“Gavigudet” Attended the Public Deliberation of the EIA Report of “Mshenebeli 2004” LLC

“Gavigudet” Attended the Public Deliberation of the EIA Report of “Mshenebeli 2004” LLC

Today, on October 26, the civil movement “Gavigudet” attended the public deliberation of the EIA report about the change in the terms of operation of the “Mshenebeli 2004” LLC enterprise.

Traditionally, the meeting was held in the Rustavi City Hall and in addition to our team, the deliberation was attended by the representatives of the enterprise, consulting company, National Environmental Agency, Environmental Information and Education Center and City Council.

Our team provided information about the public deliberation to the public in advance (see post).

LLC “Mshenebeli 2004” is a cement enterprise and plans to increase its productivity. In particular, a new 8 t/h ball mill will be added to the existing 3 t/h mill in the enterprise.

As it is clear from the EIA, currently the 8 ton/hour capacity ball mill is in operation, while the 3 ton/hour capacity ball mill is in an emergency condition. The company has planned to carry out the repair works of the mentioned mill and after this the simultaneous operation of both mills will take place.

After implementing the changes, in case the 3 ton/hour mill is operated, the total annual amount of produced cement will be equal to 35,640 tons/year.

In addition, two silos were added to the existing five cement silos and the total number became 7. With capacities of 3 units – 80 tons each, 4 units – 50 tons each.

During the operation of the enterprise, hazardous substances such as inorganic and cement dust will be emitted.

According to the EIA, in order to continuously monitor the dust concentration, a self-monitoring device has been installed on the new 8 t/h mill. A similar device is planned to be installed on the dust discharge pipe of the 3 ton/hour ball mill after its repair work.

To prepare questions and comments on the EIA report, our team discussed the document together with the trainer invited to the working meeting. We sent the comments to the Ministry and sharing them with you too:

However, before that, let us tell you that we clarified the issue of the self-monitoring device and during the visit to the enterprise after the public deliberation, we saw that the self-monitoring device has been installed on the 8 t/h mill, the application was also sent to the Ministry, however, since the enterprise is not working at this stage, the device has not been turned on yet.

Also, the company representative agrees to make self-monitoring data public once the system is on and running.

Chapter 4.1 of the EIA report states that clinker unloading is carried out in a roofed warehouse, which has a wall on one side only. In addition, the warehouse for mortar and plaster is also semi-open. It is important to foresee the fact that raw material becomes quite dusty during emptying. Even though the MPC (Maximum permissible concentration) in the dispersion chapter presented in the EIA report is within the norm, the agency must pay attention to the issues of dust spreading from open warehouses, taking into account the proximity of the population;

– Chapter 4.1.4 of the document (fire prevention measures) states that a fire prevention stand will be arranged in the enterprise. Based on the fact that the enterprise has had a permit and has been operating for several years, the absence of such a stand represents a significant violation in terms of safety;

As the representatives of the company mentioned, the fire safety issues are no longer relevant at this stage, although they had a violation in this regard before that, for which they were fined.

– In chapter 4.2 of the EIA, it is mentioned that the cyclone and sleeve filter for the mills were purchased without technical passports, in this case, their data is taken into account in the calculation based on literary sources. How accurate are the results obtained in such occasion?

– According to the EIA report, it is clear that the new mill and its related infrastructure are already installed, which again emphasizes the fact that the company representatives do not assume the possibility of not getting a permit.

– The EIA report states that the noise level at the border of the nearest resident is 37,345 dB. Whereas only the noise level from a 3 t/h mill is almost 32 dBA. The data given in the EIA report is doubtful, and the agency should ensure the verification of this data with the nearest resident with appropriate instrumental measurements, especially when the same EIA report states that most of the facilities surrounding the enterprise do not have environmental documentation and therefore their noise levels are not determined;

– According to the EIA report, in order to reduce the spread of dust, the enterprise plans to clean the tires of cement trucks before leaving the territory of the enterprise (washing with a small flow of water) and to create a green belt on the side of the settlement. Considering the closeness of the population, we consider that the mentioned measures must be determined by the agency as a condition for the company;

– The EIA report does not include information about the conditions under which hazardous and non-hazardous waste is currently stored, which requires clarification;

– Table 10.1 provides mitigation measures for atmospheric air emissions, one of them is “maximum protection of stored raw materials from wind exposure”. What specific measures are defined for this activity?;

– According to the scoping conclusion, the company had to present the information reflecting the communication with the nearest resident (if any). As it is clear from the document, the company did not communicate with the nearest resident regarding its activities, as no details are presented on this topic. While inspecting the project area, it is preferable for the agency representative to conduct interviews with residents of the nearest house, if possible, regarding the operation of the enterprise;

– According to the requirement stipulated in the scoping report, the company should have presented detailed information in a separate sub-chapter of the document about the state of fulfillment of the conditions determined by the environmental decision issued on May 19, 2021 (Order No. 2-714) (the question/analysis of the fulfillment of each condition should have been discussed). This information is not presented in the EIA report;

– According to the requirement stipulated in the scoping decision, the EIA documentation should have included information on scheduled/unscheduled inspections conducted by the Department of Environmental Supervision, including the identified violations and the actions/reasonable deadlines (if any) determined for their elimination. The above-mentioned information is not presented in detail in the relevant chapter of the EIA document, in particular, it is not clear what specific violations were detected during the inspection and what measures were taken to eliminate them; In the event that the company has not yet fulfilled any conditions from the existing environmental decision, and there are significant violations, the agency should not issue a new environmental decision;

– If there are any comments, it is desirable to send the letters sent by us to the Ministry to the company as well, so that the error in the previous document is not repeated in the future administrative proceedings. If the documentation is lacking and the letter includes our remarks, it is recommended that this letter is sent to us to the following e-mail address: gavigudet@gmail.com, or we should be informed in any other way. In case of disregarding the notes, it is preferable to inform us of the reasons for this.

– Based on the fact that the civil movement “Gavigudet” actively monitors the ongoing administrative proceedings in the Ministry, about the existing/planned enterprises in Rustavi, attends public deliberations and sends comments, it is desirable that the relevant decision or conclusion issued on a specific activity, together with the company and the municipality, is sent us too.