Environment
Environmental impact assessment
Before the founding of CNGR Finland Oy in May 2022, the Finnish Minerals Group started an environmental impact assessment (EIA) with consulting companies. The EIA procedure is used for projects that are likely to have significant environmental impacts (EIA Act 252/2017).
The EIA is a two-step process, where first the entity responsible for the project prepares an evaluation program, which presents the alternatives for implementing the project and investigating the environmental impacts. In the next step, the entity responsible for the project compiles the information obtained from the investigation into an evaluation report. The report describes the significant environmental impacts of the project’s various alternatives and the means of mitigating those impacts.
Several possible plant locations were evaluated and site finalists were chosen to be studied in the EIA. In the alternative designated VE1, the establishment of pCAM and CAM plants in the Keltakallio area, in Kotka, was examined. In the alternative designated VE2, the location of the pCAM plant was Hillonkylä in Hamina and the location of the CAM plant was Keltakallio.
The authorities stated that the report was prepared on the basis of the evaluation program as well as the statement issued by the liaison authority. Furthermore, they state the report meets the content requirements stated in Section 19 of the EIA Act and Section 4 of the EIA Regulation, is of sufficient quality and the liaison authority has nothing to comment on in this regard.
Currently, CNGR Finland Oy is developing the project further and looking for solutions that meet the qualitative, environmental and financial criteria as part of the green transition journey. The goal is to submit an environmental permit application to the authorities in early 2023.
According to the EIA report, the impacts of the project are not expected to weaken any part of the area’s ecology. Nor will it prevent the achievement of a sound ecology in the area’s water bodies.
Environmental impact assessment - The top 4 most common concerns
1
The authorities and nearby residents are concerned about possible wastewater emissions resulting from the process.
In particular, water salinity must be monitored. Salty water is heavier by nature, so deep water salinity measurements will be compared to surrounding areas.
Salinity will be monitored monthly even before the start of operations. If an increase in salt concentration is detected during operation, the mouth of the discharge pipe can be changed to a new location.
CNGR Finland Oy has been studying an economically viable solution for a process water cycle, that is at least partly closed, with regards to sodium sulphate.
2
Another concern is the effects of nitrogen emissions from treated wastewater.
Nitrogen, nickel and salt emissions were considered to be more harmful than initially estimated in the EIA for the largest production option (nitrogen load 47 t/a).
CNGR Finland Oy recycles the nitrogen-contained wastewater during its process and strives to further purify the water and lower nitrogen emissions.
Before moving to the largest production option (120,000 t/a), the aim is to find a feasible solution that also takes into account the environmental impacts of purification, in addition to the emission impacts of pCAM production.
3
In the conclusions of the EIA report, it was also stated that at the highest load level the combined effects of wastewater might do considerable harm to fish (especially local burbot) and fishing activities.
As the project progresses, a harm assessment for the fish economy and an action plan on preventing and compensating any possible damage done to the fishing industry must be composed. This has already been investigated in the present environmental permit phase, although the impact of maximum production has not been studied yet.
4
The Hamina-Kotka coastal zone is sensitive to eutrophication and there have been intermittent oxygen problems in the area in the past.
It has been recognised that the soluble ammonium nitrogen load caused by pCAM production has an impact on eutrophication in coastal waters. Additionally, warm and salty waters discharged from the process has an impact on the depletion of oxygen. If an oxygen deficit develops it can increase the internal load of phosphorus.
For this reason, CNGR Finland has studied the uncertainties relating to emission impacts by conducting measurements, modelling and searching for a better discharge point.
