Which Enterprises were Inspected during January-July 2024, and What Violations were Found in these Enterprises

Our team requested information from the Environmental Supervision Department about enterprises and violations detected in them, which were inspected by the department during January-July 2024.

In response to our letter, the Environmental Supervision Department sent us inspection acts and protocols regarding 13 enterprises. We will share with you the information provided in these materials for each enterprise:

‘Rustavi Azot’ JSC

An inspection was conducted from February 27-29, 2024, to check compliance with obligations defined in the administrative directive of July 22, 2021, and requirements established by environmental protection legislation.

The aforementioned administrative directive was issued during an unscheduled inspection, during which various violations were detected, and JSC ‘Rustavi Azot’ was given specific obligations. The company fulfilled some of these obligations and others partially, while several violations were also found during the current inspection. Detailed information about these obligations and their fulfillment status can be found in the inspection act.

Regarding the violations detected during the February 27-29 inspection, the Environmental Supervision Department issued an administrative offense protocol on April 16, 2024, which reveals that JSC ‘Rustavi Azot’ is not fulfilling the following points from the July 22, 2021 administrative directive:

– Sub-point 1.1 of the first point: JSC ‘Rustavi Azot’ failed to implement appropriate measures according to the plan-schedule agreed with the National Environmental Agency to prevent the discharge of cyanide ion-containing liquid industrial wastewater into the sewerage system and/or soil. The deadline for completing the works was set for February 15, 2024, but during inspection, it was found that the treatment system installation works were not completed. According to the company representative, these works will be completed in April.

– Sub-point 1.3: ‘Rustavi Azot’ failed to fully implement appropriate measures to eliminate pipeline/aggregate corrosion and casing damage according to the plan-schedule agreed with the Ministry.

– Sub-point 1.4: The inspection revealed that the restoration works of the intake-exhaust ventilation system were not conducted according to the Ministry-approved plan-schedule in the following workshops: Ammonia synthesis workshop and Cyan/salt production.

– ‘Rustavi Azot’ failed to ensure compliance with maximum allowable emission standards, and according to data received from the enterprise’s continuous monitoring device, instances of exceeding maximum allowable emission standards were recorded from January 1, 2024, to March 31, 2024. Specifically (see photos (click photo to enlarge):

– ‘Rustavi Azot’ is not implementing the requirements and obligations established by the Waste Management Code. Specifically:

– ‘Rustavi Azot’ has not prevented waste pollution of the enterprise territory and is not carrying out waste management in accordance with the company’s 2022-2024 waste management plan, which was approved by the Ministry’s letter dated February 15, 2023. Specifically (see photos):

Rustavi Azot does not fully maintain transportation forms for hazardous waste in the electronic waste management system that results from their operations.

Failure to fulfill the above obligations constitutes a violation under Article 79(8), Part 1, Article 79(8), Part 2, subsections “a”, “b”, “c” and Article 79(8), Note 1 of the Administrative Offenses Code of Georgia.

The inspection also revealed violations of the Waste Management Code, which constitute violations under Article 32, Part 4 and Article 41 of the Waste Management Code.

Specifically:

– More than 50 m³ of construction/inert waste and other waste materials are scattered around the enterprise territory.

– The company does not operate the inert waste landfill in accordance with the requirements and conditions stipulated by the technical regulation “On Landfill Setup, Operation, Closure and Subsequent Care”: During inspection, it was found that liquid magnesite waste was placed in the landfill, which violates the technical regulation conditions.

The inspection also revealed that the company does not operate in accordance with Condition 4 of the Environmental Decision issued by Order N2-224 of the Minister of Environment Protection dated February 19, 2021. Specifically:

– The temporary storage facility for more than 10 tons of hazardous waste near the packaging materials workshop is not arranged according to the EIA report: in one area, the facility’s fence integrity is compromised and not protected from unauthorized access; while the area of the second section does not correspond to the information provided in the EIA.

– The company made certain changes (installation of reservoirs) on the territory without a screening decision, which constitutes a violation under Article 79(7), Part 1 of the Administrative Offenses Code of Georgia.

Additionally, on August 15, 2024, an administrative offense report was drawn up against the enterprise because continuous monitoring data showed excessive levels of harmful substances on April 23, May 13, 14, 16, and 30, as well as June 6 and 8, 2024, during various times of the day, specifically (see photo):

“Viva Cement” LLC

– Based on a report received on the hotline (153) on April 29, 2024, inspectors examined the “Vivacement” cement plant that same day, and from 00:05 to 00:15 on April 30, express measurements were conducted near the plant, at the nearest resident’s location, to determine dust particles in the air and noise distribution frequency. As a result, it was determined that the noise level exceeded the permissible norm by 13.7 decibels, which violates Article 77, Part 4 of the Administrative Code. A violation report was drawn up on 07/26/24 regarding this. Furthermore, a violation report for exceeding noise levels was also drawn up on August 16, 2023.

– During an inspection conducted on January 16, 2024, it was discovered that 9 silos for storing cement were installed on the factory territory. Inspectors also found 2 cement grinding mills on the premises, one of which was involved in the technological process, while the other was being installed.

According to the environmental decision issued by the Minister’s order of December 31, 2020, the facility should have one cement grinding mill and 3 finished product storage silos. The company carried out installation works for the backup cement grinding mill without an environmental decision, which violates Article 79(7), Part 1 of the Administrative Code. Consequently, a violation report was drawn up on February 12, 2024.

– Based on a hotline (153) report, an inspection was conducted on March 29, 2024, during which it was discovered that the factory territory was littered with less than 2 kg of municipal waste and up to 5 units of secondary vehicle tires. This violates Article 31, Part 1 and Article 31, Part 4 of the Waste Management Code, and accordingly, a violation report was drawn up against the company on April 2, 2024.

“Mega Cement” LLC

According to the violation report dated March 1, 2024, LLC “Mega Cement” has not fulfilled the second condition of the environmental decision issued by the Minister’s Order N2-853 dated June 1, 2021, which means that they have not agreed with the National Environmental Agency on the “Project of Maximum Permissible Emission Standards for Harmful Substances in Atmospheric Air,” which violates Article 79(8), Part 1 of the Administrative Code.

According to the violation report dated August 12, 2024, an inspection conducted on August 9 revealed that in addition to the four cement silos with 500-ton capacity specified in the environmental decision, the facility has installed two additional silos with 65-ton capacity.

During an inspection conducted on October 8, 2021, two additional silos were found at the facility beyond the four 500-ton capacity cement silos specified in the environmental decision; also, a third silo was placed horizontally (uninstalled) on the territory.

On October 11, 2021, an administrative violation report was drawn up against “Mega Cement” for installing two additional silos without a screening decision.

Based on the inspection conducted on August 9, 2024, it was revealed that one of the additional silos documented in 2021 is installed but disconnected from the technological process, while the second silo is stored horizontally in the factory yard, indicating its dismantlement. Additionally, a third silo has been installed, which was stored horizontally in 2021.

Therefore, it is evident that “Mega Cement” carried out installation work for one additional silo without an environmental decision, which violates Article 79(7), Part 1 of the Administrative Code.

“Ruselois” LLC

According to the inspection report dated April 25, 2024, on that day, based on information spread on social media, an inspection of the facility was conducted, during which the production process was ongoing – one 9 MW electric arc furnace was operational, where the melting process was taking place. During the inspection, no visually noticeable emissions were observed from the facility’s emission pipe, however, visible emissions from the operating furnace were being released in an unorganized manner from the building.

This violates Article 79(8) Note Part 1, Article 79(8) Part 1, and Article 76(1) Part 1 of the Administrative Code, and consequently, a violation report was drawn up on June 14, 2024. The report also mentions that according to the service note dated May 20, 2024, from the head of the primary structural unit of the DES analytical service, LLC “Ruselloys” has not applied to DES for registration in the continuous self-monitoring electronic system for emissions. Therefore, the company has not fulfilled its obligation to determine the quantity and temperature of harmful substances from emission sources through continuous instrumental methods.

“Rustavoil” JSC

On June 25, 2024, an inspection was conducted at the facility based on the National Environmental Agency’s letter dated June 11. The findings of the inspection revealed that the facility was violating Article 79(7), Part 1 of the Administrative Code, specifically, the facility carried out activities without an environmental decision. Particularly, “Rustavoils” submitted a scoping report to the National Environmental Agency on May 16, 2024, which involves changes to the facility’s operating conditions – installation and operation of above-ground storage for oil and petroleum products, liquid gas with a capacity of more than 100 cubic meters, as well as waste recovery.

During the June 25 inspection, additional installation work was ongoing at the facility for two bitumen reservoirs (with capacities of 1000 and 2000 cubic meters) as specified in the operating conditions changes. However, the Agency has not issued an environmental decision for the installation of the aforementioned petroleum product storage facilities.

Based on this, a violation report was drawn up against the facility on July 8, 2024.

“Solo” LLC

According to the administrative violation report dated July 18, 2024, during the facility inspection on June 17 of the same year, unorganized emissions of harmful substances were detected from the cement silos located in the facility (violation of Article 79(8), Part 1 of the Administrative Code).

Consequently, it was revealed that the company fails to ensure compliance with the obligations established by the environmental decision issued by the Minister of Environmental Protection and Agriculture of Georgia’s Order N2-1470 dated October 18, 2021. Specifically:

– It failed to ensure compliance with the ministry-approved parameters for emission sources and air pollution control equipment as specified in the project for maximum permissible emission standards of harmful substances into the atmospheric air.

– The company does not ensure the continuous instrumental measurement of organized emissions of harmful substances.

According to a second violation report drawn up on July 18, 2024, the facility’s self-monitoring data was not provided to the ministry’s electronic repository from May 5, 2024, until July 3.

Additionally, the same report reveals that the facility violated Article 76(1), Part 1, which means that in case of interruption/termination of sending continuous instrumental self-monitoring results to the electronic system, the business entity is obligated to submit the self-monitoring results stored in its data repository for the interruption/termination period to the department without any modifications via the service after fixing the malfunction; furthermore, the business entity is required to notify the department in advance or immediately about any interruption in self-monitoring results, specifying the reason for the interruption (e.g., equipment shutdown, planned technical works…) via hotline or email, or through written application, which the company failed to do.

“Geosteel” LLC

According to the facility inspection report, based on a notification received on the DES hotline (153), DES inspectors examined LLC “GeoSteel’s” facility between 23:00 and 23:30 on March 5, 2024, during which operations were ongoing in the steel melting section – metal scrap melting process in the electric arc furnace, and in the rebar rolling shop – billet heating and rebar rolling process.

During this time interval, no unorganized emissions of harmful substances were detected at the site, and no specific odors were noticeable.

However, according to the field report drawn up on the same day, inspectors examined the facility and its surrounding area using the DES drone from 22:36 to 22:47, during which unorganized emissions of harmful substances were detected from the openings of the steel melting shop.

A violation report was drawn up on April 3, 2024, regarding this incident, which reveals that “GeoSteel” violated condition 4 of the environmental decision issued by the order of June 1, 2023, which constitutes a violation of Article 79(8), Part 1 of the Administrative Code.

Based on another hotline notification, the facility was inspected again on April 27, 2024, specifically, “GeoSteel’s” territory was examined by drone from 23:40 to 23:59, during which unorganized emissions of harmful substances were detected from the openings of the steel melting shop. Regarding this, a violation report was drawn up on June 3, revealing that by this fact, “GeoSteel” violated condition 4 of the environmental decision issued by the order of June 1, 2023, which constitutes a violation of Article 79(8), Part 1 of the Administrative Code.

“HeidelbergCement Georgia” LLC

According to the violation report drawn up on June 3, 2024, against LLC “HeidelbergCement Georgia,” data received in the central repository of the electronic system from continuous monitoring devices installed on emission sources shows instances of exceeding the maximum permissible emission standards for substances subject to continuous monitoring during the period from March 5 to March 31, 2024.

Additionally, according to the violation report drawn up on August 19, 2024, data received in the DES central repository from continuous monitoring devices installed on emission sources at the facility shows instances of exceeding the maximum permissible emission standards for substances subject to continuous monitoring at various times of the day on May 5 and 30, June 1-30, and July 1-31, 2024.

Consequently, it was determined that the facility has not complied with point 2 of the environmental decision issued by the Minister’s order of December 30, 2021.

“Ferro Alloys Production” LLC

In the violation report dated August 9, 2024, regarding the enterprise, it states that based on the National Environment Agency’s letter of August 1 (2024), an inspection of “Ferro Alloys Production” enterprise was conducted on August 8, 2024. The inspection revealed that the enterprise had carried out certain activities outlined in the scoping report for changes in metallurgical plant operation conditions, which was submitted to the National Environment Agency on July 9, 2024. Specifically: dismantling work of one ore-thermal furnace has been carried out, and in its place, a structure of 2.5 meters height and 65 square meters area has been built for a ferroalloy production furnace using the aluminothermic method, which is not roofed.

At the time of inspection, no environmental decision had been issued regarding the changes in the enterprise’s operating conditions. Consequently, it was determined that the company carried out activities subject to Environmental Impact Assessment without the environmental decision required by the “Environmental Assessment Code,” which violates Article 79(7), Part 1 of the Administrative Offenses Code.

In the explanatory section of the report, the enterprise representative’s statement reads that the company started construction in advance and only built walls made of blocks. Since the enterprise has not been operational for 2 years, is in difficult conditions, and pays employee salaries through loans, there was a desire to resume production as soon as possible.

“Elba Export” LLC

According to the violation report dated March 25, 2024, regarding the enterprise, based on data received in the central repository of the electronic system from continuous monitoring devices installed on emission sources, three instances of exceeding the maximum permissible dust emission levels were recorded – from emission source G-10 on January 31, 2024, and from emission source G-20 on March 13, 2024. This constitutes a violation of Article 79(8), Part 2, Subparagraph “a” of the Administrative Offenses Code.

“Ertoba 98” LLC

According to the violation report dated August 15, 2024, regarding the enterprise, based on data received in the central repository of the electronic system from continuous monitoring devices installed on emission sources, instances of exceeding the maximum permissible emission levels of harmful substances (dust) subject to continuous monitoring were recorded during various times of the day on May 25-26, June 20, as well as July 22, 27, and 29, 2024. This constitutes a violation of Article 79(8), Part 2, Subparagraphs “a” and “b” of the Administrative Offenses Code.

“Standard” LLC

On January 17, 2024, inspectors examined the territory of LLC “Standard” and determined that 2 reactor units and a finished product storage facility were installed on the enterprise’s territory. The enterprise plans to process waste oils, for which, according to the enterprise’s responsible person, relevant documentation has been submitted to the Ministry, and the installation of equipment will begin after approval.

“Basalt Fibers” LLC (Basalt Textile Fiber Enterprise)

Based on the National Environment Agency’s letter dated March 21, 2024, inspectors examined the enterprise on April 1 of the same year. According to the violation report drawn up on May 15, 2024, following the inspection, the company processes basalt stone at the facility and produces basalt fiber and fabrics, construction reinforcement and so-called “dowels,” as well as thermal insulation products, for which stationary sources of air pollution are present on the enterprise’s territory.

According to the National Environment Agency’s letter dated April 25, it was revealed that the company has not obtained approval for the “Technical Inventory Report of Stationary Sources of Atmospheric Air Pollution and their Emitted Harmful Substances” developed for the above-mentioned facilities; which constitutes a violation of Article 77, Part 1 of the Administrative Offenses Code.

The informational material is prepared with the financial support of the USAID National Governance Program