Activities of „Serpens” LLC (Former “Rustavoil”)

On 26^th of January, 2023, the presentation of the refinery of petroleum products, “Serpens” LLC was held in Rustavi. As it turns out, “Serpens” LLC functions based on the rebranding of JSC “Rustavoil”.

To get detailed information about enterprise functioning, we have written a note to the ministry. As it turns out from their response, there is not issued Ecological Expertise Report / Environmental Impact Permit / Environmental Decision / Scoping Report / Screening Decision for the activities of “Serpens” company.

Accordingly, it is still not clear to us, on what legal basis “Serpens” LLC operates. Based on the information, that the mentioned enterprise is a former “Rustavoil”, it is interesting whether the environmental decision issued to JSC “Rustavoil” was automatically transferred to “Serpens” LLC; Since the letter does not contain any information on the transfer of activity through a purchase or other relevant agreement.

About JSC “Rustavoil”, it has been functioning since May 2020. According to the order of the Minister of Environmental Protection and Agriculture of Georgia No. 2-949 of November 26, 2018, an environmental decision was issued on the establishment and operation of an oil products processing enterprise with a reservoir bag; And, as stated in the letter sent by the Ministry on March 1, 2023, JSC “Rustavoil” operates in the territory defined by the decision issued by the mentioned order.

In the JSC “Rustavoil”, processing of fuel oil (a product of primary oil processing), obtaining road bitumen and base oils is carried out. The enterprise will use Ukrainian-made, world-proven equipment for the production of road bitumen. The capacity of the enterprise is defined as 180,000 tons per year.

During the operation of the enterprise, the following harmful substances will be released into the air: saturated hydrocarbons (C12-C19), sulfur dioxide, nitrogen dioxide, carbon monoxide, manganese and its compounds, iron oxide, hardly soluble fluorides, fine particles.

According to the report on the dispersion of harmful substances, as a result of the operation of the enterprise, the concentration of any of the above-mentioned harmful substances released into the ambient air does not exceed the permissible value established to the nearest populated place from it (350 m).

In addition, we would like to share with you the information provided by the Ministry about the inspections carried out at JSC “Rustavoil”:

On 13-20 July 2021, A scheduled inspection of the state of fulfillment of the conditions of the environmental decision issued for JSC “Rustavoil” was carried out.

It was determined as a result of the inspection, that the enterprise had not fulfilled the conditions, defined by the environmental decision, in particular:

JSC “Rustavoil” could not provide the development of a monitoring plan for atmospheric air quality and submission to the Ministry for consideration.
JSC “Rustavoil” could not provide development of the company’s waste management plan and could not make an agreement with the Ministry.
JSC “Rustavoil” could not present relevant documentation regarding the agreement with the sewer owner on the issue of discharge of wastewater into the sewer.
JSC “Rustavoil” could not present a detailed plan for responding to emergency situations for agreement in the Ministry.
JSC “Rustavoil” did not provide the Ministry with information about the start of the enterprise’s work and its commissioning.

During the inspection, it was also established that the waste collection and separation system has not been implemented in the oil products processing enterprise belonging to “Rustavoil”.

In connection with the mentioned violations, on August 30, 2021, an administrative offense protocol was drawn up against the company. In the explanatory part of the enterprise, we read that the list of violations given in the act has been partially fulfilled, although the documentation could not be submitted.

According to the administrative letter dated April 11, 2022, the enterprise was given a deadline for the elimination of the above-mentioned violations.

As it is clear from the letter of the Ministry dated March 1, 2023, JSC “Rustavoil” fulfilled the obligations defined by the administrative letter of the department dated April 11, 2022. In particular:

A monitoring plan for harmful substances emitted in the atmospheric air was developed by JSC “Rustavoil” within the deadline specified in the letter, and was submitted for consideration to the relevant authorized body.
The company’s waste management plan was developed by JSC “Rustavoil” in writing and presented to the Ministry for approval. The mentioned plan was agreed by the Ministry with letter No. 6306/01 of June 20, 2022;
JSC “Rustavoil” provided an agreement with the owner of the sewage discharge into the sewer within the deadline specified in the letter and submitted the corresponding document to the Ministry (May 4, 2022);
The response plan to emergency situations was developed by JSC “Rustavoil” in writing and submitted to the relevant authority.