Within the framework of the working group, the scoping report of LLC “Aglomerate” was discussed

On February 18, the civil movement “Gavigudet” organized another working meeting, the purpose of which was to discuss the scoping report of the project of setting up and operating the agglomeration plant of the LLC “Agglomerate” to prepare comments and remarks.

LLC “Agglomerate” plans to set up and operate a metal ore scorching and sintering plant in Rustavi, which will produce 66000 t/year of agglomerate for 7920 hours. For this purpose, 8 baking trays will be placed in the production area. To clean the air dust generated during the sintering process, the factory envisages the arrangement of a two-stage dust collection system with an efficiency of 98%. During the operation of the enterprise, the following will be emitted: inorganic dust, manganese dioxide, nitrogen dioxide, NO2, sulfur dioxide, SO2, carbon dioxide, CO, chromium (Cr+6), zinc oxide, lead and its compounds, nickel metal, cadmium sulfate, arsenic, copper oxide, selenium, Se, which are the main pollutants in the air.

The working meeting was held remotely and was chaired by a trainer invited by the civil movement “Gavigudet”. The working meeting was attended by activists of “Gavigudet”, volunteers, and participants of the training already conducted by the movement.

The trainer reviewed the scoping report in detail with the participants, and after the meeting, the civil movement “Gavigudet” sent reasoned remarks and comments to the Ministry of Environmental Protection and Agriculture of Georgia.

We do hereby share the unchanged comments and notes of the civil movement “Gavigudet” regarding the scoping report of LLC “Agglomerate”.

– According to the scoping report, the arrangement and operation of the metal ore scorching, and sintering plant is planned on the land plot with the cadastral code 02.05.03.420, which is the property of JSC “Saqmshenindustria”. The electronic verification of the data revealed that the area is the property of LLC “Agglomerate” (it is also mentioned in the chapter of the alternatives of the area, which is not true);

– According to the scoping document, the distance from the project zone to the surface water body (Mtkvari River) is 2380 meters. It should be noted that Samgori Lake, which is the property of LLC “Rustavi Water”, is located about 490m from the area;

– Chapter 3.1 (location of the project area) gives the cadastral code 02.05.03.351 (owner – JSC “Saqmshenindustria”), which does not match the cadastral code given in the introduction to scoping. Herewith, the GPS coordinates given in this chapter do not match the coordinates given in the introductory part, which is unclear;

– In the chapter of the location of the project area, it is mentioned that a building with an area of 4944 m² is located in the area, with the nearest resident being 200 meters away from the enterprise area, and river Mtkvari is 2800 meters away. The distances on the situational plan given in the scoping report are recorded from cadastral code 02.05.03.420 and coincide with the distances presented in the introductory chapter of scoping, therefore it is unclear in which area the discussion is referring to;

– According to the scoping report, from the project area “A.E. Textili” 02.05.03.354 is located about 170 meters away. An electronic verification revealed that the distance was approximately 135 meters. In addition, the scoping report states that the land plot with the cadastral code 02.05.03.356 also represents the property of “A.E. Textili” which is not true. The mentioned plot is the property of LLC “Rustavi Textili” and the distance between the planned enterprise and the mentioned area is about 150 meters (The mentioned distances are measured from the cadastral code – 02.05.03.420, because on the situational plan presented in the scoping report, the mentioned plot is used to orient the distances);

– According to the scoping documentation, 360 meters west from the production area, there is a metal construction plant -LLC “Konstruktsia”, but the electronic verification revealed that the distance is about 100 meters;

– According to the document, 420 meters north-west from the production area there is a metal construction production plant – LLC”Construction Service”. The electronic verification revealed that this distance is actually 76 meters;

– It should be noted that about 88 meters from the project area there are located the properties owned by JSC “Grdemli” and LLC “Rustavi Grdemli Mamia”(02.05.03.489) and about 300 meters – property of LLC “EGE”(02.05.03.475) and from about 290 meters – property of LLC “Nalan Chamashir” (02.05.03.069), which are not mentioned in the scoping document at all. Also, is should be noted that in order to properly assess the cumulative impact, the specifics of these properties must be given;

– The scoping report does not discuss and needs to clarify the issues of installation and exploitation of continuous self-monitoring system (so-called emission measurement devices) in the enterprise;

– Technological alternatives state that the total efficiency of the dust collector system will be equal to not less than 99%, while in the description of the technological process and alternatives to the dust collector system indicate that the total efficiency of the two-stage dust collector system is 98%;

– It is clear from the documentation that the selection of the dust collector system was done more from an economic point of view, which is unacceptable. The dust collector systems used in production must first be selected from an environmental point of view. Accordingly, the chapter on alternatives to the dust collector system should include the characteristics of each type of the dust collector system, as well as their quality, efficiency, durability and how much it reduces the potential damage to the environment by its proper functioning;

– The technological alternatives do not specifically discuss what technology/equipment can be used in similar enterprises, other than what the company already plans;

– One of the reasons for the rejection of the presenting option given in the alternatives of the area was the proximity of the population. It is interesting to know whether the relevant forecast calculations for air emissions were made before the decision to develop the new area was made, as a result of which it was revealed that there would be an excess of the established norm;

– The chapter on alternatives for the selection of the territory states that in the future it is planned to transfer the selected production area to LLC “Agglomerate”, but at the first stage a lease agreement will be signed. This issue needs to be corrected, as the area is already owned by LLC “Agglomerate”;

– Noise emission estimates are general because it does not specify which installations are noise emitting in the plant and what the noise level is at the point taken for calculation. It should also be noted that the enterprise plans to work 24 hours a day, therefore proper attention should be paid in this direction;

– According to the submitted documentation, the drainage water generated in the project area will flow into the drainage system of Rustavi, however, it is not clear from the scoping report whether there is a drainage system or a drainage channel directly on the project area, which provides transportation of the generated water;

– The waste management plan to be submitted in the EIA report should include the companies that will manage the specific waste during the operation of the plant;

– Due to the fact that the document does not properly assess the facilities in the vicinity of the planned plant and their purpose, the information presented in the chapter on air emissions and cumulative impact assessments is less reliable and may need to be corrected;

– The document does not discuss the traffic schedule and route. It is unknown at what intensity the raw materials needed for the enterprise will be transported through the settlements and at what hours. Given that the enterprise must work 24 hours a day, 330 days, an additional assessment is required for the period specified for the active transportation of raw materials and products;

– It is revealed from the scoping documentation that the enterprise will operate 330 days a year. Since it is often not possible to control how conscientiously companies comply with this regime (especially when production takes place 24 hours a day), the documentation should consider the remaining 35 and for what purpose this period will be used, namely whether it will stop the plant for repairs or for the holidays;

– Here we would like to mention that in many cases for Rustavi projects, in the documents (EIA and permissible emissionlimit reports) in relation to the emissions, everything is in the permissible limits, but the reality is different. Existing enterprises intensively violate the correct operating conditions, do not use proper filters and consequently the air in the city is constantly polluted. Given that the Ministry today trusts the data reflected in the reports submitted by the company, it would be good to send the appropriate competence groups to the field in order to verify the emissions of each enterprise in Rustavi and these groups shall measure and check the harmful substances emitted from the enterprise using their own tools and technical equipment. This will not only verify the information provided by the companies, but also to some extent it will be possible to create an appropriate database, which will reflect the relevant data on large and relatively small polluters in the city.

– If there are any remarks, it is advisable to send the letters sent by us to the Ministry to the company as well, so as not to duplicate the gap in the previous document for the same activity during the future administrative proceedings. In case the documentation is defective, and our notes are included in the letter, it is advisable to send this letter to us or let us know. In case of non-consideration of the remarks, it is advisable to let us know the reason for this.

The project Defending Our Right to Clean Air in Rustavi is implemented with the support of the European Endowment for Democracy.