Activities of “MN Group 2021” LLC

Activities of “MN Group 2021” LLC

“MN Group 2021” LLC is a ferroalloy enterprise, which operates based on the purchase agreement of November 11, 2021, received from “Georgian Alloy Group” LLC.

On January 18, 2021, by the order of the Ministry of Environmental Protection Agriculture of Georgia, based on the environmental report N43 of 2016, an environmental decision was issued on the establishment and operation of the metallurgical enterprise of “Georgian Alloy Group” LLC.

The conclusion of the ecological examination was brought up on the EIA report, according to which, “Georgian Alloy Group” LLC planned to add two furnaces to the existing enterprise and increase the production up to 1.167 tons. According to Article 48, Part 4 of the “Environmental Assessment Code”, a person to whom a relevant administrative-legal act was issued in the field of EIA until January 1, 2018, was obligated, by January 1, 2021, on the basis of an application, to request the issuance of an environmental decision.

Accordingly, on December 25, 2020, “Georgian Alloy Group” LLC applied to the Ministry for environmental decision-making.

As we have already mentioned, ferroalloys is being produced by “MN Group-2021” LLC starting from November 2021.

Our team was interested in whether it is permissible to operate the enterprise only on the basis of the technical report of the inventory? As it is clear from the response of the Department of Environmental Supervision, “MN Group-2021” does not carry out the activities defined by the environmental decision issued by the order of January 18, 2021, since its design capacity is 20 tons per day/night, therefore, it produces less than a ton per hour. The activity of the enterprise would be subject to the ecological examination stipulated by the law of Georgia “On Environmental Impact Permit” in case of production of more than one ton per hour.

According to the Environmental Assessment Code, “starting before January 1, 2018, the activities provided for in Annexes I and II of this Code, which do not include activities subject to ecological expertise provided by the Law of Georgia on “Environmental Impact Permit”, do not require an environmental decision. Requirements established by environmental technical regulations apply to the mentioned activities. And metallurgical production is subject to ecological expertise – with the production of more than a ton of the products per hour.”

We would also like to provide you with information about the emission detected from “MN Group-2021” on October 30, 2022 and the response of the Department of Environmental Supervision. As it is clear from the inspection report, the representatives of the Department of Environmental Supervision inspected the enterprise, which was operating in consistently, although they did not observe any emission. In addition, according to the director of the enterprise, filters are installed in the factory, moreover in the process of cleaning the hood wings, the hood is turned off, during which the air becomes smoky.

Furthermore, as it turns out, an inspection was carried out at the enterprise on July 15, 2022, when it was revealed that the enterprise did not have a waste management plan agreed with the Ministry of Environment Protection and Agriculture and was operating without the mentioned plan.

Let us remind you, that our team visited “MN Group-2021” LLC on February 17, 2022; See the link for more detailed information.