The Rosia Montana gold and silver ore deposit, which has been mined for over 2000 years, was a jewel in the crown of both the Roman and the Austrian-Hungarian Empires and the most important gold producing region of Europe throughout these ages. More recently the site has gone through over 40 years of state-owned underground and open-pit mining. These historical activities, conducted with few environmental controls, have created a network of more than 140 kilometres of underground workings, and have become an extensive regional source of acid rock drainage (acidic water with heavy metal content). The name "Rosia Montana" meaning "Red Mountain" is largely attributed to the streams of red water flowing down its valleys with pH readings as low as 2.5, and existing water chemistry pollution over 70 times the Romanian legal limits.
Accordingly, development of the Project faces the environmental challenge of rectifying two thousand years of aquatic and other forms of pollution in accordance with Romanian laws, EU guidelines and World Bank standards using state of- the-industry internationally accepted mining and treatment practice. This will be accomplished in three steps. The first is to identify the current pollution sources. The second is to identify the pathways through which this pollution enters the downstream environmental system. The third and final step is the isolation and/or removal and treatment of the pollution and the beginning of biodiversity rehabilitation.
A record of these measures in a report, submitted to the Ministry of Environment.
The EIA was prepared in compliance with Romania law and in accordance with all relevant European Directives and International Best Practices to identify, assess, mitigate and manage the likely impacts associated with the project.
In fact, our EIA is the first in Romania to be EU-compliant and is designed so that not a single exemption from existing or planned laws is necessary. To illustrate our commitment to high standards, wherever Romanian and EU requirements differ, Gabriel has chosen to abide by the stricter of the two. In addition, while existing gold mines will have as long as 10 years to come into compliance with stricter regulatory standards, our Rosia Montana Project will meet these standards from Day One.
Following the EIA submission, the company undertook an extensive public-consultation process as required by law, with hearings held in 14 locations in Romania, from the village of Rosia Montana to Bucharest - with the objective of openness and transparency that should be part of any project of this scope. To honour the spirit of the Espoo Convention covering possible transboundary impacts, we translated the Non-Technical Summary of our EIA into Hungarian, and held two public hearings in Hungary as well.
This extensive series of public meetings on the Rosia Montana EIA was a first in Romania for technical projects of this size.
In accordance with the laws and directives applicable to our project, questions and concerns from all of the hearings, gathered and methodically collated by the Romanian Government, were presented to our Company in January 2007.
We delivered the Annex to our EIA to the Romanian Ministry of Environment in May 2007 providing answers to each of the 5610 questions and 93 contestations put forward. The Annex, which runs to 12,600 English pages (12,900 Romanian pages), provides detailed responses to each question, incorporating environmental, social, cultural, technical and legal aspects of the Rosia Montana Project into the answers. In cases where questions suggested a need for more information and analysis, the Company commissioned in-depth studies, which are also presented to the Romanian Ministry of Environment as part of the Annex. Examples include an independent Water Quality Modeling Study that was designed to determine river water quality downstream of the proposed mine from two perspectives: firstly, assessing the beneficial impacts of the clean up of past ("historical") mining pollution and secondly, assessing the potential impacts resulting from worst case scenario pollution events from the Rosia Montana Project. Work was also done to detail the costs of developing the area for tourism alternatives both in the absence of the new mining project and as a parallel program to the new mine.
In addition, Gabriel has chosen to adopt a broader range of more stringent requirements such as:
UN Global Compact
Cyanide & Water Management
Cyanide (a substance comprising of one atom of carbon and one atom of nitrogen) is commonly used, among other things, for the extraction of gold and silver from ores similar to the Rosia Montana Project. Over 400 gold mines worldwide currently use cyanide in their operations to recover gold and silver. In large quantities, cyanide is harmful to humans and other living organisms. The Rosia Montana Project is conceived in such a way so as to ensure the highest level of safety for both employees and the environment, in all activities involving cyanide. These activities include transportation, storage, usage and detoxification. In the modern processing plant that will be built, cyanide will be used in full compliance with national and European Union legislation, following international best practices. The processing plant will be equipped with sensors to detect cyanide or cyanide compound concentration levels so as to ensure efficient real-time monitoring. All stakeholders will be informed at all times of the main activities involving cyanide.
Cyanide Occurrence
Cyanide is present in non-harmful levels in many areas of everyday life. Example: potatoes, medication, table salt. Cyanide is also manufactured artificially for industrial requirements. The EU is the world's largest producer of artificial cyanide. Transportation of cyanide within and from the EU is conducted safely on a daily basis by truck or train.
Cyanide Use
Only 13 percent of manufactured cyanide is used in the gold industry, with 87 percent being used in industries as diverse as food processing, pharmaceutical and manufacture of plastics. Proven and well-developed designs and procedures exist for the use and management of cyanide to establish and maintain a safe working environment.
International Cyanide Management Code
A project specific Cyanide Management Plan (the "CMP") for Rosia Montana has been prepared in accordance with the International Cyanide Management Code (the "Code") for the gold mining industry. The Code was developed under the auspices of the United Nations Environmental Program (UNEP), to assist the global gold mining industry in improving cyanide management, thereby minimizing risks to workers, communities and the environment from the use of cyanide in gold mining, and reducing community concerns about its use. Gabriel is a signatory to the International Cyanide Management Code (ICMC) and is fully committed to full implementation of its principles in all aspects of responsible cyanide manaagement at our future mining operations. The Rosia Montana Project is the only European signatory to the ICMC, endorsed by the G-8 in June 2007. We believe the Code provides the necessary framework to ensure protection of workers, the environment, the community and also provides the community with a process that publicly demonstrates responsible management of cyanide. Gabriel's operations will work towards compliance with the Code and future projects are being, and will be, designed and constructed to meet the Code requirements. As an example, the current best practices international standard is 50ppm cyanide, and the new EU standard requires existing mines to reduce from 50ppm to 25ppm in five years, and to 10ppm in 10 years. All new mines applying for permits must meet the 10ppm limit immediately. At 6ppm, the Rosia Montana Project will exceed these standards from Day One.
Cyanide Management Plan
The comprehensive CMP has been developed for the use of cyanide in connection with the Project. The CMP is being reviewed by an independent team of international experts in order to ensure that it identifies and addresses all possible cyanide related risks associated with its use at the Project. All aspects of transportation, storage, handling, use, and final detoxification are covered by the CMP.
Transportation, Storage, and Handling of Cyanide
Sodium cyanide will be purchased in solid form and will be delivered in containers specially designed for cyanide transporation - special trucks with double-walled tanks that are extremely resistant. Each transport will be accompanied by an emergency intervention vehicle. To prevent leaks upon delivery, the solid cyanide will be dissolved in the tank and pumped directly into the storing and distribution system. It will not be handled in the open at any time. All the containers will be returned to the supplier in order to be reused, thus eliminating any potential problems related to their treatment and final storage.
Cyanide Detoxification - We will not leave cyanide behind
In a modern mining project, most of the cyanide is used in the chemical processes related to the processing of the ore. Most of the remaining cyanide can and will be detoxified using a modern and efficient oxidation process. The small amounts of cyanide that will remain after this will transform naturally over time into a non-harmful substance. This process has been used in more than 80 mines throughout the world over the past 30 years. After detoxification, tailings with low cyanide content will be pumped into a specially-built tailings management facility. The concentration of cyanide in the dam will be lower than the maximum limits imposed by the EU Mine Waste Directive. This Directive dates from 2008 and determines the European requirements and limitations for cyanide discharge. Those mines already in operation are required to gradually reduce their cyanide concentrations to 10ppm (parts per million) by 2018 at the latest. New mines will have to meet these requirements from the beginning. The Rosia Montana mine will have a concentration of 5ppm from day one.
Monitoring
If at any time the concentration of cyanide exceeds the safety level, an alarm will automatically sound, and the pumping systems will automatically shut down. In the case of a blackout, back-up electrical generators will kick in, which will ensure the system's continuing functioning. Employees will receive individual protective equipment and full training covering all aspects of cyanide management.
Water Management
All Acid Rock Drainage will be collected and treated. The entire process plant and TMF for the Project is being designed to maximize the use of recycled water and minimize its impact on the environment. Water will be recycled back to the process plant from the TMF. A secondary containment and collection system downstream of the TMF will collect any seepage water and this will be pumped back to the process plant water system. The only water released from the Project will be that required to sustain environmental flows downstream of the dams. These waters will be treated and checked to comply with all legal limits. To protect against water contamination, the Company will construct engineered surface water diversion structures, catchment dams, pumpback systems, water treatment facilities, process water recycling systems, a fresh water supply system, and other water management systems or structures, all in accordance with best management practices.
Contingency Plans
Due to the inherent risks in cyanide use (as with other chemicals), independent international experts have been engaged to review the designs to ensure that the Project meets international safety design, construction and operating standards.
An integral part of the CMP will include a detailed Emergency Preparedness and Spill Contingency Plan, and Community Emergency Preparedness Plan. The CMP addresses the Project's preparation and procedures for handling any possible accident and local and regional authorities will be involved in its development, practice and implementation.
Extractive Waste Management
Introduction
The Rosia Montana Project's mining operation will generate two principal types of waste: waste rock and tailings. Waste rock is the rock that has to be removed before the gold and silver bearing material can be mined. Waste rock consists of overburden soils and rock with uneconomic concentrations of gold and silver that will not undergo any kind of processing. Due to the low stripping ratio at the Project, a total of approximately 13 million tonnes of waste rock will be mined from the open pits each year. Waste will be placed in a series of managed waste stockpiles situated near the open pits. Tailings is the ground (milled) rock which results after extraction of the gold and silver minerals (it looks like grey sand). The tailings are partially dewatered and treated to minimize residual cyanide levels (to below international standards) prior to being placed in the Tailings Management Facility (TMF). Tailings from the Project will be transported from the process plant as slurry through pipelines to the TMF located in the Corna Valley.
The non-extractive waste (used oil, lead-acid batteries, waste aerosol containers, used tires, used oil filters, end-of-life vehicles) generated by the Project will be managed in compliance with the strategic principles and objectives presented and approved in the National Strategy for Waste Management ("NSWM"), according to which waste management costs should be covered by the generators of waste. The NSWM is based on resource protection (minimizing usage), the avoidance of waste generation, minimization of waste quantities, treatment for recovery, and treatment and disposal in environmentally sound conditions. Furthermore, waste will be treated or disposed of as close as possible to the site where it was generated and exports of hazardous waste will be made only to sites where appropriate disposal technologies are available and that are in observance of the conditions applying to the international waste trade.
Tailings Management Facility
The TMF is designed to prevent contamination of the environment and will be constructed in stages over the life of the Project. An 80-metre high starter dam will be the first stage and once fully developed, the TMF dam will be a 180-metre high rock-filled containment structure. A secondary containment dam, with a pump-back system, will collect and return seepage water to the main process plant water circuit. The final TMF is designed to provide a capacity of 250 million tonnes of treated tailings.
Design of the Tailings Management Facility
The TMF is being rigorously designed to comply with or exceed Romanian and international standards. It will provide a safe and environmentally acceptable storage facility for all treated process plant tailings. In addition to retaining the full amount of tailings, the TMF is designed to retain the most extreme probable rainfall event and to withstand extreme seismic forces. The design and construction of the TMF includes consideration for the closure requirements to be implemented at the end of the life of the Project. The entire design has been reviewed by recognized international and Romanian experts. The review confirmed that the design meets the highest safety standards. The operation and performance of the TMF will be monitored regularly to ensure compliance with the design criteria, standards and applicable regulations. There will be an additional ongoing monitoring program designed and checked by independent experts.
Tailings Facility Management Plan (TFMP)
An integral part of the design of the TMF is the preparation of the TFMP, which identifies and addresses issues related to the design, construction and operation, reclamation and final closure of the TMF. The TFMP is included in the Environmental Impact Assessment (EIA).
Acid Rock Drainage
Introduction
Acid Rock Drainage (ARD) is a naturally occurring process caused when water and air come into contact with rocks containing sulphide minerals. Naturally occurring bacteria bring about acidification which in turn leaches heavy metals from rocks. This acid water can render lifeless the aquatic environment in river basins and contaminate drinking water supplies. When rock is further exposed (for example by mining activities), the generation of ARD is enhanced.
Historical Mining, Existing ARD Problems
The watersheds of the Rosia Montana region are currently heavily impacted by historic ARD runoff. Such existing runoff results from historic mining operations, including existing underground workings, mine water from existing open pits and from ore and waste rock piles. The flow has continued untreated for decades into local streams and creeks, the Abrud river and ultimately further downstream into the major rivers of the Danube Basin. The results of ARD are visibly demonstrated by the red colour of the Rosia Stream.
Acid Rock Drainage Treatment Plant
Part of the design and development of the RMP is the construction of a water treatment plant using proven technology to collect and treat acid runoff. Some of this treated water will be used in the process plant offsetting the need to draw on fresh water supplies, while some will be discharged to the existing streams to maintain environmental base flows in accordance with regulations.
Remediation of Historical ARD Problems
The ARD plant will significantly improve the discharge water quality in the Rosia and Corna valleys reducing acid and heavy metal runoff, created by historical mining operations in the area. This will result in a significant improvement of the water quality within and downstream of the Project area. The Project will implement and maintain water management measures to intercept and divert many of the headwater streams to prevent natural water from contacting acid generating materials. This will also contribute to a significant improvement in water quality downstream of the project.
Mine Closure
Mine Closure Plan for New Mine
The closure of a mining project, if not carefully planned, is likely to have a severe negative impact on the socio-economic status of the community by the sudden removal of this major financial provider with nothing to take its place. Before starting any physical mine site rehabilitation, closure objectives and a detailed plan of action will be established for the Rosia Montana mine. Once the new mine proposed for the Project reaches the end of its lifespan, the Company will be responsible for the final stages in the restoration of the area in accordance with an approved Mine Closure Plan. The Mine Rehabilitation and Closure Management Plan ("Mine Closure Plan") being developed for the RMP outlines a plan for decommissioning the facility, rehabilitating the site and implementing a long-term programme of after-care to ensure that Mine Closure Plan objectives are met.
The Rosia Montana Project will restore the landscape to look and actually be pristine - which it is not today - for the community and visitors to enjoy. Today, there are two large open pits, rusted mining equipment and mine structures, all of which have caused environmental degradation, and there are no plans (other than Gabriel's) to remediate the area. All four pits that would be mined in the Rosia Montana Project have been mined in the past. One of them (Cetate), is today a vast abandoned crater. All four are riddled with underground workings, scarred with polluted rock waste. The rivers of Rosia Montana ("Red Mountain") run red with acid rock drainage and contain up to 110 times the legal limit for heavy metals. As part of the commitment Gabriel has made to follow best practices of responsible mining, the Company will fully remediate the area. Three of the four pits will be backfilled, re-contoured and re-vegetated at the end of the project; the fourth will be maintained as a lake. All roads and structures will be removed and re-contoured and vegetated to blend in with the natural landscape. This will all be done in participation with the government and the local community.
The socio-economic aspects of closing the mine will take into consideration the workforce and the community. To try to lessen the impact, Gabriel will work with both these groups and the government to establish strategies for on-going support. It is expected that a development plan for the region, taking into consideration the continuation of essential services such as medical care, schools, etc., and the formation of self-sufficient industries, will be established. Critical to this goal is ensuring that the full benefits of the project, including revenues and expertise, are employed to develop the region in a way that will survive after the closure of the mine.
Taken over 20 years, the injection of investment into the area, if handled correctly, should stimulate other development. Gabriel is committed to promoting long-term development opportunities as part of the sustainable development plan.
At the time of closure, the Company will do all it can for the existing workforce in providing assistance in finding alternative employment. Given the skills base and experience that the workers will have acquired, this might be jobs on other mining projects. Alternatively, Gabriel will provide the opportunity of re-training and support in setting up alternative businesses. Gabriel will provide a financial guarantee, updated annually with the Romanian Government, to ensure that the financial resources are available at all times to fully rehabilitate the area under any circumstances.