“Gavigudet” Attended the Public Deliberation of the EIA report of “Aglomerate” LLC

Today, on December 27th, the civil movement “Gavigudet” attended the public deliberation of the EIA report of metallurgical enterprise – LLC “Aglomerate”, held in the City Hall Rustavi municipality.

The meeting was also attended by representatives of the company, National Environmental Agency, Rustavi City hall and City Council.

We would like to remind you, that on December 19th, the civil movement “Gavigudet” met with representatives of the City Council. Our team delivered detailed information about the air pollution problem facing our city. After the discussion, we agreed on several issues, including, we got a promise from the representatives of the City Council, that they would participate in public deliberations, since their involvement in such issues is of great importance to the city.

This was the first time, representatives of the City Council took part in the deliberation. It’s noteworthy, they were actively involved in the discussion and asked a number of questions.

As usual, our team provided information about the public deliberation of the EIA report to the citizens in advance (see the post).

“Aglomerate” LLC plans to set up and operate a metal-bearing ore roasting and sintering enterprise in Rustavi, which will annually produce 66,000 tons of agglomerate throughout 7920 hours.

8 “baking trays” with auxiliary equipment and infrastructure will be arranged on the territory of the enterprise. The enterprise consists of the agglomerate workshop, raw-material stocking section and the closed warehouse for product placement.

The agglomeration cycle involves the following facilities: 1. Agglomeration workshop. 2. Area for placing raw materials. 3. Warehouse building for the product.

Harmful substances released into the ambient air as a result of the operation process are: inorganic dust, manganese dioxide, nitrogen dioxide (N2), sulfur dioxide (SO2), carbon monoxide (CO), chromium (Cr=6), zinc oxide, lead and its compounds, metallic nickel, cadmium sulfate, arsenic, copper oxide, mercury, selenium (Se). Most harmful to the environment are inorganic dust, sulfur dioxide and CO.

Our team held a working group meeting in order to prepare notes and comments on the EIA report. We submitted our remarks to the National Environmental Agency after voicing them at public deliberation.

We present to you our comments regarding the report:

– The EIA report, about the surface waters near the enterprise mentions Ajiso river and Samgori lake alongside Mtkvari river, although the non-technical summary provides information only about the Mtkvari river. In our opinion, important details like surface waters in the vicinity of the enterprise must be fully mentioned in the non-technical summery as well, to provide citizens with proper information.

– According to the EIA document, the metal-construction enterprise – “Construction” LLC is located on the west side of the enterprise within a distance of 360 meters; although as a result of electronic verification, it was clarified that the distance is actually about 100 meters.

– According to EIA documents 420 meters from the enterprise on the north-west side the metal constructions factory – “Construction service” LLC is located. As a result of electronic verification, it was determined that the distance is actually about 76 meters.

– It should be mentioned, that there is JSC “Grdemli” located approximately 88 meters away from the project area (02.05.03.489), “EGE” LLC – about 300 meters away and “Nalach Chamashir” LLC – approximately 290 meters away. None of these companies are mentioned in the document. It should also be considered, that in order to correctly evaluate cumulative influence, the specificity of these manufacturers must be stated.

– In the EIA report, the estimated amount of toxic substances in atmospheric air is rated as “medium”. We believe this evaluation to be inaccurate. Since discharged sulfur dioxide (SO2) MPC (maximum permissible concentration) is 89, which is very close to the permitted amount, also carbon monoxide (CO) and inorganic dust emission rate is relatively high, correspondingly to 0.54 and 0.41.

– In the report, it is not referred to where the temporary placement of the production waste is planned to be laid out.

– The document is not properly organized, and there are some content errors. For example, a non-technical summary says: “The enterprise is equipped with fire-fighting tools. They have a sufficient supply of fire extinguishers and fire-fighting inventory. In case of fire in the enterprise, Batumi fire department is mobilized”. In this section there’s a technical mistake, instead of “local fire department” it says “Batumi fire department”.

– Types of impact removed from the review should be mentioned in the document. In chapter 4 of the non-technical summary it is said: “Due to the specifics of the planned activity, it was not considered necessary to mention some of the impact types. Types of impacts removed from consideration” – the sentence is unfinished and the content is unclear.

– The report mentions, that “The technology related to the pretreatment of dust containing manganese can be a source of possible environmental impact”. It is preferred for the types of impacts to be specified, also it would be interesting to see how the waste is planned to be managed.

– It is desirable, our remarks, sent to the Ministry, to be sent to the company as well, in order to avoid repeating the mistakes made in the previous document for the administrative proceedings in the future. If the documentation is flawed and our remarks, mentioned in the letter, are reviewed, it would be preferred for it to be sent to us electronically at: gavigudet@gmail.com, or we be notified of it. In case of denial of these remarks, it’s desired that we be informed of the reasons.

– Coming from the fact that the civil movement “Gavigudet” is actively observing current administrative procedures, about existing/planned enterprises in Rustavi, is attending public discussions and making remarks, it is desired, that the decision issued on an activity be sent to us alongside company and municipality.