Lydian International Ltd T.LYD

Mitigation measures built on incorrect assumptions

[AniSeize]

 

The Amulsar Gold Project has some mitigation measures planned to limit environmental impact, but because the potential impacts have been underestimated, the mitigation measures have not been designed conservatively and are inadequate to truly protect water resources. The proposed passive water treatment system is not designed for acid waters, yet Lydian’s data strongly suggest that it will need to treat acid drainage. Additionally, it has no design basis for removal of some of the contaminants predicted in the drainage produced at Amulsar. Finally, the key proposed mitigation measures are untested in any way prior to  operations, as is normally required for mine approval.
Possibly the most important concern is the lack of any mine water treatment until Year 5 of mining. Uncertainties in the amount of “excess water” (water not needed in mine processes) that will require treatment are high and have not been resolved, other than an unacceptable proposal to use it for dust suppression. Lydian is assuming that groundwater will not flow into the open pits during mining, despite the fact that their monitoring and modeling results show that it is likely to occur. Based on this erroneous, non-conservative assumption, Lydian concludes that all water pumped at the mine will be used in the mine processes. If their assumption proves wrong, which appears likely, mine -influenced water will need to be treated and discharged when the pits are created, but Lydian has presented no contingency to deal with this scenario. Lydian also assumes that the treatment needed starting in Year 5 of mining can be a less expensive, lower maintenance passive system rather than a more reliable active system such as lime precipitation. This passive treatment system has been shown to be inadequate for all the contaminants predicted in mine water. Their optimistic assumptions create environmental and economic vulnerabilities that put the financial viability of the mine and the health of the environment at great risk. The woefully inadequate financial assurance (only US $34 million) for a large -scale, high-risk mine operated by an inexperienced, financially-strained mining company risks premature abandonment and transfer of the financial and environmental liabilities from the company to international lenders and the Armenian people.