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

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

Today, on December 19, a public deliberation of the scoping report on the project of changing the operating conditions of the cement enterprise of “Viva Cement” LLC was held in Rustavi City Hall.

In addition to our team, the deliberation was attended by the representatives of the enterprise, consulting company, National Environmental Agency (Department of Environmental Assessment), Environmental Information and Education Center, Rustavi City Hall and City Council.

Citizens who live near the enterprise, some within 50 meters, some within 200-300 meters, joined the public deliberation as well. These citizens expressed their concerns regarding vibration, noise and dust.

They said, that as a result of the vibration of the enterprise, the walls in the houses have cracked and it is unbearable to live in the conditions of this noise and vibration. Also, the enterprise operates 24 hours a day (except for the exception days), not 8 hours a day as it is described in the scoping report. They presented the video/photo material taken at 4:00, 5:00 in the morning and requested for this material to be attached to other documents when the agency makes a decision.

Their main demand is that the things that affect them the most (dust, vibration, noise) do not exceed the established norms.

It is also worth noting that the citizens addressed the local government several times with a letter, with signatures of about 100 people, requesting to solve the problem, and they have not yet seen an effective response. The first such letter was sent in 2020, but there have not been any changes whatsoever. Also, it was noted that the majority deputy mediated to the central authority on one of the letters. In this case, the representatives of the Department of Environmental Supervision came to the site, and despite the fact that they measured the noise at a remote location, the noise level still exceeded the permissible norm. The situation at the houses of these people is even worse.

Another issue that was highlighted and our attention was also drawn to it, is that the quality and accessibility of information regarding planned activities and public deliberation for the citizens should be increased and changed, especially in cases when the enterprise is as close to their settlement. The population expressed the desire and initiative to receive information about such important productions, impactful enterprises and planned activities in the form of a message on the phone.

Also, we have proposed an initiative to disseminate information about public deliberation using a door-to-door practice, among the population living near specific enterprises.

The technological scheme of the enterprise of “Viva Cement” LLC envisages the production of different brands of cement (mainly M300 and M400) by grinding clinker and additives. The enterprise has a two-chamber ball mill of Russian production, the maximum performance of which is 3 t/h.

Considering an 8-hour work mode, 300 working days per year and 3 t/h performance mill the maximum annual production of cement amounts to 7200 tons per year.

As it turns out from the scoping report, 7 additional silos and a backup mill have already been installed at the enterprise, which was not provided by the previous decision. However, it is now undergoing the permit procedure and a scoping report has been prepared regarding these changes.

This means that the company has already made changes before the decision was made, thereby missing the point of the EIA procedure.

We drew attention to this issue at a public hearing, and company representatives told us that the enterprise was fined for this; However, this is a systemic flaw and we have had this question with the Ministry about many enterprises/activities, and we request that the Ministry has an appropriate response to such facts to avoid such mistakes in the future.

We present the comments in a full form prepared by our team regarding the document and sent to the Ministry.

– Based on what documents was the environmental decision issued in 2020? Was it based on the permission according to which the production of “Rustavi V.G” LLC was transferred to “Viva Cement”? Did “Viva Cement” make an environmental decision on the production of “Rustavi V.G” LLC?

– The information given in the scoping document regarding the silos is confusing and it is difficult to get how many silos have actually been installed. Only 7 can be seen in the photos, however, it turns out that 7 additional silos have already been installed on the territory of the enterprise, which were not included in the old (2010) EIA. In this case, the EIA procedure is meaningless on the already installed silos and also on the additional mill; which is a violation of the environmental code.

– Technological alternatives are not provided.

– In the report (p.14) we read that the new mill has not been put into operation until now. It is interesting whether the Department of Environmental Supervision has carried out an inspection to verify this information. Also, installing the mill without permission is a violation of the environmental code.

– What leverage does the Ministry have to verify that both enterprises will not operate at the same time? This question is particularly relevant considering that, according to the information received from the locals, in the place of the installed new mill, another mill was operating without permission for years, which the company operated alongside the existing one.

– In the scoping report, in the same chapter 5, we read that the mill is equipped with a continuous self-monitoring system”, however, the letter sent by Department of Environmental Supervision on November 13 makes it clear that the monitoring information from the enterprise is not provided to the Ministry. Therefore, the enterprise works in violation of the law.

– The zero alternative of the report says: “Both the existing and the backup plant will be equipped with a high-efficiency dust filter, which is important in terms of reducing the negative impact on atmospheric air quality. An online monitoring system will be installed at the outlet of the mill dust filter.”

However, later in Chapter 5 (Changes made in the enterprise) it is mentioned that “24 more filters have been added to the existing 24 filters, and as of today, the mill is equipped with 48 units of sleeved filters, in addition, the mill located in the enterprise is equipped with a constant monitoring system.”

Also, in chapter 7 – the air quality mitigation measures during the operation stage – it is mentioned that “an online monitoring system will be installed”.

Accordingly, this information is provided in different ways in different chapters of the report and the real picture is unclear.

Given the situation, that according to the information of the Ministry (13.11.23) the monitoring system of the enterprise does not work, it is unknown which information is reliable.

– It is desirable to specify the irrigation intensity of the enterprise in the EIA.

– In the mitigation measure plan, we read that the impact of traffic operations and technological cycle in the aspect of noise will be low-negative which, considering that the enterprise is only 12 meters away from the residential house/yard, does not correspond to reality. In addition, even setting up the so-called buffer zone is not considered as a mitigation measure to contain the dust.

– Regarding the noise, it is noted that, based on the calculations of the nearest residential house, the noise level is 47 decibels, which slightly exceeds the permissible norm. We ask the minister to verify on the spot with appropriate tools whether the calculations given in the report correspond to reality. It is also important to consider mitigation measures to what extent they will actually reduce the noise level to comply with the established limit.

– Due to the proximity to residential buildings, it is important to check the vibration level.

– The scoping report specifies 2 annexes that do not accompany the document. Neither integrated in the report itself nor in the published attached files.

– (Question to the agency) Can the dust scattered by the enterprise be considered an indirect impact on the water channel?

– As it turned out during the visit to the territory, the company has stored raw materials in the outer territory of the enterprise, which is the property of the municipality. It is desirable to verify the legal basis for this and the agency to take this fact into account when making a decision.

– It is desirable to change/improve the practice of informing the population about public deliberations.

Involvement of the population living near the enterprises and voicing their comments, bringing their concern to the ministry or company representatives is of crucial importance; Especially in the case of such enterprises, whose activities / changes in operating conditions directly affect the living conditions of these people.

As it became clear at this particular public deliberation, if it were not for the post of the civil movement “Gavigudet”, people living within 50 meters of “Viva Cement” LLC would not have learned about the planned activities and public deliberation, while the main problem for them is the dust, vibration and noise from the enterprise, and several questions, comments and photo/video material were also presented regarding this at the public deliberation.

Therefore, to inform all the interested parties, it is necessary to increase access to such information, and these people should receive a telephone message, or letters should be distributed door-to-door.

– It is desirable, if there are any comments, that the letters sent by us be sent to the company as well, so that 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 to us to the indicated email: gavigudet@gmail.com

See photos of the enterprise: