denizli ccpp project

DENIZLI CCPP PROJECT

RWE & Turcas Güney Elektrik Üretim A.Ş.

Environmental and Social Impact Assessment (ESIA)

Non-Technical Summary

Final

March 2010

Environmental and Social Impact Assessment Non-Technical Summary Denizli CCPP Project

RWE & TURCAS NTS Page 1 of 32 MARCH 2010

This document is the Non-technical Summary (NTS) of the Environmental and Social Impact Assessment Report (ESIA) for the planned new CCPP (“the Project”) of RWE & Turcas Güney Elektrik A. Ş. (RWE & Turcas).

This report will be translated into Turkish language. In case of doubt the English version shall prevail.

1 Introduction

Project Background

The company RWE & Turcas Güney Elektrik Üretim A. Ş. (“RWE & Turcas”) intends to build and operate an 800 MWel combined cycle gas turbine power plant (CCPP) near Denizli, Turkey1. The plant will be located near Kaklik Municipality, 30 km east of Denizli and approximately 280 km southeast of Izmir.

RWE AG is the leading privately owned energy company in Europe. TURCAS Petrol A.Ş. is the successor of Türk Petrol ve Madeni Yağlar A.Ş., which was founded in 1931 as the first private oil Distribution Company in Turkey and transformed into a joint stock status. Established as a petroleum products retailer, Turcas is transforming itself into an energy holding company.

RWE, in 2007 decided to enter the fast growing Turkish energy market. Therefore a shareholder agreement with the Turcas has been signed in order to realize two large scale power plants in 2009.

"RWE & Turcas Güney Elektrik Üretim A. Ş." (RWE & Turcas) was registered on 09.06.2009. The company is responsible for the construction and operation of the planned natural gas fired CCPP.

The project - a state-of-the-art combined cycle gas turbine power plant - will add electrical capacity of approximately 800 MW to the national grid.

RWE & Turcas selected ‘METKA’ as a qualified international Engineering, Procurement and Construction (EPC) contractor through a process of international competitive bidding and the EPC Contract was signed on 27 October 2010.

1 The project was originally developed by E.ON together with Turcas. In March 2009, E.ON decided to sell its shares in the project to RWE.

The Project will be planned, constructed and operated to Turkish regulations as well as international standards and according to the RWE Group Policy Environmental Management.

Environmental and social findings of the ESIA with relevance for the plant design specifications and project implementation will be taken into consideration by RWE & Turcas to ensure that measures identified as necessary in this ESIA will be implemented.

The commencement of construction is planned for second quarter of 2010. Start of electricity production with the new power plant is targeted for the end of 2012.

The total capital investment of the CCPP project amounts to roughly 600 Mio EUR. Transmission lines to connect to the grid are not part of the Project. The Project is presently at the stage of construction permit.

Need for the Project

Within past years, Turkey has seen substantial economic growth and in parallel with this steep increase in electricity demand. The long term growth rate of electricity demand in Turkey is with approximately 10% per year high. The forecast for the development of the economy show moderate to high economy growth rates until 2020. Corresponding increasing energy demands are expected.

Based on forecast by TEIAS (2008) Turkey is expected to face supply shortages between 2013 and 2015 as a result of the continuing growth in electricity demand and the slow growth in generating capacity.

The Denizli region is one of the areas with the highest consumption on electricity although it is far away from other electricity generating facilities. In addition, the forecasted growth rate of energy demand in the Denizli region is higher than the Turkish average. In western Turkey, the consumption exceeds generation which is the reason why the Ministry of Energy and Natural Resources is requesting an additional capacity for this region.

The political and legal framework conditions allow investments of private companies in the energy sector. Thus, private investments appear as a good opportunity to build up the needed energy production capacity within short term whereas



state investments are more difficult to realize because of political and financial reasons.

Since the overall time needed for implementation of a gas fired power plant is shorter than for e.g. a coal fired power plant, a combined cycle gas fired power plant is the best option to provide new base load generation capacity on short term.

Therefore the construction of an 800 MWel base load gas fired power plant in Denizli region would be a benefit to the region and the whole country.

Environmental Impact Assessment for the Project

The Project requires approval from the Ministry of Environment and Forest (MOEF) which is the competent authority in Turkey for the environmental appraisal of projects. For the Project an environmental impact assessment (EIA) is mandatory according to Turkish environmental regulations. The EIA was carried out by the company Tugal Environmental Technologies from Istanbul together with Ekotest Environmental Consultancy Testing Co. Ltd (TCT), from Ankara. The EIA was already submitted to the Ministry of Environment and Forest (MOEF) and RWE & Turcas received the environmental approval of the Project in November 2008.

In addition, to fulfil environmental and social requirements of potential international project lenders, the Developer, in May 2008 has contracted a consultant team led by ERM (Frankfurt office/ Germany) locally supported by TCT to prepare additional studies and compile supplementary information in a wider scoped Environmental and Social Impact Assessment (ESIA) report. The ESIA is designed to conform to international standards and practice such as IFC Performance Standards.

The ESIA Report contains in detail the findings of the assessment of the likely environmental and social impacts associated with the construction and operation of the Project. It describes measures to avoid or mitigate identified impacts in an Environmental and Social Management Plan (ESMP), which outlines that the Project will be in an environmentally and socially acceptable manner and compliant with both national and international standards.

Furthermore, the study forms the basis for specifying the environmental and social provisions in the contract for engineering, procurement of materials, equipment and construction with the EPC contractor, as well as operation and maintenance.

Key findings of the ESIA and ESMP measures are presented in this summary report further below (cf. Section 5).

As part of the ESIA activities, consultations with stakeholders and the public were undertaken and project information was disclosed within the framework of a public consultation and disclosure plan (PCDP) set up for the Project. The Draft Final ESIA Report is subject to public disclosure and RWE & Turcas will organise a public meeting for the interested public in the communities in the vicinity of the plant in the first quarter of 2010.

2 Description of the Project

Project Site Locations

After an intensive site screening and consultations with Turkish Authorities and technical studies, the Denizli-Kaklık site could be figured out as a suitable place for the project.

The proposed site of the Denizli CCPP is located in the Aegean region, 280 km southeast of Izmir, approximately 35 km east of the city of Denizli. The site is situated 1.8 km north of Kaklik Municipality in Honaz District, Denizli Province.

The site has and area of approximately 26.7 ha and is divided in 19 land parcels with mainly private land owners. All private parcels have already been purchased amicably. The elevation is between 545 and 595 m above sea level (asl). The area required for the project will be roughly 300 m x 300 m.

An overview of the location of the Project sites is provided in Figure ES-1.



Figure ES-1: CCPP Site Location Map

Salient Features

The planned Denizli Power Plant is an 800 MWel class Combined Cycle (CCPP) natural gas-fired plant with high efficiency of about 57%.

The CCPP will be a state-of-the-art power plant for economical production of electricity for at least 25 years operation period (200,000 operational hours). The power plant will burn natural gas as sole fuel.

The central unit of the Facility will be configured with multi-shaft heavy duty industrial gas turbines equipped with dry low-NOx combustion systems. The exhaust gas of each gas turbine is fed into an associated heat recovery steam generator (HRSG). The steam from both HRSGs serves one common steam turbine. Further the plant comprises all necessary auxiliary and ancillary systems and equipment.



Measures to protect the environment are integral part of the facility design. The power plant includes effluent treatment, fire fighting systems, waste management facilities, and is equipped with all accessories, cables, piping, protection and safety equipment, auxiliary and ancillary equipment required for safe and continuous operation. All air and noise emission control measures, wastewater effluent treatment, waste handling, operational and construction activities is planned, performed and handled in such a way that the applicable legal requirements and international standards will be complied with.

Natural disaster risks relevant to the site, like storm and earthquake, along with adequate provisions for hazards is considered in the design and applicable construction norms are applied.

The main installations are as follows:

Two gas turbines (GT) and associated generators with a gross electrical power output of 268 MWel each;

Two heat recovery steam generators (HRSG) to generate steam from the waste heat of the GTs to be utilized in the steam turbine (ST);

One steam turbine (ST) and generator with a gross electrical power output of 264 MWel;

Each of the HRSGs has its own stack of 60 metres height above ground level for discharge of waste combustion gas;

Cooling of the closed loop steam/water circuit by means of Air Cooled Condensers (ACC);

Appropriate facilities will serve for raw water conditioning and wastewater treatment;

A high voltage switchyard with power transformers and power distribution systems;

A small laboratory for testing of lubricants used for operation of the plant as well as for water quality testing;

Storage tanks for de-mineralised water;

Natural gas receiving metering station;

Buildings (particularly for the Central Control Room), roads, parking and fencing.

A storage room for oils, lubricants, and other chemical materials like paints and solvents will be located in the maintenance workshop. Chemicals used for the raw water and wastewater treatment will be stored at the respective locations.

The turbine/generator units will each have their own building and are island structures to avoid propagation of vibration and noise.

Monitoring and control of the entire electrical system will be executed in the Central Control Room (CCR). The control system is designed for full control and supervision of the plant from the CCR.

Start-up of the plant will be enabled by electricity provided via the national 380 kV grid. Auxiliary steam for start-up and shut-down of the steam generator will be provided from an auxiliary natural gas fired boiler (50 MWth).

Access to the site will be via a 1 km long local road which connects to the national road D595 to Kaklik-Usak. The local road will be asphalted to allow heavy goods transport. The site will be fenced and access will be given through a main gate with gate house.

Energy Transmission

The electricity generated by the plant will be fed into step-up transformers where the generation voltage is transformed to the 380 kilovolt (kV) level of the national grid. Two parallel overhead transmission lines will connect the site with the transmission line between Denizli substation and Afyon substation. In addition, it is presently planned that a third transmission line will connect the site directly with the Denizli substation. Transmission lines required to connect to the national grids are not part of the Project.



Figure ES-2: General flow diagram of a CCPP

Air

Natural gas

MWel

MWe l

Steam turbine

Exhaust stack

HRSG

Gasturbine

Generator

Pump

Generator

MWel

Air

Natural gas

Exhaust stack

HRSG

Generator

Air Cooled Condenser

Gasturbine

Steam

Water (Closed

Hot Turbine Exhaust

Cooled Exhaust

Air Intake

Consumptions and Releases

The key consumptions and releases to the environment related to the power plant's operations will comprise the following:

Fuel consumption;

Air emissions with the waste combustion gas;

Noise emissions from the turbines, the ACC, and other equipment;

Raw-water demand particularly for the water/steam cycle,

Water discharge from wastewater streams (e.g. steam cycle blowdown, raw-water pre-treatment residues, wastewater neutralisation, oil/water separators, sanitary purposes);

Hazardous materials, used for operation and maintenance;

Solid wastes, including sludge from wastewater treatment.

Table NTS-1 lists the consumption and releases of the power plant.

Fuel

The power plant will be fuelled with natural gas supplied by BOTAS, which will be cleaned (i.e. dust filtered) prior to its usage. The site will be connected to a gas pipeline which passes the site in the south. There is also a branch to this pipeline serving the cement production plant (Denizli Çimento) about 3.5 km west of the new power plant.

The consumption of natural gas will be 2 x 14 kg/s (145,000 m³/h) for base load operation of both turbines. The total thermal energy input of the CCPP will be approx. 1,400 MWth.

Air Emissions

The main sources of emissions into the air are the two stacks of the HRSGs. An additional source of air emissions is the auxiliary boiler which is operated only in case of start-up.

For normal operation the maximum concentrations in the flue gas will be 50 mg/Nm³ for nitrogen oxides (NOx expressed as NO2) due to the installation of dry low-NOx burners. For carbon



monoxide (CO) the maximum concentration will be 50 mg/Nm³.

Sulphur content in the fuel is low; the concentration of emitted SO2 will be below 5 mg/Nm³. Emissions of particulate matter (PM) will also be low since the combustion process does not generate PM. Only particles passing through the intake filters will appear in the flue gas.

The maximum emission rates of NOx (as NO2) as well as of CO are 95 kg/h for each gas turbine at base load. Carbon dioxide (CO2) content in the flue gas is approximately 138 t/h per turbine.

Noise Emissions

The relevant sources of noise at the power plant are the gas turbines, the HRSGs, the steam turbine, the air cooled condenser, compressors, and the steam pressure pipeline. The equipment will be fitted with noise attenuation packages so that the applicable limit values will be kept.

The two HRSGs are equipped with one stack each. Silencers are installed to abate noise emissions generated by the waste gas streaming out the stacks.

Water Demand

The CCPP will employ closed loop air cooled condenser (ACC) cooling technology. This concept constitutes system intrinsic water resources saving technology. Typical adverse impacts on water resources associated with wet cooling are avoided, such as large cooling water volumes, high evaporation losses, high amount of chemicals, large cooling towers with vapour plumes. In addition, a condensate polishing plant will be installed to further reduce the amount of raw water needed.

Raw-water is required for operation of the plant will be stored in a1000 m3 combined raw water / fire fighting tank.

The water will be used for the demineralisation plant (water/steam cycle, auxiliary boiler, auxiliary cooling system), fire fighting water, other services (e.g. cleaning or washing), make-up water for heating, ventilation and air conditioning (HVAC); and potable water.

Two groundwater wells will be used and for both of them use permits from DSI were already taken. Groundwater will be filtered and demineralised as required.

Demineralised make-up water is used to cover the loss of water that has to be drained off the closed circle.

The average daily water consumption will be around 200- 260 m³/d. The maximum amount of water demand will be up to 1000 m³/day during start-up and maintenance (filling of water and steam cycles, auxiliary cooling system and auxiliary boiler), emergencies and special operation modes.

Discharge of Wastewater

Regeneration effluents are expected to be in a range of 20 to 30 m³/day after optimization of the process during detailed design.

The wastewater streams generated in the power plant are wastewater from plant operation (demineralisation plant, steam cycle, neutralisation tank, oil/water separators), sanitary wastewater and storm water runoff.

All the collected wastewater will be directed to the wastewater treatment plant. Due to the request of the Employer during the detail engineering phase of the plant the design shall be changed in such a way that the wastewater stream can be divided in a reusable flow which will be recirculated to the demi plant and in a minimized flow of wastewater which has to be discharged or transported to nearby located larger wastewater treatment plant for further treatment. The discharge of the wastewater will be done according to Turkish and International Standards for discharge into water bodies. If the water quality is suitable the water may be used for irrigation.

Sanitary wastewater, storm water runoff

The areas, where oil contaminated water can be generated during normal operation will be equipped with adequate facilities for oil/water separation and suitable retention pits will be provided

Sanitary wastewater will be collected in a septic pit which serves as a settling tank (septic basin) for the solid ingredients. The solid – free water will be transferred in a collecting basin and transported by truck to a near by located wastewater treatment plant.

Solid Wastes

Given the nature of operation as a natural gas fuelled CCPP, only minor amounts of solid wastes are generated. Beside conventional solid waste, i.e. office and household wastes, and waste packaging



material, various water endangering or hazardous wastes from repair and maintenance of the equipment has to be disposed of.

Hazardous wastes generated on-site comprise, e.g. waste laboratory chemicals, waste lubricants, oily sludge from oil/water separators. All waste will be properly managed and disposed of off-site in accordance with the Turkish environmental regulations and international standards.

Hazardous Materials

Beside the fuel a range of hazardous materials will be used for operation or maintenance at the power plant:

Diesel fuel is stored for the operation of the emergency generators and fire fighting pumps.

Lubricants and hydraulic oils for maintenance are stored in the oil storage at the workshop;

Acids and caustics for wastewater treatment and for regeneration of the demineralisation plant;

Additives for the closed water circuits (antiscaling, anticorrosion, antifouling agents)

Small volumes of solvents and paints for repair purposes;

Small volumes of chemicals for the laboratory; and

Potentially hazardous wastes (used lubricants, paints)

For the storage areas, safety measures imposed by international standards and regulations will be applied (e.g. contained storage, fire alarm, fire fighting equipment).

Table NTS-1: Consumption and releases of the power plant

Combined Cycle Power Plant *

Configuration 2 GT + 2 HRSG + 1 ST (GT – gas turbine, HRSG – heat recovery steam generator, ST – steam turbine)

Fuel consumption Natural gas: 155 000 m³/h (maximum for both GTs)

Air emissions (main sources) volume flow rate pollutant emission rate: - CO - NOx - CO2

- SO2 - PM stack height exhaust gas temperature

3.8 million Nm³/h (for both gas turbines) 190 kg/h 190 kg/h 276 t/h 17 kg/h 19 kg/h 2 x 60 m 104 °C

Water demand (ground water) max. 41.4 m³/h (max. 11.5 l/s, altogether max. approx. 1000 m³/d) average water demand after installation of all water saving techniques estimated to be 9.5 m³/h.

Wastewater Treatment by wastewater treatment plant (neutralisation, oil/water separation etc). It is intended to reuse the water at a maximum extent in a closed cycle system. A minimum wastewater amount will be discharged or transported to a nearby larger



Combined Cycle Power Plant *

wastewater treatment plant to be treated in accordance with the relevant environmental standards

Sanitary wastewater discharge (3.0 m³/h) - COD - BOD - SS - pH

septic pit 120 mg/l 45 mg/l 45 mg/l 6.0 – 9.0

Wastes - sludge - waste oils - waste chemicals and paints - non-hazardous waste

disposed, treated, reused via licensed waste disposal contractors

Source: Feasibility Study of Denizli CCPP.

Table NTS-2: Emission concentrations of the power plant and applicable emission standards in mg/m³

Pollutant Emission Concentration

Emission Standards

Denizli CCPP TR IFC EU

O2 15% 15% 15% 15%

NOx (as NO2) < 50 75 51 (25 ppm) 50

CO < 50 100 Not specified Not specified

SO2 < 5 60 Not specified 35 (3% O2)

PM 5 * No concentration specified

Not specified 5

CO2 76 g/m³ No concentration specified

* assumed to meet the EU standard

Sources: TR: RCAPOIP – Regulation on Control of Air Pollution Originating from Industrial Plants No 26236, 2006,

IFC: EHS Guidelines for Thermal Power Plants, December 2008

Project Set-up

The CCPP will be developed by RWE & Turcas on a Build-Own-Operate basis with RWE & Turcas being overall responsible for financing, construction, operation and maintenance. For design and construction, RWE & Turcas engaged an EPC contractor, METKA, responsible for engineering, procurement, and construction of the CCPP.

If possible local subcontractors will be used under the direct supervision of the EPC contractor's superintendents in order to combine technical

experience with the local experience and knowledge of construction in Turkey.

The EPC contractor will be responsible for system cleaning, flushing, and checkout and will start-up the plant. Start-up will be performed with the assistance of the plant operational and management personnel for equipment operations under the EPC contractor's supervisory direction.

The EPC contractor will be responsible for training of the operations personnel.



Employment and Staffing

The expected staff to operate the 800 MW-CCPP amount to approximately 35 – 40 FTE (Full time Equivalent).

The plant will be operated on a 24-hours, seven days per week basis, staffed by 4 shift teams (one of them is spare), working in three 8-hours shifts. Depending on the available personnel, the majority of staff is intended to be Turkish with a good educational background and the required experience for each position.

Special skills and experience (with respect to environmental issues) will be required for the Assistant Plant Manager and the Laboratory Staff.

During the construction period, it is anticipated that at maximum 350 to 400 employees will be accessing the site. Typically, the employees will work regularly in one shift (06:30-18:00 hours). For special activities (like piling, etc) also two or three shifts may be required.

The EPC contractor, Metka, is a company from Greece. However, RWE & Turcas intends that local Turkish labour (expected 80 to 90%) will be recruited by the EPC Contractor wherever possible and sufficiently skilled workers are available. The maximum use shall be made of Turkish subcontractors and suppliers wherever possible.

Plant Management

The plant management is in charge of environmental, safety and quality assurance. Plant management is responsible for the formulation and implementation of fire fighting, safety and environmental policies and management plans. Plant management is also responsible for ensuring that all operating procedures and standards are correctly applied for the day to day operation and maintenance of the plant.

Project Implementation Schedule

It is planned that establishment of the complete CCPP combined cycle power plant, will be accomplished within an estimated 2.5 years.

The main foundation works will require about 12 months in total. Civil works that are not affecting the mechanical and electromechanical works may extend beyond 12 months into other periods of the construction phase.

The start of mobilization at site is preliminary scheduled for the second quarter of 2010. The start

of commercial operation is scheduled in fourth quarter of 2012.

3 Description of the Environment

Regional Context

The Project is located in the Aegean region, 280 km southeast of Izmir, approximately 35 k m east of the city of Denizli. The site is situated 1.8 km north of Kaklık, 1.6 km west of Yokuşbaşı and 4.2 km northeast of Aşağıdağdere village, all located in Honaz District and 3.5 km northwest of Alikurt village in Bozkurz District, Denizli Province.

Kaklik is located at the junctions of the national roads D320 and D595, connecting Denizli with Ankara via Afyon-Usak.

Denizli region is characterised by agricultural and industrial activities (marble quarries, leather factories). A cement factory is located approximately 4.5 km west of the site. A touristic cave is located approximately 2 km west of the site.

Topography

The region is structured by a valley extending in west-eastern direction with mountainous areas in the north and south. The site is located at the foothills of a mountainous area in the north with Mali Dagi Mountain as highest elevation (1275 m a.s.l.).

The site has an elevation between approximately 545 and 595 m a.s.l and the terrain is ascending to the north and the east. In the north western part of the site an open pit is located. Slopes vary between 10-20% and are located in south-southwest direction.

Land use

Approximately 20% of the area in the province is settled area (settlements and commercial/ industrial areas). From the remaining 80% about the half is forest area, the other part is agriculturally used with mainly agricultural fields and only few meadows or pastures.

Settlements

Besides Kaklik town (approx. 4500 inhabitants), there are three villages, i.e. Yokuşbaşı (425), Alikurt (650) and Aşağıdağdere (675), within the 5 km radius of the project site. All settlements experienced significant population growth of about 10 to 20% since 2000 due to in-migration of workers from other parts of the country.



Agriculture

In Denizli province approximately 80% of the agricultural area is used as fields (mainly wheat, corn, barley, sun flowers and anise), 12% are vineyards and 4% each are fruits and vegetables (e.g. cherries and grapes). Aalso livestock breeding is performed (sheep, goat poultry and milk cattle).

Presently approximately one third of the regional agricultural area is irrigated which will extend up to 50% when all planned irrigation projects are finalized.

An irrigation well is located southwest of the site and an irrigation channel is leading through the site along the western site border currently being operated by the Kaklik Irrigation Cooperative.

The site was mainly used as agricultural land with dry farming of wheat and barley.

Forest

The forests in the region comprise mainly coniferous woods (such as Calabrian pine, Black Pine, juniper and some cedar) and belong to the state for production. No forest is present on site. Forest areas are located north of the site at the hill slopes, east of the site and south of the site at the hill slopes on the southern part of the valley

Infrastructure

Kaklik town is located at the junction of Denizli-Ankara-Afyon-Usak intercity highways. A railway runs through Kaklik and connects to the main railway lines of the country. The Denizli airport Cardak is located approximately 20 km east of the site. The approximately 1 km long road connection form the highway to the site is presently an earth road which will be upgraded and asphalted.

Industrial activities

The main industries of the area are leather and textile industry as well as mining of marble, limestone et al. Adjacent to the west of the project site an industrial zone is planned to be established with the purpose of leather production.

A cement factory is located 4.5 km west of the site. Marble quarries located north of the site (approximately 300 m).

Tourism

Approximately 2 km west of the site, the Kaklik cave is located with a swimming pool in close vicinity, a nature protection area which was opened to tourism Approximately 40,000 people are visiting the facilities per year.

Spatial Planning

The site is designated as natural gas fired combined cycle power plant in the 1:100.000 regional plan (25 August 2009)

At municipal level, no spatial plans were present for the site, so that two plans where prepared for the Project. Both plans, the 1:5000 scale Development Plan and 1:1000 scale Implementation Plan were approved by Kaklık Municipality on 5th September, 2008.

As part of the procedure to establish the two plans, a decision has been taken by Denizli Province Soil Protection Board on 22nd August 2008 to use the project area for other than the agricultural purposes.

Geology

Lithologic units consisting of sedimentary and metamorphic rocks ranging in age from Palaeozoic to Quaternary are present in the area. The basement rocks are composed, from bottom to top, of gneiss, schist and marble units which are impervious and Mesozoic karstic limestone. These rocks are overlain by Oligocene fluvial and lacustrine strata, Pliocene travertine and limestone, and Quaternary alluvium.

A large part of the study site is located in Neogene aged Kızılburun Formation (pebbles, sandstones, clays), Plio-Quaternary aged old alluvium terraces (pebbles), and Quaternary aged alluviums (pebbles, sand, silt and clay).

Tectonics and Seismicity

Earthquakes

The site is included in the Çukurova Basin complex: Pamukkale-Karahayıt fault in the North, Babadağ-Denizli fault in the south, and Honaz fault in the east of the basin are the main earthquake producing faults in the region.

Earthquakes to affect Denizli and its vicinity may be expected and a large number of earthquakes occurred in the past. Upon all assessments, earthquakes with low-mid magnitudes (M: 4.9-6.8) may be expected in Denizli and its vicinity in the future.

The centre of Denizli province, as well as the project site is recognized to be within the 1st degree earthquake risk region (with basic seismic coefficient 0.4). As result, the land buildings and land based structures for this project will be designed to withstand ground accelerations of 0.4g.



The study site is located on quaternary period alluvium units with thicknesses varying between 50 to 150 meters. Fault zones under the alluvium are traceable in the main rocks. However, no fault has been identified in the alluvium units in the project site and its vicinity.

According to Turkish legislation the relevant provisions of the “Regulation on the Buildings to be Constructed in Disaster Areas” will be strictly complied with during the planning stage of the buildings to be constructed during the construction phase of the proposed project.

Soils

In the study area, mainly brown forest soils and alluvial soils are present. The brown soils are observed in the mountains under forest, are shallow and suffer from erosion so that they are classified as soil type VII, i.e. they are no fertile soils which are strongly influence by water erosion, stoniness and saltiness.

Colluvial soils are present at the bottom parts of the slopes and in the river valley.They are usually fertile soils but often needs to be irrigated. Colluvial soils are observed in the middle and in western parts of the site (not irrigated) and are classified as soil type II i.e. fertile soils. However, due to the slopes, the colluvial soil is endangered by erosion.

Hydrogeology and Ground Water

On the project site Quaternary alluvial deposits with a thickness of about 32 m overlay conglomeratic bedrock. The alluvial layer comprises Neogene and late Miocene units consisting of sand, clay, gravel and mixtures of these.

Shallow groundwater was encountered in the alluvial deposits and upper layers of conglomerate between 26 and 38 m below ground level (bgl). In the vicinity of the site, groundwater is used by the irrigation cooperatives in Kaklik and Yokusbasi. Approximately 15 mio m³ groundwater per year are used for irrigation purposes in the vicinity of the site. Groundwater shows high sulphate concentration due to geogene background levels.

Hydrology/Surface Waters

The project area drains to the west and finally to Büyük Menderes River which is the largest river in Denizli Province and one of the biggest rivers in Turkey.

Approximately 2.8 km south of the site, the Çürüksu (Aksu, Emir) River passes by which collects waters from the Honaz Mountain in the south, as well as from the Kaklik regions and flows finally into the Menderes River. Çürüksu River is usually almost dry during the summer months.

Approximately 500 m to the northwest, Çaykara creek passes the site. Approximately 500 m east of the site Hasil creek is located. Both creeks are temporary streamlets. A former branch of Hasil stream diverts from the creek to the west and passes through the site as dry river bed which has lost its stream characteristics due to excavation works approximately 25 years ago.

An irrigation channel (Kaklik Irrigation Cooperative) passes through the western part of the Project area (300 m inside the boundary).

Climatic Conditions

In terms of climatic characterisation the Denizli Province is located at the transition zone from the subtropical-mediterranean Aegean Climate at the coast to a more Continental Climate. Summers are hot and dry. Winters are mild but cooler than at the coast.

Based on the meteorological station in Denizli the long term average for annual precipitation is 556 mm. Temperature varies from -10.5 °C to 42.4 °C with an average of 16.1 °C. The average sunshine hours range between 3.75 and 12 hours.

The wind regime in the Denizli region exhibits prevailing wind directions from north-northwest (NNW) and west-northwest (WNW).

While the long-term average wind speed is only 1.1 m/s (4 km/h), strong winds of up to 29 m/s (105 km/h, hurricane) were also recorded.

Air Quality

The Project area of the CCPP can be characterized as a mixture of primary rural land use with some industrial sources (cement factory, limestone and marble quarries) as well as roads, a railway and household emissions.

For characterisation of the current ambient air quality, nitrogen dioxide (NO2), sulphur dioxide (SO2), and particulate matter are the pollutants of interest. Their concentrations were measured at 35 sampling locations for two one month periods between June and August 2008 by means of passive sampling. Additionally, spot samplings for particulate matter (PM10) were taken in June 2008 at two locations on the proposed power plant site.



The results obtained at the sampling locations revealed a broad variation and an average NO2 concentration of 11 µg/m³. The average concentration of all samples was 6.9 µg/m³ for SO2. For PM10 the measured concentrations were about 10 µg/m³.

All applicable national standards were met. Also the international standards (IFC; EU) were met and hence, in terms of the IFC air quality evaluation, the baseline ambient air quality in the air shed is non-degraded.

Ambient Noise

In June 2008 the baseline of ambient noise was measured at five locations in the vicinity of the proposed CCPP site. The measured day time levels range between 36 dB (A) and 52 dB (A) with the higher values in the settlements. The measured night time levels range between 38 dB (A) and 53 dB (A).

These results meet the Turkish day time noise standard of 65 dB (A) as well as the IFC standard for residential areas of 55 dB (A). While the Turkish standard of 55 dB (A) for night time levels is met, the IFC night time standard of 45 dB (A) was exceeded at the receptor point located in Kaklik which is considered to being affected by the highway traffic.

Ecological Resources

Flora and Habitats

A significant part of the site is used for dry agricultural activities (wheat and barley). The remaining parts are covered by fallow land, and maquis.

Due to human activities hardly any natural vegetation within the area except some scrubby vegetation in the east part was found during the field study. No natural forest exists within the site.

As result of the field studies, 163 flora species were identified in a study of 5 km around the site. Endangered Species were determined according to IUCN categories and Turkish Red Lists (Ekim et. al., 2000), as well as to BERN Convention. Among the 163 plant species, nine are endemic to Turkey. One of them is classified as regional endemic but is abundant in Denizli and its vicinity. Eight are common endemic which means that they are wider spread than regional ones - either in Aegean Region or in whole Turkey.

Fauna

Faunal diversity within the study area of 5 km is relatively poor. Threatened species and habitats for wild life were evaluated according to IUCN categories, Turkish Red List and BERN Convention. In addition the status of birds and mammals in respect of Central Hunting Commission Circular (2008-2009) was identified.

Fauna findings include six reptile species. One of the amphibian species is classified as "vulnerable (VU)" by IUCN but is found to be common and widespread in Turkey. Two amphibian species were identified. All of the reptile and amphibian species identified in the study area are widespread either through Turkey or Aegean Region.

In total seven mammal species were identified. One of them is classified as "vulnerable (VU)" by IUCN, but is common and widespread in Turkey.

18 bird species were found; 11 are non-passerines and 7 are passerines. Most are resident (native) species that are observed throughout the year in the same area, but are not nesting or breeding in the site. Others are summer visitors that are widespread in several regions in Turkey.

Five bird species were found to be nesting in the impact area. No endemic or IUCN listed bird species were found. The site and its vicinity are not within bird migration routes.

In total, 33 fauna species were observed within the study area of 5km around the site. 30 are listed as endangered according to Bern Convention, 23 fauna species are listed on the Turkish Red List. All identified species are common and widespread in Aegean Region as well as in whole Turkey. Within the study area, no wildlife protection area is present according to Decree 9453 (2005).

Cultural heritage

According to information from the Directorate of Museum of the Denizli Provincial Culture and Tourism Directorate no cultural heritage is present in the site or its vicinity.

Landscape and Visual Amenity

The power plant will be located at the foot of the Mali Dagi mountainous area in the mainly covered with forest (Pinus brutia) whereas the valley is agriculturally used or is covered with maquis/steppe vegetation. The elevation difference between the valley and the northern mountain is approximately 700 m



Greenish-brown colours from the forest are prevailing in the mountains, beige-brown colours from rare vegetation and agricultural fields are prevailing in the plain. are Further prominent landscape feature in the vicinity of the site are quarries and the cement factory assumed to be of the same height as the planned CCPP (appro.x. 60 m).The settlements in the vicinity are rural

Socio-economic Situation

In 2007 Denizli Province had 907,325 inhabitants and Honaz District showed a population of 28,941 inhabitants. In the same year 6,278 people lived within the project area.

The employment rates are quite low in the area, with 68% for males and only 12% for females. The main livelihood sources are the nearby industries (marble, stone and cement industry, leather and textile, construction). Farming (wheat, barley, grape, cumin, cotton, quince, peach and sunflower) comes as the second most common occupation for both males and females.

The annual incomes vary greatly between 720-33,600YTL/year, with an average of approximately 10,000YTL/year. Approximately 32% of the families are engaged in subsistence farming. By Turkish national standards, the overwhelming majority (84%) of people in the study area are poor.

Following the national trend, the project area is found to be very homogenous in terms of ethnicity (native Turkish) and religion (Muslim).

Women headed households comprised approximately 9% of the households in the project area. Main reason for becoming the head appears to be the death of the husband. Lack of employment opportunities appeared to be the main concern of women in the area.

The average duration of education is 6.8 years for males and 5.3 years for females.The adult illiteracy rate is 3.8% for males and 19% for females. The public health situation in Turkey has some weaknesses. Denizli, when compared to other regions, benefits from higher densities of health professionals, better access to preventive health care and lower rates of infectious diseases. In general the health conditions in the project area were observed to be good.

Concerning land tenure the majority of the farmers hold title deeds for their lands and informal agreements are not common in the area.

Groundwater is the main source of water in all the settlements. While Asagidagdere, Alikurt and Yokusbasi have their own wells, Kaklik's water is piped from the neighbouring Sapaca village. 90% of people use the tap water for also drinking purposes.

All residents have access to improved sanitation. There is a natural wastewater treatment plant in Alikurt; however it is no longer working. In Yokusbasi, the wastewater is collected in a septic tank before discharge. There are no treatment systems in Kaklik and Asagidagdere. All the wastewater is discharged into dry and semi-dry river beds.

All the houses in the project area have electricity. Electricity cuts (1 to 3 times per month) and repeated changes in voltage are commonly reported problems. Coal and wood are the main sources of heating fuel.

The domestic wastes of Alikurt and Kaklik are collected by the Kaklik municipality and dumped into the designated garbage disposal site. Other villages do not practise any waste management and dump their wastes irregularly.

Other than Kaklik (regular buses), none of the settlements have their own public transportation.

Key development issues are:

Need for investments and employment opportunities;

Construction of inner roads;

Education (primary schools in Kaklik);

Transportation facilities to Denizli and workplaces;

Recreational facilities (park, playgrounds for children, library, cinema facilities, restaurants etc);

Solid waste management;

Sufficient and better irrigation facilities;

4 Alternatives

“No Action” Option

The need for the project has been described in Section 1. The "no action" alternative, i.e. not to pursue with the implementation of the Project, would result in an increasing electricity supply deficit as demand increases in future years. A lack of a secure and reliable electricity generation and supply system raises significant negative social, economic and environmental implications



Alternative Sites

The Kaklik site in Denizli Province was compared against other sites in Samsun, Adana and İzmir Province. The Kaklik site was selected since it combines the main advantages of all sites. It is located nearby an existing gas pipeline. The length of the connection to the electricity grid will be limited compared to the other sites. In addition, the site is located close to existing roads. The area is economically developing and thus creating demand for energy. The number of land owners is limited and land purchase could be based on negotiations with the owners. The location of the site in first degree earthquake area will be handled through a structural design appropriate for this site.

Since the Kaklik site is agriculturally used it was also investigated whether there is an available site in an industrial zone in Denizli region, but no available or suitable site for the power plant was found.

Fuel

The CCPP will be fuelled solely by natural gas. Alternative fossil fuels for power generation are coal and oil. Non fossil fuels are based on biomass.

Compared to oil and coal, natural gas has the following advantages:

No on site storage requirements (big storage tanks are required for oil and large stockpiles for coal, which poses a risk for soil respectively coal dust emissions);

Transportation by pipeline which causes no traffic;

Combustion of natural gas generates less air emissions than burning of oil and coal which comprise SO2, soot, particulate matter and heavy metals in addition;

The specific emissions of pollutants (quantity of pollutant per unit energy generated - i.e. kg/kWh) are less for natural gas;

The emissions of greenhouse gases is the lowest for natural gas combustion;

Burners for natural gas have higher energy generating;

Discharge of waste heat is lowest due to the higher energy efficiency

No solid wastes generation like slag or filter ash from air emission control systems;

Disadvantages when using natural gas are the potential hazard risk related to the handling of a

flammable gas, the requirement of pipeline infrastructure, and the general consumption of a fossil resource which generates greenhouse gas (CO2) emissions.

Alternative Power Generation Techniques

Non fossil/regenerative power generation is based on biomass, wind, solar energy, or hydropower.

These power generation techniques depend on specific requirements which have to be present at a site:

Burning of biomass could be an option only in case the required large quantities would be available for base load operation, which is not anticipated.

Power generation from wind power requires very large wind farms to reach the 800 MWel capacity of the CCPP with a respective occupation of land which is not available in the region of Denizli, even if there is adequate speed and continuity of wind in the region;

For solar energy the same applies; solar power plants of 800 MWel capacity to date are not available as standard and cannot serve for base load electricity generation due to their dependency on sunlight fluctuation;

From their nature, wind and solar energy are no continuous energy sources and not reliable to provide for a base load;

Hydropower can only be utilized in regions where large quantities of water are available in combination with the ability to collect water by means of a dam and/or to utilize a difference in height. Such situation is not given in the region of Denizli;

Process Technology

Power plants for electricity generation from natural gas firing are based on gas turbines. Open cycle gas turbines can achieve an efficiency of some 30-35 %. By coupling with a steam turbine, the efficiency is extended significantly. With an efficiency of approximately 57 %, the combined cycle technology of the Denizli CCPP will make a most efficient use of the natural gas fuel.

This technology represents the best available technology in terms of both efficiency of electricity production and minimisation of environmental impacts (low-NOx).

The combination of two gas turbines as chosen for the CCPP provides a higher power supply safety



than only one gas turbine (i.e. if one gas turbine is disconnected).

The key plant layout decision is about the cooling technology. The CCPP will be equipped with air cooled condensers (ACCs). Potential cooling system alternatives are “direct (once through) water cooling” and “indirect water cooling” by means of evaporative cooling towers. From the environmental perspective ACC cooling technology has several advantages:

ACC technology requires comparatively little raw water and allows for water resources saving operation (no extraction of large volumes of groundwater or surface waters for wet cooling.);

No discharge of cooling water and no thermal plume;

No cooling towers are needed;

In addition, to minimize potential effects on groundwater levels, several water saving techniques were included in the design such as a condensate polishing plant and reuse of water to a maximum extent.

5 Anticipated Environmental Impacts

and Mitigation Measures

Land use Impacts

The actual agricultural land use of the site (dry farming) has changed to industrial land use. Thus, the local development plan 1:5.000 and implementation plan 1:1.000 have been approved on 5th September 2008. The authorities (Denizli Province Soil Protection Board and finally Ministry of Agriculture and Rural Affairs) approved to use the project area for energy generation area.

The potential impact on the economic situation of the farmers is dealt with in section on social and socio-economic impact. No adverse impact on land use is expected from the Project.

Ambient Air Quality

Actual ambient air levels for the 800 MW CCPP were determined by ambient air measurements in June-August 2008. In order to determine the effect of operation of the power plant on the environment, the increments of the ground level concentration caused by the plant emissions was calculated by means of dispersion modeling.

During operation, the exhaust gas of the gas turbines of the plant will be released to the atmosphere via two 60 m high stacks. Given the

use of natural gas as fuel solely for the CCPP, the only significant air pollutant emissions to be expected from plant operations are nitrogen oxides (NOx) and carbon monoxide (CO). For both substances, the emission concentrations will be below 50 mg/m³. Emissions of sulphur dioxide and particulate matter are negligible. Based on a maximum sulphur content of 110 mg/m³ in the natural gas supplied by BOTAS (low-sulphur gas), the maximum hourly emission rate with the exhaust gas is about 8.5 kg SO2 for each stack. The concentration of particle emissions can be considered to be below the European standard of 5 mg/m³ for gas turbines.

Operation of the auxiliary boiler will be limited to only few hours of the year and when the plant is not fully operating (minor emission source which will not affect the ambient air situation in a significant way).

At standard design conditions a flue gas volume flow rate of about 1.9 million Nm³/h (dry) will be emitted from each stack at a temperature of 104°C for base load operation.

For the ambient air quality assessment for CCPP operation two different models were used for the local EIA and ESIA: Gaussian Dispersion Model and Lagrangian Dispersion Model. For the calculation, operation throughout an entire year (8,760 hours) was presumed, which neglects that operation actually is interrupted by e.g. maintenance. Calculations were performed for an area of 16 km x 16 km. (10 km x 10 km in the local EIA).

Ambient air standards applicable for the power plant are compiled and compared to the emissions of the plant in Table NTS-3. The international standards are taken from the IFC - General EHS Guidelines and regulations issued in the European Union.

Some ambient air quality standards have to be linked to a certain modeling approach. The European standards, for example, require modeling which is adapted to the standards, to evaluate a standard allowing for a certain number of exceedings as a statistical parameter.



Table NTS-3: Ambient Air impact of the CCPP

Pollutant Reference Period

CCPP

Limit / Guideline Values

Calc. max. impact at settlement areas

Calc. max impact in airshed

Kak

lik

Yok

usb

asi

Ali

ku

rt

Asa

gid

agd

ere

NO2

(µg/m³)

Annual Daily 1 hour (18 exc.)3 1 hour max2

1.2 - 33 76

0.5–0.8 - 14 – 24 15 - 26

0.1 - 0.2 - 7 – 14 10 - 19

0.3 - 22 - 24 26 - 33

0.7 - 0.8 - 23 – 26 24 - 28

100 (TU); 40 (303) (EU); 40 (G)4 (IFC) 300 (TU) 2005 (EU); 200 (G)6 (IFC) -

CO

(µg/m³)

Annual Daily Hourly (8h)

Since the maximum emissions are equal to NO2, the increments for NO2 can be taken for CO

10,000 (TU) 30,000 (TU) 10,000 (EU)

SO2

(µg/m³) Annual Daily 1 hour (24 exc.)2 1 hour 1 hour max1

- - < 4 < 0.1 8

- - <3 < 0.1 < 3

150 (TU); [50] 207 (EU) 400 (TU); 125 (EU); 125/50/20 (T1/T2/G)* (IFC) 350 (EU); 500 (10 min.) (IFC) -

PM10+ (µg/m³)

Annual Daily

Since the maximum emissions are equal to SO2 and PM10 particles behave like gases, the increments for SO2 can be taken for PM10

150 (TU); 70/50/30/20* (IFC); 40 (EU) 300 (TU); 150/100/75/504 (IFC); 508 (EU)

Dust deposition (mg/m²d)

Annual - - 450** (TU); [350] (EU)

* Air Quality Evaluation and Management Regulation (AQEMR) published in the Official Gazette number 26898, dated June 6, 2008

** Regulation on Control of Air Pollution Originating from Industrial Plants (RCAPOIR) published in the Official Gazette number 26236, dated 22.07.2006

+ airborne particles with aerodynamic diameter of 10 µm or less)

2 Maximum hour of year 3 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project.

4 The standard may be exceeded up to 24 times per year (according to the European ambient air quality standards defined as 1 hour limit but allowing for a number of exceedings. This means that the 18 highest averages of the year are excluded. As a first and conservative approach, the calculated values can be interpreted as reference 24 hours maximum, however, overestimating the actual 24-hours average.) 5 The standard may be exceeded up to 18 times per year (as allowed per the standard of the European Directive 1999/30/EC) 6 T1/T2/T3/G - IFC interim target-1 / interim target-2 / interim target-3 / Guideline value:

The guideline values provided in the IFC General EHS Guidelines are adopted from the WHO Ambient Air Quality Guideline 2005. The guideline values cascade down from higher to lower levels indicated as 'interim-target 1' through 'interim-target 3' to end up at the 'guideline value' with the lowest concentration and highest ambient air quality. Interim-targets take into consideration that achievement of the guideline value in undeveloped or developing countries requires long-term development and improvement effort. 7 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project. 8 The standard may be exceeded up to 35 times per year.



Local and Regional Climate

The site is located in a valley. Therefore the buildings of the power plant will not form a significant hindrance for local wind field and air transport. As there are no high buildings in the neighborhood no wind funnel or other effects on the local wind fields are anticipated. The operation of ACCs will not produce a vapor plume like it is known from cooling towers where high volumes of vapor is drafted into the atmosphere. Therefore no effects like increased humidity or additional fog creation on cool days in the neighborhood of the power plant are expected to occur.

It is not expected that the CCPP will have any significant effects on local or regional climate.

Local Temperature

The combined cycle process is using waste heat from burning of gas. The remaining heat is discharged via the stack. There are two main sources of thermal energy, namely the energy contained in the flue gas emitted from the stacks (137 MW) and the heat transferred into the ambient air by means of the ACC (450 MWth).

The stack emission is dispersed along the plume in a similar way than the air pollutants but with an additional reduction related to the exchange of energy with the air outside the plume. Even when ignoring the latter effect, the dilution in the plume in the most adverse situation is at least 1:600. When taking an exemplary ambient temperature of 20 °C and a flue gas temperature of about 104°C, the short-term ground level temperature increase will be not more than 0.15 °C.

From the ACCs approximately 32 degrees warm air is rising (air throughput of 22,000 m³/s). The dilution factor required to ensure a temperature increase of less than 1 °C is about 1:12. It can be assumed that such dilution is reached in the ACC's air stream after only a short time and distance.

Since the ACC fans lift the up-heated cooling air into the atmosphere, no significant waste energy flow will reach the ground.

It has also to be noted that the issue of potentially increased ground level ambient temperature caused by operation of a cooling tower or an ACC is no matter of concern for power plant projects. Neither the IFC guideline nor the EU

BREF or international regulations address this topic due to the non-existing relevance.

Greenhouse Effect

The power plant will be solely fired with natural gas, which generates CO2 that contributes to the Greenhouse Effect and Global Warming. However, no other greenhouse gases like i.e. methane (CH4), nitrous oxide (N2O), are generated by combustion of natural gas.

The specific CO2 emission rate of the Denizli power plant will be approximately 357 g per kWh of electricity generated (i.e. 2.4 million tons per year based on 8,400 hours base load operation and 276 t/h CO2 emission).

The emissions of CO2 from fuel burning in Turkey amounted to around 313 million t/a in 2005 (1st National Communication, 2007). Compared to these CO2 emissions, the Project will account for approximately 0.8 %.

Noise Impact

Construction and operation of the new CCPP will involve sources of noise, e.g. turbines, air cooled condenser. The actual sound characteristics as well as the sound absorbing features of the noise sources will be specified through the detailed design by the EPC Contractor.

To assess the impacts of operation noise of the CCPP two indicative noise predictions were conducted. A first preliminary modelling was conducted in the course of the EIA-process under Turkish law and already demonstrated compliance with Turkish law, based on the engineering available at the time (August 2008). In line with the progress in planning and engineering of the CCPP a second prediction was carried out in January 2010. The aim of the study was to answer the question on whether or not an adverse noise exposure has to be expected for the neighbourhood settlements and which mitigation measures should be considered, if required to meet the international noise standards. This modelling is based on a conservative “plausible worst-case” approach and also considered meteorological conditions, attenuation effects of buildings and plant layout effect.

The following tables present the findings of the modelling for the nearest inhabitated areas cumulated the findings of the baseline measurements and the relevant noise standards



Table NTS-4: Cumulative Noise levels at the settlements

Kaklik (IP2)

Yokusbasi (IP1)

Daytime Leq Baseline 51.6 50.5

Daytime Leq Modeling 43.0 40.0

Daytime Leq Cumulative

52,2 50.9

Night time Baseline 52.7 40.0

Night time Modeling 43.0 40.0

Night time Cumulative 53.1 43.0

Table NTS-5: Noise standards (Turkey and IFC)

Standard dB(A)

Turkey daytime standard 65

Turkey night time standard 55

IFC daytime standard 55*

IFC night time standard 45*

According to IFC EHS Guidelines (2007) noise impacts should not exceed these levels or result in a maximum increase in background levels of 3 dB at the nearest receptor location off-site.

For Kaklik the measured baseline was significantly higher than the noise impact of the CCPP. Therefore the plant's contribution to the cumulative noise level is very small. Since the dB(A) scale is a logarithmic scale, the increase of the baseline caused by the plant will be not more than 0.6 dB(A) for daytime and 0.4 dB(A) for night time.

In Yokusbasi the background for daytime was higher whereas the one for night time was approximately the same as the calculated noise from the CCPP. Therefore the plant's contribution to the cumulative level was 0.4 B(A) and 3.0 dB(A) for the day and the night time respectively.

Given these results, the Turkish noise standards are met at the two settlements for both, the day and the night time. With respect to the IFC standards, the cumulative daytime levels and the night time level for Yokusbasi (IP1) will meet the respective standard. However, for the night time the levels in Kaklik (IP2) exceed the standard. On the other side the contribution of the CCPP to the cumulative noise level of 53.1 dB(A) during night time is a mere 0.4 dB(A) which effect will not be perceptible. The additional criterion from IFC that the incremental noise from a plant shall not

increase the baseline by more than 3 dB(A) was met for Kaklik and Yokusbasi.

The input data for the modelling are based on data provided by the project proponent. The detail design will give raise to some modifications which can lead to different noise levels. The modelling should be repeated with the respective figures.

During construction, vehicles will be moving on the site area and on the access road. Noisy activities may occur over short periods during piling, concrete pumping, outdoor usage of machines (e.g. saw, compressed air tools) and activities like hammering.

All these noise sources are typical for construction activities and may temporarily cause elevated noise levels in the site's vicinity. The anticipated average noise level of these sources adds-up to a total noise power of less than 114 dB (A) as estimate for the entire construction site.

A comparison with the results for the plant operation which is based on a Lw of 122 dB/A shows that the estimated impact will be about 8 dB (A) lower than predicted for the operation. Based on this, the noise impact for Kaklik and Yokusbasi caused by the construction works will be around 40 dB (A).

Operation of noisy equipment will be limited to the daytime. The baseline measurements show that the daytime noise levels at the receptor points are higher than the estimated construction noise. Given the distance and the presence of other noise sources like public traffic, it can be expected that the noise impact is acceptable for the neighborhood.

The overall duration of the civil works is envisaged to last for more than two years. The activities will change over time and the noise sources will vary accordingly.

Vibration

Vibration from plant operation will be imperceptible beyond the site boundary as rotating equipment will be correctly balanced and equipment will be vibration isolated.

Measurement of vibration from construction plants have shown that, even from heavy construction activity, i.e. percussive piling, vibration levels typically fall to imperceptibility beyond approximately 100 m from the vibration source. From other sources of vibration, such as



excavators, bulldozers and heavy goods vehicles, imperceptibility levels are reached at much shorter distances. Furthermore, construction activities are expected only for a limited period of time and will be limited to the daytime.

Operational Health and Safety Issues

Risks were identified at different operation units of the power plant, in particular at: generator and turbine areas, electrical rooms, transformer area, cable tunnels and storage facilities for chemicals.

Major accident hazards or emergencies with the potential for injury, impairment and/or damage with potential risk to third parties, facilities, or populations that may occur in thermal power plants are: fire, explosions, electrocutions and spillages (oil, acid, chemicals). In addition, hazards particular to gas fuelled facilities are basically: the loss of containment, internal gas explosion and catastrophic failure of rotating machinery.

Given the measures incorporated into the design of the plant to minimize the risk from fire and explosion, as well as from electrocution and spillages, major disasters are considered as unlikely. In addition, since natural gas will be delivered to the plant by pipeline, there will be no natural gas storage facilities on site. Furthermore, no hazardous chemicals will be held on site in quantities sufficient to pose a major hazard.

Employees will be trained on how to avoid accidents (e.g. training for fire fighting, first aid, rescue and emerging assistance). Fire fighting is provided by CO2 fire fighting system at the turbine units and fire fighting water.

The project operator will develop an HSE Management System and Emergency Response Plan (ERP) which includes general management system requirements i.e. policy development, organization, planning and measurement, review, audit and specifically emergency response instructions and which will be part of the Operation Manual based upon established standard manual. The ERP will cover inter alia chemical spills and releases, disasters like fire and explosions, natural hazards management (e.g. earthquake, storms) and civil unrest.

Electrical Magnetic Fields (EMF)

The effects of electromagnetic fields (EMF) on human health have been a permanent highly

disputed issue in recent years, in particular long term exposure to EMF arising from installations such as transmission lines. Authoritative, internationally recognized epidemiological studies to date have failed to establish a reliable causal relationship between exposure to EMF and disease, leukemia being the main concern. Based on the findings available, the International Conference on Non-Ionizing Radiation Protection (ICNRP) has recommended precaution limit values for long term tolerable exposure to low frequency fields (50 Hz):

100 µT magnetic field

5 KV /m electric field

These limit values are internationally widely accepted, e.g. also EU Council Recommendation (1999/519/EC) 12 July 1999 on the limitation of exposure of the general public to electromagnetic fields (0 Hz to 300 GHz) for 50 Hz recommends the ICNRP limits.

EMF sources of the CCPP basically are generators, transformers, switchyards and transmission line connection.

In principal, the highest magnetic fields will occur inside the switchyard perimeter fence and under the power export transmission lines. Electrical fields from the switchyard will be blocked by the metal perimeter fence. EMF levels decay with increasing distance from the transmission lines and the transformers. The comparison with established planning guides suggests that the CCPP and connected transmission lines will be of no concerns provided that relevant distances to residential and publicly used areas will be kept.

The German Federal/Laender Immission Protection Committee (LAI, 2004) provides planning guidance in form of precaution EMF safeguard minimum distance for 50 Hz installations to residential areas in relation to the voltage level. For 380-kV transmission lines the minimum distance should be 20 m.

Interference with other facilities or activities

The CCPP plant is located in a mixed agricultural and industrially used area. The existing cement factory and marble quarries are a source of dust emission which requires appropriate filters for the CCPP to prevent its intake. Directly bordering to the west, an organized industrial area for leather industry is planned. It is assumed that the planned facilities will not have any



interference with the power plant regarding air emission, noise or other emissions. However, it is presently not known if potential competing users of groundwater resources will exist which should be considered in the ongoing hydro-geological study.

The site is located about 20 km to the west of Denizli airport and is not in a direct approach route for civil aviation. The exhaust stacks will be equipped with obstruction lighting as per international practice (continuously red marker lights during night time.) and the specific requirements of the Aviation Authority.

No local communication routes or pathways are located on the site of the planned CCPP. The existing earth road connecting the site with the national road will be upgraded and extended which is also in benefit to other users of the road (marble industry, farmers). The enhancement of the road lies within the responsibility of the Kaklik Municipality. No expropriation is foreseen for this subject.

The increased traffic during construction time may pose a safety risk on the conjunction of the site connection road with national road D595. In the transport logistics study to be carried out by the EPC contractor.

Provided that appropriate safety aspects of the conjunction of the connection road to the main road are carried out, there is no adverse interference with other facilities or activities.

Solid Waste Management

A natural gas fuelled power plant produces no ash and only a low quantity of other solid wastes during construction and operation. These include the following:

Construction waste: contaminated spoil, oil drums, etc.;

General plant wastes: oily rags, broken and rusted metal and machine parts, defective or broken electrical parts, empty containers, miscellaneous refuse, waste chemicals from laboratory;

Raw water pre-treatment sludge: residues of the raw water pre-treatment system (e.g. sand-filter back-wash, iron sludge);

Wastewater treatment: waste sludge from neutralization, belt filter residue, sludge from oil separators, sludge from drainage

interceptors used to remove solids and oils and grease from effluent;

Packaging waste: from operational consumable supplies;

Commercial wastes: from offices and staff facilities;

The amounts of sludge residuals from raw water treatment and wastewater treatment will be limited. Wastes generated at and by the plant will be disposed of from the site by licensed contractors. Final disposal of wastes will be to waste treatment plants or sanitary landfill sites, as agreed by the relevant competent administrative authority. All solid waste will be segregated into different waste types, collected, recorded and stored on site in designated storage facilities.

A waste management plan will be set up and an environmental engineer will be responsible for solid waste management at the site. The impacts of solid waste generated by the construction and operation of the power plant are not predicted to be significant.

Impact on Water

Groundwater:

Construction activities could potentially result in the release of effluents to surface or groundwater. After assembly and welding, the HRSGs and pipe duct system as well as other facilities require thorough cleaning before test operation This will be a source of polluted wastewater which requires adequate treatment. These wastewater streams will be announced to the authorities and respective permits will be obtained

No construction time impacts on surface and groundwater resources could be identified provided that the Contractor implements the following construction management measures are applied properly (“good site practice”):

Any flows of potentially contaminated washing waters e. g. from boiling out of the HRSGs will be stored temporarily in a dedicated basin and will be disposed off site only after suitable neutralization and treatment (including filtering of particles) by a licensed Contractor. The Contractor will apply suitable laboratory testing equipment to ensure that the Turkish effluent standards will be met for the final discharge of any treated effluents.



Sanitary wastewater will be collected in a septic pit which serves as a settling tank (septic basin) for the solid ingredients. The solid – free water will be transferred in a collecting basin and transported by truck to a near by located wastewater treatment plant.

Solid wastes will be collected and adequately treated outside the project area.

For the planned power plant several water saving measures are included in the design (such as ACC cooling, condensate polishing plant etc.) resulting in an average water need of approx. 200-260 m³/d. The water demand will significantly increase during start-up and maintenance, emergencies and special operation modes. The total water amount of approx. 1000 m³/d allowed to be abstracted according to DSI will not be exceeded even during peak times. The exact water need will be determined during detail engineering phase when the water saving technologies will be developed in detail.

Two groundwater wells have been drilled and the maximum abstraction rates allowed by DSI are altogether 11.5 litres/s. Water will be provided to the site by a pipeline. A groundwater study has been prepared by the Istanbul University to evaluate the best location for the new groundwater wells before drilling.

The Kaklik Irrigation Cooperative is presently the main groundwater user in the area and uses approximately 3 Mio m³ of groundwater per year. The estimated total amount of groundwater needed for the operation of the CCPP is approximately 70,000 to 100,000 m³ per year which amounts to approx. 3% of the amount used for irrigation.

Based on this comparison the overall portion of the water needed for the power plant is low compared to the water needs of the other users. Considering the information on aquifer thickness the needed amount of water will not significantly affect the overall groundwater availability. However, based on the available data local variations of the groundwater level cannot be excluded which could lead to negative effects on near by wells. But, given the fact that the location of the groundwater wells was determined under the supervision of the Turkish Water Authority DSI with the aim to minimize potential effects on nearby users, these negative effects are not considered very likely.

The applied water saving technologies are an important mitigation measure to reduce the water needs of the power plant and thus to limit potential negative effects on other users.

To verify the assumptions of the above mentioned groundwater study a groundwater monitoring should be carried out to observe the long-term development of the groundwater levels. In case negative effects on neighbouring groundwater users occur during operation of the power plant, the Developer will seek cooperation with the affected parties with the aim to develop appropriate mitigation measures. Such measures could comprise supporting the improvement of the irrigation system of the Kaklik Irrigation Cooperative to reduce the amount of water needed for irrigation.

Surface water:

No shallow groundwater and no sensitive aquifer or surface water body is expected in the project area which could potentially be contaminated by spills. Also only limited quantities of chemicals and lubricants will be normally present on site. Since raw materials in the CCPP will be in housed storage, and moreover precipitation is overall low, there is also no potential for any significant leachate generation.

Wastewater Discharge:

The amount of wastewater is expected in a range of 20 to 30 m³/day after optimization of the process. The effluent of the wastewater treatment plant will either be discharged to a nearby stream or it will be transported to a nearby larger wastewater treatment plant for further treatment. In both cases, the effluents will be treated to the quality required by Turkish and international standards (such as IFC EHS Guidelines) for discharge to receiving water body or if possible to irrigation water standards.

To verify that the applicable limit values are observed during operation the effluents should be monitored regularly.

Impacts on Soils and Geology

The surface topography of the site will be changed. The areas where the plant structure will be located will be sealed which will result in a loss of soils. The remaining areas of the site which will be used for construction activities will be compacted.



The affected soil types are abundant in the region. Thus, there are no special, sensitive or protected soils or geological features or mineral deposits within and around the site. Hence, the development of this area of land will not have any significant impacts on soil or geological features or on mineral resources.

The construction and operation of the power plant have the potential to cause some contamination through spillages and leaks, especially around fuel storage areas and chemical storage areas. Potential contaminating substances will include fuels, lubricating oils, hydraulic fluids, water treatment chemicals, plant cleaning chemicals, sanitary effluent and detergents.

The potential for soil and subsurface pollution from construction will be minimized by proper construction site management. The EPC contractor will prepare a construction site management plan which includes aspects of proper handling and storage of materials and collection and disposal of solid and liquid wastes. Also for operation the potential for subsurface contamination will be minimized by a management plan. In addition several measures have been included in the design such as secondary containment or retention pits.

The soils in the steeper areas in the northern parts of the site already suffer from erosion. The soils in the lower site area are susceptible to soil erosion. Thus, the construction management plan shall also address erosion prevention measures such as using a reduced slope angle for stockpiles etc.

With the listed mitigation measures in place, the construction and operation of the proposed power plant is not predicted to cause any ground contamination on-site or of the surrounding land.

Flora, Fauna and Habitats

Since the power plant will be located on agricultural area only parts of the flora and fauna habitats will be permanently lost. The existing endemic plant species are widely spread in the region and are therefore not considered to be threatened.

Some amphibian species were observed around the irrigation channel which may be re-located and which should be established in a way that it suits as habitat for amphibians. Although no breeding birds were found on the project site, five bird species are nesting and breeding in the

study area. No endemic fauna species was found in the project area or its vicinity.

Since in the area similar habitats are present, it is very likely that fauna species will found sufficient feeding habitats in the immediate vicinity of the site.

During construction and operation the CCPP will emit noise and light, air pollutants, wastewater and waste. For all these topics mitigation measures are planned to minimize the release into the environment. Since all these emissions will be below applicable national and international limit values no significant impacts on fauna species are expected.

No effects are anticipated from the presence of the 60 meters high stack structure on bird populations and habitat functions since area is not located within migration bird routes.

After end of construction works, the areas shall be established as maquis and steppe area where possible to provide suitable habitats. In addition, trees should be planted in the health protection zone around the site as a compensation of the lost areas.

Visual impact

The CCPP will be a noticeable installation in the landscape. The stacks of the CCPP will be about 60 meters in height and visible from a larger distance; the ACC installation will reach a height of up to 35 meters. However, it should be noted that the proposed ACC technology will avoid the adverse visual impact of traditional hyperbolic cooling towers and the generation of large visible plumes of uncondensed water vapor.

The stacks are not expected to dominate the landscape because of the high mountains in the background. It can be assumed that the CCPP installation will not be bigger than the mentioned cement factory.

However, in the near field the building structures will significantly change the view shed for the neighbouring agricultural sites, the national road to Denizli and partly also from the nearest villages Kaklik and Yokusbasi. From Alikurt, the CCPP will hardly be visible. From Asagidagdere, the CCPP will only be visible from the borders of the settlement or from the higher parts within the village.

It is intended to integrate the power plant into the landscape by using greyish-brown colours for high structures and planting a green belt around



the site. This will also create a buffer to the neighbouring agricultural areas and provide visual screening. Once fully developed, the vegetation will also have other positive effects such as additional noise attenuation and retention of dust in ambient air.

Exterior lighting will be provided for operation and maintenance. However, the visual impact of these lights is not considered to disturb the neighbouring villages due to the distance.

The exhaust stacks will be equipped for aircraft security continuously during the night hours which is similar to what can be seen on radio or television towers.

Archaeology, Historical and Cultural Heritage

No archaeological, historic or cultural remains of significance are known to be present on or near the site.

Natural disaster risks

The CCPP installations will be designed to withstand natural disaster impacts like seismic or flooding risk according to the applicable design standards and criteria.

All construction activities shall abide to the relevant laws and legislations, and the buildings and structures shall be constructed according to the legal regulations (Building Inspection Act, Building Inspection Regulation) for earthquake zones like the “Regulation on the Buildings to be constructed in Disaster Areas”. The new CCPP will be designed to withstand seismicity coefficient of A= 0.40 g.

According to the competent agency DSI, flooding of the site did not take place in the past and is unlikely to occur in the future.

Social and Socio-Economic Impacts

The analysis of social, health and economic impacts is based on social survey results. It considers permanent and temporary impacts.

Loss of Land and Natural Resources

The purchases of all private lands were made through negotiations. According to the statements of Kaklik Mayor, Yokusbasi village headman and land owners, the acquisition price was sufficient to replace the land with a similar size and similar/better quality land. Sample interviews with owners conveyed that land acquisition did not cause grievances.

The location of the project does not prevent access to any other communal/natural resources.

Interviews carried out found that drop of water table is one of the main concerns about the proposed project. In case the project becomes a competitive user this impact would be major and permanent as the plant will continue using water during the operation.

Social Networks and Infrastructure

There is already a high rate of in and out-migration in the area. The communities do not appear to have problems with the incoming people and most locals ( 85%) even support this, as migration (and increasing demands) has been accelerating the development of the area in terms of public infrastructure (e.g. education and health services, small shops etc) and economy.

The relatively sudden influx of possibly up to 350 - 400 workers with different backgrounds may affect the social structure and networks during construction. This may result in pressure on local health facilities. This impact will be minimized since health facilities for the workers will be provided on the site. In case a large amount of workers bring their families pressure on further social facilities may arise (e.g. education). However, by adoption of a local employment strategy the number of the in-migrant will be limited. In case any effect on social facilities will occur during construction this impact is expected to be temporary and will be addressed in a constructive manner between the RWE & Turcas and the Municipality of Kaklik if it occurs.

Health Risks

The extent of disease transmission between the communities and in-migrants will depend on the level of interaction between the two, the workforce size and health status of the workforce and their living conditions. Due to the general conservative nature of the society and low incidence rates the probability of an increase in acute communicable diseases such as HIV/AIDS or Tuberculosis is found to be low.

The local employment strategy and the provision of health facilties on the site will also reduce potential negative effects on the health of local inhabitants and workers.

During construction it is likely that respiratory infections, hearing impairment, work-related accidents, and traffic accidents will increase.



Incidence of Chronic Obstructive Pulmonary Disease (COPD), which is a lung disease mostly seen amongst smokers and people working in dusty environments, is high in the area. The dust emissions during construction may cause disturbance/risks for those people who have COPD. As the project area is far from settlements, no dust emissions will occur during operation and will be controlled during construction, this impact is judged to be minor.

Third party accident occurring (for example a young child falling into an excavation area) is low due to the distance to the settlements. Necessary mitigations will be taken for community safety.

Construction traffic movements (of materials and workforce), in addition to general project traffic vehicles, may result in an increase in traffic levels on the local roads. Kaklik, Yokusbasi and Alikurt are more prone to risks of increased traffic as there are highways passing through these settlements. The EPC contractor will be required to set-up a traffic management plan for on and off-site which includes transport traffic routing, safety measures for junction of site connection road with national road, instruction of workforce and drivers.

Solid waste and wastewater management systems are not sufficient in the area. An increase in the amount of solid wastes and wastewaters due to in-migration might cause odour-related disturbances, as well as vector-borne diseases if not properly managed.

In case mitigation measures are not taken the above listed impacts could be of major significance, but this may reduce depending on the safety measures and availability of emergency health care.

Economic Impacts

As the project area is very close to Denizli, which is the main determinant of local prices, no significant impact is expected on the prices of basic goods (local price inflation). However, in case a significant in-migration occurs, this may cause an increase in house rents which would mainly affect poorer renters. Considering a vast majority of people (87%) are living in their own houses and the temporary character this impact is judged to be moderate.

The in-migration will provide a larger market for local shops and farmers and others to whom to

sell their goods. Many unemployed people and those who are not earning well enough are likely to seek work on the project. Some may turn to trading or even the supply of materials to the construction site (e.g. food, water). This impact is judged to be major and positive.

However, construction-related work opportunities will last only for three years. The reduction in the workforce will result in the out-migration of workers as they leave to seek job opportunities elsewhere. This may normally result in the depression of the local economy, but as there are a few development projects in the pipeline (i.e. Logistic Railway Center in Kaklik, Leather factory close to Kaklik), those are likely to minimize this impact which is judged to be moderate.

Mitigation measures to the social and socio-economic impacts:

Aspects of the design of the project that require further detailing or confirmation in order to mitigate social, health and economic impacts are:

Confirm if construction workers camp will be there or local accommodation will be organized. Locate traffic routes in order to minimize impacts on neighbouring communities;

Confirm the route for transmission lines and necessary permanent and temporary land take; and

Confirm the need for a transformer station (related to the new transmission lines), its possible location and necessary land take.

Measures to mitigate social, health and economic impact that are proposed for implementation during the construction concern:

Construction Management Plan;

Employment and Workforce Policies;

The contractor will be required to adhere to a detailed Construction Management Plan which shall inform local communities of major activities in advance and ensure that impacts on health and safety of the community are minimized.

The EPC contractor shall be required to adhere to employment and workforce policies and codes incl. screening the health of possible employees for communicable diseases and that the workers camp is properly managed. The workers will get instructions on good construction site



management and also regulations for behaviour in the local communities (incl. road safety).

A series of support measures should be provided to local communities, in order to mitigate social, health and economic impacts. RWE & Turcas has a clear commitment to support measures to the local communities and will evaluate the support of implementation of the following activities:

Ensure that the responsible organizations (i.e. Kaklik municipality, Honaz district governorship) have a good understanding of the potential social and environmental impacts in order to be able to cope with them;

As the Kaklik municipality is in charge of enforcing zoning rules and construction licenses, it is particularly important to inform the municipality regarding the potential risk of increase illegal buildings and establishment of shanty settlements;

A local employment and sourcing policy to discourage in-migration, entailing a ban on the employment of casual migrants at the project site;

Inform local communities of employment and procurement opportunities and provide avenues applications of village locals;´

Develop and implement a social impact monitoring plan to assess the efficiency of mitigation plans regularly in order to improve the measures/implementations

The monitoring plan will comprise regular meetings with representatives from the communities in the vicinity to receive their impressions on local impacts of the project during construction and (to a lesser extend) during operation. Appropriate mitigation measures will be developed together with the communities for social and health related problems occurring during construction and operation of the CCPP. A grievance redressing mechanism will be established during the operation phase.

6 Environmental and Social Management Plan

The Project will implement an Environmental and Social Management Plan (ESMP) which includes management and monitoring activities to address relevant issues and mitigate impacts

identified during the impact assessment process. A summary of the ESMP is presented in the Annex to this Non-Technical Summary.

The ESMP outlines the organizational requirements and monitoring plans required to ensure that the necessary measures are taken to avoid potentially adverse effects of the Project on environmental, health and safety (H&S) and social aspects.

Some of these measures have already been specified by RWE & Turcas at the present state of project planning. Since an ESMP continues to evolve in scope and depth with subsequent stages of the project preparation and implementation (e.g. construction, operation, decommissioning), this ESMP provides a first outline.

Overall responsibility for the ESMP lies with RWE & Turcas for all project phases, i.e. project design, construction, operation, and decommissioning.

Responsibility for measures related to the construction phase will be with the selected EPC Contractor. His activities, however, will be supervised by staff of the project owner RWE & Turcas to ensure that adverse effects during the construction phase will be avoided.

Detailed stand-alone sub-plans may be developed to specify ESMP issues in its further progress (e.g. detailed Monitoring Plan, Emergency Response Plan,). In case of responsibility delegation, sub-plans shall be developed by contracted companies according to their area of responsibility in order to show how they implement RWE & Turcas's ESMP requirements.

Annual monitoring reports will be compiled and made available to the relevant authorities and the financial lenders, as requested and appropriate. The reports shall cover the status of EHS related aspects like permits, status of compliance with obligations arising from such licenses or permits, exceedings of regulatory environmental standards with root cause analysis, corrective measures.

7 Public Consultation and Disclosure

RWE & Turcas, in line with Turkish regulations and Guidelines established by international financing institutions is offering information and



consultation opportunities for stakeholders and the public on a voluntary basis including:

A public consultation and disclosure plan;

A project information document containing key facts and figures about the proposed project and outlining the studies which are undertaken to assess the environmental and social impacts, the envisaged timelines and next steps;

Project information brochure briefing information about the project and advertising project website;

Project website containing information about the project and disseminates public consultation plan (www. rweturcasdenizlienerjisantrali.com);

A public information meeting took place on the 17th June 2008 (Scoping meeting) and the project was initially presented to the invited stakeholders (total of 51 organizations), local authorities, government institutions and local media).

Further community meetings were held on the 17th and 18th July 2008, in four settlements. During the meetings, the project was explained to the residents and potential impacts and possible mitigation measures were discussed. The residents were also informed about the continuous communication channels (i.e. project website); imminent social baseline studies and the disclosure activities that are to take place at the completion of the environmental and social assessment works.

Following the community meetings, a social baseline survey was conducted (between 20th July and 4th August 2008). Besides gathering socio-economic data, the household surveys were also used to assess whether the people were informed about the project and to gather information about the main concerns and expectations. The majority (89%) of local people was informed about the project.

In addition interviews and meetings were held with the Governor and Deputy Governors of Denizli Province, Mayors of Honaz and Bozkurt, local health, education and agriculture officers, gendarme, officers at Kaklik health center and

Honaz Hospital. Furthermore focus group meetings were held with different groups including women, poorer residents, farmers, elderly, male and female workers, disabled and ill residents.

A number of comments were received from these consultations. In general, 72% of the local people supported the project for the economic development that it will bring and possible employment opportunities. However, also doubts were expressed regarding temperature increase, acid rains, air pollution, noise and disturbance of birds, health impacts and diminishing of agricultural production.

In order to eliminate peoples concerns regarding potential environmental impacts, a trip was organised to a similar combined cycle gas power plant (1400MW) in Bursa for 51 persons. According to the participants, the trip had greatly relieved their environmental concerns. Most residents were open to discussions while the meetings and changed their views quickly when the facts were explained.

In line with accepted international practice, the Draft Final ESIA report and a summary will be made available to all stakeholders and the public for a period of at least 1 month (30 days). The public will be informed about the possibility to review the ESIA. Comments and suggestions can be submitted to the Project Developer who will organise a public hearing in Kaklik to inform on the outcomes of the ESIA study.

All information will also be made available on the project website: www.rweturcasdenizlienerjisantrali.com

The Project Developer will designate a staff member (e.g. CSE responsible) who will be responsible for grievance response during project preparation, construction and operation (community liaison officer - CLO). Grievances will in general be responded to within 2 weeks after receipt.



NTS Annex: Summary of the Environmental and Social Management Plan (ESMP)

General Notes:

Any plan or procedure/work instruction listed in the following will be based on the contractual environmental, health & safety and social responsibility provisions of RWE & Turcas and requires approval by RWE & Turcas before implementation. Implementation Supervision will be provided by RWE & Turcas. Plans and measures are subject to revision for performance improvement if monitoring reveals weaknesses in implementation. Action item implementation will be benchmarked against key performance indicators. All activities related to construction and operation will be subject to official Turkish environmental and social inspection within the mandate of the relevant authorities.

Action Item

Potential Impact / Issue

Mitigation / Management Responsibility Implementation

Design

D1

Noise emissions of power plant

Selection of equipment, sound absorbing equipment, and noise barriers so that sound pressure levels of 40 dB(A) at Yokusbasi and 43 dB(A) at Kaklik are met. Thus, the IFC criterion that the incremental noise from a plant shall not increase the baseline by more than 3 dB(A) will be met for Kaklik and Yokusbasi.

Selection of equipment so that sound power level on site < 85 dB (A) in a distance of 1 m to the noise source

Selection, arrangement and design of necessary equipment by EPC Contractor.

Implementation of design by EPC Contractor throughout construction

D2

Groundwater abstraction

Design of the CCPP with suggested water saving technologies (ACC, condensate polishing plant etc) to reduce the water needs of the power plant.

In case negative effects on neighbouring groundwater users occur during operation of the power plant, the Developer will seek cooperation with the affected parties with the aim to develop appropriate mitigation measures

Groundwater monitoring to observe the long-term development of the groundwater levels.

RWE & Turcas, EPC Contractor

D3 Routing of Transmission Line for grid connection

Transmission line routing study shall consider environmental constraints; the impacts of the transmission lines for grid connection shall be assessed taking into account the requirements of international standards(biodiversity/avifauna, Right of Way (RoW), property issues/resettlement, EMF etc. to be adequately addressed)

Routing and implementation of transmission line by TEIAS

Accompanying land acquisition plan and EIA and ESIA by TEIAS

The project developer will emphasize the need to address potential impacts according to international standards in nego-tiations with TEIAS and support TEIAS if needed with the implementation



Action Item



D4

Life and Fire Safety

Seismic Risk

Design and construction of power plant to observe relevant legislation and international techniques to withstand seismic risk

Design and construction of CCPP to observe with Turkish and RWE (German/European) Standards on Life and Fire Safety.

Overall responsibility by RWE & Turcas

Design and construction by EPC

D5 Groundwater Quality As conservation of evidence analyze groundwater from the CCPP wells during detailed design stage for anthropogenic substances such as oil and grease.

RWE & Turcas, EPC Contractor

Construction

C1 Environmental & Social Performance of construction activities

Construction Supervision Plan

Appointment of RWE & Turcas supervisor team;

Regular site inspections and meetings of RWE & Turcas with EPC;

Regular review of reports of EPC and supervision of implementation of EPC Contractor’s Management Plans.

Set up by RWE & Turcas before construction;

Implementation RWE & Turcas throughout construction

C2

Environmental, Performance of construction activities / Good Practice

Construction Site Management Plan including sub-plans:

Spill Prevention and Contingency Plan;

Materials Handling and Storage Instructions

Hazardous Material Handling Plan acc. to RWE (German/European) and Turkish standards, Material Safety Data Sheets (MSDS)

Construction Waste Management Plan;

Construction Wastewater Management Plan (incl. collection of sanitary wastewater and HRSG boiling out water, oil/water separators, prevention of stagnant water bodies because of mosquito/malaria prevention)

Construction Site Closure Plan;

Construction Traffic Management Plan (on site and off site)

Designated EPC’s Site Manager and EHS-Responsibles

Setup by EPC prior to construction; implementation by EPC throughout construction under supervision of RWE & Turcas.



Action Item



C3

Construction Health and Safety

Construction Health and Safety Plan, inter alia including provisions for:

workplace risk-assessments, permit to work, personal protective equipment (PPE)

construction workers training and awareness

ground disturbances, lifting operations, working at heights and confined spaces

working under ongoing plant operation / stack emissions

construction traffic safety on- and off-site (transport traffic routing, safety measures for junction of site connection road with national road, instruction of workforce and drivers)

Emergency Response Plan for accidents response

Setup by EPC before construction;

Implementation by EPC throughout construction under supervision of RWE & Turcas.

(in coordination with relevant agencies: fire brigade; hospital and relevant district agencies; HS checks by Turkish Social Security Agency)

Implementation by EPC before start of works under supervision of RWE & Turcas.

C4 Construction workers welfare /workforce social issues / disputes

Social Facilities and Services Plan;

Provision of sanitation, social and medical facilities and services; workers accommodation (in –migrants or third country nationals - TCN) and transport (TCN and local workers);

Provision of facilities and opportunities for workers’ recreation and social after work activities;

Provision of sufficient infrastructure (e.g. health facilities)

In case pressure on educational facilities will occur (should a large numbers of workers bring their families – which is not expected) this will be addressed in a constructive manner between the RWE & Turcas and the Municipality of Kaklik.

Social supervision audits incl. workers interviews;

Workers Grievance Mechanism;

In line with RWE Standards, application of ILO Core Labour Standards by EPC and subcontractors

Workplace Regulation

Workers Code of Conduct

Workers information/training (under consideration of specific socio-cultural aspects of TCN, local Turkish workforce)

Implementation by EPC under supervision of RWE & Turcas. (in addition: official supervision by Turkish Work Inspection)



Action Item



C5

Community relations / Construction related community grievances / Public Health and Safety issues / Local employment and procurement

Community Liaison Plan inter alia including:

Appointment of EPC Community Liaison Officer (EPC-CLO) and E&S supervisor (RWE & Turcas); establishment of local community liaison committees

Public Information and Awareness campaign;

measures for maintaining good relationship;

Public grievance mechanism incl. conflict resolution procedure

Addressing public road safety (construction transport and traffic); vibration, noise and dust; health risks related to presence of large number of construction workforce (e.g. sexually transmittable diseases (STD), and public safety issues (such as: potential risk of social unrest because of presence of TCN)

Dust abatement during construction, e.g. spraying of soil with water

A framework for the recruitment of local workforce and local procurement to be performed wherever possible. Information about work and business opportunities will be made available to the local population (under consideration of RWE & Turcas contractors policy)

Setup by EPC in coordination with RWE & Turcas at start of works; participation of local community administration and representatives if applicable

C6 Construction site access and site security

Site Access and Security Plan;

installation of a system for safe site access; training of guards/security staff

Setup and implementation by EPC + RWE & Turcas before start of works

C7 Archaeological finds during ground works

Chance Finds Procedure,

Awareness training of workforce

Setup: by RWE & Turcas before construction works

Implementation by EPC under supervision of RWE & Turcas.

C8

Impact on habitats Set-up of ecological management plan for construction and end of construction, incl. at least following issues:

Avoid disturbance of birds during nesting period by taking appropriate measures before start of construction if necessary.

Establishment of maquis and steppe habitats areas after finish of construction

Planting trees around the site.

Set-up of ecological management plan by RWE & Turcas.

Implementation by EPC Contractor.



Action Item



Operation

O1

Environmental, Performance of operation/ Good Practice

Operation Management Plan including sub-plans:

Spill Prevention and Contingency Plan;

Materials Handling and Storage Instructions Hazardous Material Handling Plan (incl.

international labelling system, MSDS)

Wastewater Monitoring Plan as described below Emergency Response Plan (for types of emergencies

such as accidents, spills, fire, earthquake et al.) Designated RWE & Turcas Operations Manager and ES&HS-Responsibles

Setup by and implementation by RWE & Turcas.

O2 Discharge of wastewater

Waste Water Monitoring Plan (implemented in operation manual):

Regular monitoring of on-site WWTP effluent.

Set up and implementation by RWE & Turcas (frequency at start up as per manufacturer recommendation; monthly for regular operation)

O3 Noise emissions/impact

Noise Monitoring Plan:

Regular monitoring of off site community noise at dedicated reference locations; day and night time measurements during 1st year of operation

Set up and implementation by RWE & Turcas; Reference measures before start of Project operation

O4

Air emissions Air Emissions Control Plan: Regular (i.e. daily) evaluation of continuous stack emissions monitoring (NOx) against emission standards, optimization of operation in order to reduce the emissions; ensure calibration of monitoring equipment

Procedure set-up and implementation by RWE & Turcas with start of operation

O5 Storage and handling of hazardous materials and Noise Exposure on site

Work Place Risk Assessments & Exposure Monitoring Plan:

Identification of hazardous materials related work places; identification of work places with high noise levels; prevention and mitigation measures; potential exposure; regular monitoring of exposure and employee health check-ups

Procedure set-up and implementation by RWE & Turcas

Prior to start of operation

O6 Community relations Community Liaison Plan inter alia including:

Appointment of E&S supervisor (RWE & Turcas); establishment of local community liaison committees (based on present RWE & Turcas community liaison)

Public Information and Awareness campaign;

Public grievance mechanism incl. conflict resolution procedure

Set-up and implementation by RWE & Turcas before operations


Inquiries:

RWE & Turcas Güney Elektrik A. Ş

Mr. Kürsad Tosun

Eskisehir Yolu

Üstün Dekocity Is Merkezi

No:348/71

Ümitköy - Ankara - Türkiye

[email protected]

denizli ccpp project

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