“Gavigudet” Attended the Public Deliberation about the Scoping Report of “Geo Enterprise” LLC
“Gavigudet” Attended the Public Deliberation about the Scoping Report of “Geo Enterprise” LLC
Today, on July 14th, deliberation about the scoping report on the project to change the operating conditions of the metallurgical enterprise (“GEO Enterprise” LLC) was held in Rustavi City Hall.
The meeting was attended by representatives of the civil movement “Gavigudet”, enterprise, consulting company, National Environmental Agency, Environmental Information and Education Center, Rustavi City Hall and City Council.
Our team provided information about the deliberation to our citizens in advance (see post).
“GEO Enterprise” LLC plans to produce ferrotitanium alloy from titanium scrap in the existing metallurgical enterprise.
Also, the production of ferrochrome, ferrotungsten, ferromolybdenum and ferroniobium in a furnace, using the aluminothermic method.
It is planned to place the production line of ferroalloys produced by aluminothermicin the warehouse building in the southwest of the existing enterprise, the construction of which is in progress by the company.
One smelting unit will be installed in the warehouse area, where melting will be carried out in a furnace.
With this method, the enterprise plans to obtain 4 different ferroalloys according to the market demand: ferrochrome, ferrotungsten, ferromolybdenum and ferroniobium, the production of which is planned on the same technological line, in accordance with the demand.
It is planned to import a part of the raw materials needed for the production process from Turkey, Armenia, Azerbaijan and Kazakhstan, while a part of it will be purchased on the local market.
As it became clear at the deliberation, there are 5 sources of emission in the enterprise, 1 of which is organized, 4 – unorganized.
In order to prepare the comments, our team discussed the scoping report within the working team.
We voiced the comments prepared during the meeting at the deliberation, sent them to the agency and shared them with you. We received answers to several comments during the public discussion:
– the scoping report does not mention any information about the introduction of a continuous self-monitoring system in the enterprise, which must be specified in the EIA report;
As the representatives of the enterprise mentioned, there is no self-monitoring system installed at the existing enterprise, nor is it planned to be installed, since a high-efficiency purification system is installed and the spills are very small, so much so that they are not subject to self-monitoring.
As for the planned project, it is planned to install a more powerful cleaning system than the existing one. However, there are several substances in the technological process that are subject to self-monitoring, and accurate calculations at the EIA stage will determine the need to install the device.
– According to the scoping report, the furnaces in the enterprise are working alternately. What are the specifics of this process?
The technology of operation of the furnaces is assembled in such a way that the possibility of simultaneous operation of both furnaces is excluded, and depending on the need, they are alternated.
– In the existing environmental decision, one of the demands for the company was the instrumental determination of the volumetric velocity of the air-dust mixture and sulfur dioxide on the emission pipe of the induction furnaces and the submission of the results to the agency once a year. Has the company ensured the fulfillment of the mentioned conditions?
The company’s representatives noted that in the permit conditions, this obligation is placed at a point (induction furnace pipe) from which there is no place for SO2 to be released at all. In December of the last year, samples were taken and this substance was not found in the pipe. In this regard, the company provided information to the Ministry.
SO2 may be released from a non-organized source during the casting of the melted substance, however, measurements have shown that the release rate is very small.
– According to the conditions of the environmental decision, the company was instructed to monitor the composition of the slag in the enterprise, twice a year, and submit the results to the agency once a year. Does the company comply with this condition?
According to the representatives of the company, there has been a laboratory study and the dangerousness of the slag has not been confirmed. The agency was informed about this. In addition, they have found a company that buys this slag.
– It is clear from the scoping documentation that the new technological line is planned to be placed in the warehouse building, the construction of which has already started. Is the mentioned warehouse constructing the same building that was considered in the environmental decision made by the company on August 8, 2022, for the storage of auxiliary materials? The EIA report should specify how safe it is to set up a new production line in the space where the auxiliary materials needed for production should be placed, and in general, the materials that are planned to be placed in the mentioned building along with the equipment should be mentioned. In case this warehouse is a completely new facility and is not the same as the building approved in the environmental decision, it is clear that the company has started the construction of the enterprise before the relevant environmental decision was made;
As the representatives of the company explained, they already have the permission for the construction of the mentioned building, independently of this project, from the City Hall, and if the EIA is approved for this project, it will be used for production purposes, otherwise, it will remain as a warehouse area.
– In the scoping report, Table 2.1 shows that there is a sedimentation facility located on the enterprise site, which is located near the scrap storage/processing area. The EIA report should contain information about the mass accumulated in the said landfill and its management;
– As it is clear from the documentation submitted to the agency, scrap cutting is carried out in the open space, therefore, in the EIA report, special attention should be paid to the characteristics of unorganized emission released into the atmospheric air as a result of the mentioned process; However, it should be noted that in the photo presented in the scoping report, the scrap processing area is quite messy;
– The EIA report must contain information on the approval of the “safety rules for the production of ferroalloys” on the guidance of the relevant articles stipulated by the Order of the Minister of Economic Development of Georgia No. 1-1/58 of January 16, 2008;
– The EIA report must present the passport data of the technological equipment required for the implementation of the planned activity, including detailed information about the filters to be installed on the new production line;
– There is no water softening area on the general plan presented in the scoping report, therefore the EIA report should specify where the mentioned area is planned to be located, and provide information about the technological process;
– The scoping report does not contain information about the temporary storage area of the waste generated in the enterprise (under what conditions it is stored, for how long, etc.);
– On page 91 of the scoping report, it is mentioned that the enterprise will create a labor safety and environmental protection department. Based on the fact that the metallurgical enterprise has already been operating for a year, the mentioned department should already be created;
– In the environmental decision taken in 2022, one of the conditions was the re-development of a specific plan for monitoring harmful substances in the atmospheric air and submitting it to the agency, where along with the obligation of self-monitoring on all sources of emissions, the issues of instrumental monitoring on the perimeter of the enterprise and on the border of a 500 m radius should be given. To what extent has the company ensured the fulfillment of the mentioned condition so far?
– It is significant, that for enterprises that own an environmental decision and plan to change the operating conditions, it is especially important to fulfill the already established requirements. The agency should take the mentioned factor into account in the process of making the relevant decision. In case the company has not yet fulfilled any conditions from the existing environmental decision, the agency shall not issue a new environmental decision;
-It would be better if the letters sent by us are sent to the company as well, so that in future documents of administrative proceedings, the errors in the previous document will not be repeated.
– Based on the fact that the civil movement “Gavigudet” actively monitors the ongoing administrative proceedings in the agency, about the existing/planned enterprises in Rustavi, attends deliberations and sends opinions, it is desirable, that the relevant decision or conclusion issued on a specific activity, together with the company and the municipality is sent to us too, via email – gavigudet@gmail.com.
The informational material is prepared by “Eco Centre” in the framework of USAID Civil Society Engagement Program, funded by United States Agency for International Development (USAID).
The contents of this material are the sole responsibility of the “Eco Centre” and do not necessarily reflect the views of USAID, the United States Government, or EWMI.