigation and Monitoring Plan

Volume 9, Socio-Economic Environment and Heritage Resources o Appendix 9D, Archaeological Mitigation Plan

Volume 10, Accidents and Malfunctions o Appendix 10B, Spill Contingency and Landfarm Management Plan



January 31, 2013

IR Number: CNSC 37

Request Preamble:

Reference:

Volume 1, Sub-section 4.2, 4.2.1. ─Valued Components, Indicators and Measurable Parameters.

Issue:

Scope of the Assessment, the NIRB Guidelines require the identification of the purpose and need for the project.

Request:

Please provide an explanation of the purpose and need for the project.

AREVA Response:

Project purpose and need are presented in DEIS Tier 1, Volume 1, Main Document, Section 1.3.



January 31, 2013

IR Number: CNSC 38

Request Preamble:

Reference:

Volume 1, Section 8.6. ─ Socio-economic environment, subsection 8.6.1 (pages 140–142).

Issue:

In the section on residual effects, it is stated that it is “fully acknowledged that the detail of effects on different individuals, genders, age groups, vulnerable groups and communities in Kivalliq, many of which can be negative in context of overall benefit are not captured by single conclusions on each of the Valued Socio-Economic Components (VSECs) identified”.

Justification:

The sentence quoted is somewhat unclear, i.e. what does “negative in context of overall benefit” means? However, given that AREVA has identified a gap in the analysis, is there any consideration of including the gathering of this information as part of the Follow-Up program?

Request:

Please explain how AREVA will be analyzing the effects on different individuals in the absence of conclusions on individual VSECs and describe how this will be included in the follow-up program.

AREVA Response:

The quote in the preamble is a summary statement from Volume 1, and refers to the methodology for arriving at an assessment of significance. Additional explanation can be found in DEIS Tier 2, Volume 9, Socio-Economics and Community, Part 1, Socio-Economic Environment, Section 4.6, as follows: “The methodology for this DEIS is to describe residual effects as either ‘not significant’ or ‘significant’, on the basis of assigned criteria. For purposes of the socio-economic assessment, each residual effect is determined to be not significant or significant on the basis of the expected result for most people and/or of the effect’s manifestation at the community level. This is not to suggest that effects that may be experienced at the level of some individuals and/or families are not important, or even critical, to quality of life. Where this is the case, the effect is discussed, AREVA will implement mitigation and benefit enhancement measures in response, and the residual effect will be assigned attributes in terms of the criteria described in Section 4.5, Environmental Effects Criteria. Such effects however are determined to be not significant in terms of quality of life for most people and/or at the community level.” Socio-economic impact assessment methodology does not, and cannot, include assessment of impacts on specific individuals. The assessments of impacts in DEIS Tier 2, Volume 9, Socio-Economics and Community, Part 1, Socio-Economic Environment, Sections 8 through 11 indicates where there is potential for negative impact in a context of overall benefit (that is, in a context where most people benefit), and where specific groups of individuals are expected to be affected differently, or disproportionately, from the population at large. AREVA does not propose to monitor, or follow up on, Project impacts on specific individuals in respect of confidentiality issues. AREVA’s expectation with regard to monitoring is that it will collaborate with the various agencies in Nunavut and the Kivalliq Region currently engaged in community socio-economic monitoring, as may be agreed over the period before Project



January 31, 2013

construction in 2017. Currently, socio-economic monitoring is at a community rather than a subpopulation (or individual) level. Section 6.5.6 Collaborative Monitoring makes some suggestions on the types of data that might be collected, again subject to agreement with all relevant parties, and used to better understand what socio-economic trends might be attributed, or in part attributed, to the Project as opposed to other drivers of socio-economic change. Data collection at the individual household level is necessary to monitor subpopulation responses to the Project.



January 31, 2013

IR Number: CNSC 39

Request Preamble:

Reference:

Section 3.1 ─ Screening Risk Assessment Methodology

Issue:

In defining the rating for environmental protection, more thought should be given to further delineating a moderate, major and catastrophic event outside of the spatial boundaries of the spill. For example, a localized spill of an extremely hazardous substance may have more of an environmental impact than a spill that occurs outside site boundaries but is of less harm due to its chemical properties.

Justification:

Table 3.1-2 ─ Criteria for Assessing Consequences outlines a consequence rating to categories of health and safety, radiation exposure, and environmental risk as minor, moderate, major and catastrophic.

Request:

Please re-evaluate the spatial extent in defining the environmental risk and consequences.

AREVA Response:

AREVA observes that the request does not require AREVA to provide additional information; it asks for a re-evaluation of the consequence categorization system used in the assessment of malfunctions and accidents. The following discussion is offered to clarify the use of the consequences categorization methodology to address this comment. The inclusion of the phrase "but limited to site" as a modifier within the criteria for categorizing environmental consequences as "moderate" is more an indicator of the level of operational control over an incident relative to an off-site occurrence than it is of its specific impact on the environment. The location of occurrence is relevant for comparing otherwise equal events; the degree of environmental hazard has more weight in the determination of consequence than the location alone. Risk ranking is used to inform the discussion on preventative, protective, and mitigative measures. On-site incidents will benefit from having greater resources immediately available to mitigate environmental impacts than incidents which occur remotely from the site. In the subsequent discussion, for example, spills within the project footprint are discussed separately from spills which may occur during transportation as management of these events is necessarily governed by separate management plans.

Documents

Kiggavik Draft EIS Information Requests€¦ · AREVA Resources Canada Inc. ... that is traversed by regional faults and local faults and ... A floor heave analysis was conducted