On July 29, Rustavi City Hall hosted a public deliberation of the scoping report on changes to the operating conditions of Mega Cement LLC’s cement plant.
Our team attended the public deliberation along with members of the “Eco Center” Academy (13 members). The academy members asked numerous questions about the project, which we had prepared earlier during a working meeting with their involvement. An invited expert led the working meeting.
Regarding the planned activity, the company plans to increase the plant’s production capacity from 46,800 tons to 204,000 tons per year. Under increased capacity conditions, the plant will operate for 340 days a year instead of 260 days. Consequently, the existing mill in the plant will operate at a load of 25 t/h instead of 15 t/h. It’s worth noting that there are no plans to replace the mill in the plant, and the existing mill will be used, which the company has tested once and determined that it can meet the increased demands. The increase in the plant’s capacity is due to the increased demand for cement and construction materials in the country.
Impact on atmospheric air: It’s noteworthy that the existing four silos have a common air outlet pipe, which has a single collector pipe with an appropriate filter. The 3 new silos will individually have filters installed before being put into operation. The dust capture efficiency of existing and future filters on the silos is 99.9%. As the plant manager stated, filters and a self-monitoring system are currently installed on the mill, but they don’t have permission to turn it on without an environmental decision.
According to their statement, information on whether there will be an increase in atmospheric air emissions will be presented along with the Environmental Impact Assessment (EIA) report.
We also offer you the comments asked by the academy members regarding this project. As usual, we have sent these comments to the Ministry.
- The scoping report (Section 3.2), states that all the infrastructure provided for in the environmental decision issued by Order N2-853 of the Minister of Environmental Protection and Agriculture of Georgia on June 11, 2021, has been arranged on the plant’s territory. However, without the appropriate permit, 3 additional silos, each with a capacity of 65 tons, have been added to the plant’s territory, which, as you mentioned, are not yet in operation. How appropriate is this fact?
- In the report (Section 3.2, 5th paragraph), we read that there are no plans to change the mill in the plant, and the existing mill will be used which the company tested once and determined that when operating at full load, the mill can produce 25 t/h instead of 15 t/h. It would be interesting to know how suitable the old mill is and whether there is a danger that its operation with additional load will cause additional emissions.
- In the same report (Section 3.3, 3rd paragraph), it states that the raw materials brought to the site are placed on a platform arranged in a covered hangar-type building. The supply of raw materials for mixing takes place in the raw material mixing pit arranged in the same area. After mixing in the pit, the raw materials will be loaded into receiving bunkers in appropriate doses. Please specify what type of hangar it is, whether it’s only covered or enclosed on three sides.
- In the same section, the description of the hangar-type building intended for cement bagging equipment also requires clarification.
- The report (Section 6.0, 5th paragraph) states that the existing four silos have a common air outlet pipe, which has a single collector pipe with an appropriate filter. The 3 new silos will individually have filters installed before being put into operation. The dust capture efficiency of existing and future filters on the silos is 99.9%.
Please explain what kind of filters are installed on the silos in operation and whether you have installed self-monitoring systems. Also, please look at this link to see a photo of your plant, where in our opinion, 99.9% filtration is not recorded.
Do you also plan to install self-monitoring systems on the new silos?
- Regarding vehicles (Section 9.4), you state that the tires of vehicles will be cleaned of dust before leaving the industrial territory. Additionally, in dry weather, it is planned to water the access road section that leads directly to the plant every 2 hours to minimize dust. It would be interesting to know how well these procedures are currently being followed.
- The topic of greening is also interesting. Have you counted the number of trees that will be planted around the plant’s perimeter, and will this only be symbolic, as if the plant’s territory itself doesn’t allow for tree planting, this entry is only formal in nature?
- In Section 11 of the report, you mention that during the plant’s operation, the cement dust captured by filters in the dust collection systems is sold.
It would be interesting to clarify where this dust is sold.
Also in Section 11 of the report, you write that all issues related to the management of expected waste during the plant’s operational phase are given in the waste management plan of this document. We inform you that this issue is not found in the waste management plan.
Comments for the Ministry:
- It is desirable that if there are comments, the letters we send to the ministry should also be sent to the company so that the same errors in the previous document are not duplicated in future administrative proceedings on the same activity. If the documentation is flawed and our comments are considered in the letter, it is desirable that this letter be sent to us as well or that be informed. In case our comments are not considered, we would like to be informed of the reason.
- Given that the civic movement “Gavigudet” actively monitors the administrative proceedings in the ministry regarding existing/planned enterprises in Rustavi, attends public discussions, and sends comments, it is desirable that the relevant decision or conclusion issued on a specific activity be sent to us along with the company and the municipality.
The material was prepared within the project that is implemented with the financial support of USAID National Governance Program