Environment Ministry's Response to Verdict of Public Environmental Court on Nahatak Tailing Dump

Environment Ministry's Response to Verdict of Public Environmental Court on Nahatak Tailing Dump


The Ministry of Environment has sent a reply letter to Oleg Dulgaryan, President of Community Mobilization and Support Center NGO, responding to the verdict of Public Environmental Court "On Continuous Impact of Nahatak Tailing Dump on Environment and Human Health”. The verdict was sent to RA Prime Minister Nikol Pashinyan and RA Prosecutor General Arthur Davtyan on March 16, 2020.

The reply letter written by RA Environment Ministry N5/04.2/4544 says:  "In response to your letter N  09 dated on March 12, 2020 addressed to the Prime Minister, in connection with the verdict of Public Environmental Court "On Continuous Impact of Nahatak Tailing Dump on Environment and Human Health in Alaverdi” ԲՀԴ /02/20 dated on February 26, 2020, I inform the following: the positive expert opinion shall be declared invalid in accordance with the cases defined by Article 21, Part 2, Clauses 1-5 of RA Law on Environmental Impact Assessment and Expertise.

According to the requirements of the decision of the Government of the Republic of Armenia N22-N dated on January 10, 2013, the monitoring of the mined area, the location of production piles generated during the extraction and the safety of the population of the communities adjacent to them shall be carried out after the mine closedown. In order to implement them, "Akhtala OPC" CJSC has been allocating 225.0 thousand AMD every year since 2017. As of March 6, 2020, 1245.0 thousand AMD has been allocated: the payments are made according to the schedule.

Akhtala OPC CJSC submitted the monitoring reports for 2019 (http://www.mnp.am/en/pages/233). According to the reports, the overall quality of the waters of the Nahatak River above the tailing dump has been assessed as 5th grade - poor quality due to chromium, nickel, calcium, nitrate ion, sulfate ion, dependent substances (above the tailing dump) and ammonium ion, chromium, nickel, dependent materials, calcium, nitrite, nitrate and sulfate ions (below the tailing dump).

Akhtala OPC CJSC has been offered a review of the monitoring program in accordance with the design documents, EIA reports, the provisions of expert conclusions NBP-100 dated on November 14, 2017 and NBP-77 dated on September 17, 2018 and the requirements of the expert opinion.

The Ministry of Health has developed a methodology for "epidemiological risk assessment of environmental impact on the health of the population", which was submitted to the opinion of experts of the World Health Organization (WHO). In December 2019, a meeting was already held with the International Atomic Energy Agency (IAEA) and the latter made relevant recommendations. At present, the methodology has been amended, as a result of which the methodological guide has been brought in line with the current international approaches and is being approved.

In 2020, it is planned to implement the program of environmental research and population disease study in Akhtala and Alaverdi communities, Lori Region, Dilijan Community in Tavush Region due to the activities of mining and metallurgical industrial enterprises, within the framework of which the data of the research carried out by Czech Arnika Organization will be taken into account.

The Ministry of Territorial Administration and Infrastructure has initiated legislative changes to determine the extent of companies' participation in the socio-economic development of the community. According to the above-mentioned departments of the Ministry of Territorial Administration and Infrastructure, Akhtala OPC CJSC currently has no defaulting obligations under the soil management contract and overdue mandatory payments.

The expert opinion no. 2309.4 issued by "National Center for Technical Security" SNCO of the Ministry of Emergency Situations on November 23, 2018 is correct and objective, subject to invalidation only by court order. The Ministry of Emergency Situations has no control functions, but is ready to carry out technical safety inspections of any hazardous production facility if the developer applies and a contract is concluded.

At the same time, Akhtala OPC Closed Joint-Stock Company is included in the list of inspections to be carried out in 2020 by Environmental and Mining Inspection Body.


May 14, 2020 at 13:22