In the framework of the project entitled “Support to SHPP-relating Reforms Through the Dialogue of Public and RA Nature Protection Ministry for Sustainable Use of River Ecosystems” the expert group visited “Khachaghbyur 2” SHPP. “Khachaghbyur 2” SHPP carries out water intake in the administrative area of Yenoqavan community in Tavush Region, water discharge is carried out in the administration area of Getahovit community in the same region. The SHPP is constructed on the Paghjur River (length – 31 km). It’s operated by “MegaEnergy” LLC.
As a result of the monitoring, the expert group found out:
· The SHPP has been operating since March 2014.
· According to the project, the static pressure of the SHPP is 221.6 m and the company says it’s 221.8m. According to the certificate issued by the Public Services Regulatory Committee on 1 January 2016, the estimated pressure of the SHPP is 186.4 m, while the project says it’s 184.6. According to the project and PSRC certificate, the estimated yield used by the SHPP is 3.4 m3/s. According to the PSRC certificate and the project, the projected capacity is 5000 kW. According to the PSRC, as of 01.10.2015 the factual useful delivery of the electricity is 18.1 million kWh. The estimated production of the SHPP is 18.10 million kWh according to the project, duration of license - 27.05.2014-27.05.2029, water usage permit - 25.12.2014- 25.12.2017.
· The water intake and discharge coordinates in the water usage permit don’t comply with the real coordinates.
· The SHPP water intake point includes a catchment basin, a dam, a sand trap with two compartments, a chess-like fish passway.
· The length of the concrete dam of the SHPP is 17 m, its height is 2 m. The project planned to have a concrete dam of 20 m length and 1.7 m height.
· There is a semi-maze concrete fish passway constructed in the right part of the SHPP dam, which has a length of 11.5 meters, height of 1.8 meters and width of 1.4 meters. The fish passway consists of 6 sections, which are partitioned from each other with 6 concrete baffles. In the lower part of each baffle there are holes with 0.3X0.3m sizes to ensure the passage of the fish. Such a fish passway can ensure the migration of mature brown trout, but it can make additional difficulties for the other local fish species. The visual observation showed the slope available in the water intake section, which ensures the passage of estimated yield into the sand trap. The normative standards posed to fish passways are violated. In case of decrease in river water level it’s simply impossible to ensure the water course and environmental flow in the fish passway.
· There are two garbage-collecting cage nets of 122 cm long, and the distance between its bars is 3.5-5 cm. Such distance between the bars can’t be an obstacle for the small fish 10-12 cm long to appear in the pressure pipeline. The cellular net at the entrance part of the pipeline is missing.
· In the section of the Paghjur River, where the SHPP section head is constructed, you can meet the brown trout. The South Caucasus Sprilin and Kura loach may flow up here. There are fish farms on the river banks, from where the rainbow trout may flow in.
· The length of steel pipeline is 3400m and its diameter is 1220 mm, according to the project. The pipeline is over the surface, which is a deviation from the project. It’s laid through the narrow gorge of forest-covered Paghjur River, which resulted in the serious violations of the landscape in many sections of the valley slopes. If to take into consideration the fact this area is a landslide-hazardous zone, it’s simply impermissible. During years the phenomena will get more active and will cause serious problems. The natural landscape of the area is violated. The pipeline hinders the migration of the wild animals along its all length.
· Currently the activation of landslide and slope slide phenomena is observed in many sections of the gorge. During the construction because of the collapse 20-ton rock fell down on the excavator, which resulted in the death of the driver.
· Percentage correlation of aggregate length of SHPP derivation pipelines (6630 meters) of “Khachaghbyur HPP 1” SHPP (the length of the derivation pipeline is 1800 meters, according to the project), “Khachaghbyur” SHPP (according to the project, it’s length is 1430m), “Khachaghbyur 2” SHPP (the length of the derivation pipeline is 3400meters, according to the project), with the length of Paghjur River (31 km) makes up 21.38 %.
· According to the water usage permit, “Khachaghbyur 2” SHPP can take 104699.52 cum/s water ensuring 0.08 cum/s environmental flow in the river.
· The working construction project of “Khachaghbyur 2” SHPP has been amended twice, which resulted in the change of hydroenergetic indicators, including the projected capacity, which became 500 kW from 2960 kW and the estimated yield turned from 2.4 cum/s to 3.4 cum/s. The water intake point has also changed (its coordination point turned from 1050 m to 1088.5 m), the static pressure and pipeline parameters changed to L=3400 մ, D= 1200 mm instead of previous L=2450 մ, D= 1020 mm. In parallel with all these changes the amount of environmental flow has been left the same – 0.08 cum/s.
· According to “Computation Center” CJSC data, in 2014 “Khachaghbyur 2” SHPP operated for 10 months and produced 7936144 kW electricity (according to the project, the estimated production is 18.10 million kWh).
· There are four hydroaggregates of local “Khorda” production installed in the SHPP building (the project planned 4 aggregates). At the moment of observation only one aggregate was operating, which ensured 600 kW capacity with 350 l/s. According to the SHPP employee, the four aggregates ensure 5000 kW projected capacity with maximum 3.2 cum/s water amount from March to June.
· The transformer substation is fenced, two transformers are not equipped with oil-collecting system.
· Automatic management and recording of water intake and environmental flow is not ensured.
· There is no entirely automated management system in the station.
· During the SHPP construction in 2012 numerous trees were cut down illegally and afterwards the positive expertise opinion issued to the SHPP project was annulled. Later another two projects have been submitted, which mentioned tree felling.
· The permit of “ArmForest” SNCO on tree felling is missing.
· During the monitoring “Ijevan” Forestry Enterprise Deputy Director spoke about 1200 nut trees planted against felled down trees during the construction and their adaptability. Nevertheless, during the monitoring the carried out tree planting was not observable in the disturbed land areas.
· 80% of the water intake station and pipeline of the SHPP is located in “Ijevan” reserve area. The laid road resulted in the increase of wild forest felling.
· The site development works of the station area have been carried out in line with the requirements posed to SHPPs. The area is greened with newly planted trees, fenced and laid with concrete tiles.
· The discharge of household wastewater is carried out through a water-proof well. According to the SHPP representative, the household garbage is transported to the landfill site of the affected community.
· There is no water-meter sealed by a relevant environmental body in the water intake. There is a gauge-rod.
· Two criminal cases have been initiated during the construction of “Khachaghbyur 2” SHPP for the damage caused to environment, submitting projects not complying with the reality and the positive opinion of the environmental expertise, but after three years the law enforcement bodies suspended the litigation of the criminal case because of the absence of a criminal case and only an administrative fine was imposed on “MegaEnergy” LLC.
· Because of construction works the drinking water pipe is left hanging in the air.
· In 2015 an administrative fine of 200,000 AMD was imposed on the SHPP for not adhering to the requirements of Article 21 of RA Water Code.
· The SHPP employs 11 people.
The construction of the SHPP in this area was impermissible from the very beginning. As the construction of the SHPP was permitted in the specially protected areas of nature (or in bordering areas - “Ijevan” and “Arjatkhleni” state reserves), which are located in “North Basin Management Area” with their water resources, the calculation of the environmental flow hasn’t been carried out according to the methodology set in the governmental resolution no. 927-N dated on 30 June 2011 (as it was in case of all rivers). It’s extremely important to set a new methodology for the calculation of environmental flow for the water resources in the specially protected areas of nature, which will set new water amount of environmental flow for the Paghjur River. The hydroeconomic estimates shall be reviewed with the tendency to increase environmental flow.
· To ensure automatic management of environmental flow in the head section, installation of water-measuring devices and online control.
· To reconstruct the dam to ensure free passage of environmental flow.
· As the SHPP is located (and also borders) in specially protected areas of nature and in “buffer zones” - “Ijevan” and “Arjatkhleni” state reserves, which are located in “North Basin Management Area” with their water resources, it’s proposed to review hydroeconomic estimates with a tendency to increase environmental flow.
· To set a new methodology for the calculation of environmental flow for the water resources in the specially protected areas of nature, which will set new water amount of environmental flow for the Paghjur River.
· To draw up a reforestation plan to compensate for the felled down trees with “ArmForest” SNCO, which shall also include forest care (before replanting in forest), as the area is located in a landslide-hazardous zone.
· To ensure the water intake section with automated management system and water-measuring devices, which will regulate the water amount used by the SHPP and the set environmental flow.
· To equip the transformers with oil-collecting system.
· To take measures aimed at the preservation of river and soil ecosystems with the participation and consultation of relevant specialists.
The material was developed in the frames of “Supporting reforms in the sector of small hydro power plants through enabling a dialogue between civil society and the Ministry of Nature Protection for sustainable use of river ecosystems” supported by UNDP/GEF Small Grants Programme".
17:03 April 08, 2016