“HeidelbergCement Georgia” – History, Production, Violations

“HeidelbergCement Georgia” LLC owns two interconnected plants in Rustavi – a cement plant and a dry method cement plant. These plants are located in the same area – “Mshenebelta” street N70 and N70a. The nearest settlement from the cement plant is 440 meters away and from the dry method cement plant – 800 meters away.

Initially, the abovementioned enterprises held two environmental decisions, however company representatives applied to the Ministry in 2021 to request the unification of the environmental decision, thus currently the two documents are combined.

“Georgian Cement” LLC had been operating on the territory of the plant since 1991. In 2017, “Georgian Cement” was merged with the “HeidelbergCement Caucasus” and with the “HeidelbegrBeton Georgia”, and as a result of the merge the company was named “HeidelbergCement Caucasus”. In 2018, by the decision of the company owners, “HeidelbergCement Caucasus” and “HeidelbergCement Georgia” were merged, and as a result of reorganization “HeidelbergCement Georgia” LLC became a registered entity.

According to article N48, part 4, of the Environmental Assessment Code, a person who has been issued a relevant administrative-legal act in the field of EIA before January 1, 2018, is obliged to request an environmental decision based on the application by January 1, 2021. On the basis of the mentioned administrative-legal act, the Ministry will issue the environmental decision through a simple administrative procedure, without any other procedures, defined for issuing the environmental decision by this Code. Therefore, environmental decisions issued before merging in 2009 and 2013 years, were transferred to “HeidelbergCement Georgia” LLC through a simple administrative procedure.

The main pollutants of the atmospheric air are inorganic and cement dust, nitrogen oxides, sulfur dioxide, and carbon dioxide.

Waste, produced during the industrial process is the following:

1. Industrial waste (construction, production)

2. Household waste

Inspections showed, that a closed building is allocated for hazardous waste in the enterprise, while non-hazardous, metal, and wood waste is placed in the industrial area under the open sky.

Initially, cement and clinker were produced in both factories, however, in 2018 the first, and in 2021 the second and third rotating furnaces of clinker were dismantled in the cement plant; therefore, all clinker combusting furnaces have been shut down and clinker production no longer takes place in this plant. Only cement production takes place in the cement plant and clinker is imported from the dry method cement plant. Consequently, the production material from the cement plant is cement, and from the dry method cement plant – clinker. The screening report for dismantle process shows, that as a result of shutting down these furnaces, a significant source of emissions was eliminated and the state of the environment was improved.

As of September 2021, 6 units of horizontal ball mills of cement were operating at Rustavi Cement Plant; out of six, N1, N2, and N5 mills were operating through the closed cycle and N3, N4, and N6 mills – through the open cycle.

On September 1, the company representatives applied to the Ministry with a letter, stating: “because of the increased demand for the high-quality cement, the open cycle mode is less efficient and fails to meet the stringent quality requirements of the final product”. Hence, the company representatives wanted to switch the N3 mill from open to closed cycle.

This change caused to create one more source of emissions, therefore the new filter was installed in the middle of the plant, which is located 478 meters away from the nearest resident.

The specification of the sleeved filters, installed in the plant, is as follows:

1. Filtration capacity – 7500 m³/h.

2. Maximum dust concentration – 10 mg/m³

3. Height of the emission source – 17.0 m

4. Diameter of the emission source – 0.5 m

5. Diffused airflow temperature – 90⁰C

6. Diffused airflow velocity – 10.62 m/s

7. Working hours a day – 24 hours

8. Working hours per year – 7920 hours

9. Peak emission rate – 0.021 gr/s

10. Maximum annual emission rate – 0.594 tons/year

Two-step dust collector systems are installed in the cement mills:

I stage – with the efficiency of 30%;

II stage – sleeved filter, with the efficiency of 99,9%.

The operation of the dust collector equipment should be monitored on a monthly basis, by the enterprise; in case of an accident the operation process should be stopped immediately and dust collectors should be inspected/repaired thoroughly.

The enterprise has the obligation to watering the area during unfavorable meteorological conditions, in order to minimize pollution with inorganic dust.

During the last four years (2018-2021 years) 7 inspections have been carried out in the plant. The situation over the years has been as follows:

Inspection, carried out on May 16, 2018, showed, that the enterprise was not controlling the operation efficiency of the dust collectors. With regard to this fact, a report on administrative violations was drawn up on May 24, 2018. The case was transferred to the Rustavi City Court, which fined the company GEL 15, 000.

In 2017, the enterprise submitted correspondence from the Department of Environmental Supervision, according to which the enterprise had to fulfill the following obligations within a reasonable time:

1. From the moment of submission of administrative correspondence, the enterprise should start waste accounting, temporary safe placement, and transferring it to the company, holder of the relevant environmental impact permit, for further management.

2. Ensure to introduce the specific environmental monitoring plan to the Ministry, within 1 month after the submission of the correspondence; and conduct self-monitoring after the agreement.

3. To start the production of primary accounting documents upon the submission of the correspondence.

4. Carry out anti-incendiary obligations set in the EIA report, including:

– Arrange foam-forming fluid tanks within 3 months;

– Provide reservoirs with fire-fighting equipment;

– Develop special fire-fighting instructions in agreement with the relevant authority.

5. Set up a rain-water collector and deposit tank within 6 months after the submission of the correspondence. (In agreement with the Ministry, the deadline for this condition was postponed to February 1, 2019).

Inspection of the implementation of these conditions on September 21, 2018 showed, that the enterprise had fulfilled all the conditions, specified in the abovementioned correspondence (except the fifth one).

On October 2, 2018, the representatives of the Kvemo Kartli Regional Division of the Department of the Environmental Supervision additionally visited the enterprise, where they checked the waste disposal sites. They examined the waste accounting journal and waste destruction acts. No report of administrative violations was drawn up during the visit.

Inspection on April 3, 2019 made clear, that the enterprise had fulfilled the condition defined by the administrative correspondence – a rain-water collector is fully constructed and a deposit tank is arranged.

On December 20, 2019 the enterprise was the subject of one more inspection in order to check the operation of the transformer substation and the implementation of the plan schedule, established on July 17. And the inspection revealed the following:

1. The Ministry is not provided with the information on the relevant firefighting equipment at the transformer substation;

2. No information is provided on power transformers and switchers at the substation;

3. No oil-collecting tanks are set up around the transformers, and oily switchers are not spotted in the area at all.

4. There is no drainage collection system in the substation area and it is not connected to the unified drainage network of the cement plant.

On the basis of the December 20 inspection, the report was drawn up on December 24 and was transferred to the Rustavi City Court. On January 15, 2020, the court established, that company had violated the first part of Article 79³ of the Administrative Code and was charged with GEL 5,000.

At the end of 2020, the Department of Environmental Supervision checked one more time if the enterprise was implementing conditions, defined by the correspondence; and revealed, that drainage collection system was not still set up was not connected to the unified drainage network of the cement plant. Based on the inspection, an administrative violation report was drawn up on January 25, which was submitted to the Rustavi City Court on June 26. The court found “HeidelbergCement Georgia” as a violator and imposed a fine of GEL 15,000.

In 2021, only one inspection was carried out at the enterprise on 2 July, which revealed that the enterprise was violating the “obligation to continuously determine the actual amount of organized emissions of harmful substances from stationary sources of pollution into the ambient air by the instrumental method”. On the basis of this fact, a violation report was drawn up on July 12 and was sent to the City Court. The court found “HeidelbergCement Georgia” as a violator and imposed a fine of GEL 10, 000.

Although during the committee hearing on April 20, the deputy minister said, that the filtration system at “HeidelbergCement Georgia” was working properly and that the self-monitoring system had already been ordered and would be installed in the near future, two months after this announcement, the company officials have not submitted specific date of the installation of self-monitoring system to the Ministry. (We would like to remind you, that in response to our demonstration demands, the Ministry sent us a letter on June 20, 2022, which included information, provided by 11 enterprises operating in Rustavi, about the current situation and plans in regard to launching the dust collector and continuous instrumental self-monitoring systems. There was no information about “HeidelbergCement Georgia” among these 11 enterprises). If the system had already been ordered as of April 20, on the example of other companies, it would have taken about 1,5 – 2 months to transport and install the system, so it is unclear why the process was delayed or why the company has not sent a letter to the Ministry, indicating the exact date.

A well-maintained filters and self-monitoring system are critical for cement plants, as they are the main source of particulate matter pollution. Accordingly, we hope that the company will provide this information to the Ministry in a timely manner so that we will be able to share it with you.

The report was prepared with the support of Heinrich Boell Foundation Tbilisi Office, in the framework of the project – “Air Pollution in Rustavi”.