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i

Executive Summary

We have reviewed Lydian’s response to our evaluation of the Amulsar Project.

Our key recommendation is that Lydian must strengthen their ARD Management Plan immediately and that the Government of Armenia insist on receiving such a plan before allowing mining to proceed. At a minimum, this plan should include improved separation and handling of potentially acid generating materials and development of a water treatment plant that treats all the contaminated waters produced at the mine. Both measures should be implemented before pit dewatering and mining operations begin.

We agree that this project could potentially benefit Armenia and its citizens, but we believe that the proposed mine, as currently planned, will lead to the long-term environmental degradation of one of the most beautiful parts of the country. In our view, Lydian takes an overly optimistic view of the risks associated with this project, especially regarding the release of acidic, metal-contaminated waters from this site. We firmly believe that a more conservative approach is justified in light of existing site conditions and the potential long-term environmental damage associated with acid rock drainage (ARD) and contaminant leaching.

Our main disagreement with Lydian falls into five key points:

1. The risk of ARD and contaminant leaching at Amulsar is very high 2. The plans to mitigate contaminant release are insufficient 3. Lydian needs to identify and manage every potential source of contaminated water during

construction, operation, closure and post-closure 4. Lydian’s wording occasionally minimizes apparent risk and confuses issues 5. Lydian has not made available some key documents needed to fully evaluate this project

Lydian reviewers state in their summary that “independent studies show that ARD risks at Amulsar are very low.” We disagree. Most of their evidence indicates that the risk of acid generation and contaminant leaching is very high. This evidence includes:

Several naturally acidic seeps exist at the site, indicating that acid generation in this area already occurs

Waste rock that was mined during the Soviet era generates acidic drainage

Acid-base accounting results show that rocks that will be mined at the site have a high potential to acidify water. Additionally, there is virtually no rock on site that can neutralize acidic water

Humidity cell tests show that nearly every rock unit mined at this site will generate ARD

Additional tests identify several metals and metalloids that these rocks may release, including antimony, arsenic, cadmium, chromium, cobalt, copper, lead, mercury, selenium and zinc

The small acidic seeps in the Amulsar area and the Soviet-era waste rock only have localized effects. However, mining will unearth vast quantities of rock that will generate much larger volumes of acid water. Without proper measures to mitigate this, these acidic waters will travel much farther and affect far greater areas.

Lydian’s plans to mitigate contaminant release are inadequate. The ARD mitigation plan should already be in place, so that Potentially-Acid Generating (PAG) rock is managed from the start of construction. The planned management of acidic waters generated from pit dewatering and other sources during mining is problematic. It assumes that metal loads will be low and sludge management will be unnecessary. We feel this is very optimistic and believe that it is both prudent and necessary to build a lime-based treatment plant to manage these waters and the resulting sludges.

ii

The proposed passive treatment system will deal with some, but not all of the contaminants identified above. More importantly, it is not designed to treat large volumes of acid drainage with elevated metal concentrations. Given the uncertainty in predicted water chemistry during operations and at closure, we are not confident that the proposed passive treatment system will function properly and produce an acceptable discharge.

We indicated that thiocyanate is likely to be produced in the HLF for decades, yet no measure has been proposed to control this toxic contaminant. Similarly, ammonia and nitrate, as well as metals and metalloids, may be present at elevated concentrations in heap rinsate or drain down water, but no credible measure to control these contaminants has been presented.

The proposed encapsulation of barren rock and capping of the spent HLF could decrease the release of contaminants, but will not eliminate them. Potentially, this could result in release of acid drainage for many decades. In our opinion, a better practice is to segregate sulfide minerals during mining operations and backfill them into one or more of the mined-out pits to ensure that they do not generate acid drainage. This practice has been advocated for the past 15 years and is becoming the norm for mining projects with high risk of ARD (MEND 2015).

Lydian takes an optimistic approach to the management of surface and groundwater flows into the pits. Several model predictions have high uncertainty, and measures to mitigate the discharge of contaminated pit water are not based on a reliable water balance calculation. Given that these waters could flow into the Kechut Reservoir, we believe it is more prudent to assume that water treatment will be needed before Year 4 of mining and prepare for increased storage and treatment before pit dewatering and mining operations begin.

Lydian uses terminology that confounds issues. Their reference to mining wastes being resistant to “ferric iron oxidation” is unusual and irrelevant. The more relevant fact is that humidity cell tests show that every rock unit is likely to generate acid drainage. Similarly, they refer to “passive treatment as an industry-standard method for controlling ARD.” This statement is true for ARD from coal mines in Eastern Appalachia, but not for base and precious metal mines. More importantly, their discussion sidesteps the key issue that the passive treatment system design that they put forward is inappropriate for the drainage that will be generated at Amulsar.

Finally, we hear a recurrent criticism that our review omitted important reports, as though our conclusions would change significantly if we had all the necessary information. Our reviews are based on the most recent available information, but not all the pertinent information has been made publicly available. In the name of transparency and to remove any uncertainty in our conclusions about this project, we urge Lydian to make publicly available all the documents relevant to this project.

iii

Contact Information: Andrea Gerson, PhD Roger Smart, PhD Blue Minerals Consultancy Middleton, South Australia 5213 andrea@bluemineralsconsultancy.com.au roger@bluemineralsconsultancy.com.au www.bluemineralsconsultancy.com.au/ Tel: 0422112516 (Dr Gerson), or Tel: 0400835603 (Dr Smart) Ann Maest, PhD Buka Environmental Boulder, CO, USA aamaest@gmail.com Tel: 303.324.6948 André Sobolewski, PhD Clear Coast Consulting, Inc. Gibsons, BC, Canada andre@clear-coast.com www.clear-coast.com Tel: 604-240-8845

iv

Table of Contents

Executive Summary ........................................................................................................................................................ i 

Table of Contents .......................................................................................................................................................... iv 

Figures ............................................................................................................................................................................ iv 

Tables .............................................................................................................................................................................. iv 

Introduction ..................................................................................................................................................................... 1 

Risk of ARD and contaminant leaching at Amulsar is high ..................................................................................... 1 

Planned mitigation is insufficient to prevent long-term contaminant release ...................................................... 6 

Lydian needs to manage and plan for every potential source of contaminated water during construction, mining, closure, and post-closure ............................................................................................................................... 8 

Lydian’s wording confounds issues, minimizes apparent risk ............................................................................... 9 

Lydian has not been transparent with its most data-rich reports and appendices. ............................................. 9 

Recommendations ....................................................................................................................................................... 11 

References Cited .......................................................................................................................................................... 13 

Figures

Figure 1a, b. Spring pH values for areas around the (a) Erato Pit and (b) Tigranes and Artavazdes pits. ................................................................................................................................................. 3 

Figure 2. Humidity cell test results for eight samples from the Upper and Lower Volcanics. .............. 5 

Tables

Table 1. The pH and sulfate values for springs declared to be alkaline in the 2016 ESIA. Source: ESIA, 2016, Appendix 4.8.5 Groundwater Quality. ....................................................................... 1 

Table 2. The pH and sulfate values for springs declared to be acidic in the 2016 ESIA. Source: ESIA, 2016, Appendix 4.8.5 Groundwater Quality. ................................................................................. 2 

Table 3. Appendices missing from the Amulsar 2016 ESIA. .............................................................. 10 

Introducti

We thank LWe agree thwill outweimine, as cuof the counproject and impacts ass

We presentaddressing Lydian andUltimately,issues have

Risk of AR

Reviewers are “very lothat the acidalready exisquality con

a. Basnot

Using the aacidic are n

The followiwhere a sligrather than spring was these spring

Ta

ion

Lydian Internahat this projecigh the long-teurrently plannntry. It is our v

that a more csociated with

t below our mthese problem

d its consultan we believe th been address

RD and con

of our reportsow.” Howeved generation pst at the site, ditions.

seline water tably affected

available data,not, and natura

ing statementghtly alkali pHalkaline). Inssampled only

gs represent n

able 1. The p

Sprin

SP3

GA

GA

GA

AW0

ational and itsct could potenerm drawbacked, will lead tview that Lydconservative aacid rock dra

main concerns ms. We wouldnts, representahat the envirosed.

ntaminant le

s state in theirr, the potentiapotential of thespecially as

quality in thd by natural a

, springs idenally acidic ba

t is not correcH was measustead, as showy once. Sulfatnatural acid dr

pH and sulfatSource: E

ng ID #

32

A2

A3

A4

035

s consultants ntially benefitks in the projto long-term e

dian takes an oapproach is juainage (ARD)

regarding thed welcome thatives of the Aonmental perf

eaching at A

r summary thal to generatehe site is not levidenced by

he Amulsar Pacid drainage

ntified in the Easeline conditi

ct, based on thured are SP32,wn in Table 1,te concentratirainage from

te values for ESIA, 2016, App

# Samples

1

1

1

4

1

for respondint Armenia andect’s current environmentaoverly optimiustified in ligh) and contami

e current plane opportunity

Armenian govformance cou

Amulsar is h

at that indepee acid is consilow. Reviewey the seeps, an

Project area e.

ESIA (Wardeions in the sp

he data provid, GA2, GA3, , these springsons are low, eweathering o

springs declappendix 4.8.5 G

pH Va

No

3

3

4

3.45

ng to our revid its citizens,form. Our prial degradationistic view of tht of existinginant leaching

ns and presenty to discuss thvernment anduld be marked

high

endent studiesidered a risk, ers also state tnd mining wo

is generally

ell Armstrongprings is quest

ded (ESIA, 20GA4 and AWs are acidic, weven though t

of sulfide min

ared to be alGroundwater Q

alue (SU)

o data

3.96

3.82

4.21

– 3.74

ews of the Am but disagree imary concernn of one of ththe risks asso

g site conditiog.

t our recommhese issues in d internationaldly improved

s show that Aand the availthat naturallyould not wors

y high and d

, 2016; Chapttionable.

016, p. 4.8.82W035.” (note:with pH valuethe pH is acid

nerals.

lkaline in theQuality.

SO4 (mg

21.5

27

20.2

36.3 – 4

mulsar Gold Pthat these ben is that the p

he most beauticiated with thns and the lon

mendations foran open foru

l stakeholdersonce a numbe

ARD risks at Aable data dem

y acidic conditsen the existin

does not appe

ter 4.8) as bei

2): “The locat: statement saes <4; all but dic; it is not c

e 2016 ESIA.

g/L)

49.2

Project. nefits

proposed iful parts his ng-term

r um with s. er of key

Amulsar monstrate tions

ng water

ear to be

ing

ions ays alkali one lear that

.

The followiwhere a natSpring 6, Spvalues >6 a

T

As shown icorner of thwhich is loc

ing statementturally lower pring 7, Sprin

and low sulfat

Table 2. The p

Spring

SP2

SP3

ERW

ERW

Sprin

Sprin

Sprin

Sprin

Sprin

Spring

n Figure 1a ahe Artavazdescated south o

t is also incorrpH was measng 8, Spring 9te concentrati

pH and sulfaSource: E

g ID

29

33

W3

W5

g 1

g 6

g 7

g 8

g 9

g 10

and b, most sps Pit area (Figf the Artavaz

rect based onsured in April9 and Spring ons, indicatin

ate values forESIA, 2016, App

# Samples

1 (pH)

2 (SO4)

1 (pH)

2 (SO4)

3 (pH)

1 (SO4)

2 (pH)

1 (SO4)

1

1

1

1

prings have a gure 1b) with des Pit and ap

2

n the data provl/May 2014 in10.” Instead, ng that they ar

r springs decppendix 4.8.5 G

s pH

N

N

6.2

6.5

neutral pH. Tthe exceptionppears to be u

vided (ESIA, nclude SP29, as shown in Tre not represe

clared to be aGroundwater Q

H (SU)

No data

No data

6.43

6.18

21 - 6.57

52, 6.64

6.47

6.62

6.95

4.38

The acidic sprn of Spring 10upgradient of

2016, p. 4.8.SP33, ERW3

Table 2, theseentative of na

acidic in the Quality.

SO4 (m

11.9 –

18 – 3

5

5

5

5

5

29.

rings are dow0 (acidic, not f the pit.

82): “The loc3, ERW5, Spre springs haveatural acid dra

2016 ESIA.

mg/L)

18.1

38.1

1

wngradient of tshown in Fig

cations ring 1, e pH

ainage.

the NE gure 1)

Figure 1a, Yellow = pErato Pit in2016, using 

The represefrom wells values belo(Appendix and in well water in sprsulphide oxsporadic na2016, Chap

b. Spring pHH <4.5; pinkn Figure 1a ddata from App

entativeness oin the GSA (Gw 6.5 are onl4.8.5), in welGGDW016a

rings arising fxidation that hature of the obpter 4.8, p. 4.8

H values for ak = pH >6; nodo not have pendix 4.8.5, ES

of the acidic wGroundwaterly recorded onll DDGW003a in the Lowerfrom snow mhas accumulatbserved acidit8.83)

areas aroundo color = no available pHSIA, 2016. 

well samples ir Study Area) n two occasio on the Cenozr Volcanic An

melt infiltrationted over the Wty, it is equall

3

d the (a) Eradata (Note tH values.) Sou

is questioned are typically

ons in field pHzoic Flow Bandesites southn may cause tWinter periodly probable th

ato Pit and (bthat all otheurce: Modified

in the ESIA:circum-neutr

H measuremeasalts east of th-west of the temporary aci

d are ‘washed hat these are a

b) Tigranes ar springs arod from Drawing

“Groundwatral (pH 6.5 toents of groundthe Vorotan RHLF in Marcid conditions through’. Ho

anomalous pH

and Artavazdound the g 4.8.3, ESIA, 

ter samples coo 9). Mildly acdwater well saRiver in Marcch 2014. The as the produc

owever, givenH recordings.”

 

des pits. 

ollected cidic pH amples ch 2014, flush of cts of n the ” (ESIA,

b. Maacimin

The humididuration of waste rock.Upper Volcsamples wewas prematresults indicwhile likely

It is stated toxidized ARzero cumul2016). Thisold mine wbased on

(a) Hwt.%(b) Hwt.%

Hence the lIn contrast,and 0.88 wt

It is also stacells and beARD manawt.%. The m0.28 wt.%, from these minerals veamounts of (Linklater e

any statementid and requirned materials

ity cell test (Hf those two sam As shown in

canic HCT saere cut short aturely stoppedcate that the Ly less acid gen

that “…three RD. These saative acidity, s sentiment is aste piles des

HCT tests 72C%, and Historic Sovie%. leach behavio the mean sult.%, respectiv

ated in the repeen identifiedagement.” Themean sulfate respectively. minerals. In a

ersus - slowlyf jarosite requet al., 2012).

ts and resultsre treatment. s is underesti

HCT) results smples was cu

n Figure 2, allmples were te

at 20 weeks, ed. Additional Lower Volcannerating, may

of the five LVamples produc

and low ironalso reiterate

spite the prese

C, 75C and 77

et waste rock p

or observed relfide S valuesvely.

ply “Jarosite ad as non-acid ge highest sulfaS values in th. These tests

addition, statiy dissolving suire on-going A

ts in the ESIAThe short-te

imated due to

show that all ut short. The H five Lower Vested. One preven though ptesting has be

nic material isy nonetheless

V kinetic cellce consistentl

n concentratioed in the replyence of abund

7C (see Figure

piles also con

eflects the lows of the Tig/A

and Alunite hgenerating an

fate S value ofhe Tig/Art andtherefore can

ic testing doesulfate sourcesARD manage

4

A and other erm metal ano the types of

but two sampHCTs were coVolcanic HCTroduced acid apH values hadeen committes highly acid produce acid

ls showed stroly mild (pH gns despite lon

y by the reviedant unoxidize

e 1) that conta

ntaining low l

w pyrite conteArt and Erato L

have been assend have thereff the nine samd Erato Lowennot be consids not distingus. Even more ement, as now

documents cnd other contaf short-term le

ples producedonducted on mT samples proafter about 30d decreased byed to and coulgenerating an

d as well.

ong resistancegreater than 4.ng-duration teewers “Ferric ed sulphides.

ained relative

levels of sulfi

ent and not anLower Volcan

essed in detaifore not been

mples subjecteer Volcanics wdered an evaluish between aso than aluni

w acknowledg

confirm that taminant leaceach tests sele

d acid (pH <6materials expoduced acid (p0 weeks of tesy about 1 pH ld be under wnd the Upper

e to the forma.5) ARD, withesting.” (Appiron oxidatio” However, th

ely low sulfid

ide S of 0.75,

ny unusual genic barren roc

il with static tincluded in t

ed to HCT exwaste rock saluation of poteacid generateite, wastes witged by major

the site will ching potentiected.

), and the testected to becopH <6). Onlysting; the otheunit before te

way, but theseVolcanic ma

ation of ferrich low sulfate,

pendix 4.6.2, Eon has not occhis understan

de S at 0.8, 0.2

0.2, 0.14, and

ochemical resck samples w

testing and huthe discussionxamination waamples were 0ential acid ge

ed from sulfidth substantialmining comp

generate ial of the

t ome y three er two esting limited terial,

c iron , nearly ESIA curred in nding is

2 and 0.3

d 0.37

sistance. were 1.31

umidity n on as 0.2 0.36 and eneration de l panies

Figure 2. HThe red testgreen oval 2015, Appen

The ESIA (characterizapyrite/jarosoxidation an

Appendix 4portions of products woindicates thconcentratio

GRE (2014nearly non-is not unusuformation fneutralizatiacid-base aWhile the Uhad a lower

Humidity cellt results are foshows where

ndix 4.6.2, Figu

(2016) states tation completsite materials nd produce ac

4.6.2 of the 20the mineralizould result in

hat mining wilons. No ment

4, p. 7) also no-existent. “Tabual for a high frequently remon potential.”ccounting res

Upper Volcanr neutralizatio

l test results for Lower Vol

two of the Uure 24.2.

that the Loweted to date forfrom the Lowcidic leachate

015 ESIA (GRzed areas to b

an acidic leall produce a ction is made o

otes that the able 5-1 showsulfidation e

moves any ori” Therefore, tsults indicate nic samples haon potential.

for eight samlcanic samplepper Volcani

er Volcanic mr the Amulsar

wer Volcanicses with pH as

RE, 2014, p. e mined have

achate and eleclassic acid drof a low acid

ability of wasts that the barrpithermal depiginal carbonathe HCT resulthat the wastead a lower aci

5

mples from thes, and the bluc sample tests

materials are “r project (Gols lithologic grlow as 2.5.”

1) states: “It ie a potential oevated salt andrainage solutidrainage pote

te rock (“barrren rocks havposit, where eate or aluminolts demonstrae will have litid production

he Upper anue results are s were termin

“highly acid glder Associateroup are highl(ESIA, 2016,

is accepted thof oxidizing, ad dissolved mion with low pential.

ren rock”) to nve little to no extensive acidosilicate mine

ate that the wattle to no abil

n potential tha

d Lower Volfor Upper Vo

nated prematu

generating”: “es, 2013b) indly acid genera, Chapter 4.8,

hat the residuaand the result

metal values.”pH and eleva

neutralize anyacid neutralizd leaching duerals that migaste rock willlity to neutralian the Lower

lcanics. olcanic samplurely. Source:

“Geochemicaldicates that thating due to s, p. 4.8.82)

al sulfides preting oxidation This stateme

ated metal and

y acid produczation potenti

uring deposit ght have provl produce acidize the acid pVolcanics, th

les. The ESIA,

l he high sulphide

esent in n ent d sulfate

ced is ial. This

ided d, and the produced. hey also

As the reviecontaminanleach tests ileached con100:1 liquidvalues shounoted in thebarren leacharsenic, cadAppendix 4liquid:soliddescriptionmaterials beafter a rainsdiscussed in

GRE (2014values are athan paste pnet acid-genpH slightly acid, but Up

These statemsite is high.environmenimproveme

Planned m

a. Tim

The mine isadequate mof potentialto develop tManagemen

The reviewprediction.”been made from mine wenvironmenTherefore, mdecades or

b. Anwat

The passiveseepage fro

ewers noted, nts in the wastis that they boncentrations. Td:solid ratio. uld have beene Buka Enviroh solution inddmium, chrom4.6.2). As an ad ratio, or leacs and pros anecause the tesstorm or snown the docume

4, p. 12) summavailable for 5pH values. Thnerating, withbelow 5.” Th

pper Volcanic

ments and res. Absolutely rntal contaminents.

mitigation is

ming of mitig

s already undmitigation mea

lly acid generthese measurent Plan (AMP

wers suggest th” It is correct to date to prewastes can pentally damagimitigation mulonger.

active treatmters.

e treatment syom the heap le

it is true that tes, the spent oth used a higThe SPLP tesIn addition, o

n presented as onmental repodicate a potenmium, cobalt, alternative, thch tests at a vad cons of geosts are designwmelt event. Tents.

marized the re50 Erato barrehe results indih LV sampleshe results indics and colluv

sults stronglyrigorous wastnation. The fo

s insufficien

gation measur

er constructioasures, such arating (PAG) es until after P) should be i

hat the likelihthat this pred

edict the evolueak after mineing drainage cust start on co

ment system

ystem (PTS) peach facility (

the short-termore, and the b

gh liquid:solidst has a liquidonly average c

well, but moort, results fro

ntial to leach acopper, lead,

he Meteoric Wariety of liquiochemical tested to capture The extent of

esults of acid en rock sampicate that coms generating aicate that not ium is as wel

y indicate that e and water mllowing sectio

nt to preven

res

on, and acid ds careful contmaterials, andoperation begin place now.

hood of acid gdiction is unsuution of rates e closure, if ncontinuing forommencemen

is needed to

planned for th(HLF) and the

6

m leach tests sborrow materd ratio (measud:solid ratio oconcentrationore importantlom the HCTsantimony, ars, selenium, an

Water Mobilitid:solid ratiosts). Short-termreleases of q

f weathering o

potential testiples. As expecmplete sulfide an effluent pHonly is Lowel.

the acid drainmanagement ion addresses

nt long-term

drainage and ctrol of construd shotcreting gins is not bes

generation peaupported in teand amounts

not appropriatr decades Zie

nt of mining a

o handle larg

he project is de barren rock

show low conrials. The probured as mL/gf 20:1, and th

ns were reportly, lower liqus, which use asenic, copper, nd zinc from tty Procedure (s, could be usm leach tests

quickly solublof the samples

ing of the Eracted, NAG pH

oxidation woH slightly abover Volcanic w

nage/contamiis needed at thissues with p

m contamina

contaminant luction materiof long-term

st practice. In

aking after poerms of this sps of acid genetely remediateemkiewicz et and be implem

ge flows and

designed to hastorage facili

ncentrations oblem with theor L/kg), wh

he NAG testinted in GRE (2

uid:solid ratiosa 1:1 liquid:so and zinc fromthe waste roc(MWMP), whed (see Maesmust be appli

le constituentss used for tes

ato wastes as H values are could result in ve 4 and UV

waste rock exp

inant leachinghe site to avo

planned mitiga

ant release

leaching can bials and blasti

m exposed PAGn addition, an

ost-closure is pecific site, a

eration. Howeed during opeal., 1991, Har

mented over a

d metal load

andle low flowity (BRSF). A

of leached e selected sho

hich will diluteng method use2014); maxims should be usolid ratio, andm the spent o

ck (ESIA, 201hich uses a 1:t et al., 2005 ied to weathes during or shting was not

follows: “NAconsistently loall lithologiesamples an e

pected to gene

g risk at the Aid short and lation and sug

begin now wiing agents, sepG wall rock. WAdaptive

an “unsuppors no attempts

ever, acid generations, with rt et al., 1991

a likely time f

ds of mine-inf

ws generated At high flows

ort-term e ed a

mum sed. As

d the re and

15, :1 for

ered hortly

AG pH ower es being effluent erate

Amulsar long term ggested

ithout paration Waiting

rted s have neration

). frame of

nfluenced

as and/or

metal loadsthat a PTS can active trerapid sludg

The plan toARD and socontrary, mpumps and operating a

The design relevant syshardrock minstalled at that containGusek repoand sulfate flows were

The PTS prquality thananticipate thConsulting,mined rockmetal loadsoperations.

The Amulsinstalled aftflows to conneutralize aresult in the

A PTS is althiocyanateproposed Ppreviously-not shown tclimate in tgeology of

Low flows both faciliticapture uncgroundwatethe plannedhigher thanactive treatmmine-influe

s, the rapid accan offer. In featment systee accumulatio

o control contaolids settling

metal sludges apipes. Better lime plant w

of a PTS durstems operatin

mines. Two of an historic, a

ned high metaort discusses e

concentrationonly 6.3 gpm

roposed for thn these two exhat it will con, 2015). The h

k was likely tos during the d

ar PTS is desfter Year 4 of ntain high loa

acidic pH ande plugging of

lso planned toe (among otheTS has no pro

-discussed exathat these exathese examplethe ore body

expected fromies is capturedcertain. Uncerer inflow to thd PTSs. The un those predictment system benced waters w

ccumulation ofact, rapid sluem, such as a on. This is on

act waters in will happen e

are not expectcontrol of the

with a proper c

ring the mine ng at existing

f these examplabandoned unal concentratioeffectively trens and low pH

m (23.8 L/min

he Amulsar prxamples. Howntain higher mhumidity cell o be rapid. It ievelopment o

igned to treatmining to treads of acidity

d to control sluf the initial nit

o treat draindoer contaminanovisions to treamples demonamples are reles are comparassure that dr

m these the Bd, and flows rrtainties in thehe pits add laruse of a PTS bted in the desbefore miningwith elevated

of solid residuudge accumulHigh-Density

ne of the reaso

Ponds PD-7 aeasily and wilted to settle eese sludges w

clarifier.

planning stagg mines. The Ples appear to derground baons, had a low

eating flows frH. The systemn).

roject has simwever, we havmetal concentr

test results (Fis reasonable of the BRSF a

t 11.1 L/sec (~at low flows and dissolve

udges resultintrate BCRs an

own water fronts) are likelyeat these consnstrate that palevant to Lydirable to those raindown che

BRSF and HFLremain low. Te water balanrge uncertaintbecomes a riskign documeng begins. The

d levels of me

7

ues (metal sludation is one oy Sludge (HDons why it is r

and PD-8 durll not impact

easily in thesewill be necessa

ge should be cPTS design mbe relevant. T

ase metal minw pH, and hadfrom an historm was designe

milar flows anve raised concrations than thFigure 2) showto expect that

and these will

~15 gpm) (ESfrom the wasd metals. The

ng from alumnd failure of th

om the HLF. Ay to be presentstituents. Whiassive treatmian’s Amulsaanticipated a

emistry will b

L assume thatThe lack of a nce, the grounties in the preky propositio

nt. It is far moe system shouetals, sulfate, a

dges) requireof the main caDS) treatment required at A

ring operationgold extractio

e ponds and thary and will o

conservative memo provideThe first Guse

ne. The water d flows of 0.9ric undergroued to treat onl

nd is predictedcerns about ththose shown iwed that acid

at there will bel have to be tr

SIA, 2016, Apste rock pile (Be PTS design

minum and ironthe system.

As we indicatt in HLF rinsaile Wardell-A

ment of HLF dar project, i.e.at Lydian. In fbe different.

t the vast majsynthetic line

ndwater modeedicted flows on, especially ore prudent to uld be capableand acidity.

es significantlauses of PTS plant, uses clmulsar instea

ns assumes thon and recovehis may resultonly be achiev

and supportedes examples oek (2011a) resource was m9 gpm (3.6 L/

und mine that ly 7 gpm (26.

d to have betthe predicted win the design dd generation ae a high buildreated early d

ppendix 3.3) BRSF). Howincorporates n precipitatio

ated in our revate and draind

Armstrong (20draindown is a, that the draifact, significa

jority of drainer under the Bel, and a lack o

and chemistrif metal loadinstall a cons

e of treating la

y more manafailures. By clarifiers to ma

ad of a PTS.

at neutralizatery operationt in clogging ved reliably b

d by exampleof PTSs used port describe

mine adit disch/min). The 20also had high.5 L/min), and

er inflow watwater quality document (So

and metal reledup of acidityduring mining

and is predicever, we expeno front-end

on. This omiss

view, arsenic down, and the017) argues thachievable, thindown chemant difference

ndown water BRSF makes eof understandry of waters feds are significaservatively-dearge volumes

agement contrast, anage

tion of ns. On the

of by

es of at s a PTS harge

013 h metal d peak

ter and overeign ease from y and g

ted to be ect these unit to

sion will

and e hat hey have

mistry or s in the

from effective ding of feeding antly esigned s of

Lydian ne

const

a. Wa

Reviewers groundwateassessment from the modischarge stshould be bresources.

Golder admGroundwathydrogeologroundwateperched wawith as an o

The 2016 EStudy (abovintersect wi

The water bgroundwateManagemengroundwate

According tpredicted toperiod (starmine develo6.10.1, Sectmining. Thpreclude msafety is mawater balan

The FS (20pumping ofimprove stareduce minmaximum iwater, yet nsystem.

The detentistorm (FS, pExtreme stodesign.

eeds to ma

truction, mi

ater balance a

of the Bronozer inflow to thare highly un

odeling or asstarting at Yea

built as a cont

mits there are lter Modeling ogical regime er inflow duriater bodies wioperational is

ESIA still statve) indicates ith the ground

balance appener would entent Plan (2014er is not a sign

to Appendix o exceed the arting on p. 22)opment, at thtion 6.4). Thae report statesining. Statemaintained.” (pnce.

15, NI-43-10f perimeter deability of the ping costs and in-pit dewaterno contingenc

ion pond (desp. 205), and torms possible

anage and p

ning, closu

assumptions a

zian-commisshe open pits dncertain, and tsessments. Ouar 4 of miningingency, give

large uncertaiStudy, p. 39)surrounding t

ing mining. Sithin the faultesue.”

es that no grootherwise: ESdwater table,

ndix that was r the pit (ESI

4), p. 12: “Allnificant long-

6.10.1 in the available stora). The first sce peak of cumat would be dus that the pits

ments such as “p. 19) indicate

1), p. 187, maewatering welpit walls, andimprove safe

ring pumpingcy plans exist

igned to storethe HLF Storme under climat

plan for eve

ure, and pos

and effects

sioned reportsduring miningthe ESIA (20ur conclusiong is not substaen the availab

inties in their: “The regionthe ore bodieimilarly, the oed geological

oundwater wilSIA, p. 3.67: and so there w

not included A, 2015, App pit water com-term source o

2015 ESIA (mage capacity i

cenario wheremulative exceuring Year 1 could be use“Because twoe that climate

akes it clear tlls, which wil

d ensure that tety and envirog capacity is 1

for installing

e all contact wm Ponds (1 ante change con

8

ery potentia

st-closure

s state that theg. However, th016) does not ns remain thatantiated and tble geochemic

r groundwaternal groundwats with sufficioccurrence ofl sequence can

ll enter the pi“Groundwatewill be no wa

in the 2016 Ependix 6.10.1mes from metof groundwat

missing in 20in all three sc

e excess waterss water durinof mining, ye

ed for water sto such stormschange has n

that the only dll very likely he materials bonmental perf60 L/s. Dewa

g perimeter de

water from pitnd 2) are desinditions have

al source o

e ESIA and thhe results of taccurately ort the basis forthat a lime trecal testing res

r model (ESIAter flow modeient accuracy f isolated permnnot be readi

it, even thouger modelling iater ingress to

ESIA also use Site Wide Wteoric water (ter.”

016 ESIA), thcenarios examr would exceeng pre-producet no treatmentorage durings are not expenot been serio

dewatering cobe needed to being mined aformance in tatering of welewatering wel

ts and the BRigned for a “tyapparently no

of contamin

he groundwatthe modeling r adequately ir only needingeatment or revsults and close

A, 2016, Appel is not able tto predict ratmanent and sily predicted a

gh the Groundindicates that

o the pit via gr

ed an assumptWater Balance(snow and rain

he cumulative mined during aed available sction (ESIA, nt is proposedg those time, bected in the sausly consider

onsidered is inestablish hydare dry. Thesthe medium alls will likelylls and adding

RSF) is sized ftypical wet yeot been incorp

nated water

ter model do and groundwncorporate fing treatment anverse osmosise proximity to

pendix 6.9.1. to represent ttes of permansemi-permaneand must be d

dwater Modelt the pit floor roundwater so

tion that no e and Water n). Perched

excess wateran extremely storage is very2015, Appen

d until Year 5but this wouldame year, a fared in the site

n-pit dewaterdrologic contrse positive effnd long term.

y produce mucg an active tre

for the 100-yrear” (FS, p. 20porated into t

r during

assess water ndings nd s plant o water

the nent ent dealt

ling will not ources.”

r is wet

y early in ndix 5 of d actor of e-wide

ring, not rol, fects will . The ch more eatment

r, 24-hr 03). the

Updates to outflows, owould be Funderstandiponds will b2017, p. 27can contain

The problemneeding treupon a highcannot adeqwater, perimwill likely rcontaminanit is not accespecially wbe fully ope

Lydian’s w

Lydian usesiron oxidatirock unit is

Similarly, tARD.” As aindefensiblemost drainathat the pasbe generate

Lydian ha

One of the based on thavailable. USocial Riskand dissemintent to me

a. TheupdIsla

Buka Envircurrent ESIincluded in no referenc

the water baln-site manageigure 18.2 froing the need fbe lined or if 5), will be mo

n contaminant

m with the staatment until Yhly uncertain quately dewatmeter dewaterrequire treatmnt concentratioceptable to be when the wateerational befo

wording co

s terminologyion” is unusua likely to gen

they refer to “an expert in the statement. Iages from basssive treatmened at Amulsar

as not been

comments frohe most recentUnder the IFCks and Impactination of releeet internation

e Feasibility dated geocheands.

ronmental statIA (2016). Cothe Geocheme or link was

ance are in prement and stoom Lydian (2for treatment water releaseonitored for cts and should

atements and Year 4 of minwater balanceter the pit or cring wells wil

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nfounds iss

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nerate acid dra

“passive treatmhe field and aIt is only true se and preciount system desir.

transparen

om the reviewt available inf

C’s Performans (IFC, 2012)evant, transpanal standards

Study and oemical testing

ted that the nuomments to thmical Characte

provided. Ly

rocess, but whorage under d017), but withduring operat

ed to the envircontaminants be part of the

assumptions ning. The lacke and groundwcreate a cone ll need to be iof the high vomped water reon of a large-so uncertain. atering begins

sues, minim

nds issues. Thant. The moreainage.

ment… rapida world authofor ARD from

us metal mineign put forwa

nt with its m

wers was that formation, bunce Standard ), consultationarent, objectivshould certai

other documg report tha

umeric resulthe Buka Envirerization Repydian (2017),

9

hat is needed different climah numbers. Ttions. Also, nronment, incland treated if

e site monitor

highlighted ak of treatmentwater hydrogof depressioninstalled. Watolume of wateesulting from-scale mine anA reverse osms.

mizes appar

heir referencee relevant fac

ly becoming trity, one of um coal mineses. More impoard for this pro

most data-ric

the most receut not all the p1: Assessmenn with stakehve, meaningfuinly include tr

ents, includit is not avai

s for the geocronmental rep

port which is ip. 351 states:

is a series ofate scenarios,

This kind of inno mention is luding to the Gf necessary bering program.

above is that tt for four year

geologic assesn for hydrologater pumped frer and the inc

m blasting. Adnd have NO wmosis or lime

rent risk

e to minerals wct is that humi

the industry-sus knows that s in Eastern Aortantly, this oject is inapp

ch reports a

ent reports wepertinent infornt and Managolders should

ful and easily ransparency o

ing the ESIAilable withou

chemical testiport respondeincluded as an: “The charac

f diagrams sho, with uncertanformation is made of wheGndevaz Resefore discharg.

they provide rs of large-sc

ssment. If in-pgic control of

from perimetecreased nitratedditional studiwater treatmee treatment pl

wastes being idity cell tests

standard for athis is a wild

Appalachia, bustatement sid

propriate for th

and append

ere not reviewrmation has b

gement of Envd “be based onaccessible infof information

A (2016) refeut making a

ing program aed that “Numen appendix to

cterization of

owing water iainties. An excritical for

ether the contaservoir (see Lyge. Non-conta

the basis for nale mining repit dewateringf mine-influener dewatering e and other ies are underwent available, lant must be b

resistant to “fs show that ev

all but the moly optimistic,ut not for ARDdesteps the keyhe drainage th

dices.

wed. Our revibeen made puvironmental an the prior disformation.” Ln.

er to results trip to the

are not includerical results o the FS.” Howthe Acid Roc

inflows, xample

act water ydian, act water

not elies g sumps nced wells

way, but

build and

ferric very

ost severe , D or y issue hat will

ews are ublicly and sclosure

Lydian’s

from an Channel

ded in the are wever,

ck

Drainage (Areport has bhttp://wwwtesting, andmeasures.” mention of is not includnot want to

“Waninag

The updateshould havefor the projtransparent

b. TheLyd

The reviewdeterminedApril/May 2017 report

c. In infoava

The followiLydian Armquestion rem

Lydian shou

2015 ESIA

3.1 Feasibil

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ARD) propertbeen fully‐upd

w.lydianinternad to report pre

This link leaAppendix 15ded in the Fea transparently

With the excend drawings Helier Jerse

greement.”

d geochemicae been includect. Making dwith its stake

e Independendian documen

wers of the rep as sufficient 2017). A Knit was not avai

addition to thformation abailable in the

ing appendicemenia websitemains: why w

uld upload th

A Appendix

lity Design of

lity Design of

hemical CharReport

ties of the Amdated by GREational.co.uk/

edictive modeds to the 2016

5 can be foundasibility Study release the i

eption of Appcan be viewe

ey, Channel I

al characterized as an appedocuments dieholders.

nt Environments, but it is n

ports stated thby Independe

ight Piésold reilable.

he appendicebout the min

2015 ESIA a

es were availae. The 2015 Ewere these key

hese and all ot

Table 3. App

x # and Title

f BRSF

f HLF

racterization a

mulsar site waE (Appendix /reponsibility

eling associate6 ESIA. Apped on the Lydi

dy. A statemeninformation c

pendix 1 - AMed and are avIslands, Unit

ation report wendix in the 2fficult to find

ental and Socnot available

at testing, theent Environmeport from 20

es not availabne’s environare not includ

able electroniESIA is still avy appendices

ther missing a

pendices mis

e

and

10

as first reporte15 found in E

y/esia) to inclued with the upendix 15 doesan Internationnt at the beginontained in th

MC Appendvailable In thted Kingdom

was completed016 ESIA and

d does not fost

cial Consultato the public

e EMSP, and mental and Soc016 was found

ble in the Feanmental perfded in the 201

ically in the 2vailable on thexcluded from

appendices to

sing from th

Notes

2016 Appendreport on the A of AppendBRSF.

The feasibilitincluded in th

This report cocontaminant materials.

ed by Golder ESIA version ude the resultp‐to‐date mins not exist. Thnal website (nning of the Fhe FS append

dices A, B andhe Lydian In

m after signin

d by the publd made easilyter trust in the

ants (IESC) rc.

other Lydian cial Consultad online (Kni

asibility Studformance an16 ESIA.

2015 ESIA, whe Lydian Intem the updated

o their website

he Amulsar 2

dix 3.1 is titlepassive treatm

dix 8.1.9 also

ty design for the 2016 ESIA

ontains criticaleaching char

Associates (G10, found on

ts of additionane planning anhe FeasibilitySGS, 2015). IFS makes it cdices:

d C, all othernternational Lng a confiden

lication date oy available one ability of Ly

report is men

documents oants (IESC, Knight Piesold a

dy, five appennd visual ap

which is no lonernational wed 2016 ESIA

e for the proje

016 ESIA.

ed BRSF desigment system addresses the

the HLF and A.

al informationracteristics of

Golder, 2013cthe Lydian w

al geochemicand ARD mitigy Study (FS) aIn fact, Appelear that Lydi

r documents Ltd. offices

ntiality

of the ESIA an the Lydian wydian to be

ntioned many

or studies havnight Piésold

and Co., 2016

ndices with imppearance th

nger availableebsite, but the?

ect (Table 3).

gn but is inste(PTS). Appen

e PTS for the

the BRSF are

n on the f Amulsar min

c). This website at al gation and a ndix 15 ian does

and website

y times in

e been d, 6), but the

mportant hat were

e on the e

ead a ndix

e not

ned

2015 ESIA

6.5.1 Figure

6.10.1 Site Managemen

Recomme

Stacor

Shomin

It iswilacidoxi

pre

Basgentim

The(abgenpre

Angrome

Thegeouncsysbe and

Theand

A Appendix

es

Wide Water Bnt Plan (2014

endations

atements in thrrected.

ort-term leachned materials

s stated in sevll be undertakdity (i.e. the idation. How

eviously were

sed on furthneration shou

me scale of thi

e current Besbove a cut-offnerate acidityevent long-ter

Adaptive Moundwater eleasures to be t

e basis for onochemical tescertainties in stem should bcapable of tre

d acidity.

e site-wide wd taking more

x # and Title

Balance and W4)

he ESIA abou

h tests with lo.

veral places inken during 2presence of jever, the test

not − and suf

her testing anld be modelles evolution.

st practice to f grade) from y should be dm acid genera

Management evations shoutaken, respons

nly needing tsting results ithe site water

be installed beating large v

water balance e extreme even

e

Water

p

ut the acidity

ower or varia

n the reply fro2017 and therjarosite and at samples ne

fficient in num

nd planned red and mitiga

identify sulfinon-sulfide w

dumped near ation (MEND

Plan (AMP)uld be in placsibilities, and

treatment starindicting a str balance, andefore mining

volumes of m

should be recnts (>100-yr

11

Notes

Contains 103visibility of thfrom various and Gndevez

The 2015 sitecontained no site during opproviding linkon the LydianAppendix 6.1

of springs sh

able liquid:sol

om the reviewreafter. This alunite) and reed to be pro

mber and dur

rates of wasation measure

ides at the wawaste should one of the

D, 2015).

) to address ce now. The

d evaluation o

rting in Yeartrong potentiad the close pr

g begins. The ine-influence

calculated assstorm) into ac

3 pages of mahe mine throuvantage poin

z Village.

e wide water bnumeric info

perations and nks. The referen website. Th10.1.

hould be comp

lid ratios shou

wers that consshould serve

rate and degreoperly repres

ration.

ste rock accues should be

all face and sbe implemen

pits, and eve

changes in plan should

f mitigation e

r 4 of operatial to developroximity to wsystem shou

ed waters with

suming the neccount.

aps and drawinughout the yents in the area

balance ESIAormation on fld references toenced reports

he 2016 ESIA

pared to the w

uld be condu

siderably more to address ee of acid gesentative – th

umulation, thplanned to sp

segregate wasnted. Sulfide entually back

water qualiidentify trig

effectiveness.

ion is not subp acid drainagwater resourceuld be designeh elevated lev

eed for perim

ngs showing ears of mininga, including Je

A appendix flows at the mo reports withs are not avail

A eliminated

water quality

ucted on repre

re geochemicsuch issues a

eneration due hose chosen

he evolutionpecifically ad

ste containingwaste that is

kfilled and fl

ity, streamflogger levels, m

bstantiated. Gge, the acknoes, an active ted conservativels of metals

meter dewater

the g ermuk

mine hout lable

data and

esentative

al testing as stored to pyrite for HCT

n of acid ddress the

g sulfides likely to

ooded to

ows, and mitigation

Given the owledged treatment ively and s, sulfate,

ing wells

Lyprecleawer

ydian’s intentevious documarly named inre not subject

t to meet inments and datn chronologict to a confiden

nternational sta should be cal order. It wntiality agreem

12

standards shoplaced on th

would confer cment.

ould include he same Lydicredibility if t

transparencyian website athe availabili

y of informaas ESIA 201ity of these do

ation. All 6 and be ocuments

Reference

Golder, 201Lak

GRE, 2014Glo

Gusek, J., KcheAmSucLexAvhttpON

Gusek, J.J.,opemeFighttp

Hart, W. MProAbInteSochttpard

Knight PiésEnvMahttp

Linklater, CJaro(IC629Av

Maest, A.SMeonlhttpiCe

Mine EnvirWahttp

SGS, 2015.IslaAm

Sovereign CMe

es Cited

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ical Characterr Associates Imical Characg Ltd. and Shipley, B

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/detail/predict

15. Report 2.udy Results -ds/2.36.1b-In-Study. Prepareianinternation

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BIOCHEMIC_GOLINSKYdiverting cap a. InterntationO USA. Proce

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ting_water_qu

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-Pit-Disposal.ed for: Lydiannal.co.uk/ima

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actor construc1 National M

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pdf. us Model to Prrnational ConfCanada, Voluandards on En

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iew of the Amrion Resource

5490a23f2a1cAcid Genera

ence on Acid da 20-26 Mayk, NY 12571

Water Qualityks, Washingto

uality_at_har

t Disposal of 2015.250 p. A.pdf n Internationaages/Technica

Design Basis

Amulsar Gold

date, 31 Augu

tion and mineMeeting of the

nces Leadingtavesta Rd., nver, Colorad

TOR_CONSTLIFORNIA. e biochemicaler Associatiokersdorfer, Br

redict the AMference On T

ume 2, 257-27nvironmental

C_Performanc

mulsar Projecte Partners (US

ccb71005c8.pation from AluRock Drainagy 2012, ISBNpp. 1051−106

y at Hardrockon, DC. Avai

rdrock_mines

Reactive MinAvailable onl

al, LTD., ChaalReports-pdf

s. Technical

d Project.

st 2014,

e pool

g to

do.

TRUCTI

l reactor n rown &

MD The 70 pp. l and

ce_Stand

t SA) LP.

pdf unite and ge

N: 978-1-62.

k Mines: ilable

/#.WTW

ne line:

annel fs/2015-

Wardell ArAsshttpesia

Wardell ArAsshttp

Wardell Ar44

ZiemkiewicRocTas

rmstrong, 201sessment (20p://www.lydiaa rmstrong, 201sessment (20p://www.lydiarmstrong, 201pp. cz, P., J. Rentck Type and Ask Force Sym

5. Lydian Int15 ESIA). Avaninternation

6. Lydian Int16 ESIA). Avanarmenia.am7. Response t

ton and T. RyAmendment,"

mposium, Apri

ternational Amvailable on Lyal.co.uk/proje

ternational Amvailable on Lym/en/publicatito Reports Pr

ymer, 1991, "P" in Proceedinil 3-4, 1991, M

14

mulsar Gold Mydian Internatects/amulsar/e

mulsar Gold Mydian Armeniions.html repared by Mr

Prediction anngs Twelfth AMorgantown,

Mine Project,tional websiteenvironmenta

Mine Project,ia website:

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nd Control of AAnnual West , West Virgin

, Environmene: al-and-social-

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Drainage: Effeface Mine Dr

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