ArmInfo. Amulsar gold-bearing quartzite deposit located 14km away from resort town of Jermuk is considered to have the largest gold reserves in Armenia. Geologists discovered the gold-bearing deposit yet in 2006. During the following ten years, they had studied the possibilities, pros and cons of starting operation activities.In 2014, the Government of Armenia granted Mining Right to Lydian Armenia CJSC. In 2015, the Project’s environmental and social impact assessment (ESIA) was approved. Despite that comprehensive,almost 6,000-page document, the company is constantly facing harsh criticism by environmental organizations who do not believe and some do not want to believe in successful implementation of Lydian’s biodiversity conservation measures.In an interview with ArmInfo, Armen Stepanyan, Lydian Armenia Sustainability Director speaks about possible environmental impacts of mine operation and mitigation measures planned.
Mr. Stepanyan, a 6,000-page document! Why are some environmentalists still not comfortable with it? They claim that the document has major deficiencies and there is a threat of contamination of Jermuk’s mineral waters.
Any responsible company conducts research to assess potential impacts. We started collecting data on soil, waters and biodiversity of the region at large years ago. In 2010, when geological exploration confirmed that we deal with rather a large gold-bearing deposit, we launched more comprehensive study of economic, environmental and social indicators. The company set a goal to work strictly in compliance with Armenian laws and international standards. The latter was also a requirementof our institutional shareholders. For preliminary studies, we invited a UK-basedconcultancy Wardell Armstrong Int (WAI). The purpose of the studies was to identify potential risks our company may face when developing the deposit and to assess risk management opportunities.Environmental Impact Assessment (EIA) was completed in February 2015. It has identified all risks and there are no unmanageable ones. At the next stage, we assessed the risks and vulnerable points, designing mitigation measures simultaneously to project design.
Parallel implementation of works on design, operation and assessment of environmental risks have become extraordinary for Armenia. Studies to identify the level of potential risks to biodiversity have expanded beyond the future mine site. The studies covered 600 sq/km area, embracing large territories beyond the deposit and future crusher and process plant. The company adopted a method that dictated studies in a wider area to assess all risks without exception. We conducted monitoring of wild animals, their movement in the area, conducted genetic surveys of plants, monitored birds, insects, amphibians, as well as archaeological monuments. We have studied a huge number of factors, which resulted in changes in preliminary plans and designs, including haul roads for future mine trucks.
What companies have you involved in those activities? How have you selected and assessed them?
We have involved both local and foreign specialists, cooperated with Zoology Institute of the RA National Academy of Sciences, Institute of Botany, Scientific Research Institute on Soil, Agricultural Chemistry and Melioration and many privates and well-known international advisory firms. Information about everyone involved in our activities is available in ESIA.
What criteria did your company use to select them? Some environmentalists claim that your experts were paidout.
Since the very beginning of the activities, all the organizations involved in our Project were selected through calls for proposaland in compliance with international standards for feasibility studies. In 2010, WAI British consultancy services company was selected from a number of international advisory companies to conduct technical, environmental and social assessment. Similar open tender procedures were held to select the other companies providing technical and engineering services. In the course of works, we found a company specializing in water management projects.Everyone was doing his job and contractors were changing regularly including because projects were changed frequently. In some cases we were not satisfied with the quality of services provided by some companies and we refused from further cooperation with them and announced new calls for proposal.
Do you think responsible approach to business solutions is what helped Lydian receive Government’s approval for EIA?
I haven’t answered your question about EIA and the mechanisms we used to make the results maximum accessible to both experts and everyone concerned about these issues. That 6,000- page document contains chapters that provide a detailed description of all the processes and procedures of our activity, taking into account economic, environmental and social risks, starting from transportation of ore recovered from the deposit up to final production at process plant.
Did your company present EIA to the public properly?
We did it in two stages. At first, we paid close attention to presentation of EIA to the society, which is the key condition to starting mining activities in the territory of Armenia. Therefore, weheldopenpublichearingsregularly. Therewere 16 suchhearings. The company came to each hearing with answers to the questions raised at previous one and where acceptable, addressing all comments. Besides, in compliance with requirements of our international shareholders, we organize regular public meetings in the communities affected by our activities. We held public consultations with every community separately. I am speaking about Jermuk, Gndevaz, Saravan and Gorayk communities. Representatives of the Government, public organizations and other stakeholders and experts were invited to the public consultations held in Yerevan.
Did representatives of public organizations and local residents make substantiated arguments against the Project at those hearings? Was it just emotional protest?
There were different situations. If they provided any scientifically and technically substantiated objections concerning a specific program, if appropriate, we worked to eliminate shortcomings, if there were such. Specialists, independent experts have always been invited to such meetings. One of Gndevaz villagers, biology teacher, cast doubt on quality of work carried out by serpentologists. He claimed that EIA lacks information about a type of endemic snake.
And what was your response?
We entrusted the RA National Academy of Science Zoology Institute with basic herpetology surveys i.e. reptiles and amphibians. And inviting scientists from that institute to disputes would not be a good idea. That is why, we invited a specialist from abroad. He arrived from France. The dispute was over Armenian (Yerevan) steppe viper (Viperaeriwanensis). After expeditions, the expert proved on-site that information in our document was appropriate. Normally, we involved more than 50 organizations and independent experts in our expeditions. We invited 12 ornithologists from Armenia and Belgium who carried out inventory of birds simultaneously, in different zones and in accordance with the assigned method.
Comprehensive studies of surface, ground and underground waters were conducted. Wepreparedalsoanon-technicalsummaryofthe 6,000-pageESIA. It is about 100-page brief summary free of technical terminology and presents ESIA in layman’s terms with references to more detailed information.
Field studies discovered Potentilla porphyrantha, a very rare plant for the Armenian flora, growing in area of the deposit…
Well, big populations of rose family plants were found in area of the deposit. It is a red listed, endemic plant in Armenia. In fact, there are 32 species of Potentilla growing in territory of Armenia, but Potentilla porphyranthais one of the three critically-endangered species. This species of potentilla grows on boulders and screes between 2,800-3,000 meters above sea level, and rarely on Geghama and Vayk mountain ranges, as well as near the border of Armenia and Nakhijevan, Syunik highlands near Iran. Actually, no one knew about existence ofPotentilla porphyrantha on Amular mountain before.
What will happen to it when you start operation of the mine? Do you plan any reintroduction activities?
Certainly, under Armenian laws, reintroduction of plants, particularly endangered species, to appropriate areas is a requirement. There were three locations appropriate for reintroduction of potentilla, two of which were in nature. For a number of reasons, we refused those two options. Therefore, we started preparations to create appropriate conditions for introduction at Yerevan and Sevan botanical gardens. Potentilla porphyranthaseeds were collected and planted. Survival tests carried out by Armenian scientists and Cambridge University experts showed that 21% of total species of Potentilla porphyrantha growing on Amulsar will be enough for introduction at Sevan Botanical Garden. Sevan was chosen also because 98% of the seeds planted there survived. The Garden will become a temporary shelter for the plants for mine life. Afterward, the plants will be reintroduced on Amulsar. The company invested 500,000 USD in project to preserve Potentilla porphyrantha.
Do you plan any reclamation activities after mine closure?
Sure, reclamation will be carried in several phases. At first, we will remove topsoil and store it in a designated area. Reclamation activities on the area of mine will start in 2028. Topsoil will be returned and restored.
Measures will be taken to create an appropriate drainage system. We weigh construction of special drainage systems to manage acid rock drainage. Our reclamation experience on such large area will become unprecedented for Armenia. All structures and roads to be built for mining activities will be demolished and the area will be rehabilitated.
What do you plan to do with such associated resources as lead, mercury, arsenic (arsenic iron)?
Well, firstly, the Project will have no tailings, waste dumps. The company will use gold heap leaching technology with no tailing dumps. Ore-bearing rock will be hauled by mine trucks to the crushing and screening facility. The crushed ore size will not exceed 19mm. Afterwards, ore will be supplied to heap leach facility via overland conveyor that will be covered to prevent dust generation. The conveyorwillhavea 5.4kmtotallength.
How steady will be that facility? Does it have warrantee life? What measures do you plan in case of heap leach facility liner damage and leakage? Armenia is an earthquake-prone region.
The heap leach pad will not be covered by concrete. The underlying area, about 117ha, will consist of a 30cm-thick clay layer with high-density polyethylene liner – geomembrane that will serve as a barrier. Along with this, a special leak prevention system will be used.
Yet, you are going to use cyanide solution for heap leaching. Did you consider any other methods of heap leaching, for instance, hydrochloride or bacterial methods that are much safer?
Cyanide heap leaching method is applied at dozens of mines around the globe. It is quite safe method. Besides, we will be using a progressive method of drip irrigation that has a series of advantages: reduces evaporation of the solution, can be used in winters too and reduces destruction of the surface. If we chose other methods of solution volatilization, we would face such problems as origination of ponds. Considering the large area of heap leach facility, the bird fauna would be endangered. Birds could land on those ponds, which is not desirable. Meantime, our solution will not be on surface; it will be covered by bird balls and the entire process of heap leaching will be a closed cycle i.e. for the solution we will be using surface waters only. The solution will be circulating constantly in a closed cycle. The cyanide solution will be reloaded for each new cycle of heap leaching. There will be no discharge. This prevents penetration of cyanide into soil.
We rejected hydrochloride method, since it is inefficient. Besides, it may have other impacts. As to the bacterial method suggesting extraction of gold using microorganisms, it is not practiced widely in the world.
Let’s return to associated minerals. What are you going to do with them?
EIA contains a chapter about this too. Grade of associated minerals is minimal. For instance, quartz veins contain very little amount of mercury. We are planning to separate mercury and other minerals, if need be, during ore processing and collect them in special containers. Of course, it would be brilliant if we could sell them, but it is not real, because of small volumes of mercury, for instance. Therefore, we have decided to supply mercury to any local organization that needs it, when certain volumes are accumulated. In any event, everything will be controlled like it is done at dozens of other modern mines.
What are the parameters of noise impact when crusher, process plant and the mine equipment are operated?
We studied potential noise impact on people and animals. Depending on time and season, there are thresholds for acceptable levels of noise impact. For Armenia, in daytime, noise level is deemed allowable if it does not exceed 45-50dB. However, there are some nuances here. If noise level in an area does not exceed for example 30dB, we have no right to exceed it. To be more precise, 30dB noise can be compared to clock beating. Noise impact parameters for the mine site are different. For instance, backup alarms of trucks shall be on to prevent accidents. In daytime, that noise will not exceed the allowable level.
You have described all your activities as ideally thought out. Speaking of “no net loss”, let’s remember that a critically-endangered plant was found in area of the mine and there are mineral springs in the adjacent areas.
Well, that is why I have presented in detail the process we hadgone through when preparing ESIA. After endangered plant was found on Amulsar, we had to change the initial layout of one of the hauls roads. Now that road will pass by the area were potentilla species grow. And that area will be preserved. We studied all potential risks of environmental impact in an extremely responsible manner and weighed all possible options of biodiversity offset. As for concerns about impact on mineral waters, they are groundless, since research of tectonic beds ruled out risks of impact on underground waters even in case of a severe earthquake.
All contact waters, including rain waters that will contactmine infrastructures will be collected in water catchment area through drainage system and will not impact any, including Jermuk waters, or Vorotan, Arpa rivers and Ketchut reservoir. Our company has taken into consideration the international experience of the process of gold heap leaching.
Thank you for the interview. And the last question about establishment of Jermuk National Park. Why are you so interested in establishment of the park?
In some cases, despite all measures taken, residual impacts on flora and fauna are still possible, since the project may impact habitats of some species. A responsible company shall offset potential impact if it is not mitigatable by investing in a comparable environmental project. When we studied offset options, the Government of Armenia was discussing establishment of Jermuk National Park. As we studied habitat of Brown Bear too, we offered investments in that project that address the issue of the bear and have a positive impact of other wild animals. Our company plans to invest 5.7 million USD in that project.