In many industries and technological processes, a liquid imbalance occurs that requires further management. For regions with a sufficiently warm climate, the most cost-effective method is natural evaporation in specially designed facilities — ponds. Potash fertilizer production is no exception, where not all brine volume is returned to the production cycle.
Why are evaporation ponds needed?
Evaporation ponds are not facilities for the treatment and/or disposal of potash ore processing waste (clay-salt sludge). Instead, they are aimed at solving the brine imbalance problem through the natural evaporation of excess brine from the free water surface, banks, and basin. They also allow for a reduction in water intake from natural sources for the technological needs of a mining and processing plant (GOK). The purpose of evaporation ponds is the natural evaporation of excess brine.
Features of identifying objects of negative impact
According to Article 1 of Federal Law No. 7-FZ dated January 10, 2002, "On Environmental Protection," an object that has a negative impact on the environment (NVOS) is a capital construction object and/or another object, as well as a set of objects, united by a single purpose and/or inseparably linked physically or technologically and located within one or more land plots.
Thus, there are two alternative criteria for classifying a set of objects as an NVOS object:
According to Decree of the Government of the Russian Federation No. 2398 dated December 31, 2020, "On Approval of Criteria for Classifying Objects Having a Negative Impact on the Environment as Category I, II, III, and IV Objects," the performance of economic and/or other activities on subsoil plots provided for use in accordance with the Law of the Russian Federation "On Subsoil," which is not specified in sections I, II, and IV of this Decree, is a criterion for classification as Category III objects. Evaporation ponds are located within the boundaries of a deposit (subsoil plot); therefore, during identification, they can be classified as Category III objects.
If evaporation ponds are technologically linked [1] to the GOK's tailings storage facility, in most cases, this connection is not inseparable, as almost all existing tailings storage facilities in the Russian Federation are currently operated without significant difficulties in the absence of evaporation ponds.
A GOK tailings storage facility is a disposal facility (in terms of storage) for Class V waste, which, according to the criteria of Decree No. 2398, corresponds to a Category II NVOS object.
Objects of State Environmental Expert Review
In accordance with Article 11 of Federal Law No. 174 dated November 23, 1995, "On Environmental Expert Review," the objects of the State Environmental Expert Review (GEE), among others, are:
Thus, the design documentation for "Evaporation Ponds" cannot be an object of GEE as provided for in clause 7.5 of Article 11 of Federal Law No. 174, since evaporation ponds, under various approaches, can be classified exclusively as Category II or III negative impact objects. Nor can they be covered by clause 7.2 of Article 11 of Federal Law No. 174, as they are not intended for waste disposal and/or treatment.
Will Rosprirodnadzor support this position? Perhaps not, but a corresponding inquiry has already been sent.
[1] In Rosprirodnadzor's letter No. MK-02-02-34/26174 dated August 1, 2022, it is stated that the inseparable technological connection of a set of objects consists in the impossibility of carrying out economic and/or other activities using the NVOS object, or the occurrence of significant difficulties in its implementation, in the absence of at least one of the objects in the set making up the NVOS object.