2.1. GENERAL OVERVIEW 2.1.1 Project Impact on Mureș River.arpmtm.anpm.ro/files/arpm...

Report to the Environmental Impact Assessment Study

,,Gold-silver ore mining of Certej perimeter”

„Amendments to the technical documentations EIS Report, SR, IpCT, requested by the

Ministry of Environment and Forests for the application

of the Espoo Convention provisions”

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II . WATER

2.1. GENERAL OVERVIEW

2.1.1 Project Impact on Mureș River.

The measures for the water pollution fighting and prevention which are to be implemented

within the Project will positively impact Mures river, as a result if the pollution mitigation alaong

Certej stream. The expectations are in accordance with the environmental targets provided by the

Frane Directive WATER 2000/60/EC, which aim at the long term protection ,use and sustainable

management of waters and with the Management Plan of Mures water basin ( 22 December 2009)

which purpose consists of the balanced management of the water resources as well as the protection

of the aquatic eco-systems so that to achieve a „good condition‖of the surface waters in compliance

with the provisions of the Water Frame Directive.

The argumenrs of this statement are detailed in the Report to the Environmental Impact

Assessment sub-chap. 4.1, a summary being presented below.

„The acid waters are produced presently because of the past mining activities and wil be

produced by the future exploitation as well. Due to the characteristics of these waters ( low pH,

heavy metal presence, metalloids and neutral salts in solution) their treatment prior to their

discharge in the environment is required so that to comply with the NTPA 001/2005 regulations.‖

(excerpt of page 66).

The acid drainage resulting at the open pit and waste dumps further to the interaction

between the precipitations and sub-layers, they will eb cuaght and pumped to the acid drainage

treatment plant from the Processing Plant yard and the treated water will be discharged in the

emissary, Coranda stream. „The acid drainage treatment plant will be operating during the operating

and closure stages as long as acid drainage is collected and their quality requires treatment. (excerpt

of pag 61).

„The proposed process of the project for the acid water treatment ( with lime) is the optimal

alternative and one of the most largely ndusrtially sued processes providing good environmental

performance. ‖ (excerpt of pag. 69)






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„The rainfall water ( not contaminated) collected from the processing plant surface areas will be

collected through the channels from each platform and will be directed through channels to Coranda

stream emissary. The contaminated rainfall water from the surfaces where contamination may occur

will be collected in the retention basins provided with sumps wherefrom it will be directed to the

technological process.‖ (excerpt pag 86).

Another project which may generate contaminated water is represented by the Flotation

Tailings Management Facility. The clarified water of this tailings facility will be colected and

pumped to the processing plant to be partly recycled to the process while the excess water will be

discharged in the emissary `( Coranda stream) after treatment. „The proposed BAT technologies

and presented previously for the aicd water treatment are valid also for the treatment of clarified

waters discharged from the tailings facility and for the slurry resultd at ore flotation.‖ (excerpt pag

70).

For the cyanidation TMF, the clarified waters collected and pumped to the plant will „be

entirely recycled to the process and discharged only under special meteorological conditions and

after treatment‖ (excerpt pag 95).

„Taking into account the above mentioned and in the previous chapters (catchment,

diversion and canalization of some surface waters , collection and treatment of contaminated

meteoric waters and meteorice , water recycling, contaminant concentrations in the used water, used

water flow rates, efficiency of the treatment plants, monitoring acitons etc.), there results that used

waters discharged in the emissary will have lower concentrations compared to those provided by

the environmental legislation in force (NTPA 001/2002),and the quality of the receiver , its use and

the downstream eco-systems will not be impacted after the used water discharge. On the cotnrary,

under the circumstances of constructing a divesion, collection and treatment system of the waters

from the waste dump and open pit zone (according to those mentioned above),the new investment

will contribute to the significant mitigation of the negative impact which is generated currently by

these waters which are not controlled on the surface waters of the zone.” (excerpt pag 95).

„The frame Directive Water 2000/60/CE (transposed in the Romanian legislation through

the Law 310/2004 amending and completing the Law of Waters 107/1996) defines, at Art.2 the

condition of the surface waters from the ecological and chemical point of view, on the basis of a

classification system in 5 classes : very good, good, moderate, poor and bad.‖(excerpt pag 45)






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The main objective of the Frame Directive Water is to achieve a ‗good condition‖of all the

water bodies except for the strongly modified and artificial water bodies for whihc the „good

ecologic potential‖is defined. The Management Plan of Mures water basin represents the tool for

the implementation of the Frame Directive Water regulated through the Article 13 and the Annex

VII and its goal is to achieve a balanced management of the water resources as well as the

protection of the aquatic eco-systems, mainly aiming at a „good condition‖of the surface and

underground water.

In accordance with the Management Plan of Mures water basin „( 22 December 2009)

Mures river is consdiered as a water body highly modified from downstream Reghin locality and to

downstream Deva. The monitoring data indicate, prior to the mining exploitation start up, a good

condition both from chemical and ecological point of view, upstream the flowing out point of Certej

stream in Mures river and downstream ,too. The things are even better for several indicators which

are relevant for the mining operations indicating the presence of other pollution sources within

Mures water basin upstream teh flowing out point of Certej stream. Thus, there have been noticed

in terms of annual averages that the concentrations of sulphates, cadmium, copper, nickel,

manganese, zinc decreased downstream ( Branisca sector) compared to upstream ( Gelmar sector)

the confluence with Certej stream and in terms of maximum concentrations, they decreased for

sulphates, cadmium, copper, managanese , nickel, zinc. (abstract pages 44-46).

The efficient management solutions of the water resources provided to be implemented

within the Project are complying with the environmental targets established by the art.4 of the

Frame Directive Water and those of the Management Plan of Mures water basin and their goal is: to

prevent the deterioration of the surface water condition, imprivment of the strongly modified and

artificialw ater bodies so that to acheive a \‘good ecological potential‖and „good chemical

condition‖until the year 2015 and gradual mitigation of pollution with contaminants / gradual

removal of the prioritarily dangerous matters of surfce waters by the implementation of the best

available technologies (BAT). Under such circumstances throughout the Project life and after the

exploitation termination it is expected to maintain „agood ecologic potential‖and „a good chemical

condition‖downstream the confluence of Certej river with Mures river and even an improvment of

the water quality and aquatic life of many specific indicators.

2.1.2 Impact on the project at different stages of water courses.

There are different sources generating used waters and they depend on the activities

developped by each of the objectives and incompliance with the project development stages.






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The Report to the Environmental Impact Assessmnet, sub-chap. 4.1.3.1. Sources of used

waters (pag. 48-59) provides information referring to the quality and quantity of thes waters for

each of the project development stages ((construction, running, temporary cessation of activities,

decommissioning and closure and post – closure) and each of the spurces including the issues

related to the ex[pected impact on thereceiving waters .

În the Report to the Environmental Impact Assessment in sub-chap. 4.1.4 (pag. 89-96) it is

presented the expected impact on the water courses for each of the project development stage.

As for the impact caused by the accidental cessation of the acid drainage plant running the

following conclusions could be drawn:

-Acid drainage treatment plant has been designed to run as long as acid drainage is

collected including durin the post-closure stage. There will be treated the waters collected from the

open pit and the two waste dumps.

-„ During the operating period the two objectives can be sources of used waters generated

by the meteoric waters percolating or washing the waste dump slopes. The composition of these

waters may be different, depending on the dumped waste composition. The design provides the

catchment, canalization , drainage of permanent and non-permanent surface water courses of the

dump territory as well as their treatemtn in the Aicd Water Treatment Plant of the plant yard. Also,

it is designed to collect the rainfallw ater from outside the waste dump area through the guard

channels which direct the waters outside their perimeter. The details referring to these arrangement

works were described in chapter 1.‖ (Report to the Environmental Impact Assessment chap. 4.1.

pag. 52).

-When an accidental stoppage of the acid drainage treatment plant occur, the acid water are

no longer pumped out of the open pit and from the collection basins situated downstream the two

waste dumps.

-The pluvial waters collected from the open pit remain within the open pit until the

treatment plant operation is resumed so no additional impact on water courses is generated.

As for the pluvial water collected of the two waste dump zone they will be collected in the

storage basins described in the Report to the Environmental Impact Assessment chap. 1 :

„North waste dump acid water settling and storage basins

Based on the dimensioning calculations, two acid water collecting basins have been






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designed. The catchment area for the North waste dump can be divided in two separate areas

because there are two streams within its territory. Area no.1 is 155.000 m2, whereas Area no.2 is

675.000 m2. The runoff water from Area 1 will be collected by basin no.1 of the North waste dump,

whereas the leaking water from Area 2 will be collected by basin no.2 of the North waste dump.

..... The North waste dump storage basin no.1 will have the maximum capacity of 16.000m3

.... The North waste dump storage basin no. 2 will have the maximum capacity of 4.000c.m

South waste dump acid water settling and storage basins

Based on the dimensioning calculations for the South waste dump (which has a catchment

area of 650.000 m2)

, one basin has been designed for collecting the acid waters.

The South waste dump acid water storage basin will have the maximum capacity of

15.000c.m. (excerpt pag. 25-26).

These basins have been designed to collect 75 % of the average 24 hour rainfall.

Based on the hydrology data presented by the Directorare of Mures Basin Waters and

namely:

o „Determination of the maximum flow – rate for a probability of 0,1%, 0,5%, 1%,

2%, 5% and 10% return for Macris stream

o „Determination of te maximum flow-rate with a probability of 0,1%, 0,5%, 1%, 2%,

5% and 10% return along Grozei, Ciongani, Borzei, Floroaia Toader streams‖,

The average flow (m3/h) from the waste dumps assumming different return periods have

been calculated, and the results for the reception area are presented in a cumulative manner, in the

table below:

Month /Year Flowing

coefficient

Ian Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Average

Average precipitation 70% 41 37 45 72 85 102 92 81 75 47 41 52 64

Precipitation with 10

year return

70% 57 51 63 100 119 143 129 114 105 66 58 73 90

Precipitation with

100 year return

80% 101 90 112 177 210 252 227 201 185 116 102 129 158

Precipitation with

1,000 year return

80% 138 123 153 241 287 344 310 274 253 159 139 177 217

Precipitation with

10,000 return

90% 197 176 218 344 409 491 443 392 361 226 198 252 309






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It is noticed that in June there occur the highest values. Taking into account that the

collection and storage basins have a total capacity of 35,000 c.m if nothing is pumped to the

treatment plant, they get filled within:

Return period (years) Average 10 100 1000 10000

Duration of the basin filling (hours) 343 245 139 102 71

There was also calculated a maximum volume of water induced by a maximum precipitation of 24

hours, for the waste dumps for different return periods and the results are given below:

Return period (years) Maximum

average

10 100 1000 10000

Probable volume for Area 1 North waste

dump (m3)

20635 27311 42483 57049 71714

Probable volume for Area 2 North waste

dump (m3)

4663 6172 9601 12893 16184

Probable volume for North waste dump

(m3)

25298 33483 52084 69941 87799

Probable volume for South waste dump

(m3)

19788 26190 40740 54708 68676

Total probable volume (m3) 45086 59673 92824 124650 156475

Total probable volume (m3/h) 1879 2487 3868 5194 6520

Taking into account that the collection and storage basins have a total capacity of 35,000

c.m if nothing is pumped to the treatment plant , they are entirely filled during

Return period (years) Maximum average 10 100 1000 10000

Duration of basin filling

(hours)

18,6 14 9 6,7 5,4

If the treatment plant stop running and thus the pumping operations from these basins to the

plant is stopped, the precipitation waters flow from the two waste dumps and are collected in the

above described basins until:






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- a. The rain stops and so no collection is required. In such case no additional impact on

water courses occurs.

- b. Collection of waters continue until the entire filling of the basins and further on the

collected water overflow the basin in Macris stream until such rain stops. In this case, thete may be

an impact of Macris stream water quality.

This impact was quantified considering that:

1. The cessation of the tretament plant running takes place during the rain which flow-rate is

equivalent to the mzximum precipitation for 24 hours, for 1,000 year return period, and last more

than 6,7 hours , so the waters collected overflow the basin in Macris stream for at least 24-6,7 =

17,3 hours , at a fow-rate of 5,194 c.m/h or 1,443 c.m/s.

2. In accordance with the data provided by the „Apele Române‖National Administration

Water Directorate of Mureş through the note no. 13090/8.01.2009, the maximum flow-rate for a

0.1% return probability of Macris stream , in section P4 ( before the confluence with Valea Baiegii

stream, downstream the South waste dump where the receiving surface of the stream is 7.63 sq.km)

is 86.5 c.m/s while along Valea Baiegii within P1 section (dopwnstream South waste dump where

this stream has a receiving surface of 3.79 sq.m) is 57.1 c.m/s, so the flow-rate of Hondol stream

dowstream the confluence of Macris stream with Valea Baiegii is 143.6 c.m/s.

3. At the development of the Report to the Environamental Impact Assessment, INCD

ECOIND took soome samples amd analusyed the existing waste samples ( dumped) presently on

the two waste dump sites. To revel the eventual contaminants which could be engaged by the

precipitationw aters on these samples there have been carried out levigation batch tests in

accordance with the requirments of the SR EN 12457/2003 – Test for checking the compliance for

the levigation of the grain residues and slurries Part 2 – Test with one stage per batch for a L/S

ration of 10 1/kg for materials with high content of solids and particles below 4mm.

In table 3.3. of chapter 3 there are presented the results concerning the levigate

compositions.






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Table No. 3.3. The results of the leaching tests

*) detection limit of the applied method (excerpt of the Report to the Environmental Impact Assessment

sub-chap. 4.1 pag. 50)

Shlould other data referring to the expected composition of the water collected from the two

waste dump surface, are missing, then the environmental impact will be based on a composition

calculated as the average of the above two determintions, expressed as concentration of the aqeous

extract resulted at the levigation test:

Crt.

No. Indicator UM

The value of the

indicators

Leaching ratio: L/S10

l/kg

North

waste

dump

South

waste

dump

1

Total

dissolved

solids (TDS)

mg/kg dry

substance 880 8.740

2 Sulphates mg/kg dry

substance 399.10 5563.40

3 Cadmium mg/kg dry

substance

< 0.02* < 0.02*

4 Cr total mg/kg dry

substance

< 0.1* < 0.1*

5 Cobalt mg/kg dry

substance < 0.2* < 0.2*

6 Copper mg/kg dry

substance

< 0.08* < 0.08*

7 Nickel mg/kg dry

substance

< 0.08* < 0.08*

8 Lead mg/kg dry

substance

< 0.2* 4.25

9 Zinc mg/kg dry

substance

9.144 82.71

10 Arsenic mg/kg dry

substance

0.001 0.001

11 pH - 3.87 6.90






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No. Indicator MU

Indicator Value

Levigation report L/S10 l/kg

North

waste

dump

South waste

dump

Average

1 Filterable

residue mg/l 88 874

481

2 Sulphates mg/l 39.91 556.34 298.12

3 Cadmium mg/l 0.002 0.002 0.002

4 Cr total mg/l 0.01 0.01 0.01

5 Cobalt mg/l 0.02 0.02 0.02

6 Copper mg/l 0.008 0.008 0.008

7 Nickel mg/l 0,008 0,008 0.008

8 Lead mg/l 0.02 0.425 0.2225

9 Zinc mg/l 0.9144 8.271 4.592

10 Arsen mg/l 0.0001 0.0001 0.0001

11 pH - 3.87 6.90 5.8

Because the calculation flow-rate for a 0,1 % probability (return period of 1,000 years) has

been calculated at 1.443 c.m/s and Hondol stream flow-rate downstream the two waste dump is

143.6 c.m/s, it can be considered that the acid drainage overflown from the storage basins are

approximately 100 times diluted and thus there can be calculated an expected composition of

Hondol stream water, assuming that pollution is caused only by the flows from the basins while the

water courses of receiving water are very clean.

The table below presents the expected concentrations of Hondol stream water compared to

the admissible limits provided for the surface water quality as per the Order of the Minister of the

Ministry of Environment and Water Administration 161/2006:






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Indicator

Average

Conc.

dumps

Expected Conc.

Hondol streaml

Classification of the surface water quality as per the

Order of Minister of the Ministry of Environment and

Water Administration 161/2006

Cal. I Cal. II Cal. III Cal. IV Cal. V

pH 5.8 6.88 6,5 — 8,5

Filterable residue

(mg/l) 481 4.81 500 750 1000 1300 >1300

Cr total (µ/l) 10 0.1 25 50 100 250 >250

Cu (µ/l) 8 0.08 20 30 50 100 >100

Pb (µg/l) 222.5 2.225 5 10 25 50 >50

Zn(µ/l) 4592 45.92 100 200 500 1000 >1000

Cd (µ/l) 2 0.02 0.5 1 2 5 >5

Ni (µ/l) 8 0.08 10 25 50 100 >100

Cobalt (µ/l) 20 0.2 10 20 50 100 >100

SO42-

(mg/l) 298.12 2.9812 50 120 250 300 >300

As (µ/l) 0.1 0.001 10 20 50 100 >100

Reviewing the rsults obtained it can be noticed that all the indicators considered reveal

values corresponding to the I class of quality, so that it can be expected there will actually be no

impact.‖

2.1.3 Map of the hydrology system of the Project zone






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2.1.4. Simulation of the storage capacity of the tailings management facilities under unusual heavy

precipitations.

The high flow-rates safety of the tailings facility was reviewed for precipitation calculation

(1/1000) and checking precipitation (1/10000), in accordance with the provisions of the

STANDARD 4068/87 for a I class construction work. There has been also performed a PMP check.

The hypothesis according to which the collection system and the water diversion from the outer

basin of the tailings facility ( valley side basin) was compromised and that the whole amount of

precipitation water gets into the tailings facility, has been considered.

The design determined the clearance elevations to be maintained for each stage of the dam

construction so that to take over the water amount generated by extraordinary precipitations (§ 5.2).

To discharge this water within a time recommended by ICOLD and IPROMIN institutions, the

flow-rates are pumped from the CIL TMF in the Flotation TMF and then in the emissary the pumps

being placed on floating barges.

VERIFICATION CALCULATIONS

1. Maximum volumes of water to verify CIL TMF’s dam

Maximum volume. = Volume of water falling on the pondc + volume of water flowing out the valley sides

of the water basin

hs 0,01% = flown layer from the water basin

hs 0,01% = 225mm (according to the hydrology study INHGA Aug.2010)

Vol. max.= Slac x PMP + F1 x hs 0,01 % în care:

Slac = pond surface area at different levels (sq.m)

PMP – maximum probable rainfall (440mm is adopted as per Roşia Montană Project)

F1 = Surface area of the water basin up to the CIL dam of the hydrology study INHGA

F1 = 0,70 sq.km = 700.000 sq,m

Dam on 780mdMN level

S lac = 60.618 mp hs = 0,44m

V1 = 60.618 mp x 0,44m = 26.671,92 mc

S valley sides = (700.000 – 60.618)sq.m = 639.382sq.m hs = 0,225m

V2 = 639.382sq.m x 0,225m = 143.861c.m






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A safety factor of 20% 1,20 x 143.861 = 172.633,14c.m

V total retained = 26.671,92 + 172.633,14 = 199.305,1 c.m ~ 199.300 c.m

Dam on 800mdMN level

S pond = 184.493 sq.m hs = 0,44m

V1 = 184.493sq.m x 0,44m = 81.176,92 c.m

S valley sides = (700.000–184.493)sq.m =515.507sq.m hs = 0,225m

V2 = 515.507sq.m x 0,225m = 115.989,1c.m

A safety factor of 20% 1,20 x 115.989,1= 139186,89c.m

V total retained = 81.176,92 + 139.186.89 = 220.363,8mc ~ 220.400c.m

Dam on 827,50mdMN level

S pond = 261.318 sq.m hs = 0,44m

V1 = 261.318sq.m x 0,44m = 114.979,9 c.m

S valley sides = (700.000–261.318)sq.m =438.682sq.m hs = 0,225m

V2 = 438.682sq.m x 0,225m = 98.703,45c.m

A safety factor of 20% 1,20 x 98.703,45= 118.444,14mc

V total retained = 81.176,92 + 118.444,14= 233.424,10mc ~ 233.500c.m

2.Maximum volumes for Flotation TMF’s dam verifying

Maximum volume = Volume falling on the pond + vol. Flown from the valley sides of the water

basin

hs 0,01% = layer flown from the water basin

hs 0,01% = 220mm (according to the hydrology staudy INHGA aug.2010)

Vol. max.= Spond x PMP + F2 x hs 0,01 % where:

Slac = surface of the pond at different levels (ha)

PMP – maximum probable rain (about 440mm is adopted as per Rosia Montana Project)

F2 = Surface of the water basin up to the flotation TMF‘s dam of the INHGA hydrology

study

F2 = 1,8 sq.km – 0,7 sq.km = 1,10 sq.km = 1.100.000 sq.m


S pond= 97.536 sq.m hs = 0,44m






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V1 = 97.536 sq.m x 0,44m = 42.915,84 c.m

S valley sides = (1.100.000 – 97.536)sq.m = 1.002.464sq.m hs = 0,225m

V2 = 1.002.464sq.m x 0,225m = 225.554,4c.m

Asafety factor of 20% is added: 1,20 x 225.554,4= 270.665,28c.m

V total retained = 42.915,84 + 270.665,28= 315.581,1 c.m ~ 315.600 c.m


S pond = 266.632 sq.m hs = 0,44m

V1 = 266.632 sq.m x 0,44m = 117.318,1 c.m

S valley sides = (1.100.000 – 266.632)sq.m = 833.368sq.m hs = 0,225m

V2 = 833.368sq.m x 0,225m = 187.507,8c.m

A safety factor of 20% is added 1,20 x 187.507,8= 225.009,36c.m

V total retained = 117.318,10 + 225.009,36= 342.327,40 c.m ~ 342.400 c.m


S pond= 421.162 sq.m hs = 0,44m

V1 = 421.162 sq.m x 0,44m = 185.311,30 c.m

S valley sides = (1.100.000 – 421.162)sq.m = 678.838sq.m hs = 0,225m

V2 = 678.838sq.m x 0,225m = 152.738,60c.m

A safety factor of 20% is added 1,20 x 152.738,60 = 183.286,26c.m

V total retained = 185.311,30 + 152.738,60= 368.597,5 mc ~ 368.600 c.m






2011

Flotation TMF No. 1 Dam

Crest of wave level h

guard Water level

Tailings

facility

volume

Volume

water level

High flood

volume

Tailings

volume

Deposition

level

H

High

flood

h

safe

elevation

[mdM] [m] [mdM] [mii mc] [mii mc] [mii mc] [mii mc] [mdM] [m] [m]

1 2 3=1-2 4 5 6 7=5-6 8 9=3-8 10=9-2

707,00

0,70

706,30 22.824 22.533 369 22.164 705,36 0,94 1,64

700,00 699,30 19.957 19.710 364 19.346 698,34 0,96 1,66

695,00 694,30 18.043 17.799 360 17.439 693,32 0,98 1,68

690,00 689,30 16.244 16.017 356 15.661 688,28 1,02 1,72

685,00 684,30 14.554 14.345 353 13.992 683,22 1,08 1,78

680,00 679,30 12.969 12.777 349 12.428 678,15 1,15 1,85

675,00 674,30 11.486 11.306 346 10.960 673,06 1,24 1,94

670,00 669,30 10.103 9.920 342 9.578 667,92 1,38 2,08

655,00 654,30 6.555 6.422 331 6.090 652,57 1,73 2,43

640,00 639,30 3.984 3.895 321 3.574 636,92 2,38 3,08

625,00 624,30 2.183 2.119 314 1.805 620,78 3,52 4,22






2011

CIL TMF No.2 dam

Crest of wave

level

h

guard Water level

Tailings

facility

volume

Volume

water level

High flood

volume

Tailings

volume

Deposition

level

H

High flood

h

safe

elevation

[mdM] [m] [mdM] [thous.c.m] [thous.c.cm] [thous.c.m] [thous.c.m] [mdM] [m] [m]

1 2 3=1-2 4 5 6 7=5-6 8 9=3-8 10=9-2

827,50

0,70

826,80 8.147 7.968 233 7.735 825,88 0,92 1,62

825,00 824,30 7.510 7.338 231 7.107 823,34 0,96 1,66

822,50 821,80 6.908 6.743 229 6.513 820,80 1,00 1,70

820,00 819,30 6.332 6.179 227 5.952 818,25 1,05 1,75

817,50 816,80 5.794 5.645 225 5.420 817,71 1,09 1,79

815,00 814,30 5.273 5.135 223 4.911 813,17 1,13 1,83

812,50 811,80 4.786 4.647 222 4.425 810,62 1,18 1,88

810,00 809,30 4.310 4.184 220 3.964 808,05 1,25 1,95

805,00 804,30 3.450 3.341 216 3.124 802,88 1,42 2,12

800,00 799,30 2.711 2.618 212 2.406 797,81 1,49 2,19

795,00 794,30 2.083 2.050 209 1.841 792,79 1,51 2,21

790,00 789,30 1.559 1.495 205 1.290 786,95 2,35 3,05

785,00 784,30 1.131 1.080 202 878 781,40 2,90 3,60

780,00 779,30 788 748 199 549 775,58 3,72 4,42






2011

Calculul volumelor de precipitatii acumulate in iazul CIL la nivel coronament 780 mdMN (baraj starter)

fara oprire uzina cu oprire uzina fara oprire uzina cu oprire uzina

20,00% 43,06 mm 17,59 mm 295700 mp. 60600 mp. 6745 mc. 3024 mc./zi 509 mc./zi 13 zile

10% 51,65 mm 26,59 mm 295700 mp. 60600 mp. 9381 mc. 3024 mc./zi 509 mc./zi 18 zile







Calculul volumelor de precipitatii acumulate in iazul sterile flotatie la nivel coronament 625 mdMN (baraj starter)










Nota: Cu rosu este situatia in care uzina se opreste - situatie acceptata de beneficiar

Volumele de precipitatii pentru asigurarile de pana la 1% au fost calculate tinandu-se cont de faptul ca precipitatiile din amonte de canalele de garda sunt preluate de acestea.

Volumele de precipitatii pentru asigurarile de peste 1% au fost calculate fara a se tine cont de canalele de garda.

Calculul volumelor de precipitatii acumulate in iazul CIL la nivel coronament 827,5 mdMN (cota maxima a iazului)










Calculul volumelor de precipitatii acumulate in iazul sterile flotatie la nivel coronament 707 mdMN (cota maxima a iazului)










Nota: Cu rosu este situatia in care uzina se opreste - situatie acceptata de beneficiar

Volumele de precipitatii pentru asigurarile de pana la 1% au fost calculate tinandu-se cont de faptul ca precipitatiile din amonte de canalele de garda sunt preluate de acestea.

Volumele de precipitatii pentru asigurarile de peste 1% au fost calculate fara a se tine cont de canalele de garda.

AsigurareStrat cazut

precipit.

Strat scurs

precip. (hs)

Supraf. luata in

calculSupraf. iaz

Volum

precipitatii

Capacit. statie epur.

ape iaz flotatie

Debit pompare Timp necesar pentru evacuare ape

Supraf. iaz

Supraf. iaz

Supraf. iazVolum

precipitatii

Capacitate statie

Detox2

Debit pompare Timp necesar pentru evacuare apeStrat scurs

precip. (hs)

Supraf. totala

luata in calcul

Asigurare

Asigurare

Strat cazut

precipit.

Strat cazut

precipit.

AsigurareStrat cazut

precipit.

Debit pompare Timp necesar pentru evacuare apeStrat scurs

precip. (hs)

Supraf. totala

luata in calcul

Strat scurs

precip. (hs)

Supraf. luata in

calcul

Volum

precipitatii

Capacitate statie

Detox2

Volum

precipitatii

Capacit. statie epur.

ape iaz flotatie

Debit pompare Timp necesar pentru evacuare ape



„Amendments to the technical documentations EIS Report, SR, IpCT, requested by

the Ministry of Environment and Forests for the application


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These calculationscoinsidered the rainn falling on the pond to which no flowing

coefficient was added.

The new tables indicate the data presented for the CIL TMF starter dam (780 mdMN) and

for the Flotation TMF (625 mdMN), as well as to the maximum level of the TMF‘s (827,5

mdMN for CIL TMFand 707 mdMN for Flotation TMF). Further to the data it can be noticed

that, as the dams rise, the deposition surface areas are larger while the water level is less raised in

case of some precipitations. The calculations were made up to a 0.01% rate while for the rain

falling on the TMF and forming a rainwater layer (hs) there have been use dthe data of the

INMH studies with coefficient of reduction for the valley sides and without such coeffciients for

the TMF surface.

When proceeding with a 1% to 0,5% probability, there is a sudden increase of the tailings

facility surface because over the 1% probability the guard channels are no longer taken into

account consdiering that in such cases it is very likely that all the water from the valley sides will

reach the tailings facility surface area.

The surface area of 6 ha represents the minimum surface considered for calculation, and

with such area the clarified water discharge system can run ( in case of a smaller surface area the

water clarification in the tailings facility does not occur).

The data presented above represent the calculations according to to the current

dimensions of the treatment and pump stations from the tailings management facilities for the

two sceanrios ( stopping the runnning of the plant and no stop of plant running)). It is considered

that the palnt will be running unde rnormal conditions up to a 1% safeguard. From the tables

presented, it is noticed that the level of the water acumulated in the tailings facilities rises only

366mm in the CIL TMF and 353 mm in the Flotation TMF, under the worst scenario at the early

stage of the TMF‘s running. Thes elevels do not raise any concerns for the tailiungs facilities

where the guard was calculated with much higher values. For a 1% safeguard, the plant will be

stopped during the water discharge of the TMF‘s and it is accepted by the beneficiary.

The rainfalls with 1% return up to 0.01% rainfalls can remain on the TMF‘s for 2 months

without no risks. Under such extreme rains the treatment of the accumulated waters in the

tailings facilities will take 23-57 days for the CIL TMF and 23-59 days for the Flotation TMF.






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2.1.5 Protection fo underground water

According to the art.2 of the Directive 2006/118/CE about the underground water

protection against pollution and deterioration, „the discharge of contaminants in the

underground waters‖ means the direct or indirect inputs of the contaminants in the underground

waters as a result of humana ctivity. The guideline “Water use WAT-PS-10-01 - Assigning

groundwater assessment criteria for pollutant inputs‖, Scottish Environment Protection Agency

(SEPA), March 2010, define the indirect input as:

- infiltration throuhg the saturated zone ,

or

- its source is entirely situated within the non-saturated zone even during the season

fluctuations of the underground water level (see figure 7):

As for the indirect discharges, the annex A point 1. 6 of the guideline above indicate that

the „Directive 2000/60/EC takes into account that the discharge of matters from list II represnets

an activity which can cause pollution. The Directiva 2006/118/EC requires measures to regulate

these discharges from punctiform sources of pollution. The two directives have the same goal ,

and despite it, the Directive 2006/118/EC is more restrictive in the sense that it applies to all the

contaminants not only to those of the List II of the Directive 2000/60/EC.






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In accordance with the Directive 2006/118/EC. Article 6 – Measures for the

prevention or restriction of the contaiminant discharges in underground waters correlated

with the Directive 2000/60/EC . Article 4 – Environmental targets, referring to the

underground waters, the member states apply the required measures to prevent or restrict the

discharge of the contaminants in the udnerground waters to avoid the deteriorartion of all

underground water bodies, (direct discharges of contaminants in underground waters are not

allowed).

In the meaning of the Directive 2000/60/EC , the following definitions are applied:

- „underground water”: means that all the waters at the ground surface in the

saturated zone and in direct contact with the soil and sub-soil;

- „aquiferous”: mean one or more undrground layers of rocks or other types of

geological layers with a sufficient porosity and perviousness to allow either the flowing of a

significant amount of underground water, or the catchment of significant underground

water amounts;

- „underground water body”: mean a distinct volume of underground water from

one or several aquiferous.

The first aquiferous ( that is the upper one) indicate two zones of underground water :

non-saturated zone ( the upper one) and the saturated zone ( the lower one), separated by the

cloth surface. The saturated zone includes the solid-water complex and closes the underground

water cloth. All the voids are filled with water, the saturation coefficient is equal to 100%, while the

humidity reaches its maximum value.

The upper surface of this zone is even the cloth surface. The thickness ranges depending on

the geologicla structure and supplying rate.

From hydrology point of view, the rocks are classified as follows:

1. Pervious rocks – allow the water flowing through their pores. They can be: granular

(formed of grain material and generallly non-uniform); fissured (consisting of impeervious rocks

but with fissures with different sizes).

2. Semi-pervious rocks – water is circulating with high difficulty.






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3. Impervious rocks – do not allow the water flowing.

In relation with the perviousness, the rocks are classified as follows:

- Aquiferous rocks – have over- capillary pores and water sttorage capacity , but also it is able

to let it flow ( gravels, sands, sandstones, weakly cemented congglomerates, lumps etc.,).

- Aquiclude rocks – have capillary and sub-capillary pores with storage capacity , but

having a small capillary porosity and a low water ciculation rate and only under pressure they

are not able to let water flow ( clays, marns).

-Aquifuge rocks – consolidated rocks where the water does not penetrate because of

the very ,low porosity ( eruptive, metamorphiv, sedimentary cemented rocks)).The water

circulates only through the fissures.

In the Report to the Envrionemtnal Impact Assessment chapter 4.1 watrer sub-chapter

4.1.1.2 Quality of underground water, the following comments are made:

„The level of the underground water resulted at the infiltrations of the meteoric waters is

about 80m below the 410 m level (Hondol pit). The water flow-rate of Nicodim gallery which

collect the infiltrated meteoric waters of the open pit is small, below 1l/s and the water is

strongly mineralized having an electric conductivity of 12600 s/cm and a pH of 2,2 - 3.

The colluvial and alluvial deposits of the valley floors and from their marginal zones may

contain shallow underground water and thes edeposits usually constitute the water sources for

the wells used by the local communities. In general, the dwellings form the neighbourhood of the

investigated zone are located on upper levels compared to the industrial projects ramps (Bocşa

Mare and Bocşa Mică villages) and the quality of the underground water of the wells used by the

residents will not be impacted by the operations to be developed within this zone.

To reveal the quality of the phreatic cloth within the impact zone of the activities

developed by Certej Mine there were conducted investigations for the environmental balance-

sheet level II (INCD ECOIND, 2006)

Additionally there have been made attempts to analyse the underground water quality in

corrrelation with the the provisions of the Directive 2006/118/EC about the underground water

protection against pollution and deteriorations transposed in the Romanian legislation through






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the Government Decision no.53/2009 about the approval of the National Plan for the

underground water protection and deterioration and of the Order o the Ministry of Environment

no.137/2009 approving the threshold values for the underground water bodies of Romania (3.

Directorate of Mures Waters) for the following indicators: ammonia, chlorides, , sulfates,

arsenic, cadmium, lead, nitrites. Further to the analyses it was noticed that the in investigated

region there is no underground water body which make the object of specific analyses and this

otherwise clearly explained in the own investigations. Thus, considering the lack of specific

threshold values for the region considered, there was no possibility of correlation between the

concentrations obtained as a result of the sample analyses with certain values of the threshold

concentration values. Despite all these, the admissible values stipulated by the Law of drinking

water are more restrictive than in many cases compared to the values established by the OMM

no.137/2009.‖

To better reveal the current situation of the underground water quality in June 2010 there

was conducted anothe campaign of water sampling by means of several drill holes /wells (their

location is presented in the annex 4.1.1 1 chap.4.1 Water of the Report to the Environmental

Impact Assessment):

The water samples have been analyzed at the accredited determination laboratory for

water quality - - Târgu-Mureş, of "Apele Române"National Administration, Mures River Basin

Administration. The results obtained are given in the table 4.1.2. of chapter 4.1 Water of the

Report to the Environmental Impact Assessment, photocopies of the bulletins of anaysis are

attached in the Annexes to the same chapter.

Conclusions (Report to the Environmental Impact Assessment chap.4.1) :

No significant aquiferous occur in the zone; the depth circulation of the underground water

takes place at tje fracture system level.

The underground aquiferous which are to be impacted of the open pit, waste dump and

tailings facility zones are small and do not constitute drinking water sources.

Within the zone of the future mine, the underground aquiferous will not be subject to

significant modifications of the quality. The quality indicators of the phreatic water were not






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aubject to significant modifications, not even under the historical pollution circumstances

caused by the old mining works of the zone.

The new mining works will determine local modifications of the flowing direction of

uinderground water because of the specific planning works of the open pit zone.

In the zone of the tailings management facilities there have not been identified any

underground aquiferous at the depth of 60m at places where the drill holes for the hydro-

geology studies have been drilled.

În zonă nu există lucrări amenajate (puţuri sau lacuri cu prize) pentru alimentarea cu apă

potabilă a localităţilor.

The Report to the Environmental Impact Assessment chap. 4.1 indicates:

„c. Zone of the Flotation and CIL TMF‘s –V. Măcrişului

.... Within this zone, there were carried out in July 2008 geological prospecting drill holes

, namely in the hydrograhoc basin of Paraul lui Avram (depth 60 m), Valea Măcrişului (depth 60

m) and at the confluence of the two streams (depth 21 m). The hydrostatic level of the

underground water was not intercepted up to the drilling depth.

The underground aquiferous of the proposed location site of the tailings management facilities

are probably small and do not constitute drinking water supply sources.‖ (excerpt pag. 9)

„The tailings management facilities are located on hornblende andesite and Săcărâmb biotite

type (rooted bodies and lavas) and bodies rooted in quartziferous andesite with biotite and

Cetraş hornblende , formations with low fissure permeability. It gives a natural protection to the

geological structures below the tailoings management facilities. ( excerpt pag. 90)

„The tests performed indicate that the rock is little fractured and the perviousness is

lower than 10-9

m/s. It is to be specified that the document Reference document on best available

techniques for Management of Tailings and Waste-Rock in Mining Acitivities‖, chap. 4,

dstribuited by the European Counciul in January 2009, recommends that the sub – layer

perviousness is not higher than 10-8

m/s,because if otherwise, sealing measures are required to

reduce this admissible limit value. The results obtained so far suggest that the investigated site






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meets this requirement and no sealing measures are required . It is posisble that later on, once the

superficial layer is removed, there are identified zones with high perviousness because of the

fractures . In this case, the sealing of the portions in discussion will be made choosing a solution

in compliance with the concrete situation on the site .

.... Further to the investigation of the values obtained it is noticed that the calculated rate

of the water infiltration in the sub – layer is very low. This result is complying with the low

values of the eprmeability both for the tailings stored in the tailings facility and of the host rock.

The simulation achieved using the SEEP/W indicate that 95-98% of the water infiltrating in the

tailings deposits upstream the dam, crosses the dam body and the remaining 2-5% penetrate the

host rock beneath the tailings management facility. This is a conclusion valid for both TMF‘s.

Considering the permeability calculated for each of the units that constituting the two TMF‘s and

the obtained mathematical model it is concluded that the draining dams built of rockfill and the

existence of a drainage filter wof 3m thick is efficient for the fluid drainage from the tailings so

that they infiltrate at very small extent in the host rock. ‖ (excerpt pag. 93-95)

To establish the geotechnical parameters of the land and the foundation conditions the

investigation works continued between 2008-2010.

Within the location zone of the two tailings management facilities and respective dams (

Flotation and CIL TMF‘s) there have been completed open shafts and drill holes. All shafts, with

no exception, once they crossed the soil, delluvium or detritus stopped when reached the

bedrock, represented by mostly fresh andesites. Only close to the surface over depths between

0.10m and 1.00m the andesites are fissured and oxidized. There have been made attempts at the

laboratory „Geomecanică” of University of Petrosani. The rock quality is expressed by the

recovery coefficient established by means of the drill cores logged on site (RQD).

According to the tests and determinations performed pn the samples from the drill

holes, viziting shafts, the values of the physical – mechanic characteristics of the rocks from

the tailings management facility sites indicate the presence of rocks ( andesites) which

constitute a good foundation ground.






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Based on the results obtained with the investigations performed there has resulted that the

covering formations ( consisting of soils, delluvium or detritus and sometimes fissured and

latered andesites of up to 2.10m thick at some zones) show physical and mechanic properties

which do not allow their use for the dam construction. To get to a good rock for foundation it is

necessary to remove the superficial rock layer over the whole surface of the dam territory.

According to the design, an average 3m thickness has been provided for the riverbed zone and

1m in the valley side zone.

In IpCT item 26 (pag. 237-242) details about the Geologica Data about the tailings

manage,ment facility location site are presented.

In conclusion, it is not necessary to implement some impermeabilization measures for the

tailings facility site and waste dump sites because there is no aquiferous in the zone , maybe only

at big depths and the non-saturated zone consist of aquifuge rocks which are actually impervious.

This conclusion has been confirmed by the REPORT OF THE SURVEY/APPROVAL OF

THE TECHNICAL DOCUMENTATION ABOUT ―dams of the GOLD-SILVER ORE

MINING OF CERTEJ PERIMETER, HUNEDOARA COUNTY” TO OBTAIN THE SAFE

OPERATION PERMIT, developed in December 2010 by eng. Alexandru

CONSTANTINESCU, Expert for teh assessment of the safety condition of the dams and dykes

for industrial waste storage facilities, which at chap. 12. Recommendations specify that: „It is

not necessary to carry out piezometer drill holes on the slopes. As indicated by the geological

studies, because of the rocky characteristics of the valley sides with low fissures , there is no

piezometer level. ‖.

2.1.6.Prevention of an accident asimilar to the one of Baia Mare

The documentation Documentația „Survey/approval of the technical documentation about the

gold-silver ore mining of Certej perimeter, Hunedoara county‖ underlines in chapter 13

Conclusions:„ Further to the review of the technical design of these dams there results that the

solutions designed comply with the engineering practice in the field and complies with the safety

requirments provided by the Romanian regulations and International recommendations in the

field. ”






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In November 2010 The Technical University of Construction Buchares (UTCB)

developed the „The risk study for the tailings management facilities dams of the gold-silver

ore mining of Certej perimeter” . This study „aims at the quantifying and analyzing the

occurrence probabilities of some negative consequences downstream the tailings facilities of the

gol-silver ore mining project of Certej perimeter, as a result of some major failures or dam

bursts. The quantifying and analysis of the probabilities deserve to see to what extent the safety

of the dams from the TMF‘s complies with the currently accepted safety of the retention dams

and tailings management facilities.

The study establishes also to what extent the dams corresponding to the two tailings

management facilities – flotation and CIL TMF‘s – provides the safety allowance againts the

uncontrolled discharge of water and tailings and reveals the measures to prevent such event

throughout the facility operation stage ‖

The conclusions of this study indicate:

„ The risk study quantified the burst probabilities – burst being defined as „loss of contaminated

water and tailings downstream the Flotation TMF dam” – and of the probabilities regarding the

occurrence of some incidents with downstream impact.

The study was carried out using the consequence tree method. There were considered the CIL

TMF dam which burst would be the trigerring event for the risk analysis of the flotation TMF

dam and then the Flotation TMF dam. For each of the dams the chracateristic stages of their

evolution were reviewed and namely the starter dam construction , the first centreline rise and

the further rises.

The triggering events of the critical burst scenarios consisted of the catastrophic precipitations,

strong earthquakes and staic liquefying. For the Flotation TMF dam the water and tailings

discharge was considered for the case when the dam fails.

Assessment of the study results revealed that:

No sequence of critical events which would result in dam burst, indicate an occurrence

probability higher than 10-7

(one to 10 million years).






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The maximum probabilities of dam burst are lower by one magnitude order compared to

the admissible limits established by the Romanian standard about the „ Analysis and

assessment of the risk associated to the dams‖.

The burst probabilities and the occurrence of some ioncidents with downstream impact

are lower than those usually considered as criteria for the water retention dams or for

other engineering structures..

The particular safety of the dams from Certej mining exploitation is due to the type of dams , to

the construction of the dam bodies made of rockfill of good quality from the quarry, consolidated

using the same techniques like for the water retention dams, claearances able to retain water

volumes generated by maximum credible precipitations and to the monitoring system of the

design..‖ (Page 34 Risk study)

2.1.7 Trans-boundary Impact ul în context transfrontieră.

The provisions of the Convention of Helsinki about the trans-boundary effects of

Industrial Accidents apply to Certej Project,too , because of the following reasons :

it develops activities using one or several dangerous matters which amounts can be

equal or even bigger than the limits stipulated by the Annex I to the Convention (cianura de

sodiu),

they are located in the water basin of some trans-boundary water basins( Mureş

river) so they could generate a trans-boundary effect.

In accordance with the „guidelines establsihed for facilitating the identification of the

dangerous activities in the meaning of the Convention‖, paragraph 5 „Criteria corres[onding

to the location”, will be applied the following criteria of the lcoation site for identifying those

dangerous activities able to cause trans-boundary effects in accordance with the Convention

provisions:

(a) over a distance of 15km from the boundary for the activities implying the use of

substances that can start up a fire or an explosion involving the use of toxic substances that could

be released in the atmosphere in case of accident;






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(b) along or within the water basins of the trans-bounadry and boundary river coursesof

the trans-boundary lakes or within the water basins of trans-boundary underground lakes or

international lakes for activities involving the use of substances of the 3, 4, 5 or 8 categories of

part I of the Annex to the Convention and which can be released in the water courses in case of

accident.

If such an activity is or is not able to cause a trans-boundary effect , this is to bed ecided

by the entitled authority of the original part , preferrably further to the consultations with the

relevant authorities (any bilateral commission or multi-lateral commission or any other such

institutional cooperation methods established between the riperian parties). The decision must

depend among others, on the presence of some alarm and warning systems within the water

basins and the distance between the location of the dangerous activity and the border (Joint

group of experts for waters and industrial accidents constituted ad hoc so that this distance

corresponds to a distance required for a two days flowing at an average rate of the river flow-

rate)

Având în vedere că distanţa până la cea mai apropiată graniţă este de cca. 130 km, nu se

pune poblema unor efecte transfrontieră pe calea aerului.

Also, the distance along the water courses corresponds to a duration of flowing at

average flowrates of about 44 days , so the activity within the Project would not cause any trans-

boundary effects on the water course either.

Details about the potential impact assessment under trans-boundary circumstances are

given in: ―REPORT ABOUT THE CUMULATED AND TRANS-BOUNDARY IMPACT

ON AIR QUALITY OF ROSIA MONTANA AND CERTEJ PROJECTS” , developed by

S.C. WESTAGEM S.R.L. Bucharest in November 2009 and the ― POTENTIAL IMPACT ON

THE QUALITY OF WATER MURES BASIN IN CASE OF ACCIDENTAL

DISCHARGES FROM ROSIA MONTANA AND CERTEJ MINING PROJECTS”,

developed in November 2010by Professor Steve Chapra Tufs, Boston University and

Professor Paul Whitehead, Oxford Centre for Water research, Oxford University.






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2.2. Non-technical abstract.

2.2.1 Clarification – Water balance in the process

According to the balance-sheet of water used in the process, the average flow-rate of

water proposed to be caught from Mures River is approximately 60 l/s representing less than

0.04 % of the multi-annual average flow-rate and less than 0.22 % of the minimum multi-annual

flow-rateof Mureş River within the sampling sector.

Consequently, from quantity point of view, it can be considered that this will not result in

a significant impact on Mureş River.

Details are given in RIM chap 4.1 pag 46-47:

„„4.1.2. Water supply

In the Annexe 4.1.7 it is presented the water consumption balance-sheet and it has been

noticed that the drinking water consumption is 3.9 c.m/h ( about 1,1 l/s) and thus, it can be

supplied from the source presented in chapter 1.. The average industrial water consumption

which is to be supplied from Mureş River, is 214.76 c.m/h (about 0,06 c.m/s) the rest being

supplied from the meteorical water falling on the waste dumps and open pit and tailings

management facilities as well as by highly recycling the process water ( the water recycling is

over 84 %).

According to the hydrological monitoring data referring to Mureş River in the relevant

sectors related to the Project the quantitative characteristics of the process water source are

presented below:

GELMAR hydrometer station situated upstream the confluence with Geoagiu river

Multi-annual average flow-rate between 2005-2009 - 142 c.m/s;

Maximum flow-rate between 2005-2009 - 765 c.m/s;

Minimum flow-rate between 2005-2009 – 28,2 c.m/s.

BRĂNIŞCA hydrometer station situated downstream the confluence with Cerna river

The multi-annual average flow-rate between 2005-2009 - 187 c.m/s;

Maximum flow-rate between 2005-2009 - 889 c.m/s;

Minimum flow-rate between 2005-2009 – 41.0 c.m/s.






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Taking into account that the average water flow-rate to be caught from Mureş River is

about 60 l/s and represents less than 0.04 % of the multi-annual average flow-rate and less than

0.22 % of the mutli-annual minimum flow-rate.

The average minimum monthly flow-rates of the future proposed catchment location is

given below :

- Q80% - 30 m³/s;

- Q90% - 23.5 m³/s;

- Q95% - 21.4 m³/s;

The estimation was carried out based on the values provided by the Sǎrvârşin hydrometer

station situated downstream the propsoed catchment sector where the multi-annual average flow-

rate is slightly higher compared to the values recorded at Brǎnişca station near the catchment

location (source: http://www.directiaapelormures.ro/proiectul_planului_de_management.html).

Consequently, it can be considered that the catchement will not have a significant impact

on Mureş River from quantity point of view.‖

2.2.2. Clarification – relief modification.

The considerations of the non-technical abstract regarding the ―modification of the relief

and water flow regimes‖strictly delas with the impact caused by the significant amounts of waste

rocks generated by the exploitation and processing of the ore, while referring to the ―impact on

the underground water quality‖it is related to the risk of pollution of the underground wter by the

acid water generated from the open pit.

The detailed assessment of these impacts ( on which basis the conclusions of the Non-

Technical Abstract was drawn up and according to which the expected negative impact is minor

regarding the modification of the relief and the water flowing regime because of the significant

amounts of waste rocks and respectively, positively significant referring to the risk of

underground water pollution with the acid waters generated from the open pit) is presented in the

Report to the Environmental Impact Assessment (RIM) chapter 4.6 for the relief modification ,

http://www.directiaapelormures.ro/proiectul_planului_de_management.html






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in the RIM chapter 1 and 4.1 for the modification of the water flowing regime and in the RIM

chapter 4.1 for the pollution risk of the underground water pollution.

For making easier the review of the data , there are presented below the excerpts from the

original documentations referring to each of the issues mentioned:

a. Modification of the relief is mainly caused by the open pit operations and the waste

rock dumping and tailings facilities. Even now, the relief is modified as a result of the previous

mining operations ( the void resulted at the open pit works as well as the ground rises at the

waste rock dump sites) . The proposed Project will produce a significant increase of the surface

area and depth of the void existing in the open pit, the two waste dumps will be higher and will

fill part of Măcrişului valley. This impact will be mitigated and compensated by the ecological

rehabilitation works to be completed.

The assessment of this impact is detailed in the sub-chapter 4.6 ―Landscape ―of the

Report to the Environmental Impact Assessment (RIM):

―The results of the baseline study indicate that both the landscape and the habitat structure has

been significantly impacted by the human activities.. The zone deterioration can be grouped in

two large categories, namely the deterioration caused by structural modifications of the

landscape and deterioration caused by the modification of the eco-system. These modifications

have been assigned to the historical mining works and the resulting pollution related to those

works ( including acid waters), transformation of natural systems in pastures lands, human

settlements and forest plantations and renewable resource exploitation ( such as the wood

exploitation). All these factors determined the significant impact on flora, fauna and natural

habitats of the zone determining the ―landscape modification.‖ (excerpt pag. 8-9)

―The relatively small surface area occupied by the project, the remote position and the limited

sights determine a minor impact on the regional landscape.

Locally, ( within the project impact boundaries), the impact on the landscape will be significant

by modifying the traditional use of the lands, modification of the topography, vegetation and






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impact on human settlements. The current features of the landscape will be permanently

changing by continuing the mining operations.‖ (excerpt page 11)

―On a long term, the impact on the landscape will be mitigated by the implementation of the

rehabilitation/restoration site plan. It assumes also the placement of a grass carpet and

development of pastures on the tailings facility surface, the partial flooding of the open pits to

create lakes with rocky valley sides and rehabilitation of the vegetation on the waste rock dumps

for the rehabilitation of the land use as it was prior to the min ing operation development within

these areas. The open pit excavations and the tailings facility beaches will determine a major and

permanent modification of the local landscape. But the sile will be entirely covered again by

vegetation during the closure stage planting indigenous species to re-establish the plant

communities and natural models. Although the existing shape of the land will be permanently

modified the traditional landscapes will be re-established by replanting and re-introduction of

some similar land uses.

…….

The topography modification caused by the project implementation is permanent. The impact of

these structures on the landscape will be mitigated by landscape architecture works integrating

the respective structures within the environment as recommended by the standards in force, too..

The main method for the visual impact mitigation will consist of the gradual and continuous

rehabilitation throughout the whole period of the exploitation stages. Finally, during the slosure

stage the soil and vegetation will be put in place , the dwellings,power lines, pipelines and

haulage roads will be decommissioned, the waste rock dump and tailings storage sites will be

rehabilitated, the dumps will be stabilized and the disturbed sites will be remodelled and covered

with vegetation.

At the Project work closure the impacted zones of the project impact area will be gradually

covered with grassy vegetation in a first stage.‖ (excerpt pag. 20-21)

b. Modification of the surface water flowing regime is caused by the regularization

works and diversion of surface water courses (Valea Băiegii, Valea Măcrişului, Valea Corănzii

creeks). These works are meant to prevent the water contact with the mining works or the

existing mining wastes or minign waste dumps to be built during the running period of the






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project (there is a significant mitigation of the current pollution of the surface waters and their

pollution during the project running life is prevented) and represent the main mitigation

measures of the impact on water environmental element.

The detailed description of the works resulting in the modification of the surface water

flowing regime is given in the chapter 1 of the Report to the Environmental Imapct „General

Information‖:

“C. Works performed prior to the construction of the flotation tailings management facility dam

For the dam construction, the following prior works are to be completed:

-The gallery for the collection of Macris creek water will be built beneath the main dam. To

prevent the floats or large size material penetration in the gallery, the upstream end of the gallery

will be provided with a bottom grate with 10cm spacing between the bars. This grate will be

decommissioned when the connection with the upstream sector is made.

The gallery was sized for a flow-rate of 19m3/s. The gallery opening will be 2m at its base , it

will be made of reinforced concrete, it will follow the valley route, will take over the water of

Macris and Icoanei creeks from the tailings facilities sites.

The gallery length on Valea Măcrişului will reach 2,400m and 615 m on Icoanei creek. In the

main gallery, during the construction stage, the 400mm diameter lateral drains of polyesthers

reinforced with glass fiber (PAFS) will be connected.

After the tailings management facility rise and reaching the final level these pipes will be no

longer functionning and the pluvial water will be collected by the perimeter guard channels .

......

D. Works performed prior to the construction of the CIL tailings management facility dam

The following works are to be carried out to build the dam:

- The gallery for the collection and discharge of water of Macris creek beneath the main dam. To

prevent the floats or large size material penetration in the gallery, the upstream end of the gallery

has been provided with a bottom grate with 10cm spacing between the bars. This grate will be

decommissioned when the connection with the upstream sector is made.‖ (extras pag 15-16)






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„Catchment and discharge of waters from North waste dump site (Annexe 1.10)

This is done for the canalization of Corănzii creek within North waste dump zone to discharge in

a controlled manner, the Floroaia and Pârâul lui Toader creeks discharge , .

The canalization of Coranzii creek within North waste dump zone will include the following

works:

-Gallery for the discharge of water flows beneath North waste dumps , it will be 740m long and

unique profile which ias half excavated in he host rock and half of it is made of reinforced

concrete.

The gallery will discharge the maximum flow-rates: Qmax 1% = 8,65 mc/s

- Constructions designed on Coranzii creek (Floroaia), upstream the water input in the gallery:

- Riverbed planning works over a L = 20m, with coarse stone and cement mortar

consolidation dry walls and 2 dips with h = 1,50m

- The loading basin will be made of reinforced concrete with (5,00 x 10,0) m szies and

6.50m deep.

- The upstream gallery gate will be made of reinforced concrete with the following sizes h

= 7,0m, b= 5,0m and d = 1,0m

-The constructions downstream the gallery consist of:

Downstream gallery gate of reinforced concrete with h = 7,0m, b= 5,0m and d = 1,0m

Energy dissipator made of reinforced concrete with (5,00 x 10,0) m sizes and h = 6,5 m

Coranzii creek riverbed planning works over 125m length in order to make the

connection of the gallery to the natural riverbed.

Catchment and discharge of waters from South waste dump site (Annexe 1.1)

It represents the entire water works aiming at the claring of Coranda – Certej and South waste

dump sites by the diversion of Ciongani creek and its tributaries (Grozei, pr. Borzii, Vale 1 and

Vale 2 creeks ) in the neighbouring Pârâul Mare water basin.

The Open Pit and South waste dump were situated along pr. Ciongani creek and thus Coranda

ore open pit occupies the right valley side of pr. Ciongani creek from the confluence of

confluenţa pr. Ciongani creek with pr. Grozii creek (East boundary) and up to pr. Măcrişului






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creek riverbed (West boundary) while South waste dump occupies the left valley side of pr.

Ciongani creek , at about 100m from the cross point with the communal road from Bocşa Mică

with pr. Izvorul Zgibuleşti creek ( east boundary) and up to about 400m from the riverbed of pr.

Măcrişului creek (West boundary).

To carry out the prposed works on site: For Coranda Open Pit and South waste dump it is

necessary to carry out the diversion of the matural water courses with either permanent or non-

permanent flows (creeks, torrents).

The dievrsion system of the surface waters will include the following works:

1)Guard channel on the East boundary of Coranda Open Pit, (L = 250m) sized for a Q max

1% = 0,70 c.m/s, with V profile with b = 0,50 m, h = 1,00 m, 1:m = 1:1. The channel will be

made of dry coarse stone walls and a mortar and cement stone revetment at the inner side of the

channel. Cthe guard channel will discharge the flows in pr Grozei creek upstream the intake

dam.

2)Joint catchment of Ciongani and Grozei creeks called C1 in the design, has been designed

with an intake dam made of rockfill and located across pr. Ciongani riverbed, downstream the

confluence with pr. Grozei creek. The collected flows will be discharged through a channel

which will cross the dam and which has been designed for a Q max 1% = 18,52 c.m/s and

tested for a Q max 0,1% = 31,85 c.m/s. The test channel collection of flow-rates has been carried

out to check the intake dam water overflow for 0.1% excess probability. Also, the first sector of

the diversion channel ( from the intake dam at the confluence with pr. Borzei creek) has been

designed for a Q max 1% and tested for a Q max 0,1%; further on the diversion channel has been

sized only for a Q max 1%, no checking for a Q max 0,1% - according to the provisions of the

STANDARD 4273 – 83.

3)Channel discharing the collected flows in pr. Pârâul Mare creek.

The diversion channel has been divided in the following 5 sectors:

- Sector I, L =40 m, V profile b= 2,00m, h = 2,30 m, 1:m = 1:0,5 with a rectangular

profile basin at the base b = 1,00 m, = 0,50 m , Q1%= 18,52 c.m/s, h1% = 1,07 m, Q 0,1%=

31,85c.m/s, h0,1% =1,47 m






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- Sector II, L =110 m, V profile b= m, h = m, 1:m = 1:0,5 with arectangualr profile basin

at the base ,b = 1,00 m, = 0,50 m, Q1%= 22,11 c.m/s, h1% =2,11

- Sector III, L = 760m, V profile b= m, h = m, 1:m = 1:0,5 with a rectangular profile bsin

at the base b = 1,00 m, = 0,50 m, Q1%= 23,25mc/s, h1% = 2,17m

- Sector IV, L = 490 m, V profile b= m, h = m, 1:m = 1:0,5 with a rectangular profile

basin at the base b = 1,00 m, = 0,50 m, Q1%= 24,88mc/s, h1% =2,25m

- Sector V, L = 100 m, V profile b= m, h = m, 1:m = 1:0,5 with a rectangular profile basin

at the base, b = 1,00 m, = 0,50 m, Q1%= 24,88mc/s, h1% =2,25m

4)Lucrări pe canalul de deviere: 3 captări de afluenţi (pr. Borzei, Vale 1, Vale 2), 3 dips h =

0,50 m, 5 dips with h = 0,75m, 1 culvert for the loacl road crossing the channel

5) Regularization of pr. Pârâul Mare creek, in order to discharge the maximum flow-rate, Q

max 1% = 5,80 c.m/s, plus the maximum diverted flow –rate of Ciongani water basin, Q max 1%

= 24,88 c.m/s. Taking into account that Pârâul Mare flows across Bocşa Mică village and the

discharged flows will be approximately 5 times higher, the resizing and consolidation of the

current riverbed consdiering the new circumstances have been proposed. The diminution of the

bottom slope from about 0.10 to 0.05%, has been proposed considering the maximum

admissible rates of the water flows . The slope diminution has been carried out by means of 70

dips with h = 1,50 m.

6) pre-fabricated concrete culverts– premo tubes, situated at the crossing point of Pârâului Mare

regulated creek course with the roads of Bocşa Mică inside built up area. They are made at the

crossing of water courses, over creeks with small flow-rates of 0-2 c.m/s, so that to carry out

urgent works so they represent temporary works which are done only under particular

circumstances and for limited uses.

The works consist of placing some Premo type tubes with 1m diameter and 6m long.‖ (excerpt of

pages 21-23)

The assessment of this impact was presented in details in the Report to The

Environmental Impact Assesment sub=chapter. 4.1 ―Water‖:






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„4.1.1. Existing situation

...

Baiaga creek

Within this zone there is an old waste dump located on the right and left valley sides and

developed along the whole old open pit edge. The waste rocks were dumped after the rpevious

diversion of the creek water to the base of the left valley side using a dry wall channel. During

the dumping operation performance, there occurred natural landslides which together with the

waste dump displacements caused the planning work damage (channel, drains ).

The diversion channel ofBaiaga creek wihtin this sector of the valley side bottom was much

damaged by the land slides.. All the fissures, cracks and dislevelment allow the direct water

penetration in the ground determining the deterioration of the physical and mechanic properties

of the basement.

On the left valley sides there are water sources at different elevations , somne of them even

above the access road. There also torrents and their existence is indicated by the ground soaking

and presence of specific vegetation of these zones.

Free water is flowing along the valley over andesite rocks.

Corănzii creek

Corănzii creek is flowing parallel to the north side of the open pit.

In Corănzii creek flowing zone there is a waste dump showing some slide events which for now

stopped. Thes eslide events determined the modification of the natural ground morphology.

Since the origin zone, Corănzii valley is widely opened with valley side slopes ranging between

5-150 partly afforested. The valley is blocked by the dumped waste rocks and a water

accumulation occurred there as a result of the water springs and valley side flows existing in the

zone. The water from this zone penetrated in the dump body. On the left valley side there are

waste rocks sliding from the dump, in a first stage along the steepest slope of the valley side. The

sliding rocks leant against the right valley side , blocked a series of torrents and created water

accumulations. Under such circumstances and considering the lithology of the predominantly






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clayous basement and the materials of the dump body (mixture of clayous rocks and altered

andesite rocks) and the existence of water with the dumped material, the sliding event enhanced

and with the time, it flowed along the valley engaging all the materials encountered. As it gets

down, Corănzii valley becomes narrower , it changes the direction and there are hill

protuberances with forests which slowed down the sliding face advance.

Măcrişului creek

In the upper zone Valea Măcrişului creek flows perpendicular to the open pit and the parallel to

the West side of the open pit.

The zone where the tailings managament facilities are to be placed is crossed by Valea

Măcrişuluicreek and its left hand tributaries (Icoanei creek), collecting from the va,lley sies the

non-permanent flow torrents. From hydrological point of view the flow-rate of Valea Măcrişului

creek is permanent and varies with the precipitation regime which determine additional flows

from gthe steep valley sides because of the torrents. Currently, the zone is covered by forests ,

bushes and pastures.‖(excerpt pag.17 – 18)

„4.1.4. Impact prognosis

a.Construction stage

.The route of the surface water courses will be somehow modified. (ex. Valea Băiegii, Valea

Măcrişului, Valea Corănzii), some water courses will be caught, regulated , channeled and/or

diverted to other pathways than the natural ones for the optimal development of the operations

during the runnning mine life. By means of these measures an additional protection of the water

courses against the pollution is carried out , taking into account that currently, some creeks are in

direct contact with the the older waste deposits which are a continuous pollution source of the

waters.

.......

Under these circumstances and taking into account the designed scale of the works, there is no

risk of major pollution or of trans-boundary pollution on the surface or underground water during

the project implementation stage. On the contrary, when the regulation local water courses works






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are finalized, an improvment of these water quality is expected as they are no longer in direct

contact with the old waste dumps .‖ (excerpt pag. 89)

„4.1.6. Measures for the impact mitigation

...For the construction stage, the main measures for the mitigation of the impact on the water

environmental element consist of the catchment, regulation, diversion of some of the surface

water courses (ex. Valea Băiegii, Valea Măcrişului, Valea Corănzii) to prevent their direct

contact with the mining works or mining waste dumps to be built during the project running

life.‖ (excerpt pag. 99)

c. The quality of the underground water quality is presently impacted in the open

pit zone because of the infiltration water ( mine water) which is acid, with high sulphate and

heavy metal contents. The Project provides the collection of pluvial waters falling on the open pit

surface and its slopes, their pumping to the treatment plant of the processing plant yard, their

neutralization with lime milk so that to comply with the maximum admissible limits of the

contaminants stipulated by the regularions referring to the quality of water discharged in the

natural emissaries and to use it in the technological process and only the excess water is to be

discharged. Consequently, the impact of the Project implementation on the environmental water

element will be significantly positive even if the mine water flow rates are less important from

their quantity point of view.

The assessment of the environmental impact is described in sub-chapter 4.1 ―Water‖ of

the Report to the Environmental Impact Assessment :

„4.1.1.1. Underground water condition

a. Within Certej deposit area

...

Reviewing the geology, geo-morphology and particularly the hydro-geology of the deposit site,

the modest existence of infiltration water, less than 0,2 l/s during the maximum flow-rate periods






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on the fractures and fissures developed both on the sedimentary and Neogene andesite deposits

within the irruptive –s edimentary contact zones has been noticed.

Within Coranda open pit no obvious evidence of the significant infiltrations occurrence has been

noticed from the open pit faces and neither was there indicated the necessity to remove the

phreatic water from the floor (+ 475 m level). Further to the open pit slope checking, there have

been noticed some particular occasional cases of infiltrations in the open pit walls, but they were

caused by the dripping water ( water resulted at rainfalls or snow melting).

......

Throughout both the exploration and geotechnical drilling program development, no significant

infiltration or phreatic water amounts have been noticed , not even at the drill holes performed at

a level lower than the proposed open pit floor at about. 330 m.‖ (extras pag. 1-2)

„The underground mining works performed along the years determined the formation of some

underground voids consisting of galleries, shafts, raises , cut and fill chambers. Throughout the

underground operations the water level had to be lowered and the water had to be removed by

pumping. By means of these processes, the original hydro-chemical regime was disturbed by

significantly increasing the aeration and pervious zones, allowing the oxidation and dissolution

chemical reactions as well as the preferred direction of the rainfall water infiltrations to the

mineralized zones. As a result, the mine water is acid, highly sulphated and with high contents of

Fe, Zn, Mn, Al, Cu, Sr, As, Co, Ni, Cr. Iron congtent is very high and it precipitates as colloidal

Fe(OH)3- or crypto-crystalline (FeOOH).

The level of underground water resulted at the meteoric water infiltrations is by about 80 m

below the 410 m level (Hondol shaft). The flow-rate of Nicodim gallery which collects the

meteoric infiltration water of the open pit is low, less than 1 l/s, and the water is strongly

mineralized with electric conductivity of 12600 S/cm and pH of 2,2 - 3.

The colluvial and alluvium deposits of the valley flloor and their marginal zones contain shallow

underground waters, these deposits usually constituting water sources for the wells used by the

local communities. In general, the households neighbouring the investigated zone arte located at

upper levels compared to the industrial objective pads (Bocşa Mare and Bocşa Mică villages),






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and the underground water quality for the wells used by the locals will not be impacted by the

activity developed within this zone.‖ (excerpt pag. 9-10)

„4.1.4. Impact prognosis

a. Construction stage

..According to the geotechnical studies performed, within the area potentially impacted

considering the topography of ground, there are no significant aquiferous or drinking water

sources. Also, the project site is located neither within the sanitary protection area and nor in

hydro-geoelogical protection area. Taking into account the specific works to be eprformed within

this stage and that the local aquiferous are small size ones being located at depth , there is no risk

of significant impact on the underground water.‖ ( excerpt pag. 89)

2.2.3 Clarification – Prevention of underground water pollution

The collection and treatment of pluvial waters falling on the open pit surface and slopes

is the measure provided by the project to reduce the acid pluvial water infiltration and diminution

of the underground water pollution presented in the sub-chapter. 9.5 of the Report to the

Environmental Imapct Assessment : Measures for the impact mitigation of the non-technical

abstract:

―7. Collection and treatment of acid water of the open pit, waste dumps and neighbouring

zones in the treatment plant located in the plant yard

Expected impact: Prevention of acid drainage and metal containing waters and gradual

diminution of the quality of natural water courses ‖ (excerpt pag. 19)

Consequently, we do not think it is necessary to complete and/.or modify the Technical

Abstract.

This measure is presented in the chapter 2 of the Report to the Environmental Impact

Assessment : Technological Processes: „The dripping water from the open pit benches are






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collected within the open pit area and from there they are pumped to the acid drainage treatment

plant situated within plant yard.‖ (excerpt pag. 2)

„a. Potential acid drainage from certej Open Pit

The acid drainage collected in the Open Pit will be pumped to the acid drainage treatment plant

located within the processing plant yard.

.....

The acid drainage ( potentially acid drainage) will be treated using the classic

neutralziation technology of the heavy metal acidity and precipitation with lime following

that the resulting water are used in the technological process and the excess water will be

discharged in the emissary (valea Corănzii creek)‖ (excerpt pag. 54)

Description of the technological flow-sheet of acid drainage treatment is given at pag. 54-55.

Also the chapter 4.1 Water of the Report to the Environmental Impact Assessment

presents data about the collection and discharge of pluvial water from the open pit yard:

„For the collection and discharge of pluvial waters and waters resulting at the ore recovery

process from certej perimeter the following works have been provided:

-the open pit berms will be arranged so that the pluvial water falling on the berms will easily

flow;

-the pluvial water of the yard will be collected in a collectiing basin and pumped to the treatment

plant of the processing plant yard;

-the pluvial water from outside the open pit will be discharged outside the open pit perimeter in

the guard channel – to prevent the water accumulations within the open pit territory;

Considering a collection and discharge system of the water generated in the open pit is built (

according to the above mentioned) the new investment will contribute to the significant

diminution of the negative impact which is currently generated by these waters on the surface

water from the zone.‖ (excerpt pag. 51)






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„- Acid drainage treatment plant – sthe plant is designed for the construction in the first year

of exploitation and will be running as long as acid drainage is collected, including the post –

closure stage. It will provide the treatment of collected waters from the open pit and two waste

dumps .‖ (excerpt pag. 59)

Details regarding the sizing of the acid drainage treatment plant are given at pag. 60-63.

2.2.4. Clarification – Emission of of hydrocyanic acid vapors

The issues referring to the hydrocyanic acid emissions at the CIL TMF surface are

presented in the Report to the Environmental Impact Assessment chapter 2 Technological

Process:

―The cyanide decomposition of the clarified solution from the tailings management facilities was

investigated by means of several specialized studies and it was concluded that the main processes

were volatilization and oxidation of cyanides. The amount of CN ions volatilized depend on the

free cyanide concentration, pH, free surface of the water surface and last but not least, the air

circulation ( wind) and agitation of the liquid surface ( waves) and do not depend on the tailings

flow-rate pumped on the tailings management facility. The cyanide oxidation is mainly caused

by the exposure to ultraviolet radiations and depends on the specific insolation of the location

zone. The specialized studies indicate that about 90 % of the total amount of cyanide lost in the

clarified solution from the tailings management facilities is caused by volatilization and the rest

by oxidation. Taking into account the climate specific conditions, the estimated composition of

the clarified solution remaining on the tailings facility and the constructive parameters of the

tailings management facility an estimated loss of about. 0,05 kg CN/h. was estimated‖ (excerpt

pag. 72)






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A detailed assessment of the impact of these emissions on the environment was carried

out and presented in the sub-chapter 4.2 Air in the Report to the Environmental Impact

Assessment:

„storage of the CIL processing tailings which could generate hydrocyanic acid emission .

The HCN emissions from the tailings management facility surface containing cyanides ( from

the CIL circuit) will occur as a result of the pH diminution in the sueprficial layers of the

solution ( allowing the HCN formation) and of desorbtion ( air volatilization) of this compound.‖

(excerpt pag. 41 – 42)

„The processing tailings resulted at the CIL ircuit and stored in the tailings management facility

after detoxication will contain cyandie at concentration below 10 mg/l. From the surface of the

tailings management facility where these tailings are stored it is possible that emissions of

hydrocyanic acid occur. Thes eemissions can be generated as a result of the pH diminution in the

superficial layers of the solution, a process allowing the formation of the HCN and the

desorbtion of this compound in the air.

The estimation of the cyanide mass volatilized under HCN form was based on the information

from the specialized literature, experimental data considering the average concentration of

cyanide from the tailings facility and climate conditions impacts. Thus, there have been

estimated the higher emission rates because of the higher temperatures and for winter time when

the volatilization rate is minimum.

An annual emission of 2.20 t/year of cyanide volatilized as HCN has been estimated, and 1.64 t

of it during the hot season and 0.56 t during the cold season resulting emission rates from the

tailings management facility of:

- Average during the hot season of the year– 379.6 g/h;

- Average for the cold season of the year – 129.6 g/h;

- Annual average– 251.12 g/h.‖ (excerpt pag. 53)

„Referring to the HCN pollution, modelling considered the non controlled emissions from the

processing plant and CIL tailings management facility. Because the Romanian legislation does






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not provide admissible limits for this contaminant, the assessment of the concentrations could be

reached only in relation with the values recommended by the forums and international

organisations such as American Conference of Governmental Industrial Hygienists (ACGIH).

These recommend an admissible value of 5000 µg/m3 on short term.

(http://www.epa.gov/ttn/atw/hlthef/cyanide.html#*)‖ (extras pag. 66)

„Operating stage – hydrocyanic acid

In the Annexes 4.2.27 and 4.2.28 there are presented the maximum hourly values and the

averaged maximum values for 8 hours of the HCN concentrations, the highest values being

located strictly in the neighbourhood of the processing plant and CIL tailings management

facility. The values do not exceed 53 µg/m3 averaged for 1 h and 40 µg/m

3 for 8 h, existing at

least 2 magnitude orders below the recommended value, mentioned above. These values are

rapidly diminished with the distance having minor values at remote distance of several hundreds

meters.‖ (excerpt pag. 79)

The issues concerning the hydrocyanic acid toxicity for people, birds and plants (

although the fish and aquatic invertebrates are particularly sensitive to the exposure to the

cyanide, the hydrocyanic acid vapors released from the CIL tailings facility are rapidly dispersed

in the atmospheric air and thus, it is little likely to be absorbed in the surface water where aquatic

life is present in the zone) are presented in the chapter 7 Risk Situation of the Report to the

Environmental Impact Assessment :

„The HCN toxicity for people depend on the exposure type. Because of the variability of the

dosage – reply impacts among the individuals the toxicity is expressed like the concentration or

dosage which is lethal for 50% of the population exposed (LC50 sau LD50). LC50 for gaseous

HCN is 100-300 ppm. The inhalation of a cyanide concentration of this value range cause the

death within 10-60 minutes, and during this time it is reduced with the increase of cyanide

concentration.






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.... originally, the cyanide poisoning can occur becuase of the exposure to a HCN concentration

of 20-40 ppm, and these can be indicated by headaches, sleepy condition, dizziness, weakness

and high pulses, deep and rapid breath, nausea and vomiting. (excerpt pag. 73)

„ b) Impact on birds

Oral LD50 related to the birds varies between 1,43 mg/kg of body weight ( wild duck) and 11.1

mg/kg of body weight (chiken). The symptoms are eye blinking, panting, salivation, lethargy and

they show within 1-5 minutes since the ingeration by the sensitive species and in up to 10

minutes for the more resistant ones. The exposure to the high dosage determined the difficult

breath followed by repeated swallows for all the species. The death rate occur within 15-30

minutes; despite all these, the birds which survive more than half an hour recover probably b

ecause of the rapid metabolism cyanides in the thiocyanate and due to its rapid elimination.

.........

c)i mpact on mammalians

....Oral LD50 related to mammalians varies between 2,1 mg/kg of body weight (coyote) and 10,0

mg/kg of body weight (laboratory rats). The acute poisoning signs including the excitation with

muscle shievering , salivation, tear dropping, heavy breath, defecation and urination followed by

muscle disorder, panting and convulsions occur within 10 minutes after ingeration . In general,

the sensitivity to cyanide decreases from cattle to the sheep flocks, horses and pigs. The deer

seem to be very resistant to the cyandie toxicity.

.....

Although existing and available ins everal plant species the toxicity of the cyanides is not largely

spead because of a number of significant elements. Cyanide is little persistent in the environment

and is not accumulated or stored by any investigated mammalian. No biological growth of

cyandie has been reported in the prophic chain. Although the chronical intoxication with cyanide

exist, cyanide toxicity is low. The sub-lethal dosages of cyanide determine the cumulated

adverse impacts. Many species may tolerate significant amounts of cyanide, but at sub-lethal

intermittent dosages over ,long periods of time.‖ (excderpt pag. 76-78)






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As noticed, the maximum hourly values and 8h averaged maximum values of the HCN

concentrations determined by simulation are much lower than the concentrations which could

generate toxic impacts, although the HCH emission impact is negatively minor.

2.2.5.Clarifications- risks associated to the flotation tailings management facility

„The rapid and uncontrolled loss of the tailings management facility contents may result in:

- people death ;

- impacts on the biological and physical environment;

- material damages caused to the thirds of the impacted zone;

- direct damages caused to Deva Gold because of the repair work costs and production

shutdown during the remediation works;

- impacts on the company image (stock exchange quotation, permitting regime, etc) .

The quantification of these consequences is very difficult because some of the consequences do

not have money representation, such as the people death and others are extremely difficult to

evaluate as monetary units, like the environmental impact or the impact on the company image.

The human settlements are sitauted relatively away from the dam and thus the loss of human life

is little probable. The impact on the environment and properties may occur but they are limited

particularly because of the low risk indicated by the material deposited in this tailings

management facility and the damages caused to the company and its image in case of accident

will most certainly occur.

The area possible to be impacted in case of the dam burst would include, up to the

confluence with Mures , Hondol (598 loc) and Certeju de Sus (1795 loc) villages belonging to

the Certejul de Sus commune as well as Bârsău (529 loc) village of Hărău commune.‖ (excerpt

from the Report to the Environmental Impact Assessment chap. 7 „Risk Situations”, pag. 153-

154)

In accordance with the provisions of the Art. 2 of the Urgency Order of the Government

No. 244/2000 referring to the dam safety approved and amended by the law no. 466/2001, the

„dam category” include „any water work having an existing or proposed structure which can






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provide the permanent or non – permanent accumulation of industrial residues (tailings

management facilities of the mining industry), which failure could result in the uncontrolled loss

o the accumulated contents with negative impact on the social, economic and / or natural

environment..

The article 6 (1) and (3) of the same law establishes that for the new dams, their owners

have to obtain from the Ministry of Waters and Environment Protection the permit for safe

running and this permit refers to the categorization of the dams from importance point of view,

to the adoption of the designing solutions, to the location and compliance with the law

regulations and laws as well as to the expertise in the field.

In accordance with the provisions of Art. 4 of NTLH-032 about the procedure for the

permit and approval for safe running of the dams (Official Journal part I, No. 427/19.VI.2002)

the permit is issued based on the approval issued by a certified expert of the Ministry of

Environment and Water Administration, as a result of the project review and studies related to

the project.

Based on the regulations in force presented above, in December 2010 Mr. Alexandru

CONSTANTINESCU, Expert for the assessment of the safety condition of the dams and dykes

for industrial residue deposits , holding the Certificate no. 207/2007 developed the Report for

the auditing / approval of the technical documentation related to the “DAMS OF THE

GOLD-SILVER ORE MINING OF CERTEJ PERIMETER , HUNEDOARA COUNTY”

to obtain the safety running permit.

This audit aimed at the substantiation of the approval and reviewed the categorization of

the dam by importance categories , the criteria, standards and regulations on which basis the

design was developed, adjustment to the field conditions, basic data amount and accuracy,

expected safety of the exploitation regime, structural safety as well as the efficiency of the

designed UCC.

There are presented further on, some issues approached in this audit report which meet

the requirments formulated:

„In accordance with the provisions of the NTLH-021/2002 about the methodology for

establishing the importance category of the dams approved by the joint Order issued by the






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Ministry of Water, Forests and Environment and Ministry of Public Works, Transport and

Dwelling and published in the Official Journal of Romania , Part I no. 427/19.VI.2002, the

criteria on which basis the importance category of the dams and deposits is established, consists

of the risk expressed as risk index RB. For the dams related to the industrial residue storage

facilities, the calculation is made in accordance with the annexe 2 of the mentioned order.

...

According to the Art. 6 of the NTLH-021 the two dams and tailings management facilities are

included in the „B‖category of „particular importance (0,80>RB>0,15 ). „The dam and tailings

facility classification as “particularly important” results in the necessity of a „special

monitoring”of its behaviour.

The special monitoring plamn was included in the technical design ...‖ (excerpt pag. 40)

„The special monitoring includes regulated specific, periodical investigations of some

parameters that characterize the construction or parts of it. The special monitoring objectives of

the construction behaviour are

Ensuring the safety and reliability of the constructions by identifying in time the

dangerous unpredictable events and zones where they occur;

Monitoring the evolution of some predictable events with possible negative impacts on

the safe running of the exploitation;

Rapid signaling of the warning criteria or of the admissible values provided by the

measuring and control instrumentation;

Checking the efficiency of all the applied intervention measures; checking the

construction impact on the environment;

Supply of a high amount of data that can be statistically processed ( database) required

for:

Determination of the range of values corresponding to a normal and safe exploitation

under all circumstances the construction is facing during its life, both from point of view of

stresses and environmental influences necessary to assess the calculation assumptions and for

determining the ―attention‖, ―warning‖ and ―alarm‖ ranges for the respective parameters;






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For a work carried out simultaneously with the exploitation, there are expected

significant modifications of the design, adjustments of the execution design or other constructive

modifications if the site condition does not fit in the calculation assumptions; nothing could be

done in this sense, if there no relevant monitoring outcomes;

Checking the behavior under real complex circumstances of some material types;

Experimental checking of the new calculation methods.

The technical design developed for the GOLD-SILVER ORE MINING OF CERTEJ

PERIMETER, HUNEDOARA COUNTY‖ includes a special chapter which is characterized as

“special monitoring project”. ― (excerpt pag 35)

„8.1. CONSIDERATIONS ABOUT THE SELECTION OF THE SITE

The location of the two tailings management facilities of Valea Măcrişului observed some

economic and technological requirments . For Certej exploitation the selection of the sites was

based on the complexe studies started in 2003 by the Scott Wilson Mining company which

developed the first “Review of the site selection for the waste material storage”, where eight

possible sites were evaluated. The results were re-evaluated by two Romanian specialists, prof.

Dan Stematiu and prof. Mircea Şelărescu, which proposed an evaluation and categorization

method. There were selected areas neighbouring Certej open pit of the licence concession. In

total there were estabslihed 11 options which have been investigated and assessed taking into

account the following political, social, technical and environmental factors:

Geological / hydrogeological factors;

Geotechnical factors;

Necessity/ requirements/ restrictions depending on the zone;

Topography;

Distance from the plant site;

Access;

Impact on the environment;

Impact on the social environment/ attitude of the local communities.

Further to the analysis there was selected the option regarding the location of the two tailings

management facilities in Valea Măcrişului. The analysis were based both on the technical






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solutions and on costs. All the objectives are situated on the administrative territory of Certeju de

Sus commune.

From the point of view of the dam and related tailings facility safety the site conditions are

good and justify the selection of the site.

Thus:

Within the investigated perimeter there are prevailing the quartziferous andesites of

Sacaramb type, of gray colour, sometimes light green or gray. The rock has a porphyry structure

with medium particle size with slight large to small variations. They are hard rocks, little

cracked. Based on the values obtained for the compression and tension strength it resulted that

the rock is suitable for foundation. Also, the values obtained for the porosity and for the

absorption capacity indicate that the foundation rock is suitable both for the two tailings

management facilities and implicitly for the rockfill dams. There resulted that on the respective

sites, the foundation material allow the construction of rockfill dam of about 200m high.

The seismic risk of the zone is low (zone F according to the P 100-1/2004);

The water basin upstream the tailings facility is low, consequently the flows in the tailings

facility are small and thus the overflowing risk in case of high floods from the upstream basin

can be controlled by suitable measures;

In all the rise stages the tailings facility surface area meets the requirement of Siaz ≥ (6...8)

ha/ for each 1,000 t stored by day, this surface area is stipulated by the regulations to allow the

sedimentation and consolidation of the beach near the dam;

The rock is little fissured and its perviousness is below 10-9

m/s; the hhydrogeology of the

zone does not raise any concerns regarding the safety ; there is no risk of underground water

contribution to the source site situated outside the own basin;

The location of the tailings facility close to the flotation plant significantly reduces the risk

of damages or incidents along the pipeline, and the high solid content of the tailings reduces the

risks of safety associated to the clarified water discharge system;

As for the consequences caused by a potential damage the site is suitable. The location of the

CIL tailings management facility upstream the flotation tailings facility is advantageous because

in case of an accident the downstream tailings facility can limit the impact area. The downstream






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tailings facility is safer ( the whole dam is developed either downstream or centerline developed)

and its capacity is higher so that to take over the random water amounts.

Regardless it, the design must include a warning – alarm – discharge plan correctly developed

and agreed with the inspectorate for emergency situations‖ (excerpt pag. 45)

2.2.6. Clarification referring to the waste dumps and water courses zones

The issues mentionned in the non-technical abstract at page 16 referring to the location

zone of the two waste dumps deals only with the current condition when the two water courses

(valea Corănzii and valea Băiegii creeks) are impacted by the waste dumped on the two existing

waste dumps (North and South).

A detailed review of these water courses is presented in the Report to the Environmental

Impact Assessment sub-chapter. 4.1. Further on, there are summarized several aspects we

consider relevant for these water course condition:

„4.1.1.4. Quality of surface water

4.1.1.4.1. Quality of water courses within the exploitation concession

To determine the quality of the waters within the open pit, processing plant, waste dump, and

tailings management facility areas during the first sampling campaigns ( March and May 2007)

carried out by the experts of INCDPM – ICIM Bucureşti there were taken the following samples

from the following sampling locations ( their location os presented in the annexe 4.1.4):

.......

Valea Corănzii creek upstream the confluence with Valea Hondolului creek (code 105-2);

......

Valea Băiegii creek upstream the confluence with Valea Hondolului creek (code 103-2);

Certej creek, downstream Certejul de Sus locality (code 046-2 and 107-2).

........

Further to the comparison of the results obtained at the laboratory assays of the water samples

with the admissible values required by the Order 161/2006, the following results were revealed:

.......






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Valea Corănzii creek, sample of 16.05.2007 (bulletin of analysis no. 105-2) is classified as:

class I for quality indicators: CCO-Mn, nitrates, soluble orthophosphates, chlorides,

cadmium;

class II for quality indicators: Cr, Pb;

class III for quality indicators : total nitrogen ,

class IV for quality indicators: calcium;

class V for quality indicators: ammonia, nitrites, sulphates Ca, Mg, Fe, Cu, Mn, Ni, Zn.

The water is strongly acid pH: 2,7.

......

Valea Băiegii creek , sample of the 16.05.2007 (bulletin of analysis no. 103-2) is classified

as follows:

class I for quality indicators: CCO-Mn, nitrates, soluble orthophosphates, chloride;

class II for quality indicators: nitrates, Cr, Pb;

class III for quality indicators: total nitrogen;

class IV for quality indicators: nitrites, calcium;

class V for quality indicators: ammonia, sulphates, Ca, Mg, Fe, Cd, Cu, Mn, Ni, Zn,

filterable residue dried at 1050C.

Waters are strongly acid pH: 2,8.

.......

.... In June 2010 a sampling campaign from several pre-set locations was developed (their

location is presented in the annexe 4.1.1.):

Pârâul lui Toader creek close to the confluence with Corănzii creek and upstream the propsoed

North waste dump (code 1);

Valea Corănzii creek close the confluence with Valea Hondolului creek and downstream the

proposed North waste dump (code 2);

Valea Băiegii creek upstream the propsoed open pit boundary and South waste dump (code 3);

Valea Băiegii creek close to the confluence with Valea Hondolului creek and downstrean the

open boundary and proposed South waste dump (code 4);

......






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Further to the comparison of the results obtained at laboratory water sample analysis to identify

the contaminants related to the gold-silver mining exploitations with the admissible values of the

Order no.161/2006 it was revealed like in the first stage of sampling , a massive pollution of the

lower water courses, namely Valea Corănzii (code 2), Valea Băiegii (code 4),and respectively

Hondol creek (code 7,8), and Certej creek (code 9), for the latter being noticed that a certain

dilution occurs under high flow-rate circumstances. The first two water courses cross the old

waste dumps and stripped rock dumps which have high sulphur and non-ferrous contents. The

reaction of the air oxygen with the rocks containing sulphides result in the formation of acid and

in such case the metals are highly soluble and the relevant indicators such as the pH, sulphates

and most of the metals dfetermine the classification of the waters in the quality class V. Hondol

and Certej creeks are the emissaries collecting the used waters with high contaminant contents.

The water courses not impacted by the old exploitations ( Paraul lui Toader creek - code 1, upper

course of Văii Băiegii creek – code 3 and Valea Măcrişului creek - code 5,6) presenting better

quality indicators.‖ (excerpt pag. 19-24)

To meet the requirments for the „gradual diminution of pollution with priority

contaminats and the gradual removal of emissions, discharges and losses of dangerous matters as

well as the prevention of the deterioration of all surface water bodies‖ according to Law of

Waters no107/1996, with the further modifications and amendments ( transposes the Directive of

the European Parliament and Council no. 2000/60/CE about the determination of a community

policy in the field of water) is necessary to apply ‚some control measures of the emissions of the

main sources of these discharges based among others on all the technical measures considered to

reduce the discharges‖ (excerpt GUO 3/2010 art. 2).

Because the current pollution of the two water courses is caused by the direct contact

with the waste generation acid drainage too, besides the measures implemented to catch and

divert Băiaga creek (which does not cross any longer the South waste dump site) and the

canalization of Corănzii creek across North waste dump zone (measures described in details in

the Report to the Environmental Impact Assessment chap. 1, pag. 19-24) there are provided






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special measures in order to clear the land occupied with the waste dumped on the old North and

South waste dumps and for the development of the works necessary to obtain the stability of the

structure and foundatrion ground.

Because the proposed sites for the construction of the new North and South waste dumps include

also the old waste dumps where currently waste material from the old mine is dumped it is

necessary to determine the methods for the assymilation of this material in the new construction.

According to the description of the working technology regarding the waste dumping and of the

construction works necessary for the two waste dumps, it is noticed that the waste dumping on

the two proposed sites is carried out upward after rpeviously having performed the foundation

planning works, the construction of drains and retaining walls from the dump „leg‖( (details in

the Report to the Environmental Impact Assessment chap. 1 pag. 67-68 and chap. 2 pag. 2-4)

To assymilate the existing waste material of the old waste dumps in the new mining

constructions of North and South waste dumps strictly observing the works to be done for

ensuring the stability of the structure – foundation land there are necessary the above

descriptions complying with the following working stages:

1. – staged construction from downstream to upstream of the foundation planning

works and drain constructions startingfrom the dump ,,leg‖ ;

2. – construction of retaining walls from the ,dump ,leg‖ ;

3. – dumping the newly mined waste from Certej open pit in successive layers on the

waste dump site following an upward trend starting from the retaining wall according to the

working technology;

4. – simulatneously with the waste depositions there will be eprformed works for

clearing the land occupied by the waste resulted at the old mine and deposited on the old dumps

situated upstream. The existign waste material from the proposed site of the new dumps, will be

excavated loaded in trucks, transported and stored on the dumping benches of the dumps under

construction, downstream. The excavation of this material is performed always upward for the

gradual clearing of the land to perform the foundation planning works and drain constructions.

Thus the waste material of the site will be gradually incorporated in the new mining construction.






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5. – completion of the foiundation planning works and continuation of the drain

construction towards upstream on the sites from where the old waste material has been gradually

removed.

2.2.7.Clarifications – mining exploitation will be performed within the approved perimeter

boundaries

The mining exploitation will be developed within the boundaries of the exploitation

perimeter approved by NAMR as per the Mining Law and thus the amount of waste generated by

the ore exploitation and processing is limited

The use of the old access roads does not result in additional waste amounts. Also,the

depositions resulted at the stripping operations of the old locations existing already within the

approved exploitation perimeter of Certej mining Project do not generate additional waste

amounts.

2.2.8.Clarifications– entire recycling of the clarified waters.

Within the proposed project, under normal running conditions, the entire clarified water

collected in the CIL tailings management facility is recycled to the processing plant being re-

used for the technological process. However, it is not about a closed system of the clarified water

( like for instance at Aurul Baia Mare tailings facility by the time of the accident from 2000) for

the because:

- “8. There will be built a treatment plant for clarified waters collected from CIL tailings management

facility for treating the used water to be eventually discharged under some exceptional circumstances

Expected impact: Prevention of risks associated to the dangerous rise of the water level in the CIL

tailings management facility and of an eventual trans-boundary impact as well as the mitigation of the

impacts on the water quality particularly referring to the cyanide contents” (RIM chap. 9 , pag. 21)

-―In case of extreme precipitations when, for certain technical reasons the clarified and natural

water cannot be recycled, the diversion and drainage galleries cannot take over the excess water






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– the water level in the tailings management facility exceeds the safety level, to avoid the

uncontrolled overflowing over the dam crest of wave, there was designed the construction of an

overflowing zone at the level of each rise bench and open channels in the valley sides for taking

over the possible flow-rates formed from the starter dam crest of wave and further on for each

dam rise bench (Annexe 1.22).‖ (Report to the Environmental Impact chap. 1. pag. 49)

It is to be mentioned that in case of other mining proejcts, too the zero overflow principle

regarding the water collected from the tailings facility has been successfully applied. „The

baseline document about the The Best Available Techniques for the Waste Management

and Residual Sediments resulted at Mining Operations”,of January 2009, presents in

chapter 3 several examples of water management and in some of these cases the principle of the

total recycling of the water resulted at the tailings management facilities was applied:

-„The ore processing plant of Aitik uses 100% of the re-used water resulted at the tailings

management facility. Under normal circumstances, the total water consumption of 31.5

Mm3/year is supplied by re-using the water from the tailings management facility. About 1.8 m3

of water per tonne of processed ore is used in the processing plant. During snow melting season

the excess water is normally discharged from the clarification basin in the emissary. The

discharged water is good quality water and does not need any treatment.‖ (excerpt pag.158)

„The designing criteria and the management system of the tailings facility from Bergama-

Ovacik are set at a \‘zero‖level for the water discharge in the environment. This is possible

because the operator is a high water consumer ( due to the hot climate) and re-uses the water

from the tailings facilities for the plant running. The annual average values of the precipitations

and the evaporations are 728 millimeters of precipitations and respectively 2313 millimeters

evaporation (the balance –sheet is negative ).

The catchment area of the upper dam is about 0.6 sq. km. According to the calculations, the

water amount possible to be discharged in case of floods during the first hour of heavy

precipitations, is 24.6 m/s. In case of very heavy precipitations the water resulting from the

catchment area will be stored in the pluvial water pond situated behind the upstream

embanklment. The stored water will be pumped to the tailings management facility, and the






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excess water will be directly delivered to the diversion channel which is built along the Northern

face of the tailings facility.‖ (excerpt pag.213)

2.2.9. Pipeline

The issue referring to the possibility of the pipe breakage has been addressed also in the

„Refernce Document about the Best Available Techniques of the management of wastes and

resuidual sediments resulting at the Mining Operations‖ in chapter 4.6. Mitigation of risks (pag.

418). There are given several possible technical measures meant to mitigate the impacts caused

by the eventual breakage of the pipes, b ut none of them mentions the impermeabilization of the

ground and the reason may be the fact that incurrs high costs.. For Certej project such a solution

is technically impossible to implement because of the land configuration.

The Project provides the following active measures to restrict the consequences

generated by the eventual failures of the pipeline (in compliance with the technical measures

described in the BREF):

1. The tailings pressure and flow-rates pumped to the tailings management facilities

will be measured at the tailigs delivery pump level and at the overflowing level in the TMF‘s,

using flow-meters transducers and respectively pressure transducers connected to the input of

some interface modules distributed to the repsective locations. The interface modules are

connected to a redundant networks provided with optical fibers for data transmission to a

redundandant automatic system ,located at the main control chamber of the technological process

on the +593m pad near the processing plant in the MCC. By the process control system of the

technologicla process there will be implemented the control and adjustment functions of the

technological parameters , there will be the command and signalling systems of the tailings

pump running frequencies, which will be driven by asynchronous varyable speed electric motors.

Thus, there willbe detected the failure, the alarm signals will be generated, as well as the

command to stop the piumps to avoid an eventual failure. The system will alllow the

visualisation in real time of the technological parameters.






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2. Another verification form of the pipeline wearing rate consists of the epriodical

cverification to be developed in accordance with the „plan of verification and control‖‖ of the

technical condition of the pipes. The identification in due time of the eventual advanced weear of

tpipes which could result in breakages, fissures or holes will be carried out using ultra-sound

detectors and the maintenance teams will be equipped with such devices.

In the IpCT item 26 (pag. 237-242) there are detailed the Geological data of the tailings

management facility location site.

The answer given at item 2.1.5 , provides details ablout the tests for the rock

peverviousness determination and calculations regarding the infiltration of water from the

TMF‘s in the sub- layers indicating that there is no need to implement

impermeabilization measures for the tailings management facilities and waste dump

rocks sites because within these ones we can talk about the existence of an aquiferous

eventually at very big depths and the non-saturated zone consists of aquifuge rocks which

are actually impervious.

2.1.10 clarifications – pag 22 și 23 non technical abstratc and increase of the quality of Certej

stream.

In accordance with the provisions of the Law 310/2004 about the amendment and

completion of the law of Water no.107 / 1996 the objectives of the environment protection

applicable for Certej stream are the „protection, improvment and rehabilitation of the surface

water bodies to reach a good condition in accordance with the provisions of the annexe no. 11,

until the 22nd December 2015;‖ (Art. 21 (1) lit. B).

―the water resulting at the open pit and the water resulted at the waste dumps will be

collected and treated determining the mitigation of the impact of the surface water which

currently are polluted because they cross over some old mining works or waste dumps existing

in the region.‖ (RIM chap. 4.1 pag. 100)

As the proposed mining works of the project will be developed only within the approved

perimeter the impact mitigation refers only to the pollution sources existing within this

perimeter, so the project implementation will result in the gradual improvment of the quality of






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waters of Hondolului creek and indirectly the improvment of the quality of Certej stream. As for

the fulfilment of goals provided by the Law 310/2004 within the due time, it depends when the

implementation of the project which is currently under environmental permitting process, starts

up.

III. ENVIRONMENTAL ELEMENT AIR

The information required through the note of the Ministry of Environment and Forests is

presented in the Annex to the documentation RIM, RS and IpCT required by the Ministry of

Environment and Forests in order to apply the provisions of the Espoo Convention‖

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