“Gavigudet” Attended the Public Deliberation of the EIA report of “Geo Enterprise” LLC

“Gavigudet” Attended the Public Deliberation of the EIA report of “Geo Enterprise” LLC

Today, on December 4, the civil movement “Gavigudet” attended the public deliberation of the EIA report on the project to change the operating conditions of “Geo Enterprise” LLC.

The discussion was held in the Rustavi City Hall and, in addition to our team, the discussion was attended by the representatives of the enterprise, consulting company, National Environmental Agency, Environmental Information and Education Center and Rustavi City Hall.

“Geo Enterprise” LLC plans to produce ferrotitanium alloy from titanium scrap in the existing metallurgical enterprise. Also, ferrochrome, ferrovanadium and ferrotitanium are produced in a blast furnace, using the aluminothermy method.

It is planned to place the production line of ferroalloys produced with aluminothermic method in the southwest of the existing enterprise, in the existing warehouse building, the construction of which was carried out by the company.

One smelting unit will be installed in the warehouse area, where the smelting will be done in a blast furnace.

With this method, the enterprise plans to obtain 3 different ferroalloys: ferrochrome, ferrovanadium and ferrotitanium, the production of which is planned on the same technological line (one of them), according to the demand.

After changing the operating conditions, an aluminum powder receiving device and another casting device will be added to the territory of the existing enterprise.

In order to prepare questions and comments on the EIA report, our team discussed the document yesterday, on December 3, together with an invited trainer. We have sent these comments to the Ministry and as always, we present these questions to you:

– As it is clear from the documentation submitted to the agency, the scrap cutting takes place in the open space, therefore, in the environmental decision-making process, special attention should be paid to the characteristics of the disorganized dispersion in the atmospheric air as a result of the mentioned process, as well as to the noise dissemiantion; In addition, it should be noted that in the photo presented in the EIA report, the scrap processing area is quite untidy;

– in the EIA report, chapter 5.4. (Description of the technological process) It is mentioned that the plasma-cutting method of scrap metal can be introduced in the enterprise, although at this stage only press scissors and air-cutting equipment will be arranged. Considering the fact that scrap cutting is carried out in the open air, as a result of which damage occurs to various receptors of the environment, it would be good to have more information about the scrap plasma-cutting method in the EIA report and consider it as one of the technological alternatives;

– Chapter 5.8 (waste) of the EIA report states that the laboratory study of the slag composition confirmed that the slag obtained from metallurgical processes does not contain hazardous substances, and its composition is a useful additive for cement production. Considering the above, the company does not consider slag as waste, it is sold to cement manufacturers. However, in chapter 6.7 of the same document, as well as in the corresponding table, it is indicated that the slag obtained as a result of metallurgical production will be transferred to “Sanitar” LLC, therefore the mentioned issue needs clarification;

As it was clarified at the public deliberation, this applies to filter dust. Therefore, we removed this comment from the version that was sent to the Ministry.

– Chapter 6.6.2 of the document mentions that the wastewater produced in the territory of the enterprise will be discharged into the Rustavi drainage water collector. At one of the public deliberations, it was mentioned that Rustavi does not have a drainage system, therefore the municipality should clarify the actual situation;

– In the atmospheric air quality chapter given in the document, the results of the atmospheric air quality monitoring conducted in Rustavi in 2021 are taken as indicator data. It would be desirable to obtain more recent data that could be used to demonstrate the average concentration of lead in atmospheric air;

– The zero (no action) alternative presented in the EIA report is not justified from an environmental point of view. The main justification is devoted to economic benefits, while the chapter on alternatives mentions a cost-benefit analysis, which should reflect specific figures of both losses and benefits, which are not given in the document;

– The EIA document mentions that the company plans to plant trees in the area of settlement. It is desirable to address the mentioned issue in the form of a condition in the decision;

– In the chapter on cumulative impact, it is mentioned that the environmental protection documentation of “Basalt Fiber” LLC, located near the enterprise, could not be found, therefore this specific object was not taken into account in the cumulative calculations. It is desirable to find out the type of activity of this company, at least the inventory report and to take into account the data in the calculations made by the company;

As the representative of the consulting company mentioned at the public deliberation, the Ministry also does not have the documentation of this enterprise, because they have not agreed to anything with the Ministry.

Therefore, at the discussion, we asked the National Environmental Agency to clarify whether this enterprise is functional or not without any agreements. Such a fact is inadmissible and accordingly, the cumulative impact is incorrectly calculated.

– In the EIA report, in the section of the analysis of the opinions and comments submitted by the public at the scoping stage, the assessment of the comments and questions raised at the public discussion is not presented;

– The report states that no violations were detected in the enterprise as a result of the inspection made by the Department of Environmental Supervision. It would be desirable if the EIA report contained the inspection document in the form of an appendix, so that the people who are interested in it would have the opportunity to see this information;

– It is desirable, if there are any comments, that the letters sent by us be sent to the company as well, so that in the future documents of administrative proceedings do not repeat the errors in the previous document.

– Since the civil movement “Gavigudet” actively monitors the ongoing administrative proceedings in the agency, about the existing/planned enterprises in Rustavi, attends public discussions 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 us to the indicated email: gavigudet@gmail.com