The Ministry of Environment issued a clarification in response to the assertion of the Ministry of Ecology and Natural Resources of Azerbaijan regarding the construction of a metal smelting plant in Yeraskh village of Ararat region that the construction and operation of the metal smelter will harm the environment of their country.
"In accordance with Article 2 of the Convention on Environmental Impact Assessment in a Transboundary Context (hereinafter referred to as the Convention) " Each Party shall take the necessary legal, administrative or other measures to implement the provisions of this Convention, including, with respect to proposed activities listed in Appendix I that are likely to cause significant adverse transboundary impact, the establishment of an environmental impact assessment procedure that permits public participation and preparation of the environmental impact assessment documentation described in Appendix II”.
In this case, the planned activity is the processing of black metal scrap in the village of Yeraskh, Ararat Province, Armenia, which is not included in the 1st Annex defining the types of activities of the Convention, and the planned activities of "blast furnaces and open-hearth furnaces and non-ferrous metallurgy enterprises" included in the 1st Annex of the Convention are in no way related to the intended activity under question, since the process of casting black metal scrap will be carried out using an induction furnace, which works exclusively with electricity.
Moreover, the envisaged activity, taking into account Article 2, Part 5 and Annex 3 of the Convention, cannot be considered as having a significant transboundary harmful effect either, for the following reasons:
The criteria defined by Annex 3 of the Convention are:
Size - proposed activities which are large for the type of the activity.
Annual productivity of 108 thousand tons is considered a small volume for the type of ferrous metal scrap processing activity. The productivity of such processing plants generally starts from 1 million tons.
Location - proposed activities which are located in or close to an area of special environmental sensitivity or importance (such as wetlands designated under the Ramsar Convention, national parks, nature reserves, sites of special scientific interest, or sites of archaeological, cultural or historical importance) also, proposed activities in locations where the characteristics of proposed development would be likely to have significant effects on the population.
The closest specially protected area of nature in Nakhichevan area is located about 5 km away from Yeraskh village in a straight line, and the planned activity cannot have any negative impact on the mentioned areas. There are also no wetlands defined by the Ramsar Convention, and the closest candidate is 12 km away from the Emerald site in a straight line.
The impact of the planned activity on the existing archaeological, cultural or historical monuments in this area is also excluded, taking into account that the nearest possible monument is located at a distance of about 12 km in a straight line.
Effects - proposed activities with particularly complex and potentially adverse effects, including those giving rise to serious effects on humans or on valued species or organisms, those which threaten the existing or potential use of an affected area and those causing additional loading which cannot be sustained by the carrying capacity of the environment.
The selection of the area, the applied modern technology and the planned environmental measures will minimize the negative impact on human health and the environment.
Negative impact on atmospheric air is excluded. Gases emitted into the atmosphere contain carbon oxide and dioxide, hydrogen, oxygen, nitrogen.
A two-stage cleaning system will be installed on the exhaust gases, the efficiency of which will be 99%.
The installed systems will ensure a lower level of harmful substances in the gases emitted into the atmosphere than the maximum permissible concentrations. In addition, in order to improve the dispersion conditions in the atmosphere, a 33-35m high pipe is planned for the release of gases into the atmosphere.
The dust content in the exhaust gases from induction furnaces is several times less than from arc furnaces.
Impact on water resources is excluded. The water demand is planned to be met at the expense of groundwater, the level of which is very close to the surface in the given area.
Water for technical needs will be used only for cooling. The daily consumption of circulating water is planned to be 328.8 cubic meters. Water leakage from the production process is not planned, the factory will work with a closed circulation system.
Fresh water is used only to supplement the circulation system.
A modern biological wastewater treatment plant with 95-98% efficiency is planned for domestic waste water.
The purified water can be discharged into the land canals in the area and also used for the purpose of irrigation of the area.
The border river Araks is located at a distance of 6 km. A harmful effect is excluded, considering that the production processes do not foresee any harmful discharge into the water basin.
There is no impact on the fauna and flora objects in this area. There is no fauna and flora in this area. In case of encountering them, appropriate protection measures will be implemented in accordance with the law.
There can be no negative impact on land resources either. The factory is planned to be built in an already disturbed area, where there are half-destroyed buildings, dam remains, etc. There is no fertile layer of soil in the area subject to activity.
Waste management will also be carried out in accordance with the established legal requirements. Black metal scrap is a non-hazardous waste. The slag resulting from the smelting of black metal, which does not have a hazard class, is planned to be used in road construction and other purposes, thus reducing waste accumulation in landfills.
