Gavigudet Comments on the EIA Report on the Change of Operating Conditions of the Rustavi Steel

On October 8, 2021, in Rustavi City Hall public deliberation on the Environmental Impact Assessment report of Rustavi Steel LLC (one of the biggest polluters in Rustavi) was held. The meeting lasted about 2 hours. It was attended by the representatives from the Ministry of Environmental Protection and Agriculture, Rustavi City Hall, LTD Gama Consulting, Rustavi Steel LLC and the Gavigudet Movement.

During the meeting representatives from Rustavi metallurgic factory once again approved that all industrial activities are being carried out without any system of filtration. As we already know, according to the legislation, filtration systems were mandated from the 1^st of June, but the factory disobeys. This distinctively demonstrates enactment from the side of the government and creates a clear dissonance between legislation and reality. The situation visibly endangers the health of every human being in Rustavi.

Besides this, Gavigudet asked many critical questions about the new project of Rustavi metallurgical factory. Part of the remarks and question are already sent to the ministry.

Below you can see the questions/comments unchanged:

– According to the Environmental Impact Assessment, machine for producing cement is being used for lime. Was this change communicated with the Ministry and is it acceptable?

– In the EIA, the cadastral code of 02.07.04.079 cannot be identified. In reality, cadastral codes are 02.07.04.764 and 02.07.04.014 as marked in postscript. This postscript is not indicated in non-technical variant and it must be.

– In EIA, there is no mention of #16 and #17 penitentiary institutions, which are situated at the border of Rustavi Steel LLC.

– Document indicates that distance from the factory to the river Mtkvari is 1400-1600 meters. But there are some areas where the distance is about 1300 meters.

– About 50 meters of distance divides the cadastral border and residence building and this is not indicated in the document. But in the EIA, calculations are done around the matter, that closest citizen is 80 meters far.

– According to the EIA, there is an open area for saving scrap metal. Is the company planning to roof this place and process the scrap in a closed space?

– According to the photos presented in the EIA report, the place where the scrap metal is treated is quite disorganized. Is the safety conditions of employees in such an environment protected?

– According to the EIA report, in the long run, the enterprise will consider the arrangement of a hazardous waste disposal facility (landfill) and after obtaining the relevant permit, a dangerous fraction of dust caught in the dust collectors will be placed at the planned facility. Besides the dust, what type of hazardous waste does the company plan to place thereWillthe planned landfill serve other companies as well?

– Specifically when is the company going to install self-measuring devices in the enterprise?

– In the EIA, it is mentioned that in case of any unexpected inaccuracy/accident emergency discontinue of the processes will occur. But photos underline that factory building is damaged – there are openings on the walls, from where the harmful emissions are directly released in the air. What are the company’s plans around this?

– In the EIA report, the chapter on human health and safety issues states that the risks of deteriorating the health of people employed in the enterprise may be related to the presence of harmful emissions in the indoor air of working areas. With this record, the reader may get the impression that currently, there is no such problem in the working areas of the enterprise and no harmful emissions are released into the indoor/outdoor air that endangers the health of employees. Even photos presented in the EIA report (photo N4.3.2.1; photo N4.3.2.3.1) shows that this issue is huge today as well. So how does the company deal with this kind of exposure today?

– Looking at the air quality in Rustavi, we have a concern. In the EIA report, in the part of cumulative influence, why other factories in the 500 meters’ radius (LLC “Ruselois”, LLC “Rustavi Metallurgic Plant” and others) are not taken into the consideration? Also, LLC “Geosteel” which is included in the cumulative impact assessment, periodically operates with inaccuracies, which is demonstrated by the emission of pollutants from all possible openings, thus the reliability of the cumulative impact assessment given in the report is questionable. We would recommend the Ministry, to check the air quality around the enterprise with the appropriate tools by its own specialists/experts at the stage of administrative proceedings. This should happen without prior notice to the companies.

– We also had questions about the Waste Management Plan and the management of particular waste (code 10 02 10) generated during the process of production.

– In the chapter on waste management, there is information about washing the waste disposal containers. How will these containers be washed and where will the polluted water go?

– Chapter 3.7 of the non-technical summary is most likely copied from “Rustavi Azoti’s” documentations. Because, the main profile of Rustavi Steel LLC is metallurgic activity, not the production of fertilizers and etc.

– Also, after the commissioning of the new furnace, the factory takes responsibility to suspend the operation of two existing furnaces, until the dust collector/filtration system is installed on them;

– In case of a negative decision by the Ministry to put the new furnace into operation, what is the specific plan of the enterprise regarding the installation of dust collectors on the old furnaces?

– If the factory will be given permission to start the operation of the new furnace, when will air filters/dust collectors be installed.

The project Defending Our Right to Clean Air in Rustavi is implemented with the support of the European Endowment for Democracy.