Teghut, Drembon, Alaverdi, and the Politics
“Every citizen has the right to live in a clean environment, and in case the latter fails, then he/she has the right to be considered as a victim of an environmental disaster.” That’s the law according to the Republic of Armenia’s legislation on the Preservation of Nature (Article 11). Article 15 of the same law clarifies matters further: “Enterprises are obligated to guarantee environmental safety according to existing standards, [obligated] to secure the un interruptible and efficient functioning of cleaning equipment, structures and stations, by means of neutralization of harmful wastes, by means of investing into environmentally harmless technologies and into water recycling systems. It is forbidden to allow the operation of those objects, which do not guarantee the execution of all environmental requirements. When such objects are given operation permits, the [permitting] committee chairman and committee members are subject to civil and criminal prosecution.” It’s tough language concerning an important issue that effects citizens all over our homeland. Those of us who want to see a healthy, clean, and beautiful environment in Armenia applaud this legislation. But what we in the Greens Union of Armenia find deplorable is the way that, in recent years, these laws have been bypassed, and even manipulated, to suit the interests of mining companies working in Armenia. This article presents some facts concerning mining operations in three populated areas, along with our own analysis and conclusions about what is happening -- and what can be done to uphold Armenia’s environmental laws.
Mining in the Teghut forest
A key player in Armenia’s mining activities is the Vallex Group of companies, which has plans to mine copper-molybdenum deposits inside the Teghut forest, near the vicinity of Teghut and Shenogh villages. However, the Greens Union of Armenia performed and published an analysis of the company’s plan, and found it to be misleading and incomplete in its environmental impact and risk assessment. For such reasons alone the plan should have been rejected by Armenia’s Ministry of Nature Protection (MONP). When it further emerged that the proposed plan would violate several international conventions, as well as the laws of the Republic of Armenia, we had hoped that the MONP would decisively reject the mining plan. To our surprise, though, MONP accepted and approved the plan -- without even performing an independent environmental impact assessment. In most cases, this would be considered an extremely irregular development, and it leads us to conclude that there may have been collusion between the Vallex Group (which includes the Armenian Copper Program, ACP) and certain officials in MONP. Beyond the specific circumstance here, an important broader issue is that sacrificing the richly bio-diverse Teghut forest for the sake of mining would serve as a precedent for further environmental sacrifices. Indeed, at the present time, mining exploration work is being carried out inside several other Armenian forests.
Drembon mining dump
Drembon in Artsakh is an active mining site, where Vallex Group is mining copper and gold. News reports have assured the public that the tailings dumps and reservoirs (where toxic mining waste products are deposited) at Drembon are structurally safe, because the reservoir dams are made of reinforced concrete built to withstand an earthquake intensity of up to 9.0 (on the European MSK scale of 12 grades), while the typical local earthquake tremor reaches a maximum intensity of 4.5. The same reporters have stated that the reservoir floors are waterproof. The assertions are mistaken, and almost certainly qualify as disinformation. Indeed, it is unclear whether any independent investigation or study has gone into the news reports. As any actual visitor to the Drembon waste/tailings reservoirs can witness, the walls are not made of concrete, but are mounds of packed earth. The official earthquake map for this part of Karabakh (MSK-64, 1997) shows that local earthquake strength can reach up to 9.0. The well-known Sarsang water reservoir, located directly next to the mine tailings dump, sits on an earthquake fault line; so as a result, during an earthquake toxic wastes from the tailings dump could easily spill into the water reservoir. Furthermore, the floors of the tailings reservoirs are not waterproof. During an official June 22-24 visit to Drembon -- organized and paid for by the Vallex Group to educate the public, including reporters and NGO representatives, about the company’s mining methods – representatives of the Greens Union and other visitors witnessed a new tailings dump being built directly on top of the ground surface . The tailings are dumped over grass and the stumps and roots of the newly cut trees, on ground adjacent to a field where cows were being pastured – a state of affairs clearly impermissible under Armenian law.
Copper smelting in Alaverdi
On July 4, the Minister of MONP organized a tour of the copper smelter at Alaverdi to familiarize himself and the public with the situation there. Again, several reporters were invited to be a part of the tour; nevertheless they somehow neglected to report on a very good speech given on the occasion by Mr. Ara Babloyan, chairman of the National Assembly Committee on Social, Health and Nature Protection Issues. In his speech, Mr. Babloyan acknowledged the importance of maintaining, under the current economic conditions, the 600-plus jobs at the Alaverdi smelter. However, he said, it is a serious question whether keeping those jobs is worthwhile if it comes at the expense of the local population’s health, and at the future expense of caring for thousands of disabled people. Babloyan also called on the plant owners to begin employing proper emissions control technology in advance of considering any expansion of the plant’s production capacity. Expressing precisely the opposite view are several non-profit organizations, which continue to justify the necessity of operating the Alaverdi smelter according to its current standards, and the necessity of mining at Teghut. An NGO leader made this argument as recently as two months ago on Armnews TV. Currently, raw copper ore is crushed and then subjected to an inefficient flotation-extraction process carried out at various mine locations. The resulting “copper concentrate” -- which contains about 28 percent copper in the form of copper disulfide, plus other elements -- is brought to the Alaverdi facility for smelting in its furnace at very high temperatures, to produce a slag containing copper mixed with other metals (silver, gold, etc.). Volatile impurities such as arsenic, mercury, and sulfur are driven off into the air, with the sulfur being removed as sulfur dioxide. All of the air emissions cause enormous damage to nature and to human health. The slag is currently exported without any further processing. However, further extraction of metals from the slag can and should be carried out locally; the technologies used in such extractions – such as the electrolytic refinement process -- would be much less harmful to the environment than all the previous processes combined. This further extraction step would produce clean copper, gold, silver, rhenium, and other rare metals. The new processes produce a relatively low volume of gas, which, being high in sulfur dioxide, is well suited to the production of sulfuric acid. New smelters are designed to capture 90 percent or more of the sulfur contained in the feed materials.
The Politics of Pollution
Officials of the Vallex Group have linked all three issues – mining in the Teghut forest, the mining operation at Drembon, and saving the city of Alaverdi from an environmental catastrophe -- together. In their public discussions, at open forums and in public hearings, company leaders have stated that mining the copper-molybdenum deposits in Teghut would allow them to expand the production capacity of the smelter in Alaverdi, which consequently would allow them to install emissions control technology, thus saving the city’s air from pollution; the mine at Teghut would itself be operated in a manner similar to the Drembon facility, they have said. As they stand, these statements do not correspond to reality. To begin with, the mine at Teghut is planned as an open-pit operation, while the mine at Drembon is a closed mine using underground tunnels. But the larger question is, Why should improving emissions controls in Alaverdi be tied to the issue of mining in Teghut? Around 12 years ago, the owner of the Alaverdi smelter signed an agreement with the government of the Republic of Armenia to rehabilitate the smelter. Was there a provision in that agreement to the effect that the rehabilitation of the smelter was conditional on the mining in Teghut? And in light of that agreement, why has the owner been allowed to pollute the air around the city of Alaverdi and its environs for the past 10 years? One of the owners of the smelter, Mr. Valery Mejlumian, is on record as stating that if the company were given permission to annually produce 100 to 120 thousand tons of slag copper (copper mixed with other metals), instead of the current 10 to 12 thousand tons, then it would be possible to have an environmentally safe smelter in the town of Alaverdi. Also according to him, the Teghut mine would produce an amount of ore equivalent to 30 thousand tons a year of slag copper in its early years of operation; in later years, mine production would be expected to double or even triple. These figures are meant to show that at present levels of copper production, installing emissions control technology is impossible, since operating the smelter with such controls in place is unprofitable. But Mr. Mejlumian’s subtext is also clear: If copper deposits in Teghut cannot be exploited, then the smelter must be shut down, and the company (and its jobs) will leave Armenia. Technologies currently exist that allow for the capture of sulfur dioxide emitted during the smelting operation; this is used to produce sulfuric acid, which is utilized widely in industry. Mr. Mejlumian’s company does not attempt to make sulfuric acid, and thus allows sulfur oxides to escape into atmosphere. He justifies this course by citing a lack of demand for the 40 thousand tons of sulfuric acid annually that the company would be producing were it to capture all of the sulfur emitted. (According to him the demand is less than 10 thousand tons a year.) Yet the Vallex Group has declared that it has purchased sulfuric acid-producing technology, at a cost of three million dollars, in anticipation of its expanded operations. But think for a moment: If the company insists that it cannot sell the (currently unrealized) production of 40 thousand tons of sulfuric acid per year, then how does it expect to sell the even greater amount of sulfuric acid when it expands its copper production? (To add another wrinkle to the cascade of contradictions, there actually is a present-day use for large amounts of sulfuric acid. According to the Agriculture Ministry’s Department of Soil Remediation and Use, there are currently in Armenia about 50 thousand hectares of salinized soils, whose remediation would require the application of three million tons of sulfuric acid.)
Waning public confidence
There are other matters that contribute to the lack of confidence we have in the Vallex Group’s environmental record in Armenia. In 2006, as a result of the smelter operation, 26.7 thousand tons of sulfur dioxide was released into the atmosphere – far surpassing the annual permissible limit for that chemical of 1.18 thousand tons. It turned out that Armenia’s MONP had given the Vallex Group a temporary permit to release 15.6 thousand tons of sulfur dioxide annually, thus helping the company to avoid hefty fines for exceeding the permit levels. Evidently, the rationale was that the savings for Vallex could be invested in installing emissions control equipment, so that eventually the facilities could meet those emissions standards. But though the temporary permit expires at the end of the year 2008, no steps have been taken yet to install the required emissions control equipment. Also in 2006, the annual rate of emission of sulfur dioxide saw an increase of 2,546 tons over the 2005 level. In the same year, in addition to sulfur, the smelter released into air 12 tons of arsenic, 2.9 tons of lead, 104.7 tons of particle dust, 41 tons of zinc, and over 2 tons of copper. Compared to 2005, air emissions of heavy metals have increased by 23.81 tons. These are the official emissions figures, quoted by Armenia’s Ministry of Nature Protection. However, officials at MONP are not sure whether these figures are a result of sampling and analysis, or are deduced from calculations based on chemical processes at the plant. In fact, since the MONP has not carried out an independent assessment of air emissions from the smelter, the figures almost certainly originate from the plant operators – who are not required to disclose their worst levels of emission or discharge into the environment. During the first 10 years of the smelter’s operation, a special permit from the MONP allowed even elevated emission levels to be considered legally acceptable. Subsequent to May 2, 2005, these special-permit high levels acquired additional legal standing when Armenia’s National Assembly amended the law on Nature Protection and Nature Usage Fees, setting new temporary standards on the air emission of toxic substances. This was clearly a show of good will towards industry on the part of the government; but in spite of such gestures, the Vallex Group continues to threaten at public meetings that it will shut down the smelter entirely if pressed to carry out air emissions control measures, because these measures “don’t cover the costs,” as Valery Mejlumian puts it. Meanwhile, the inhabitants of the city of Alaverdi continue to suffer the ill effects of the emissions. Thanks to the fumes from the smelter stacks, adults and children alike have to take medication before going to bed in order to cough less and sleep through the night. Sooner or later, someone is going to take the company to court and demand compensation for the damage to his family’s health. Taking all of these things into consideration, we strongly feel that the Vallex Group needs to take steps to improve its current standards of operation, and thus win the trust of the population and the government, before embarking on new ventures or expanding old ones.
Yet surprisingly, even in the face of such problems associated with its operations, the Vallex Group has managed to win a certain degree of media support. Early on, the media showed a great deal of attention and concern for the Teghut forest issue. Numerous articles and broadcasts argued in favor of saving the forest. But in the past six months, media outlets like Golos Armeni, Novoye Vremya, Iravunk (“The Right”), Hayots Ashkharh, Delovoy Express, ArmNews, Armenpress, and others have begun issuing articles in favor of mining at Teghut – articles which we feel show a decided and unwarranted bias in favor of the mining operations. This issue of media bias became quite evident during a June 22-24 trip to the Drembon mine in Artsakh, organized and subsidized by the Valex Group, where many reporters and representatives from various non-profit organizations were invited to participate. In the wake of that visit, the reporters and representatives from various environmental organizations began broadcasting praise regarding the company’s proper mining methods at Drembon: they cited the use of the tunneling method of mining (as opposed to the open-pit mining method); the sealing/closing of the exhausted tunnels/cavities with concrete (as opposed to abandoning them without closure); the neat and clean state of the ore processing plant nearby -- all of which evidently left a deep, positive impression on the trip participants. What is troubling to us is that these were the very news reports which also severely misrepresented some critical mining issues relating to Drembon, as described in the section on the mine above. An obvious instance of misrepresentation appeared in Hayots Ashkharh on July 6: a reporter wrote that while touring the Teghut forest with the Minister of MONP, he saw no cut trees in the forest, “neither in areas where exploration drilling is being carried out, nor in the neighborhoods of the roads inside the forest; no logging evidence that can be observed from the roads was observed, no logging associated with the mine exploitation was observed.” This statement defies the evidence anyone can observe in the forest and its surroundings; these include clear cutting trees in order to make roads, and also in order to do exploratory drilling in numerous places inside the forest . It seems obvious to us that such a report can only be intended to mislead the public, and give them a false sense of confidence about the operations at Teghut.
We repeat that from our study of the relevant evidence – independent scientific assessments, official government reports, the often contradictory statements and claims of the company involved, and simple observation of the facilities in question and their surrounding populated areas – we are convinced that Armenian environmental laws are being bypassed, standards are being manipulated, and perhaps even influence is being peddled to suit the interests of the mining company in Teghut, Drembon, and Alaverdi. The industrial and employment needs of Armenia are serious matters, but the cost of fulfilling such needs should not be the potential ruination of Armenia’s environment and the well-being of its vulnerable citizens. Part of the problem – and an obstacle to workable solutions -- is the great lack of interest on the part of government officials to pursuing alternative development plans for these areas, instead of handing them over to mining programs. For example, with regard to the Teghut and Shenogh villages, why shouldn’t agricultural development be considered as a viable alternative to mining? Only two decades ago that same area enjoyed a profitable agricultural production. Surely that state of affairs could be restored and expanded today. Surely that would be preferable to the pollution associated with current methods of mining and exporting metals, which destroy Armenia’s wilderness, agricultural land, water resources, and public health.
Dr. Hakob Sanasaryan is president of the Greens Union of Armenia; he can be contacted via e-mail at email@example.com. Dr. Anne Shirinian-Orlando heads the Greens Union’s U.S. office; her e-mail address is firstname.lastname@example.org.