“Gavigudet” Attended the Public Deliberation on the Scoping Report of “Elba Export” LLC

On September 29, the civil movement “Gavigudet” attended the Public Deliberation on the scoping report of a lime factory – “Elba Export” LLC, held in the City Halll of Rustavi Municipality.

Representatives of the company, City Hall and the National Environmental Agency attended the meeting.

Traditionally, the population was informed about the public deliberation by our team in advance (see the post).

Within the framework of the project, it is planned to set up a lime and combined fertilizer processing enterprise, which envisages the construction of two buildings with the auxiliary infrastructure.

The production process is planned for 300 days a year with a 24-hour working schedule, where 150 workers will be employed. Production of 87 600 combined fertilizers and 45,000 tons of lime is planned.

Different kinds of combined fertilizer will be produced, depending on the demand for th specific period of the year.

Our group discussed the scoping report in order to prepare comments and notes. We submitted our remarks to the National Environmental Agency after voicing them in public deliberation.

Our remarks regarded the following issues:

– The zero-alternative presented in the report is not properly justified from an environmental point of view, but only from the economic benefits. While the idea of discussing the alternatives is to find the one, the most acceptable in terms of protecting the environment and nearest settlements.

– In the technological alternatives chapter we read, that the lime processing is considered only with coal-anthracite; Whereas, it is known that the use of natural gas is much more appropriate from an environmental view. It is desirable, the EIA report to contain the information regarding the inevitability of the use of the less appropriate method.

– The EIA report should specify the transportation plan-schedule – in which part of the day/at which hours will the raw materials be imported and the products exported?

– The general overview chapter states, that production of 86, 400 tons of combined fertilizer is planned annually, while in the chapter 2.2.2. (production of combined fertilizer) we read, that production of 87, 600 tons of combined fertilizer is planned annually. Therefore, the exact amount of released production needs to be specified.

– We believe, that the document contains a lot of information, irrelevant to the report, that goes beyond the focus of the document. For example, the date of ensemble “Rustavi”, or the first library, or information about the exhibits in the Rustavi museum.

– The document does not contain the information about office and parking lot arrangement/construction works.

– It is interesting, if the company has the appropriate permission for removing and managing the fertile layer of the land.

– It is desirable, the EIA report to reflect the information about the management of excavated layers – specified conditions of its location area, whether the laboratory testing be conducted to determine the presence of hazardous substances in these layers? Is it planned to hand over the mentioned waste to the company with the appropriate managing permission?

– The EIA report should contain the detailed information about the hazardous waste temporary storage facility.

– It is desirable, the EIA report to describe the preventive measures to avoid the dust dispersion from the raw material reception open type bunker.

As company representatives explained, the details of the preventive measures like the height and speed of dropping raw materials from the vehicle into the bunker will be clarified during the EIA stage.

– The distances to the neighboring enterprises (“Geo Leader” LLC, “Automatics” LLC, “Polyvim” LLC, “Tema” LLC, “Qimbochko” LLC) are not indicated in the document. In the chapter of cumulative impact states, that there are no emission sources of other enterprises within the 500 meters radius from the given enterprise; however, there is no data confirming this statement.

– The document does not contain the waste management plan, in addition, there is no information about the contractor companies, responsible for waste management.

– Since the number of productions in Rustavi is increasing at a large scale, before determining the load norm of the city, we do not consider it appropriate to add a new enterprise; as the cumulative impact is significantly increasing in the city. On top of that, we believe, further studies should be carried out in order to figure out if it is safe to produce fertilizer from such a close distance to the city.

– Sulfuric acid spraying s considered in the production process, which, we believe, will cause the spreading of a strong unpleasant smell in the populated area.

As it is clear from the response of company representatives, the release of a very small dose (approx. 0,00092) of sulfuric acid will occur in a second; therefore, there is no danger of spreading the smell.

– Heating – cooling process of granulated fertilizer is described in the document; the hazardous substances come along with the vapor, emitted during this process. The preventive measures to avoid the spread of these substances should be specified.

Company representatives explained that high-efficiency aspiration systems will be installed in both enterprises (lime and combined fertilizer production). On top of that, there are unorganized sources of emissions, however, it is planned to combine them under a cyclone (dust-collector device). These details will further be clarified at the EIA stage.

The News was prepared with the financial support of “European Endowment for Democracy” in the framework of the project “Defending Our Right to Clean Air”.