“Gavigudet” Attended the Public Deliberation of the EIA Report of “Viva Cement” LLC

vivacement Today, on October 31, a public deliberation of the Environmental Impact Assessment (EIA) report for “Viva Cement” LLC was held at Rustavi City Hall.

The meeting was traditionally attended by representatives of the enterprise, consulting company, National Environmental Agency (The Department of Environmental Supervision), Environmental Information and Education Centre, and Rustavi City Hall.

Residents living near the enterprise also joined the meeting and noted that they have frequently observed emissions from this plant at night (they presented footage of this) and are bothered by noise, requesting assistance.

Before the public deliberation, our team reviewed the EIA with Academy members during a working meeting and prepared comments.

“Viva Cement” LLC produces 2 types of cement which are stored in separate silos.

According to the EIA report 2010, the plant had planned to install three silos for product (cement) storage, which were set up next to the ball mill. Currently, the plant has added 7 more silos.

The company plans to install 3 additional silos in the future to create reserves on site. Each will have a volume of 60 m³, and these silos will be placed next to the backup mill.

According to the EIA report 2010, each silos’ capacity is 65 tons, totaling 195 tons. These silos could store 8 days’ worth of production.

To maintain market competitiveness, the company planned changes.

As stated in the EIA report, the planned changes at the plant include: installation of additional silos; improvement of dust collection filters; installation of continuous emission monitoring systems; and placement of a backup mill.

As for dust collection filters, according to the EIA report, the plant has upgraded its dust collection equipment. Specifically, while the EIA report of 2010 year included 24 sleeve filters, an additional 24 filters were added during improvements, and currently, the mill is equipped with 48 sleeve filters. Furthermore, the mill is equipped with a continuous monitoring system.

The plant’s operations emit and release into the atmospheric air: welding aerosol (iron oxide), manganese and its compounds, nitrogen dioxide, soot, hydrogen sulfide, carbon monoxide, saturated hydrocarbons C12-C19, inorganic dust 70-20% SiO2, cement dust (inorganic dust SiO2<20%).

We voiced our prepared comments about the planned activities at the public deliberation and then sent them to the ministry.

Here are our comments:

– As stated in the report, self-monitoring equipment is installed at the plant. According to the latest data we requested in April, information from the device was not being provided to the ministry, and according to news agency information from several weeks ago, self-monitoring information from this plant is still not being provided to the ministry. What is the reason for this?

Plant representatives say that the self-monitoring device is installed and connected to the system, but currently, production is suspended, which is why no data is reflected in the database.

– The introduction mentions that “as noted in the plant’s screening and scoping reports, additional silos were installed for storing manufactured cement, additionally, dust collection filters were upgraded on the mill, and a continuous monitoring system was installed as required by law, and a backup mill similar to the existing mill was also installed. The backup mill will operate in case the main mill fails.”

However, in the alternatives chapter, it’s mentioned that the EIA report changes include: installation of additional silos; improvement of dust collection filters; installation of continuous emission monitoring systems; installation of backup mill.

So it’s unclear in the report whether these changes have already been implemented or are only planned. EIA procedures lose their purpose for already implemented changes.

– In the alternatives chapter, the placement of dust collectors is discussed in territorial terms, which goes beyond logical content. As the subtitle itself suggests – “Improvement of dust collection filters” – this should discuss from a technological perspective what alternatives were available and how the filtration system was improved, what parameters were used to select the existing filter, and what percentage of dust retention it provides compared to other alternatives.

(The same comment applies to the installation of the continuous monitoring system).

– The report also notes that (specific list is made at the beginning of the no-action alternative chapter) additional silos have already been installed, for which the plant is now going through the EIA procedure, and additionally, installing 3 more silos are planned. As it turns out, the permitting procedure is being conducted jointly for already installed and future planned 3 silos, and all ten silos are actually being considered for future reserve creation, while only the planned 3 silos are mentioned for future reserve purposes. It would be desirable for the information in the report to be presented more clearly and distinctly.

– In the non-technical summary, the alternatives chapter and consequently the same information is repeated twice, which only unnecessarily inflates the report’s volume and loses logical comprehension for the reader.

– In the activity description chapter, we find the statement: “The plant will operate only during daytime hours and all production operations will be performed only during daytime hours”; however, it has been repeatedly confirmed that this statement does not correspond to reality, residents have several times sent photo/video materials (Link 1; Link 2) of plant operations taken during nighttime hours.

– It would be desirable to have a detailed description of the plant’s hazardous waste temporary storage area.