Discussion of the EIA Report of “Rustavi Steel” LLC Held Within the Working Group

Discussion of the EIA Report of “Rustavi Steel” LLC Held Within the Working Group

On February 12, a working group meeting was organized by the civil movement “Gavigudet” to review, comment on, and prepare remarks for the Environmental Impact Assessment (EIA) report of the metallurgical enterprise “Rustavi Steel” LLC.

“Rustavi Steel” plans to change the operating conditions of the metallurgical enterprise. In this regard, our team, with an invited trainer reviewed the EIA document in a working meeting via the Zoom platform and prepared comments, which we offer below. We have also sent our comments to the ministry.

Before that, let us mention that the public discussion of the EIA report will be held on February 20 at 12:00 PM at Rustavi City Hall. Any citizen has the right to attend the discussion.

You can view the EIA report at this link.

See our comments regarding the document:

– Page 18 of the EIA report states that the enterprise operates on a three-shift schedule. On page 19, it’s mentioned that work is conducted on a four-shift schedule. This information needs correction.

– Electronic verification of the data revealed that the cadastral code 07.04.764 presented in the document is no longer valid. The new cadastral code for this plot is 02.07.04.816, so the information needs to be updated.

– In section 4.2 of the EIA, the product range and actual production capacities of the enterprise are listed. In this list, for several workshops, we encounter the phrase “with the prospect of production increase”. Does this phrase imply that the enterprise will go through relevant procedures for increasing enterprise capacity in the future? Or does this EIA report cover the prospectively changed capacity?

– In section 4.3.5 of the EIA report, which describes the foundry workshop, photos of the workshop are presented. The photos show that the workshop is quite disorganized. Is it acceptable for the workshop to function in such a condition in terms of safety? Moreover, it should be emphasized to the agency that according to the EIA, the furnaces in such a workshop do not have air purification systems, and the purified gas-dust mixture should be emitted into the atmosphere through an existing 15m high pipe. The scoping report prepared for the same activity indicated that the 15m high pipe for flue gas emissions was in an inoperative state. What is the situation today, and has this pipe been put into operation?

– The enterprise inspection materials revealed that there is no ventilation system in the pipe rolling workshop for the organized emission of harmful gases released in the workshop building through aeration skylights into the atmosphere. What is the current situation in the enterprise in this regard?

– In section 6.2.4 of the EIA report – Calculation of harmful substances dispersion in atmospheric air, it is mentioned that during the calculations, documentation for the dry cement production enterprise located within a 500-meter radius from the border of “Rustavi Steel” LLC could not be found. Does the agency have this information in its database? If not, what is the reason?

– In section 6.2.5 of the EIA report – Results and analysis of the harmful substances dispersion calculation, the maximum concentrations of pollutants at control points are given in MPC rates, where the nitrogen dioxide indicator is quite high. It is desirable for the ministry to independently verify the data obtained so close to the MPC, especially considering that there is a clinic and a penitentiary institution near the enterprise’s territory.

– In the noise calculation section of the EIA report, it is noted that according to the calculation results, there is an excess of the established noise propagation level for night hours (norm 40 dBA) at the border of the institution located on the southern side of the enterprise territory. However, in section 6.9 of the EIA report – Cumulative impact, it is noted that according to the results of measurements conducted directly at the enterprise’s borders, noise propagation levels do not exceed the normalized values. This information needs clarification.

– In the noise calculation section, where noise level exceedance is identified, it is noted that if we consider the natural and artificial barriers on the territory (trees, concrete fence, etc.), noise propagation levels will be reduced by at least 5-10 dBA. In such cases, the ministry should verify with appropriate instruments whether the noise level is actually reduced by the barriers present on the enterprise’s territory.

– Let us remind you that one of the conditions determined after the violation is that the company should ensure instrumental monitoring implementation no later than 2 months from the plan approval (EIA, p. 198). When does the company plan to acquire the appropriate equipment to conduct instrumental monitoring of radiation emissions on imported raw materials and exported products?

– The EIA documentation states that waste in the enterprise is collected in a segregated manner in appropriate containers, but in the same report, Table N6.13.1 indicates that the purchase, marking, and placement of waste collection containers on the enterprise territory is planned in the near future. It is necessary to clarify what the actual situation is at this stage regarding waste collection in the enterprise.

– In the aforementioned table, in response to the EIA note where a watering schedule is requested to be agreed within 1 month of receiving the administrative letter, the company has written – “Considered: The combustion of oil-contaminated engines is done in a thermal furnace”. This entry is inconsistent with the request and needs clarification on what stage the watering schedule agreement is at.

– One of the obligations of the enterprise is to submit an enterprise re-equipment plan-schedule to the agency by December 31, 2024, to which the company has responded that the enterprise has been updating and re-equipping technological equipment for years. A clear example of this is the installation of a new electric arc furnace in the steel smelting shop, the installation of a new 43 t/h capacity furnace in the section rolling shop, and others. Technological re-equipment is welcome, but the identification of the re-equipment plan-schedule with technological changes implemented without permission should cease.

– The EIA report states that in the third quarter of 2025, a continuous monitoring system will be installed on the emission pipe of the section rolling shop to ensure instrumental monitoring of nitrogen dioxide and carbon monoxide. Considering that the MPC indicator for nitrogen dioxide is quite high, it is desirable for the agency to obligate the company to install a continuous monitoring system on this pipe in a short time.

– The EIA report states that local exhaust ventilation will be installed in all closed workshops where grinding (abrasive) stones are used, with the implementation date indicated as January 1, 2016. The date needs correction.

– In the EIA report, monitoring of harmful substances in atmospheric air is determined once per quarter. Given that the MPC indicator for nitrogen dioxide is quite high, it is desirable to increase the frequency of control at least for this substance.

– According to the EIA report, there is no storm water collection system in the open areas for temporary storage of slag and scrap metal reception and processing, therefore the quality of water generated in these areas and its management issues need clarification.

– The EIA report states that the company plans to glaze the windows and openings of the existing enterprise building, which is desirable to be defined as a condition for the company with specified deadlines.

– In almost all documentation prepared by the company in recent years, we encounter a note that appropriate documentation is being prepared for the unauthorized slag dump, which should be submitted to the agency for obtaining a permit. During this period, the slag dump, including the slag and scrap processing shop, continues to operate without interruption. What difficulties did the company encounter in preparing the EIA document, and why couldn’t the relevant report be prepared over so many years?

– According to the EIA report, there are no instrumental methods for determining the explosive hazard of scrap metal, and therefore control is carried out by visual inspection. How is explosive hazard determined by visual inspection?

– The agency should specify deadlines for the company to submit relevant analyses conducted on the composition of dust captured in the gas-dust trapping device to clarify their hazardous/non-hazardous status and then determine specific management directions for them.

– According to the Environmental Assessment Code, the activity implementer is obliged to submit relevant permitting documentation to the agency at the earliest possible stage of activity planning for decision-making. It is known to both the agency and the public that the company has implemented these changes at least 2 years ago, even when the company was operating the planned 35 t/h furnace in test mode. The fact that the implementer is obliged to submit the permitting document to the agency at an early stage of activity planning is only a notation and has no legal weight, as LLC “Rustavi Steel” is unfortunately not the only facility that submits permitting documentation to the agency after implementing the change. Companies, especially large facilities like LLC “Rustavi Steel”, prefer to pay fines stipulated by law and operate in violation of the law because they know that the agency lacks different leverage to restrict large enterprises that are already established and functioning. If the agency does not have legal leverage to require the dismantling of the enterprise/equipment before obtaining a decision for such unauthorized productions, it needs to raise the issue of changing the law in this direction with the relevant authority, as the irresponsible actions of such companies jeopardize not only the environment but also public health.

– Given that the civil movement “Gavigudet” actively monitors administrative proceedings in the ministry regarding existing/planned enterprises in Rustavi, attends public discussions, and sends comments, it is desirable that the relevant decision or conclusion issued for a specific activity be sent to us as well at the email address – gavigudet@gmail.com, along with the company and municipality.