EcoLur
On 27 September the second hearings on the EIA of Amulsar project will be held in Gorayq, Syunik Region, submitted to “Environmental Experise” SNCO by Lydian International Company as represented by “Geoteam” CJSC. These are the second hearings, the first one was held on 25 August in Gndevaz Village, Vayots Dzor Region. “EcoLur” Informational NGO took part in the first hearings and addressed its official opinion on the EIA of the Amulsar project to “Environmental Expertise” SNCO. The opinion says, ““EcoLur” Informational NGO thinks that the State Environmental Expertise must turn down Amulsar project, the EIA of which was presented by Lydian International Company /‘”Geoteam” CJSC in Armenia/ at the public hearings in Gndevaz Village, Vayots Dzor Region, on 25 August 2014.
Despite the volume of the documentation – 440 pages of the EIA, 25 appendices and closed mining project, the EIA doesn’t reflect real risks for health and environment, while the public and governmental bodies – Scientific-Expert Committee on Lake Sevan Preservation, independent experts have beaten many alarms signals on these risks to Nature Protection Ministry, Government and shareholders of Lydian International Company - International Finance Corporation and the European Bank for Reconstruction and Development.
First of all, Amulsar project bears risks for the strategic water resources of the country, as most infrastructures of the project are located in the drainage area of Arpa and Vorotan Rivers, as well as in close proximity to Kechout and Spandaryan reservoirs, which, in their turn, are a part of Lake Sevan drainage area, (Article 3 of RA Law “On Lake Sevan”). For this very reason, still in 2012 the Scientific-Expert Committee on Lake Sevan Preservation issued a negative opinion to Amulsar open pit mining project, which is available in the documentation package submitted to 'Environmental Expertise' SNCO.
On waste dumps
The analysis of the samples taken during geoprospecting shows that gold concentration in the mine makes up only 0.8-0.9 g per one ton of ore. The rest are accompanying elements such as cadmium, lead, arsenic and other toxic elements and heavy metals. All these admixtures in dispersed form in tails and barren rock, under the exposure of air and sun, will start getting spread in the air, soil and water in the form of compounds aggressive for the environment. But the project doesn’t say anything about it. Instead of the list of the toxic elements, the EIA says, “inorganic dust”, and nothing is said that inorganic dust is one of the most hazardous pollutants. Under the EIA, the emissions of ‘inorganic dust’ will make up 373.6 tons per year, transportation – 0.61 tons, heap leach plant – 349.7 tons only from the accumulation of the debris.
The EIA doesn’t show the composition of this dust – how much cadmium, lead, arsenic and other toxic elements and heavy metals it contains. Already now the concentration of heavy metals in the soil exceeds the MPC because of high volumes of geoprospecting and geological exploration held by the company in Amulsar in 2006.
The EIA says that “as a result of mining activities, 660 ha of land areas will be used, which will become a source of pollution with heavy metals both for water and agricultural land areas, while the project doesn’t say anything about it.”
The presence of uranium in the territory of Amulsar project is not a debatable issues, as the explorations made by Gromov and Koltsov expeditions are open for reading and prove about the presence of about 100 tons of uranium in Amulsar mine. The opinion of Scientific-Expert Committee on Lake Sevan Preservation says about radiation contamination risks, as well as the letter by the Chairman of the State Committee on Nuclear Safety by RA Government, “…Taking into consideration then possibility of contaminating the area with radioactive isotopes during mining, “Geoteam” CJSC must organize radiation monitoring both in the mine and neighboring areas and to submit the data to the State Committee on Nuclear Safety,” Chairman Ashot Martirosyan’s letter says. A question arises: if the background already exceeds the standard, what kind of measures the company must take to reduce it? The EIA says nothing about it.
Besides the monitoring of the radiation background, the company doesn’t propose anything else. There are no studies on mapping the borders of the uranium mine and the company is not entitled to carry out such studies, as “Armenian-Russian Mining Organization” has a monopoly over uranium studies.
The risks of heap leach facility are not submitted at all. Under the EIA, the facility will accumulate 102 million tons of crushed ore. The need for sodium cyanide will annually make up 2000 tons, hydrogen chloride - 100 tons per year. 20% of the cyanide solution will be prepared on the spot and filled into tanks. In such concentration cyanide will pose huge threats for all human organisms. The EIA doesn’t say anything about probable man-made accidents and natural disasters and human factor, which can cause cyanide spillout. The company makes a reference to international standards, while the international standards take these risks into consideration: the either refuse from heap leaching or establish a special fund, which will help to compensate damage. Nevertheless, the EIA doesn’t say anything either about possible damage or establishing a special fund or probable accidents and cyanide spills.
Besides, it should be noted that the heap leach facility must be constructed on 145 ha of agricultural land areas and orchards owned by 5280 households. The EIA says that the owners will get compensation, which, in our opinion, won’t replace either the special fund or territories with new plants.
The largest chapter is devoted to biodiversity, which presents the studies made by groups of specialists hired by the company. Here there is great divergence in the data on the number of red-listed species inhabiting in the project area presented by WWF Armenia. Secondly, Article 26 of RA Code on Subsoil is interpreted, which imperatively bans mining in red-listed species habitats and passage corridors. The company speaks about the transfer of the species making a reference to NAS RA, nevertheless, its appendix contains NAS’s replies to these questions, which say the question needs further investigation.
And here we have 440 pages hiding rewritten methodologies and own conclusion often not complying with the opinions of the experts hired by the company.
September 26, 2014 at 16:00