"EcoLur" Informational NGO submitted opinions, remarks and suggestions to RA Environment Ministry regarding the environmental impact assessment (EIA) report draft of the expansion of the ferroalloys plant of "Alapmet" CJSC in Charentsavan.
The letter says: "On August 8, 2023, "EcoLur" Informational NGO participated in the 4th public hearing of the environmental impact assessment report project of "Alapmet" CJSC ferroalloys plant expansion held in Charentsavan, Kotayk Region, Armenia. We submitthe comments and suggestions by "EcoLur" regarding the draft EIA report for the expansion of the plant. The document lists legislative provisions that must be observed, but does not specify by what measures. We suggest clearly specifying the measures.
The risks of qualitative and quantitative changes of "Bjni" mineral water deposit and Alapars fresh water were not considered. The report does not contain data on the storage, neutralization or consumption of gypsum and copper plaster produced in the technological process, which does not meet the requirements of the EIA law.
1. The report shall reflect the information required by Article 7 (1(2)), of RA EIA Law on the surface and underground waters of the area, their quality class, flow regime, qualitative and quantitative indicators, pollution level, water system or its separate parts.
2. The report shall specify the amounts of sulfuric acid, gypsum, and copper gypsum generated during the technological process during the year, give clear explanations regarding their storage conditions and possible consumption amounts.
3. The report shall present the risks of possible shock emissions in the factory, perform calculations of shock emissions and measures aimed at mitigating these risks.
4. Recalculation of atmospheric air pollution, including calculation of sulfur oxide emissions, indicating the distance, wind direction shall be performed, as well as risk reduction measures shall be planned.
5. Risks to human health and to specify measures aimed at reducing them shall be assessed".
August 15, 2023 at 12:15