Robert E. Moran, Ph.D. Michael Moran Associates, L.L.C. Water Quality/Hydrogeology/Geochemistry Golden, Colorado, U.S.A.
[email protected] Ada Tepe Gold Deposit EIS, Krumovgrad, Bulgaria: Technical Comments Summary. 1-The project will use tremendous volumes of water: roughly 2.9 billion liters per year. The validity of the claim that roughly 98% of this water will be recycled has not been demonstrated. Merely the proposed extraction well in the Krumovitsa gravels requires 5 liters per second, which equals 157,680,000 liters per year. Long-term pumping of this well would, in fact, be extracting water indirectly from the Krumovitsa River. 2-Long-term water extraction will increase local competition for water. It may also lead to declines in local ground water levels and cause spring flows to reduce or cease. 3-The EIS fails to provide any site-specific, quantitative testing of the local aquifers to determine the actual volumes of ground water available and the impacts from long-term pumping on other water resources. 4-BMM operations will crush and expose massive volumes of mineralized rock to chemical reaction; will use tremendous quantities of explosives, fuels, oils and greases, chemical process reagents, herbicides, pesticides, antifreeze, etc.---all of which are potential contaminants, and are routinely released into the environment at mine sites. 5-Contamination of local ground and surface waters will occur over the long-term. 6-Truly “closed-circuit” systems do not exist in fact in mining. All facilities leak to some extent, long-term. 7-Facility wastes will remain on site forever---requiring long-term maintenance.