The EIA Report Of “Lev 2019” LLC Was Discussed Within the Framework of the Working Group
The EIA Report Of “Lev 2019” LLC Was Discussed Within the Framework of the Working Group
A meeting of the working group was held in order to review the EIA report of the cement enterprise “Lev 2019” and prepare comments and notes under the organization of the civil movement “Gavigudet”. We are glad that a citizen joined our team at the meeting.
“Lev 2019” LLC has planned to change the operating conditions of the enterprise. Specifically, in connection with the increase of the demand for cement in the country, the installation of a new 17 t/h capacity separation mill was planned on the territory of the enterprise, as a result of which 112,200 tons of cement will be obtained. That is, after changing the operating conditions, a total of 191,400 tons of cement of different brands will be produced in both mills in the enterprise.
Also, 4 silos will be added to the existing 6 silos at the enterprise after the change in operation, each of which will have a capacity of 120 tons. That is, after the change in operation conditions, there will be a total of 10 silos, the total capacity of which will be 1200 tons.
On the existing 6 silos, it was planned to install a cleaning system – sleeve filter on each one, but they were connected to each other with pipes and one cleaning system, sleeve filter was installed on them, which serves 6 silos at the same time, in which cement is received alternately.
Also, a single sleeve filter was installed on 4 new installation silos at the enterprise, which will serve all 4 silos, which will be connected to each other by a pipe.
The working meeting was held through the Zoom platform and was led by an invited trainer. At the meeting, we discussed the report in detail and prepared comments that we will announce at the public hearing. We will send our position in writing to the National Environmental Agency, and until then we will share our prepared comments with you:
– In the chapter 3 of the EIA report. The basis of the operation of the enterprise is unclear, we were not able to tell whether the workshop is working or not at the moment, because along with the activities envisaged by the change in the operating conditions, the current activities are also considered as in the planning process. For example, in this chapter we read: “The company plans to produce 79,200 tons of cement per year. The enterprise will work for 330 working days, with a 20-hour work schedule.” While the output of the new mill is mentioned in the same chapter as 112,200 tons of cement;
– In the EIA report, chapter 2.1 “Location of the project area”, there is no complete information about the purpose of the enterprises located next to the cement factory (e.g. “Geofero Metal” LLC, “OB Group” LLC; “XD 22” LLC; “Geometal Group” LLC, “Chakhvadze and Company” LLC);
– In the EIA report, in Chapter 2.6 “Fauna and Flora”, several paragraphs are devoted to the importance and beneficial properties of greenery, although it is unclear whether the company plans to implement any specific greening measures. Taking into account the proximity to the population, detailed information on the arrangement and maintenance of the green belt should be presented in the EIA report. In addition, it would be good if the company, in case of making an environmental decision, would have the obligation to arrange a green belt as a condition;
– In the EIA report, chapter 2.9 “Analysis of ecological situation” it says – “If we take into account the capacity of the enterprise and the number and capacities of existing enterprises in Rustavi, it can be said that increasing the capacity of the enterprise will practically not lead to the current background situation of Rustavi, it will change insignificantly only in the surroundings of the enterprise”. On what basis is this conclusion made?
– In the document, in the chapter describing noise dissemination, one of the sources of noise generation is named “already installed new mill”. Does this entry imply that the new mill is already in place? Or is there an error in the record?
– In the EIA report, in the chapter on noise pollution, it is mentioned that the spread of noise will not be significant, since the noise-generating devices are placed in a closed building. However, in the following chapters, it becomes clear that the buildings located on the premises of the enterprise are the hangar type, roofed on three sides and on top. Therefore, the part of noise dissemination and reduction needs to be reviewed;
– According to the information given in the EIA report, in the chapter of the report on the dispersion of harmful substances in the atmospheric air, the maximum allowable concentration of cement dust to the nearest inhabitant is equal to 0.91, which is quite close to the maximum permissible level. It would be good if, in such cases, the agency ensures the verification of this indicator with the tools at its disposal;
– In the EIA report, chapter 4.2, it is mentioned that the drainage waters generated in the territory of the enterprise will enter the city, in the Rustavi drainage system. This type of record is common in documents, but it is later revealed that these waters pass through the ground. The fact that Rustavi does not have a unified drainage system is also frequently mentioned during some deliberation meetings. In addition, the EIA report contains an appendix on the violations identified as a result of the inspection by the Department of Environmental Supervision, where it is noted that there is no drain, drainage and collecting system in the territory of the enterprise. Therefore, it is not clear how the organized collection of drainage water is done and then discharged into any drainage system;
– In the EIA report, in chapter 4.7, we read – “The rules for handling waste and ash subject to incineration will be explained to the staff”. What is meant by this record and what waste does the company plan to incinerate?
– In Chapter 5 of the EIA report, it is mentioned that in order to prevent the occurrence of local fires in the enterprise, it is planned to place fire extinguishers. Due to the fact that the enterprise is already functioning, the fire protection stand should already be arranged in the area. In addition, it should be taken into account that as a result of the inspection of the Road Traffic Authority, it was established that the company does not have any lightning conductors on the territory;
– The documentation mentions that the enterprise carries out measurements near the nearest settlement, and the results of the measurements conducted on June 30th of the current year are presented. The measurement results show that the noise level near the nearest settlement is 47-50 dBA, while the maximum permissible level is 60 dBA. How well will the mentioned conditions be preserved when the second mill is installed? In addition, in the EIA report and non-technical summary, in the section on noise pollution, it is stated that the noise level during the operation of the enterprise will not exceed 30 dBA, which is not true according to the above measurements;
– The EIA report contains a number of information that is not relevant to the document (for example historical references of Gardabani prison and Rustavi prison, detailed description of laws and regulations, etc.), which makes it difficult to understand the document and read the necessary details. In addition, it is difficult to find out in the document what the company is doing at this stage and what approaches it guides even in terms of waste management, because the same information is written in several chapters at different times;
– The EIA report provides information on the company’s compliance with the conditions of the existing environmental decision on their activities, and it is clear that “Lev 2019” LLC has not fulfilled several conditions. In addition, the violations recorded by the Road Traffic Authority are presented in the form of an appendix. According to the company, it plans to complete the unfulfilled conditions and correct the violations after making a new environmental decision, which is not correct. The company already has an environmental decision, the conditions of which are mandatory to be followed and guided by it. In addition, it should be noted, that the company independently has already implemented one significant change regarding the filters, namely, connecting 6 units of silos with each other with pipes and installing a common filter on them;
– It is significant that for enterprises that have an environmental decision and plan to change the operating conditions, it is especially important to fulfill the already established conditions and to be guided by the facts specified in the EIA report presented at the time. The agency should take the mentioned factor into account in the process of making the relevant decision. In the event that the company has not yet fulfilled any conditions from the existing environmental decision, there are significant violations, the agency should not issue a new environmental decision;
– It is desirable, that the letters sent by us are sent to the company as well, so that in the future documents of administrative proceedings, the errors in the previous document will not be repeated.
– Due to the fact that the civil movement “Gavigudet” actively monitors the ongoing administrative proceedings in the agency, about the existing/planned enterprises in Rustavi, attends deliberations 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 too to our email – gavigudet@gmail.com
The deliberation of the EIA report will be held on September 14 at 12:00 in Rustavi City Hall. Also, a public hearing will be held on September 14 at 2:00 p.m. in the public school of Tazakendi and, unlike the previous discussions, our team will attend the deliberation in village Tazakendi.
The meeting was held within the framework of USAID Civil Society Engagement Program, funded by United States Agency for International Development (USAID).
The contents of this material is the sole responsibility of “Eco Centre” and do not necessarily reflect the views of USAID, the United States Government, or EWMI.