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Responses to Sevan Committee and other Stakeholders’ Comments

The following comments were provided from the Meeting of the Lake Sevan Protection Expert Committee of the National Academy of Science, June 5, 2012, Yerevan:

Comment 1. The heaps of the mine are designed to be located at 2570-2360 m elevations, in a couple of kilometers from the epicenter of the destructive earthquake of the year 735, in 4 layers of 40-50 meters, with an average height of around 100 m, with m=1m ramp incline and without interim berms. There are no calculations in the draft to justify the stability of the ramps, considering the high (10 points intensity) seismicity of the region.

 Response 1.  It is assumed that the comment refers to the waste dump (WD) facility and not the heap leach facility or the open pit as the elevations of 2570-2360 referenced are pertinent to the WD.  Golder has performed detailed calculations and assessment of stability for each of these proposed project facilities. The calculations and assessment for stability of the WD will be provided in the Golder WD Facility Final Design Report to be included in the project Feasibility Study.It is recognized that Armenia lies within a seismically active zone, with some areas having a high risk of major earthquakes. The Amulsar project area is seismically active with the most recent destructive earthquake recorded in September 1931 at the township of Sisian some 30 km to the southeast of the project site.  Destructive earthquakes have also been recorded near the ancient city of Vayk, some 20 km to the west.As such, a site specific earthquake hazard assessment study was performed in order to develop seismic design parameters for all structures.  Refer to the report by Golder (2012b) for more details of this study.

Engineering slope stability analyses were performed for estimating the potential seismic deformations of the waste pile slopes and liner systems during operations and after closure based on the feasibility level designs prepared. 

 Based on the results of the seismic hazard assessment for the project site, a peak ground acceleration (PGA) of 0.21g was used for the operating basis earthquake (OBE) with Magnitude M6.3 for the engineering stability analyses of the waste dump during the operating mine life.  A PGA of 0.40g was used for the maximum design earthquake (MDE) with Magnitude M6.4 for use in the engineering stability analysis of the WD facility for the long-term permanent closure condition.

 By definition, the OBE has a 10% probability of exceedance in 50 years (commonly referred to as the 475-year event) and the MDE has a 2% probability of exceedance in 50 years (commonly referred to as the 2,475-yr event).  These are considered the standard of care for international design criteria for similar facilities which are used by engineers throughout the world in design of mine waste facilities in high seismic regions.

 The results of the analysis by Golder indicate that the design of the WD facility has adequate and acceptable long-term factors of safety and will result in safe operating performance of the WD even in the case of the design earthquake.

 Comment 2.  “In addition to that, due to hydrogeological characteristics of the heap site, the leachate can infiltrate into groundwater flows in a numerous locations and reach Vorotanriver, and after that it can reach Lake Sevan through Vorotan-Arpa-Sevan tunnel. There are active landslide zones along the perimeter of the heap site, which can be further activated under the pressure of the heap and the impact of explosions in the mine area, especially in spring season; the activation of landslides can have unpredictable consequences.

Response 2. It is assumed that this comment is also related to the WD facility.  The geotechnical conditions of the site are all being taken into consideration as part of the engineering design and analysis for the WD facility which will be included in the Waste Dump Facility Design Report to be included in the Feasibility Study.  The presence of shallow groundwater in the form of seepage and springs at the WD is being mitigated by a series of underdrains as well as inclusion of a low permeability clay liner at the base of the waste dump.  The presence of clay soil in the foundation at the WD site and potential for landslides have been considered and designed for in the engineering design of the WD facility.  In addition, the design includes an underdrain system to capture and convey water that come in contact with the mine waste.  In the event that the collected “contact” water is determined to exceed discharge water quality standards, the contact water will be treated in the WD facilitywastewater treatment plant.  Surface water from seasonal precipitation and snow melt that does not come in contact with mine waste, referred to as  non-contact water, will be diverted around the perimeter of the WD by engineered diversion channels that prevent non-impacted water from contacting the waste dump material.  Blasting operations at the mine would not have any impact on the waste dump which is well over 2 kilometers from the open pit.  A previous technical study by Golder (Golder, 2012a) addressed stakeholder concerns relative to blasting operations in detail and indicated that the safe distance for location of a mine groundwater monitoring well was 65 meters.

comments from Dr. A. Saghatelyan

The following comments were provided A. Saghatelyan, Doctor of geological-mineralogical sciences.

Comment 1. The risk of soil contamination with heavy metals and the transfer of the latter into the food chain. 

 Elemental composition of mineral rocks and ore is not presented in the document, but according to the multiple data (on composition of waters and soils) it becomes obvious that ecologically hazardous toxic elements such as As, Ni, Pb, Hg, Cr, Zn are present in the mine designated for exploitation. Thus, the abovementioned and a number of other heavy metals will be dispersed into the environment together with the dust.  According to the presented calculation the dispersed total dust mass will constitute 337tons per year, but the size of the territory which will occupy the dispersed dust and the load per unit area (kg/sq. km year) are not clarified. With these auxiliary indicators it would be possible to estimate the quantity of heavy metal penetration into the soil. Soils of mine adjacent areas which are used under pasture will become contaminated with the aforementioned elements which will be absorbed by the vegetation and eaten by the cattle and etc. Due to their high-accumulative properties these elements will move up the food chain, first into the livestock organism, then dairy produce and etc.  Soil contamination with heavy metals is persistent and the contaminated areas will become non-applicable for agricultural purposes.  Thereof we can calculate the extent of damages.

 Response 1. Golder is currently undertaking a risk assessment of the impacts from dust generated by the mine, using dust generation and dispersion results from modeling undertaken by WAI.  The modeling is not yet complete but will consider potential leaching of contaminants from the dust to soil, uptake by grasses and ingestion by grazing animals, followed by transfer to humans via milk and meat.  The modeling will be undertaken using internationally accepted procedures and models developed by the United States Environmental Protection Agency (US EPA) and the Environment Agency of England & Wales (EA).  The results will be presented in a memorandum when the modeling is complete and will be incorporated in the ESIA.

 Comment 2. Risks of water quality deterioration

 According to the given data waters in the mine territory are of acid composition and it is obvious that in case of opencast mine exploitation quarry waters will become acidified as well. Volcanic rocks of the mine area are heavily fractured and vertical flow of the waters through fractures reaches deep horizons of the soil. Arpa-Sevan tunnel which plays a role of drainage system for the mining site may be subjected to heavy corrosion dew to the impact of aggressive acid waters. Mobilization of heavy metals in rocks dew to acid waters will have an adverse impact on the spring waters situated down-gradient the mine.  Finally a part of the aforementioned heavy metals may appear in the Lake Sevan.

 Response 2. An assessment of the potential impact of the mine operation on groundwater has been undertaken and will be presented in the Integrated Water Studies report that form an Appendix to the ESIA.  In addition the specific impacts on the Spandaryn – Kechut tunnel have been assessed and are presented in a separate technical memorandum (Golder 2012d).  Based on the assessment it is concluded that during operation of the tunnel there will be no significant impact on the quality of water in the tunnel and that under current conditions there will be no environmental significant impact or impact on the tunnel fabric.  The planned engineering design, controls, and engineering procedures as discussed the technical memorandum prepared by Golder (Golder, 2012d) combined with the distance and the mine pit and facilities from the Spandaryn-Kechut tunnel and the Spandaryn and Kechut reservoirs provide a robust system of controls to prevent impacts to the tunnel, water quality in the tunnel, the Jermuk springs and the water quality in the Jermuk springs as well as to Lake Sevan.

 Comment 3.  Seismological risks

 Currently the whole region is in a stage of seismic activity. In conditions of estimated seismicity rate even small change of rock jointing can result in minor focus earthquakes. In this very case the frequently repeating explosions in the mine territory may result in direct seismicity and induce minor and even moderate earthquakes. Subsequently Arpa-Sevan tunnel will be damaged and what is more probable hydrodynamic regime of the adjacent areas will be disturbed which might pose a threat to loosing Jermuk springs.

 Response 3. The suggested impacts from blasting at the open pits will not have impacts which could damage the Arpa-Sevan tunnel or the hydrodynamic regime of the adjacent areas or the Jermuk Springs.  Please refer to the Response #1 to the comment from the Lake Sevan Committee.  The potential for impacts due to blasting from the project was previously addressed in a Technical Memorandum to the Stakeholders (Golder, 2012a).

comments from E. A. Saghatelyan

The following comments were provided in a document from E. A. Saghatelyan.

Comment 1.The geo-structural basis of the mine is missing, which had to include deep faults, hydrodynamics (don’t mix with hydrometrics, which was informed in the first chapter of the EIA)

Response 1.  The Feasibility Report will provide a description of the structural geology of the Amulsar deposit prepared by Lydian.  A detailed study on earthquake hazards and seismic parameters was prepared by Golder (Golder, 2012b) and was used as the basis for engineering design of the major site facilities including the open pits.  A report on the pit stability was also prepared by Golder (Golder, 2012c) and this was used as the basis for safe design of the open pits and ramps prepared by IMC.

 Comment 2.        The blasting impacts on the hydrodynamics were not considered. As different studies show even little impacts on hydrodynamic regimes can bring to massive closures and dry-ups of mineral and drinking waters sources. This was witnessed in middle 20 century when significant amount of water sources and springs dried in Jermuk.

Response 2.       Please refer to the Response #1 to the comment from the Lake Sevan Committee.  The potential for impacts due to blasting from the project was previously addressed in a Technical Memorandum to the Stakeholders (Golder, 2012). comments from K. Hovhannisyan

The following comments were provided in a document from K. Hovhannisyan.

Comment 1. The pit area is known to be the area of water formation, thus damaging these areas will inevitably bring to minimization of the current water resources. The water quality of Vorotan and Arpa rivers are also under danger, which according to the tables seem to be pretty clean. These water could be used for recreational and fish farm or other water use purposes.

Response 1.Groundwater from the vicinity of the pit will move towards the river Vorotan and the Darb Golder 2012d and as demonstrated by the groundwater modeling study presented as part of the Integrated Water Studies report (Appendix to the ESIA).  This groundwater will provide baseflow to these rivers and no impact on flow is anticipated as a result of mining (i.e. there will be no reduction in groundwater flow.  The potential impact of the heap leach on the Vorotan and groundwater in the Vorotan valley has been assessed and the results are presented in the Integrated Water Studies report presented as an Appendix to the ESIA.  The impact assessment demonstrates that there will not be a significant impact on quality of water in the Vorotan or to groundwater.

 Comment 2.It is hard to assess what to be the impact on water ecology if the tailings are damaged and toxic materials will flow into the rivers.

Response 2. There are two sources of toxic waste: Acid Rock Drainage (ARD) from the WD Facility; and leakage of cyanide and metals from the heap leach facility. As discussed above in Section 1.0, Response 2, the WD Facility has been designed to ensure that leachate from the facility is captured and treated (if determined necessary) and that non-contact surface or groundwater is captured and routed to keep it separate from contact water from the WD facility.  As previously discussed in Response 1 above, an assessment of the integrity of the heap leach facility has been undertaken and it is demonstrated in theIntegrated Water Studies report presented as an Appendix to the ESIA that the facility will not have a significant impact on water quality in the Vorotan.

 references

 Golder Associates Inc.  2012a.  Stakeholder Concerns Over Proposed Amulsar Mining Operations.  A Technical Memorandum prepared for Lydian International Ltd.  Golder Project No. 113-81597FS.  14 pp.  February 20, 2012.

Golder Associates Inc.  2012b.  Earthquake Hazard Assessment and Seismic Parameters for Amulsar Gold Project Site, Armenia.  Prepared for Lydian International Ltd.  Golder Project No. 113-81597FS.  29 pp.  March, 2012.

Golder Associates Inc.  2012c.  Feasibility Level Pit Slope Design Report, Amulsar Project, Armenia.  Prepared for Lydian International Ltd.  Golder Project No. 113-81597FS.  138 pp.  June, 2012.

Golder Associates Inc.  2012d.  Water Related Impacts on the Spandaryan – Kechut Aqueduct and Jermuk, Amulsar Project, Armenia.  Technical Memorandum Prepared for Lydian International Ltd.  Golder Project No. 11514250168.505/B.0.  15 pp.  12 July, 2012.

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