Remarks on the EIA Report of “Ferro Alloys Production” LLC

A public deliberation on the EIA report of “Ferro Alloys Production” LLC should have been held on August 8, however the meeting was canceled, because the company had not provided proper complete documentation.

The company had planned to install two induction stoves in order to produce 7, 200 tons of alloy a year, during 3, 600 hours in total.

The information about the cancellation of the meeting was published on the same day as the meeting was scheduled (8 August). We think, it is more appropriate to warn all the interested parties in advance, via e-mail, as it is impossible to check the webpage of the National Environmental Agency on a daily basis.

On August 2 our group organized a working group meeting in order to discuss and prepare comments/notes on the EIA report. The meeting was led by invited trainer.

Despite the cancellation of the public deliberation, we submitted our comments to the Agency, which are the following:

– The EIA report does not include information, required by the scoping conclusion, about the bordering territories of the project area, nor the information about enterprises, operating nearby (within 500 meters radius) and their functional load.

– Alternatives, described in the EIA report is oriented to justify the economic benefits of the project and does not provide the proper environmental explanation. On top of that, it is almost impossible to read the first paragraph of the zero alternative. It is incomprehensible what is the connection between the zero alternative and the note – “to comply the requirements imposed on the qualitative and quantitative norms of the country, is related to purchasing technical devices, that are high-price and require significant financial and material-technical support for renewal under the exploitation process.”

– There is little environmental justification for selected alternatives and the focus is more on economic benefits, despite the fact, that it was required by the scoping conclusion, especially in terms of ambient air emissions. Besides, it is not clear from the report whether appropriate forecasting studies, regarding emissions into the ambient air, were carried out before the decision to increase performance was made, which would reveal if the changes would or would not result into exceeding established emission norms.

– Impact of the noise diffusion is not properly evaluated in the document. The provided information is not based on the specific researches or calculations, but represents only a general information, copied from the law.

– No sources of noise are indicated in accordance with the scoping conclusion in Annex I (gen-plan with emission sources).

– The company representative noted on the public deliberation, that scrap cutting would have taken place in a closed building, but Annex I of the EIA report, scrap processing area is indicated as one of the emission sources (g-4). Thus, hermetical isolation issue of the scrap processing area needs to be clarified.

– According to the document, simultaneous operation of the two furnaces will not take place and the annual amount of the product is the guarantee for this. It is interesting, how the Agency will control this? Will the revenue service have connection to the proper authority for controlling the amount of manufactured products?

– No information, required by the scoping conclusion about parameters and ensuring proper operation of cleaning devices is provided.

– Traffic rout agreement letter with the Rustavi municipality is not attached to the EIA report. Besides, it is unclear whether the vehicles be cleaned from the excessive dust before leaving production area, that is necessary to reduce the dust emission impact during the transportation.

– The EIA report evaluates significance of the waste management as “average”. This note is not proper, taking into consideration the fact, that the slag management is a major challenge for most enterprises.

– According to the document, laboratory studies on slag will be conducted directly before its realization. As the slag management is still challenge for Rustavi, our team asked from the Agency to put periodic submission of the results of laboratory studies on slag and proof of realization as the condition in the environmental decision.

– About the drainage system, on the one hand, the document says, that drainage waters from the enterprise would be discharged into the Rustavi drainage system, however on the other hand, the company representative mentioned, that even if the drainage channel would be arranged in the enterprise, it could not be connected to the city system, because there is no system at the industrial zone. Moreover, drainage channel is still indicated on the gen-plan of the enterprise, even the issue of arranging remains unclear. This fact amplifies the idea, that in the environmental documents of the enterprises everything is in order, so that permission-issuing authority does not have any questions, although the reality is different.

– The direction of the prevailed winds in the project area is not properly described in the report; only general characteristics of the region are provided. This issue is especially noteworthy because the food industry facilities (“Kazbegi” JSC; “Rustavimeat” LLC) are located within the 500 meters radius.

– The impact on the ambient air is evaluated as “average” in the document. The basis for such evaluation is vague, especially when the maximum allowable concentration rates are quite close to the limit.

– The EIA report should provide the information about the introduction of a continuous instrumental self-monitoring system in the enterprise; including indication of emission sources, monitoring subjected components and selected method and standard for the self-monitoring. Information, given in the document is general and does not depict specific decision.

– It is mentioned in the 14^th chapter of the report, that “these measures revealed the interest of the population mainly in term of possible employment which indicates the fact that at the current stage of the socio-economic situation, the solution of employment problems for the population is of a higher priority than ensuring environmental measures” – it is not clear, what this record is based on, whether the company carried out a relevant survey with the population of Rustavi or have they met the residents of the nearest settlement, based on which this kind of attitude towards the project was revealed.

– It is more appropriate to present a certain cost-benefit analysis in the part of the irreversible impact assessment, that will provide specific numbers to show the economic benefits for the city and how these benefits are able to balance the environmental damage.

– It is desirable from the Agency to send all our comments to the company as well, in order to properly be taken into consideration for future administrative proceedings.

– Due to the fact, that “Gavigudet” actively follows the ongoing administrative proceeding in the Ministry, about existing/planned activities of plants in Rustavi, attends public deliberations and sends notes, it is desirable that the relevant decision or conclusion issued on a specific activity, be sent to us as well, together with the company and the municipality.

The informational material was prepared with the financial support of “European Endowment for Democracy” in the framework of the project “Defending Our Right to Clean Air”