World Bank Document

E1173

Public Disclosure Authorized AES-3C MARITZA EAST 1 EOOD

MARITZA EAST 1 Public Disclosure Authorized

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Amber Court, William Armstrong Drive Newcastle upon Tyne, NE4 7YQ, UK 44-(0) 191-226-1899 Fax: 44-(0)191-226-2104 AES-3C MARITZA EAST 1 EOOD

MARITZA EAST 1

ENVIRONMENTAL IMPACT ASSESSMENT NON-TECHNICAL SUMMARY

FEBRUARY 2005

...... ------AES-3C MARITZA EAST 1 EOOD

MARITZA EAST 1

ENVIRONMENTAL IMPACT ASSESSMENT NON-TECHNICAL SUMMARY FEBRUARY 2005

Document No. 621604/PBP/OOOOO1 0774R005.DOClS1/2JW PBPower Non-technical Summary Page 3 of 1

Preface

The project company, Consolidated Continental Commerce (Mauritius) Limited (3-C), owned 88 per cent by AES Corporation 8 per cent by Dominion Development Limited, and 4 per cent by Konstatin Dimitrov, is proposing to construct a baseload 670 MW (gross) power plant (AES-3C Maritza East 1), at the site of the existing Maritza East 1 power plant which is located within the municipality of Galabovo, along the northern shore of Rozov Kladenetz Lake. The project is a new power plant constructed on the site of an existing, partially decommissioned power plant. The proposed project site is located in southeast Bulgaria, approximately 40 km south-east of Stara Zagora and 250 km south-east of the capital city of Sofia.

The site for the proposed new 670 MW plant is on property occupied the existing Maritza East 1 power plant and owned by Brikel EAD, and/or Natsionalna Elektricheska Kompania EAD. The larger Maritza East energy complex refers to the general region that includes the centrally located Maritza East lignite mine (the largest lignite open pit mine in Bulgaria) and three independently operated lignite-fired power plant facilities referred to as Maritza East 1 (ME-1), Maritza East 2 (ME-2), and Maritza East 3 (ME-3). The locations of the three thermal power plants operating within the Maritza East energy complex are shown in Figure 1.1. The figure provides more detail of areas near Maritza East 1 and highlights the relationship of the proposed plant site to the host municipality, the closest village, the plant water supply, the area of the mine reserve that will supply the lignite and the general area of ash and gypsum disposal. At their peak, the installed capacities of the three Maritza East plants were 500, 1445 and 840 MW, respectively. Today, the three plants provide over 30 per cent of Bulgaria's electricity supply.

Construction of the proposed 670 MW AES-3C Maritza East 1 power plant is scheduled to begin in January 2006, and last for approximately 3 years. The commissioning/start-up stage is expected to begin in December 2008. Commercial operation of Unit 1 is expected in December 2008 and Unit 2 is expected to be in operation by 1 April 2009. Under present plan, the Project Company proposes to construct, finance, own and operate the 670 MW AES-3C Maritza East 1 plant.

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CONTENTS

Page

1. THE PROJECT

2. THE DEVELOPER 2

3. NEED FOR THE PROJECT AND BENEFITS 2

4. ENVIRONMENTAL ISSUES 4

4.1 General 4 4.2 Topography, geology and seismicity 4 4.3 Ecology 4 4.4 Cultural heritage 5 4.5 Noise 5 4.6 Socio-economics 5 4.7 Water quality 6 4.8 Air quality 6 4.9 Traffic and infrastructure 6 4.10 Conclusions 7

LIST OF FIGURES

FIGURE 1 SITE LOCATION

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1. THE PROJECT

The proposed project is the development of a 670 megawatt (MW gross; 600 MW net) lignite-fired power plant, to be constructed adjacent to the site of the existing Maritza East 1 power plant. The proposed site is 40 kilometres (km) south-east of Stara Zag ora and 250 km south-east of Sofia, Bulgaria.

The new power plant will be a base-load facility that will operate 24 hours per day and 7 days per week. Planned maintenance activities and estimated forced outages will result in an effective annual capacity factor of 95 per cent (ie the plant is expected to operate approximately 8 300 hours each year). At full output, the plant's two identical pulverized lignite-fired steam generator units will generate a combined total of 670 MW of electrical power. Facility power requirements will consume approximately 70 MW and the remaining 600 MW will be sold to the national electrical power distribution grid, owned and operated by Natsionalna Elektricheska Kompania EAS (NEK).

NEK will be responsible for the construction and operation of a new 400 kV primary substation and the construction of transmission lines from the project site.

The water supply for condenser cooling and for fire protection will be withdrawn from Rozov Kladenetz Lake using the existing intake structure and existing cooling water and fire water pump stations. The water supply for cycle make-up water, service water, and potable water will also be derived from water withdrawn from Rozov Kladenetz Lake. Water will be recycled and reused to the greatest extent practicable, resulting in "zero-discharge" of process waste water.

When the plant is operating at full capacity, one 10-car train of lignite will arrive at the power plant's lignite unloading area every 30 minutes, resulting in a total of 48 train trips per day. Existing off-site rail lines will be used to transport lignite to the power plant site. Approximately 1 km of new rail line will be constructed on-site to serve the new railcar unloading area and new combustion waste loading area. The lignite receiving area and storage piles will be built on the existing Maritza East 1 power plant's No 1 ash disposal area, a relatively flat reclaimed and partially revegetated area.

The project will help satisfy future demand for electricity in the country as old, inefficient, unsafe and environmentally substandard electric power-generating facilities, both lignite and hard coal burning and nuclear, are decommissioned. Closure of many of Bulgaria's current power generating facilities is scheduled in the next decade. In December 2002 Units 1 and 2 of Kozloduy nuclear power plant were decommissioned in an agreement between the Bulgarian Government and the EU. The EU also requested decommissioning of Units 3 and 4 at Kozloduy by the end of 2006.

The proposed AES-3-C Maritza East 1 facility will use state-of-the-art technology, with an energy conversion efficiency of approximately 36 per cent. It will have pollution control equipment to meet World Bank, European Union and Bulgarian air and water pollution control standards.

The estimated start date for construction for the new plant is January 2006. The construction work is expected to take place over a 36 month period with an average of 1245 workers per month being required during this time All of the construction jobs are expected to be filled from the local and regional work force. Priority will be given to workers from the Municipality of Galabovo (eg the Town of Galabovo and the ten villages in the Municipality) ..

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2. THE DEVELOPER

AES currently owns or has an interest on 113 power plants totalling over 45 000 MW in 27 countries. AES also distributes electricity to 11 million customers in eight countries through 17 distribution businesses. In addition to having assets in excess of £21 billion, AES has several projects in construction or late stages of development. The company has placed more than £8 billion of financing with commercial banks, export credit agencies, multilateral financial institutions and public markets. AES employs approximately 30 000 people around the world.

AES's partners, Access International and Delphos International, have experience in developing more than 15 private power projects within the last 10 years in Central and South America, Central and Eastern Europe, and Asia. These projects total approximately 1500 MW of electricity generation.

Contact details for the AES project director are:

Matthew Bartley. The AES Corporation 4300 Wilson Boulevard Arlington VA 22203 USA

Telephone +1 7036826311

Fax +17035221315

3. NEED FOR THE PROJECT AND BENEFITS

Not only will the new plant output help Bulgaria meet its overall national objectives for additional power generation, it will also help meet the Government's lignite extraction targets for the Maritza East mines. The use of indigenous lignite will also have a beneficial effect on Bulgaria's foreign trade balance. The price of domestic lignite in Bulgaria is approximately 25 to 50 per cent lower than that of liquid fuels and natural gas, which are obtained primarily through imports. The success of the proposed project may facilitate further deregulation and privatisation of the Bulgarian power sector, paving the way for future independent Power Producer (IPP) projects. However, due to the general low-grade quality of Bulgaria's lignite, achievement of this objective is not possible without using pollution control technologies such as those proposed for this project.

In addition, the project will have other economic and environmental benefits, which are summarized below:

1. Regional development. The project represents the largest foreign direct investment in the history of Bulgaria, thereby mobilizing substantial direct capital from private sources. This large infusion of new capital into the region will improve investor confidence in the domestic and international markets. With total construction costs estimated at approximately €700 million, up to €150 million could be earned by local companies. The project will provide industrial and residential users with an efficient and reliable supply of electricity, which could help

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increase Bulgaria's power exports to neighbouring countries, thereby improving the balance of payments.

2. Improved air quality. Sulphur dioxide air emissions from the proposed plant will be significantly reduced over current emission levels at the existing Maritza East 1 power plant. In particular, the AES project will limit sulphur emissions to 400 mg/Nm3 that will lead to a significant long-term improvement in regional air quality. Improved regional air quality will lead to long-term human health benefits, as well as reduced ecological impacts resulting from acid rain.

3. Local water quality improvement. The proposed facility will have zero discharge of process wastewater. Thus there will be no discharge of wastewater to Rozov Kladenetz Lake or the Sazlijka River. This will reduce thermal and chemical impacts to surface water quality.

4. Employment. At the local level, the project will employ up to 2600 people during the 3 year construction period. During operation, the new power plant will provide direct employment for up to 250 people as well as indirect employment for the lignite mine- and limestone quarry workers, and railway and lorry transport workers.

5. Continuation of lignite mine and limestone quarry operations. The project will help secure the long-term future (perhaps another 40 years) of the lignite mine and limestone quarry. The project will indirectly support the employment of thousands of miners at the Maritza East complex, currently estimated at 12 000 workers in total.

6. Tax revenues. The project will provide increased tax revenues at both the municipal and central levels of Government, amounting to as much as $22 million per year of operation. The Project Company will be registered locally and thus pay relevant taxes to Galabovo Municipality.

7. Related industries. The project's secondary economic effects will result in a possible increase in new business opportunities associated with the plant operations. The need for services and products to support the new facility will create additional business opportunities in Galabovo.

8. Technology transfer. The project will stimulate the transfer of technologies and operating known-how in Bulgaria.

New capacity. The project will provide new electricity capacity to replace the planned decommissioning of Units 3 and 4 (2006/2007) and the already decommissioned Units 1 and 2 (2002) of the 4760 MW Kozloduy nuclear plant. The proposed AES-3C Maritza East 1 power plant will also provide replacement capacity for old coal, or lignite fired plants which are unable, and are not to be retrofitted with FGD to enable them, to comply with the requirements of the Large Combustion Plant Directive.

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4. ENVIRONMENTAL ISSUES

4.1 General

No areas protected under the Bulgarian Law of Protected Areas have been identified in the project region. Rozov Kladenetz Lake is not a Ramsar Convention site, and has not been officially proposed to be listed.

The project is not expected to adversely affect recreational opportunities in the project area nor affect the visual quality of the area. There may be some change in the composition of fish in Rozov Kladenetz Lake as the temperature slowly lowers due to reduction in the heated discharge from the existing Maritza East 1 power plant (should the power output of this plant reduce in future years).

There will be no change in recreational opportunity or attractiveness of the area to outside visitors. Likewise there will be no change in the visual landscape. The proposed project will be integrated into the current plant site. The addition of the cooling tower will be consistent with the stacks that already exist.

4.2 Topography, geology and seismicity

Development of the proposed project will be confined to the AES-3C Maritza East 1 power plant property. This is a brownfield site comprising of land formerly occupied by the now demolished larger units of the old Maritza East 1 plant, with the west of the site including a now reclaimed ash pond. The natural landscape has already been disturbed as the project site was levelled and/or filled prior to construction of the existing Maritza East 1 power plant. As a result, there will be no on site or off site impacts to topography.

The project will not have any direct impacts to regional geological structure. Excavation will be confined to the project site where previous testing has indicated suitable conditions for the foundations that will be required for the proposed buildings.

The project site is within a region identified as 8 to 9 on the MSK-64 earthquake intensity scale. The facility will be built according the standards necessary for development in such a region.

4.3 Ecology

The construction of the new AES-3C Maritza East 1 power plant will largely occur within the boundaries of the existing industrial site and is anticipated to have little to no impact on terrestrial ecology during the construction phase. No significant impacts will occur to the soils and the vegetation outside of the footprint of this previously disturbed area. No rare and endangered species of plants and animals have been identified in the vegetation communities occurring within the proposed construction zone.

Since the new plant will be built within an existing industrial area, any increased noise caused during construction and operation is not expected to have significant impacts on local wildlife.

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4.4 Cultural heritage

As proposed, the project is not expected to impact known and identified archaeological or historic resources. Most of the development will take place on already disturbed lands. Of the two Class 1 sites identified in archaeological investigations undertaken for this project, one is within the existing Maritza East 1 power plant site and already protected by a fence; the second is off site and outside the area of planned construction.

Encroachment into either of the two identified areas would result in additional investigation to further determine archaeological significance. This would be undertaken by the local museum located in Radnevo. Once construction is completed, there is nothing in the on going plant operations that should affect identified cultural resources. The integrity of the protected cultural resource that is on the project site will continue to be maintained so as to insure that routine plant operations do not affect this area.

4.5 Noise

The construction of the power plant will take approximately 36 months. Since construction machines operate intermittently and the types of machines in use at the construction site change with the phase of the project, noise emitted during construction will be highly variable. However since the nearest residential properties are located approximately 1500 m from the project site, it is estimated that construction noise will rarely exceed existing levels. Consequently, construction activities are expected to have minimal and temporary impacts on the noise environment in the communities south and west of the project site.

Once operational the proposed facility will produce noise that will occasionally be perceptible at the nearest residential receptors. The operational levels as estimated for the four measured locations are within both the Bulgarian and World Bank daytime and night-time limit of 70 dBA in industrial areas.

4.6 Socio-economics

The construction of the new plant will not impact employment at the existing Maritza East 1 power plant. The proposed project does not require or mandate the closing of the existing Maritza East 1 power plant or the currently operating briquette manufacturing plant. Throughout the three-year construction period, both plants are expected to continue normal operations.

The most significant socio-economic impact the proposed project will have during the construction period is increased employment in the Galabovo area. This is an important benefit to the local area, as the unemployment rate in the Municipality of Galabovo is estimated at 13.9 per cent.

An average of 1245 workers per month would be required during the construction period. In addition to the direct employment impact during construction, the indirect generation of construction jobs and part-time jobs (ie less than 40 hours a week, or less than a full-time equivalent), would increase the peak construction work force to an estimated 2600 workers.

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4.7 Water quality

Water discharge related impacts associated with the construction of the power plant include sanitary waste water management, storm water management, and management of construction-dewatering groundwater discharges. Implementation of appropriate controls, best management practices, and mitigation will ensure that construction phase water resources impacts will not be significant.

During operation water for use in the power plant will be withdrawn from Rozov Kladenetz Lake using the pump station serving the existing Maritza East 1 power plant. As a zero-discharge facility the waste waters will be recycled and reused within the facility. As a result there will be no discharges of wastewaters to local surface waters, therefore there should be no impacts associated with waste water discharges.

4.8 Air quality

Air quality in the Galabovo area has historically been poor due for the most part to high level of emissions of Sulphur Dioxide, Oxides of Nitrogen and particulate matter from the three existing power plant, Maritza East 1, Maritza East 2 and Maritza East 3. The high level of emissions for these pollutants is a result of the poor quality of the lignite fuel (mined locally) that has a high sulphur content and the lack of sufficient abatement techniques at these plants to deal with such pollutants. The plants at Maritza East 2 and Maritza East 3 are retrofitting abatement technology that will help reduce their impact to air quality though the existing Maritza East 1 is not.

The AES 3-C Maritza East 1 plant meets all emissions criteria as defined by the Bulgarian Government, the EU and all other relevant authorities unlike the plants at Maritza East 2 (smaller units) and the existing Maritza East 1 which will either have to retrofit abatement technology in the next few years or face the prospect of limited hours operation and eventual closure after 2008.

As part of this EIA ground level concentrations of pollutants emitted from the proposed AES-3C Maritza East 1 plant have been modelled and found to be well within the Bulgarian and EU limits. It was found that the proposed plant would have an insignificant effect when compared to the exiting Maritza East plants, indeed should the proposed AES-3C Maritza East 1 plant be built and reduce the load factor at these plant an improvement in air quality would be achieved

4.9 Traffic and infrastructure

During the 36 month period of construction, traffic in the site area will increase due to the delivery of goods and materials and the twice-daily arrival and departure of site construction workers. Estimated employment at the peak of construction will be approximately 2600. Based on current employment patterns and the substantial skill base within the larger Stara Zagora economic area, it is expected that most workers will commute to the job site from within the region. Because of the current level of bus traffic in the area, the addition of buses transporting construction workers, when timed to not coincide with the shift changes at existing plant, will result in an overall increase in area traffic but should not result in a sUbstantial increase in the peak average hourly traffic rate.

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using a combination of public and private rail lines. Some materials deliveries will also be made exclusively by truck. Vehicles used for such transport will be similar in size and weight to the large, international transport trucks that now frequent the roads in the vicinity of the power plant and should not significantly impact on local or regional traffic patterns.

During operation plant employment is expected to total no more than 250. This increase is not expected to impact the three traffic intersections considered most critical to maintenance of local area traffic flow. Most workers will commute to the plant site via bus. Delivery of supplies to the plant area will increase. Increased coal quantities will be brought by private rail. Limestone will also be delivered via private rail lines. Truck transport will increase but area traffic flow should be unaffected. Facility-related truck traffic is expected to represent only a small increase in overall area traffic but not contribute to a decreased level of service.

4.10 Conclusions

The proposed AES-3C Maritza East 1 plant will have a largely beneficial effect both to the natural and human environment. The plant will generate 670 MW of electricity from locally sourced fuel helping to reduce the impact of the decommissioning of units at the Kozloduy nuclear power plant to the Bulgarian grid. During operation plant employment is expected to total up to 250 with a peak of up to 2600 employed in the construction phase representing a Significant investment to both the local and national economy.

As a zero-discharge facility the waste waters will be recycled and reused within the facility. As a result there will be no discharges of wastewaters to local surface waters from plant processes. The proposed plant will have an inSignificant effect on air quality especially when compared to the existing plant in the Galabovo area.

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FIGURE 1 SITE LOCATION

Document No. 621604/PBP/OOOOO1 0774ROO5.dodS5I11w AES-3C MARITZA EAST 1 EOOD

MARITZA EAST 1

ENVIRONMENTAL IMPACT ASSESSMENT FEBRUARY 2005 Our ref: Your ref:

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Yours PB POWER

Document No. 62160AlPBP/OOOOO1 0774ROOOOOClS2I1M1 PBPower List of Revisions Page 1 of 1

LIST OF REVISIONS

Current Date Page Prepared Checked by Checked by Approved Rev. affected by (technical) (quality by assurance)

Final draft Feb 2005 All

R WEAR MOUTH KGRIFFIN MA MITCHELL PT CLARK REVISION DETAILS Final draft Feb 2005 All Final issue as Document No 62160A/PBP/000001

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CONTENTS

Page

LIST OF ABBREVIATIONS

1. INTRODUCTION Section 1 Page

1.1 Project overview 1 1.2 Project sponsor 1 1.3 Contractual arrangements 4 1.4 Project history 5 1.5 Project objectives and benefits 6

1.5.1 Objective No 1 - upgrading electricity generating infrastructure 6 1.5.2 Objective No 2 - achieve greater energy self-reliance 6

1.6 Purpose and need for the proposed project 8

1.6.1 Demand 8 1.6.2 Projected supply versus projected demand 8

1.7 Organization of the EIA 10

2. PROJECT DESCRIPTION Section 2 Page

2.1 Site location and characteristics

2.1.1 Site location 1 2.1.2 Site history 2 2.1.3 Integration of existing and new facilities 4

2.2 Facility description 4

2.2.1 Process description and site layout 4 2.2.2 Lignite supply and processing 7 2.2.3 Fuel oil supply and storage 9 2.2.4 Air emission control systems and associated materials and by-products 11 2.2.5 Water and waste water systems and associated materials and by-products 13 2.2.6 Miscellaneous oil storage 17 2.2.7 Management and disposal of other facility non-hazardous wastes 17 2.2.8 Management and disposal of potential hazardous wastes 17

2.3 Planned construction activities 17

2.3.1 Site clearing. excavation and utilities relocation 18 2.3.2 Rehabilitation of existing facilities 18 2.3.3 Construction of new facilities 18 2.3.4 Construction water supply 19 2.3.5 Construction waste water management 19

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Page

2.3.6 Construction storm water and ground water dewatering discharges 19

2.4 Other local facilities potentially affected by the project 19

3. LEGAL AND ADMINISTRATIVE FRAMEWORK Section 3 Page

3.1 Applicable Bulgarian environmental regulations

3.1.1 Environmental administration 1 3.1.2 Major environmental legislation 2

3.2 World Bank environmental guidelines 4 3.3 European Union 5 3.4 International Environmental Conventions and Agreements 7

3.4.1 Convention on Biological Diversity 8 3.4.2 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) 8 3.4.3 Convention on Wetlands of International Importance Especially as Waterfowl Habitat (the Ramsar Convention) 9 3.4.4 Bern and Bonn Conventions 9 3.4.5 Convention for the Protection of the World Cultural and Natural Heritage ("World Heritage Convention") 9 3.4.6 Framework Convention on Climate Change 10 3.4.7 Kyoto Protocol 10 3.4.8 other 10

4. EXISTING ENVIRONMENT Section 4 Page

4.1 Topography, geology and seismicity

4.1.1 Topography 1 4.1.2 Geology 1 4.1.3 Tectonics and seismicity 2

4.2 Soils 2 4.3 Meteorology and air quality 4

4.3.1 Meteorological and climate characteristics 4 4.3.2 Ambient air quality 8

4.4 Surface water resources 12

4.4.1 Stream flow 13 4.4.2 Water quality 16 4.4.3 Rozov Kladenetz Lake temperature 22

4.5 Ground water resources 25 4.6 Terrestrial ecology 27

4.6.1 Vegetation 29 4.6.2 Fauna 32

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4.7 Aquatic ecology 37

4.7.1 Fish 38

4.8 Protected areas 38

4.8.1 Bulgarian law of protected areas 38 4.8.2 Wetland conservation strategies 39 4.8.3 Co-ordination of information on the environment (CORINE) sites 40 4.8.4 International protection of avian species 40

4.9 Endangered and threatened species 40

4.9.1 Plants and invertebrates 42 4.9.2 Mammals 42 4.9.3 Fish 42 4.9.4 Reptiles and amphibians 42 4.9.5 Avifauna 42 4.9.6 Avian conservation under Bulgarian law 47

4.10 Socio-economics 47

4.10.1 General socio-economic conditions in Bulgaria 49 4.10.2 Regional and local socio-economic conditions 52

4.11 Transportation 59

4.11.1 Regional transportation network 59 4.11.2 Project site access 61

4.12 Noise 62

4.12.1 Site description 62 4.12.2 Existing noise sources 64 4.12.3 Representative monitoring locations 64 4.12.4 Sound monitoring programme 64 4.12.5 Monitored sound levels 65

4.13 Land use 66 4.14 Recreation and visual resources 67 4.15 Archaeological, historical and cultural resources 67

4.15.1 History 67 4.15.2 Cultural resources 68

5. ENVIRONMENTAL IMPACTS Section 5 Page

5.1 Topography, geology and seismicity

5.1.1 Construction phase impacts on topography, geology and seismicity 5.1.2 Operation phase impacts on topography, geology and seismicity 2

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5.2 Soils 2

5.2.1 Construction impacts on soil 2 5.2.2 Operation phase impacts on soil 2

5.3 Air quality 2

5.3.1 Construction phase impacts on ambient air 2 5.3.2 Operation phase impacts on air quality 3

5.4 Atmospheric emissions and their impact 10

5.4.1 Introduction and summary 10 5.4.2 Key findings 12 5.4.3 Existing environment 14

5.5 Ambient air quality 16

5.5.1 Selection of air quality dispersion model 16 5.5.2 Selection of meteorological data 18 5.5.3 Model receptors and terrain 18 5.5.4 Model inputs 18 5.5.5 Land use analysis 19 5.5.6 Emission scenarios for modelling 19 5.5.7 Results from dispersion modelling 20

5.6 Acid deposition and trace element impacts on soil and vegetation 26

5.6.1 Deposition modelling 26 5.6.2 Comparison to guidelines 27 5.6.3 Impacts on vegetation 28 5.6.4 Effects from ambient concentrations of acid precursors 28

5.7 Air quality summary 30

5.7.1 Measured air quality 30

5.8 Water supply and treatment 31

5.8.1 Construction phase impacts associated with water supply and treatment 31 5.8.2 Operation phase impacts associated with water supply and treatment 31 5.8.3 Impacts of water supply withdrawals on regional water budget 32 5.8.4 Raw water treatment 42

5.9 Storm water and waste water management 43

5.9.1 Storm water and waste water impacts during construction phase 43 5.9.2 Storm water and waste water impacts during operation phase 44

5.10 Impacts on groundwater resources 46

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5.11 Impacts on terrestrial ecology 47

5.11.1 Impacts on vegetation and soils 47 5.11.2 Impacts on fauna 48

5.12 Aquatic ecology 50

5.12.1 Construction phase impacts on aquatic ecology 50 5.12.2 Operation phase impacts on aquatic ecology 50

5.13 Socioeconomics 52

5.13.1· Construction phase impacts on socioeconomics 52 5.13.2 Operation phase impacts on socioeconomics 54

5.14 Impacts on transportation 55

5.14.1 Construction phase impacts on transportation 55 5.14.2 Operation phase impacts on transportation 56

5.15 Impacts on noise levels 56

5.15.1 Construction phase impacts on noise levels 56 5.15.2 Operation phase impacts on noise levels 57

5.16 Impacts on land use 61

5.16.1 Construction phase impacts on land use 61 5.16.2 Operation phase impacts on land use 61

5.17 Recreational, protected and visual resources 61

5.17.1 Construction phase impacts 61 5.17.2 Operation phase impacts 62

5.18 Impacts on cultural resources 62

5.18.1 Construction phase impacts on cultural resources 62 5.18.2 Operation phase impacts on cultural resources 63

5.19 Impacts of solid waste production and disposal 63

5.19.1 Construction phase impacts- solid waste production and disposal 63 5.19.2 Operation phase impacts - solid waste generation and disposal 63

5.20 Impacts of hazardous substances 64

5.20.1 Construction phase impacts from hazardous substances 64 5.20.2 Operation phase impacts from hazardous sUbstances 65

5.21 Occupational health and safety hazards 67

5.21.1 Construction phase impacts on occupational health 67

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5.21.2 Operation phase impacts on occupational health 67

5.22 Impacts of ancillary facilities associated with the proposed project 67

6. MITIGATION MEASURES Section 6 Page

6.1 Project design-related mitigation measures

6.1.1 State-of-the-art pollution control technology 6.1.2 Physical plant layout

6.2 Mitigation measures during construction 2

6.2.1 Storm water management and erosion control 3 6.2.2 Excavated material 3 6.2.3 Liquid effluents 3 6.2.4 Air emissions control 4 6.2.5 Noise 4 6.2.6 Chemical/fuel storage 4 6.2.7 Accidental releases 4 6.2.8 Solid wastes 5

6.3 Mitigation measures during power plant operation 5

6.3.1 Storm water management 5 6.3.2 Solid and liquid waste management 5 6.3.3 Spill prevention 6 6.3.4 Accidental spills 6 6.3.5 Lighting 7 6.3.6 Dust control 7

7. ALTERNATIVES Section 7 Page

7.1 Alternative technologies

7.1.1 Record of performance 2 7.1.2 Limestone requirements for S02 control 2 7.1.3 Emission rate limitations 3 7.1.4 Alternative stack design 3 7.1.5 Environmental considerations of the alternative design 3

7.2 other alternatives considered 4 7.3 No action 5

8. ENVIRONMENTAL MANAGEMENT AND MONITORING Section 8 Page

8.1 Environmental management 1 8.2 Environmental monitoring 2 8.3 Employee training 2

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9. PUBLIC CONSULTATION Section 9 Page

9.1 Regulations and requirements 9.2 Previous public consultation and disclosure

9.2.1 Disclosure during initial project development 1 9.2.2 Disclosure during host country environmental review 2

9.3 Stakeholders 4 9.4 Public conSUltation programme 4

9.4.1 IPPC Consultation 4 9.4.2 Open house 4 9.4.3 Operation 5

9.5 Resources and responsibilities 5

A. AIR QUALITY INFORMATION Appendix A

B. FAUNA SPECIES LISTS Appendix B

C. NOISE MONITORING DATA Appendix C

D. PUBLIC CONSULTATION AND DISCLOSURE MATERIALS Appendix D

Document No. 62160AlPBP/OOOOO1 0774ROOO.OOClS4I7M1 PBPower List of Abbreviations Page 1 of2

LIST OF ABBREVIATIONS

degrees OK degrees Kelvin °c degrees Celsius € Euro $ US dollar jJg/m3 micrograms per cubic metre AES-3C the project company BOD biochemical oxygen demand Btu British thermal unit BSS Bulgarian State Standard CFB circulating fluidized bed CFR Code of Federal Regulations CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora CORINE Coordination on Information on the Environment cm centimetre cm3 centimetres cubed CO carbon monoxide COD chemical oxygen demand EBRD European Bank of Reconstruction and Development ECC Energy Conversion Contract EEC European Economic Community EIA Environmental Impact Assessment EMMP Environmental Management and Monitoring Plan EPA Environmental Protection Agency EPC Engineering Procurement and Construction ESP electrostatic preCipitators EU European Union FGD flue gas desulphurization FTE full time equivalent g gram GDP gross domestic product GEP good engineering practise gpd gallons per day gpm gallons per minute GWh gigawatt-hours GW gigawatt ha hectares HDI Human Development Index HFO heavy fuel oil HRSG heat steam recovery boiler IFC International Finance Corporation IMF International Monetary Fund IMG Inter-Ministerial Group IPPC Integrated Pollution Prevention and Control ISC3 Industrial Source Complex kcal/kg kilocalories per kilogram 3 kg/m kilograms per cubic metre kJ/kg kilojoules per kilogram km kilometres 2 km square kilometres kV kilovolts LCP Large Combustion Plant LCPD Large Combustion Plant Directive Leq equivalent noise level

Document No. 62160AlPBP/OOOOO1 On4ROOO.OOClS5I2NV PBPower List of Abbreviations Page 2

LFO light fuel oil LHV lower heat value m metres 2 m square metre 3 m metres cubed ME1 Maritza East 1 Power Plant ME2 Maritza East 2 Power Plant ME3 Maritza East 3 Power Plant MEECC Maritza East 1 Environmental Coordination Committee MEW Ministry of Environment and Waters mg/kg milligrams per kilogram mg/L milligrams per litre mg/Nm3 milligrams per normal metre cubed MME Maritza Mines East EAD MIGA Multilateral Investment Guarantee Agency mm millimetres MOU Memorandum of Understanding MW megawatt NCESD National Centre for Environment and Sustainable Development NEK Natsionalna Elektricheska Kompania NGO Non-governmental Organisation NIMH National Institute of Meteorology and Hydrology NMHC non-methane hydrocarbons NO nitric oxide N02 nitrogen dioxide NOx oxides of nitrogen 0 3 ozone OPIC Overseas Private Investment Corporation PC pulverized coal PCB polychlorinated biphenyls PM particulate matter PM 10 particulate matter with particle size 10 microns or less PPA Power Purchase Agreement ppm parts per million RIEW Regional Environmental Inspectorate of the Ministry of Environment and waters SG State Gazette S02 sulphur dioxide SPEC Species of European Conservation Concern SZREDA Stara Zagora Regional Economic Development Agency TDS total dissolved solids TPP thermal power plant TSP total suspended particulates UNDP United Nations Development Programme USEPA United States Environmental Protection Agency

Document No. 62160AlPBP/OOOOO1 0774ROOO.OOClS5I2NV PBPower Section 1 Page 1 of 10

1. INTRODUCTION

1.1 Project overview

The project company, Consolidated Continental Commerce (Mauritius) Limited (3-C), owned 88 per cent by AES Corporation and 8 per cent by Dominion Development Limited, and 4 per cent by Konstatin Dimitrov, is proposing the construct a base load 670 MW (gross) power plant (the AES-3C Maritza East 1 power plant), adjacent to the site of the existing Maritza East 1 power plant which is located within the municipality of Galabovo, along the northern shore of ROZQV Kladenetz Lake. The project is a new power plant constructed on the site of partially demolished units of the existing Maritza East 1 power plant. The proposed project site is located in south-east Bulgaria, approximately 40 km south-east of Stara Zagora and 250 km south-east of the capital city of Sofia.

The site for the proposed new AES-3C Maritza East 1 power plant is all within the boundaries of the existing Maritza East 1 power plant on land currently owned by either NEK or Brikel EAD. The larger Maritza East energy complex refers to the general region that includes the centrally located Maritza East lignite mine (the largest lignite open pit mine in Bulgaria) and three independently operated (but state owned) lignite-fired power plant facilities referred to as Maritza East 1 (ME-1), Maritza East 2 (ME-2), and Maritza East 3 (ME-3). Only ME-2 is still state owned. The locations of the three thermal power plants operating within the Maritza East energy complex are shown in Figure 1.1. The figure provides more detail of areas near the existing Maritza East 1 power plant and highlights the relationship of the proposed plant site to the host municipality, the closest village, the plant water supply, the area of the mine reserve that will supply the lignite and the general area of ash and gypsum disposal. At their peak, the installed capacities of the three Maritza East plants were 500, 1445 and 840 MW, respectively. The two largest units of the ME-1 power plant are now decommissioned and the plant has a maximum electrical output of 200 MW. Today, the three plants provide over 30 per cent of Bulgaria's electricity supply.

Construction of the proposed AES-3C Maritza East 1 power plant is scheduled to begin in January 2006, and last for approximately 3 years. The commissioning/start-up stage is expected to begin in December 2008. Commercial operation of Unit 1 is expected in December 2008 and Unit 2 is expected to be operation by 1 April 2009. Under present plan, the Project Company proposes to construct, finance, own and operate the 670 MW Maritza East 1 plant. The site area can be seen in Figure 1.2.

1.2 Project sponsor

The project sponsors are The AES Corporation, Dominion Development Limited and Konstantin Dimitriov, acting as a joint venture via a special purpose project company, Consolidated Continental Commerce (Mauritius) Limited (3-C.) Access International, via 3-C was the former developer of the project. Each of Dominion Development Limited (wholly owned by Jacob Menahem), Delphos International and Konstantin Dimitrov had a shareholding or other economic interest in the original development of the project. 3-C remains as the name of the project company and is used in the project's various contracts. In 1999, the AES Corporation acquired an 88 per cent shareholding in 3-C. The original developers retain between them a 12 per cent shareholding in 3-C.

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AES-3C FIGURE 1.1 DD PBPower MARITZA EAST I POWER PLANT GENERAl SITE LOCATION ~.-- <0 Cooyricht PB Power -'B~ J11J avo ! g' '"' '<' ; 0' ~ af Q f 11=lllf IL,., PBPower Section 1 Page 4

The AES Corporation is leading the development of this project, acting through its wholly owned subsidiary AES Horizons Limited based in London, with a development office in Sofia, Bulgaria. The AES Corporation, founded in 1981, is the World's largest private global power company. AES is dedicated to supplying safe, clean, reliable electricity to meet global energy needs. AES generates and distributes electricity and is also a retail marketer of heat and electricity.

AES currently owns or has an interest on 113 power plants totalling over 45 000 megawatts in 27 countries. AES also distributes electricity to 11 million customers in eight countries through 17 distribution businesses. In addition to having assets in excess of £21 billion, AES has several projects in construction or late stages of development. The company has placed more than £8 billion of financing with commercial banks, export credit agencies, multilateral financial institutions and public markets. AES employs approximately 30 000 people around the world.

Contact details for the AES project director are:

Matthew Bartley The AES Corporation 4300 Wilson Boulevard Arlington VA 22203 USA Telephone +1 7036826311

Fax +17035221315

1.3 Contractual arrangements

The Project Company has a Power Purchase Agreement (PPA) with Natsionaina Elektricheska Kompania EAD (NEK). the state-owned utility. Electricity generated by the plant will be sold to NEK under this PPA for subsequent distribution. NEK, pursuant to Bulgarian electricity market liberalization legislation has sold, or is in the process of selling, most of its generation capacity and will become the transmission system owner and operator and an electricity trading company only. The seven Bulgarian distribution companies were privatized in 2004.

New disposal facilities for the ash and gypsum will be constructed and operated in accordance with European Union, World Bank and Bulgarian environmental regulations.

Impact assessments of the coal mine, limestone source, ashlwaste disposal area and electric transmission facilities are outside the scope of this EIA document. However, because these facilities are essential to plant operation, general information regarding the location, technical details of development, anticipated supporting infrastructure and employment are described in this document.

NEK will develop or be responsible for the following project-related support or ancillary facilities:

• construction and operation of a new 400 kV substation;

Document No. 621604/PBP/OOOOO1 0774R010.DOClS1I8NJ PBPower Section 1 Page 5

• a new high voltage transmission line including all interconnection facilities and the point of interconnection. The new transmission line will extend from the new substation in a south-west direction, traverse Rozov Kladenetz Lake, and connect to an existing substation located approximately 6.5 km south-west of the site;

• the operation and maintenance of the existing Rozov Kladenetz Lake intake structure, and the existing Sazlijka River pumping station, and;

• all necessary rights of way for construction, operation and maintenance of the new AES-3C Maritza East 1 power plant. These include rights-of-way for land for transmission lines and land for discharge of stormwater (a strip of land from the new plant to a point near the junction of the Sazlijka River and the Sokolitsa River).

1.4 Project history

The major milestones in the development of the proposed project to date are the following:

1. In August 1998, following a competitive bid process, NEK awarded 3-C a contract to construct a new power generation facility of not less than 600 MW within the Maritza East 1 complex.

2. An Energy Conversion Contract (ECC) was signed by 3-C and NEK on 16 October 1998, whereby NEK will purchase electricity produced by the project from the 670 MW ME-1 plant for a period of 15 years.

3. In April 1999, the proposed project was given "priority investment status" by the Bulgarian Council of Ministers and AES was invited by 3-C to act as co-developer and sponsor for the project.

4. AES and 3-C signed a joint venture agreement in September 1999.

5. An EIA, prepared in accordance with Bulgarian requirements, was submitted to the Ministry of Environment and Water on 16 December 1999. The Bulgarian EIA was used as a reference for developing this EIA.

6. An amended Energy Conversion Contract (ECC) was Signed by the Project Company and NEK on 15 February 2000. This amended ECC included an associated Memorandum of Understanding (MOU).

7. A public information session for the project was held between 9.30 am - 1.00 pm on 16 February 2000 at the House of Culture in Galabovo, Bulgaria. The public information session was followed by a public hearing from 1.30 pm - 4.30 pm at the same location.

8. The current PPA was signed on 13 June 2001 to replace the ECC.

9. The Lignite Supply Agreement with Minii Maritza was Signed on 13 June 2001.

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10. An EPC Contract for construction of the plant was signed with Alstom on 24 April 2002.

11. An amendment agreement to the PPA was signed on 20 September 2002.

12. An IPPC permit application was made on 31 March 2004.

1.5 Project objectives and benefits

There are two main objectives of the proposed 670 MW Maritza East 1 power plant project:(1) to aid Bulgaria in upgrading its aged, inefficient, unsafe and polluting electricity generating infrastructure (including nuclear facilities) by substituting state-of-the art technology as outdated facilities come offline, and (2) to support Bulgaria in its efforts to achieve greater self-reliance by using its only locally available fuel source, lignite, to generate electrical power.

1.5.1 Objective No 1 - upgrading electricity generating infrastructure

The project will help satisfy future demand for electricity in the country as old, inefficient, unsafe and environmentally substandard electric power-generating facilities, both lignite and hard coal burning and nuclear, are decommissioned. Closure of many of Bulgaria's current power generating facilities is scheduled in the next decade. In December 2002 units 1 and 2 of Kozloduy nuclear power plant were decommissioned in an agreement between the Bulgarian Government and the EU. The EU also requested decommissioning of units 3 and 4 at Kozloduy by the end of 2006.

The proposed AES-3C Maritza East 1 power plant will use state-of-the-art technology, with an efficiency of approximately 36 per cent. It will have pollution control equipment to meet World Bank, European Union and Bulgarian air and water pollution control standards.

1.5.2 Objective No 2 - achieve greater energy self-reliance

Not only will the new plant output help Bulgaria meet its overall national objectives for additional power generation, it will also help meet the Government's lignite extraction targets for the Maritza East mines. The use of indigenous lignite will also have a beneficial effect on Bulgaria's foreign trade balance. The price of domestic lignite in Bulgaria is approximately 25 to 50 per cent lower than that of liquid fuels and natural gas which are obtained primarily through imports. The success of the proposed project may facilitate further deregulation and privatization of the Bulgarian power sector, paving the way for future independent Power Producer (IPP) projects. However, due to the general low-grade quality of Bulgaria's lignite, achievement of this objective is not possible without using pollution control technologies such as those proposed for this project.

In addition, the project will have other economic and environmental benefits, which are summarized below:

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PBPower Section 1 Page 7

local companies. The project will provide industrial and residential users with an efficient and reliable supply of electricity, which could help increase Bulgaria's power exports to neighbouring countries, thereby improving the balance of payments.

2. Improved air quality. Sulphur dioxide air emissions from the proposed plant will be significantly reduced over current emission levels at the existing Maritza East 1 power plant. In particular, the AES-3C project will limit sulphur emissions to 400 mg/Nm3 that will lead to a significant long-term improvement in regional air quality. Improved regional air quality will lead to long-term human health benefits, as well as reduced ecological impacts resulting from acid rain.

4. Employment. At the local level, the project will employ up to 2600 people during the 3 year construction period. During operation, the new power plant will provide direct employment for up to 250 people as well as indirect employment for the lignite mine and limestone quarry workers, and railway and lorry transport workers.

8. Technology transfer. The project will stimulate the transfer of technologies and operating known-how in Bulgaria.

9. New capacity. The project will provide new electricity capacity to replace the planned decommissioning of units 3 and 4 (2006/2007) and the already decommissioned units 1 and 2 (2002) of the 4760 MW Kozloduy nuclear plant. The proposed AES-3C Maritza East 1 power plant will also provide replacement capacity for old coal, or lignite fired plants which are unable, and are not to be retrofitted with FGD to enable them, to comply with the requirements of the Large Combustion Plant Directive.

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1.6 Purpose and need for the proposed project

A study of the Bulgarian Energy Market was prepared on behalf of the Project Company by the consulting company Nera. The study concluded that new capacity is needed to meet demand and maintain an acceptable level of electricity capacity supply reliability and that a new plant at Maritza East 1 is the least cost new capacity for Bulgaria.

1.6.1 Demand

Based on projected growth in electricity demand in Bulgaria there will be demand for the additional power to be supplied by the development of the proposed AES-3C Maritza East 1 power plant The growth in electricity demand is projected both as a result of Bulgaria's export commitments as well as the resumption of economic growth. New capacity is required both as a result of the closure of outdated nuclear units, and the closure of units unable to meet the requirements of the Large Combustion Plant Directive (LCPD).

Two scenarios of future demand were presented in the National Energy Strategy. The first scenario is the "Maximum Demand" scenario, which assumes a relatively high Gross Domestic Produce (GOP) growth rate. The second scenario is the "Minimum Demand" scenario which assumes a relatively low GOP growth rate. Combining these maximum and minimum growth rates in domestic product with assumptions about energy effiCiency, the Bulgarian estimates of total demand growth per year are 1.5 per cent in the minimum scenario and 2.8 per cent in the maximum demand scenario. As a base cast, the AES sponsored Market Study used the conservative growth rate of 1.5 per cent per year. The resulting estimates in future demand shown in Table 1.1 assume a conservative 1.5 per cent annual growth rate for the period 2004-2010. GWh indicates the number of gigawatts (GW) produced per year and forecasts are well within the estimates provided in the National Energy Strategy.

1.6.2 Projected supply versus projected demand

As noted previously, in the period from 2004 to 2010 there are projected to be a number of plant closures. Overall capacity will decline because of these closures as well as the effect of the continuing deterioration of existing units. Balanced against this is a desired and projected increase in demand as Bulgaria continues its economic recovery, Table 1.2 shows the projections in supply and demand for period from 2000 to 2006.

Document No. 621604/PBP/OOOOO1 0774R010.DOc/S1I8M' TABLE 1.1 ELECTRICITY CONSUMPTION FORECAST (GWH)

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

36887 39436 38132 38070 38003 37926 37834 37734 37620 31011 30895 30548 30737 30938 31145 31359 31558 31737 31916 32034 32125 Sent Out Generation (GWh)

7293 7540 7388 7376 7363 7348 7330 7311 7289 6008 5986 5919 5955 5994 6034 6076 6114 6149 6184 6207 6224 Maximum Sent out Demand (MW)

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TABLE 1.2 COMPARISON OF PROJECTED THERMAL AND HYDRO ELECTRICITY SUPPLY AND DEMAND IN BULGARIA

Year Total available thermal and hydro System peak demand - sent out capacity - sent out (MW) (MW)

2005 10063 6383

2006 9873 6452

2007 8775 6497

~ 2008 8454 6517

2009 8044 6518

2010 7644 6482

2011 7712 6591

2012 7775 6699

1.7 Organization of the EIA

This document is a revision of the EIA produced by ENSR in June 2000 including up to date information wherever possible and is independent of the EIA that was prepared for the Bulgarian Government. This EIA, following guidelines used by international lenders (the Equator Principles) is organized as follows. Section 2 provides the project description, which includes a description of the site location, the existing Maritza East 1 power plant facility, and the proposed AES-3C Maritza East 1 power plant. The policy, legal and administrative framework for the project is described in Section 3. Section 4 provides descriptions of the existing environmental and socio-economic conditions in areas directly and indirectly affected by the proposed power plant. Section 5 presents the discussion of potential environmental impacts resulting from the proposed AES-3C Maritza East 1 power plant. Mitigation measures to minimize potential environmental impacts resulting from the proposed AES-3C Maritza East 1 power plant are presented in Section 6. Section 7 provides an analysis of the alternatives to the proposed AES-3C Maritza East 1 power plant. The project environmental management and monitoring plan is included in Section 8. Section 9 presents the public consultation programme for the project.

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2. PROJECT DESCRIPTION

The proposed project is the development of a 670 megawatt (MW gross; 600 MW net) lignite-fired power plant, (the" AES-3C Maritza East 1 power plant") to be constructed adjacent to the site of the existing Maritza East 1 power plant. The proposed site is 40 kilometres (km) south-east of Stara Zag ora and 250 km south-east of Sofia, Bulgaria. The power plant is being developed by AES-3C Maritza East 1 EOOD (the "Project Company"), a 100 per cent owned subsidiary of Consolidated Continental Commerce (Mauritius) Limited.

The AES-3C Maritza East 1 power plant will be a base-load facility that will operate 24 hours per day and 7 days per week. Planned maintenance activities and estimated forced outages will result in an effective annual capacity factor of 95 per cent (ie the plant is expected to operate approximately 8300hours each year). At full output, the plant's two identical pulverized lignite-fired steam generator units will generate a combined total of 670 MW of electrical power. Facility power reqUirements will consume approximately 70 MW and the remaining 600 MW will be sold to the national electrical power distribution grid, owned and operated by Natsionalna Elektricheska Kompania EAS (NEK).

2.1 Site location and characteristics

The existing Maritza East 1 power plant is one of three lignite-fired power plants located along the perimeter of Maritza East lignite mines (the largest lignite open pit mines in Bulgaria). All three power plant facilities (Maritza East 1 (ME-1), Maritza East 2 (ME-2), and Maritza East 3 (ME-3) are fired using lignite from the Maritza East mines. The existing Maritza East 1 plant was merged with the adjacent briquette manufacturing facility to form a new company, Brikel EAD.

2.1.1 Site location

The lignite mines and adjacent power plants are located within the Sazlika River valley area of the low-lying Upper Thracian Plain. This south-east portion of the Upper Thracian Plain is bounded to the north by the Sredna Gora Mountains (600 to 900 m elevation; a component of the Balkan Mountains), to the south by the Sakar Mountains (400 to 600 m elevation; a component of the Rodopi Mountains) and to the east by lesser elevation (150 to 200 m) upland areas. The Sredna Gora Mountains, Sakar Mountains, and eastern upland areas are approximately 50 km north, 60 km south, and 15 km east of the Maritza East 1 power plant site, respectively.

The Maritza East 1 power plant is the further west of the three Maritza East power plant facilities (see Figure 1.1). The existing Maritza East 1 power plant is within the municipality of Galabovo, approximately 1.6 km east of the town of Galabovo. The closest residential community is the village of Obruchishte, located approximately 0.8 km south-east of the site. The power plant property is relatively flat, with an approximate elevation of 107 m above sea level.

Figure 2.1 shows the boundaries of the AES-3C Maritza East 1 power plant which will be purchased from NEK and Brikel EAD by the Project Company The power block and principal facilities of the existing power plant are located to the north of Rozov Kladentz Lake, the man-made cooling water reservoir for the facility. Ash ponds for the existing facility extend for several kilometres to the west of the main power plant area. Ash Pond 1 and Ash Pond 2 have been closed, reclaimed, and revegetated. Ash Pond 3 (shown in the north-west corner of Figure 2.1) is currently used by the

Document No. 62160AlPBP/OOOOO1 0774r020.doclS 1/201w PBPower Section 2 Page 2

existing ME1 facility. The Sazlijka River (a north to south flowing tributary of the Maritza River) serves as the western boundary of the ash ponds.

The Maritza East 1 power plant property is bordered directly to the east and the south by independently operated industrial facilities. Across the road from the power plant to the east is the lignite briquette manufacturing facility of Brikel EAD that produces briquettes for use in heating of local homes and, from time to time, for use in electrical power generation at the existing Maritza East 1 power plant. Across the road from the power plant to the south is Energoremont parts repair facility, which restores, repairs, and replaces parts and equipment used at the existing Maritza East 1, Maritza East 2, and Maritza East 3 power generating facilities.

2.1.2 Site history

The existing Maritza East 1 power complex was constructed and began operation in the early 1960s. Between 1959 and 1962 the first 200 MW power generating facility was constructed. This facility consisted of a lignite drying plant, six boilers, four 50 MW steam turbine generators and associated steam extraction equipment. In addition to generating electrical power, the 200 MW facility provided steam for district heating (for the town of Galabovo) and steam used for the lignite drying process at the adjacent briquette manufacturing facility. Between 1962 and 1964, an additional 300 MWof generating capacity was added, consisting of four boilers and two 150 MW steam turbine generators.

The existing 200 MW power plant/steam heating plant (Boilers 1 through 6 and Turbines 1 through 4) continues to operate, providing both electrical power and steam for district heating and for the briquette manufacturing facility. With the closing of the lignite drying plant, the mix of lignite supplied to this power plant has been modified to improve combustion efficiency. High moisture content raw lignite from the mines is now mixed with high calorific value (high sulphur content) lignite briquettes from the briquette manufacturing facility, improving burning efficiency but adversely affecting sulphur dioxide air emissions.

The plant's hazardous materials are stored in several indoor and outdoor locations, typically in close proximity to the locations where they are being used. The primary hazardous material storage area is adjacent to the eXisting heavy fuel oil storage tanks. This area is used to store drums of fresh (unused) oil and hazardous material. Adjacent to the drum storage area is a tank farm, with nine aboveground storage tanks. The tanks are used to store fresh and used turbine oil. The plant's waste oils are collected in drums and tanks and taken by the plant's oil supplier for recycling.

The plant operates a vehicle fuelling station and an equipment fuelling station. The vehicle fuelling station is located adjacent to the oil storage area and contains two underground storage tanks (ie one 3 for gasoline and one for diesel fuel). Each of the tanks has a capacity of 290 m . The tanks were installed in 1994. The equipment fuelling station is located near the eXisting plant's lignite pile. This station, which contains aboveground diesel fuel storage tanks and a pump dispenser, is used to fuel the heavy lignite handling equipment used in the yard.

The existing Maritza East 1 thermal power plant does not maintain records regarding spills/releases of oil or hazardous materials. Facility management indicate that there have been oil spills at the site as well as several incidents involving the plant's transformers.

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2.1.3 Integration of existing and new facilities

Figure 2.2 shows a site arrangement plan for the proposed AES-3C 670 MW Maritza East 1 power plant while Figure 2.3 presents a three-dimensional rendering showing the existing and new power facilities. The main power block for the new plant will be constructed to the north of the existing power plant facilities.

Although much of the future plant area has been cleared, several aboveground and underground structures remain. Aboveground facilities, including the partially demolished lignite drying plant, a centrally located contractor's building, outdoor parts and equipment storage areas, a pipe insulation storage warehouse, a former concrete batch plant, and a former ash pellet plant, are all to be removed to ground level by NEK prior to transfer of the property to the Project Company. Associated foundations and underground utilities will be left in place to be removed as part of the planned power plant construction. Existing rail lines that will serve the planned power plant will be left in place. Existing aboveground ash slurry pipes and an underground industrial sewer line (running from the briquette factory to an existing sewer pump station) are to be relocated by NEK prior to the initiation of new power plant construction.

Other facilities that will be used to support the new power plant include the rail lines to and from the lignite mining area and the overburden disposal area, the Rozov Kladenetz Lake circulating water and fire water intake structure and pump stations, the Sazlijka River pump station, and the existing lignite unloading area, Bunker C (currently used for lignite unloading; planned to be used for limestone unloading).

2.2 Facility description

2.2.1 Process description and site layout

The AES-3C Maritza East 1 power plant will generate 670 MW (gross) of electricity, of which 600 MW (net) will be provided to the local power grid. Power will be generated by means of two pulverized lignite-fired boiler units coupled with two 335 MW steam turbine generators. Electrical power will be provided to the Bulgarian national electrical power company (NEK) for distribution to the national grid. NEK will be responsible for the construction and operation of a new 400 kV primary substation and the construction of transmission lines from the project site.

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FIGURE 2.3 THREE-DIMENSIONAL RENDERING OF EXISTING MARITZA EAST 1 AND PROPOSED AES-3C MARITZA EAST 1 POWER PLANTS

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Pulverized lignite will be burned within two steam generator tower boilers, each equipped with a series of beater mills and low NOx burners. Steam will be routed to two 335 MW turbine generator units that will be used within a newly constructed steam turbine building. Exhaust steam will be condensed by means of a cooling tower with the condensate return water routed back to the boilers. After passing through air heater units, exhaust flue gases will be routed through electrostatic precipitators to capture fine dust and through wet limestone flue gas desulphurization (FGD) absorbers to reduce sulphur dioxide emissions. The exhaust flue from each of the two FGD absorbers will discharge into the cooling tower above the cooling water discharge system.

Lignite for the plant will be supplied from the Maritza East lignite mines (mainly from Troyanovo North mine, but also from Troyanovo 1 and Troyanovo 3) located 7 km north of the power plant site. The transportation of lignite from the mines to the power plant site will be by rail car and will be the responsibility of the mining company, Mini Maritza Iztok (MMI). Lignite will be unloaded at the newly constructed lignite train unloading area. Limestone for the FGD system will also be supplied by railcar, with the most likely source being the existing Chala limestone quarry, located approximately 60km south-west of the project site. Limestone will be unloaded at the limestone train unloading area.

The power plant will use heavy fuel oil (HFO) for start-up and low load flame stabilization of the steam generators and will use diesel light fuel oil (DFO) to fire the auxiliary boiler. HFO will be transported to the site by rail (as is currently the practice) and transferred to storage tanks. DFO will be transported to the site by truck. New DFO storage and truck unloading facilities will be constructed as a component of the planned project.

Water will be recycled and reused to the greatest extent practicable, resulting in "zero-discharge" of process waste water. Boiler blow down, treated sanitary effluent, plant drains, and lignite pile runoff will be routed to the cooling tower for use as tower make-up water, reducing water withdrawals from the lake. Cooling tower blow down will serve as the water supply for the flue gas desulphurization system and will be used for ash quenching.

2.2.2 Lignite supply and processing

2.2.2.1 Lignite delivery and storage

Lignite for the power plant will be provided mainly from the Troyanovo North mine, located approximately 7 km north of the power plant site. At full load, lignite consumption at the proposed plant is estimated to be approximately 9 million metric tonnes per year or approximately 25 000 tonnes per day. A representative, design-based fuel analysis for the lignite to be used at the facility (and for the ash likely generated) is presented in Table 2.1.

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TABLE 2.1 DESIGN LIGNITE AND ASH QUALITY - MARITZA EAST 1 POWER PLANT

Item Guaranteed A max Wmax Qmax Ash (air-dried basis) % 35.00 45.00 33.00 30.00 Moisture (as received) % 55.00 49.00 57.00 55.00 Ash (as received) % 15.98 22.95 14.09 13.50 Carbon (as received) % 18.23 18.85 18.22 20.17 Hydrogen (as received) % 1.54 1.42 1.54 1.70 Oxygen (as received) % 5.46 5.05 5.47 6.02 Nitrogen (as received) % 0.32 9.30 0.32 0.35 Combustible sulphur (as received) % 2.70 3.20 2.90 2.40 Volatiles from mineral (as received) % 1.51 2.19 1.35 1.28 substances Calorific value kcallkg 1,410 1,315 1,400 1,590 (LHV) kJ/kg 5,910 5,510 5,860 6,600 Volatiles • % 60-64 Hydroscopic moisture % 11 Milling efficiency per K 0.83-1.22 per guaranteed coal k = 1.1 Si02 % 35-50

AIz0 3 % 16 -32

Fe20 3 % 7-20 MgO % 1.5-3.5 CaO % 2.5 -5.0

S03 % 2.5 -15 Ash fusion temperature A. In oxidizing environment (by Letis) for analysis 1, 2, 3 Deformation point °C 1,250 1,210 -1,300 Melting point °C 1,280 1,260 - 1,300 Running point °C 1,300 1,280 -1,300 B. In semi-reducing environment (by Bunte-Baum) for analysis 4 Deformation point °C 1,050 -1,150 Melting point °C 1,150 -1,300 Running point °C 1200-1,400 Density grams/cm 3 1.5 -1.9 3 Bulk weight kg/m 700-1,000

Lignite will be transported from the mine to the power plant site in 1 O-car trains, each car with an approximately capacity of 55 tonnes, resulting in a total maximum capacity of 550 tonnes of lignite per train. The lignite rail cars will be top-loading, bottom-dumping wagon type rail cars, similar to those currently in use at the mines and power plant. When the plant is operating at full capacity, one 10-car train of lignite will arrive at the power plant's lignite unloading area every 30 minutes, resulting in a total of 48 train trips per day. Existing off-site rail lines will be used to transport lignite to the power plant site. Approximately 1 km of new rail line will be constructed on-site to serve the new railcar unloading area and new combustion waste loading area. The lignite receiving area and storage piles

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will be built on the existing Maritza East 1 power plant's former No 1 ash disposal area, a relatively flat reclaimed and revegetated area.

Lignite will be unloaded at a two-track railcar unloading area, similar to the unloading area currently in use at the Maritza East 2 power plant. Lignite will fall by gravity from the bottom dumping lignite trains and will accumulate on the ground beneath the rail platform. The lignite unloading area will be capable of unloading 10 rail cars at each track. Wheeled reclaimers will move the lignite from the unloading area onto conveyors that will transfer the lignite to a coarse crusher crushing lignite from lumps in the range of 300 to 800 mm in diameter down to smaller lumps that are generally less than 200 mm in diameter. Crushed lignite will be placed on covered belt conveyors and transported to stacking equipment that will form four trapezoidal lignite piles. Each lignite pile will be built on an impermeable base and surrounded by a structure that will collect storm water runoff and route it to the lignite pile runoff pond. A 14-day supply of lignite will be maintained in the lignite storage area throughout the year. The maximum height of an individual lignite pile is expected not to exceed 25 m.

2.2.2.2 Lignite preparation and combustion

Two reclaiming units (each serving two lignite piles) will lift lignite from the lignite piles onto the covered belt conveyors that will transfer the lignite to the fine crusher units. The fine crushers will consist of running hammer crushers that will be capable of further reducing the lignite lump size to around 15 to 40 mm in diameter so that it will be suitable for subsequent milling in the beater mills (pulverizers). After fine crushing, the lignite will be deposited in the boiler bunkers located in the main steam generator building.

Conveyors will be used to transport lignite from the bunkers to the pulverizers (beater mills), located at the base of each tower boiler unit. Each tower boiler will be equipped with six beater mills. The beater mills will serve both as lignite dryers and pulverizers, making the lignite suitable for burning in a combustion system. At peak operation, pulverized lignite will be fed to the boilers at an approximate rate of 505 tonnes per hour per unit.

2.2.3 Fuel oil supply and storage

The power plant will use heavy fuel oil (HFO) for start-up and low load flame stabilization of the steam generators and will use diesel light fuel oil (OLO) to fire the auxiliary boiler and the emergency diesel generator. Table 2.2 presents a typical specification of the HFO and OFO that will be used.

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TABLE 2.2 TYPICAL FUEL OIL SPECIFICATION

Characteristics ASTM Heavy fuel oil Diesel fuel oil (HFO) (DFO) Calorific value (LHV, MJ/kg) (minimum) 39.8 Ultimate analysis by weight (%) Carbon - - - Hydrogen - - - Nitrogen - - - Sulphur (maximum) 0129 3.5 0.3 Ash (maximum) 0482 0.14 0.02 Oxygen - - - Gravity 3 Density at 20°C (grams/cm ) - 1.015 Pour point (OC) 097 - - Flash point (OC) 093 110 50 Freezing temperature (OC) (maximum) - 25 - Viscosity

Kinematic viscosity at 80°C 115 - (centistokes) Kinematic viscosity at 20°C - 2.5- 8.0 (centistokes) Water and sediment (vol. %) Water by distillation (vol. %) 095 - - Water by extraction (wt. %) 0473 - - Water soluble acids and alkalis - Negligible Ash constituents Vanadium (mg/kg) 01548 127 - 230 - Sodium (mg/kg) 01318 70-90 Zinc (wt. %) - Not controlled - Potassium - - - Calcium - - - Lead (OFO only) - - - Carbon residue (wt. %, Conradson) 0189 11 to 17 0.2 Asphaltene (mg/kg) - 8 to 233 - Note: Values presented in this table represent typical values for oils based on Bulgarian standards. Actual received quality of oil may vary.

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Approximately 510 tonnes of HFO will be consumed each year. Significantly less DFO will be 3 required. HFO will be stored in two 2000 m capacity bunded storage tanks. DFO will be stored in several new, lesser capacity DFO storage tanks. HFO will be transported to the site in rail-road tank cars and DFO will be transported to the site by truck.

The HFO unloading area will be capable of simultaneously unloading up to as many as 4-tank cars. For unloading purposes, the viscous HFO is heated to 60°C. Flexible hoses are connected to the tank cars and the heated oil is pumped (by suction pumps) into the fuel oil storage tanks. Prior to use in the power plant, heavy fuel is filtered, heated to 70°C, and pumped to the combustion units. Steam from the existing power facility is currently used to heat the HFO and a similar configuration will be established for the new power plant. Condensate from the HFO/steam heat exchanger will be routed to an oil/water separator prior to subsequent reuse. Storm water collected in the bunded fuel oil storage area will also be routed through an oil/water separator prior to being routed for reuse.

2.2.4 Air emission control systems and associated materials and by-products

Induced draught fans will draw flue gas exhaust from each boiler unit through an air heater (heat exchanger) and into a set of electrostatic precipitators (ESPs). The ESPs will be designed to capture fly ash and dust particles present in the exhaust gas, ensuring compliance with the World Bank, EU and Bulgarian particulate matter guidelines. From the ESPs, the flue gas will be directed into a wet limestone flue gas desulphurization (FGD) system, which will absorb sufficient sulphur dioxide (S02) to ensure compliance with the World Bank, EU and Bulgarian S02 emission guides. The desulphurized air emissions from each of the 335 MW units will be released using individual flues (one flue per unit) housed within the cooling tower. Each flue will be equipped with continuous emissions monitoring for S02, NOx and particulates.

2.2.4.1 Limestone supply and processing

The wet limestone flue gas desulphurization (FGD) system will require a steady supply of limestone. Limestone for the FGD system will be provided. The most probable source of limestone will be the existing Chala limestone quarry, located approximately 60 km south-west of the project site. Other sources include the existing Ogniznovo and Volvkan quarries. A representative limestone analysis is provided in Table 2.3. At full operational load, approximately 760 000 tonnes per year of limestone will be required for use in the FGD system.

Limestone will be transported to the site using top-loaded, bottom-dumping rail cars, similar to those to be used for lignite transportation. Also similar to lignite delivery, limestone will be shipped from the quarry to the power plant using 1O-car trains, each car with 55-tonne capacity. Each day, three 10-car trains of limestone will be transported to the power plant site. Existing rail lines running north from the Chala quarry will be used to the extent possible, as will existing on-site rail lines currently used in conjunction with lignite loading and unloading; No new rail lines are anticipated for the limestone delivery system.

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TABLE 2.3 TYPICAL LIMESTONE ANALYSIS

Range Limestone characteristic Typical Maximum Minimum Percent by weight Calcium carbonate (dry basis) 93.2 - - Magnesium carbonate (dry basis) 3.5 - - Silica and other inerts (dry basis) 3.3 Moisture - - - Hardness as kvs work index - - - Grindability (20.8 - 1.36 x work index) - - - Particle size distribution - - - Density (g/cm3) 2.7 - - Note: Values presented in this table represent typical values for local limestone. Actual received quality of limestone may vary

Each limestone train will be emptied at the rail unloading area and stored in the underlying limestone bunkers. From the bunkers, limestone will be reclaimed, placed on a covered limestone conveyor, routed through limestone hammer crushers and stored in a covered storage area that will be sized to hold a one-week supply of limestone. After crushing, the limestone will be conveyed from the storage area to wet mill grinding units and subsequently mixed with water, to form a slurry, and stored in a limestone slurry storage tank. From this tank, the limestone slurry will be pumped into the FGD wet scrubbers.

2.2.4.2 Gypsum storage and disposal

The flue gas desulphurization system will consist of a wet limestone scrubbing process. In this process, within the FGD absorber, limestone slurry is sprayed downward, counter-current to the upward moving flue gas flow. The limestone slurry reacts with sulphur dioxide in the flue gas and, with subsequent aeration, produces a wet gypsum slurry by-product at the base of the absorber. The gypsum blowdown will be routed to the limestone preparation and gypsum dewatering building, where it will be dewatered to approximately 30 to 40 per cent moisture content. The dewatered gypsum will be temporarily stored in a gypsum silo, to be located at the combustion waste collection building. Gypsum from FGD systems has successfully been used as a raw material for gypsum wallboard manufacturing and as an additive for cement. The Project Company has performed an evaluation to determine whether it will be economically feasible to establish a market for gypsum related products in this region of eastern Europe. No such market is believed to currently exist. If economically feasible, facilities will be developed to use the gypsum (or at least some portion of it) in a wallboard manufacturing or similar operation. If beneficial reuse of gypsum is not economically feasible, gypsum will be disposed off site. Gypsum stored in the gypsum silo will also be placed in rail cars, and will be transported for disposal in the planned Dryanovo ash/gypsum disposal area. Approximately 3500 tonnes per day of gypsum will be generated. Including the weight of the ash this will result in approximately 7000 tonnes per day of solid waste that will be transported to the

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ash/gypsum disposal area. Approximately twenty 1O-car trains per day will be required to transfer these combined wastes to the disposal area.

2.2.4.3 Ash storage and disposal

The combustion process will generate bottom ash from the boilers and fly ash from the electrostatic precipitators. Bottom ash will be collected in the bottom of each steam generator unit. The bottom ash will be cooled in a water-filled trough (submerged chain conveyor) and, after dewatering, will be stored in a silo located at the combustion waste collection building. Fly ash will be collected from the electrostatic precipitators and from the air heaters using a pneumatic dry system that will deliver the fly ash to silos located at the combustion waste collection building. An estimated 3500 tonnes (dry) of ash will be collected each day from the ESP and bottom ash units.

Ash will be loaded into rail cars, and transported to the Dryanovo overburden disposal area, where it will be disposed of in a newly constructed, lined ash disposal area.

2.2.5 Water and waste water systems and associated materials and by-products

2.2.5.1 Water supply and treatment

Water use at the power plant will include circulating water for the condenser cooling systems (cooling tower make-up), fire water, cycle make-up water, general service water, and potable water for sanitary use. A water balance for the planned facility is provided in Figure 2.4.

The source of water for the plant will be Rozov Kladenetz Lake, a man-made reservoir that has historically served as the supply for fire water and once-through condenser cooling water for the existing Maritza East 1 and Maritza East 3 power facilities.

When the existing power plant was constructed in the early 1960s, Rozov Kladenetz Lake was formed by damming the Sokolitsa River (an east to west flowing tributary to the Sazlijka River located approximately 2.2 km south of the power plant site) and diverting its flow into a 3.6 km2 surface water impoundment. When stream flow is sufficient (typically during the winter and spring months), the diversion of water from the Sokolitsa River to the lake is implemented. A screen house and pump station were also constructed adjacent to the Sazlijka River. This pump station has been and is still used to pump water from the Sazlijka River to Rozov Kladenetz Lake, to maintain the water level of the lake. The Sazlijka River pump station also includes pumps that have been used to withdraw water from the river for use in the existing power plant's steam cycle.

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The fire water and cooling water supply for the existing power plant is withdrawn from the lake using separate cooling water and fire water pump housing, located side by side along the north bank of the lake opposite the main gate of the power plant. The new power plant will use three existing refurbished Rozov Kladenetz Lake water supply facilities (intake structure, travelling screens, cooling water and fire water pumping equipment, etc) as part of the new plant's water supply system.

All water pumped to the power plant from the lake will undergo clarification and lime softening. Softened water will be routed to the cooling tower for use as tower make-up. Circulating cooling tower water will be treated with sodium hypochlorite for biological control and sulphuric acid to control scale deposition. Water to be used in the main power plant will be treated for suspended solids, dissolved solids and hardness reduction in the same solids contact clarifier that supplies the cooling tower. This water will undergo filtration and disinfection (sodium hypochlorite) prior to being stored in a filtered water storage tank. Filtered water will serve general service water needs. Potable water and water to be used as boiler make-up in the power cycle will require further treatment to remove impurities. Both will be treated prior to final treatment specific to the intended uses. Potable water will be drawn from the storage tank, stabilized and disinfected, and stored in a potable water storage tank. Demineralized water used to make-up the power cycle, will be further treated by ion exchange demineralization. Water in the condensate-feedwater-steam cycle will be conditioned with hydrazine (an oxygen scavenger), and ammonium hydroxide (for pH control). Trisodium phosphate will be added to the boiler water to minimize scale and corrosion.

2.2.5.2 Waste water treatment reuse

The AES-3C Maritza East 1 power plant will be designed to operate as a closed-loop or "zero discharge" facility for waste water. Facility waste streams will include water treatment system discharges (eg filter backwash and water treatment sludge dewatering effluent), demineralization system discharges (eg neutralized ion exchange system resin regeneration waste water), boiler blowdown, plant drains, and treated effluent from the sanitary waste water treatment facility. These streams will be reused. Cooling tower blowdown will be routed to the flue gas desulphurization system wet limestone scrubber, where it will be both mixed with crushed limestone to form the limestone slurry mixture and directly injected into the FGD scrubber unit. A small quantity of the cooling tower blowdown will also be routed to the bottom ash system for use in ash quenching.

2.2.5.3 Storm water management

The AES-3C Maritza East 1 power plant will have three distinct areas with respect to storm water runoff; the lignite pile area, several outdoor oil handling and storage areas, and the remaining main power block area. Storm water runoff from the area surrounding the lignite piles and lignite train unloading area could potentially have elevated concentrations of suspended solids due to the coal dust likely present in these areas. Storm water runoff from the lignite pile and lignite train unloading area will be routed to a lignite pile runoff pond. The lignite pile runoff pond will be sized to store runoff from precipitation events up to and including the 10-year 24-hour storm event (estimated at approximately 122 mm of rainfall). Water collected in this pond will be treated (eg pH neutralization, if required) and routed to the raw water treatment system.

Storm water from the bunded HFO oil storage tank areas, from the HFO unloading area, from any outdoor DFO storage or handling areas, and from the planned electrical substation area could

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potentially contain oil and will, therefore, be routed to one or more oil/water separator unit. Clarified effluent from the oil water separators will be routed to the raw water treatment system.

Storm drainage for the new main power block area will be routed to a small runoff pond, sized to store runoff from the 1-year 24-hour storm event (estimated at approximately 50 mm of rainfall). This smaller pond will be sized to capture and allow settling of "first flush" suspended solids (typically runoff from the first 30 minutes of rainfall event).

Occasional storm water overflows from the smaller power block storm water pond and less frequent overflows from the larger lignite pile runoff pond are expected to be generally free of suspended sediment. These overflows will be routed to the Sazlijka River and will be discharged at a pOint prior to the Sazlijka River's confluence with the Sokolitsa River.

2.2.5.4 Water and waste water treatment chemicals

A variety of chemicals will be required to support facility water treatment and waste water treatment systems. Water treatment chemicals potentially used on-site and stored in the vicinity of the waste treatment building could include the following:

• Boiler water treatment chemicals such as trisodium phosphate, ammonium hydroxide, hydrazine.

• Cooling tower treatment chemicals such as sulphuric acid, sodium hypochlorite, and potentially various additional scale and/or corrosion inhibitors, as determined to be required.

• Raw water chemical precipitants, disinfectant, and clarification chemicals including lime (calcium hydroxide), sodium hypochlorite, ferric chloride, and sulphuric acid.

• Service water and potable water disinfectant (sodium hypochlorite).

• Demineralization system regeneration chemicals and neutralization basin pH adjustment chemicals, sulphuric acid and sodium hydroxide.

All chemicals will be stored in bunded areas.

2.2.5.5 Water and waste water treatment residuals

The chemical addition and precipitation component of the water treatment process will generate a high water content solid waste (sludge), consisting primarily of calcium carbonate and ferric hydroxide. This sludge will be dewatered and used in the FGD plant.

The facility's sanitary waste water treatment plant will also generate a residual solid waste (sludge). This sanitary waste will be tested and, if acceptable, will be used as fertilizer or for land reclamation. If necessary, and as approved by the municipality, this sludge will be dewatered and disposed of in the Galabovo solid waste landfill.

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2.2.6 Miscellaneous oil storage

In addition to the fuel oils (HFO and DFO), there will also be lesser quantities of lubrication oil, hydraulic oil, and electrical dielectric fluids (transformer oil) used and stored on-site. Although the turbine generator units will be hydrogen cooled, each will be equipped with a dedicated lube oil 3 system and reservoir. Each steam turbine generator lube oil reservoir could hold as much as 50 m of oil. These large oil reservoirs will be located inside the main turbine building and their oil level will be closely monitored. Other mechanical equipment with moving parts (eg boiler feed pumps, beater mills, induced draught fans, crushers, conveyors, etc) will similarly be equipped with lube oil and/or hydraulic oil system, however, involving significantly less quantities of oil. The electrical substation will likely include transformers, capacitors, circuit breakers, and switches, each likely containing from 1 litre to several hundred litres of mineral oil dielectric fluid or other similar transformer oil.

To support these various oil-filled units, an oil drum storage area, containing several 55 gallon drums of the various oils used on-site, will be maintained inside the steam turbine building. NEK will maintain their own separate drum storage area to serve the 400 kV electrical substation. Oil drums in the steam turbine building will be stored within secondary containment to ensure that any oil spills are fully contained.

Occasionally lube oil, hydraulic oil, and transformer oil will need to be replaced within a given piece of equipment. Drums of used oil, also including oil removed from any of the on-site oillwater separator units, will be temporarily stored in a used oil drum storage area to be located in proximity to the clean oil drum storage area. Periodically, drums of used oil will be shipped off-site for subsequent reuse or recycling. All oil will be stored in bunded areas.

2.2.7 Management and disposal of other facility non-hazardous wastes

Operation of the power plant will generate other non-hazardous waste, in addition to those previously discussed. These will include domestic office wastes (paper, packaging materials, general refuse) and non-toxic industrial solid wastes (disposable filters, rags, spent desiccant material, machine shop wastes, empty drums and containers). These miscellaneous non-hazardous solid waste will be collected and, with local approval, disposed of in the municipality of Galabovo's solid waste landfill.

2.2.8 Management and disposal of potential hazardous wastes

It is not anticipated that the operation of the power plant will generate any significant quantities of hazardous wastes. Hazardous wastes generated will be temporarily stored on-site and transported to a licensed facility for appropriate off-site treatment and disposal, in compliance with Bulgarian Ordinance on Industrial and Hazardous Waste Treatment and Transportation (Decree No 53 of 19.03.1999).

2.3 Planned construction activities

The overall construction of the AES-3C Maritza East 1 power plant, from the issuance of a Final Notice to Proceed to the Engineering, Procurement, and Construction (EPC) contractor to the completion of testing and commencement of operation, is estimated to be 36 months. A Final Notice to Proceed will be issued to the EPC contractor following financial closure, with the potential to issue a Limited Notice to Proceed before financial closure. During this period, final design work and materials

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procurement can be initiated. On-site construction, beginning with site clearing and underground utility relocation, will be initiated by January 2006. It is anticipated that commercial operation of Unit 1 will be initiated by December 2008 with Unit 2 to follow by 1 April 2009, Construction of the project will, at its peak, involve a workforce of as many as 2 600 workers. It is anticipated that most of these workers will be from the local area.

2.3.1 Site clearing, excavation and utilities relocation

Construction of the project will begin with the clearing of the project site and relocation of existing utilities that are to remain active during the construction phase of the project. NEK will have completed the demolition (to ground level) of existing buildings and structures within the footprint of the planned project site (eg lignite drying factory, the cement plant, the outdoor parts storage areas, and the centrally located contractor's building, etc). The site clearing work undertaken by the EPC contractor will involve the excavation and removal of the remaining building foundations and any abandoned underground utilities. Whereas NEK will be responsible for relocation of the existing active aboveground ash slurry pipelines and underground industrial sewer pipeline (running from the briquette factory to the sewer pump station) that currently traverse the planned power block area, the EPC contractor will be responsible for relocating existing active underground fire protection pipelines located in the planned project area (the fire protection systems serving the existing power plant).

Site clearing debris such as excavated concrete foundations and abandoned utility pipelines, manholes, and cable galleries, will be disposed of in a construction debris landfill designated by the municipality.

3 It is estimated that approximately 270000 m of excavation will be required for the construction of the power plant and associated structures. A small portion of the excavated materials will be underground debris associated with the existing power plant. Most of the excavated materials, however, will be on-site soil. The excavated soils will be stored and used on-site and there is no plan for off-site disposal of these soils. Should there be excess excavated soils and/or stone, these materials will either be deposited in the construction debris landfill (possibly used as cover materials) or placed in railcars and disposed of in the Dryanovo overburden disposal area.

2.3.2 Rehabilitation of existing facilities

Several facilities at the existing Maritza East 1 power plant will continue to be used at the new power plant. These facilities include the circulating water and fire water pump stations (and associated screens, pumps, and pipelines). During the final design process, the condition of these facilities will be fully assessed and plans for rehabilitation will be developed. Rehabilitation of these facilities will take place during the early middle period of the construction schedule.

2.3.3 Construction of new facilities

Construction of the new facilities at the project site will generally follow a five step process: final design, materials and equipment procurement, civil construction, mechanical/electrical construction, testing/start-up. Civil construction, beginning in June 2006 and extending through the summer of 2008, will involve site clearing and excavation, construction of concrete foundations and steel superstructures, construction of site roadways and rail spurs, and erection of buildings. Mechanical and electrical construction will begin in the spring of 2007 and continue through the autumn of 2008.

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Mechanical/electrical construction will involve the erection of boilers, turbine generators, cooling towers and condensers, mechanical piping and pumps, air pollution control equipment (FGD scrubbers, ESPs), and associated electrical equipment. It is anticipated that NEK will be constructing the electrical substation and associated transmission lines during this same time frame. Start-up and testing are expected to begin in August 2008, so that Unit 1 will begin commercial operation in December 2008 and Unit 2 will begin commercial operation in April 2009.

2.3.4 Construction water supply

Bottled water will be provided as drinking water during the construction of the project. Water in support of construction activities will be obtained by way of a connection to the municipal water supply line that currently services the existing Maritza East 1 power plant.

2.3.5 Construction waste water management

A construction workforce of as many as 2600 people could generate as much as 250 m 3 of sanitary waste water each day. Construction phase sanitary waste water will be collected in on-site holding tanks and transported off-site for appropriate treatment and disposal.

2.3.6 Construction storm water and ground water dewatering discharges

Construction techniques will be implemented that will minimize soil erosion and the quantities of sediment in storm water and ground water dewatering discharges from the construction area. Site grading and materials stockpiling will be performed using techniques designed to minimize potential erosion of topsoil. Where appropriate, hay bales and/or silt fencing will be installed in areas down gradient of construction activities to minimize sediment loading in storm water runoff. If necessary, and where appropriate, a temporary storm water sedimentation basin will be constructed that will control peak flows of storm water runoff and dewatering discharges and allow for the settling of suspended sediment. Storm water runoff and ground water dewatering discharges will be routed to the storm drainage system currently in the existing Maritza East 1 power plant facility.

2.4 Other local facilities potentially affected by the project

As discussed in previous subsections of this project description, there are several facilities not directly related to the AES-3C Maritza East 1 power plant project that could potentially be affected by the new project. These facilities include the existing Maritza East 1 power plant, the Briquette Factory Ltd (ie Galabovo coal briquette manufacturing facility), the Energoremont parts repair facility, and the Rozov Kladenetz Lake fish farm co-operative.

The existing Maritza East 1 power plant (Brikel EAO)

Brikel EAD was formed by the merger of the existing Maritza East 1 power plant and the briquetting factory. The current Maritza East 1 employs approximately 1100 workers. The 200 MW facility is over 40 years old and many of its structural and mechanical components are approaching the end of their anticipated design life. There are no plans to fit Flue Gas Desulphurisation facilities to this plant. Consequently it is planned to op.erate for only 20,000 hours after 2008 as required by the Large Combustion Plant Directive.

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The coal briquette manufacturing facility is located directly east of the existing Maritza East 1 power plant. This facility was constructed and became operational in the mid-1960s and, similar to the existing Maritza East 1 power plant, is approaching the end of its design life. The facility manufactures high calorific value coal briquettes for use in residential coal stoves and, in recent years (since the closing of the lignite drying plant) for use in the existing Maritza East 1 power plant. A specific high calorific value (high sulphur content) type of lignite (referred to as "briquetting lignite") is transported from Maritza East lignite mines to the briquette plant by rail. The lignite briquettes are manufactured using a process that includes raw lignite crushing and grinding followed by lignite drying and a briquetting pressing operation, and subsequent cooling. The briquette factory's lignite drying process uses steam extracted from the existing Maritza East 1 power plant as a heat source. Industrial and sanitary waste water from the briquette factory are currently routed to a sewer pump station located at the existing Maritza East 1 power plant (in the vicinity of the Sazlijka Rive pump station), where it is pumped for disposal in the active Maritza East 1 ash ponds. This facility will close when the associated existing Maritza East 1 plant closes.

Energoremont-Galabovo JS Company

This parts repair and manufacturing facility is located just south of the existing Maritza East 1 power plant. This facility employs approximately 1 450 workers and includes boiler and turbine spare part production facilities, boiler and turbine eqUipment repair workshops, and workshops for electrical and furnace construction and reconstruction work. The facility's principal clients are the Maritza East 1, Maritza East 2, and Maritza East 3 power generating facilities.

Rozov Kladenetz Lake fish farm

A small fish farming co-operative is currently operated along the north bank of Rozov Kladenetz Lake, in the vicinity of the location where the existing Maritza East 1 power plant's heated circulating water system discharge first enters the lake. The co-operative raises perch, carp, and catfish both for direct sale and, to a lesser degree, for stocking of the lake. During the colder months of the year, a stream of warm water is diverted from the thermal discharge canal into a fish farming impoundment. This warm water both prevents the water impoundment from freezing and accelerates the maturing process of the fish raised at the co-operative.

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3. LEGAL AND ADMINISTRATIVE FRAMEWORK

This Section identifies the regulations applicable to the project, both Bulgarian and international. As a project seeking financing or insurance guarantees from various international financial institutions (eg OPIC, IFC, EBRD, MIGA) it is necessary to demonstrate compliance with host country regulations, World Bank environmental guidelines, European Union (EU) guidelines, and international agreements and conventions to which Bulgaria is a signatory.

Bulgaria is not currently a member of the European Union (EU) but is a candidate for EU Accession, and is the subject of an Accession Partnership Agreement that was adopted in March 1998. As part of its efforts to achieve EU membership, Bulgaria is undertaking extensive efforts to harmonize its environmental laws with those of the EU. EU environmental policy and regulation, therefore is applicable to the project both through the requirements of prospective lenders but also because the EU regulations have either come into force or are expected to come into effect during the lifetime of the proposed project.

3.1 Applicable Bulgarian environmental regulations

3.1.1 Environmental administration

3.1.1.1 Ministry of Environment and Water

Environmental decision-making in Bulgaria is carried out by the Ministry of Environment and Water (MEW). With both a central authority as well as regional inspectorates, the agency functions broadly to:

• draft environmental legislation;

• co-ordinate environmental protection activities and pollution control;

• monitor the state of the environment and compliance with environmental legislation;

• enforce environmental legislation;

• implement measures to protect biological diversity and manage protected areas;

• co-ordinate and implement environmental international agreements

• manage the National Environmental Protection Fund and control the use of the Municipal Environmental Protection Funds;

• issue permits, and

• supervise EIAs jointly with relevant ministries.

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Acting jointly with the Ministry of Health Care, the Ministry of Agriculture, Forests and Agriculture Reform, the Ministry of Construction and Regional Development, the Ministry of Environment and Waters:

• develops air, water and soil ambient standards, standards for the emission or discharge of hazardous sUbstances into air and water, and regulations governing natural resource use;

• determines environmental charges;

• establishes the procedures for EIAs; and

• issues instructions for the transport, storage, use and disposal of hazardous substances.

The MEW has 16 Regional Environmentallnspectorates. The closest MEW Regional Environmental Inspectorate (RIEW) to the project site is located in Stara Zagora, approximately 40 km north-west of the project site. The responsibilities of the Regional Environmental Inspectorates include assisting the MEW in the following:

• enforcement of environmental laws;

• preparation of environmental improvement programmes; and

• dissemination of public information on the state of the environment.

3.1.2 Major environmental legislation

The main environmental legislation relating to power plants is the Environmental Protection Act (91/2002 and 9812002). This converts several European Union Directives into Bulgarian Law. The two most significant with respect to power stations are the revised Large Combustion Plant Directive (LCPD) and the Integrated Pollution Prevention and Control Directive (IPPC).

The Bulgarian Ambient Air Quality Standards Ordnance No 9 (3 May 1999), are based on the European Union Air Quality Directive.

The Waste Management Law, (86/2003) and the Waste Classification (Regulations of 1 July 2004) are also based on European Union Directives. Disposal of waste is covered by these regulations and by Regulation 12 of 152/1998 on waste disposal sites and by Regulation 10 of 151/1998 on documentation.

The Bulgarian laws relating to aqueous effluents also reflect European Union Directives, (the Bulgarian legislation is 97/2000 and 98/2000).

The Bulgarian regulations regarding noise emissions are covered by two Bulgarian standards:

1. Bulgarian State Standard 14478-82 "Acceptable Noise Levels at Workplaces".and

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2. Hygiene Norm No 0-64 "Maximum Permissible Noise Limits in Residential and Public Buildings and Residential Areas" (State Gazette Issue No 87/3 November 1972 as amended by Issue No 16/25 February 1975).

Bulgarian State Standard 14478-82 stipulates noise limits in workplace locations (not at the site boundary) and the general requirements for performing noise measurements. Hygienic Norm No 0-64 establishes the maximum noise limits for off-site locations in residential, public, commercial, industrial and institutional areas.

The sound level limits defined by this Norm are presented in the table below. Corrections to the limits defined in this table can be applied depending on several factors that influence the perception of sound. These corrections are listed in the table below.

TABLE 3.1 MAXIMUM ADMISSIBLE LEVELS OF SOUND PRESSURE IN DIFFERENT AREAS AND ZONES OF TOWNS AND VILLAGES

Sound level in dBA Territories and zones of built-up areas Day Night

Residential zones and areas a. existing urban zones 55 45

Existing urban zones close to main thoroughfares 60 50 b. new sites 50 40

New sites close to main thoroughfares 55 45

Central town areas 60 50

Industrial areas and zones 70 70

Recreation centres 45 35

Sites for hospitals, sanatoriums, and other hospitals 45 35

Sites for research, scientific and educational facilities 45 35

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TABLE 3.2 CORRECTIONS TO ADMISSIBLE SOUND LEVELS

Influencing factor Condition Correction dB

Nature of noise Broadband 0

Tonal, impulse -5

Hour of the day Daytime (6 am-10 pm) 0

Night-time (10 pm -6 am) -5

Duration of permanent noise More than 4 hours 0 (with interruptions) per 24 hour day From 2 to 4 hours =5

Less than 2 hours +10

Location Resort area -5

Newly projected urban residential 0

Residential area in an existing residential development

The withdrawal of water from a water body is controlled by the Waters Act (67/27 July 1999). A permit to withdraw water from the Rozov Kladenetz Lake has been obtained from the Water Department within the Ministry of Environment and Water.

3.2 World Bank environmental guidelines

The World Bank has established environmental review criteria for air emissions, ambient air quality, liquid effluent discharges, and ambient noise levels that apply to new thermal power plants. World Bank guidelines are typically referenced by lending institutions and insurance providers, including OPIC, IFC, and others to judge the suitability of a proposed project for financing, insurance or other support.

The September 1998 Thermal Power Guidelines for New Plants gives limits for air emission, liquid effluent, and noise.

The World Bank environmental guidelines contain recommended limits for S02, NOx and particulate matter emissions from combustion stacks and limits for ambient air quality levels downwind of these stacks. The guidelines require that a "good engineering practice" (GEP) stack height be used as a basis for assessment of ambient air quality impacts.

The guidelines also contain limits for liquid effluent discharged from thermal power plants. Recommended effluent limits are specified for pH, total suspended solids, oil and grease, total residual chlorine, chromium (total), copper, iron and zinc, as well as a limit for the resultant receiving water temperature increase.

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Guidelines for noise specify maximum allowable levels at receptors outside the property boundary of a project. Different overall levels are set for daytime and night-time periods for two categories of receptors: residential and industrial. The residential daytime (0.700 to 22.00) limit is 55 dBA while the night-time (22.00 to 7.00) limit is 45 dBA. The limit in industrial and commercial areas is 70 dBA during both the day and night. For areas with already elevated noise levels, the project related increase is limited to 3 dBA above ground levels. The World Bank also addresses solid waste disposal, although not in great detail.

The proposed project qualifies as a "category A" project under OPIC and IFC guidelines, because "diverse and significant environmental impacts may result". As a category A project, an "full and detailed" EIA must be prepared that addresses a comprehensive list of environmental and social issues.

3.3 European Union

Environmental protection has been an integral part of the European Union since the Single European Act was incorporated in 1987 into the Treaty of Rome, which established the EU. Original, and somewhat vague directives that were up to the discretion of member countries to adopt and enforce, have recently been replaced by more prescriptive directives and regulations. These not only set specific limits, but also have the effect of transferring power from individual member sates to the European Union and/or European institutions .. Of relevance to this project, are the current requirements for EIAs, limits on various process discharges and regulations governing the use for former industrial sites.

3.3.1.1 Environmental Impact Assessment

Council Directive 85/337/EEC originally passed in 1985 and later amended by Directive 97/11/EEC in 1997 requires that an Environmental Impact Assessment (EIA) be prepared for projects that due to their nature, size or location could have an adverse impact to the environment. Thermal power plants larger than 300 MW thermal input that are constituted after 1988 are required to prepare an EIA that provides a comprehensive evaluation of the project's direct and indirect effects relative to humans as well as flora and fauna as it relates to soil, water, air, climate and the landscape. The directive does not include specific environmental standards, but instead creates a process for public review and comment.

3.3.1.2 Large Combustion Plant

The original LCPD (88/609/EEC) has been replaced by the revised LCPD (2001/80/EC). For new solid fuel fired power stations over 300 MW thermal input the limits on emissions to air are 200 mg/Nm3 for sulphur dioxide and oxides of nitrogen and 30 mg/Nm3 for dust. A derogation is given in Annex III for plant where due to the characteristics of the fuel the 200 mg/Nm3 limit for sulphur dioxide cannot be attained. The derogation for plant with a thermal input greater than 300 Mwth is a desulphurization rate of 95 per cent together with a maximum permissible emission limit value of a 400 mg/Nm The lignite proposed for use at AES-3C Maritza East 1 has characteristics that invoke the derogation.

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3.3.1.3 National Emissions Ceilings

The National Emissions Ceilings Directive (2001/81/EC) gives annual limits for emissions of various pollutants such as sulphur dioxide and oxides of nitrogen to the atmosphere for each member sate of the EU. These limits are to be attained by 2010. A further EU wide limit for 2020 is also set.

This directive does not currently apply to Bulgaria.

3.3.1.4 Emissions Trading Directive

The Emissions Trading Directive (2002/07/EC) introduces limits for each EU state for emissions of carbon dioxide from 2005 and sets out regulations for trading of carbon dioxide between member states and with other countries. This directive does not currently apply to Bulgaria.

3.3.1.5 Landfill

The Landfill Directive (99/31/EC) regulates the disposal of hazardous, non-hazardous and inert waste in landfills.

This directive is incorporated into Bulgarian legislation.

3.3.1.6 Integrated Pollution Prevention and Control

The Integrated Pollution Prevention and Control Directive was passed in 1996 and regulates emissions to air, water and land from new and existing industrial facilities including those of the energy industry. New installations are subject to the directive permitting requirements as of the date of implementation in November 1999. Existing facilities are subject to the regulations in the event of a substantial change or within 8 years of the directive's implementation. Central to the emission limits which must be included as part of a facility permit and which cover discharges to air, water and land, is the use of best available technology. Emission limits are specified for particular facilities, such as power plants, and are intended to ensure compliance with ambient standards.

Air emissions from general industrial processes are regulated under Directive 84/360 and require prior authorization before plant operation is initiated. More specific regulation of air emissions is provided in Directive 88/609 amended by 2001/80/EC which applies to emissions from large combustion plants and specifically to power plants larger than 50 MW. Emission limits are included for sulphur dioxide, nitrogen oxide and dust along with associated monitoring and reporting requirements. An important provision of this directive is the note that for new plants which burn indigenous solid fuel where the limit value for sulphur dioxide cannot be met because of the nature of the fuel, the specified limit values can be exceeded provided that a desulphurisation rate of at last 95 per cent is achieved and 3 an emission limit of 400 mg/Nm . The resulting emission limits for SUlphur dioxide, nitrogen oxide and dust both as specified in the EU directive, the parallel Bulgarian regulation, and in the World Bank guidelines are presented in Table 3.3 at the end of Section 3.

Ambient air quality was originally regulated under a number of pollutant specific directives that had the effect of specifying values that member states were to try to achieve. A subsequent directive passed in 1996 aimed to strengthen the initial framework by providing specific direction on ambient air quality sampling, measurement and assessment. New ambient air limit values for sulphur dioxide, nitrogen

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oxide, particulate matter, dust and lead took effect in 1997 with limits for other pollutants (such as benzene, carbon monoxide, cadmium and other metals) to follow. The ambient EU air quality standards (all of which are in effect by January 2000) together with the Bulgarian and World Bank ambient air standards are listed in Table 3.4 at the end of Section 3.

Water discharges are broadly regulated under a Framework Directive of 1976 which sought to eliminate the discharge of a "black list" of chemicals and reduce the pollution resulting from the discharge of a second "grey list" of chemicals. The first list of particularly dangerous chemicals included organohalogen, organophosphorus and organotin compounds as well as mercury and petroleum hydrocarbons. The grey list included other heavy metals such as zinc and copper, cyanides and fluorides as well as ammonia and nitrates. Again a notion of best technical means is used to define emission limits that are stated as not to exceed values for black list chemicals and as water quality standards for the grey list chemicals. Table 3.5 presents the list of applicable limits from the EU regulations, the parallel Bulgarian regulation, and the World Bank guidelines. This table is provided at the end of Section 3.

General facility noise and its potential effects on a community are not currently regulated in the European Union. A draft directive is under consideration. Specific directives address noise associated with individual pieces of equipment, such as a lawn mower, but no standards have been set comparable to the World Bank standard of an allowable level or allowable increase ass measured at a sensitive receptor. Other areas in which there is no existing European Union environmental regulation include property transfer requirements, spill prevent and control, or the clean-up of spills and contaminated disposal sites. In addressing areas where there are no EU regulations, the EBRD guidelines refer to the World Bank guidelines. For the assessment of contamination, the World Bank references the US EPA standards.

3.4 International Environmental Conventions and Agreements

International agreements or programmes to which Bulgaria has or will likely become a party are listed below:

• Convention on Biological Diversity

• Convention on International Trade in Endangered Species ("CITES")

• Convention on Wetlands of International Importance. Especially Waterfowl Habitat ("Ramsar")

• Convention for the Protection of the World Cultural and Natural Heritage ("World Heritage Convention")

• Framework Convention on Climate Change

• The Kyoto Protocol.

These international conventions and agreements are summarized in the following sections. Adherence to the principles and provisions of these conventions is also incorporated in the World

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Bank guidelines and EU environmental regulations. As with other regulations, these are used to evaluate site conditions and/or the significance of project impacts.

3.4.1 Convention on Biological Diversity

Bulgaria ratified the 1992 Convention on Biological Diversity on 29 February 1996. The Convention has been in force since 16 July 1996 and was promulgated in SG, Vol 19/02.03.1999. The National Nature Protection Service within the MEW has the responsibility of implementing this Convention.

The Convention includes many general policy principles, the most important of which is a requirement that every country develop a national biodiversity protection plan. In addition, it requires the preparation of environmental impact assessments, with public participation, for government projects that are not now covered by the Bulgarian EIA law, including forestry projects (Downes and Wold, 1998).

Bulgaria achieved one of the Convention objectives of developing a national biodiversity protection plan with publication in 1994 of a report entitled "Conserving Biological Diversity in Bulgaria: The National Biological Diversity Conservation Strategy". This report summarized the findings and recommendations from Bulgaria's National Biological Diversity Convention Workshop, held in March 1993.

More recently, a document of scientific papers was prepared as a foundation for an updated version of the National Biological Diversity Conservation Strategy through the efforts of the Bulgarian government, the US Agency for International Development (USAID), and the Biodiversity Support Program (a consortium of the World Wildlife Fund, the Nature Conservancy, and the World Resources Institute funded by USAID). The document of scientific papers is entitled "Bulgaria's Biological Diversity: Conservation Status and Needs Assessment", Volume 1 and 2 (March 1998).

3.4.2 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)

CITES regulates the international trade of endangered species of flora and fauna. The Bulgarian National Assembly ratified CITES on 12 December 1990, effect 16 April 1991. The MEW is planning to develop implementing legislation and will submit it to the National Assembly. Because international instruments are "self-executing" under the Bulgarian Constitution (ie the Constitution provides that international treaties ratified by Bulgaria have immediate force as domestic law), species listed under CITES automatically receive legal protection in Bulgaria, but implanting legislation will be needed to provide for penalties for violations and other necessary measures (Downes and Wold, 1998).

Bulgaria has designated the MEW as the management authority and three officials in the MEWs Department of Biodiversity, Protected Areas, and Forests (DBPAF) have the authority to issue permits. The government has also designated several Scientific Authorities (the Institute of Zoology for vertebrates and invertebrates, the Institute of Botany and Botanical Gardens for plant species, and the Institute of Ecology for vertebrate species) to provide assistance with regard to species listed in the Red Data Book of Bulgaria (Downes and Wold, 1998).

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3.4.3 Convention on Wetlands of International Importance Especially as Waterfowl Habitat (the Ramsar Convention)

Bulgaria signed the Ramsar Convention on 24 September 1975: the treaty entered into force on 24 January 1976. The treaty's text was published in the State Gazette No 56, 10 July 1992. Bulgaria has placed five wetlands on the Ramsar List, including the Srebarna Lake Reserve, Arkoutino Marsh Nature Reserve, the Atansovsko Lave Nature Reserve, Dourankoulak Lake Nature Monument and the Lake Shabia protected site. Four of the Ramsar sites are located along the Black Sea and one is located along the Danube River.

As part of the Ramsar Convention, Bulgaria completed a National Action Plan for the Conservation of the Most Important Wetlands in Bulgaria in April 1993. Conservation measures have been implemented for 14 of the 15 wetlands included in the National Action Plan (Ramsar, 1999).

3.4.4 Bern and Bonn Conventions

Bulgaria ratified the 1979 Bern Convention on the Conservation of European Wildlife and Natural Habitats on 25 January 1991, effective 1 May 1991 and published in the State Gazette, Vol 23, 10 March 1995. The Bern Convention included in the appendix a list of Bulgarian species under total or partial protection (OECD, 1996).

Bulgaria is not a party to the 1979 Convention on the Conservation of Migratory Species of Wild Animals (the Bonn Convention) but took part in adoption and signing of other agreements on protection of migratory species.

3.4.5 Convention for the Protection of the World Cultural and Natural Heritage ("World Heritage Convention")

The 1972 Convention is administered by the United Nations Educational Scientific and Cultural Organization (UNESCO) through a World Heritage Committee of representatives from 21 countries. The Committee creates and administers the World Heritage List of sites and areas that all of "universal outstanding heritage" and part of "the world [natural and cultural] heritage of mankind as a whole" (Downes and Wold, 1998).

The World Heritage Convention was signed, ratified and has been in force in Bulgaria since 1976. The National Nature Protection Service within the MEW has the responsibility of implementing this Convention. Two natural heritage sites in Bulgaria have been placed on the World Heritage List (Downes and Wold, 1998).

1. Pirin National Park, covering 27 500 hectares in the Pirin Mountains, has protected legal status as a national park, and

2. the Srebama Nature Reserve, consisting of 600 hectares of wetlands near the Danube River west of Silistra. This reserve provides critical habitat for rare birds, and has the protected legal status of a nature reserve.

These World Heritage sites are not located in close proximity to the project site.

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3.4.6 Framework Convention on Climate Change

The Climate Change Convention, adopted 9 May 1992, requires that signatory countries take climate change into account "to the extent feasible" in "relevant" social, economic and environmental policies. The Convention also requires signatory countries to prepare, publish, and update inventories of greenhouse gas emissions and carbon sink removals (ie forests) and requires developed countries and countries in transition to take measures to mitigate climate change by limiting emissions and enhancing sinks (Downes and Wold, 1998).

The Climate Change Convention was signed by Bulgaria on 5 June 1992, and ratified in March 1995. Bulgaria has pledged that its CO2 emissions in 2000 will not exceed the 1990 level (OECD, 1996). The MEWs outline for implementing the Convention covers the inventorying of emissions, development of a national plan for reduction of emissions (including selection of a pre-1990 base year), and protection of carbon sinks (specifically including forests), (Downes and Wold, 1998).

3.4.7 Kyoto Protocol

The 167 nations that ratified the 1992 Framework Convention on Climate Change created the Kyoto Protocol in December 1997, which was a follow-up document to the original climate treaty, and marks the first international attempt to place legally binding limits on greenhouse gas emissions from developed countries. In addition to CO2, the primary greenhouse gas, the Protocol focuses on five other greenhouse gases: methane (CH4), nitrous oxide (N20), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SFs) (World Resources Institute, 1999).

Bulgaria has committed to an 8 per cent reduction of their 1990 greenhouse gas emission levels by 2012.

3.4.8 Other

Bulgaria has ratified a number of regional and global conventions on air pollution. The convention most applicable to the proposed project is the Oslo Protocol. The Oslo Protocol calls for the country to reduce S02 emissions by 33 per cent in 2000, by 40 per cent in 2005 and by 45 per cent in 2010 from 1980 levels. This Protocol also calls for the adoption of stringent, uniform emission standards for both new and existing power plants by 2004 (OECD, 1996).

In March 1995, Bulgaria ratified the Espoo Convention on Environmental Impact Assessment in a Transboundary Context and the Helsinki Convention of the Transboundary Effects of Industrial Accidents. The Espoo Convention has been in force since 10 September 1997 and requires countries to undertake EIAs for proposed activities that are likely to have significant adverse transboundary impact. The Helsinki Convention requires signatory countries to take measures to prevent industrial accidents that could involve transboundary effects. These transboundary conventions are not applicable to the proposed project (OECD, 1996).

Document No. 62160AlPBP/OOOOO1 0774R03O.00c1S 1/1 ONV TABLE 3.3 til APPLICABLE BULGARIAN, EUROPEAN UNION AND WORLD BANK AIR EMISSION STANDARDS AND GUIDELINES d' ~ Bulgarian Regulations Environmental European Union Directive 2001/80/EC World Bank Guidelines (July 1998) Protection Act 91/2002 and 98/2002 Parameter Solid fuel Liquid fuel Solid fuel Liquid fuel Solid fuel Liquid fuel

802 (general limit) 200 mg/Nm3 200 mg/Nm 3 200 mg/Nm3 200 mg/Nm3 2000 mg/Nm3 (6% 2000 mg/Nm3 (3% (6% oxygen) (3% oxygen) (6% oxygen) (3% oxygen) oxygen) and 117 tpd oxygen) and 117 tpd (as calculated for (as calculated for 670 MW plant based 670 MW plant based on following formula: on following formula: 0.2 tonnes/day/MWe 0.2 tonnes/day/MWe (for first 500 MWe) (for first 500 MWe) plus 0.1 tpd for each plus 0.1 tpd for each additional MWe in additional MWe in excess or 500 MWe) excess or 500 MWe)

802 (limit firing 400 mg/Nm3 and 200 mg/Nm3 400 mg/Nm3 and 200 mg/Nm3 same as general same as general indigenous coal) 95% (3% oxygen) 95% (3% oxygen) 802 solid fuel limit 802 liquid fuel limit desulphurization desulphurization

3 3 3 3 3 3 NOx (general limit) 200 mg/Nm 200 mg/Nm 200 mg/Nm 200 mg/Nm 750 mg/Nm 460 mg/Nm (6% oxygen) (3% oxygen) (6% oxygen) (3% oxygen) (6% oxygen) (3% oxygen)

Particulate matter 30 mg/Nm3 30 mg/Nm3 30 mg/Nm3 30 mg/Nm3 50 mg/Nm3 50 mg/Nm3 (general limit) I ~ ~Rl .:~ -ug> til (') (0 :::::!': 0."~~ 0.", CD 0 ::J n~~ W TABLE 3.4 APPLICABLE BULGARIAN, EUROPEAN UNION AND WORLD BANK AMBIENT AIR QUALITY STANDARDS AND til GUIDELINES ~ , Bulgaria European Union World Bank (July 1999) ~ (Ordinance No 9 (03.05.1999) EU 1999/30/EC of 22 April 1999) Parameter Maximum Average Average Maximum Average Average Maximum Average Average single event daily 24 hour annual single event daily 24 hour annual single event daily 24 hour annual 3 1 hour (p.g/Nm ) 1 hour (l1g/Nm3) 1 hour (l1g/Nm3) 3 3 3 3 (l1g/Nm ) (p.g/Nm ) (p.g/Nm3) (p.g/Nm3) (p.g/Nm ) (p.g/Nm ) SOz 350 125 20 350 125 20 - 150 80 exceed exceed (meet by exceed exceed (meet by Q4times/pa $3 times/pa 1.1.2003) Q4times/pa $3 times/pa 19.7.2001) (meet by (meet by (meet by (meet by 1.1.2005) 1.1.2005) 1.1.2005) 1.1.2005)

NOx 200 - 40 200 40 - 150 100 exceed NOz human exceed N02 human $18 times/pa health (meet $18 times/pa health (meet (meet by by 1.1.2010) (meet by by 1.1.2010) 1.1.2010) 30 1.1.2010) 30 NOx NOx vegetation vegetation (meet by (meet by 1.1.2002) 19.7.2001) TSP ------230 80 total suspended particulates

PM lO - 50 30 - 50 40 0 150 50 particulate exceed (meet by exceed (meet by matter less $35 times/pa 1.1.2009) $35 times/pa 1.1.2005) than until 2008 20 until 2008 20 10 microns (meet by (meet by exceed (meet by I (lJ.m) in size 1.1.2005) ~ 1.1.2010) $7 times/pa 1.1.2010) >lo> exceed thereafter ,.-.... '" ;00> $7 times/pa (meet by §~ thereafter 1.1.2009) "1J~ (meet by III () ~~ C.Q!:t: 1.1.2009) CD 0 ~~ --,,::l NW Bulgaria European Union World Bank (July 1999) (Ordinance No 9 (03.05.1999) EU 1999/30/EC of 22 April 1999) til Parameter Maximum Average Average Maximum Average Average Maximum Average Average single event daily 24 hour annual single event daily 24 hour annual single event daily 24 hour annual .0" 3 3 1 hour IJ,tg/Nm ) 1 hour (llg /Nm1 1 hour IJ,tg/Nm ) 3 3 3 ~ IJ,tg/Nm ) (llg/Nm3 ) IJ,tg/Nm ) (llg /Nm3 ) (llg /Nm3 ) IJ,tg/Nm ) PM25 - 40 20 ------particulate matter less than 2.5 microns ij,tm) in size Lead - - 0.5 - - 0.5 (meet by - - - (meet by 1.1.2005) 1.1.2005)

Notes:

1. Bulgarian Regulation No 14/23/09.09.97 provides ambient air quality criteria for additional parameters not presented above. Pending confirmation the table above assumes that the Ordnance 15 criteria presented for the parameters above supersede the respective parameter provided previously in Regulation 14.

2. Bulgarian and European Union standards presented above will be phased in incrementally. The table above presents the ultimate limit that will apply and the year in which it will apply.

I ~ o -.J0l -.J'" ... ~ ;U0l @~ "Ug> III 0 ~~ (Q !:!: ~§ <1> 0 ~~ ::J WW TABLE 3.5 POTENTIALLY APPLICABLE BULGARIAN, EUROPEAN UNIT AND WORLD BANK EFFLUENT LIMITS AND GUIDELINES til ~ Parameter Bulgarian Water World Bank Environmental Guidelines for Thermal Power European Union Requirements for Discharges from Urban Waste Water Quality Standard Plants (July 1998) Treatment Plants (9112711EEC as amended by 98/15/EC) ~ (Ordinance 718.8.1986)

Guideline value Notes Effluent limit Minimum Notes percentage reduction pH - Sto9 - - - - Total suspended - 50 - 35 90% Failing samples taken under normal solids (mgll) (>10000 pel (>10000 pel operating conditions must not deviate 50 70% from the parametric values by more than (2000 to (2000 to 100%. For the parametric values in 10000 pel 10000 pel concentration relating to total suspended solids deviations of up to 150% may be accepted. The parameter can be replaced by another parameter: total organic carbon (TOC) or total oxygen demand (TOO) if a relationship can be established between BODS and the substitute parameter Oil and grease - 10 - -- (mgll) Total residual - 0.2 "chlorine shocking" may be preferable in -- - chlorine (mgll) certain circumstances. This involves using high chlorine levels for a few second rather than a low-level release. The maximum value is 2 mgll for up to 2 hours. not to be repeated more frequently than once in 24 hours. with a 24 hour average of 0.2 mgll. (The same limits would apply to bromine and fluorine) r Total chromium - 0.5 - -- - (mgll) o ~ .... '" Copper (mgll) 0.5 - ....,.~ '" - - -- Al'" ~~ Iron (mgll) - 1.0 - - - - Zinc (mgll) - 1.0 - - lJ~ ------III C"l n (Q~ al8 CD 0 ~~ ..... ::::1 .f:>.W Parameter Bulgarian Water World Bank Environmental Guidelines for Thermal Power European Union Requirements for Discharges from Urban Waste Water Quality Standard Plants (July 1998) Treatment Plants (91/2711EEC as amended by 98/15/EC) (Ordinance ;g 718.8.1986) ~ Guideline value Notes Effluent limit Minimum Notes percentage ~ reduction

Temperature Not exceeding the <;3"C The effluent should resu~ in a <3"C - Source: 78/659/EEC (Quality of Fresh increase rC) average seasonal temperature increase of no more than temperature Waters Needing Protection or temperature by more 3"C at the edge of the zone where in~ial rise Improvement in Order to Support Fish than 3"C mixing and dilution take place. Where Life). zone is not defined, use 100 m from the Temperature downstream of a point of point of discharge when there are no thermal discharge (at edge of the mixing sens~ive aquatic ecosystems within this zone) must not exceed the unaffected distance temperature by more than 3"C. Thermal discharges must not cause temperature downstream of the point of thermal discharge (at edge of mixing zone) to exceed 2S"C. Temperature limit may be exceeded 2% of the time. Biochemical - -- 25 70% to 90% The parameter can be replaced by oxygen demand another parameter: total organic carbon (BOD5 at 20"C) (TOG) or total oxygen demand (TOO) if a without relationship can be established between nitrification (mg/l) BOD5 and the substitute parameter. Failing samples taken under normal operating conditions must not deviate from the parametric values by more than 100%. For the parametric values in concentration relating to total suspended solid deviations of up to 150% may be accepted. Chemical oxygen - - - 125 75% The parameter can be replaced by demand (mglO another parameter: total organic carbon (TOC) or total oxygen demand (TOO) if a relationship can be established between ~ BOD5 and the substitute parameter. For ~ the parametric values in concentration " relating to total suspended solid ~ deviations of up to 150% may be ~~ ,.~ accepted. elg) l5~ 0.", "U~ OJ 0 ~~ COd ~o C1l 0 ~~ .... :;j (J1W Parameter Bulgarian Water World Bank Environmental Guidelines for Thermal Power European Union Requirements for Discharges from Urban Waste Water Quality Standard Plants (July 1998) Treatment Plants (91/2711EEC as amended by 98/15/EC) (Ordinance til 718.8.1986) ~ Guideline value Notes Effluent limit Minimum Notes percentage ~ reduction Total phosphorus - -- 2 80% Applies to discharges to sensitive areas (mgll) (10 000 to which are subject to eutrophication. 100 000 pel Either total phosphorus or total nitrogen 1 values (or both) may be applied (>100000 pel depending on the local situation. Total nitrogen - -- 15 70% to 80% Applies to discharges to sensitive area (TKN= N03 + (10000 to which are subject to eutrophication. N02) (mgtl) 100 000 pel Either total phosphorus or total nitrogen 10 values (or both) may be applied (>100000 pel depending on the location situation. These values for concentration are annual means. However, the requirements for nitrogen may be checked using daily averages when it is proved that the same level of protection is obtained. In this case, the daily average must not exceed 20 mgll of total nitrogen for all the samples when the tem perature from the effluent in the biological reactor is superior or equal to 12"C. The conditions concerning temperature could be replaced by a limitation on the time of operation to take account of regional climatic conditions.

General notes:

1. Bulgarian regulations currently do not include effluent limits but are based on maintaining ambient water quality classifications. Legislation in the process of being drafted may include effluent limits but this is not a certainty. ~ 2. World Bank guideline values should be considered applicable. European Union limits are applicable and will likely form the basis for future Bulgarian effluent limits.

I 3. It is assumed that European Union limits related to water temperature in ''fish waters" are pertinent. Since there is no information indicating the use of the lake and rivers for () 0 '" shellfishing or as bathing waters EU regulations related to shellfish waters and bathing waters have not been considered. :jR; ... ~ ;u'" 4. One pe (population equivalent) unit refers to the organic biodegradable load having a 5 day biochemical oxygen demand (BOD5) of 60 g of oxygen per day. §~ -u~ W 0 (0 ~ ~~ CD 0 ~~ ~:::l (J) W PBPower Section 4 Page 1 of 69

4. EXISTING ENVIRONMENT

This section describes existing conditions at the project site and within the project area. The project area encompasses a 20 km radius of the site and is defined as the area within which the maximum air quality impacts would be expected to occur. Existing conditions are summarized for the environment as it relates to air quality, water quality, ecology and other natural resources as well as the social and economic conditions of the local population and its supporting infrastructure. Those resource areas expected to sustain the greatest project impacts are described in the most detail.

4.1 Topography, geology and seismicity

4.1.1 Topography

The location of the proposed new AES-3C Maritza East 1 power plant is in south central Bulgaria. The immediate project area is relatively flat and part of the Sazlijka river basin, which covers the south-eastern part of the large Gomo Trakia lowlands. The topography in this general area is characterized by low hills and gentle slopes where the average elevation is in approximately 100 m.

Several nearby and more distant hills and mountain ranges define the project area. To the north and north-east is the elevated area Svetilijski vavz while to the east is a second equally elevated area Manastirski vazv. To the south, at approximately the same elevation, is Sakar. The elevations in these three areas range between 400 and 600 m. Together with the Sazlijka River, which runs from north to south at the base of Svetilijski vavz and Manastirski vazv, these define the eastern limits of the plain which extends to the west as far as Plodiv.

The open, rolling plain of the project area is limited to the north by the Sredna Gora mountains which extend over a wide area from east to west across Bulgaria. To the south the Rodopi form a similar, extended boundary. These extensive features define the topography that affects the meteorology and general climatic conditions at the site.

The Sazlijka River is the principal surface water body in the area. The river is 145 km long and drains 2 3 an area of 3293 km with an average stream flow of 10.41 m /s. The lower part of the river, outside the project area, turns parts of the adjacent land into marsh. The Ovacharitsa River and the Sokolitsa River are tributaries to the Sazlijka and part of the larger river basin.

4.1.2 Geology

4.1.2.1 Regional geology

A geologic profile confirms that the south-east part of the Gorno Trakia lowland is part of a Pliocene lake formation that reaches south to the valley of the Sokolista River. It is comprised of Quaternary alluvial sediments from the Sokolista River, which were formed through the erosion of Pliocene bed rocks. These Pliocene sediments have variegated bedding of Paleozoic and Triassic rocks, which contain granite-gneiss, quartz, plagioclase and marbled limestone and dolomites. Four lithologic and stratigraphic horizons have been differentiated within the Pliocene sediment complex: the foundation, sub-coal floor, coal seam and super coal horizon. The foundation is approximately 75 m of rock bedding, conSisting of Tertiary sediments containing clay breccias and conglomerates, with alternate

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gravel and sand. The sub-coal floor ranges from 160 to 250 m and consists of light brown sand clays. The coal seam horizon, which ranges in thickness from 5 to 40 m, has layers ofthick grey black to black clays containing coal fragments with complex structure. Finally, the super coal horizon is between 30 and 40 m thick with alevrite sand and sand thick clays which contain quartz, limestone, sandstones and small grain gravel.

4.1.2.2 Geology of the proposed site

The proposed site of the new AES-3C Maritza East power plant is almost entirely within the boundaries of the existing Maritza East 1 power plant property. This locale is overlain by lake and lake marshy sediments. The site is located on alluvial deposits associated with the Sazlijka and Sokolitsa Rivers. Through the transitioning of lake basin to marsh land, coal seams have formed in the area. However, artificial filling, consisting of clay, sand, gravel, and coal, covers the majority of the project site. The artificial filling is approximately 4 to 5 m deep.

4.1.3 Tectonics and seismicity

There are several geologic features in the general project area. These include mud volcanoes, landSlides, possible significant water flows in excavations, sand liquefaction, natural radioactive anomalies, and a nearby earthquake epicentre with magnitude between 5 and 6. In addition, it appears that the site is located in very close proximity to an active fault, and within an earthquake zone ranked between 8 and 9 on the MSK-64 scale. This translates to a "severe" earthquake zone (Richter scale 6.2 - 7.3). An earthquake with an intensity of 8 typically has the following effects: chimney fall, branches break, cracks appear in wet ground and there can be difficulty controlling a moving vehicle. For an earthquake of intensity 9, the effects include general panic, damage to foundations, and sand and mud bubble from the ground.

The MSK-64 earthquake intensity scale was developed by Medvedev, Sponheuer, and Karnik in 1964 and replaced the Modified Mercalli (MM) scale of 1956. The MSK-64 scale was modified in 1992 and finalized in 1998, becoming the EMS-98 (European Macroseismic Scale). All of these scales are similar in that they are 12-degree earthquake intensity scales that range from not felt to complete devastation. EMS-98 is currently the international reference scale for measuring earthquake intensity.

4.2 Soils

The soils found in the site region are part of the Bulgarian Tracian-Bourgas soil region. The most common type of soil found in this area is the terra negra, or Vertisols. These soils are distributed over slightly drained area, and are formed under the influence of meadow-bog vegetation and bedrock and typically have a relatively high carbonate content. The humus horizon found in this soil type is 40 to 50 cm deep. These soils have high sorption and water retention capacity and are generally suitable for growing almost all basic agricultural crops.

Another soil type frequently found in the area is that maroon forest soils, or Luvisols. These are comprised of leached and podsolized soil varieties that occur at higher altitudes, along slopes with good drainage. This soil structure is poorly developed and can be highly granular with inter-soil clay formation.

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The fluvisols found along the river valley tend to have rock fragments both on the surface and deep within the soil. They tend to be sandy-clayey in composition but also poorly developed in structure.

Much of the natural soil has been stripped as part of the long term area-wide mining. Further alteration in the soil surface has been associated with quarry development, reservoirs, roads and railroads. Many of the areas formerly used for mining have been revegetated, in some cases without addition of humus and others with the addition of humus or ash. Those areas revegetated without addition of humus layer have used clays obtained after completion of mining operations. The soils are dense and generally have unfavourable physical properties and lack any active nutrients. Many studies have been done of the soil conditions in the area, including vegetation experiments to determine the most successful means of vegetation.

Soil samples taken at six locations have concluded that soils used in the areas that have been revegetated are similar in characteristics to the neighbouring vertisols. Tested for a variety of chemicals associated with conventional air emissions, the studies concluded that the concentration of heavy metals in these soils was not harmful to humans, plants or animals. Table 4.1 describes the characteristics of the area where each of the soil samples was taken; Table 4.2 presents the results of the sample analyses.

TABLE 4.1 SOIL SAMPLE LOCATIONS - MARITZA EAST 1 AND SURROUNDING AREA

Sample Uncultivated soil in oak plantation about 1 km south of Galabovo. The soil is maroon forest Location 1 (Hromic Luvisols). Samples were taken by layers: 0 - 5 cm, 5 -10 cm, 10 - 20 cm Sample Cultivated land sown with wheat south of Galabovo. The soil is terra negra (Vertisols). Location 2 Samples are taken from 0 - 22 cm Sample Cinder dump No 1 (reclaimed Ash Pond 1) at Maritza East 1 TPP. The first 3 are from the cap Location 3 soil, and the fourth is from the ash material Sample Re-cultivated terrain with addition of humus cover over yellow and green clays, used in the Location 4 past for agricultural purposes. Samples were taken from 0 - 20 cm Sample Re-cultivated terrain without addition of humus cover over yellow and green clays. The terrain Location 5 is forested with Austrian pine (16 -18 years of age). Samples were taken from soil litter and two layers; 0 - 5 cm and 5 - 10 cm Sample Between the administrative buildings of Maritza East 1 TPP Location 6 Source: Energoproekt, 1999

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TABLE 4.2 SOIL SAMPLE RESULTS - HEAVY METALS IN AREA SOILS

Sample Depth pH Cu Zn Cd Mn Cr Co Ni Pb location 1. 0-5 5.6 48 67 <0.5 1623 45 24 43 55 5-10 5.4 59 64 <0.5 1116 49 24 39 62 10-20 5.2 49 56 <0.5 366 21 22 16 28 2. 0-20 6.5 52 48 <0.5 398 29 26 21 41 3. 0-5 5.1 51 45 <0.5 419 31 17 24 35 5-10 5.2 51 34 <0.5 332 26 9 21 27 10-20 5.1 47 34 <0.5 374 29 11 23 29 40-60 5.1 96 68 1.40 400 66 30 69 32 4. 2-0 5.8 20 102 <0.5 508 12 4 15 31 0-5 6.6 28 72 0.95 544 43 25 31 41 5-10 6.8 33 69 <0.5 355 36 19 27 34 5. 0-20 6.5 17 44 <0.5 539 27 15 22 34 6. 0-20 5.0 31 86 1.20 359 43 20 37 48 Source: Energoproekt, 1999

4.3 Meteorology and air quality

4.3.1 Meteorological and climate characteristics

Prevailing regional and local climatic conditions are import parameters affecting the dispersion of air pollutants emitted from an industrial source. A thorough understanding of the Maritza East region is necessary to estimate the impact of the new facility's emissions on ambient air quality. This section presents a general overview of the existing climatology of the region. The overview includes summaries of long-term patterns of winds, precipitation and temperature.

4.3.1.1 Regional climatology

The existing Maritza East 1 power plant is located near the town of Galabovo in south-east Bulgaria, approximately 40 km south-east of Stara Zagora and 250 km east of Sofia. The planned facility is located in the Sazlijka River valley at the eastern end of the Thracian plain. The slopes of the Monastery Heights are to the east and south-east and St Elijah Heights are about 35 km to the north north-east. The area immediately surrounding the site is generally flat or gently rolling terrain ranging from about 100 to 110 m above mean sea level elevation. The mountainous terrain bordering the Thracian Plain, especially the Balkan Mountains to the north and the Rodopi Mountains to the south, have an influence on local wind patterns. The major water bodies in the region are the Black Sea, 150 km to the east, and the Aegean Sea, 150 km to the south.

The region's climate reflects both European continental and Mediterranean influences. According to climatic data collected near the lake adjacent to the power plant (Rozov Kladenetz Lake), the regional climate is temperate and semi-arid with an annual temperature of about 13°C and annual precipitation

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of about 592 mm (Committee for Environmental Protection, 1978). The climatological data summary is provided in Table 4.3. Summers are characterized as hot and sunny with mean temperature ranging from 21°C to 24°C; winters are relatively cold and cloudy with mean temperature ranging from about DOC to 3°C. Precipitation occurs most frequently in the transition months, late spring to early summer (May-June) and middle to late autumn (October-December).

Cold season

During the winter the westerly storm track often passes south of the region bringing periods of unsettled and cold weather. When storms pass across the eastern Mediterranean and cold high pressure systems build over middle and eastern Europe, the easterly wind flow off the Black Sea often results in cloudy, damp conditions. Most of the cold season precipitation occurs in November and December when the contrast between the air temperature and the temperature of the Black Sea is greatest. Snowfall occurs most frequently in January and precipitation from snow occurring on average 4.5 days of the month and with an average of 6.6 days of snow cover. The coldest recorded temperature is below -25°C.

TABLE 4.3 CLIMATE DATA COLLECTED AT ROZOV KLADENETZ LAKE METEOROLOGY STATION -1962 to 1977

Temperature ('C) Precipitation Cloud coyer Snow Dally Daily Daily Extreme Extreme Mean Days Cloud Cloudy Days Days Month mean max min max min (mm) with >0.1 cover days with with mm (tenths) (>8.0 precip. snow tenths) from cover snow January 0.8 4.4 -2.3 17.6 -25.2 45 9.8 7.4 17.2 4.5 6.6 February 3.2 7.6 -0.9 19.5 -17.8 42 7.9 6.8 12.7 3.8 2.8 March 6.7 11.8 1.7 23.5 -13.8 47 8.2 6.6 12.8 2.9 0.6 April 12.5 18.6 6.3 29.8 -2.0 54 10.1 6.2 9.5 0.9 0 May 17.6 23.7 11.2 36.2 2.5 67 11.3 5.5 6.2 0 0 June 21.2 27.4 14.4 35.7 5.0 60 10.6 4.0 4.4 0 0 July 23.3 29.7 16.4 40.4 9.8 45 7.9 3.9 4.4 0 0 August 22.7 29.4 15.6 38.0 8.7 37 5.8 3.5 2.7 0 0 September 19.1 25.9 12.2 35.4 -1.7 36 6.2 4.0 5.6 0 0 October 13.3 19.4 7.9 31.5 -3.3 53 8.4 5.2 8.4 0.1 0 NOIIember 8.5 13.2 4.3 25.0 -9.8 52 8.6 6.3 11.8 0.8 0.2 December 3.0 6.6 -0.4 19.6 -16.5 54 9.8 7.5 16.5 3.2 3.6 Annual 12.7 - - 592 104.6 5.6 112.2 16.2 13.8 Source: Co\Ilcii for Environmental Protection - Meteorological Index for the Regime of Meteorological Elements in Water BodiesiLakes, May 1978)

Warm season

In summer the storm track shifts northward and westerly winds are more prevalent. Convection associated with frontal passages, and to a lesser extent surface heating, results in a maximum rainfall in late spring to mid summer. By late summer and early autumn the potential for preCipitation is lessened because of the domination of high pressure with little opportunity for convective conditions. The hottest recorded temperature is above 40°C.

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Winds

Regional surface wind patterns are reflected in Figure 4.1, the annual wind rose (1999-2003) for Plovdiv, (approximately 70 miles to the south west of Maritza East 1, the closest representative weather station with a continuous data record. The wind rose shows a predominance of north easterly and south easterly winds that are reflective of terrain influences. Measurements of surface wind speed and direction, sampled three times per day at the Rozov Kladenetz Lake meteorological station from 1983 to 1992, are summarized in Table 4.4 and Table 4.5 for the annual and monthly periods, respectively. These tables indicate that locally winds are generally from the north, are most predominant and occur nearly half of the time. The strongest winds are from the north and north-east and the weakest winds are from the south-west. Winds are often nearly calm (less than 1 m/s) at night, occurring here nearly a third of the time. The late autumn and early winter months have the greatest frequency of calm periods and spring and summer have the fewest calm periods. The wind direction pattern is fairly consistent among the seasons. The exception is southerly winds that are very infrequent in the summer and autumn and more than twice as frequent in winter and spring.

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FIGURE 4.1 WIND ROSE FOR PLOVDIV (1998)

N C81mhours

D <: 1.54m1s II 1.54 . 3.09 mls D 3.09·5.14 mts

5.14 - 823 mIs E D II 8.23 - 10.80 mls II > 10.BOmis

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TABLE 4.4 ANNUAL DISTRIBUTION OF WINDS AT GALABOVO

Wind direction Parameter N NE E SE S SW W NW Calm Frequency 16 15 13 3 7 3 7 5 31 Average speed (m/sec) 3.1 4.1 4.2 3.4 3.3 2.5 3.2 2.9 <1

TABLE 4.5 MONTHLY DISTRIBUTION OF WINDS AT GALABOVO (frequency per cent)

Wind direction Parameter N NE E SE S SW W NW Calm January 14 9 7 1 8 5 19 5 40 February 16 16 11 4 9 3 8 4 29 March 17 19 15 3 10 3 6 4 23 April 14 16 15 6 12 3 7 5 22 May 15 15 15 7 9 3 8 5 25 June 14 9 15 3 6 4 19 7 32 July 21 16 15 2 3 3 5 6 29 August 17 19 18 1 3 2 5 3 34 September 17 16 17 2 4 2 5 3 34 October 18 14 9 3 5 3 9 4 35 November 17 13 8 2 5 3 9 5 38 December 16 13 7 2 7 3 9 4 38

4.3.2 Ambient air quality

4.3.2.1 Applicable air quality standards

The AES-3CMaritza East 1 power project will contribute to the airborne emission of several pollutants for which ambient air quality criteria have been established by Bulgaria, the European Union and the World Bank to safeguard human health and welfare. The existing air quality regulations in Bulgaria: Regulation No 9, addresses sulphur dioxide (S02), oxides of nitrogen (No,. and N02), total carbon monoxide (CO), lead (Pb) and PM10, particulate less than 10 microns aerodynamic diameter and

PM 25, particulate less than 2.5 microns aerodynamic diameter. In addition, Ordinance No 9 sets forth ambient criteria that become increasingly restrictive between the years 2000 and 2010.

Regulation 9 standards are provided in Table 4.6. In evaluating future air quality using air dispersion modelling, these Bulgarian standards as well as European Union and World Bank ambient air quality standards will be used. These standards are summarized in Table 4.6.

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4.3.2.2 World Bank airshed characterization

The World Bank's Pollution Prevention and Abatement Handbook includes "Thermal Power Guidelines for New Plants" which establish concentration thresholds for particulate, sulphur dioxide and nitrogen dioxide, to characterize whether the ambient air quality in an airshed is degraded. The purpose of this characterization is to encourage economic development that improves the ambient air quality in areas where pollution levels are already high. Thus, proposed power plants greater or equal to 500 MW in airsheds with moderate air quality and all power plants in areas with poor air quality are subject to site specific emission offset provisions. Because the proposed power project is 670 MW, ambient concentrations exceeding the moderate air quality thresholds would trigger these guidelines. Moderate and poor air quality are defined in the World Bank as follows:

Moderate air quality is defined as follows:

3 3 3 Annual mean: PM 10 >50 I-lg/m or TSP >80 I-lg/m or S02 >50 I-lg/m (where TSP =Total Suspended Particulates)

TABLE 4.6 SCHEDULE FOR IMPLEMENTATION OF BULGARIAN, EU AND WORLD BANK AMBIENT AIR QUALITY STANDARDS

Bulgaria European Union World Bank (July 1998) (Ordinance No 9/03.05.1999) (EU 1999130/EC of 22 April 1999) Parameter Maxinum Average Average Maximum Average Average Maximum Ayerage Average single event daily annual single event daily annual single event daily annual 1-hour 24-hour 1-hour 24-hour 1-hour 24-h0ur (!igINm') (!igINm') ()Ig/Nm') (!igINm') ()Jg/Nm') ()Ig/Nm') ()JglNm') ()lgINm') ()Jg/Nm') SO, 350 125 20 350 125 20 - 150 80 exceed <24 exceed :>;3 (meet by exceed <24 exceed :$;3 (meet by times/year timesfyear t.t.2oo3) times/year timeslyear 19.7.2001) (meet by (meet by (meet by (meet by 1.1.2005) 1.1.2005) 1.1.2005) t.l.2005) 200 40 200 40 NOx 150 100 exceed <18 n~human exceed <18 n",human times/year health (meet times/year health (meet (meet by by 1.1.2010) (meet by by 1.1.2010) 1.2.2010) 30 1.1.2010) 30 NOx NOx vegetation vegetation (meet by (meet by 1.1.2002) 19.7.2001) TSP - - -- 230 80 Total suspended particulate

PM 10 50 30 50 40 150 50 Particulate exceed <35 (meeting by exceed <35 (meet by matter less timesfyear 1.1.2009) timeslyear 1.1.2005) than 10 until 2008 until 2008 microns (fllTl) exceed ~7 20 exceed '5.7 in size 20 timelyear (meet by time/year (meet by thereafter 1.12010) thereafter 1.1.2010) (meet by (meet by 1.1.2009) 1.1.2005) PM 2 !i 40 20 - - Particulate exceed :0:;14 (meet by matter less timeslyear 1.1.2009) than 2.5 (meet by microns (fllTl) 1.1.2009) in size Lead - 0.5 - 0.5 - (meet by (meet by 1.1.2005) 1.1.2005) Notes: 1. Bulgarian and European Union s1andards presented above will be phased in inaementally. The table above presents the ultimate limit that will apply and the year in which it will apply.

3 or N02 >100 I-lg/m or

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h 3 3 98 percentile 24 hour average: PMlO >150 Jlg/m or N02 . 150 Ilg/m 3 3 or S02 >150 Jlg/m or TSP >230 Jlg/m .

Poor air quality is defined as follows:

3 3 3 Annual mean: PMlO >100 Jlg/m or TSP >160 Ilg/m or S02 >100 Jlg/m 3 N02 >200 Jlg/m or

th . 3 3 95 percentile 24 hour average: PM 10 >150 Ilg/m or N02 . 150 Ilg/m 3 3 or S02 >150 Jlg/m or TSP >230 Jlg/m .

4.3.2.3 Air quality measurements and comparison to standards and guidelines

Ambient air quality has been measured for the years 1996 - 1999 at two locations in the Maritza East 1 area at Galabovo. The original monitoring site was located approximately 2 km south-west of the Maritza East 1 power plant across Rozov Kladenetz Lake, adjacent to the major roadway. In 1997, the site was moved to downtown Galabovo, approximately 2 km west-south-west of the Maritza East 1 power plant. The followin,g criteria pollutants that will be emitted from the Maritza East 1 power project were measured: non-toxic dust (TSP), sulphur dioxide (S02), nitrogen dioxide (N02), and lead (Pb). Summaries of the measurement data for each of these pollutants are provided in Table 4.7 though to Table 4.10. The tables include references to Bulgarian Standard 14 and World Bank degraded airshed guidelines.

Measurements of ambient air quality demonstrate that the air quality can be characterized as good for N02 and Pb. For S02 and TSP there are monitored exceedences in Bulgarian Standard 14 as well as the World Bank guidelines for degraded airsheds. As will be established in Section 5, future concentrations of S02 will be substantially reduced by the proposed Maritza East 3 repowering project. The issue of particulate air quality is complicated by the fact that the existing TSP standard

(Standard 14) will be replaced by standards for PMlO and PM 2.5. As noted below, fugitive dust appears to be the main contributor to the measured TSP concentrations. Because only a minor fraction of fugitive dust may be smaiL particles, the present air quality with respect to PM 10 and PM 2.5 is uncertain.

TABLE 4.7 SUMMARY OF PARTICULATE MEASUREMENTS AT GALABOVO

3 Year Exceedances of standard 14 (250 I19/m ) Annual concentration* (119 /m 3) 24 hour limit 1996 110 246 1997 26 155 1998 51 195 1999 (Jan-Sept) 1 146

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TABLE 4.8 SUMMARY OF SULPHUR DIOXIDE MEASUREMENTS AT GALABOVO

Year Exceedances of standard 14 Maximum 30 minute Annual concentration 3 3 (150 /1g/m ) concentration (/1g/m 3) (J19/m ) 24 hour limit 1996 69 1000 130 1997 47 868 115 1998 55 441 127 1999 (Jan-Sept) 11 316 117

TABLE 4.9 SUMMARY OF NITROGEN DIOXIDE MEASUREMENTS AT GALABOVO

Year Exceedances of standard 14 Maximum 30 minute Annual concentration 3 3 (100 /1g/m ) concentration (/1g/m 3) (J19/m ) 24 hour limit 1996 0 36 9 1998 0 90 10 1999 (Jan-Sept) 0 116 12

TABLE 4.10 SUMMARY OF LEAD MEASUREMENTS AT GALABOVO

3 3 Year Exceedances of standard 14 (1 /1g/m ) Annual concentration (J19/m ) 24 hour limit 1996 0 0.1 1998 0 0.14 1999 (Jan-Sept) 0 0.13

Particulate (TSP)

Concentrations exceed the then applicable Bulgarian Standard 14 (now superseded by Ordinance 9) as well as World Bank degraded airshed criteria. Table 4.7 indicates that since 1996, TSP concentrations measured at the Galabovo site have decreased considerably. The decreasing values are partially reflective of the fact that the TSP monitoring was relocated from a site that was strongly influenced by dust generated by vehicular traffic to a site that is further away from the main highway. However, the present site is still located in a heavily travelled area. There is also evidence that fly ash from the existing Maritza East 1 power plant may contribute to ambient dust concentrations locally. As such, the current reported concentrations of particulate are also likely to overestimate the actual concentrations present in the general area.

Evidence that concentration levels are not representative of the entire region is provided by concurrent ambient measurements at Mednikarovo (approximately 10 km east of the Maritza East 1 power plant) which over the same 4 year period did not exceed either the Regulation 14 24 hour or annual criteria. Dispersion modelling investigation has determine that the present emissions from the Maritza East 1 stack contribute less than 1 per cent of the ambient concentration in Galabovo.

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Moreover, as noted in the previous section, TSP is no longer considered a pertinent parameter to evaluate the potential health effect of particulate because it includes large particulates that cannot be inhaled. Given the poor siting of the Galabovo measurement station, and the lack of PM10 or PM 25 measurements, the characterization of ambient particulate concentrations and sources contributing to air quality in the vicinity of the Maritza East 1 power station are somewhat uncertain.

Sulphur dioxide

Table 4.8 shows that while there has been a noticeable decrease in ambient S02 concentrations from 1996 to 1999, measured concentrations at Galabovo were still above the 24 hour standard set forth in the then applicable Bulgarian Regulation 14 of 150 jlg/Nm3 (now replaced by the harsher limit of 125 jlg/Nm3 set in Regulation 9) as well as the degraded airshed guidelines set by the World Bank. The existing Maritza East 1 power plant is a major contributor to the ambient S02 concentrations in the Galabovo area, although all three Maritza East power plants contribute to the regional S02 air quality. The proposed project to replace current generating capacity with cleaner power plants in the Maritza East area will result in lower S02 emissions and improve ambient air quality.

Nitrogen dioxide

As shown in Table 4.9, ambient concentrations of N02 are comfortably below the Regulation 14 standard and the World Bank thresholds. As such, air quality is characterized as good with regard to this pollutant. Given the expected level of emissions and dispersion associated with the Maritza

East 1 power project, it is anticipated that this characterization of ambient N02 concentrations will not be affected.

Lead

The measurement data in Table 4.10 indicate that ambient concentrations of Pb are well below Regulation 9. As such, air quality is characterized as good with respect to this pollutant. As with nitrogen dioxide, given the expected level of emissions and dispersion associated with the Maritza East 1 power project, it is anticipated that the characterization of lead concentrations will not be affected.

Carbon monoxide

Carbon monoxide is the only criteria pollutant which has not been routinely measured in the area. Given that high ground level concentrations have historically been associated with urban traffic congestion, it is likely that concentrations of CO in the region are well below applicable standards. Moreover, the rate of emission and dispersion of the AES-3C power project is not expected to contribute significantly to ambient concentrations of this pollutant.

4.4 Surface water resources

The Maritza East coal mines and surrounding Maritza East power plants (Maritza East 1, 2 and 3) are 2 all located within the 3293 km Sazlijka River basin. The source of the Sazlijka River is a series of springs located at the foothills of the Sredna Gora Mountains. The river has two main branches, the Sjujutlijka Branch to the west and the Sazlijka Branch to the east, that converge to form the main Sazlijka River to the south of the town of Radnevo. The main river continues flowing to the south,

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eventually discharging to the larger Maritza River south of the town of Simeonovgrad. The two branches of the river and main river have a total length of 145 km.

The Sazlijka River is joined by numerous smaller tributaries. In the general vicinity of the AES-3C Maritza East 1 project area, the two principal tributaries are the Ovacharitsa River (an east to west flowing river that enters the Sazlijka River approximately 8 km upstream of the town of Galabovo) and the Sokolitsa River (an east to west flowing river at the southern limits of the town of Galabovo). The confluence of the Sokolitsa River with the Sazlijka River is approximately 16 km upstream of the confluence of the Sazlijka River with the Maritza River.

When the existing Maritza East 1 power plant was constructed in the early 1960s, an artificial cooling water reservoir was constructed by damming the Sokolitsa River and diverting its flow, forming what is 2 3 today referred to as Rozov Kladenetz Lake, a 3.6 km (18.6 million m capacity) surface water impoundment located directly south of the existing power plant (see FIGURE 4.2). Rozov Kladenetz Lake has since served as the once-through cooling water and fire water reservoir for the power plant. Water has been withdrawn from the lake at ambient temperatures and has been return to the lake as heated discharge. The water level in the existing lake has been maintained by diverting a portion of the flow from the Sokolitsa River (when sufficient flow is available, often for as much as six months of the year) and by pumping water from the Sazlijka River. Since its construction, in addition to serving as the cooling water/fire water reservoir for the power plant, the lake has become an important natural resource, supporting both recreational and commercial fisheries and serving as a gathering point for migratory birds.

4.4.1 Stream flow

The Bulgarian National Institute of Meteorology and Hydrology (NIMH) is responsible for the collection of stream flow data and maintenance of stream flow records. NIMH has developed stream elevations/discharge relationship curves for 236 stream flow measurement stations. Twice each day (morning and evening), stream elevation measurements are recorded (by visual observations of a staff gauge placed in the stream) and daily average stream flow estimates are recorded.

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ROZOV KLAOENETZ LAKE

AE8-3C FIGURE 4.2 DR PBPower MARITZA EAST I POWER PLANT SURFACE WATERS -.ji - PBPower Section 4 Page 15

Stream flow is measured at several locations in the Sazlijka River basin, including the three stream flow stations presented in Table 4.11. Stream flow station No 305 is located on the west branch of the Sazlijka River (the Sjujutlijka Branch) near the town of Rakinitza, approximately 80 km upstream of the town of Galabovo. Observed stream flow at this station is less impacted by the upstream withdrawals than the stream flow at the other two stations shown in Table 4.11, and is more representative of "natural" stream flow conditions in the basin. Stream flow station No 342, the station closest to the project area, is located at a roadway bridge crossing, downstream of the power plants Sazlijka River pump station but upstream of the town of Galabovo (approximately 19 km upstream of the Sazlijka River's confluence with the Maritza River). Stream flow station No 320 is located just upstream of the confluence of the Sazlijka River with the Maritza River, at a bridge crossing east of the town of Simeonovgrad.

TABLE 4.11 STREAM FLOW DATA FOR SAZLlJKA RIVER 1954 TO 1995

Measurement station Catchment Mean flow Stream flow to Q75% Q9O"h Q95% area drainage area ratio 2 3 3 3 3 (km ) (m Is) (litre/sec per km) (m Is) (m Is) (m Is) Sazlijka River (Sjujutlijka 346 1.454 4.202 0.657 0.341 0.221 Branch) at Rakinitza (No 305) Sazlijka River at 3040 9.738 3.203 5.775 3.846 2.882 Galabovo (No 342) Sazlijka River before 3293 10.410 3.161 6.173 4.112 3.081 confluence with Maritza River (No 320)

Notes:

1. 0,5% is equal to the flow in the Sazlijka River that is exceeded 75% of the time. 0 90% and 0 95% are similarly defined. 2. Source: NIMH stream ftow data as report in Energoproekt, 1999

The flow statistics presented in Table 4.11 were collected over a 41 year time period, from 1954 to 3 1995. The average stream flow in the river near Rakinitza is 1.454 m /s and the stream flow to 2 2 catchment area ratio (based on a 346 km catchment area) is 4.202 I/s/km . As expected, the average stream flow observed 80 km downstream at Galabovo is greater (9.738 m3 /s ), however the stream flow to catchment area ratio at Galabovo is 25 per cent less. This reduced value is primarily attributable to the Sazlijka River pump station's diversion of river water to maintain the water level in Rozov Kladenetz Lake and for use as process water in the existing Maritza East 1 power plant. The pump station is located several hundred metres upstream of the Galabovo stream flow measurement station, effectively reducing the stream flow measurements taken at the station.

A representative "low flow" value in the river is the 95th percentile low flow. It is estimated based on a record of stream flow measurements as the flow which, statistically, is exceeded 95 per cent of the 3 time. The 95th percentile low flow of the Sazlijka River at Galabovo is 2.882 m /s. At approximately 30 per cent of the average value, this indicates that historically, the Sazlijka River has continued to flow even under the driest conditions.

3 Average stream flow at the confluence with the Maritza River (near Simeonovgrad) is 10.45 m /s. The 2 stream flow to catchment area ratio is less than at Galabovo (3.161 I/s/km as compared to 2 3.203 I/s/km at Galabovo), primarily due to seasonal diversions of flow from the Sokolitsa River

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watershed into Rozov Kladenetz Lake. As at Galabovo, the Q95% flow near the confluence with the Maritza River is approximately 30 per cent of the average flow, indicating consistent flow in the river, even under dry conditions.

Figure 4.3 presents average monthly stream flow values for the Galabovo stream flow station, computed for a 20 year period (1976 to 1996). This figure shows that stream flow varies during the year, but is typically highest during the late winter and early spring (February and March) and is typically at its lowest during late autumn and early winter (September through November). The highest flows are associated with the combined factors of late winter snow melt and early spring rainfall. The lowest flows observed in October follow the two late summer months (August and September) with typically the lowest rainfall and highest evaporation rates.

4.4.2 Water quality

Bulgarian Ordinance No 7 (Indicators and Standards Applied in Assessment of Running Surface Water Quality; dated 8 August 1986) classifies surface water in one of three categories, based on the results of water quality analysis for a detailed list of parameters. While the title of the regulation indicates that it applies to "running" surface water, Article 1 of the Ordinance indicates that the standards also apply to lakes and reservoirs. Table 4.12 presents the (14.05.1999) Bulgarian ambient water quality standards. In addition to serving as ambient standards, Ordinance No 7 indicates that these limits are to be maintained downstream of a discharge "after effluents have been released" to a running water (ie after mixing). In practice, the Ministry of Environment and Waters has used these ambient criteria as "end-of-pipe" effluent limits and assessed fines accordingly. A new Bulgarian water law became effective on 29 January 2000, but promulgation of formal "effluent limits" is not expected until late 2000 or early 2001.

All surface waters in the vicinity of the project site (Sazlijka River, Sokolitsa River, and Rozov Kladenetz Lake) have been classified as Class III waters, indicating that they are generally suitable for irrigation and industrial use, but not suitable for use as a drinking water supply. The Regional Inspectorate of Environment and Water (RIEW - Stara Zagora) maintains records of monthly water quality data at several locations in the Sazlijka River watershed. Two of the locations monitored are in the same area as the NIMH stream flow measurement stations: Station 342 (Sazlijka River at Galabovo) and Station 320 (Sazlijka River at confluence with the Maritza River). Table 4.13 and Table 4.14 present 12 months of water quality data for the respective monitoring stations for 1999.

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Figure 4.3 Surface waters in the vicinity of existing Maritza East 1 power plant

Sazlijka River at Galabovo Streamflow Monthly Averages -1976 tb 1996

18 , i 16 j i I -(/) 14 i -E 12 J -~ 10 o I E -m C1) lo.. : I CJ)- : I I o i J F M A M J J A SON D Month

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TABLE 4.12 BULGARIAN WATER QUALITY STANDARDS (ADMISSIBLE POLLUTION RATES OF VARIOUS CATEGORIES OF RUNNING SURFACE WATERS)

Item Indicators Measure Category No Unit I II III Group A: General physics and inorganic chemistry indicators 1. Temperature ·C Not exceeding the average seasonal temperature by more than 3·C 2. Colour Degrees No visible additional colouring at 20·C 3. Smell Force 2 3 3 4. Active reaction pH 6.5-8.5 6.0-8.5 6.0-9.0 5. Oxygen saturation % 75 40 20 6. Electric conductivity "Stcm 700 1300 1600 7. Dissolved oxygen mg/l 6 4 2 8. Dissolved substances mg/l 700 1000 1500 9. Suspended matter mg/l 30 50 100 10. Total hardness meq/l 7 10 14 11. Chloride ions mg/l 200 300 400 12. Sulphate ions mg/l 200 300 400 13. Hydrogen sulphide (free) mg/l n.a. n.a. 0.1 14. I ron (total) mgll 0.5 1.5 5 15. Manganese (total) mgll 0.1 0.3 0.8 16. Nitrogen (ammonia) mg/l 0.2 2.0 5 17. Nitrite nitrogen mgll 0.002 0.04 0.06 18. Nitrate nitrogen mgll 5 10 20 19. Phosphates (P04) mgll 0.2 1.0 2 20. Phosphorous (total content as P04) mgll 0.4 2.0 3 21. Selenium mgll 0.Q1 0.01 0.01 22. Beryllium mgll 0.0001 0.0002 0.002 23. Vanadium mg/l 0.1 0.01 1 24. Molybdenum mgll 0.5 0.5 3 25. Barium mgll 1 1 1 26. Boron mgll n.a. n.a. 1 27. Silver mg/l 0.Q1 0.01 0.01 28. Uranium mg/l 0.6 0.6 0.6 29. Radium 226 mBq/l 150 150 150 Group B: General indicators of organic pollutants 30. Organic non-dissolved matter mgll 5 15 25 31. Oxygen demand (permanganate) mgll02 10 30 40 32. COD (bichromate) mgll 25 70 100 33. BOD5 mgll 5 15 25 34. Dissolved organic carbon mgll 5 12 20 35. Extractable species (with tetrachloromethane) mgll 0.5 3 5 36. Organic nitrogen mgll 1 5 10 Group C: Indicators of inorganic industrial pollutants 37. Mercury mg/l 0.0002 0.001 0.001 38. Cadmium mg/l O.OOS 0.01 0.02 39. Lead mgtl 0.02 0.05 0.2 40. Arsenic mg/l 0.02 0.05 0.2 41. Copper mgll 0.05 0.1 0.5 42. Chromium (trivalent) mg/l 0.1 0.5 1 43. Chromium (hexavalent) mgll 0.02 0.05 0.1 44. Cobalt mg/l 0.02 0.1 0.5 45. Nickel mgll 0.05 0.2 0.5

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Item Indicators Measure Category No Unit I II III 46. Zinc mg/l 1 5 10 47. General beta-activity mBq/1 750 750 750 48. Cyanides (highly degradable) mg/l n.a. 0.05 0.1 49. Cyanides (total) mg/l n.a. 0.5 1.0 50. Fluorides (total) mg/l 0.5 1.5 3 51. Free active Chlorine mg/l n.a. 0.05 0.1 Group 0: Indicators of industrial organic pollutants 52. Anionoactive detergents mg/l 0.5 1 3 53. Phenols (volatile) mg/l 0.Q1 0.05 0.1 54. Oil products mg/l n.a. 0.3 0.5 55. Aldrine mg/l 0.0002 0.0002 0.0002 56. Pirydine mg/l 0.2 0.2 0.5 57. Xanthogenates mg/l 0.001 0.01 0.1 58. Saponines mg/l 0.2 0.2 1 59. Styrene mg/l 0.1 0.2 0.5 60. Benzene mg/l 0.5 0.5 1 61. Formaldehyde mg/l 0.5 0.5 1 62. Caprolactam mg/l 1 1 1 63. Phthalic acid mg/l 0.1 1 5 64. Phenitrotione (Agria 1050) mg/l 0.0001 0.0001 0.3 65. Zolone (Agria 1060) mg/l 0.0001 0.0001 0.002 66. Saturnine mg/l 0.1 0.1 1 67. Atrazine (Ceazine) mg/l 0.25 0.25 2.5 68. Lasso mg/l 0.3 0.3 0.5 69. 2,4 D mg/l 1 1 5 70. Sevine (Decarbam) mg/l 0.002 0.002 0.1 71. Vinyl chloride mg/l 0.Q1 0.01 0.01 72. Dichlorethane mg/l 1.5 1.5 1.5 73. Aphalone mg/l 0.5 1.0 1.0 74. Pathorane mg/l 0.2 2.0 2.0 75. Dimyde mg/l 1.0 1.0 5.0 76. Ramrod mgll 0.5 0.5 1.0 77. Treflane mg/l 1.0 1.0 5.0 78. Propanide mg/l 0.1 1.0 2.0 79. Diphezoquate mgll 0.2 1.0 5.0 Group E: Biological indicators SO. Saprobacity Olygo beta-mezo alfa-mezo Pantle-Book Index <1.5 <2.5 <3.2 Zelenika-Marvan-Rotstein Index >60 >40 >25 81. Species variety of the macrozoobenthos (by Shannon) >3 >2 >1 82. Macrozoobenthos equalization degree >0.7 >0.6 >0.5 83. Macrozoobenthos domination degree <0 .. 2 <0.3 <0.5 84. Micro-organism total (direct count) 6 6 6 3 85. Total coli-t~re cm <0.1 <0.1 <0.001 o 86. Escherichia-coli-titre-thermoresistant cm <1.0 <1.0 <0.01 87. Pathogenic micro-organisms n.a. n.a. n.a. Notes: 1. n.a. = not admissible 2. source: Bulgarian Ordinance No 7 on Indicators and Standards Applied in Assessment of Running Surface Water Quality

Document No. 6216OA1PBP/OOOOOl 0774R040.DOC/S1/19M1 TABLE 4.13 ;g SAZLlJKA RIVER AT GALABOVO - 1999 WATER QUALITY DATA "3 ~ Date Units 18Jan 15 Feb 22 Mar 19 Apr 17 May 21 June 20Jul 23 Aug 20 Sap 19 Oct 8 Nov 13 Dec Mean Min Max ., Temperature "C 6.1 7.1 12.3 17.8 22.3 24.0 23.0 23.3 20.0 13.8 130 10.3 16.1 6.1 24.0 pH S.u. 8.09 8.18 8.12 8.14 7.53 7.49 7.60 7.43 7.80 7.82 7.83 8.03 7.84 7.43 8.18 Dssolved oxygen mgtlo, 7.1 7.4 6.5 4.6 4.0 4.4 5.0 3.5 3.5 6.1 5.9 7.4 5.5 3.5 7.4 Oxygen sat. '10 60 68 62 56 44 59 62 43 40 55 57 61 55.6 40.0 68.0 Conductivity !-,Stcm 945 761 950 854 685 1046 870 1030 1115 1190 1392 827 972.1 685.0 1392.0 BODs mgn 18.14 14.15 17.80 15.72 0.00 17.00 19.45 11.22 0.00 9.60 17.22 16.20 1304 000 19.45 Oxygen demand mgn 0, 8.16 8.64 9.40 11.84 48.80 4.48 9.92 6.16 6.08 9.76 7.92 7.20 11.9 6.1 48.8 (permanganate) COD mgtl 30.1 16.2 30.8 24.0 89.8 36.3 43.7 00 24.9 49.6 46.7 21.7 34.5 0.0 89.8 ! Dissolved solids mgn 624 506 646 586 476 750 624 738 772 872 1048 550 682.7 467.0 1048.0 Suspended solids mgn 34 92 59 90 323 52 89 47 81 27 12 20 77.2 12.0 323.0 Chloride ions mgtl 36.20 27.10 39.60 32.97 27.04 36.26 34.29 46.50 43.52 46.82 51.43 24.13 37.2 24.1 51.4 Sulphate ions mgn 224.0 198.0 254.0 213.0 147.0 293.0 65.5 238.0 262.0 275.0 439.0 190.0 234.0 65.5 439.0 Ammonia nitrogen mgtl 1.30 0.97 1.76 1.20 0.99 1.06 1.10 1.46 1.65 0.86 2.06 1.02 1.29 0.86 2.06 Nitrite nitrogen mgn 0..110 0..0.90. 0..130. 0..188 0..280. 0..370. 0..270 0..340. 0..350 0..230. 0..260. 0..160. 0..23 0..0.9 0..37 Nitrate nitrogen mgn 4.72 3.54 3.95 3.97 1.92 2.58 2.64 2.23 4.17 2.53 3.32 2.63 3.18 1.92 4.72 Phosphates mgn 1.0.5 0..61 0..78 1.0.3 1.15 1.67 2.30 1.91 2.03 1.61 2.48 1.20 1.49 0.61 2.48 Cyanide mgtl - absent - absent - absent - Phenols mgtl - absent - 0.04 absent absent absent absent 0.040 Oils mgtl absent absent absent absent absent absent absent absent absent absent absent absent absent absent absent Detergents mgtl - absent - 0.14 absent absent absent 0.140 Iron mgn 0.380 - 0.257 - 0.221 - 0.190 - 0.262 0.190 0.380 Manganese mgtl 0.033 - 0.061 - - 0.107 0.196 0.099 0.033 0.196 cadmium mgtl 0.002 0.002 - 0.001 - - - 0.002 0.001 0.002 Lead mgtl - 0.005 - 0.005 0.013 - - 0.018 0.010 0.005 0.018 Copper mgtl - 0.006 - 0.002 0.007 - - 0.017- 0.008 0.002 0.017 Trivalent chromium mgtl - absent - - absent absent - - absent - absent absent absent Hex. chromium mgtl absent - absent absent - - absent - absent absent absent Nickel mgn 0.004 - 0.007 0.050 0.022 - 0.021 0.004 0.050 Zinc mgtl 0.015 - 0.037 0.018 0.042 - 0.028 0.015 0.042 Total micro-org. 77000 130000 160000 46000 270000 110000 26300 13000 200000 1500000 143230 13000 1500000 Total coli-titre em' - 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.010 0.010 0.010 0.004 0.001 0.010 i Esh-coli-titre em' - 0.010 0.001 0010 0.00.1 0.010 0.001 0.001 0010 0010 0.;010 0.006 0.001 0010 ~ Pathog.miero-org - - absent - absent absent absent absent absent absent absent absent absent absent absent ..,,,~'" Source: R1EW-Stara Zagora -ug> Ql 0 ~~ (C ~" CD 0= 8:~ IV:;:' t~~ O.l>. TABLE 4.14 til SAZLlJKA RIVER AT MARITZA CONFLUENCE -1999 WATER QUALITY DATA ~ ~ Date Units 18Jan 15 Feb 22 Mar 19 Apr 17 May 21 June 20Jul 23 Aug 20Sep 19 Oct 8 Nov 13 Dec Mean Min Max ~ Temperature 'C 5.9 7.8 12.0. 18.1 23.6 25.0. 23.6 24.4 20..0. 14.4 12.7 10..3 16.5 5.9 25.0. pH s.u. 8.0.7 8.16 8.09 8.20. 7.52 7.55 7.61 7.43 7.89 7.84 7.84 8.0.8 7.86 7.43 8.20. Dissolved oxygen mgll 7.1 8.2 7.0. 5.6 3.2 4.3 5.4 3.4 4.2 6.1 5.6 6.6 5.6 3.2 8.2 Oxygen sat. % 59 74 68 61 39 54 65 42 48 61 53 68 57.7 39.0. 74.0. Conductivity f'S/cm 999 759 833 910. 829 10.64 899 10.90. 1140. 1330. 1436 857 10.12.2 759.90. 1436.0. BOD, mgn 14.83 5.12 12.70. 13.38 0..0.0. 20..33 21.31 10..95 0.00 12.70. 15.0.4 15.82 12.9 0..0. 21.3 Oxygen demand mgll 7.60. 9.12 4.90. 12.00 25.30. 8.00 10..56 60.8 5.68 6.80. 7.60. 7.04 9.2 4.9 25.3 (permanganate) CCD mgll 24.8 20..2 35.3 18.5 41.0. 41.2 56.3 0..0. 21.2 34.7 47.1 29.3 33.6 18.5 56.3 Dissolved solids mgn 690 536 576 628 594 774 638 832 816 10.0.4 10.91 540. 726.6 536.0. 10.91.0. Suspended solids mgn 46 60. 51 77 161 68 113 79 91 24 27 62 71.6 24.0. 161.0. Chloride ions mgll 36.60. 27.10. 33.00 32.97 31.65 39.56 34.29 35.80. 44.84 51.43 52.42 32.97 37.7 27.1 52.4 Sulphate ions mg/l 244.0. 214.0. 228.0. 246.0. 198.0. 302.0. 64.2 255.0. 247.0. 30.0..0. 468.0. 20.8.0. 247.9 64.2 468.0. Ammonia n~rogen mgll 0..87 0..70. 1.29 0..61 0..78 0..47 0..19 0..84 1.15 0..43 0..70. 0..74 0..73 0..19 1.29 Nitrite nitrogen mgn 0..100 0..0.70. 0..090. 0..159 0..270. 0..250. 0..160. 0..260. 0..230. 0..150. 0..180. 0..135 0..17 0..0.7 0..27 Nitrate nitrogen mg/l 4.51 3.85 3.92 5.60. 2.56 3.48 3.24 2.98 4.0.5 2.94 4.0.3 2.66 3.65 2.56 5.60. Phosphates mgn 1.0.9 0..56 0..58 0..58 0..97 1.14 1.68 1.94 2.0.1 1.93 2.0.1 1.11 1.39 0..56 2.0.1 Cyanide mgll absent - absent absent absent - 0..0.0. 0..0.0. Phenols mgll absent - 0..03 absent absent 0..0.3 0..0.3 Oils mgll absent absent absent absent absent absent absent absent absent absent absent absent 0..0.0. 0..0.0. Detergents mgll absent - 0..06 absent absent 0..0.6 0..0.6 Iron mgn 0..840. - 0..195 0.000. 0..187 0.20.0. 0..284 0..0.00 0..840.; Manganese mgll - 0..0.37 - 0..0.38 0..0.73 - 0.155 0..0.76 0..0.37 0.155 Cadmium mgil 0..0.0.1 - 0..0.0.1 0..0.0.2 0..001 0..0.0.1 0..0.0.2 Lead mgll 0..0.0.6 - 0..004 0..0.17 - 0..0.18 0..0.11 0..004 0.018 Copper mgll 0..0.0.5 - 0..0.0.2 0..0.0.8 - 0..0.13 0..007 0..0.0.2 0..0.13 Trivalent chromium mgll absent - absent - absent absent absent absent absent Hex. chromium mgil - absent - absent - absent - absent - absent absent absent Nickel mgn 0..0.0.2 - - 0..0.0.7 0..0.25 0..0.10. - 0..0.11 0..0.0.2 0..0.25 Zinc mgll 0..0.13 - 0..0.31 - 0..0.20. 0..0.25 0..0.22 0..0.13 0..0.311 Total micro-org. - 840.00 150000. 20.0.000. 11500 330.0.00 160.0.0.0. 63600 120.00 1650.0.0. 170.0.0.0.0. 287610. 1150.0. 17000.0.0. Total coli-t~re cm' 0..001 0..0.0.1 0..0.0.1 0..0.10. 0..0.0.1 0..10.1 0..0.10. 0..0.10. 0..0.10. 0..0.0.1 0..006 0..0.0.1 0.0.10., Eseh-coli-titre em' - 0..001 0..0.0.1 0..0.0.1 0..0.10. 0..001 0.0.10 0..0.10. 0..0.10. 0..0.10 0..0.10. 0..006 0..0.0.1 0.0.10.: Pathog.micro-org. absent absent absent absent absent absent absent absent absent absent absent i~ p Source: RIEW-Stara Zagora -oW Q) 0 ~~ (Q ;om""~ ~ (J) 0 I\J~ 0.",*~ ~~ 8." ~§ ~~ PBPower Section 4 Page 22

A review of the annual average values for the various parameters indicates that, on average, the river generally meets Class II requirements, expect for biological parameters. The average total micro organism count of 287 610 and 253 320, at Galabovo and at the confluence with the Maritza River far exceed the 6 organisms standard. Biological contamination is a result of the discharge of untreated sanitary sewage to the river, both locally and extending to the upstream cities of Stara Zagora and Nova Zagora. A review of monthly data indicates that dissolved oxygen levels in the river can decline significantly during the late spring and summer months. Dissolved oxygen at both measurement stations was at or below 4 mgtl (the Class II standard) during May and August. The biological contamination and the decline of dissolved oxygen concentrations during the summer months are likely primarily responsible for the Class III designation of the river.

A comparison of the Galabovo data with the downstream Maritza confluence data does not indicate a significant difference in water quality between the two locations. While total dissolved solids and conductivity tend to be slightly greater at the downstream station (typically around 5 per cent greater) than at Galabovo, this difference is not significant.

RIEW does not regularly collect water quality data in the Sokolitsa River or in Rozov Kladenetz Lake. Consequently, a long term continuous time series of water quality data is not available for these water bodies. Table 4.15 presents water quality data collected as a one-time effort by RIEWat Rozov Kladenetz Lake, the Sokolitsa River upstream and the Sazlijka River, and the Sazlijka River downstream of the Sokolitsa River. The data was collected on 9 June 1999. The data indicates that the lake and the Sokolitsa River have a water quality generally similar to that of the Sazlijka River. The conductivity, total dissolved solids, and sulphate concentrations of the Sokolitsa River are elevated due to waste water discharges, cooling tower blowdown discharges, and ash pond overflows from the upstream Maritza East 3 power plant. Since the Sokolitsa River is diverted direct into Rozov Kladenetz Lake (occurring typically 6 months each year), the lake similarly has elevated dissolved solids, conductivity, and sulphate concentrations. Although biological monitoring was not performed, it is expected that untreated sanitary discharges from the Maritza East 3 plant result in a Sokolitsa River water quality similar to that of the Sazlijka River.

4.4.3 Rozov Kladenetz Lake temperature

As a man-made reservoir, Rozov Kladenetz Lake is relatively shallow, reaching a maximum depth of 7 m near its centre. Consequently, the discharge of heated cooling waters to the lake has resulted in elevated water temperature that extends for the full depth of the water column. This elevated temperature has created an artificial environment which has benefited the local ecosystem. The warm waters have expedited the maturation process of fish in the lake, creating a productive fishery for recreational purposes and facilitating the operation of a commercial fish farm operation along the northern shoreline. The elevated water temperatures typically have prevented the lake from freezing over during the winter which, combined with the presence of a thriving fish population, has made Rozov Kladenetz Lake a popular gather place for migratory birds.

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TABLE 4.15 WA TER QUALITY DATA ROZOV KLADENETZ LAKE, SOKOLITSA RIVER AND SAZLlJKA RIVER

Parameter Units Sokolitsa River Rozov Kladenetz Sazlijka River upstream of Lake downstream of Sazlijka River (collected at dam) Sokolitsa River (downstream of Maritza East 3) pH S.u. 8.0 9.9 7.64 Dissolved oxygen mg/l 02 5.8 11.2 5.7 Oxygen saturation % 68.0 139.0 64.0

Conductivity !!S/cm 1460 889 1018 8005 mgll 2.8 5.9 8.5 Oxygen demand (permanganate) mgll 02 4.5 5.4 7.6 COD mg/l 10.4 11.5 13.6 Dissolved solids mg/l 1202 648 794 Suspended solids mg/l 17 24 107 Ammonia nitrogen mg/l 0.14 0.1 0.73 Nitrite nitrogen mg/l 0.93 0.94 0.235 Nitrate nitrogen mg/l 1.62 0.9 2.7 Sulphate mg/l 531 287 220 Petroleum products mg/l not detected not detected not detected Manganese mg/l 0.001 0.003 0.036 Copper mg/l 0.013 0.010 0.002 Lead mg/l 0.006 0.Q14 0.005 Chromium (total) mg/l not detected not detected not detected Nickel mg/l 0.008 0.006 0.003 Zinc mg/l 0.048 0.039 0.079 Cadmium mg/l 0.001 0.002 0.002 Iron mg/l 0.06 0.06 0.11 Note: Sampling and analysis conducted by RIEW - 9 June 1999

Figure 4.4 presents average monthly water temperature data for Rozov Kladenetz Lake and for several other water bodies located in south-eastern Bulgaria. Temperature readings were taken at around 8:00 am each day for a 16 year period from 1960 to 1976 and the average monthly data was reported in the Meteorological Index for the Regime of Meteorological Elements in Water Bodies and Lakes (Committee for Environmental Protection of the Ministries of Bulgaria, 1978).

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FIGURE 4.4 COMPARISON OF AVERAGE WATER TEMPERATURE OF LAKE ROZOV KLADENETZ AND OTHER SURFACE WATERS IN SOUTH-EASTERN BULGARIA

Rozov Kladenetz Lake Water Temperature Data (1960-1976)

Rozov Kladenetz Lake Water Temperature

30 U ..2. 25 Gl :; 20 1Q ~ -Surface ~ 15 E - 5 meters ~ 10

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Water Temperature at 5m Depth

-+-Rozov Kladenetz , Ovcharista Ivajlovgrad Studen Kladenec

M J J A S o N D Document No. 62160AlPBP/oOOOO1 on4R040 OOClS31291CH PBPower Section 4 Page 25

The first graph in this figure demonstrates the minimal difference between water temperature at the surface and at a depth of 5 m in Rozov Kladenetz Lake. Typically, the water surface is no more than 0.5 to 1.5°C warmer than water at a depth of 5 m. The average monthly temperature value at 5 m for the month of November is not believed to be accurate (an apparent transcription error), but is shown because no alternate estimate is available. This data indicates that the lake is too shallow for any significant thermal stratification to occur.

The bottom two graphs of Figure 4.4 provide a comparison of the average water temperature of Rozov Kladenetz Lake with three other surface waters in south-eastern Bulgaria. Ovacharitsa Lake, located approximately 20 km to the north-east of Rozov Kladenetz Lake, is similar in that it also has served as a cooling water reservoir for a power plant (Maritza East 2). Studen Kladenec Lake and Ivajlovgrad Lake are both surface impoundments located along the Ardes River, approximately 70 km south of Rozov Kladenetz Lake. The two graphs clearly demonstrate that water temperatures in the lakes receiving heated cooling water are consistently higher than lakes under "natural" conditions. Rozov Kladenetz Lake temperatures are generally slightly higher (typically by 2°C) than Ovacharitsa Lake temperatures, likely due to the smaller size of the lake. Rozov Kladenetz temperatures are significantly higher (typically by 2 to 4.5°C) than those of the "natural" lakes.

4.5 Ground water resources

While regional ground water resources of the Sazlijka River basin yield sufficient water to support community water supply systems, agricultural uses, and small commerciallindustrial uses, the regional aquifer has sufficient yield/capacity to support the significant process and cooling water demands of the local power generating facilities. Ground water flow in the basin generally follows surface topography, flowing from upland areas towards the lower lying surface waters. In the vicinity of the project site, ground water is approximately 6 m below the ground surface and generally flows from north to south, in the direction of the Sokolitsa River. At the western and north-western limits of the project property, there is likely an east to west component of ground water flow, toward the Sazlijka River.

Table 4.16 presents the surficial geology of the project area (as discussed previously in Section 4.1) as it relates to hydro-geological and water supply issues. The clayey nature of the overburden soils in the Sazlijka River basin dominates the availability of ground water in the region. Although permeable alluvial deposits (hydraulic conductivity estimated from 30 to 80 m/day) exists in an approximately 2 km wide corridor along each of the local rivers, these deposits are thin (typically less than 6 m) and shallow. Since these units are hydraulically connected to the surface water bodies, the quality of water withdrawn from the unit is typically degraded.

Interbedded sand layers in the upper tertiary and in the sub-coal layers are sufficiently permeable (hydraulic conductivity 1 to 14 m/day) to meet municipal, domestic, and irrigation demands, but would not be capable of consistently yielding the quantities of water required to support a power generating facility. Water in sand and gravel deposits located at the top of the weathered gneiss bedrock unit is generally under pressure (a semi-confined unit) and can yield a Significant supply of water (hydraulic conductivity anticipated to be 1 to 10m/day), however the depth of the unit below the ground surface limits the use of this unit.

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TABLE 4.16 HYDRO-GEOLOGIC PROPERTIES OF REGIONAL AQUIFER

Geologic unit Typical depth Description Estimated hydraulic Water supply range conductivity potential (metres below (m/day) ground surface) Alluvial Oto 10 Present only in the immediate vicinity of 30 to 89 in sand and Unn too thin to yield deposits the Sazlijka, Sokolitsa and OVacharnsa gravel Significant water. Rivers, an alluvial unit consisting of Unit connected to 3-4 m of sandy clay over 5 to 6 m of potentially polluted sand and gravel surface waters

Upper tertiary Oto 40 Dominated by sandy clays with <0.5 in clays; sand Specific sand layers interbedded sand layers layers average 1 to 2 can serve domestic but can approach 10 and irrigation applications

Coal 40 to 80 Thick grey/black silty clay containing <0.5 Insufficient yield and clayey lignite coal layers of varying water quality issues quality (dissolved solids, sulphate) Sub-coal 80 to 280 Light brown sandy clay and silty clay. <0.5 in clays; sand Specific sand layers Interbedded thin (5 to 8 m) sand and layers vary from 0.04 can serve domestic sand with gravel layers to 14 and irrigation application Foundation 280 to 350 Weathered and fractured gneiss with sand and gravel Top of bedrock can sandy and clayey fills. Some water deposits at top of unn serve as productive bearing gravel and clayey sand - results of testing water supply, deposits along fractured top horizon. not available - likely although depth to unit Portions of unit under pressure 1 to 10m/day can be an issue Hydraulic conductivity estimates from Energoproekt Bulgarian EIA (December, 1999) and are based upon their September/October 1995 geologic field testing programme.

The best sources of regional ground water quality data are the wells operated by local towns and villages. Table 4.17 presents water quality data for several municipal water supply wells located in the vicinity of Maritza East 1 power plant (including the Galabovo wells) and provides a comparison with applicable Bulgarian and European Union drinking water quality standards. This data indicates that, with the exception of the Mednikarovo wells ground water quality generally complies with drinking water standards. As demonstrated by elevated sulphate and dissolved solids concentrations, at the time of the sampling (1995) ground water in the vicinity of the Mednikarovo wells was apparently contaminated with infiltration of polluted water from the ash ponds of the Maritza East 3 power plant and the Sokolitsa River. Other wells were apparently less affected by surficial contaminants, meeting standards for all parameters except from the European Union standard for lead (exceedence likely due to piping materials and not ground water contamination).

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TABLE 4.17 WATER QUALITY OF MUNICIPAL WELLS LOCATED IN THE PROJECT AREA

Parameter Units Bulgarian European Galabovo Mednikarovo Madrets Glaven drinking Union wells3 wells3 wells3 wells3 water drinking standard' water standard2 pH S.u. 6.5-8.5 6.5-9.5 8.0 7.4 7.8 8.2 Hardness meqtl 12 - 6.5 29.9 8.5 7.7

Oxygen demand mgtl02 2.6 5 1.5 1.1 1.5 1.1 (permanganate) Nitrates mgtl 50 50 4.0 10.0 10.9 27.8 Chloride mgtl 250 250 20 93.0 57.0 48.0 Sulphate mgtl 250 250 62 1477 123.0 111.0 Phosphate mgtl 0.5 - 0.04 0.11 0.08 0.18 Dissolved solids mgtl 1000 - 344 2320 496 560 Calcium mgtl 150 - 70.1 378 112 96.2 Magnesium mgtl 80 - 36.6 135 35 35.4 Iron mgtl 0.2 0.2 0.11 0.11 0.04 0.04 Manganese mgtl 0.1 0.05 --- - Copper mgtl 0.2 2.0 0.005 0.007 0.006 0.010 Lead mgtl 0.05 0.01 0.022 0.030 0.038 0.042 Zinc mgtl 5.0 - 1.5 1.5 1.5 - Notes: 1. Bulgarian National standard for Potable Water, 80S 2823/83 2. European Union Directive on the Quality d Water for Human Consumption, 98/831EC 3. Data provided by local water authorities, 1995

4.6 Terrestrial ecology

The new AES-3C Maritza East 1 power plant project is located near the confluence of the Sokolitsa and Sazlijka Rivers. From the confluence of these two rivers, the Sazlijka River flows in a southerly directly for approximately 25 km, prior to discharging to the Maritza River. This region is known as the Thracian Plan, and is located between the Sredna Gora Mountains to the north and the Rodopi Mountains to the south (see Figure 4.5).

The Thracian Plain is generally flat, with low hills and gentle slopes predominating. Elevations in the vicinity of the project are approximately 100 m above sea level, and regional elevations range from approximately 100 to 200 m above sea level. Agricultural land uses predominate in the region, and include large areas of cultivated crops (eg cotton, maize), meadows, and orchards, Prior to conversion to agricultural land, the Thracian Plan was forested, with fixed oak forests as the dominant cover type. Within the general vicinity of the proposed project, especially along the lowland river valleys, remnants of forest communities remain. Remnant oak forests also occur in mountainous regions to the south of the Maritza River (eg the Rodopi Mountain range and foothills) and to the south-east and east. Many of these areas have remained forested because they are too steep to farm.

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The lowlands of Gorna Trakia in the vicinity of the proposed project have a long history of industrialized and agrarian uses. Converting native terrain to arable farming lands led to removal of the forests and ploughing of the area's natural grasslands. As a result, native woodland and grassy vegetation are uncommon in this area, with the exception of small forest groves located to the west and north-west of the village of Galabovo, north-east of the village of Drianovo, between the villages Mednikarovo and Obruchishte, and to the east and south-east of Mednikarovo Village. Small natural grasslands have also formed on the alluvial meadow soils in the valleys of Sazlijka, Ovacharitsa, and Sokolitsa Rivers.

4.6.1 Vegetation

The proposed AES-3C Maritza East 1 power plant project is located in the Thracian forest vegetation zone, which is a sub-group of the Macedonian-Thracian Province of the European deciduous forest zone (Zahariev et aI1979). This eco-region is sometimes referred to as the Transitional-Continental Central Bulgarian Forest-Vegetation Province (Pavlov 1998).

4.6.1.1 Native terrestrial communities

Much of the native forest vegetation in the immediate vicinity of the proposed AES-3C Maritza East 1 power project has been eliminated due to agricultural development, industrial construction, mining, road construction, and urban development. The development and mining of the lignite coal deposits in the Maritza East basin and the construction of the three Maritza East thermal power plans have caused significant changes in the natural vegetation and terrain. According to the Vegetation Map of Bulgaria, the project site is located in an area characterized as farmland, replacing forests of field elms (Ulmus minor), field ash (Fraxinus oxycar) and common oak (Quercus pedunculiflora).

Any forested areas in the general project region are small and fragmented, and do not form contiguous forest communities. In the few remaining fragmented forest tracts in the region, floristic communities are dominated by a zerophytic and mesoxerophytic hardwood oak complex with oak (Quercus frainetto and Q. cerris) as the predominant woody taxa. Other forest trees found in this region include oak (Quercus pubescens and Quercus pedunculiflora), Querceta pedunculiflora, Q. roboris, maple (Acer campestre and Acer tataricum), elm (Ulmus minor), ash (Fraxinus oxycarap and Fraxinus ~mus), and Sorbus domestica. The forest understory shrub communities include such species as single-style hawthorn (Crataegus monogyna), blackthorn (Prunus spinosa), Vibumum lantana, Comus mas, Ugustrum vulgare, Carpinus orientalis, Paliurus spina-chrisi, a and dog rose (Rosa canina). Forbes and grasses found in the new remnant forest areas in the region include Brachipodium sylvaticum, Festuca valesiaca, Festuca hetarophylla, Dactylis glomerata, Poa nemoralis, Elymus repens, Dorycnium herbaceum, Carex muricata, Teucrium chamaedrys, Veronica chamaedrys, V. jaquinii, Tanacetun corymbosum, Dorycnium herbaceum, Hellenborus odorus, Viola riviniana, and Melica uniflora.

In low-lying areas (eg around the perimeter of the Rozov Kladenetz Lake and on the river banks), limited emergent wetland communities are found. Common species in these areas include Phragmites australis and Typha angustifolia.

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4.6.1.2 Non-native terrestrial communities

Much of the land in the vicinity of the proposed project is in agricultural use. Vegetative cover types in the region include agrarian communities, secondary ruderal grass and shrub-grass communities, man-made grass communities and tree plantings on reclaimed lands, forest communities and agrarian communities on reclaimed lands, and fragments of other successional communities. Maize, cotton. and wheat are the primary crops grown in this region.

Non-agrarian lands near the project site include early successional old field and ruderal graminoid communities integrated with single individuals and micro-groupings of three and shrub species. Typical species in this cover type include Lolium perenne, Oactylis glomerata, Cynodon dactylon, meadow grass (Poa pratensis), knott grass (Polygonum aviculare), Cynosrus echinatus, Trifolium pratense, Taraxacum officinale, Sedum album, S. acre, Oxalis comiculata, Stelaria media, Malv sp., Alopecurus agrestis, Chondrilla juncea, Eragrostis minor, Grifolium arvense, Vicia hirsuta, Sc/eranthus annuus, Ononis Hircina, Bromus commutatus, Trifolium fragiferum, and Xeranthemum annuum.

A similar community occurs in disturbed regions following forest cutting or abandonment of cultivated areas. These early successional communities are dominated by graminoid species, with herbaceous material such as Lolium perenne, Cynodon dactylon, bulbous meadow grass (Poa bulbosa), Trifolium repens, and Festuca valesiaca occurring. Xerophytic successional communities in drier soils typically include Chrysopogon gryllus, Oichantium ischaemum, burr medick (Medicago minima), Potentilla recta, foot cover (Trifolium arvense), rough clover (T. scabrum), T. setiferum, field eryngo (Eryngium campestre), Leontodon crispus, Astragalus onobrychis, Sedium caespitosum, Verbascum nobile, Convolvulus cantabrica, and Carduus nutans.

Landscape and horticultural specimens at the power plant project site include single individuals and groups of the following trees and shrub species:

• Trees - Thuja orientalis, Picea pun gens, P. abies, silver birch (Betula pendula), Platanus acerifolia, Aesculus hippocastanum, ash (Fraxinus americana), F. exe/sior, Cercis sliliquastrum, large-leaved Iyme (Tilia tomentosa), T. platiphyllos and T. platiphyllos and Albizziajulibrissin.

• Shrubs - Forsythia X intermedia, Buxus sempervirens, Spiraea X vanhouttei, rose (Rosa sp.) privet spreading bush (Ugustrum vulgare), barberry (Mahonia aquifolium) and Hydrangea hortensis.

Graminoid communities provide 60 to 100 per cent absolute cover on the partially reclaimed cinder dumps located to the east of the proposed power plant. Dominant species in these areas include Vulpia myurus, Cynodon datylon, Brachipodium dis tachyon, Poa Concina, Erodium cicutarium, Aira elegans, Aranaria serpyllifolia, burr medick (Medicago minima), Anchussa sp., and Echium vulgare. In certain locations around the tailings dump, 10 to 12 year old black and honey locust trees (Robinia pseudoacacia and Gleditsia tiacanthos) occur.

During the past few decades, land reclamation projects to the east of the existing Maritza East 1 facility have resulted in forested plantation areas. These areas are covered by a mixture of indigenous and non-native trees, including black pine (Pinus nigra), oak (Quercus rubs, Q. robur) , silver birch (Betua pendula), large leaved lime (Tilia tomentosa), Platanus aceerifolia, Robinia

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pseudoaeacia, ash (Fraxinus om us, F. oxyearpa), Populus X euroamerieana, and Ailanthus glandulosa. Shrubs in the re-forested areas including Syringa vulgaris, Amorpha frutieosa, Tamarix tetranda, and privet spreading bush (Ugustrum vulgare), and the dominant herbaceous species are Jasminum futieans and Elymus repens. Trees have also been planted on some reclaimed coal mining sections. The planted areas are small, with non-native pitch pine (Pinus rigida) as the most common species.

4.6.1.3 Site specific research

Studies done in areas around the power plant indicate that vegetation has been affected, most likely due to existing pollution sources. In 1999, chloroses on the leaves of clover and Graminae grasses were observed within 100 to 200 m of the existing power plant and in the vicinity of Obruchishte and Galabovo. Top drying and dead trees were found on the replanted lands to the west of the power plant. The Austrian pine culture near Apilovo Village was observed to be in poor condition due to crown defoliation and deformation. Average crown defoliation of 25 to 30 per cent for Austrian pine and 30 to 40 per cent in Scots pine (Pinus silvestris) was found in the conifer plantations near Glavan where chloroses and needle twist were also observed. Die-back of the oak forest was found to affect 20 to 30 per cent of the tree plantations in this region.

While the condition of plant species within the project area appears compromised, studies of the heavy metal content of various agricultural and forest species do not indicate the presence of heavy metal pollution. The locations of the sampling and analytical results supporting this are present in Table 4.18.

TABLE 4.18 CONTENTS OF MACRO AND MICROELEMENTS IN PLANT SAMPLES

Sample # Plant species Concentration (mg/kg) Location Cu Zn Ca Mn Cr Co Ni Pb 1. D.glomerata 2.28 12.75 1900 150.9 2.31 0.47 2.21 6.38 2. Z.mays 2.34 19.66 4606 57.75 5.90 1.34 2.19 6.75 3. C.dactylon 3.92 39.14 3714 134.26 5.33 1.28 4.00 4.53 4. C.dactylon 11.30 81.58 3174 58.24 8.23 1.72 9.40 6.70 5. A1.agrestis 5.39 41.48 6067 82.14 5.58 1.14 3.03 7.36 6. E.repens 2.84 33.83 3883 85.73 4.60 0.74 4.45 7.40 Location 1 - oak plantation - Galabovo; 2 - field - Galabovo; 3 - cinder dump over soil; 4 - cinder dump over ash; 5 - recultivated terrain with humus for agricultural use; 6 - Austrian pine plantation - recultivation without humus.

The concentrations listed in Table 4.18 are generally within the limits of the natural variation of these elements in plants. The increased level of certain heavy metals that was detected in Cynodon daetilon from sample location 4 was likely due to this being an ash pile with no soil covering. For the same species growing on the ash pile that was covered with soil, considerably lower concentrations of heavy metals were found.

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4.6.2 Fauna

The AES-3C Maritza East 1 power plant is located in the southern zone of the Thracian zoogeographic region. The Maritza and Tundza River valleys serve as natural corridors for Mediterranean fauna to enter from the south. Numerous insect taxa found in the Thracian region are of Mediterranean origin. Up to 24 per cent of the region's nesting birds are Mediterranean species, and up to 22 per cent of the region's insectivorous mammals and rodents are Mediterranean species. Euro-Siberian and European wildlife species also occur in the project area. These species are presumed to have migrated to the region from the west, across the mountains in south-west Bulgaria.

4.6.2.1 Amphibians and reptiles

Amphibian and reptile diversity in Bulgaria is among the richest in Europe. Sixteen species of amphibians (salamanders, frogs, and toads) and 36 species of reptiles (lizards, snakes, and turtles) have been reported. Several species occur throughout Bulgaria and may be expected at or near the site. These include Rana ridibunda, Buto viridis, Lacerta viridis, Lacerta Muralis, Natrix natrix, and Natrix tessel/ata. Other species found in south Bulgaria which may occur near the site include C/emys caspica, E/aphe situ/a, Typh/ops vermicu/aris, Ophisops e/egans, and Ma/p%n monspessu/anus.

4.6.2.2 Mammals

Eighty-eight species of mammals occur in Bulgaria (Meine, 1998), including native and non-native (introduced) species (eg Dama dama and muskrats (Ibdatra zubetguca)). Nineteen species are included in the Red Data Book. Of these 88 species, four are marine mammals not occurring near the project site, and 27 species are bats (two are rare).

Although the region surrounding the Maritza East 1 power plant is largely in agricultural use, the interspersion of agricultural lands, remnant forest, successional old field, and shrub communities in the area may provide habitat for species such as European hare, fox, weasel, European polecat, badger and European marbled polecat. Table B1 in Appendix B is a list of mammal species, excluding bats, which may be expected to occur in the vicinity of the project site.

4.6.2.3 Birds

The river valleys in the vicinity of the AES-3C Maritza East 1 power plant (eg the Sokolitsa, Sazlijka, and Maritza Rivers) serve as migratory flyways for a wide variety of avifauna. A major bird migration route (the ·Via Aristolis· route) occurs along the Maritza River, to the south of the site (see Figure 4.6). Some migrating birds passing through this route continue to the Bosphorus in autumn or to Northern Europe in spring. The primary migration route in Bulgaria is along the Black Sea Coast, and is known as ·Via Pontica", or "Western Black Sea Migration Route".

Approximately 397 species of birds have been reported in Bulgaria; 225 of these species are known to nest in the country. This relatively rich avifauna is in part due to Bulgaria's position between wintering areas in Asia and Africa and breeding areas in western and northern Europe, as well as breeding areas in Bulgaria. Some birds from Northern Europe also winter in Bulgaria.

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Approximately 100 to 150 bird species are likely to occur in the vicinity of the project (see Figure 4.7). The largely agricultural landscape in the vicinity of the power plant can provide abundant forage for certain members of the bird community. Table B2 in Appendix B includes bird species which may be expected to occur in the vicinity of the project site. All but three of the species listed are protected from hunting. Of those, only two are included in the Bulgarian Red Book.

The presence of the Rozov Kladenetz Lake and Ovacharitsa Lake (both of which are man-made lakes built to support the region's power plants) adds diversity to the region's ecology; in particular, the avifauna benefits from the presence of these lacustrine water bodies (Yankov, Profirov, Kutsarov 1997; EIAS 1995; Green Balkans.

Rozov Kladenetz Lake is a wetland that is important for wintering geese, pelicans, cormorants and other waterfowl. Several globally threatened species, including the Dalmatian pelican (Pelecanus crispus) and pygmy cormorant (Phalacrocorax pygmeus) are known to winter on this unfrozen lake. The lake also supports wintering populations of the cormorant (Phalacrocorax carbo), as well as a number of other water birds, including grebes, pelicans, geese, and herons. White-eyed bochard or Ferruginous duck (Aythya nyroca) have also been observed at the reservoir. Two other internationally endangered species, the lesser kestrel (Falco naumanni) and corncrake (Crex crex), have been reported in the vicinity of the Maritza 3 power plant (Bulgarian Society for the Protection of Birds, 1997).

During a 15 February 2000 survey, 12 avian species were observed at Rozov Kladenetz Lake (Table 4.19). These species include waterfowl, gulls, grebes, and terrestrial birds. Large numbers of raptors migrate through and/or winter in the region of the project site. Individuals or groups of raptors may pass over the site during migration, with some individuals resting or feeding near the lake or nearby habitats. Large numbers of raptors are not expected to occur in area through the winter. However, the diversity of raptors, including protected species, passing through the region is significant (Table 4.20).

TABLE 4.19 AVIFAUNA OBSERVED AT ROZOV KLADENETZ LAKE DURING 15 FEBRUARY 2000 SURVEY

Common name Scientific name Number of birds observed Number of birds observed in the morning in the afternoon

Rook CONUS frugulegus 208 Coot Fulica atra 58 64 'Black headed gull Larus ridibundus 40 20 Cormorant Phalacrocorax carbo 31 95 'Pygmy Cormorant Phalacrocorax pygrneus 30 30 Great Crested Grebe Podiceps cristatus 20 6 Magpie Pica pica 9 Starling Stumus vulgaris 4 Buzzard Buteo buteo 2 Mallard Anas platyrhynchos 25 'Shelduck TaOOma laOOma 5 Gulls spp Larus spp 28 , Protected (Bulgarian Red Data Book, 1985. IUCN) Source: ENSR 2000

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TABLE 4.20 RAPTORS AND OTHER LARGE SOARING BIRDS OBSERVED MIGRATING OVER THE BURGAS, BULGARIAN REGION IN 1978

Common name Scientific name Number of raptors Number of raptors observed during February, observed during March, April 1978 September and October 1978 White Pelican "Pelecanus onocratalus 1478 2706 Dalmatian Pelican "Pe/ecanus crispus 30 0 White Stork "Ciconia ciconia 15531 0 Black Stork "Ciconia nigra 79 301 Crane "Grus grus 698 277 Osprey "Pandion haliaetus 2 7 Black Kite "Mulvus migrans 87 8 Short-toed Eagle "Circaetus gal/icus 16 163 Sparrow hawk "Accipiter nisus 122 3 Buzzard Buteo buteo 1962 2917 Rough-legged Buzzard Buteo lagopus 2 4 Long-legged or White-tailed "Buteo rufinus 0 15 Buzzard Booted Eagle "Hieraaetus pennatus 5 21 Tawny Eagle "Aquila aquila 1 0 Lesser Spotted Eagle "Aquila pomaria 330 2862 Spotted or Greater Spotted "Aquila clanga 0 6 Eagle Marsh Harrier "Circus aeruginosus 12 0 Hen Harrier "Circus cyaneus 5 19 Pallid Harrier "Circus macrourus 3 3 Harrier spp. Circusspp. 14 5 Red-footed Falcon "Falco vesperlinus 0 76 Hobby "Falco subbuteo 2 13 Kestrel Falco tinnunculus 15 56 Peregrine Falcon "Falco peregrinus 0 3 Saker "Falco cherrug 0 3 Falcon spp. Falco spp. (large) 3 93 . Protected (IUCN. SPEC or Red Data Book) Source: Roberts 1979

Although only small (lumbers of shore birds are expected to sporadically use Rozov Kladenetz Lake in the winter, the numbers of birds stopping at the lake during spring or autumn migration is potentially significant. A total of 47 species of shore birds have been reported in Bulgaria.

The avifauna at the Ovacharitsa Dam Lake has been well studied (Energoproekt, 1999) and it is likely that species assemblages observed at this lake also occur at Rozov Kladenetz Lake. Ovacharitsa Dam Lake is recognized as an internationally important area for wintering waterfowl: 17 species reported at the lake have been included in the Red Data Book of Bulgaria. Twenty-six species reported at the lake are of European conservation significant. The Ovacharitsa Dam Lake is an important wintering area for the cormorant, Dalmatian pelican, and white-fronted goose. In addition, the red-breasted goose (Branta ruficollis) has been sporadically recorded in the winter at Ovacharitsa Dam Lake. Between 1992-1995, maximum numbers of approximately 6 000 white-fronted geese,

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1 000 cormorants, 5000 pygmy cormorants, and 120 Dalmatian pelicans have been recorded. Uncontrolled hunting is a serious problem on both reservoir lakes.

During mid-winter counts taken from 1977 to 1981, large numbers of water birds were recorded at Ovacharitsa Dam Lake. An average of 21 500 total individuals representing 12 species were present on the lake (minimum 2876 individuals, 4 species; maximum 39793 individuals, 18 species). Typical species encountered during the mid-winter surveys of Ovacharitsa Dam Lake are presented in Table 4.21.

TABLE 4.21 TYPICAL OVER-WINTERING SPECIES AT OVCHARITZA DAM LAKE

Common name Scientific name Great Crested Grebe Podiceps cristatus Little Grebe Tachybaptus ruficoflis Grey Heron Ardea cinerea Whopper Swan Cygnus cygnus Mallard Anas p/atyrhynchos Teal Anascrecca Wigeon Anas penelope Pintail Anasacuta Shoveler Anas clypeata Tufted Duck Aythya fu/igu/a Velvet Scoter Me/anitta fusca Smew Mergus a/bel/us Coot Fullica atra Herring Gull Larus argentatus Lapwing Vanel/us vanel/us Source: Michev et al. 1981 (taken from the Bulgarian Maritza East 1 Power Plant EIA submitted to the Ministry of Environment and Waters on 16 December 1999

Additional discussion regarding the use of the impounded lakes in the region (ie Rozov Kladenetz Lake and Ovcharitza Dam Lake) by rare and endangered waterfowl is presented in Section 4.9.

4.7 Aquatic ecology

Limited information is available regarding the aquatic ecology of Rozov Kladenetz Lake. However, a similar impounded lake (Ovacharitsa Dam Lake) is located approximately 20 km to the north-east of the AES-3C Maritza East 1 power. Given that local experts feel that the two lakes have similar geomorphological and ecological characteristics, the extensive studies done at Ovacharitsa Dam Lake are used to characterize Rozov Kladenetz Lake.

Lowland power station cooling pond reservoirs, such as Rozov Kladenetz Lake or Ovacharitsa Dam Lake, are characterized by an active exchange of water, thick sediment layers with rich benthos, frequent oxygen saturation in the upper layers and low quantities of oxygen in the lower layers, and high maximum summer temperatures. Summer temperatures are typically at the 27 to 29°C range, but may reach summer highs of 3rC. Due to the thermal influence of the power plant, much of Rozov Kladenetz Lake provides year round, open water habitat.

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Limited palustrine emergent wetland communities are present around the perimeter of Rozov Kladenetz Lake. Commons species in these areas include Phragmites australis and Typha angustifolia. Portions of the reservoir's banks have been planted with Austrian pine (Pinus nigra) and common locust (Robinia pseudoacacia), whereas along the Sazlijka valley typical riparian plants can be observed, such as willows (Salix sp.) and poplars (Populus sp.).

4.7.1 Fish

Approximately 100 to 122 species of freshwater fish occur in Bulgarian rivers, wetlands, and lakes, including brackish waters. More than 50 species or subspecies occur in southern Bulgaria. Fish species potentially occurring in rivers and lakes of the region include carp (Hypophthalmichthys molitrix, Ctenopharyngodony idellaJ, perch (Carassius carassius), chub (Scardinius erythrophthalmus), river mullet (Leucicus cephalus), black barbel (Barb us meriodionalis peteny/), Maritea barbel (Barbus cyC/olepia), and Crimean barbel (Barbus tauricus). Other species known to occur in Ovacharitsa Dam Lake include Rutilus ruti/us, Tinca tinca, Aspius aspius, Albumus albumus, Abramis brama, Vimba melanops, Cyprinus carpio, Carassius auratus gibe/io, Aristichthys nobi/is, Gambusia affinis, Cobitis taenia, Silurus glanis, Stizostedion lucioperca, Perca f1uviati/is, Gymnocephalus cernua, Lepomis gibbosus, and Proterorhinus marmoratus.

The ichthyofauna of the nearby Ovacharitsa Dam Lake has also been well studied (Energoproekt, 1999). About 20 fish species have been observed in this reservOir, including Ruti/us rutilus, River mullet (Leucicus cephalus), Cyprinus carpio, Tinca tinca, Perch (Carassius carassius), Perca fluviatilis, Gymnocephalus cernua, and Albumus album us.

A number of the species found in the area are raised in commercial fish farms, which produce stocking material and fish for consumption. Carp, herbivorous species, silver carp, grass carp, rainbow trout, brown trout, buffalo fish, and channel catfish are among the preferred species for artificial reproduction and distribution. A fishing co-operative (fish farm) has developed along the shore of Rozov Kladenetz Lake. While commercial harvests of up to 20 different species could potentially occur, the numbers of fish harvested on an annual basis are not known.

4.8 Protected areas

The main objective of land protection initiatives in Bulgaria is to preserve both ecosystem biological diversity and the natural processes that occur in them. Specific Bulgarian conservation initiatives, as well as European and global conservation strategies are that are relevant to the Maritza East 1 project are summarized below.

4.8.1 Bulgarian law of protected areas

The Bulgarian Law of Protected Areas defines the following natural categories:

• Reserves,

• National parks,

• Natural parks,

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• Managed reserves, • Protected sites, and • Natural monuments.

No officially protected areas under the Bulgarian Law of Protected Areas occur in the project region.

4.8.2 Wetland conservation strategies

The preservation of wetlands is one of the main priorities of the National Biological Diversity Conservation Strategy (1994). Wetland conservation is of great significance in Europe, including Bulgaria, where agricultural and industrial land use patterns have altered or destroyed many wetlands. Statistical data show that since the beginning of the 20th century the total area of wetlands in Bulgaria as a whole has been reduced 18-fold (Bulgarian Ministry of Environment and Waters, 1995). The National Plan for Wetland Conservation gives priority to the most important natural sites. Bulgaria has ratified the Convention for Conservation of Wetlands of International Importance; an element of this initiative known as the Ramsar Convention provides protection for water birds.

The Ramsar Convention is an intergovernmental treaty that was signed in Ramsar, Iran in 1971. The official name of the treaty is "The Convention of Wetlands of International Importance especially as Waterfowl Habitat". The Convention includes criteria to identify important wetlands and maintains a "List of Wetlands of International Importance". To date, 119 countries are part of the Convention, including Bulgaria, which was the eighth (8th) country to joint on 24 January 1976. On 27 February 1986, Bulgaria signed the Protocol for introducing amendments to the Ramsar Convention (Paris Protocol).

Five sites in Bulgaria are included in the Ramsar Convention; four of these Ramsar sites are found along the Black Sea coast, and one is located along the Danube River. The first Bulgarian Ramsar Convention site was listed prior to 1981. The remaining four sites were listed in 1981 and 1996. The Bulgarian Ministry of Environment and Waters has the obligation in Bulgaria to establish an administrative structure for management and patrolling of all Ramsar Convention sites. Up until 1999, Bulgaria had a "Ramsar National Committee", but this committee was recently disbanded and is no longer functional.

The Rozov Kladenetz Lake (approximately 735 hectares), located directly south of the Maritza East 1 project site, is not a Ramsar Convention site, and has not been officially proposed to be listed by Ramsar. The lake is described in The Ramsar Convention on Wetlands National Report of Bulgaria for COP7 (1999), as being "in the process of deSignation as a protected wetland". This report also states that this lake is of "international importance due to the wintering of geese, pelicans, cormorants, and other bird species".

The Rozov Kladenetz Lake is one of 88 water bodieslwetlands listed in the Bulgarian "National Action Plan for the Conservation of the Most Important Wetlands in Bulgaria - 1995". At thattime, Bulgaria proposed to study all 88 sites, but Ramsar did not have funds available to finance the required studies.

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In order to formally classify the lake as a Ramsar site, the Bulgarian Ministry of Environment and Waters would have to complete an assessment of the lake and file a formal proposal for the lake. The assessment would need to provide information on the ecological state of the lakelwetland, define the threats and violations to the natural protection of the lake, and outline the priority measures needed to protect the wetland. Like the other sites listed in the National Action Plan, there is insufficient information on which to base a formal proposal.

Experts acknowledge that while the lake has some characteristics of a Ramsar site (ie the attraction to birds), its man-made condition and reliance on human activities to maintain its "bird-attracting" environment, make it unlikely that the necessary studies would ever be undertaken to complete a formal proposal. In 1992, Ramsar representatives visited 17 sites in Bulgaria to determine if further study was appropriate. Rozov Kladenetz Lake was not among the sites that they visited. In order to proceed with the Ramsar designation process, the lake would have to first be formally protected in Bulgaria (which it is not currently) and then be reviewed under the additional Ramsar criteria.

4.8.3 Co-ordination of information on the environment (CORINE) sites

Rozov Kladenetz Lake is listed as one of 141 CORINE sites in Bulgaria. COR.INE was established as an experimental project by the Commission of the European Communities (now the European Environmental Agency - Copenhagen) to "gather, co-ordinate, and ensure the consistency of information on the state of the environment and natural resources" in the European Community. Priority areas include "biotopes for conservation, acid deposition protection of the Mediterranean environment, and improvement in comparability and availability of data and methods of analysing data". This designation carries no national or international regulatory protection.

4.8.4 International protection of avian species

Many of the avian species known or suspected to occur at Rozov Kladenetz Lake are afforded international protection. Several of these species are globally threatened; the Dalmatian pelican (Pelecanus crispus), and pygmy cormorant (Pha/acrocorax pygmeus) are both known to winter in this unfrozen, thermally influenced lake. Use of Rozov Kladenetz Lake by protected bird species, as well as species included in the Bulgarian Red Data Book, is further described in Sections 4.9 and 4.10 of this report.

4.9 Endangered and threatened species

The AES-3C Maritza East 1 power plant site occurs in an area of low importance for Biological Diversity in Bulgaria (Figure 4.8) (Biodiversity Support Programme, 1994). This determination is from a composite mapping of several indices including species richness, number of endemic taxa, and numbers of rare (protected) taxa. The Red Data Book of Bulgaria, Volume II lists threatened and endangered species known to currently and historically occur in the Maritza East region. Information from the Red Data Book is presented in Appendix B.

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4.9.1 Plants and invertebrates

The largely agricultural landscape in the vicinity of the AES-3C Maritza East 1 plant limits its use by many terrestrial endangered and threatened species. No rare or endangered plant communities are know to occur at or near the project site (Figure 4.9). Similarly, no Bulgarian or Balkan endemic plants are known from this local area (Meine, 1998). Although the power plant project site borders a region to the north and west of the Maritza River known to have more than 100 rare invertebrate taxa, no rare and endangered invertebrates are known to occur in the immediate vicinity of the project site (Figure 4.9 and Figure 4.10).

4.9.2 Mammals

Nineteen mammal species are listed in the Red Data Book of Bulgaria (Botev and Peshov, 1985). These threatened and endangered taxa include two species of bats, eight carnivores, one seal, two porpoises, one goat, and five small rodents. Only a few of these species have ranges that include the project site, including Myotus emarginatus, Canis lupus, Myomimus roachi bulgaricus, Cricetulus migratorius , Lutra lutra, and Vormela peregusna. Although several of these species could potentially occur in the region, it is likely that several of these taxa would require more remote habitats than the agricultural region surrounding the AES-3C Maritza East 1 power plant site provides.

4.9.3 Fish

Of 100 species of freshwater fish in Bulgaria, less than 20 species are included in the Bulgarian Red Data Book (Botev and Peshov, 1985). Some of these include Cyprinus carpio (end.) Anguilla anguilla (end.), Lota Iota (end.) Lucioperca volgensis (rare), Neogobius Kessler (end.) and 8enthuophilus stellatus (rare). All of these species occur in the near the Danube River. Only the eel (Anguilla anguilla) could potentially occur near the project site in rivers that connect to the Aegean Sea.

4.9.4 Reptiles and amphibians

One turtle species, three species of lizard, eight species of snake, and a toad species are included in the Red Data Book. There are rio records of any of the reptilian species (ie snakes, lizards and turtles) occurring near the project site between 1970 and 1985. Although there are no documented occurrence records it is possible that the toad Polobates syriacus (an endangered species) could occur in the region.

4.9.5 Avifauna

The AES-3C Maritza East 1 power plant project site is within a region of Bulgaria containing 'moderate' numbers of rare (protected) bird species (see Figure 4.7). The largest numbers of rare taxa are in isolated mountain forest habitats, or in coastal wetlands along the Black Sea coast. No unique bird ecosystems or mapped critical habitats occur at the project site; the nearest such habitat is south of the Maritza River, in the eastern Rodopi Mountain Range and at the near Sakar Mountain (see Figure 4.12). However, as discussed elsewhere in this report, Rozov Kladenetz

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Lake provides important overwintering habitat for a number of species of geese, pelicans, cormorants, and other waterfowl. Several globally threatened species, including the Dalmatian pelican and pygmy cormorant, are known to winter on this thermally influenced, unfrozen lake. The project site is located in an area characterized as having a moderate distribution of rare bird species (see Figure 4.13).

4.9.5.1 Internationally protected species

The World Conservation Union (UCN) (formerly the International Union for the Conservation of Nature) is an international agency whose aim is to help countries identify and protect natural resources at risk (ie develop conservation strategies). The UCN "Red list" includes 13 species of threatened birds that are known to or could potentially occur at or near the project site. Of these species, only six could potentially nest in the region. These are described in Appendix B.

4.9.5.2 Species of global conservation concern

A number of European conservation organizations, including Non-government Organizations (NGOs), have recently assessed the status of birds in Europe. They have developed a list of birds known as "Species of European Conservation Concern" ((SPEC). SPEC categories 1 and 2 are listed in Appendix B along with summaries of the species status.

4.9.6 Avian conservation under Bulgarian law

Although most wintering species previously discussed are also included in the Red Data Book, several other species occurring in the local region are not internationally protected, but are protected by Bulgarian law. These species are also listed in Appendix B.

The most important of the birds afforded protection under Bulgarian law is the cormorant (Phalacrocorax carbo) which is very common at Rozov Kladenetz Lake in the winter. Approximately 600 cormorants were reported at the lake in 1985, and in January 1993, more than 3900 cormorants were observed at Ovacharitsa Dam Lake, approximately 25 km to the north-east. The local population in the winter is significant, and some local movement between the two lakes is expected. Greylag geese (Anser anser) are also common in the region in the winter (average winter population 1370 for period 1977-1989). Most occur farther east near the Black Sea coast, but they have been reported at Ovacharitsa Dam Lake, and could potentially over-winter at Rozov Kladenetz Lake.

4.10 Socio-economics

Since 1990, Bulgaria as a country has been undergoing massive transition from a state-owned and state run economy to one that is moving rapidly toward free market conditions. A brief review of the overall conditions in the country is necessary in order to understand the social and economic conditions in the project area.

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4.10.1 General socio-economic conditions in Bulgaria

4.10.1.1 Background

More than 40 years of Communist rule that ended in the late 1980s were followed by six government changes since 1990. Late 1996 and early 1997 saw the near collapse of the Bulgarian economy with a winter of unprecedented hardship for the Bulgarian population. Inflation rose to 311 per cent, state salaries and pensions declined by 60 per cent and employment dropped by 8 per cent. The economy of Bulgaria has seen further sustained improvement in recent years with inflation dropping back to 2.6 per cent in 2003, and increasing only marginally in 2004. Since 2000 GOP growth has averaged around 5 per cent. The average real wage fell to US$20 per month in early 1997, from US$130 in late 1995.

Since 1997 a number of economic indicators began to improve. The government's strong commitment to financial stability led to the decision to sign the first 3 years of a standby agreement with the International Monetary Fund (IMF), aiming at supporting the balance of payments of the country during the period of macro-economic stabilization and structural reforms. Inflation was contained to a record low of 1 per cent in 1998 and the GNP growth was estimated at approximately 4 per cent. The privatization process of state-owned companies slowly moved forward.

The social cost of the transition in Bulgaria has been one of the highest in Central and Eastern Europe. The official Human Development Index (HOI) ranking for Bulgaria, which annually measures the country's social and economic well-being as compared to other countries, went from a ranking of 33 in 1991 to 67 in 1998 (0.789). Except for a minority of affluent households, the majority of Bulgarians remain close to the poverty line, with food expenditures accounting for well over 50 per cent of the total household budget.

More than 85 per cent of Bulgarian households receive some form of income transfer, regardless of household income, often from multiple programmes. For example, workers at still-productive ages receive pensions (while working in the informal sector) because of early retirement privileges, and uninsured mothers receive maternity benefits for up to 3 years regardless of household income. As a result, despite large, unsustainable public expenditures on social protection (approximately 9 per cent of GOP in 1996 and 1997), benefits under Bulgaria's current social protection system have been reduced to levels too low to meaningfully assist those most in need of income support (World Bank, 1998).

The 2004 population of Bulgaria was 7 517 973 million persons, which represented a near 10 per cent decline from the 1996 level. The majority of the population (67 per cent) lived in urban areas.

Bulgaria is one of the new countries in Central and Eastern Europe that has exhibited a demographic decline since 1990 due to a continuously falling birth rate and a rising death rate.

Over the past 15 years, Bulgaria has had a constant decline in births, which dropped to 9.65 per 1000 in 2004, compared to 14.5 per 1000 in the early 1980s.

Likewise, there has been a general decrease in the fertility rate from 59.8 per 1000 women in 1980 to 32.5 per 1000 women in 1996 and a decrease in the population of age groups 0-14 and 15-49. DepreCiation of the incomes of most young families, rising unemployment rates and the limited

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prospects for future prosperity has meant the one-child family has become the norm in Bulgaria as opposed to the two-child family typical of the 1980s.

The rate of registered unemployment has been steadily increasing in recent years, from 13.7 per cent in 1996 to 15.0 per cent in 1997, to 16.0 per cent in 1998 but has recently decreased to 14.3 per cent in 2003. Long-term unemployment (over 1 year) has been steadily growing since October 1997 reaching approximately 30 per cent in January 1998. It was estimated that there were 47 unemployed persons for each available job in January 1998.

The predominant sources of household income are wages and retirement pensions (approximately 70 per cent in 1996).

Document No. 62160AlPBPfOOOOO1 077 4R040. COClS3129NV TABLE 4.22 tg BULGARIA SOCIO-ECONOMIC DATA d' Socio-economic indicator 1970-75 1980-85 1990-95 1996 1998 2004 ~ Population L Total population (in millions) 8.7 8.9 8.4 8.342L 8.257 7.517 Urban population (% of population) 57.5 64.5 70.7 - - - Annual average growth rate (per cent) 0.5 0.2 -0.3 - - - Crude birth rate - - - 8.6~ - 9.65 Crude death rate - - - 14.0~ - 14.25 Rate of natural increase - - - -5.4~ - 4.60 Total fertility rate (births per woman) 2.2 2.0 1.2 1.24~ - 1.37 Infant mortality rate (per 1000 live - - - 15.6~ 14.4~ 21.3 births) Life expectancy at birth (years) Total 71 71.71 - - 71.75 Male 69 69 68 - - -68.14 Female 74 74 75 - - -75.59 Employment Unemployment rate - - - 13.7 L 16.0~ 14.3

Income I GNP per capita (US$) 2000 1330 2220 - - 7600- Net primary school enrolment rate (% of age group) Total 96 98 82 - - - Male - 96 83 - - - Female - 96 81 - - -

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4.10.2 Regional and local socio-economic conditions

The AES-3C Maritza East 1 power plant is located in the Municipality of Galabovo, 1.6 km from the municipal centre in the Town of Galabovo. The closest residential community is the village Obruchishte, located approximately 0.8 km south-east of the plant site. Up until 1999, there were nine administrative districts in Bulgaria. In 1999, a new administrative division was enacted and the number of districts was increased from nine to 28 as of January 1999.

Separate from this political organization, a number of redevelopment areas were established. The Town of Galabovo is the municipal headquarters for the Municipality of Galabovo. It is part of the larger Stara Zagora administrative district and also part of the area promoted by the Stara Zagora Regional Economic Development Agency (SZREDA).

4.10.2.1 Stara Zagora administrative district and regional economic development agency area

The Stara Zagora administrative district is located in the central part of southern Bulgaria with an area 2 of 5147 km . The SZREDA area includes the Stara Zagora administrative district plus the Municipality of Topolovgrad. The City of Stara Zagora is in the heart of the area with a population of approximately 200 000, and is located approximately 40 km north-west of Galabovo. The City of Stara Zagora has a highly developed industrial sector and a well-developed health care system, due to the presence of the Thracian University School of Medicine.

The SZREDA area includes a total of ten municipalities with a total population of approximately 390 000. The area has nine towns and a population density of 76 people per square kilometre, which exceeds the national average.

The Municipality of Galabovo is located within the SZREDA area and includes the town of Galabovo and ten villages with a total population of 18 000. The town of Galabovo has the greatest share of the population with 11 000 people, followed by the village of Obruchishte with 2000 people, and the villages of Glavan and Madrets with over 1500 people each. The remaining population (less than 2 per cent of the district population) is comprised of residents of the villages of Velikovo, Razdelna, Mussachevo and Iskritsa.

The coal mining and power industries playa major role in the regional economy, providing a high rate of employment. The major industrial companies in the Galabovo areas are the three Maritza East thermal power plants, Mines Maritza East EAD which produces lignite, the briquette production facility associated with the ME1 power plant, and the Energoremont company. The Energoremont company is a power plant equipment manufacturinglrepair facility which is located directly south of the ME1 power plant.

In addition to the power industry, agriculture is an important economic sector in the Galabovo area. Agricultural production is concentrated in 13 private co-operatives and numerous private farmers. Major agricultural crops in the Galabovo area include wheat, barley, corn, cotton and sunflowers.

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Socio-economic development in the Stara Zagora administrative district

The Global Human Development Index (HOI), released annually by the World Human Development Report, is a method to compare sustainable human and socio-economic development between countries, as well as between administrative districts in Bulgaria. The HOI value indicates how far a country or individual district has to go to attain the following three goals: (1) an average life span of 85 years; (2) access to education up to the high school level for all children aged 5 to 19 years and (3) a decent standard of living, measured by the world threshold of real per capita GOP adjusted to its real purchasing power.

The HDI for the Stara Zagora administrative district is relatively high when compared to the other districts in Bulgaria: the Stara Zagora administrative district is ranked 4th out of the 28 districts. In general, districts with high levels of HDI, such as Stara Zagora, have the following characteristics:

• high enrolment rates in secondary education

• low unemployment rates

• high industrial employment

• recipients of migration from other areas.

The Stara Zagora administrative district has a low level of unemployment: it had a 1999 employment! unemployment ratio of 8.8 per cent, which was exceeded in only two other districts (Plovdiv and Sofia). The employment!unemployment ratio measures the number of employed persons per one unemployed. The Stara Zagora district also has high industrial employment, due to the high concentration of industries in the Town of Stara Zagora and the three Maritza East power plants and lignite mines in the Galabovo/Radnevo area.

Although employment levels in the Stara Zagora administrative district are relatively high when compared to other districts at the national and regional level, the number of layoffs due to the liquidation of companies has continued to rise. The highest share of layoffs in 1999 was recorded in Sofia (33 per cent of the layoffs), followed by Stara Zagora, in which 8 per cent of the layoffs were recorded. At both the national and regional levels, the expected restructuring of the economy, and the related processes of privatization and bankruptcies is expected to lead to new layoffs, mainly in the public sector.

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4.10.2.2 Municipality of Galabovo

The Municipality of Galabovo is comprised of the town of Galabovo (ie town/municipal centre) and ten villages. In most cases, the most recent socio-economic data available for the Municipality of Galabovo was 31 January 1998.

Population

The total 1998 population for the Municipality of Galabovo was 17653 persons, of which 58 per cent lived in the town centre of Galabovo, and the remaining 42 per cent lived in the outlying villages within the Municipality (see Table 4.23).

TABLE 4.23 POPULATION DATA FOR THE MUNICIPALITY OF GALABOVO

Popu lation centre Number of persons T own of Galabovo 10246 Village of Obruchishte 2287 Village of Glavan 1 559 Village of Madrets 1097 Village of Mednikarovo 730 Village of Aprilovo 457 Village of Pomoshtnik 398 Village of Musachevo 321 Village of Iskritsa 294 Village of Razdelna 147 Village of Velikovo 117 Total 17653

Population projections estimated by the Municipality of Galabovo forecast a maximum population of 18 000 persons for the municipality by the year 2003, which translates to a population growth rate of 2 per cent for the 1998-2003 period.

The age structure of the population in the Municipality in 1999 is shown in Table 4.24. As can be seen in the table, approximately half of the population in the Municipality is of working age (eg between 18 and 55 years of age), and a significant third of the population is over 55 years of age.

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TABLE 4.24 POPULATION AGE STRUCTURE FOR THE MUNICIPALITY OF GALABOVO

Age group Number of persons

0-7 years 1 100

7-14 years 1 562

15-17 years 650

18-55 years 8690

Over 55 years 5758

Total 17760

Employment

The largest employment sector in the Municipality of Galabovo is the energy sector: approximately 60 per cent of the population is employed in energy-related industries. Energy-related industries in the Galabovo area include the Maritza East 1 power plant and the adjacent lignite briquette manufacturing plant as well as the Energoremont industrial company located directly south of the Maritza East 1 plant. The Energoremont facility manufactures and repairs power generating equipment. In addition, there are the Maritza East 2 and 3 power plants, that are respectively located approximately 15 km north-east and 6 km east of the town of Galabovo, and the Troyanovo 3 mine area, which is located approximately 7 km north-east of the town of Galabovo. The number of people from the Municipality of Galabovo employed at these energy-related facilities as of 30 September 1999 is shown in Table 4.25. The total number of labourers from the Municipality of Galabovo that work in the energy sector is approximately 16 per cent of the population.

TABLE 4.25 NUMBER OF PERSONS FROM THE MUNICIPALITY OF GALABOVO EMPLOYED AT ENERGY FACILITIES

Energy facility Number of people employed Maritza East 1 power plant 556 Briquette factory 495 Maritza East 3 power plant 516 Energoremont 826 Troyanovo 3 mine 500 Total 2893

Table. 4.26 shows the total employment at the Maritza East 1 power plant, the briquette plant and the Maritza East mines from 1994 to 1999. As can be seen from the table, employment in the energy industry has been generally declining since 1996, with the greatest decline in employment from 1998 to 1999.

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TABLE 4.26 TOTAL NUMBER OF EMPLOYEES IN MARITZA EAST ENERGY SECTOR INDUSTRIES (1994-1999)

Industry 1994 1995 1996 1997 1998 19991 20002

Maritza East 1 power 1 199 1255 1251 1240 1222 1 192 1100 plant

Briquette plant 1 076 1 040 1 024 995 1032 972

Maritza East mines 10763 12515 13015 12879 12846 9361

Total 13038 14819 15290 15 114 15100 11525

1. Data for Maritza East 1 plant is from 31 October 1999. 1999 Data for briquette plant is from 31 December 1999. 1999 data for Maritza East mines is from 30 November 1999. 2. 2000 data from Maritza East 1 plant is from 29 February 2000.

The majority of the workers at the Maritza East 1 power plant (eg 66 per cent) have achieved a high school or vocational school education. An additional 25 per cent of the plant workforce has achieved an education at the primary school level; only 9 per cent have received a university education at the bachelor or master degree level. The age structure of the Maritza East 1 workforce is shown in Table 4.27. As can be seen from the table, the majority of workers (60 per cent) are between the ages of 30 and 49.

TABLE 4.27 AGE STRUCTURE OF MARITZA EAST 1 POWER PLANT EMPLOYEES

Age Per cent of workforce (1%)

20-29 18

30-39 24

40-49 36

Over 50 22

Total 100

In 1999, the number of registered unemployed people in the Municipality of Galabovo was 1300 persons. Table 4.24 indicates that the total labour force for the Municipality was 9340 persons in 1999 (eg between the ages of 15 and 55). Therefore, 1300 unemployed persons translates to an approximate unemployment rate of 13.9 per cent for the Municipality in 1999. However, communication with municipal authorities and the municipal Employment Bureau indicate that real unemployment figures are much higher. While the Galabovo Employment Bureau provides financial resources for unemployed persons to enrol in courses to acquire job skills and other qualifications, many people with no sources of private transportation find it difficult to attend such courses as they are usually located in Stara Zagora, which is 1 hour away from Galabovo.

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In terms of higher education, it is estimated that only 3 per cent of the population of the Municipality are educated at the university level. The technical college in the town of Galabovo prepares students for work in the energy sector (eg career training to become electricians, mechanics, accountants, engineers, technicians, energy equipment operators, etc). As most of these professional positions are filled by males, most of the female students in Galabovo do not achieve more than an 8th grade education. Those that do, musk seek education in other locales, such as Stara Zag ora.

Municipal services

Health care

There is one hospital in the town of Galabovo that has 36 doctors and 105 beds. In addition to this hospital, there are health care centres in each of the ten villages within the Municipality of Galabovo, but only the villages of Glavan and Obruchishte have qualified doctors (one doctor in each of these two towns. The remaining village health care centres are staffed by nurses.

Table 4.28 presents the types of illnesses recorded in 1999 in the Municipality of Galabovo.

TABLE 4.28 ILLNESSES RECORDED IN THE MUNICIPALITY OF GALABOVO

Type of illness Number of people affected by illness

Respiratory 5774

Nervous system 3133

Kidney/urinary 1409

Injuries and poisonings 1 641

Total 11957

Fire protection

There is one fire station in the town of Galabovo that has two fire trucks. The Maritza East 1 and 3 power plants have their own fire trucks for their own fire protection arrangements. The Maritza East 1 plant has two fire trucks.

Solid waste

As shown in Table 4.29 the total annual solid waste generated in the Municipality of Galabovo for 1997 was 19 523 tonnes of solid waste, which amounted to an average per capita waste generation rate of 1.11 tonnes per person per year for the Municipality. The largest component of the municipal waste stream is organic waste, which comprises almost one half of the waste stream.

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TABLE 4.29 GENERATION OF SOLID WASTE BY TOWNNILLAGE IN THE MUNICIPALITY OFGALABOVO

Town/village Number of residents Annual solid waste Annual per capita generation (tonnes) solid waste generation rate Galabovo 10246 14288 1.39 Obruchishte 2287 1620 0.71 Velikova 117 115 0.98 Aprilovo 457 290 0.63 Razdelna 147 150 1.02 Musachevo 321 280 0.87 Mednikarovo 730 480 0.66 Iskritsa 294 210 0.71 Madretz 1 094 320 0.29 Glavan 1 559 1 500 0.96 Pomoshtnik 398 270 0.68 Total 17 653 19523 1.11

There is a municipal solid waste collection service in the town centre (eg town of Galabovo) that collects trash from residences, apartments, and administrative, industrial and commercial buildings. Collected solid waste from the town centre is disposed of at the town of Galabovo's solid waste landfill located 0.5 km south-east of the town centre. This landfill site is called "Erkesene". The landfill is not fenced and has no vegetated buffer zone to trap wind-blown debris; therefore wind-blown trash is common in this area. The maintenance of the Galabovo landfill is the responsibility of a contracted entity from the town of Radnevo.

There is no solid waste collection service in the ten villages of the Municipality. Designated solid waste containers are provided in several locations in each of the villages. There is no separation of waste; all waste types are deposited within the containers. The solid waste containers are then transported to one of several landfills designated for residential and construction wastes. Table 4.30 lists the solid waste landfills in the Municipality of Galabovo.

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TABLE 4.30 SOLID WASTE LANDFILLS IN THE MUNICIPALITY OF GALABOVO

Townlvillage Name of landfill Distance from Landfill capacity town/village (km) (tonnes) Galabovo Erkesene 0.5 68268 Obruchishte Nad rakienia kazan 0.5 23200 Velikovo Do mogilata 0.7 765 Razdelna Skeleta 1.0 4130 Musachevo Prystnitsata 0.3 712 Mednikarovo Karagyaurovo birchilo 1.0 7590 Iskritsa Chuchura 1.5 1875 Madrets Dermenkata 0.1 3000 Glavan Kalinkata 2.0 8780 Pomoshtnik Kofaliata 0.3 3920 Total 125290

Water supply

The drinking water supply for the town of Galabovo and the village of Obruchishte comes from water withdrawn from various well sources. The well water is then piped to a water tank at a site known as Zhrebchevo. The water from the tank receives water treatment near the town of Sliven and then is piped to a distribution water tank located in the village of Aprilovo. From there, water is piped to the town of Galabovo and the village of Obruchishte. The drinking water in the area of Galabovo is very low in iodine and as a result there have been high incidences of endocrine system-related illnesses in children. As of 2 years ago, school children were given iodine tablets to prevent such illnesses, but this is no longer the case due to a lack of municipal funding.

Many residences in the Municipality of Galabovo have wells for non-potable water use for housekeeping purposes such as watering gardens.

Sewage system

The town of Galabovo has a central sewage pipe distribution system, while the villages in the Municipality do not. There is no waste water/sewage treatment plant in the town of Galabovo. The waste water from the pipe distribution system is discharged untreated to the Sazlijka River. Almost all of the houses in the Municipality of Galabovo have outdoor latrines.

4.11 Transportation

4.11.1 Regional transportation network

Figure 4.14 is a regional map that shows the relationship of Galabovo to major towns and cities. The main means of accessing the region is via roadway and rail. The airport in Plovdiv, approximately 95 km west of the project site, is principally a domestic airport while the Sofia airport, located 245 km

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west of the site, is the main international airport. Passenger trains provide daily service between Stara Zagora (located approximately 40 km north-west of the site) and Sofia. Otherwise, public transport within the region is principally via bus while private transport includes cars, motorcycles, horse drawn carts and bicycles. Additional rail lines, some owned by NEK and MME, provide direct access for lignite and freight delivery to the plant site.

Highway E-80 is the main roadway connecting southern Bulgaria and Turkey. From the border at Svilengrad, Highway E-80 heads north-west to Haskovo and Plovdiv. In this area the road is largely two lanes (one lane each way) with few traffic signals or other means of controlling traffic or limiting access. In the vicinity of Plovdiv, Highway E-80 becomes a divided four-lane limited access highway that continues west to Sofia.

For traffic heading north, the main highway is E-85, which proceeds north from Highway E-80 at Haskovo to Stara Zagora. Highway E-85 is located approximately 20 km west of Galabovo.

An alternative north-south route begins near the town of Harmanii along Highway E-80 where it proceeds north through Simeonovgrad, Galabovo and Radnevo. At Radnevo, northbound traffic can head north-west to Stara Zagora to connect with Highway E-85, or continue north to Nova Zagora. While traffic maps would indicate that the main north-south road from Svilengrad, Bulgaria on the Turkish border to Ruse, Bulgaria on the Romanian border would be via Highway E-85, observations at the project site indicate that substantial international truck traffic is choosing the second-class road that passes through Galabovo and directly in front of the project site.

4.11.2 Project site access

The access to the project site from Highway E-80, located approximately 22 km south of the site, is provided via the alternate north-south route previous described that passes through Simeonovgrad and then the Galabovo. Direct access to the site from Galabovo is via a two-lane road that connects Galabovo and the village of Obruchishte.

Three key traffic intersections in Galabovo are critical to the movement of the many large trucks that pass through the region. The first intersection is located on the south side of town and is a narrow "r intersection. This intersection is without any signage or traffic control except to indicate the various destinations. Approaching from the south northbound traffic must execute a sharp turn to the right and cross over a narrow two-lane railroad crossing that has a barrier to prohibit movement when the tracks are in use. The road then heads in an easterly direction and passes by a number of large apartment buildings before making another sharp right turn at the second key intersection.

At the second intersection the main traffic flow is to the east. This traffic has the right of way relative to all other traffic movements that include either a left turn into the town of Galabovo or a continuation straight ahead on a road that passes on the east side of town, generally paralleling the Sazlijka River. After turning right, the road is two lanes in each direction going over the bridge before splitting at a large intersection where traffic flow is controlled by a large island, in the centre of which is the Galabovo town monument. After a right turn, heading east-north-east, the road continues in the direction of the power plant. The road width and condition vary substantially in this very short distance from being new, divided, and well maintained, to narrow and severely deteriorated on the approach to the plant.

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In the immediate vicinity of the power plant, the road widens and provides dedicated areas for bus drop off on both the north and south sides of the road. Several elevated steam lines pass over the road with substantial clearance for the large transport trucks.

The third main intersection is immediately east of the power plant. Traffic through this intersection is controlled via three traffic islands. Traffic bound for Obruchishte and the Maritza East 3 power plant is uncontrolled while northbound traffic is controlled via a stop sign. After the stop the roadway is briefly divided as it passes under the steam pipes that connect the briquette plant to the ME1 power plant. Beyond the power plant and briquette plant the road is again two lanes that are undivided.

Traffic counts taken in front of the plant site during the morning peak hour, that included the shift change at the power plant are shown in Table 4.31. While the traffic counts during this period are dominated by worker-related automobile traffic, they show the relatively constant pattern of truck traffic that occurs throughout the day. This is mostly international truck traffic that is travelling through Galabovo, passing through each of the three key intersections.

TABLE 4.31 TRAFFIC VOLUME AT EXISTING MARITZA EAST 1 POWER PLANT

Eastbound Westbound Time period Cars Trucks Cars Trucks

7.15 am - 7.30 am 25 13 23 11

7.30 am - 7.45 am 41 16 14 7

7.45 am - 8.00 am 27 9 12 6

8.00am-8.15am 23 15 25 9

8.15 am - 8.30 am 28 21 13 13

8.30 am - 8.45 am 24 19 17 18

4.12 Noise

Noise is a feature of all environments. It is objectionable when it is inconsistent with the environment by being either too loud or distinctive in character (ie tonally or temporarily varying). The goal of acoustical design is to have power plant noise consistent with the level and character of other sounds in the environment and is therefore based upon an understanding of the existing background sound in areas that surround the project site.

4.12.1 Site description

The proposed new Maritza East 1 power plant is to be located at the site of the existing Maritza East 1 power complex. Figure 4.15 is a topographical map that shows the location of the project site, surrounding areas and noise monitoring locations. From a noise perspective, the area can be characterized as follows:

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• North of the proposed plant is unoccupied land with no nearby residential properties where sound impact should be considered.

• East of the proposed plant is a lignite briquette manufacturing plant and the southern section of the Maritza East lignite mines. Again, there are no nearby residential properties where sound impact should be considered.

• South of the proposed plant is a commercial facility (Energoremont). This facility is approximately 800 m south of the main power block of the existing plant. The village of Obruchishte is located south and south-east of the project site. The nearest residences to the power plant in this village are approximately 1.4 km south of the main power block.

• West of the proposed plant is the town of Galabovo. The nearest residences to the power plant in this town are located approximately 2 km west of the main power block and 1.2 km from the lignite storage piles.

4.12.2 Existing noise sources

Background sounds in the communities surrounding the proposed project site are typical of rural villages that are adjacent to industrial developments. Primary sources of transient background sounds that influence the acoustic environment include:

• traffic on nearby roadways and railways

• sounds produced by domestic animals (dogs, chickens, donkeys, etc)

• sound produced by human activity

• indigenous sources of sound such as birds, insects and weather.

In addition, steady state background sounds produced by the distant industrial facilities are also audible. These sounds are only audible during periods when there is a void in the previously mentioned transient sounds (typically during the late night and early morning hours).

4.12.3 Representative monitoring locations

For this study, background sounds were monitored at four representative locations in the project area. In general, monitoring locations were selected on the basis of where sound impact from the new facility is anticipated to be greatest. A thorough review of land uses in the vicinity of the project site was conducted to identify the appropriate measurement locations. These locations are indicated in Figure 4.15 and represent the four closest residential receptors that are in defined residential areas surrounding the proposed AES-3C Maritza East 1 power plant.

4.12.4 Sound monitoring programme

In order to document the time varying characteristics of environmental sounds, monitoring at the selected locations was conducted during the daytime and night-time hours of Monday, 14 February and Tuesday, 15 February 2000.

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Attended interval (10-20 minutes) monitoring was performed at all four selected locations. These measurements were performed using a Quest Technologies Model 2900 Integrating/Logging should level meter outfitted with a % inch measurement interval using a Quest Technologies QC-10 sound level calibrator. During all measurements the sound level meter was tripod mounted with the microphone situated approximately 1.5 m above ground. This instrument confirms to ANSI S1.4- 1983, IEC 651-1979 and IEC 804-1985 standards for Type 2 sound measurement instrumentation. For each measurement interval the following A-weighted sound level descriptors were recorded:

• maximum sound level (Lmax)

• minimum sound level (Lmin)

• percentile sound levels (Los, L10, Lso, Lgo )

• equivalent sound level (Leq).

Wind speeds, temperature, other relevant meteorological data, traffic counts and subjective observations were also recorded for each measurement interval.

Percentile sound levels (Los, L10, Lso, Loo) are the statistical descriptors of the A-weighted sound pressure levels exceeded 5 per cent, 10 per cent, 50 per cent and 90 per cent of each interval monitored. The Loo represents the nominally lowest levels reached during the monitoring interval. The Lgo is typically influenced by sound of low level, but nearly constant duration, such as constantly operating eqUipment or distant traffic lights. The Lgo is often used to quantify the existing background sound level. Conversely, the Los represents the highest sound levels reached during a monitoring interval. The Los is typically influenced by sound of high level, but short duration, such as that produced by vehicles passing by the measurement location.

The equivalent sound level (Leq) is the energy average sound level and is influenced by both sounds of low level and long duration, as well as sounds of high level and short duration. Bulgarian Standards and World Bank Guidelines use the Leq for expressing limits for time varying sound sources.

4.12.5 Monitored sound levels

Table 4.32 presents a summary of the existing environmental sound levels (Leq and Loo) measured at each of the four selected monitoring locations. Data presented in Table 4.32 is the arithmetic mean of the daytime and night-time intervals for each location. A complete listing of all the interval data can be found in Appendix C.

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TABLE 4.32 SUMMARY OF MEASURED NOISE DATA FOR EXISTING CONDITIONS

Existing A-weighted sound levels (dBA)

Leq (day) L90 (day) Leq (night) L90 (night)

Location 1 57 41 47 37

Location 2 54 38 53 36

Location 3 50 39 42 38

Location 4 56 43 49 41

With the exception of the night-time measurements performed at Location 3 there is a significant difference between the background (L90) sound level and the equivalent sound level (Leq). This indicates that for the most part, sound at the selected sites is dominated by transient events produced by car and truck passbys. Locations 1 and 4 are the closest to active roadways, and as would be expected the sound levels measured at these locations were higher than at the other two locations. The fact that night-time background sound levels (Loo) are typically above 35 dBA indicates that steady-state background sounds produced by existing industrial facilities are audible only when traffic noise is negligible.

4.13 Land use

Like the country as a whole, the land use in the area of the project is dominated by agriculture. With the organization of large-scale agriculture in Bulgaria in the late 1940s and 1950s, field boundary strips were ploughed, trees and bushes were uprooted and large fields were cultivated. The ploughing of pasture land and deforestation resulted in high expanses of arable land that continue to dominate the landscape.

The Stara Zagora region, where the new Maritza East power plant will be located, is a productive region which has a thriving agricultural community. Table 4.33 shows the amount of arable land versus total land area for the three municipalities within the 20 km study region defined in the air quality analysis as the area of maximum expected project impact.

TABLE 4.33 MUNICIPALITIES OF THE STARA ZAGORA REGION

2 2 Southern municipalities Total land area (km ) Arable land area (km )

Opan 300 188

Radnevo 532 386

Galabovo 343 275

Document No. 62160NPBPfOOOOO1 0774R040.00CIS5f18NV PBPower Section 4 Page 67

In Opan, 62 per cent of the land is arable and agricultural irrigation is a widely practiced technique. Corn fields and perennial plants are the most widely cultivated crops.

Radnevo, located to the north of the future thermal power plant, is known for its serial crops. The 2 agricultural area in this municipality is 386 km , or 72 per cent of the total land area. Perennial crops grown here include cherries, hazelnuts and grapes. The most widely cultivated crops in Radnevo are wheat, barley, sunflower and cotton.

2 Galabovo has a total of 275 km or arable land that presents 72 per cent of the land area of the municipality. Wheat and barley crops are produced on 45 per cent of the arable land, while 27 per cent of the arable land is used for growing industrial and fodder crops like sunflower, silo corn and 2 cotton. Woodland areas constitute 37.7 km of Galabovo, and the remaining 19.27 km2 of land is populated.

Following agriculture, the other dominant land use in Galabovo and Radnevo municipalities is the 2 Maritza East lignite mining fields. Covering a land area of approximately 80 km the Maritza East mining complex accounts for approximately 90 per cent of Bulgaria's lignite output.

4.14 Recreation and visual resources

The project site is a previously developed industrial area while the surrounding area is either isolated towns or large agricultural fields. There are no formally managed recreation areas in the region nor are there areas that would be considered recreation destinations for foreign visitors. The nearby Rozov Kladenetz Lake and the Sazlijka and Sokolitsa Rivers are used on a limited basis for local recreational fishing. The lake is often noted as important to various bird species and as an important area for recreational bird watching.

Topographic features within and surrounding the project area are flat to rolling countryside with vegetation dominated by active agriculture. Man-made features that have altered the landscape include the existing Maritza East 1 thermal power plant, high-voltage transmission line corridors, an above ground electrical SUbstation and distribution lines, and the railroad tracks that connect the mine to the power plant.

10 km to the east of the Maritza East 1 power plant is another coal-fired power plant, referred to as Maritza East 3. This plant, approximately twice the size in terms of installed capacity as the existing Maritza East 1 plant The heights of the existing exhaust stacks that are the dominant features at both plant sites are 150 m at Maritza East 1 and 325 mat Maritza East 3.

Farther to the north-east is the Maritza East 2 power plant. At any point on the roadways in the project area, one or more of the existing power plants is visible. From selected locations, all three power plants are visible.

4.15 Archaeological, historical and cultural resources

4.15.1 History

The Thracians ruled Bulgaria beginning as early as the fifth century BC and inhabited an area extending over most of modern Bulgaria, northern Greece and European Turkey. The Thracians were

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a powerful and wealthy warrior aristocracy that had close ethnic links with their neighbours in both the Danube basin to the north and Asia Minor to the east, which placed them at the centre of an extensive Balkan-Asian culture.

The Bulgarian nation was formed in late 660 with the establishment of the first Bulgarian Kingdom. Early in the 11th century they were briefly overtaken by the Byzantine Empire. The second Kingdom was established in late 1100 at which time the borders of Bulgaria extended from the Adriatic to the Aegean. The Ottoman Empire took over Bulgaria in approximately 1400 and ruled the country for the next 500 years.

4.15.2 Cultural resources

As a result of its history, Bulgaria is rich in cultural resources. Of the 630 properties on the World Heritage List, nine are in Bulgaria. Two of the sites, Srebama Nature Reserve and Pirin National Park, are natural areas while the remainder include a church, monastery, tomb or ancient city. None are in the vicinity of the proposed project.

Separate from these sites of international importance, the Bulgarian countryside, including the region where the project is located, has numerous Thracian burial mounds, the majority of which remain unexcavated. Thracian tombs are of particular importance because they often possess funerary offerings that include gold, silver, bronze and clay objects which depict the civilization that existing at the time.

The Ministry of Culture seeks to protect these sites through laws and regulations that provide a three tier classification system that identifies their importance and then, based on site significance, dictates the use of the land where the resources are located.

Resources are classified as being either a World Heritage site (as noted above); a Class 1 site indicating national significance; or class 2, indicating regional or local significance. Prior to any construction activities, potentially affected areas must be surveyed by a registered archaeologist who has the authority to provide general archaeological research, in particular in support of project environmental impact assessments.

Investigations undertaken for this project identified two listed, Class 1 archaeological sites. The first is a small Thracian burial mound, with a height of 1.80 m and a diameter of 16 m. It is located immediately north of the existing Maritza East 1 power plant site, on the west side of the road between the plant and Radnevo. While this archaeological monument is considered to have high cultural, historical and scientific value, a steel pylon for a high voltage electric power line was previously installed on the burial mound.

The second site is within the existing Maritza East 1 thermal power plant complex, just west of the main turbine building and in the immediate vicinity of the active coal stockpile. This site is a relic of the prehistoric villages of the Neolithic and Proto-Neolithic periods, the Bronze Age and the early Iron Age. This prehistoric settlement is enclosed with a wire fence to protect it from current plant operations.

Additional cultural sites are found in the area but many have been disturbed due to past development and at the time when there was less concern for cultural resources. A Thracian sepulchral burial

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mound called "Ruchukova Moglia" is located south of the Maritza East 1 Complex. The mound was partially destroyed during construction of the road to Galabovo. Archaeological research associated with development of the Maritza East 2 power station identified 25 archaeological remains. The remains of a village settlement destroyed in 5500 BC are approximately 100 km due west of the Maritza East 3 power station. Throughout the Sazlijka River valley there are numerous "pit" complexes from the early Iron Age. These pits, which date from the second and first century BC are largely unidentified and unstudied but are important to an understanding of the history of the Thracian tribes as they typically contain abundant archaeological materials.

Per Bulgarian regulation, as long as project activities will not disturb any identified sites within the area studied, the opinion provided by the archaeologist who undertook the investigation is sufficient for approval of the Bulgarian EIA and no further action is required. Potential encroachment into either of the identified areas would result in additional investigation to further determine archaeological significance. Disturbance outside the area investigated would require study to determine the presence of identified sites. It is not anticipated that project activities will impact areas outside the project site boundaries.

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5. ENVIRONMENTAL IMPACTS

This section presents the analysis of the proposed project's potential impacts to the natural and human environment. Environmental benefits will result from the installation of state-of-the-art pollution control equipment which will replace old, inefficient polluting power generation equipment. As a condition of Bulgaria's accession to the European Union, two units at the Kozloduy nuclear power plant have been decommissioned and two further units are intended to be decommissioned in 2006 and 2007. The AES-3C Maritza East 1 power plant project will help to replace the lost capacity resulting from such decommissioning while also helping Bulga~ia to become a net exporter of electricity. Socio-economic benefits of the project include short- and long-term job creation in the Galabovo region.

Numerous environmental impact categories are addressed in this section as they relate to construction and operation of the proposed power plant. A summary section is provided at the end of Section 5 that addresses impacts from ancillary facilities such as the ash and gypsum disposal areas and the lignite mining area. Some aspects of the proposed project have more significant potential impacts to the environment and are discussed in greater detail. Siting the project on a brownfield industrial site will help to minimize environmental impacts. As with all lignite-burning power plants, the primary impacts to the environment relate to air emissions and water use and discharge. Other resources will experience little to no change and are therefore discussed only briefly. Air emissions, in particular, are an important aspect of lignite-burning coal facilities. Thus, a significant portion of this section is devoted to air modelling.

5.1 Topography, geology and seismicity

5.1.1 Construction phase impacts on topography, geology and seismicity

Development of the proposed project will be confined to the Maritza East 1 property. This is a brownfield site comprising of land formerly occupied by the now demolished larger units of the old Maritza East 1 plant, with the west of the site including a now reclaimed ash pond. The natural landscape has already been disturbed as the project site was levelled and/or filled prior to construction of the existing Maritza East 1 power plant. As a result, there will be no on site or off site impacts to topography.

The project site is within a region identified as 8 to 9 on the MSK-64 earthquake intensity scale. The facility will be built according the standards necessary for development in such a region. Regulations applicable to project construction including the following:

• Ordnance No 1 on geologic protection activities (SG No '12/1994);

• Ordnance No 1 on flat foundation design (BSS No 10/1996); and

• Standards of Building and Facility Design in Seismic Regions (SG No 6/1989).

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5.1.2 Operation phase impacts on topography, geology and seismicity

The only operational activity that will have a direct impact on topography, geology or seismicity is solid waste disposal. A new landfill will be developed for the project in an area that was previously been used for the disposal of mine overburden. Given that the topography in this area has already been altered this incremental impact is not considered significant. Appropriate geotechnical studies will be done as part of landfill design to fully determine the site-specific conditions and assure protection of underlying ground water resources.

5.2 Soils

5.2.1 Construction impacts on soil

It is intended that excavated soils will be stored and used on-site. Construction debris from removal of underground foundations, pipes and utilities will be disposed of off-site in an area designated by municipal authorities. Should there be excess excavated soils and/or stone, these materials will either be deposited in the facility's planned construction debris landfill (possibly used as cover materials) or placed in railcars and disposed of in the Dryanovo overburden disposal area.

No identified on-site soil contamination areas are expected to be disturbed by project construction. In consideration of the historical industrial use of the project site, prior to the initiation of site excavation, a series of soil samples has been collected from different areas of the site and analysed for potential contamination. Further soil sampling will be performed both in areas where historic operations indicate a potential for contamination and in areas where considerable excavation is anticipated (eg the planned main power block area). Where areas of soil contamination are identified, their location will be noted and, during construction, soil excavated from these areas will be separately stockpiled, further tested, and either redistributed on-site or disposed of off-site (depending on testing results) in accordance with the requirements of the Galabovo municipality.

5.2.2 Operation phase impacts on soil

During operation there will be no impacts to on-site soils. There is the potential for impacts to the general chemistry of regional soils as a result of air emissions from the plant (acid deposition). Potential off-site soil acidification impacts are discussed in Section 5.6.

5.3 Air quality

5.3.1 Construction phase impacts on ambient air

The construction phase of the proposed AES-3C Maritza East 1 power plant will have a duration of approximately 3 years. Air emissions resulting from construction activities are of a temporary and intermittent nature. During the construction phase, air pollutant emissions will consist of fugitive particulate matter that results from earthwork, demolition, and vehicular traffic and wind erosion from PBPower Section 5 Page 3

exposed surfaces. Emissions from the operation of vehicles and heavy equipment and other internal combustion equipment will consist of particulate matter as well as gaseous combustion products. There will also be emissions of volatile organic compounds from paint and cleaning solvents and asphalt operations.

All construction phase emissions will be released at or close to ground level. Much of the particulate matter generated will deposit nearby. Suspended particulate matter and gaseous pollutants will rapidly disperse due to the turbulence caused by the interaction of the wind with the buildings, structures and equipment at the site. As such, construction phase emissions will be sufficiently diluted such that concentrations beyond the work site are expected to be inconsequential.

Fuels to be used during construction include diesel and gasoline to power on-site construction equipment as well as vehicles of the construction workers. The majority of the site preparation activities that have the greatest potential to generate fugitive particulate matter will occur during the first several months of construction. During the following months, only minor grading and landscaping will occur. Paving and seeding of open areas will control incidental wind erosion of soil particulate matter during the latter stages of the project construction.

Sources of on-site traffic include worker transit in personal vehicles, delivery vehicles, and operation of on-site power equipment and large vehicles such as cranes, graders and trucks. Paints and cleaning solvents would be used primarily during the late phases of the project. Paving of parking areas and on-site roadways would occur during the early to middle phases of construction, with finish paving during the completion phase.

Emissions produced by construction activities on the project site will be controlled by a variety of means. Unpaved roadways and earth surfaces will be watered to control fugitive dust from vehicle and equipment traffic. On-site vehicles will be cleaned to minimize transport and mobilization of fugitive particulate matter. Paints and solvents will be stored, handled and used and applied in compliance with applicable requirements and Best Management Practices to minimize incidental loss of volatile components.

5.3.2 Operation phase impacts on air quality

5.3.2.1 Project emissions

The project will have an impact on local and regional air quality. However, the facility has been designed so that all emissions meet Bulgarian, EU and World Bank standards. The air quality of the region is expected to approach attainment with ambient air quality standards as other power plants are equipped with pollution control equipment or decommissioned.

Based on the current design, there will be the following sources of air emissions at the proposed thermal power plant:

• two pulverized lignite-fired boiler units;

• diesel light fuel auxiliary boiler;

• emergency diesel generator; PBPower Section 5 Page 4

• liquid fuel storage tanks;

• a natural draught cooling tower. • fugitive dust from lignite and limestone handling. • emergency diesel driven fire pumps

The boiler units in the proposed power project will be the main source of emissions. Pollutants

emitted include sulphur dioxide (S02), nitrogen oxides (NOx), particulate matter (PM) and carbon monoxide (CO), with minor amounts of trace elements and non-methane hydrocarbons (NMHC). The auxiliary boiler and diesel generator emissions will be negligible in comparison to the power boilers because of their relative size, cleaner liquid fuel and very low frequency of usage. Because neither the auxiliary boiler nor the diesel generator will be used at the same time as the lignite-fired boilers, emissions from these auxiliary and standby units are not included in the air quality assessment. The liquid fuel storage system that will emit very small quantities of non-methane hydrocarbons is also not included in the air quality modelling.

Induced draught fans will draw flue gases from each boiler unit through an air heater (heat exchanger) and into a set of electrostatic precipitators (ESPs). The ESPs will be designed to capture fly ash and dust particles present in the flue gases. From the ESPs the flue gases will be directed into a wet limestone/gypsum flue gas desulphurization plant (FGD), which will reduce the sulphur dioxide (S02) to 400 mg/Nm3 to ensure compliance with EU and Bulgarian standards. Dust emissions will also be reduced to 30 mg/Nm3 in accordance with EU and Bulgarian standards. The flue gases will be discharged through two flues (one per boiler) located within the 135 metre high natural draught cooling tower.

Boiler emissions

Table 5.1 presents the parameters used to estimate the pollutant emissions from each of the lignite boilers.

Table 5.2 summarizes the pollutant emissions from each of the lignite boilers. Discussion of emissions from each pollutant follow.

TABLE 5.1 PARAMETERS USED IN DETERMINING POLLUTANT EMISSIONS FOR EACH 335 MW BOILER

Parameter Units Lignite

Maximum heat input MW thermallh 970.5

Maximum lignite burned Kg/sec 162

Combustion gas flow rate Nm3/sec - dry 436

Oxygen concentration Per cent - dry 6 PBPower Section 5 Page 5

TABLE 5.2 ESTIMATED CRITERIA POLLUTANT EMISSIONS ANTICIPATED FROM EACH 335 MW BOILER

Pollutant Units Estimated Bulgarian World Bank EU limits emissions limits limits

S02 tonnes/day 13.95 - 117 - 3 mn/Nm , @ 6% O2 - dry 400 400 2000 400 - g/sec 161.5 -- -

NO 3 x mg/Nm , @ 6% O2 - dry 200 200 750 200 g/sec 81 ---

3 PM mg/Nm , @6% O2 30 30 50 30 g/sec 12 - - -

3 CO mg/Nm , @6% O2 00 250 -- g/sec ---

CO2 kg/sec 108 ---

Sulphur dioxide S02

When combined with other pollutants, S02 can have a variety of human health affects. At high concentrations, it can affect human respiration, especially among asthmatics. It can also be transformed into acidic compounds that can harm vegetation and acidify lakes and streams.

802 is produced by oxidation of sulphur in fuel. It is assumed that all of the sulphur in solid fuels is emitted upon combustion as gaseous sulphur dioxide. Uncontrolled emission of 802 is thus affected by the sulphur content of the fuel alone, and not by the firing mechanism, boiler size or operation. Sulphur dioxide can either be controlled by limiting the sUlphur content of the fuel or by removing S02 from the exhaust gas after its formation. From the ESPs, the flue gas will be directed into a wet limestone flue gas desulphurization (FGD) system, which will absorb sufficient sUlphur dioxide (S02) to ensure compliance with Bulgarian and EU standards, which are not less than 95 per cent removal as S02 in the FGD plant and a maximum of 400 mg/m3 in the exiting flue gases. Total S02 emissions will be 323 g/sec (emissions levels from all Maritza plant are summarized in Table 5.5).

Nitrogen oxides (NO.)

Oxides of nitrogen, along with non-methane hydrocarbons, contribute to the formation of ozone in the lower atmosphere. In addition, nitrogen dioxide (N02) when inhaled in sufficiently high concentrations, can result in respiratory distress and related physical ailments. The chief component of NO. emissions is nitric oxide (NO) which is much less a health hazard than N02. However, most of the NO emitted to the atmosphere is transformed into N02 as it travels downwind. At distances PBPower Section 5 Page 6

greater than 50 km, NOx is also transformer to nitric acid and nitrates, which can contribute to acidic deposition.

NOx is formed through combustion processes in two ways: (1) the combination of elemental nitrogen and oxygen in the combustion air within the high temperature environment of the combustor (thermal

NOx), and (2) the oxidation of nitrogen contained in the fuel. The rate of thermal NOx formation is dependent on the residence time, amount of free oxygen and peak flame temperature. Virtually all NOx emissions originate as nitric oxide (NO), as both nitrogen and oxygen disassociate into the atomic form at the high temperatures within the boiler and then recombine to form NO. A minor fraction of the NO is further oxidized in the flue gas system to form N02. The bulk of the NOx formation will be through thermal oxidation of nitrogen from the combustion air, referred to as thermal

NOx.

The amount of fuel NOx formed is dependent on the amount of nitrogen compounds in the coal. The rate of formation of thermal NOx is a function of the residence time, free oxygen and the peak flame temperature. Combustion techniques for managing the formation of thermal NOx are aimed at minimizing one or more of these variables.

Particulate matter (PM)

High concentrations of inhalable particulate matter (PM1o, particles with aerodynamic diameter of less than 10 microns) are know to present a health hazard, especially in conjunction with exposure to other pollutants, such as S02. Recent evidence also indicates that fine, respirable particulate matter (less than 2.5 micron diameter) comprise most of the health risk associated with respiratory distress and increased mortality rates.

The composition and amount of particulate matter emitted from coal-fired boilers are a function of firing configuration, boiler operation, coal properties and emission controls. Particulate matter will be emitted from the boilers as a result of entrainment of incombustible inert matter (ash) and condensable substances. PM emissions will be removed from the flue gas stream by electrostatic precipitators.

Because of the high removal efficiency of large particles, nearly all of the particles exiting the precipitators are in the form of PM 1o. Although it is likely that actual emissions will be somewhat lower, in the modelling evaluation the emission rate has been set to the Bulgarian and EU limit of 3 30 mg/m at 6 per cent oxygen in the flue gas.

Carbon monoxide (CO)

CO is formed as a result of the incomplete combustion of carbon and organic compounds in fuel. CO emissions are a function of oxygen availability (excess air), flame temperature, residence time at flame temperature, combustor design and turbulence. Inhalation of CO causes reduced ability of blood to delivery oxygen to vital tissues, affecting primarily the cardiovascular and nervous systems. High concentrations can affect individuals with heart disease. Very high concentrations can cause dizziness, headaches and fatigue, and in extreme cases, death.

Control of CO can be realized in two ways: (1) combustion modifications to minimize the formation of the pollutant, or (2) flue gas catalytic oxidation of any CO formed in the combustion process. The PBPower Section 5 Page 7

latter control is not routinely installed on lignite boilers due to the inherent high combustion efficiency of this type of boiler.

Based on measurements at other lignite fired plants in the Maritza area the CO emissions will be close to zero.

Carbon dioxide (C02)

The primary combustion products of all fossil fuels are carbon dioxide (C02) and water vapour. While

CO2 is not toxic and is naturally produced through respiration, it is the major component of "greenhouse gases". The other major, naturally occurring, greenhouse gas is methane. Greenhouse

gases such as CO 2 and methane build up in the atmosphere inducing global climate change (the

"greenhouse" effect"). Increases of CO2 in the global atmosphere are attributable to fossil fuel combustion and have been implicated in potential global warming. Effects of climate change on human health and environment are still uncertain. Global temperature changes could, however, have a variety of serious effects.

As a signatory to the Kyoto protocol, it is the goal of Bulgaria to reduce the emission of greenhouse

gases such as CO2 and methane by at least 8 per cent from 1990 levels. The proposed plant at Maritza East 1 and other upgrades to Maritza East 2 and 3 will provide more efficient combustion of the lignite reserves than the existing lignite burning facilities in the Maritza East area.

Consider, for example, the effect of replacing the aging units at the existing Maritza East 1 power plant (which until the early 1990s had a capacity of 500 MW) with the proposed 670 MW facility. The new units will be designed for a heat rate of 10 320 kJ/kWh (LHV) basis at full load. The plant will operate in base load mode so that the heat rate should always be near the full load value (as opposed to part load where efficiency is lower). With an average heating value of the fuel of 591 0 kJ/kg, the amount of fuel burned at the new units will be approximately 10200/5910 kg/kWh - 1.7 kg/kWh. This

results in a CO2 emission of approximately 6 million tonnes per year.

The similar numbers for existing units are developed by dividing the annual quantities of fuel burned by the annual power generation, assuming that process steam is insignificant. In NEK's technical brochure on the existing Maritza East 1 plant, it is stated that the average annual generation is 1000 GWh and that average coal consumption is 2.7 million tonnes for the current 200 MW plant.

The amount of fuel burned therefore is 2.7 kg/kWh. Based on a 500 MW plant size, the CO2 emissions were approximately 7 million tonnes per year. Therefore, the new plant features increased efficiency plant emissions, the new plant (even with a higher MW capacity) features a reduction of

CO2 emissions by more than 15 per cent. This corresponds to an annual reduction in CO2 emissions of approximately 1 million tonnes.

Trace elements

There will be small amounts of trace elements emitted as a result of the combustion of the lignite. Trace element emission rates were calculated as a fraction of particulate emissions based on concentrations in the ash (Maritza East 1 December 1999 EIA) supplemented by data from the US EPAs AP-42, Emission Factors for Lignite Combustion (Chapter 1.7, Table 1.7-14. Emission Factors for Trace Metals from Controlled Coal Combustion, September 1998). The EPA report is based on field measurements at 11 power plants. Emission rates for the proposed plant are shown in Table 5.3 PBPower Section S Page 8

Although a fraction of these low trace element emissions may deposit on the surrounding area, it has been shown that trace element emission rates are sufficiently minor so as not to impact soils and vegetation.

TABLE 5.3 AIR TOXIC EMISSIONS WEIGHTED AVERAGE LIGNITE COMPOSITION

Emissions basis

Trace metal Fuel-based emission Concentration in fly Emission rate factor ash (Ib/ton)* (%)** (g/sec)

Antimony 1.80E-OS - 1.36E-03

Arsenic - 0.0062 2.43E-03

Beryllium 2.10E-OS - 1.S8E-03

Cadmium - 0.006 2.3SE-03

Chromium - 0.002 7.84E-04

Cobalt - 0.004 1.S7E-03

Copper - 0.009 3.S3E-03

FluorinelHF 4.20E-04 - 3.16E-02

Lead - O.OOS 1.96E-03

Manganese 4.90E-04 - 3.69E-02

Mercury 8.30E-OS - 6.2SE-03

Nickel - 0.1 3.92-E-02

Selenium 1.30E - 9.29E-02

Zinc - 0.2 7.84E-02

US EPA AP-42: #Section 1.7 Lignite Combustion, Table 1.7

December 1999 Bulgarian EIA Maritza East 1, TPP, Table 3.1.3.10

Emissions from materials handling

The proposed power plant will have systems for the handling and storage of coal, limestone and ash.

These systems will control emissions of PM and PM10 such that there will only be small amounts of PM 10 emitted. Fugitive emissions from unloading, transfer and crushing operations were calculated PBPower Section 5 Page 9

using the methodology for materials handling outlined in US EPA AP-42. Emissions of PM and PM 10 from loading, unloading and transfer operations will occur where material is released from one unit to another. Table 5.4 provides the emission estimates for lignite and limestone handling. Potential PM 10 emissions from these sources total approximately 11 tonnes/year.

The fugitive dust emissions will be kept to these low levels by use of modern material handling equipment and good engineering practice dust suppression techniques. As such, these emissions will not substantially contribute to ambient concentrations of PM 10 in the project area.

TABLE 5.4 SUMMARY OF PM 10 EMISSIONS FROM LIGNITE AND LIMESTONE HANDLING

Source Emission rate (g/sec)

Coal pile unloading 0.018837

Coal pile area source 0.060575

Limestone unloading and crushing 0.0924

Primary coal crusher 0.088613

Secondary coal crusher 0.088613

PM 10 emissions equation: E (lblton =0.3S*0.OO32*«U/S)**1.3)/(MI2)**1.4 Where U = mean wind speed (6.5 mph) M =mean moisture content (20% for lignite, 0.2% for limestone) Source: AP-42: 13.2.4 Aggregate Handling and Storage Piles (eq. 1)

The wet gypsum from the control system will be dewatered within the limestone preparation and gypsum dewatering building with the dewatered gypsum having a moisture content of approximately 30 to 40 per cent. Ash and gypsum will be placed in rail cars, and transported off-site to a lined ash/gypsum disposal area. Given the high moisture content of the conditioned ash and the dewatered gypsum, it is not anticipated to be a substantial source of particulate emissions.

Liquid fuel storage

Non-methane hydrocarbon emissions (NMHC) emissions from the liquid fuel storage tanks will be minimal due to the extremely low vapour pressure of the liquid fuel. The liquid fuel will be stored in fixed roof tanks, which is good engineering practice for these low vapour pressure liquids. In addition, the facility will be designed to control any spills that may occur, thereby minimizing emissions of volatile organic compounds.

5.3.2.2 Other sources of air pollution in the Maritza East area

To evaluate the air quality in the area prior to and subsequent to the proposed project requires information about other major sources of air pollutants in the region. The location, emission and stack parameters of the proposed source and other emission sources are provided in Table 5.5. The PBPower Section 5 Page 10

Troyanovo lignite mines are located in the area between the three Maritza East power plants. Emissions estimates for mining activities were developed using US EPA AP-42 emission factors for open coal mining operations and information on the Troyanovo mines from Maritza East Mine Development Guidelines. Table 5.5 describes stack parameters for the other sources of air pollution in the area. The larger units at Maritza East 2 have been equipped with FGD and all four units at Maritza East 3 are undergoing rehabilitation, so only post-rehabilitation specifications are included. These scenarios were used as a basis for air modelling described later in this Section.

TABLE 5.5 EMISSIONS FROM MAJOR SOURCES IN THE MARITZA EAST AREA

Stack parameters Thermal power Emissions Stack co-ordinates plant scenario (g/sec) Height Temp Diameter Velocity

East North H2 T. D. V. S02 NO. PM10 (m) (m) (m) (K) (m) (m/sec)

Proposed Maritza 413846 4667450 135 +10.6 63 10.5 323 161.6 24 East 1 (AES-3C) on ambient

Maritza East 1 - 413702 4666 935 150 470 6 8 876 136 21 100 MW'

Maritza East 2

Stack a 432548 4677 750 325 453 12.4 14 9000 509 90

Stack b 432548 4678050 325 308 9.5 14 530 216 32.5

Maritza East 3 -

Stack a 423836 4665922 150 343 8.6 16.5 283 91 13.5

Stack b 423974 4665884 150 343 8.6 16.5 283 91 13.5

Troyanovo Lignite N/A N/A N/A N/A N/A N/A N/A N/A 25 Mines

'ME 1 is assumed to only produce 100 MW though capacity at that plant exists for 200 MW

5.4 Atmospheric emissions and their impact

5.4.1 Introduction and summary

The aim of the study is to predict the effects on air quality in the vicinity of the AES-3C Maritza East 1 power plant due to the operation of the lignite fired plant.

The impact of the proposed plant has previously been assessed as part of the Environmental Impact Assessment, written in June 2000 by ENSR. The modelling requires revision for the purpose of this Environmental Impact Assessment due to the following reasons: PBPower Section 5 Page 11

• The proposed plant now utilizes a single cooling tower for both cooling and emission of the flue gases from both 335 MW units.

• The dispersion model used, ISC 3, has been superseded by new, more refined models. In the dispersion modelling undertaken for this revised EIA, AERMOD has been selected in preference to ISC 3.

• The standards against which the impact of the plant should be assessed have been revised where appropriate.

The main gaseous pollutant emitted from the proposed new lignite fired power plant is S02 due to the high sulphur content of the lignite fuel. To help lower the emissions of S02 the plant will include a 3 Flue Gas Desulphurization plant that will limit S02 emissions to 400 mg/Nm .

Note that due to the characteristics of the lignite fuel (high ash, high moisture, high sulphur content and low calorific value) the FGD plants cannot meet the 200 mg/Nm3 new plant standard in the Large Combustion Plant Directive. The FGD plants do meet the derogation limits of 95 per cent desulphurization and 400 mg/Nm3 emission values of the Large Combustion Plant Directive

Other pollutants of lesser significance are N02and particulates. The N02 is formed when NO oxidizes

to N02 in the presence of ozone. NO. of which 95 per cent is NO and 5 per cent N02 will be emitted from the plants combustion process and so therefore the plant will contribute to background

concentrations of N02.

The plant is equipped with electrostatic preCipitators and these will remove almost all the particulates 3 produced during combustion. The particulate emission will be at maximum 30 mg/m .

To assess the emissions contribution of the plant, a dispersion modelling exercise has been carried out. Detailed information is provided in this report on plant emissions (and their control), the dispersion modelling and the predicted impact on ambient air quality.

The dispersion modelling exercise quantifies the relative contributions the proposed plant makes to existing background concentrations of S02, N02 and particulates in order to determine the overall effect on a receptors in the area. The assessment of the impact on air quality due to emissions from the proposed plant is based on the predicted changes of the ground level concentrations of pollutants. This is in accordance with the relevant Bulgarian (and other) legislation, which set standards and objectives for these ambient concentrations.

A conservative view of the operation of the plant has been adopted in the modelling so that a "worst case" is presented. The maximum impact of the proposed plant has therefore been assessed on the basis of the following scenarios:

• Operation of both units of the proposed plant at base load.

• Operation of both units of the proposed plant at base load in conjunction with operation of the existing Power Plants at Maritza East 1, Maritza East 2 and Maritza East 3. The modelling takes into account the fitting of FGD to the Maritza East 3 plant (work on which is well underway), to the larger units at Maritza East 2 but not the smaller units at Maritza East 2 plant. The smaller units at r""------

PBPower Section 5 Page 12

Maritza East 2 are likely to be fitted with FGD within the next 3 years but no appropriate data is available for use in the dispersion modelling exercise.

The result of using this pessimistic approach is to ensure that the absolute maximum predicted impact within the potential operating regime of the plant is considered. This ensures that there is a "factor of safety" built into all of the air quality assessment, giving a high degree of confidence that the actual impacts will be less than those presented in this assessment. The results of the modelling have been compared to all appropriate legislation including Bulgarian, European Union and World Bank and are presented in Table 5.9, Table 5.10, Table 5.11 and Table 5.12.

5.4.2 Key findings

Key findings from the analysis, on the basis of the worst case meteorological year with the maximum potential output, are:

• The maximum 25th highest hourly S02 concentration due to the AES-3C Maritza East 1 power plant is 41.6 1l9/m3 for 1996 meteorological data. This represents 12 per cent of the Bulgarian and EU limit of 350 1l9/m3. The location the maximum concentration occurs is 18.6 km to south west of the stack.

• The maximum 25th highest hourly S02 concentration due to the other Maritza Plants is 944.7 1l9/m3 for 1998 meteorological data. This prediction is well over the Bulgarian and EU limit. The location of maximum concentration occurs 26.0 km to south east of the AES-3C Maritza East 1 power plant stack.

• Due to the limitations imposed by recognized modelling programmes available (as discussed in Section 5.4.1) it was not possible to model the combined effect of the proposed AES-3C Maritza East 1 power plant along with the other Maritza plant in one simultaneous modelling run. As a result the maximums reported for the combined effect should be considered an extreme worst case with the necessary meteorological conditions needed to achieve a 'combined maximum' often requiring the wind to be blowing in completely opposite directions simultaneously. This is a result of the way dispersion models record ground level concentrations at given locations for 8760 hours/365 days per year but do not specify the hour in which the reported maximum is recorded. The one exception to this is for annual results where the model results can be combined to give an accurate comparison.

• The maximum 25th highest hourly S02 concentration for the all plants including the AES-3C Maritza East 1 power plant is 951.2 1l9/m3 for 1998 meteorological data. The AES-3C Maritza East 1 power plant contributes 6.48 1l9/m3 to this maximum. This prediction is well over the Bulgarian and EU limit though the AES-3C Maritza East 1 power plant's contribution represents just 1.9 per cent of the allowed limit and just 0.7 per cent of the observed ground level concentration. The location of maximum concentration occurs 8.1 km to south east of the AES- 3C Maritza East 1 power plant stack. PBPower Section 5 Page 13

• The 4th highest 24 hour maximum for the AES-3C Maritza East 1 power plant is 51.85 1l9/m3 for the 1998 metro log ical data representing 41 per cent of the allowed Bulgarian limit. The maximum occurs 15.8 km to the south east of the AES-3C Maritza East 1 power plant stack. Comparisons with the World Bank limit of 150 1l9/m3 for the 24 hour maximum show the plant will operate within this limit with the maximum ground level concentration observed of 121.4 1l9/m3.

• The 4th highest 24 hour maximu~ for the other Maritza plant is 206.31 1l9/m3 for the 1998 metrological data exceeding the allowed Bulgarian limit. The maximum occurs 6.1 km to the south east of the AES-3C Maritza East 1 power plant stack. Comparisons with the World Bank limit of 150 1l9/m3 for the 24 hour maximum show that all the other plants combined give a maximum total ground level concentration contribution of 280.171lg/m3 for the 1998 metrological data, well above the allowed limit.

• The 4th highest 24 hour maximum for the all plants including the AES-3C Maritza East 1 power plant is 281.92 1l9/m3 for the 1998 metrological data exceeding the allowed Bulgarian limit. The maximum occurs 6.1 km to the south-east of the AES-3C Maritza East 1 power plant stack. Comparisons with the World Bank limit of 150 1l9/m3 for the 24 hour maximum show that all the other plants combined give a maximum total ground level concentration contribution of 281.921lg/m3 for the 1998 metrological data, well above the allowed limit though it should be noted the AES-C3 plant accounts for just 1.751lg/m3 of this maximum.

• The annual average S02 concentration for AES-3C Maritza East 1 power plant is 1.741lg/m3 (1997). This is 8.7 per cent of the Bulgarian and EU limit of20 1l9/m3 for the protection of ecosystems. The annual average concentration for all the other Maritza power plants is 45.92 1l9/m3 (1997) 11.2 km (and 22.4 km) to the south-east. This is more than double the Bulgarian and EU limit. The combined annual average for all the existing Maritza plants plus AES-3C Maritza East 1 power plant ME1 is 46.09 1l9/m3 with the AES-3C Maritza East 1 power plant contributing just 0.17 1l9/m3 to the maximum. This figure exceeds the Bulgarian and EU limits of 20 1l9/m3, however it should be noted that the modelling undertaken assumes 100 per cent load fact for all the Maritza plants, something that is not likely to occur. Further more it should be note that the proposed plant would likely reduce the load factor of the other Maritza plant such as the old Maritza East 1 plant thus reducing the combined effect of the Maritza plants. All modelled scenarios show that the combined effect of the Maritza plant will be within the World Bank limit of 80 1l9/m3.

• The maximum 19th highest hourly NO. concentration due to the AES-3C Maritza East 1 power plant is 41.62 1l9/m3 for 1996 meteorological data. This prediction represents 20.8 per cent of the Bulgarian and EU limit of 200 1l9/m3. The location of maximum concentration occurs 18.6 km to north-east of the stack.

• The predicted maximum annual average NO. concentration due to the AES-3C Maritza East 1 power plant is 0.87 1l9/m3 on the basis of 1997 meteorological data. This prediction represents just 2.9 per cent of the EU and Bulgarian limits PBPower Section 5 Page 14

3 of 30 Jlg/m for N02. The location of maximum concentration occurs 18.6 km to the north-east of the stack. The levels observed are well under the World Bank 3 limits of 100 Jlg/m even with NO. to N02 conversion of 100 per cent that is unlikely to occur.

• The maximum 24 hour mean for particulates for the combined Maritza plants is 1.77 Jlg/m3 for the (1996) metrological data. Even though as has been discussed this is a very worst case it is still well below the Bulgarian and EU limits of 3 3 50 Jlg/m and World Bank limit of 150 Jlg/m .

• The annual concentration from the all Maritza plants including the proposed AES-3C Maritza East 1 power plant is 0.94 well below the allowed EU/Bulgarian 3 3 limit of 20 Jlg/m and the World Bank limit of 50 Jlg/m .

In conclusion, the impact of the atmospheric emissions from the AES-3C Maritza East 1 power plant will be within the legal limits as defined in Bulgarian and EU legislation as well as being within the limits outlined by the World Bank. Isopleths for worst case results are provided in Appendix A.

5.4.3 Existing environment

Bulgaria has specified a series of standards and objectives for national air quality. These were most recently amended in Standard 9 to comply with the latest EU Directive. A summary of Standard 9 and of the Directive is set out below in Table 5.6 PBPower Section 5 Page 15

TABLE 5.6 EC AIR QUALITY STANDARDS FOR THE PROTECTION OF HUMAN HEALTH

Parameter Reference period Compliance Statutory ground Number of date level permitted concentration exceedences limit values 3 (J.1g/m )

Hourly 2010 200 18 Nitrogen dioxide Annual 2010 40 -

Hourly 2005 350 24 Sulphur dioxide 24 hourly 2005 125 3

24 hours (daily mean 2005 50 35 Particulates values) (Stage 1) Annual limit 2005 40 -

24 hours (daily mean 2010 50 7 Particulates values) (Stage 2) Annual limit 2010 20 -

Air quality guidelines from the World Bank are given in Table 5.7. The limit values are similar or more lenient than those of the Bulgarian and EU Legislation however exceedences are not permitted. The World Bank also includes additional or differing averaging periods to those of the found in Bulgarian and EU legislation.

TABLE 5.7 WORLD BANK AIR QUALITY LIMITS

Recommended ground level Parameter Reference period concentration guide values

24 hour average 150 1l9/m3 Nitrogen dioxide Annual average 1OOllg/m3

24 hour mean 150 1l9/m3 Sulphur dioxide Annual average 8Ollg/m3

24 hour average 15Ollg/m3 PM_10 Annual average 5Ollg/m3 PB Power Section 5 Page 16

5.5 Ambient air quality

The existing ambient air quality is monitored at Galabovo and details of monitoring points and results are given in Section 4.3.2.3.

5.5.1 Selection of air quality dispersion model

Atmospheric dispersion modelling can predict the ground level concentrations that occur due to the emissions from an elevated point source.

When flue gases are discharged from a conventional stack they have two sources of momentum. One is related to the velocity of discharge. This is usually designed to be in excess of 15 metres per second as this value has been found to be sufficient to avoid immediate downwash of the plume. The momentum from the velocity of discharge is soon dissipated.

The second source of momentum is much more significant and is related to the discharge temperature of the flue gases. The flue gases being warmer than the surrounding atmosphere into which they are discharged, have a buoyancy and thus rise. This process continues until the flue gases have cooled to the same temperature as the surrounding air.

Mathematical models calculate the effects of these two sources of momentum and determine the height to which the flue gases will rise. This height plus the height of the chimney gives an effective chimney height.

The mathematical model then determines the dispersion of the flue gases from this effective chimney height. Note that the effective chimney height can be many times greater than the actual chimney height due to the large amount of heat present in the flue gases.

Dispersion occurs as a result of turbulence, and turbulence can result from both buoyancy effects and wind shear (also called mechanical) effects.

As an example of buoyancy effects, on a sunny day, solar heating creates turbulence by heating the ground and the air near the ground. The buoyancy of the heated bubbles of air causes it to rise, creating turbulence. These are the thermals experienced by small plane and glider pilots on sunny days. These can also rapidly disperse a plume in the surrounding air. At night, during stable conditions, the buoyancy effect is to suppress rather than cause or enhance turbulence.

Wind shear as a cause of turbulence is well known to pilots, as well. Wind shear effects importan~ to air pollution modelling result from high (several meters per second) wind speeds near the ground. Since the wind speed at the ground is zero, any high wind speeds result in substantial wind shear. Wind shear dominates over buoyancy effects not only under high wind conditions, but also near the ground under any conditions.

As a result of this, two parameters are used to define the 'stability" of the atmosphere. The first is the friction velocity. This is a measure of wind shear. Shear stress per unit mass has the units of velocity squared. The square root of this is the friction velocity, indicated by the symbol u. PBPower Section 5 Page 17

The second parameter is a stability term called the Monin-Obukhov length. As mentioned above, shear stress always dominates near the ground. The height above the ground, where buoyancy effects begin to dominate (generating turbulence in convective conditions or suppressing turbulence in stable conditions), is called the Monin-Obukhov length. T.his can be thought of as a depth of the neutral (Le. shear-dominated) flow. The Monin-Obukhov length (L) is positive for stable conditions, and negative for convective. Near-neutral conditions are characterized by very large negative or very large positive Monin-Obukhov lengths. Very stable conditions have Monin-Obukhov length of a few metres to a few tens of metres, while very unstable conditions have negative lengths of about the same size.

The proposed AES-3C Maritza East 1 power plant unlike the conventional stack found at Maritza East 1,2 and 3 will emit the flue gases generated via a cooling tower. This technique is uncommon outside Germany where it was pioneered in the mid 1980s due to the small number of coal/lignite fired power plant that have been developed since this time. The approach uses the extra buoyancy produced by way of heat as the water vapour in the cooling tower plume condenses to propel the flue gas further into the atmosphere than would have been the case for a conventional stack.

This presents a problem for the well-established and accredited dispersion models such as AERMOD and ISC-3 recognized by the US EPA, the EU and World Bank and for the ADMS model approved by the EU and UK Environment Agency due to the differences between the way conventional stack and cooling towers function. Conventional stack emit flue gases at a set exit temperature meaning that the dispersion of the flue gases varies depending on the ambient temperature observed at any given time. Cooling towers however pull vast amounts of air through the cooling tower base increasing the temperature by a relatively constant interval before emitting the air saturated with water vapour. The dispersion models discussed are programmed to model conventional stack and are unable to model fluctuating exit temperatures as is required for flue gas emission through a cooling tower. However it is possible to adapt these models to allow for an appropriate assessment of the proposed emissions technique at AES-3C Maritza East 1 power plant provided that the other Maritza plants are modelled separately. This can be achieved using one of two options:

• Set the exit temperature of the cooling tower to a level above that of the maximum observed ambient temperature to account for the temperature rise experienced as air moves through the cooling tower. If the exit temperature is set lower the model will ground the plume as soon as the ambient air temperature exceeds that of the plume temperature.

• Preset the ambient air temperature in the metrological data and the exit temperature of the stack to provide the constant temperature increase that would be observed in the relationship between the plume and the ambient air.

It was considered that the use of the second option would be preferable as it would provide a worst case scenario while allowing the use of approved modelling programmes with a proven record in modelling emissions from conventional plant as was required for the assessment of the other Maritza East Plants. PB Power Section 5 Page 18

5.5.2 Selection of meteorological data

There is no available on-site meteorological data for the proposed project area. Historical meteorological data taken at the site near Galabovo, Bulgaria helped to guide the choice of a representative site for the modelling. The selection of a 5 year meteorological database was considered essential so that a statistically stable result representative of a long period of project operation could be simulated.

Plovdiv was selected as the data is relatively complete for the recent years (1996-2000) in contrast to that of a number of the other sites. Winds in the Plovdiv area are, generally west-north-west in contrast to the expected predominance of winds generally from the north-north-west in the Galabovo region, however the data was found to be more appropriate than that available from other nearby metrological stations including Stara Zagora (40 km to the north-west) where data availability was insufficient and Burgas (135 km to the east-north-east on the Black Sea) which was disqualified due to its influence by sea breezes from the Black Sea.

5.5.3 Model receptors and terrain

Although terrain is relatively flat in the immediate vicinity of Maritza East 1, data from a 1 m interval digital terrain model (DTM) was used to ensure a thorough investigation.

The dispersion modelling undertaken used 2 Cartesian grids. One high resolution 2 km by 2 km grid with receptor separation 100 m centred on the AES-3C Maritza East 1 power plant stack with the second grid having a receptor separation of 1000 m encompassing an area 10 km around each of the three other Maritza Plants.

5.5.4 Model inputs

The principal buildings that were considered in this analysis are shown in Table 5.8.

TABLE 5.8 BUILDINGS CONSIDERED IN MODELLING EXERCISE

Building Dimensions height x width x length (m)

Electrostatic Precipitator (West) 25 x 44 x 25

Electrostatic Precipitator (East) 25 x 44 x 25

Boiler Housing (Main) 94 x 110 x 53

Boiler Housing (North) 50x 10120

Boiler Housing (South) 54x110x12

Turbine Hall 25 x 110 x 37 PB Power Section 5 Page 19

5.5.5 Land use analysis

The choice of either urban or rural dispersion coefficients in AERMOD is dependent upon the land use within 3 km of the source. Although some industrial (urban-like) areas exist near the plant and the town of Galabovo is located within 2 km to the south-west, the majority of the area near the plant is characterized by open water or vegetated areas. Therefore, rural dispersion coefficients were selected for use in the modelling runs.

5.5.6 Emission scenarios for modelling

Two scenarios were modelled:

• The contribution from the proposed AES-3C Maritza East 1 power plant in isolation using metrological data with a set difference in ambient air temperature.

• The combined contribution from the plant at Maritza East 1, Maritza East 2 (with FGD for the large units but not the small units) and Maritza East 3 (with FGD on all four units) using metrological data with observed ambient air temperatures.

This was considered to be appropriate as the fitting of FGD to two of the Maritza East 2 large units is complete and fitting to the other Maritza East 2 units as well as Maritza East 3 is underway. While there are plans to fit FGD to the remaining units at Maritza East 2 no emissions information is currently available. There are currently no plans to fit FGD to the existing Maritza East 1. PB Power Section 5 Page 20

5.5.7 Results from dispersion modelling

Modelling results for sulphur dioxide

Modelling results for the scenarios described above are presented in Table 5.9.

TABLE 5.9 GROUND LEVEL S02 CONCENTRATIONS DUE TO MARITZA EAST PLANTS

Year AES-3C Maritza East 1 power Other Maritza plant AES-3C Maritza East 1 power plant plant and other Maritza plant combined

25th 4th Maximum 25th 4th Maximum 25th 4th Maximum highest highest annual highest highest annual highest highest annual hour daily hour daily hour daily conc conc conc

1996 !!g/m3 41.62 19.92 1.10 799.58 143.73 44.04 808.34 149.47 44.84 (exceedances) (0) (0) (0) (1109) (16) (701) (1151) (79) (721) Distance (km) 18.6 15.6 20.0 24.2 21.5 19.1 24.2 15.6 19.1 Direction (.) 225 135 93 135 135· 96 135 135 96

3 1997 !!g/m 40.35 32.71 1.74 664.06 135.19 45.92 672.24 136.35 46.09 (exceedances) (0) (0) (0) (307) (6) (86) (359) (36) (93) Distance (km) 18.6 15.6 19.0 26.0 23.3 11.2 .22.4 23.3 23.3 11.2. Direction (") 225 135 93 135 135· 135 135 135 22.4 135

1998 !!g/m3 35.73 51.85 1.42 944.74 206.31 38.87 951.22 207.52 39.03 (exceedances) (0) (0) (0) (731) (40) (473) (809) (59) (502) Distance (km) 3.0 15.6 10.3 26.0 6.1 5.1 8.1 6.1 5.1 Direction (") 135 135 151 135 135· 135 135 135 135

1999 !!g/m3 34.35 33.57 1.39 936.37 178.21 34.52 943.32 179.25 35.23 (exceedances) (0) (0) (0) (591) (53) (383) (691) (108) (403) Distance (km) 3.0 10.8 10.8 20.2 6.1 19.1 7.1 6.1 19.1 Direction (") 225 158 158 96 135· 96 135 135 96

2000 !!g/m3 29.55 28.62 1.14 796.08 136.85 35.42 801.94 137.83 36.27 (exceedances) (0) (0) (0) (449) (10) (122) (551) (10) (135) Distance (km) 10.3 15.6 19.0 23.1 7.6 19.1 8.1 7.6 19.1 Direction (.) 151 135 93 96 135· 96 135 135 96

AES-3C Maritza East 1 power plant in isolation

The results show that emissions from the proposed AES-3C Maritza East 1 power plant are low, especially when compared with those from the other plant in the Maritza area. The AES-3C Maritza East 1 power plant in isolation provides a maximum of 41.62 1l9/m3 representing just 11.7 per cent of the Bulgarian and EU 25th highest hourly limits.

The 4th highest 24 hour maximum observed was 51.85 1l9/m3 for the 1998 metrological data representing 3.7 per cent of the Bulgarian limit of 125 1l9/m3. The 24 hour maximum observed was 121.41 within the 150 Ilg/m31imit set by the World Bank. This figure is nearly twice that of the next highest 24 hour maximum of 68.13 1l9/m3 observed for the 1997 data. PBPower Section 5 Page 21

The maximum annual concentration observed for the AES-3C Maritza East 1 power plant was 1.74 1l9/m3 for the 1997 metrological data representing just 8.7 per cent of the Bulgarian and EU limit of 20 1l9/m3 and just 2.2 per cent of the World Bank limit of 80 1l9/m3.

Contribution from other Maritza plants

The results show that emissions from the existing Maritza East plants (1,2 and 3) are high. These plants give a maximum of 944.74 1l9/m3 significantly exceeding the Bulgarian and EU 25th highest hourly limits of 350 1l9/m3.

The 4th highest 24 hour maximum observed was 206.31 1l9/m3 for the 1998 metrological data exceeding the Bulgarian limit of 125 1l9/m3. The 24 hour maximum observed was 280.17 1l9/m3 for the 1998 metrological data exceeding the 150 Ilg/m31imit set by the World Bank by nearly 100 per cent.

The maximum annual concentration observed for the plants was 45.92 1l9/m3 for the 1997 metrological data representing a significant exceedance of the Bulgarian and EU limit of 20 1l9/m3 while remaining within the World Bank limit of 80 1l9/m3.

Combined effect

As was discussed in Section 5.4.1 limitations of the dispersion model made simultaneous modelling of the AES-3C Maritza East 1 power plant and the existing Maritza East 1, 2 and 3 plant impractical. Combination of the results subsequent to modelling is to some extent inappropriate as it gives the impression of a much worse case than may be possible. This is because during a modelling run the maximum concentrations are calculated and recorded for every hour of a year for all receptors identified ie the maximums at a given location may occur at different times of the year so combining them does not give an accurate account of likely ground level concentrations .. However the coordinate of the maximum is 151 0 (south-east) from the AES-3C Maritza East 1 power plant stack but not from the other plant stack meaning the wind would have to blow in two or as in this case three different directions simultaneously to achieve the maximum, which is clearly impossible. This should be taken into account with regards to the increase in the number of exceedances observed.

Table 5.10 gives a break down of the contribution to ground level concentrations of the existing Maritza East plants (1,2 and 3) for the worst-case for year (with regards to maximum number of exceedance). It should be noted that the existing Maritza East 1 plant and the Maritza East 2 plant generate the majority of exceedances observed with no exceedances from the fully FGD retrofitted Maritza East 3. Maritza East 1 has no Sulphur abatement and does not plan to fit any choosing instead to run up until January 2008 and for 20 000 hours beyond before ceasing operation, most likely in 2011. Maritza East 2 has fitted FGD to the larger units of the plant (which has been taken into account in the modelling) and is planning to fit FGD to the smaller units (which it was not possible to include due to a lack of data). Once Maritza East 2 fits FGD to all units the number of exceedances for ground level concentrations will fall leaving the existing Maritza East 1 as the only source of significant S02 ground level concentrations. PBPower Section 5 Page 22

TABLE 5.10 GROUND LEVEL S02 CONCENTRATIONS DUE TO INDIVIDUAL MARITZA EAST POWER PLANTS

Year Maritza East 1 Maritza East 2 Maritza East 3 AES-3C

25th 4th Annual 25th 4th Annual 25th 4th Annual 25th 4th Annual highest highest conc highest highest conc highest highest conc highest highest conc hour daily hour daily hour daily hour daily conc conc conc conc

1998 536 91.98 25.71 934.01 203.73 35.97 141.03 30.02 6.7 35.73 51.08 1.42

It is considered that the modelling results recorded for the AES-3C Maritza East 1 power plant (as shown in Table 5.10) prove the plant would have a negligible impact on ground level concentrations in the Galabovol Maritza area. Indeed, should the plant be built it would be likely to reduce the load factor of more polluting plant in the area thus improving air quality. However in order to produce an extreme worst case scenario it was decided to present the combined effect of the existing plant and the AES-3C Maritza East 1 power plant by combining the impact at the receptors modelled.

The results show that emissions from the existing Maritza East plants (1, 2 and 3) together with the AES-3C Maritza East 1 power plant are high. The plants give a maximum of 951.23).1g/m3 3 significantly exceeding the Bulgarian and EU 25th highest hourly limits of 350 ).1g/m . The AES-3C Maritza East 1 power plant contributes 6.49 Ilg/m3 to this ground level concentration.

The 4th highest 24 hour maximum observed was 207.52 ).1g/m3 for the 1998 metrological data 3 3 exceeding the Bulgarian limit of 125 ).1g/m . The 24 hour maximum observed was 281.92 Ilg/m for the 1998 metrological data exceeding the 150 ).1g/m 3 limit set by the World Bank by nearly 100 per cent. The AES-3C Maritza East 1 power plant contributes 1.75 ).1g/m3 to this maximum.

The maximum annual concentration observed for the plants was 46.09 ).1g/m3 for the 1997 metrological data representing a significant exceedance of the Bulgarian and EU limit of 20 ).1g/m3 3 while remaining within the World Bank limit of 80 ).1g/m . The AES-3C Maritza East 1 power plant contributes just 0.17 Ilg/m3 to this ground level concentration.

Modelling results for oxides of nitrogen

Table 5.11 gives the relevant maximums observed from the dispersion modelling undertaken. The values recorded in the table allow for 100 per cent NO. to N02 conversion. PBPower Section 5 Page 23

TABLE 5.11 GROUND LEVEL NOx CONCENTRATIONS DUE TO MARITZA EAST PLANTS

Year AES-3C Maritza East 1 power Other Maritza plant AES-3C Maritza East 1 power plant plant and other Maritza plant combined

19th Maximum Maximum 19th Maximum Maximum 19th Maximum Maximum highest daily annual highest daily annual highest daily annual hour conc hour conc hour conc

1996 I!g/m3 41.62 24.00 0.55 102.55 23.82 5.92 120.76 33.49 6.25 (exceedances) (0) (0) (0) (0) (0) (0) (0) (0) (0) Distance (km) 18.6 18.6 18.6 8.5 10.8 12.2 8.5 18.6 12.2 Direction (0) 54 54 54 135 135 135 135 54 135

1997 I!g/m3 38.56 34.08 0.87 78.85 27.68 5.81 86.61 40.76 6.11 (exceedances) (0) (0) (0) (0) (0) (0) (0) (0) (0) Distance (km) 18.6 18.6 18.6 8.9 9.1 12.2 11.0 18.6 12.2 Direction n 54 54 54 135 84 135 90 54 135

1998 I!g/m3 27.88 60.74 0.71 100.91 37.20 5.27 110.55 66.36 5.46 (exceedances) (0) (0) (0) (0) (0) (0) (0) (0) (0) Distance (km) 18.6 24.7 24.7 8.9 9.1 12.2 8.9 24.7 12.2 Direction n 54 135 135 135 84 135 135 135 135

3 1999 I!g/m 33.14 23.85 0.70 104.01 35.39 4.99 112.08 37.22 5.19 (exceedances) (0) (0) (0) (0) (0) (0) (0) (0) (0) Distance (km) 18.6 24.7 24.2 10.8 10.8 12.2 10.8 10.8 12.2 Direction (0) 54 135 135 135 135 135 135 135 135

2000 I!g/m3 24.96 24.38 0.57 88.74 23.29 5.22 95.7 37.38 5.54 (exceedances) (0) (0) (0) (0) (0) (0) (0) (0) (0) Distance (km) 10.3 15.6 19.0 9.5 11.2 12.2 9.5 18.6 12.2 Direction n 151 135 93 135 135 135 135 54 135

AES-3C Maritza East 1 power plant in isolation

The results show that emissions from the proposed AES-3C Maritza East 1 power plant are low. The AES-3C Maritza East 1 power plant in isolation provides a maximum NOx concentration of 41.62 1l9/m3 (1996) representing just 20.8 per cent of the Bulgarian and EU 19th highest hourly limits of 200 1l9/m3.

The 24 hour maximum observed was 60.74 1l9/m3 for the 1998 metrological data representing 45.5 per cent of the 150 Ilg/m31imit set by the World Bank.

The maximum annual concentration observed for the AES-3C Maritza East 1 power plant was 0.87 1l9/m3 for the 1997 metrological data representing just 2.9 per cent of the Bulgarian and EU limit of 30 1l9/m3 and just 0.87 per cent of the World Bank limit of 100 1l9/m3.

Contribution from other Maritza plants

The results show that emissions from the existing Maritza East plants (1,2 and 3) are lower than those for the AES-3C Maritza East 1 power plant. These plants combined give a maximum ground level PBPower Section 5 Page 24

concentration of 102.55 ~g/m3 (1997) representing just 51 per cent of the Bulgarian and EU 19th highest hourly limits of 200 ~g/m3.

The 24-hour maximum observed was 37.2 ~g/m3 for the 1996 metrological data much lower than the 150 ~g/m3limit set by the World Bank.

The maximum annual concentration observed for the plants was 5.92 ~g/m3 for the 1997 metrological data well within the Bulgarian and EU limit of 30 ~g/m3 and the World Bank limit of 100 ~g/m3.

Combined effect

The results show that emissions from the existing Maritza East plants (1, 2 and 3) together with the AES-3C Maritza East 1 power plant relatively low. The plants give a maximum of 120.75~g/m3 well within the Bulgarian and EU 19th highest hourly limits of 200 ~g/m3.

The 24 hour maximum observed was 66.36~g/m3 for the 1998 metrological data well within the 150 ~g/m3limit set by the World Bank

The maximum annual concentration observed for the plants was 6.25 ~g/m3 for the 1996 metrological data within the Bulgarian and EU limit of 30 ~g/m3 and the World Bank limit of 100 ~g/m3. ....------

PBPower Section 5 Page 25

Modelling results for PM_10

Table 5.12 gives the relevant maximums observed from the dispersion modelling undertaken for PM 10.

TABLE 5.12 GROUND LEVEL PM 10 CONCENTRATIONS DUE TO MARITZA EAST PLANTS

Year AES-3C Maritza Other Maritza plant AES-3C Maritza East 1 East 1 power plant power plant and other Maritza plant combined

36th Maximum 36th Maximum 36th Maximum daily annual daily annual daily annual maximum maximum maximum conc conc conc

1996 Jlg/m3 0.20 0.08 1.65 0.89 1.77 0.94 (exceedances) (0) (0) (0) (0) (0) (0) Distance (km) 19.0 20.0 8.9 6.3 9.8 6.3 Direction (0) 93 93 270 270 270 270

1997 Jlg/m3 0.29 0.13 1.59 0.87 1.68 0.91 (exceedances) (0) (0) (0) (0) (0) (0) Distance (km) 19.0 19.0 9.1 6.3 10 6.3 Direction (") 93 93 270 270 276 270

1998 Jlg/m3 0.27 0.11 1.63 0.80 1.70 0.82 (exceedances) (0) (0) (0) (0) (0) (0) Distance (km) 17.7 10.3 9.1 6.3 9.8 6.3 Direction (0) 106 151 270 270 156 270

1999 Jlg/m3 0.22 0.10 1.66 0.76 1.73 0.78 (exceedances) (0) (0) (0) (0) (0) (0) Distance (km) 17.7 10.8 8.9 6.3 9.8 6.3 Direction (0) 106 158 270 270 270 270

2000 Jlg/m3 0.23 0.09 1.52 0.78 1.60 0.81 (exceedances) (0) (0) (0) (0) (0) (0) Distance (km) 19.0 19 7.3 6.3 7.3 6.3 Direction (") 93 93 270 270 270 270

AES-3C Maritza East 1 power plant in isolation

The 36th 24 hour maximum observed was 0.27 Jlg/m3 for the 1998 metrological data representing 0.9 per cent of the 30 Jlg/m3 limit set by the EU and Bulgarian legislation while representing just 0.18 per cent of the World Bank limit of 150 Jlg/m3

The maximum annual concentration observed for the AES-3C Maritza East 1 power plant was 0.13 Jlg/m3 for the 1997 metrological data representing just 0.7 per cent of the Bulgarian and EU limit 3 3 of 20 Jlg/m and just 0.26 per cent of the World Bank limit of 50 Jlg/m . PBPower Section 5 Page 26

Contribution from other Maritza plants

The 36th 24 hour maximum observed was 1.66Jlg/m3 for the 1998 metrological data much lower than the 50 Jlg/m3 limits set by the Bulgarian and EU legislation and significantly lower than the 150 Jlg/m3 limit set by the World Bank.

The maximum annual concentration observed for the plants was 0.89 Jlg/m3 for the 1997 metrological 3 3 data well within the Bulgarian and EU limit of 20 Jlg/m and the World Bank limit of 50 Jlg/m .

Combined effect

The results show that emissions from the existing Maritza East plants (1, 2 and 3) together with the AES-3C Maritza East 1 power plant low. The plants give a 36th 24 hour maximum of 1. 77Jlg/m3 (1998) within the Bulgarian and EU 24-hour limits of 50 Jlg/m3 and the 150 Jlg/m3 1imit set by the World Bank.

The maximum annual concentration observed for the plants was 0.94 Jlg/m3 for the 1996 metrological 3 3 data within the Bulgarian and EU limit of 20 Jlg/m and the World Bank limit of 50 Jlg/m .

5.6 Acid deposition and trace element impacts on soil and vegetation

5.6.1 Deposition modelling

Although the facility's emissions will be well controlled, it is necessary to assess long term impacts of trace elements and acidic deposition to ensure that no harm will come to the environment. Materials released from the power plant will disperse in the atmosphere. Some of the material will eventually reach the surface and become deposited. When this occurs in the absence of rain, the process is called dry deposition. When plume material is washed out of the air by precipitation, this process is called wet deposition. Over a long period, both processes contribute to the total deposition of plume material. Therefore, for this analysis, dry plus wet deposition was assessed and is referred to as "total deposition".

The deposition of trace elements was analysed using a US EPA screening method (EPA, 1980a) to assess impacts upon soils, vegetation and animals. Fossil fuels all contain small amounts of trace elements, most of which are emitted as small particulates or aerosols. The proposed facility's electrostatic precipitator will remove nearly all of these trace elements and trace element emissions will be a very small percentage of total particulate matter emissions from the facility.

All soils contain natural levels of trace elements. Plants and animals utilize trace elements as part of their growth process. Trace elements are considered in this analysis because, in sufficiently high amounts, they can negatively impact soils, vegetation, and animals.

The deposition of sulphur and nitrogen was calculated to assess potential acidic impacts upon soils, vegetation and surface waters. S02 and NO. are normal products of fossil fuel combustion. The proposed facility will minimize S02 through flue gas desulphurization and will minimize NO. through combustion temperature controls. Nevertheless, sulphur and nitrogen containing compounds emitted to the atmosphere will eventually reach the earth's surface. When this occurs, these compounds can contribute hydronium ions to the media in which they are present, thus increasing the acidity of these ... ------~-~~-----~~------

PBPower Section 5 Page 27

media. In large amounts, sulphur and nitrogen deposition can reduce the pH of sensitive soils, can cause damage to forests and crops and result in reduced yields. In small amounts, sulphur and nitrogen deposition may have no effect. It is therefore important to assess the acid deposition impact of the proposed facility.

3 Dry deposition of NOx and S02 was calculated by multiplying modelled annual concentrations (mg/m ) of NO. and S02, respectively, at each modelled receptor by a deposition velocity of 0.01 m/sec (recommended in the US Forest Service Handbook 2509.19) to obtain dry deposition values (g/m 2_yr). (This value of deposition velocity represents an upper limit found in literature on the subject.)

NO. and S02 are not directly depleted from the atmosphere by precipitation. NOx and S02 emitted

from combustion sources must be transformed in the atmosphere to N03 and S04, respectively, before being scavenged by precipitation and eventually reaching the ground. For conservatism, US Forest Service Guidance was followed in assuming that over an annual period, wet and dry deposition are equal in magnitude.

Total (dry plus wet) deposition was estimated by applying an effective deposition velocity of 0.02 rnIsec. From the total deposition values, the maximum acid equivalent deposition rates for Nand S were calculated and evaluated as follows.

5.6.2 Comparison to guidelines

There are no sulphur or nitrogen deposition standards in Bulgaria. However, certain guideline values are being used for comparison purposes. Selected examples of commonly used deposition guidelines are given in Table 5.13. In this study, the average guideline value, 7.9 kilograms per hectare per year (kg/ha/pa) (0.79 grams per square meter per year - g/m2/yr) is used as the acceptable limit for sulphur deposition.

TABLE 5.13 RECOMMENDED GUIDELINE LIMITS FOR SULPHUR DEPOSITION

Country Guideline limit kg/ha/yr Remarks (g/m2/yr) 2 Canada 6.6 (0.66 g/m Iyr) plus 6.6 kg/ha/yr for background deposition 2 Denmark 5.0 (0.50 g/m Iyr) Excluding background 2 Netherlands 12.8 (1.28 g/m Iyr) target for year 2000 including background

The maximum total (dry + wet) sulphur deposition predicted from the proposed power plant is 3.48 kg/ha/pa (0.348 g/m2/pa). This value is predicted at the location of the maximum annual average S02 concentration at 4 km to the south of the stack. This highest value, which meets the guidelines of Denmark, Canadian and the Netherlands, is predicted to occur at a single, elevated location. The average sulphur deposition in the vicinity, especially to the east and west of the power plant is an order of magnitude lower, well below all guideline levels. To comply with World Bank Guidelines applicable to degraded airsheds, the net effect of the proposed project will be to reduce overall PBPower Section 5 Page 28

emissions of sulphur dioxide in the Maritza East 1 area. As such, the potential for acidic deposition will actually be lessened from present conditions.

The noted deposition guidelines exist only for sulphur, because it is considered to be the primary cause of acidic deposition. However, nitrogen oxides are also thought to contribute to acid deposition, although to a much lesser extent than S02. An appropriate level of significant impact for nitrogen deposition is, therefore, expected to be greater than the guideline levels for S02. In terms of nitrogen, the maximum total wet deposition (as wet deposition of N02does not occur) was calculated to be 0.174 g/m2/yr, less than 20 per cent of the sulphur impact. Therefore, its impact on acidification should also be considered insignificant.

5.6.3 Impacts on vegetation

Air emissions can affect plants by causing visible injury such as leaf necrosis, leaf discoloration, and, for some vegetable cash crops, a reduction in yields. Plants can be affected by ambient concentrations of pollutants and wet and dry deposition of acidic components. Susceptibility to pollutant exposure varies among species.

Agriculture in the local region is a source of income to the local population. As such, agricultural crops are considered in this analysis.

5.6.4 Effects from ambient concentrations of acid precursors

The available literature relating exposure to ambient S02 concentrations and plant susceptibility are summarized in FIGURE 5.1. From this figure it can be seen that the threshold value for any potential impact can safely be assumed to be 900 ~g/m3 for short- term «24 hour average) and 150 ~g/m3 for annual average. Predicted impacts of S02 in the area were shown previously to be far below these concentrations.

Studies with simulated acid rain reported in the literature indicated that, based on visible effects on the foliage, the sensitivity to wet acidic deposition ranks from high to low in the following order: herbaceous dicot, woody dicot, monocots and conifers. For all of the tested species, the extent of visible leaf injury was found to be linearly correlated to the acid concentrations of the applied solution (Evans, 1982; Lee et aI., 1980). Table 5.14 summarizes literature information on the susceptibility of various plant species to foliar damage together with the corresponding threshold pH values of the applied precipitation. The thresholds shown in the table are for short exposure durations that are unspecified. According to this information, root crops are deemed the most sensitive groups to foliar damage due to acidic precipitation. FIGURE 5.1 Influence of Different S02 Concentrations and Exposure Times on the Appearance of Injury Systems of Different Plants

, MO.nr.r PiaDI 'Ia1cIcc

J. b,..... 2L ~c:oIlOqe g 01 2- ~ IDnlip ~& l. -ptJIaIO ~ ! 22- ...... "...... Z~f ~ot $ ...... 1 p:oope ,3 t301 .. 23. ea pIIIIl 0 140. 1. ...~ 24. .... ". lSol s. ~ lIpiaac:I!. I_IT. 160 I7S 1 ,. lS. .,. 10. ...~ 26. 04 ~o' .... 0$ 200\ 11. IInIIIf:C .... 12- cIIi.-cahboI,e n. a1Ca1fa 0$ Z'O \ Zw"q l'. IpiaIda \ ...... 2~ 14. .-P'PI""" U . ~ \ ,.....,. rice ;rape 07 240 \ \ IS. ~ 29. alfalfa I Will" .. 16- -poc:uo 30. ,.-..pc 6'"' \ 31. x OZ5 \ t1. .,..,. 12- --poUto--~ " DATI CI \ I&. so,bco S! oz. \ ---a..jsaad&G.- 33. IIoodcy 15 ;s ....TI .. \ 1'9 • - 8lfiIIfa OZ7 \ 20. ...Idhocr ""c z ... n ::I \ .. \ E... \ \ 'NT' \ \ \ \ \ o ...... -a D' ""'T SY_,.." \ D- ...... 3,...,. ....S 6 \ \ • \ $1 dt. n O \ \ 2 \

100 PBPower Section 5 Page 30

TABLE 5.14 THRESHOLD PH VALUES FOR VISIBLE FOLIAR INJURY

Species Threshold pH Growth Conditions· -. Root Crops 2.8 - 3.0 F General 3.5-4.0 C Radish 2.74.2 - 5.6 F Carrot 3.0-3.5 C

Leafy Lettuce 3.1-4.0 C Tobacco 3.5-4.0 C

Cole 3.0 - 3.5 C Cabbage 3.5-4.0 C Cauliflower

Tuber Potato 3.5-4.0 C

Legume Alfalfa 3.1-4.0 C Bean (bush) 2.5 - 3.0 C Bean (kidney) 2.8 - 3.2 C Greenpea 3.5-4.0 C Soybean 2.7 - 5.6 C

Fruit Apple 2.5-4.0 F Cucumber 3.5-4.0 C Grape Leaves 2.5 F Green Pepper 4.0 - 5.6 C Strawberry 3.0-3.5 C Tomato 3.5-4.0 C

Grain Barley 3.0 C Corn 3.0 ~ 3.5 C Wheat 3.0 C

Forage Bluegrass 4.0 - 5.6 NA Timothy 3.5-4.0 NA Ryegrass 3.5-4.0 NA

F =Field Conditions; C =Culture Conditions; NA =Not Available Source: Torn, et aI., 1987

5.7 Air quality summary

5.7.1 Measured air quality

Measurement data at Galabovo indicate that the present ambient air quality in the vicinity is good for some pollutants and poor for others. For instance there are low concentrations of nitrogen dioxide and lead and the area is well in compliance for these criteria pollutants. However, there are relatively PBPower Section 5 Page 31

high concentrations of sulphur dioxide and particulate matter (suspended dust) in the area. Concentrations of both pollutants sometimes exceed existing Bulgaria air quality standards as well as World Bank guidelines for degraded airsheds.

To evaluate the extent that emissions of the major point sources in the Maritza East area (existing Maritza East 1,2 and 3 power generation stations) contribute to the ambient air quality, dispersion modelling was performed. Dispersion modelling indicates that the major lignite-fired power plants in the area currently contribute most of the ambient sulphur dioxide concentration. Reductions in emissions associated with rehabilitation and flue-gas desulphurization at Maritza East 2 and 3 reduces sulphur dioxide concentrations in the atmosphere and help attain the ambient air quality standards.

Although measured total suspended particulate matter (TSP) concentrations are above the existing ambient criteria, it is uncertain the extent to which ambient concentration levels represent a health concern. This is because measurements of total suspended particulate include particles that are too large to enter the lungs. Because of th is, total particulate matter standards have been replaced by new EU and Bulgarian standards that represent particles of smaller size that can be inhaled and

respirated (PM 10, less than 10 microns diameter and PM 25, less than 2.5 microns). As a general rule,

it is expected that about 50 per cent of the TSP from fugitive dust sources may be in the form of PM 10. Dispersion modelling of particulate matter emissions indicates that only a small fraction of the measured concentrations are contributed by stack emissions from the Maritza East power plants. This indicates that area sources, such as fugitive dust generated by on- and off-road vehicles, fly-ash ponds and low-level industrial sources are likely to be the major contributors to particulate matter concentrations in Galabovo.

5.8 Water supply and treatment

5.8.1 Construction phase impacts associated with water supply and treatment

There will be no water supply related impacts during construction of the proposed project. Water for the construction phase of the project will come from existing sources and no development of new water supply and associated water treatment will be required. The project will connect into the municipal water supply serving the existing Maritza East 1 power plant for most construction-related water needs. To ensure that a high quality drinking water supply is available throughout the construction of the project, bottled water (from a local commercial supplier) will be provided.

5.8.2 Operation phase impacts associated with water supply and treatment

The water withdrawal associated with the proposed AES-3C Maritza East 1 power plant is not anticipated to result in significant environmental impacts. Under certain future scenarios, it could result in improved conditions related to water supply and discharges.

Rozov Kladenetz Lake will serve as the primary source of all water for the planned project including cooling water, fire water and service water. As a zero-discharge facility, water withdrawals will represent a full consumptive use. Therefore, the effect of these withdrawals on the regional water budget (as compared to current power plant related withdrawals and discharges) is assessed below. Lake water will require varying degrees of treatment for each of these potential uses and discussion of PBPower Section 5 Page 32

3 treatment processes and associated effluents is also provided. Approximately 1,161 m per hour (m3/h) of water from the Rozov Kladenetz Lake will be withdrawn for cooling, fire water and service 3 water uses for the proposed power plant via the existing intake structure. An additional 61 m per 3 second of water will be withdrawn from the lake for use as demineralized water. This 1222 m per second total quantity of water withdrawn will represent a consumptive use and no water will be returned to the lake or river.

Ecolog ical impacts associated with water withdrawal from the proposed project and potential thermal discharge impacts from the operation of the existing Maritza East 1 facility are discussed in Section 5.12.

5.8.3 Impacts of water supply withdrawals on regional water budget

Depending on the operational mode of other significant users of water in the region (the existing Maritza East 1 power plant, the briquette factory, the Maritza East 3 power plant), the impact of planned water withdrawals associated with the AES-3C Maritza East 1 power plant on the regional water budget ranges from a negligible adverse impact (a 1 per cent decrease in Sazlijka River stream flow) to a minor favourable impact (an 8 per cent increase in Sazlijka River stream flow). In no case is there any significant impact associated with the planned AES-3C Maritza East 1 power plant water supply withdrawals.

In order to evaluate the potential impact of planned AES-3C Maritza East 1 power plant water supply withdrawals on regional water resources, a conceptual regional water budget for surface water resources in the vicinity of the power plant was developed. The regional water budget described in this section is based on an evaluation of historic stream flow data and assumptions related to past and future operational water demands of major water users in the area.

Figure 5.2 is a schematic drawing showing the current and historic management of surface water bodies associated with the operation of the existing Maritza East 1 power plant. Rozov Kladenetz Lake serves as a water supply reservoir, providing water for the existing Maritza East 1 power plant's once through cooling system, fire water system, and also provides a small amount of supplemental water for non-potable process needs. Water is also withdrawn from the lake for use at the Maritza East 3 power plant and at the briquette manufacturing facility. When sufficient flow is available (as much as six months each year) stream flow from the Sokolitsa River is diverted to Rozov Kladenetz Lake to maintain the water level. A pump station located on the south bank of the Sazlijka River pumps additional water to Rozov Kladenetz Lake (supplementing the Sokolitsa River diversion). The pumping station also pumps process water to the Maritza East 1 power plant for use in boiler makeup and other process water needs. FIGURE 5.2 WATER INTAKE AND DISCHARGE SYSTEM AT EXISTING MARITZA EAST 1 POWER PLANT

::::""" ====:::::~=-__~_::.::....ve1 -..------~~

Ro%ov Ktadenett Lake ~.( ~

OiS(;harge Channel

\C,~~-' I ~o~-_-:--~;;;"C-- -~":Room ~O""'l ~

'\- I' II ~ ~:>... il"---- '",,' 1"1 ~ n n ~ II t No.1'• Power Slalion ; U No. 2 Ash Dump -==~ P L...--'--_...... ~ : for Industfial \/\later . ~: Pum Room PBPower Section 5 Page 34

Figure 5.3 (Case 1) presents the estimated regional surface water budget for historic and current operations in the vicinity of the Maritza East 1 power plant. Figures 5.4, 5.5 and 5.6 present the estimated regional surface water budgets for three future operational scenarios involving the full load operation of the AES-3C Maritza East 1 power plant facility and anticipated alternative operating conditions of the other water consuming facilities in the area (existing Maritza East 1 power plant, Maritza East 3 power plant, and the briquette manufacturing facility.

Development of Figure 5.3 (Case 1) is cantered on the average stream flow at the "Galabovo" and "upstream of the confluence of the Maritza" stream flow measurement stations (9.738 and 10.41 0 m3/s, respectively) and maintaining a balance of flows into and out of Rozov Kladenetz Lake. The specific assumptions used to develop this regional water budget are provided in Table 5.15. The results of the four operational scenarios are presented in Table 5.16.

In Case 1, power plant (Maritza East 1 and Maritza East 3) and briquette factory water supply withdrawals are set at fixed values, the diversion flow from the Sokolitsa River is set at 50 per cent of total flow (or a 100 per cent diversion for 6 months of the year), and the Sazlijka River pump station "lake water diversion" flow is adjusted so that flow into Rozov Kladenetz Lake balances flow out of Rozov Kladenetz Lake. As a check, the resultant stream flow upstream of the Sazlijka River's confluence with the Maritza River is then checked versus historic average value. Since the water budget flow is within 0.02 m3/s of the 10.41 m3/s reported average value, there is general agreement.

Figure 5.4 (Case 2) reflects the full load operation of the AES-3C Maritza East 1 power plant project (withdrawal from the lake of 1222 m3/h) and a reduced load operation (50 per cent reduction, down to 100 MW) of the existing Maritza East 1 power plant. Case 2 assumes that the briquette factory continues to operate at current capacity and the Maritza East 3 power plant continues to operate without the implementation of planned improvements (installation of flue gas desulphurization systems). Since thermal discharges to the lake would be reduced, it is assumed that lake evaporation would be reduced by 10 per cent as compared to historic conditions. Case 2 indicates a potential reduction in Sazlijka River stream flow (as compared to historic average stream flow) at Galabovo (downstream of the pump station) of 0.11 m3/s and at the location upstream of the confluence with the Maritza River of approximately 0.11 m3/s. These values represent a flow reduction of approximately 1 per cent, a non-significant reduction. FIGURE 5.3 REGIONAL WATER BUDGET - CASE 1 - HISTORICAL OPERATIONS (EXISTING MARITZA EAST 1 POWER PLWNT (200 MW) AND MARITZA EAST 3 (WITHOUT FGD)

SAZUJKA RIVER FlOyV UPSTREAM OF PUMP SAlLlJKA RIVER STATION PUMP STATION 11.05 EXISTING PROCESS WATER MAAITZJ.\ EAST 1·200 PLAt'·017 MW ADD1~ OPERATION SAZLIJKA RIVER FLOW AT \ WATER / GALABOVO MEASUREMENT STATION

WATER \ / TO LAKE I AES MARITZA EAST 1 NOT IN LAKEt Y- OPERATION EVAP.~ KLADENETZ 0.14 \ lAKE

BRIQUETTE FACTORY

MARITZA EAST 3 - 0.32 DIVERSION TO LAKE PAIORTO -----i~F~G~D~M~O~D~I:F.J 0.05 r ME-;3 DISCHARGE

DRAiNAGE AREA 0.63 SOKOLITSA RIVER DOWNSTREAM OF $OKOUTSA - DOWNSTREAM GALABOVO (NOT iNCL RIVER BASIN OF DIVERSION SOKOLITSA) FLOW

SAZLlJKA RIVER FLOW AT NOTE: ALL FLOWS IN M3fS MEASUREMENT STATION UPSTREAM OF CONFLUENCE WI MARIT RIVER LAKE WATER BALANCE 10.39 WATER IN 1.56 M~rS WATER OUT 1.56 M3!S CASE 1 FIGURE 5.4 REGIONAL WATER BUDGET - CASE2 - FUTURE CONDITION AES-3C MARITZA EAST POWER PLANT (670 MW), EXISTING MARITZA EAST 1 POWER PLANT (100 MW) AND MARITZA EAST 3 (WITHOUT FGD)

SAZLlJKA RIVER FLOW UPSTREAM OF PUMP SAZUJKA RIVER STAT!ON PUMP STATION 11 ,16 _~~ __.. ___.JJ..o.3... ______---.I EXISTING I ~-- PROCESS WATER MARITZA

EASTMW 1·· 100J OPERATION

SAZUJKA RIVER FLOW AT COOUNG GALABOVO WATER MEASUREMENT STATION

963 AESMAR1TZA EAST 1 670 MW l.. OPERATION

.... r BRIQUETTE 'J' """ 0.20 ..~ FACTORY

MARITZA EAST 3 - 0,32 DIVERSION TO LAKE PRIOR TO FGD MODIF. 0,05 ME-3 DISCHARGE

DRAINAGE AREA 0.64 SOKOLITSA RIVER - DOWNSTREAM OF SOKOLITSA RIVER DOWNSTREAM OF GALABOVO (NOT INCl. BASIN FLOW DIVERSION SOKOLITSAj

SAZUJKA RIVER FLOW AT NOTE: ALL FLOWS IN M'/S MEASUREMENT STATION UPSTREAM OF CONFLUENCE WI MARITZA AIVER LAKE WATER BALANCE 10.30 WATER IN '.81 M3!S WATER OUT 1.81 MatS CASE 2 PBPower Section 5 Page 37

TABLE 5.15 REGIONAL WATER BUDGET ASSUMPTIONS - CASE 1: HISTORICAL OPERATIONS

Estimate Value Basis

3 Sazlijka River flow at 9.74 m /s Fixed value. The average stream flow at the Galabovo, downstream of measurement station from 1954 to 1995. Sazlijka River pump station

3 Sazlijka River flow 11.05 m /s Calculated value. Estimated by adding flow at Galabovo upstream of Sazlijka River to calculated withdrawals at Sazlijka River pump station. pump station

3 Sazlijka River flow 10.39 m /s Calculated value. Estimated by adding flow at Galabovo upstream of confluence to discharge from Sokolitsa River and flow from remaining with Maritza River watershed downstream of Galabovo measurement station. Value is approximately equal to the observed (1954 to 1995) 10.41 m3/s average flow value.

3 Total flow of Sokolitsa 0.58 m /s Calculated value. Estimated based on 160 km River basin. contributing drainage area and a stream flow to catchment 2 area ratio of 3.63 IIs/km . This ratio is calculated using stream flow upstream of the Sazlijka River pump station (11.05 m3/s) and dividing by the Galabovo measurement 2 station drainage area (3040 km ).

3 Diversion of Sokolitsa River 0.32 m /s Calculated value. Estimated assuming that 6 months of flow to Rozov Kladenetz the year (50 per cent of the time) the flow of the river Lake (plus the discharge from Maritza East 3) is diverted in the lake.

3 Sokolitsa River flow 0.32 m /s Calculated value. Estimated assuming that 6 months of discharging to Sazlijka the year (50 per cent of the time) the flow of the river River (plus the discharge from Maritza East 3) is allowed to flow to Sazlijka River

3 Existing Maritza East 1 0.07 m /s Fixed value. Estimated based on one of the station's 3 Sazlijka River pump (250 m3/h) two 250 m /h process water pumps operating at full station process water capacity year-round. withdrawal

3 EXisting Maritza East 1 1.35 m /s Calculated value. Value determined by iterative process, Sazlijka River pump station (4860 balancing the flow of water into and out of Rozov "lake water diversion" m3/h) Kladenetz Lake. withdrawal

3 Existing Maritza East 1 9.17m /s Fixed value. Approximate withdrawal under current circulating cooling water (33 000 operations. Since this withdrawal is not a consumptive flow fromlto Rozov m3 Ih) use, it does not directly affect the historical regional Kladenetz Lake water balance.

3 Existing Maritza East 1 0.17m /s Fixed value. Approximate withdrawal of water from lake "additional plant water (600 m3/h) for meeting miscellaneous non-process and non-cooling withdrawal" from Rozov demands. I/I ...... ___ ~ I _I, ..... PBPower Section 5 Page 38

Estimate Value Basis Kladenetz Lake

3 Briquette Factory water 0.20 m /s Fixed value. Approximate withdrawal of water from lake withdrawal from Rozov (720 m3/h) to meet facilities process water needs. Kladenetz Lake

3 Maritza East 3 water 1.06 m /s Fixed value. Approximate withdrawal of water from withdrawal from Rozov (3800 lake to meet process and cooling needs. Kladenetz Lake m%)

3 Maritza East 3 - Discharge 0.05 m Is Calculated value. Estimated as approximately 5 per to Sokolitsa River (190 m%) cent of water withdrawal from Rozov Kladenetz Lake

3 Lake Evaporation 0.14m /s Calculated value. Estimated based on Rozov Kladenetz Lake annual average of evaporation rate of 3.42 mm/day.

TABLE 5.16 COMPARISON OF HISTORICAL AND FUTURE REGIONAL WATER BUDGETS AVERAGE FLOW CONDITIONS

Case Sazlijka River Per cent change Sazlijka River Per cent change flow at in flow from flow upstream in flow from Gal a bovo historical of confluence historical 3 (m ts) average at with Maritza average at Galabovo River (m3ts) Confluence

Historical Average 9.74 - 10.41 - Stream flow Data

Case 2 AES-3C ME-1 9.63 -1.1% 10.30 -1.1% Old ME-1 @ 100 MW ME-3 without FGD

Case 3 - AES-3C ME- 10.34 +6.2% 10.98 +5.5% 1 Old ME-1 @100 MW ME-3 with FGD

Case 4 - AES-3C ME- 10.66 +9.4% 11.30 +8.5% 1 ME-3 with FGD Old ME-1 and briquette factory closed

FIGURE 5.5 (Case 3) reflects the full load operation of the AES-3C Maritza East 1 power plant, a reduced load operation (50 per cent reduction, down to 100 MW) of the existing Maritza East power plant, continued operation of the briquette factory, and implementation of FGD improvements at the Maritza East 3 power plant. The implementation of improvements at the Maritza East 3 power plant is expected to reduce water supply withdrawals from 3800 m3/h down to a rate of 1200 m3/h. Discharges from the facility are also expected to decrease. Where current discharges are estimated at approximately 5 per cent of withdrawals from the lake, the discharge after implementation of the FIGURE 5.5 REGIONAL WATER BUDGET - CASE 3 - FUTURE CONDITION AES-3C MARITZA EAST1 POWER PLANT (670 MW), EXISTING MARITZA EAST 1 POWER PLANT (100 MW) AND MARITZA EAST 3 WITH FGD

SAZUJKA RIV!;R FLOW UPSTREAM OF PUMP SAZUJKA RIVER STATION PUMP STATION 11.16 ~~~t-- Q.03 ______EXISTING ...... PROCESS WATER r:---.-~. MARITZA n~ EAST1· 0.78 \ ADD'l PLANli 0 OS 100 MW \ WATER / . SAZLlJKA RIVER FLOW AT rr;.~"Nit''l.0~P-=E....;RA_T-=I0.J GALA60VO MEASUREMENT STATION

WATER \\. 10.34l TO LAKE AESMARITZA EAST 1 670 MW LAKE ROZOV OPERATION I EVA? KlADENETZ 0.13 LAKE

MODIFIED ,----",",,,,",-JIoi MARITZA 0.30 DIVERSION TO LAKE EAST 3 0.01 ME·3 DISCHARGE 034 DRAINAGE AREA 0.59 SOKOLITSA RIVER DOWNSTREAM OF SOKOLITSA - DOWNSTREAM GALABOVO (NOT INCl. RIVER8ASIN OF DIVERSION SOKOUTSA) FLOW

SAZliJKA RIVER FLOW AT NOTE: ALL FLOWS IN M:l/S MEASUREMENT STATION UPSTREAM OF CONFLUENCE WI MAAITZ RIVER LAKE WATER BALANCE 10.98 WATER IN 1.08 M3/S WATER OUT i08 ~/S CASE 3 PBPower Section 5 Page 40

proposed improvements is estimated at 2 per cent of the withdrawal from the lake. Under Case 3, regional surface water withdrawals would decrease, resulting in a potential increase in Saziijka River stream flow (as compared to historic average stream flow) at Galabovo of 0.60 m3/s and at the location upstream of the confluence with the Maritza River of approximately 0.57 m3/s. These values represent a flow increase of approximately 5 to 6 per cent, likely resulting in improved water quality.

FIGURE 5.6 (Case 4) reflects the full load operation of the AES-3C Maritza East 1 power plant, and implementation of FGD improvements at the Maritza East 3 power plant. Under Case 4, the existing Maritza East power plant and the briquette factory would close, eliminating water supply withdrawals and cooling water discharges. With the complete elimination of the thermal discharge to the lake, it is assumed that lake evaporation would be reduced by 20 per cent as compared to historic conditions. Under Case 4 regional surface water withdrawals would further decrease, resulting in a potential increase in Saziijka River stream flow (as compared to historic average stream flow) at Galabovo of 0.92 m3/s and at the location upstream of the confluence with the Maritza River of approximately 0.89 m3/s. These values represent a flow increase of approximately 8 to 10 per cent, likely resulting in improved water quality.

A separate set of regional water budgets were set up for evaluating changes in stream flow under 95th percentile low-flow conditions. The results of this evaluation are presented in Table 5.17. The results of this evaluation are similar to those of the average flow evaluation. Since the 95th percentile flow value is a smaller number than average flow, the resultant percentage changes of flow values are greater. Under Case 2, the estimated reduction in Saziijka River flow at Galabovo and upstream of the confluence with the Maritza River would be 7.6 and 4.5 per cent, respectively. While these percentage reductions in stream flow would be greater than under average flow conditions, they are not of a magnitude that would be expected to result in significant impacts. Increases in stream flow, on a percentage basis, under Cases 3 and 4 would be greater during low-flow conditions (17 to 28 per cent increases), likely resulting in improved water quality. FIGURE 5.6 REGIONAL WATER BUDGET -CASE 4 - FUTURE CONDITION (AES-3C MARITZA EAST 1 POWER PLANT (670 MW), AND MARITZA EAST 3 WITH FGD, EXISTING MARITZA EAST 1 POWER PLANT AND BRIQUETTE FACTORY CLOSED)

SAZLlJKA RIVER FLOW , UPSTREAM OF PUMP I SAZLlJKA RIVER STATlON t 1.16 I PU~TION 000 .------tl>oI EXISTING I""L...J PROCESS WATER MARITZA 1---+-01----, / EAST 1- I 0.50 ADD'L PLANT! 000 NOT IN j WATER . OPERATION SAZLIJKA RNER FLOW AT COOLING GALA80VO WATER MEASUREMENT STATION

WATER 10.66 TO LAKE AESMARITZA EAST 1 670MW LAKE t ROZOV OPERATION EVAP. _ KLADENETZ 0.11 LAKE I BRIQUETTE ! FACTORY NOT .-...... ". .. IN OPERATION

MODIFIED 0.30 DIVERSION TO LAKE MARITZA EAST 3 0.01 *ME·3 DISCHARG E DRAINAGE AREA 0.59 SOKOUTSA RIVER DOWNSTREAM OF SOKOllTSA • DOWNSTREAM GALABOVO (NOT INOL RIVER BASIN OF DIVERSION SOKOUTSA) FLOW

SAZLIJKA RJVER FLOW AT NOTE ALL FLOWS IN M'/S MEASUREMENT STATiON UPSTREAM OF CONFLUENCE WI MARIT RIVER LAKE WATER BALANCE 11.30 WATER IN 0.79 M3lS WATER OUT 0.79 M"/S CASE 4 PBPower Section 5 Page 42

TABLE 5.17 COMPARISON OF HISTORICAL AND FUTURE REGIONAL WATER BUDGETS 95th PERCENTILE LOW FLOW CONDITIONS

Case Sazlijka River Per cent change Sazlijka River Percent change flow at in flow from flow upstream in flow from Galabovo historical 95% of confluence historical 95% (m3/s) low-flow at with Maritza low-flow at • 3 Galabovo River (m Is) Confluence

Historical 2.88 - 3.08 - 95 percentile low-flow stream flow data

Case 2 - AES-3C ME- 2.66 -7.6% 2.94 -4.5% 1 Old ME-1 @ 100 MW ME-3 without FGD

Case 3 - AES-3C ME- 3.37 +17.0% 3.62 +17.5% 1 Old ME-1 @ 100 MW ME-3 with FGD

Case 4 - AES-3C ME- 3.70 +28.5% 3.95 +28.2% 1 ME-3 with FGD Old ME-1 and briquette factory closed

5.8.4 Raw water treatment

Water for use in the power plant will be withdrawn from Rozov Kladenetz Lake using the pump station serving the existing Maritza East 1 power plant. Lake water has elevated suspended solids (typically 25 mgtl), total dissolved solids (typically 600 to 700 mgtl) and sulphate (typically 250 to 460 mgtl) concentrations. River water is of similar quality, except that suspended solids concentrations are typically higher (80 mgtl). Consequently, the raw water will require varying degrees of treatment prior to use in the facility ..

All lake water will be clarified and lime softened. Circulating cooling tower water will be treated with sodium hypochlorite for biological control and sulphuric acid to control scale deposition. Water to be used in the main power plant will be treated for suspended solids, dissolved solids and hardness reduction in the same solids contact clarifier that supplies the cooling towers. Further, this water will undergo filtration and disinfection (sodium hypochlorite) prior to being stored in a filtered water storage tank. Filtered water will serve general service water needs. Potable water and water to be used as boiler makeup in the power cycle will require further treatment to remove impurities. Both will be treated prior to final treatment specific to the intended uses. Potable water will be disinfected, and stored in a potable water storage tank. Demineralized water used as makeup to the power cycle will be further treated by ion exchange demineralization. Water in the condensate-feed water-steam cycle will be conditioned with hydrazine (an oxygen scavenger), and ammonium hydroxide (for pH contrOl). Trisodium phosphate will be added to the boiler water to minimize scale and corrosion. PBPower Section 5 Page 43

Waste waters and residual solid wastes will result from water treatment operations. These include lime sludge, filter backwash, and ion-exchange resin regeneration wastewater. Impacts associated with these waste streams are discussed in subsequent wastewater and solid waste sections.

5.9 Storm water and waste water management

5.9.1 Storm water and waste water impacts during construction phase

The existing Maritza East 1 power plant is not equipped with sanitary wastewater treatment facilities and the planned sanitary wastewater treatment facility for the new power plant will not be completed until late in construction schedule. Hence, temporary facilities will be required to manage sanitary wastewater during construction. Wastewater from temporary sanitary facilities will be collected in on site holding tanks. Periodically, as needed, these tanks will be pumped out to tanker trucks and sanitary wastewater will be transported offsite for appropriate treatment and disposal by a licensed sewage disposal contractor.

Since the project site is a relatively flat, previously developed property, storm water management is not anticipated to be a significant issue. Construction storm water pollution prevention best management practices will be implemented to minimize soil erosion and the quantities of sediment in storm water discharges from the construction area. Site grading and materials stockpiling will be performed using techniques designed to minimize potential erosion of topsoil. Construction will be performed using a phased approach, minimizing the area of disturbance at anyone time. Where appropriate, hay bales and/or silt fencing will be installed in areas down gradient of construction activities and surrounding storm drainage structures, to minimize sediment loading in storm water runoff. If necessary and where appropriate, a temporary storm water sedimentation basin will be constructed that will control peak flows of storm water runoff and dewatering discharges and allow for the settling of suspended sediment. Where appropriate, storm water runoff will be allowed to drain offsite by sheet flow, following natural drainage patterns. In the immediate planned power block area, storm water will be routed to the storm drainage systems currently serving the existing Maritza East 1 power plant facility. This combined discharge will then be discharged to active ash pond 3, as is currently the practice.

Groundwater in the vicinity of the project site is approximately 6 meters below the ground surface. Consequently, it is antiCipated that during certain stages of deep excavation (eg foundation construction), groundwater dewatering may be required. Sampling for potential groundwater contamination at the project site has not been performed to date, but will be performed prior to the initiation of project construction. Assuming that groundwater is not contaminated, dewatering discharges will be managed in a similar manner to the storm water discharges, as discussed above. If groundwater is determined to be contaminated, it will be collected and appropriate treatment will be provided prior to discharge to the existing power plant's storm drainage system.

To prevent potential chemical contamination of storm water, raw materials, fuels, and chemicalS used in support of construction activities will be stored in specifically designated areas. Such materials will PBPower Section 5 Page 44

be stored either under cover (in areas not exposed to precipitation) or in areas equipped with some form of secondary containment.

It is assumed that any improvements associated with the use of the existing intake structure will occur within the existing cooling water pump station and that the bank of the lake will not be disturbed. Therefore, construction related impacts to Rozov Kladenetz Lake will be minimal.

5.9.2 Storm water and waste water impacts during operation phase

5.9.2.1 Storm water

Storm water runoff at the AES-3C Maritza East 1 power plant will be managed to minimize the potential for storm water contamination. A lignite pile storm water detention pond and associated drainage system will be installed in the vicinity of the lignite piles and lignite train unloading area. The pond will be sized to store runoff from precipitation events up to and including the 10 year 24 hour storm event (estimated at approximately 122 mm of rainfall). Water collected in this pond will be treated (e.g. pH neutralization, if required) and routed to the raw water treatment plant for reuse.

A small storm water runoff pond, sized to store runoff from the 1 year 24 hour storm event (estimated at approximately 50 mm of rainfall), will be constructed in the main power block area to capture the "first-flush" storm water runoff (ie, the runoff containing a majority of sediment and potential contaminants). Occasional storm water overflows from this small storm water pond and less frequent overflows from the larger lignite pile runoff pond are expected to be generally free of suspended sediment. These overflows will be routed to the Sazlijka River and will be discharged at a point prior to the Sazlijka River's confluence with the Sokolitsa River. Discharge of such storm water into the Sazlijka River during times of high stream flow (extreme storm events) will have no impact on water quality in the river.

Oillwater separators will be used to treat potentially oily water from fuel oil storage and handling areas and other oil storage areas (eg lube oil, hydraulic oil, etc). The large oil storage tanks and most of the smaller oil storage areas will be located in bermed areas or will otherwise be equipped with secondary containment to minimize the potential for a release of oil. Clarified effluent from the oillwater separators will be routed to the raw water treatment plant for reuse.

Water and wastewater treatment chemicals will mainly be stored indoors. Chemicals stored outdoors, such as sulphuric acid and sodium hypochlorite, will be stored within secondary containment areas so that any potential spills or releases would be contained within the storage area.

5.9.2.2 Waste water

As a zero-discharge facility, there will be no waste water discharges to local surface waters and, therefore, no impact. FIGURE 5. 7presents the water balance diagram for the planned power plant. Most of the wastewater generated on-site will be associated with water supply treatment systems. . The effluents will be recycled as shown on FIGURE 5.7. Blow down from the cooling tower will be used in the air quality control system's wet limestone flue gas desulphurization system and in the bottom ash quenching system. r ------L{;~-l F~-::l 0, seoo, . ------1

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L______._ .. __ .. __ ... _._." J. .__ ... _-_ .. .1 ::11 00\0 In tin 'i. L1)GE ~!l~~~-__ -~l ~1_~~~.~ , ~ ~------~~S-"3~C------'------F~IG~U~R~E~5.7~------~~m--'---~~~Ir~~PB--PO----~~ MARllZA EAST I POWER PLANT WATER BALANCE DIAGRAM ~. wer ~ Ocot>yr'qllPBP_ PBPower Section 5 Page 46

Individual waste water streams (as described in FIGURE 5.7) generated will include the following:

• pre-treatment system sludge dewatering effluent (which will have elevated dissolved solids) will be returned to the raw water treatment plant,

• pre-treatment system filter backwash (containing elevated dissolved solids and suspended solids) will be channelled to the raw water treatment plant,

• plant and equipment drain water will also be sent to the raw water treatment plant (water from plant chemical drains will be routed to the neutralization basin),

• ion exchange resins regeneration wastewater (acidic and caustic waste streams) will be channelled through the neutralization basin, then to the ash water storage basin,

• boiler blow down (relatively clean water with minor quantities of residual boiler conditioning chemicals) will be reused in the water treatment plant,

• sanitary wastewater to sanitary wastewater treatment plant, where it will be treated using activated sludge followed by disinfection using calcium hypochlorite; the treated effluent will be routed to the ash water storage basin, and

• cooling tower blow down (with elevated dissolved solids) will be used in the air quality control flue gas desulphurization wet limestone scrubber for both direct injection and for use in mixing the limestone slurry; also used for quenching in bottom ash system. Any excess will discharge to the ash water storage basin.

Since waste waters will be recycled and reused within the facility and since there will be no discharges of wastewaters to local surface waters, there should be no impacts associated with waste water discharges.

5.10 Impacts on groundwater resources

Water supply for the construction and operation of the planned power plant will not include groundwater withdrawals. Limited groundwater dewatering may be required during the construction of building foundations (the groundwater table is at a depth of approximately 6 m below the ground surface), however, such withdrawals would be minor in quantity and short in duration. Consequently, there will be no long-term groundwater withdrawal related impacts.

Groundwater quality sampling will be performed prior to construction to assess potential contamination related to past practices at the site. If contamination is detected, treatment of the withdrawn water will be conducted to ensure that groundwater dewatering discharges comply with Bulgarian Class III water quality standards (as presented previously in Section 4.4).

Protection of groundwater resources from potential construction and/or operational phase oil or chemical spills or other releases to groundwater will consist of structural measures, operational (loading/unloading) procedures, regular inspections of storage areas, and rapid implementation of a contingency plan in response to a perceived release. Structural measures will include provision of an impermeable liner under the lignite storage piles, provision of impervious secondary containment in oil PBPower Section 5 Page 47

and chemical loading and unloading areas, and provision of bulk storage tank spill prevention/leak detection devices (eg, visible level gauges, level alarms, leak detection sensors, etc). Fuel and chemical loading and unloading procedures will be designed to minimize the potential for a spill or release and allow for a rapid response to a spill should one occur (through training and readily available spill response equipment). A spill response contingency plan will be developed to facilitate rapid response in the event of a release.

5.11 Impacts on terrestrial ecology

5.11.1 Impacts on vegetation and soils

5.11.1.1 Construction phase impacts on vegetation and soils

As described in Section 4, the Thracian Plain landscape surrounding the existing Maritza East 1 power plant site is largely agricultural in nature. Prior to conversion to agricultural land, the Thracian Plain was forested, with mixed oak forests as the dominant cover type. Within the general vicinity of the proposed project, especially along the lowland river valleys, remnants of forest communities remain. There are no terrestrial endemic, threatened, endangered or rare plant or animal species located at or within the immediate vicinity of the site.

The construction of the new power plant will largely occur within the boundaries of the existing industrial site and is anticipated to have little to no impact on terrestrial ecology during the construction phase. No significant impacts will occur to the soils and the vegetation outside of the footprint of this previously disturbed area. No rare and endangered species of plants and animals have been identified in the vegetation communities occurring within the proposed construction zone.

Construction of the new facility has the potential to impact ruderal, successional vegetation growing on the reclaimed areas of the overburden disposal area. Debris from the demolition of portions of the old Maritza East 1 power plant has been deposited in the overburden disposal area. In the near future, demolition of the ancillary structures (eg, drying plant, acetylene station, and old concrete mixing plant) will result in continued disposal of debris in this or a new area.

5.11.1.2 Operation phase impacts on vegetation and soils

The dispersion of pollutants from the plant and subsequent deposition on the terrestrial landscape would be the major potential operation phase impact on vegetation and soils. The proposed power project will primarily emit nitrogen oxides (NOx), sulphur dioxide (S02), particulate matter (PM) and carbon monoxide (CO). There will be minor amounts of trace elements and non-methane hydrocarbons (NMHC). Deposition of airborne pollutants has the potential to adversely affect vegetation, soils, and animals in the deposition zone. With regard to terrestrial ecological receptors, exposure to unacceptable levels of airborne pollutants has the potential to result in changes in physiological processes, ecosystem health, the quality and quantity of agricultural production, and species diversity or richness. PB Power Section 5 Page 48

5.11.2 Impacts on fauna

5.11.2.1 Construction phase impacts on fauna

No protected species are known to occur or nest within areas proposed for construction of the new AES-3C Maritza East 1 power plant, therefore, no impacts are expected.

As described in Section 4, several globally threatened avian species, including the Dalmatian pelican (Pelecanus crispus) and pygmy cormorant (Phalacrocorax pygmeus), are known to over-winter on the unfrozen, thermally influenced Rozov Kladenetz Lake. Construction activities should not significantly impact these species, since construction of the new power plant and associated facilities should cause minimal impact to the lake. Impacts could potentially occur if runoff during site preparation enters the lake, which could result in minor short-term negative impacts on the fisheries resource. Potential winter feeding areas for geese and ducks would be impacted if large areas of grain fields are used to store equipment during construction. This impact would not be significant since agricultural lands are common throughout this area. Since the new plant will be built within an existing industrial area, increased noise during construction is not expected to have significant impacts on local wildlife.

Additional minor impacts are possible when intake and discharge structures are upgraded or modified. This could potentially result in short-term disturbance of birds using Rozov Kladenetz Lake. This impact would be more significant if any large-scale lake-side construction occurred during the winter months, and resulted in disturbances to over-Wintering birds on the lake.

5.11.2.2 Operation phase impacts on fauna

The majority of potential operation phase impacts on fauna can be placed in two broad categories: (1) impacts to threatened and endangered animal species; and (2) migratory bird collisions with the facility's buildings.

5.11.2.3 Operation phase impacts on threatened and endangered species

Operation of the proposed AES-3C Maritza East 1 power plant is generally expected to be beneficial to the environment. After the new facility is operation of the proposed power plant will meet all Bulgarian and international standards. This suggests that any current negative effects from air pollution on over-wintering threatened and endangered avian species on Rozov Kladenetz Lake should rapidly decrease once the new facility is operational. Likewise, endangered and threatened avian species would be expected to benefit from the improved water quality associated with operation of the new power plant. Since the new power plant is a zero discharge facility, it is anticipated that eliminating wastewater discharge into Rozov Kladenetz Lake will eventually increase the overall health, growth, and reproduction of all aquatic life forage used by the protected bird species (eg, fish, which are the main food for cormorants, pygmy cormorants, and Dalmatian pelicans).

(eg, shutdown of the existing Maritza 1 east plant), thermal discharge to Rozov Kladenetz Lake will be eliminated. Although no modelling data are available, it is possible that the lake will revert to its normal state and will freeze in the winter months. The potential for the lake to freeze is determined by interaction of varied factors, including air temperature, ambient water temperature of the lake (without the thermal input), the water temperatures of the Sokolitsa and Sazlijka River discharges into the lake, the depth of the lake, cloud cover and solar radiation, snow cover, wind speed, and circulation patterns within the lake.

In the absence of an external thermal discharge, Rozov Kladenetz Lake could potentially revert to its natural state and freeze. This condition has the potential to: (1) temporally limit the use of the lake by certain over-wintering waterfowl, including endangered species, and (2) result in reduced winter growth of fish in the lake, thereby affecting the availability of forage prey items by endangered and threatened species. It is possible that there could be locations within the lake which do not freeze, including water in the vicinity of the power plant's water intake structure, and near the points at which Sazlijka River and Sokolitsa River water are discharged to the lake. In general, January would likely be the time period most impacted by the lack of heated discharges to the lake.

These conditions could cause the protected birds to move to other unfrozen lakes in the region to feed. Other lakes in the region (Ovacharitsa Lake, and possibly others) are expected to remain open and provide food for these species. It is not expected that the change in food availability will significantly impact these species.

5.11.2.4 Collision mortality of migratory birds

The river valleys in the vicinity of the AES-3C Maritza East 1 power plant (eg, the Sokolitsa, Sazlijka, and Maritza Rivers) serve as migratory flyways for a wide variety of avifauna, and the largely agricultural landscape in the vicinity of the power plant likely provides abundant forage for certain members of the bird community. A major bird migration route (the "Via Aristolis" route) occurs along the Maritza River, to the south of the site. Peak migratory months are March to May and August to October. Migration distances, behaviour, and timing vary greatly between species. It is likely that the Maritza River is a major landmark by which birds chart their course during both spring and fall migrations.

A potential ecological concern associated with the AES-3C Maritza East 1 power plant project is migratory bird collisions with the proposed facility's buildings. Although no information is available, this ecological concern currently exists with the existing facility's stack. A body of literature is available indicating that bird mortality from flying into man-made structures (including tall buildings, radio and television towers, cooling towers, and tall stacks) represents a potentially significant impact to bird populations. Several studies have indicated that, under a certain set of circumstances, avian collisions with a single man-made structure (eg, one tall building or one stack) may result in annual losses of greater than 1,000 birds per structure. The majority of stUdies have focused on 150 to 330 m structures; the proposed cooling tower at the AES-3C Maritza East 1 power plant station is approximately 135 m in height.

Avian collisions with man-made structures is not solely due to incidental collision; several studies have indicated that the lighting on towers and other tall structures, intended to provide warning for aircraft or security for facilities, may actually attract birds. On overcast or foggy nights, the lighting of towers refracts in the moisture present in the air, illuminating the area around the tower. One study of PBPower Section 5 Page 50

bird behaviour around a 984 ft TV tower in Illinois, USA indicated that birds were circling the tower during an overcast, foggy night. The birds dispersed quickly when the lights were turned off for short periods of time; reappearing when the lights were turned on (Cochran and Graber, 1958). Observations by Avery, et ai, (1976) and Larkin and Frase (1988) indicated that birds concentrated around lighted towers on nights when weather conditions were overcast or when a light mist was present. Conversely, birds were unlikely to be found near the towers on clear nights.

Birds migrating at night are often attracted to artificial light. This is the single most important factor in rendering a structure a hazard to birds (Ogden, 1996). The reason for the attraction is not entirely known. Migrating birds may view the lights as navigational aids or confuse them with the moon. The attraction to light leads birds to the structure. Once there, the birds are reluctant to leave the lighted area and will circle the structure until exhausted (Graber, 1968). Therefore, if direct collision with the lighted structure does not injure the birds, the potential remains for extreme exhaustion to drive the birds to the ground where they may die, or fall victim to predators.

Certain sub-families of the Passeriformes tend to be more commonly affected by man-made structures (Ogden, 1996). In general, these songbirds fly at low altitudes during migration. This, combined with their nocturnal behaviour, makes them particularly vulnerable to mortality resulting from interaction with man-made structures. Limited evidence exists suggesting that certain taxonomic groups (eg, warblers and sparrows) are more vulnerable to light attraction mortality than others.

5.12 Aquatic ecology

5.12.1 Construction phase impacts on aquatic ecology

It is assumed that no wetlands or other water bodies will be disturbed or removed for construction. However, it is likely that some minor modifications of existing intake or discharge structures will occur, possibly affecting the Sokolitsa River, Sazlijka River, and the Rozov Kladenetz Lake. Since no Significant or protected aquatic resources occur in these habitats, no long-term impacts are expected.

Potential impacts could occur to all water bodies from storm water runoff during site preparation (earth moving, grading, soil storage) and during the period before all surface runoff catchment basins are completed and prior to revegetation of disturbed soils. Any Significant sedimentation of these water bodies has the potential to adversely affect aquatic resources. However, since the existing water carries some sediment load, these potential impacts are not expected to be significant or long term, especially if these potential impacts are mitigated.

5.12.2 Operation phase impacts on aquatic ecology

The majority of potential operation phase impacts on aquatic ecology can be placed in two broad categories: (1) migration of pollutants from the plant and subsequent deposition in the aquatic environment; and, (2) water withdrawal and discharge impacts associated with power plant operation.

5.12.2.1 Potential airborne pollutant impacts on aquatic ecology

As discussed earlier, the proposed power project will emit nitrogen oxides (NOx), sulphur dioxide (S02), particulate matter (PM) and carbon monoxide (CO). There will be minor amounts of trace elements and non-methane hydrocarbons (NMHC). At sufficiently high levels, deposition of airborne PBPower Section 5 Page 51

pollutants can adversely affect surface water and sediment quality, palustrine and aquatic vegetation, and animals in the deposition zone. For aquatic ecological receptors, exposure to elevated levels of airborne pollutants has the potential to result in changes in aquatic community health and diversity, and ecosystem function.

Air modelling suggests that current negative effects from air pollution on the riverine and lacustrine communities should rapidly decrease once the new facility is operational.

5.12.2.2 Water withdrawal and discharge impacts on aquatic ecology

Rozov Kladenetz Lake currently provides water for the existing Maritza East 1 power plants once through cooling system, fire water system, and non-potable process needs. When sufficient stream flow is available, water from the Sokolitsa River is diverted to Rozov Kladenetz Lake to maintain the water level. A pump station on the southern bank of the Sazlijka River supplements the Sokolitsa River diversion and also pumps process water from the river to the existing power plant for use in boiler makeup and other process water needs.

Limited baseline data are available to evaluate ecological impacts associated with the water level drawdown from operation of the existing power plant. In Rozov Kladenetz Lake and the two rivers, water depth is likely a critical ecological factor in determining the abundance and distribution of fish, benthic invertebrates, and aquatic macrophytes. Undesirable possible side effects of water level drawdown include the loss or reduction of desirable plant species, facilitation of invasion by draw down resistant undesirable plants, possible fish kills if oxygen demand exceeds re-aeration during a prolonged drawdown, possible loss of fish spawning areas, possible reductions in benthic invertebrate diversity and abundance, and more frequent algal blooms following re-f1ooding. These undesirable side effects may not be currently manifested in Rozov Kladenetz Lake, since water levels in this lacustrine water body are artificially elevated through river drawdown; however, the existing drawdown regime may have an adverse impact on river ecology, particularly in the Sazlijka River.

The water withdrawal associated with the proposed AES-3C Maritza East 1 power plant will generally result in improved conditions in the adjacent rivers and man-made lake. Rozov Kladenetz Lake will serve as the source of all water for the planned project including cooling water, fire water, boiler makeup, service water, and potable water. As described in Section 5.8, under the majority of scenarios, operation of the proposed power plant will result in a net decrease in water consumption from Rozov Kladenetz Lake, the Sazlijka River, and the Sokolitsa River. This net decrease in water consumption is expected to result in higher, more typical seasonal water levels in the lake and the rivers. It is possible that water column and benthic invertebrates, as well as fish species, will benefit from this normalization of water levels, and that the possible side effects associated with water withdrawal and drawdown outlined above will be reduced or eliminated.

As a zero-discharge facility, there will be no wastewater discharges from the proposed AES-3C Maritza East 1 power plant to local surface waters, and therefore no adverse impacts associated with wastewater discharge. Heated once-through cooling water from the existing power plant is returned to Rozov Kladenetz Lake. Some wastewater is also discharged into settling lagoons or returned directly to the Sazlijka River. As a result of this thermal influence, water temperatures in the lake are artificially elevated and the lake does not freeze in winter months. In large part due to the unfrozen winter condition of Rozov Kladenetz Lake, it functions as a important over-wintering ground for geese, pelicans, cormorants and other waterfowl. PBPower Section 5 Page 52

For two of the three potential operational scenarios outlined in Section 5.8, the existing plant will remain operational, and will continue to discharge thermally treated water to the lake. It is anticipated that no significant change in the lake conditions will result, and it is possible that the lake will continue to remain artificially unfrozen during winter conditions. Under the third operational scenario evaluated in Section 5.8 (eg, shut-down of the existing Maritza 1 east plant), thermal discharge to Rozov Kladenetz Lake will be eliminated. Although no modelling data are available, it is possible that the lake will revert to its normal state (ie, will reflect ambient climatic conditions rather than artificially elevated temperatures) and will freeze in the winter months. This has the potential to: (1) temporally limit the use of the lake by certain over-wintering waterfowl, including endangered species, and (2) result in reduced winter growth offish in the lake, thereby affecting the local fish cooperative.

5.13 Socioeconomics

5.13.1 Construction phase impacts on socioeconomics

5.13.1.1 Employment impacts

The construction of the new plant will not impact employment at the existing 200 MW Maritza East 1 power plant. The proposed project does not require or mandate the closing of the existing Maritza East 1 power plant or the currently operating briquette manufacturing plant. Throughout the three year construction period, both plants are expected to continue normal operations.

The most significant socioeconomic impact the proposed project will have during the construction period is increased employment in the Galabovo area. This is an important benefit to the local area, as the unemployment rate in the Municipality of Galabovo is estimated at 13.9 per cent.

The estimated start date for site construction works for the new AES-3C Maritza East 1 power plant is June 2006 The entire construction period from Final Notice to Proceed (estimated date January 2006) to the completion of construction is estimated at 36 months. Final Notice to Proceed is defined as the date at which the project enters the final design phase and is the beginning of the 36 month construction period. Actual construction on site will not take place until 5 months after the Final Notice to Proceed.

During the 31 month actual construction period, it is estimated that a peak of 2000 construction workers would be required for 2 months (estimated date January-February 2007). An average of 1245 workers per month would be required during this 31 month period. In addition to the direct employment impact during construction, the indirect generation of construction jobs and part-time jobs (ie less than 40 hours a week, or less than a full-time equivalent, would increase the peak construction work force to an estimated 2600 workers.

All of the construction jobs are expected to be filled from the local and regional work force. Priority will be given to workers from the Municipality of Galabovo (eg the Town of Galabovo and the ten villages in the Municipality). Any training needed is expected to be provided by the existing technical college in the Town of Galabovo that currently provides employment training for the energy sector. If workers with the appropriate skills are not available in the local area, workers from the larger Stara Zagora Regional Economic Development Agency (SZREDA) area will be recruited. This larger regional area would include the ten municipalities located within the Stara Zagora administrative district which PBPower Section 5 Page 53

include: Stara Zagora, Radnevo, Opan, Chirpan, Bratia Daskalovi, Pavel Bania, Kazaniak, Maglizh and Topolovgrad.

As discussed in Section 4, approximately half of the population of the Town of Galabovo is of working age (eg between the ages of 15 and 55). This translates to a total labour force of approximately 5100 workers for the Town of Galabovo. Assuming that there is the same age structure (ie 50 per cent of the population is of working age) for the remaining 10 villages in the Municipality, there would be an additional total labour force of 3700 workers. Therefore the total labour force in the Municipality of Galabovo is approximately 8800 workers. Applying the 13.9 per cent unemployment rate for the Municipality of Galabovo to the total municipal labour force results in an estimate of 1200 available workers. This available municipal labour force will most likely be adequate to fill the average employment requirements for the construction of the new power plant.

However, workers from outside the Municipality of Galabovo from the SZREDA area will have to be recruited for peak construction. The SZREDA area should be more than adequate to fill the peak construction employment needs of the project. The entire SZREDA area has an approximate population of 390 000 people. The Municipality of Stara Zagora is the largest municipality within the region, with approximately 200 000 people residing in the City of Stara Zagora.

5.13.1.2 Economic impacts

The project will have positive economic impacts on the local region. Construction of the new plant will result in a large infusion of capital into the project region. The total construction cost of the project is estimated at $700 million, of which up to $150 million could be earned by Bulgarian companies. The project's economic multiplier effect will most likely result in an increase in new business opportunities associated with the plant construction. A multiplier is simply the ratio between an initial expenditure and the total increase in economic activity resulting from the initial expenditure.

In addition to the project investment of capital into the region, indirect positive economic impacts will be created as construction workers spend their income on goods and services in the local Galabovo area, which may result in local businesses hiring more workers to meet this increased demand. Additional jobs may then be created as service industries catering to the construction workers and industries producing the equipment for the new plant increase output and hire.

5.13.1.3 Housing and infrastructure impacts

It is not anticipated that the generation of new jobs during construction will induce residential expansion in the Municipality of Galabovo or in the SZREDA area. Likewise, it is not antiCipated that new housing will be necessary to accommodate employees during construction as the workers will come from areas within the Municipality of Galabovo and the larger SZREDA area that are within commuting distance of the project site. Since the demand for workers will be supplied largely from the regional labour area, it is expected that these workers will reside in existing housing and will not significantly impact existing municipal services such as fire protection, schools, health care facilities and water supply. .... ------~----~

PB Power Section 5 Page 54

5.13.2 Operation phase impacts on socioeconomics

5.13.2.1 Employment impacts

It is expected that the proposed plant will operate at the full capacity of 670 MW while the existing plant will operate at an average level of 100 MW. Although the existing Maritza East 1 power plant would operate at half capacity, this would not necessarily affect the number of employees at the current plant or associated briquette plant. Changes in the number of shifts, job assignments and seasonal variation in employment may result. These changes, at either the existing Maritza East 1 plant or the briquette plant, would be the responsibility of the respective facility owners. The project company through the project's anticipated social responsibility program, has committed to work with the local community to provide job training and other forms of assistance to maintain and/or improve the economic condition of the local area. Workers who might be affected by changes in operation at the power plant or briquette plant would be among the first eligible for participation in this program.

The new power plant will provide direct employment for up to 250 people during operation. The majority of the operational staff will be employed from within the SZREDA area. In addition to direct employment impacts, the project will indirectly support the employment of thousands of miners at the existing Maritza East lignite mines, currently estimated at 12 000 workers. The project will also provide for the indirect employment for the limestone quarry-workers, railway and lorry transport workers and other associated service industries.

5.13.2.2 Economic impacts

During operation, the project will provide substantial economic benefits via increased tax revenues at both the municipal and central levels of government, amounting to approximately $22 million per year of operations. The Project Company will be registered locally and thus pay relevant taxes to the Municipality of Galabovo.

5.13.2.3 Housing and infrastructure impacts

There will be no relocation as a result the operation of the new plant. The plant is adjacent to the existing Maritza East 1 power plant on an industrial site owned by either NEK or Brikel EAD. Therefore, no expropriation of private lands will occur as a result of the proposed project.

As stated previously, the majority of the operational staff will be employed from within the SZREDA area. New housing or residential expansion in the local area is not anticipated to occur as a result of the operational staff employed at the new plant.

The new plant will not require the expansion of fire protection, schools, health care facilities, water supply or other local municipal services, because the majority of the operational staff will come from the regional area. The few operational staff that are hired outside of the SZREDA area will have a minimal impact on local infrastructure.

Fire protection eqUipment associated with existing structures will remain in place and be expanded to include the new structures (turbine building, cooling tower, lignite crushing building, etc). The new plant will make use of the fire truck associated with the existing Maritza East 1 plant. Any PBPower Section 5 Page 55

modifications or upgrades will be based on the latest U.S. National Fire Protection Association standards, and local Bulgarian fire codes.

The new plant will have a zero discharge of wastewater and the water supply for the new plant's operational needs will come from the Rozov Kladenetz Lake. Therefore, the project will not require or use any municipal water supply or treatment services.

5.14 Impacts on transportation

5.14.1 Construction phase impacts on transportation

During the 36 month period of construction, traffic in the site area will increase due to the delivery of goods and materials and the twice-daily arrival and departure of site construction workers. Estimated employment at the peak of construction will be approximately 2600. Based on current employment patterns and the substantial skill base within the larger Stara Zagora economic area, it is expected that most workers will commute to the job site from within the region. While the exact locations that they will come from cannot be determined at this time, it is expected that staffing will result in the following:

• Those workers who might come from outside a distance defined by a daily commute, will be housed in existing local facilities and will not require construction of a dedicated worker camp.

• Transportation to the site for workers from Stara Zagora, Galabovo, Radnevo, Nova Zagora and other towns will generally be by bus.

• Shift changes for the construction workers will be timed so as to minimize the increase in traffic that is associated with the twice-daily shift change at the existing Maritza East 1 power plant.

• Limited parking will be available within the construction site for those workers who commute by car.

Because of the current level of bus traffic in the area, the addition of buses transporting construction workers, when timed to not coincide with the plant shift, will result in an overall increase in area traffic but should not result in a substantial increase in the peak average hourly traffic rate. Rather the period of peak traffic flow will be extended from the current one-hour peak to two, two hour peak periods per day.

Delivery of materials and supplies will be by rail and truck. The very largest items, such as the plant turbines, will be sent by ship to the port of Varna, which is east of Galabovo on the Black Sea coast. From there, these as well as materials being sent from Sofia, will be transported to the site by train using a combination of public and private rail lines. The private rail lines are currently used by NEK for deliveries to the existing Maritza East 1 power plant.

Some materials deliveries will also be made exclusively by truck. Vehicles used for such transport will be similar in size and weight to the large, international transport trucks that now frequent the roads in the vicinity of the power plant. For the delivery of the largest plant items, it can be expected this may PBPower Section 5 Page 56

result in some slow down in traffic, and at the point of actual delivery at the site may require temporary traffic control. Prior to undertaking the very largest deliveries, vendors and those responsible for delivery will need to review road and bridge conditions to confirm adequacy of clearance and compliance with roadway load limits.

5.14.2 Operation phase impacts on transportation

Plant employment during operation is expected to total no more than 250. This increase is not expected to impactthe three traffic intersections considered most critical to maintenance of local area traffic flow. Most workers will commute to the plant site via bus. Should there be any adverse effects to existing worker traffic patterns, this can be easily corrected by altering the times of the shift changes at the existing and proposed power plants.

Delivery of supplies to the plant area will increase. Increased coal quantities will be brought by private rail and therefore will not affect private rail traffic. Limestone will also be delivered via private rail lines. Truck transport will increase but area traffic flow should be unaffected. Facility-related truck traffic is expected to represent only a small increase in overall area traffic but not contribute to a decreased level of service.

5.15 Impacts on noise levels

5.15.1 Construction phase impacts on noise levels

The construction of the power plant will take approximately 36 months. Since construction machines operate intermittently and the types of machines in use at the construction site change with the phase of the project, noise emitted during construction will be highly variable. To estimate noise levels associated with the construction of the power plant, construction activities have been divided into five stages: site preparation, excavation, foundations, erection and finishing. For each phase, an estimate of the equivalent sound level (Uq) at various distances from the project site has been calculated using computer modelling. The model uses the following data and adjustments:

• The numbers of each type of construction machine typically present at the site for each phase of construction.

• The usage factor for each type of construction machine.

• The typical A-weighted sound level at a distance of 15 m from each type of construction machine.

• The distance between construction machines and various receptors (500, 750, 1000, 1500, 2000, and 3000 m).

• Distance attenuation associated with atmospheric absorption and anomalous effects.

Table 5.18 is a compilation of equivalent sound levels (Leg) estimated for each phase of construction. Appendix C presents a complete printout, of the computer model for the various distances that have been selected. Since the nearest residential properties are located approximately 1500 m from the PBPower Section 5 Page 57

project site, it is estimated that construction noise will rarely exceed existing equivalent sound levels (Uq). It is likely that noise from construction will be noticeable at the nearest residences, particularly during the "foundation" phase when pile driving occurs and during the "finishing" phase when steam blowouts are performed. The maximum sound levels associated with these activities are approximately 55-65 dBA. Consequently, construction activities are expected to have minimal and temporary impacts on the noise environment in the communities south and west of the project site.

TABLE 5.18 ESTIMATED EQUIVALENT (U Q) SOUND LEVELS (dBA) FOR VARIOUS PHASES OF POWER PLANT CONSTRUCTION

Distance Site Excavation Foundation Erection Finishing (meters) Preparation

500 62 63 62 56 58

750 58 59 58 52 54

1000 55 55 55 49 51

1500 50 51 50 44 46

2000 47 47 46 40 43

3000 42 42 41 35 38

5.15.2 Operation phase impacts on noise levels

The proposed facility will produce noise that will occasionally be perceptible at the nearest residential receptors. This section of the report discusses noise produced by the operation of plant equipment. It also discusses modelling of operational noise and provides estimates of facility sound impact in the surrounding community.

5.15.2.1 Facility sound sources

The chief sources of environmental sounds produced by the AES-3C Maritza East 1 power plant are listed below:

Lignite Delivery, Storage, and Preparation

Lignite rail delivery

Lignite railcar unloading

Mobile reclaimers (2)

Conveyors

Transfer towers

Lignite crushers (coarse and fine) PBPower Section 5 Page 58

Stacker reclaimers (2)

Lignite pulverizers (16)

Limestone Handling and Preparation

Limestone rail delivery

Limestone railcar unloading

Limestone crusher

Conveyors

Transfer towers

Dryers

Blowers

Steam Generation Structures (2)

Boilers (2)

Primary air fans

Secondary air fans

Fluidizing air fans

Boiler feed pumps

HP blowers

Turbine-Generator Structure

Steam Turbines (2)

Generators (2)

Exciters (2)

Condensers

Condensate pumps

Electrostatic Precipitators (2)

Induced Draft Fans (2)

Flue Gas Desulphurization Structure

Unit Transformers (2)

Cooling Tower. PB Power Section 5 Page 59

5.15.2.2 Impact assessment methodology

Operational sound levels produced by the power plant have been calculated using SoundPlan® Wins Version 5.0 environmental sound monitoring software. For this project the General Prediction Method (OAL 28) was used to calculate facility sound levels in a 12 square km area surrounding the project site. In addition, single point calculations to each of the four selected sound monitoring locations were also performed. Receptor sound levels for each of the sources listed above are calculated using the following data and corrections:

• Source sound power level (in octave bands)

• Source directivity

• Equipment usage factor

• Distance between source and receptor

• Air absorption

• Ground effect

• Barrier attenuation (from earth contours or man-made structures)

Appendix C presents selected printouts from the sound model that list source sound power levels and source contributions at each of the four sound monitoring locations.

5.15.2.3 Predicted impacts on noise levels

FIGURE 5.8 graphically presents estimated isocontours of facility operational sound levels in the area surrounding the project site.

Table 5.19 presents estimated facility operational sound levels at each of the four selected sound monitoring locations. Included in this table are the existing sound levels at each location and the potential impact (ie sound level increase) due to the operational noise from the facility. 40-45 ,, Sound Level

\ \ 65<1<= 70 t 60< <= 65 55 < <= 60 I, i -'-'~II; ,~ 50 <~'c\':' <= 55 \ ';{:':J 45 < <= 50 \ l~· 40 < <= 45 35 <. <= 40 <= 35

, ..... j

-- ->

Location 3

~ ~------.------,~-;~~--~~------~~ AES - 3C FIGURE 5.B II. PB Power ~ MARITZA EAST I POWER PlANT NOISE CONTOUR PlOT ~. c CopyrIcjIt PB Power PBPower Section 5 Page 61

TABLE 5.19 EXISTING AND ESTIMATED EQUIVALENT (UQ) SOUND LEVELS (dBA) AT SOUND MONITORING LOCATIONS

Existing sound levels Estimated plant Estimated sound level sound 24 hours with facility operating

Daytime Night-time Daytime Night-time

Location 1 57 47 39 57 48

Location 2 54 53 36 54 53

Location 3 50 42 42 51 45

Location 4 56 49 39 56 49

Daytime is defined as 7 00 am -10 00 pm Night-time is defined as 1000 pm - 700 am

Based on the existing sound levels, the area would be characterized as industrial under both Bulgarian and World Bank noise standards. The resulting sound levels as estimated for the four measurement locations are within both the Bulgarian and World Bank daytime and night-time limit of 70 dBA in industrial areas. The estimated increase in noise is also in compliance with the World Bank limit of 3 dBA in areas of elevated sound levels.

5.16 Impacts on land use

5.16.1 Construction phase impacts on land use

The majority of the proposed project will be developed on lands previously devoted to industrial uses. There will be no conversion of lands from agricultural use to industrial use. Similarly there will be no conversion of lands from residential use to industrial use. The few forest lands in the region will not be affected by project construction.

5.16.2 Operation phase impacts on land use

Operation of the proposed power plant is consistent with current area land uses. Agricultural and mining activities in the project area will be unaffected. No formal land use plans have been identified that indicate a proposed alternate use of the project site. Rather, the Bulgarian National Energy Strategy has targeted this area for rehabilitation of the energy generation facilities and continued operation of the supporting lignite mines.

5.17 Recreational, protected and visual resources

5.17.1 Construction phase impacts

Construction of the proposed project will increase roadway traffic, noise and dust. These short-term impacts will largely affect local area residents and may result in their temporarily seeking recreation in PBPower Section 5 Page 62

areas removed from the project site. Those outside the area who might frequent the lake for bird watching will likewise seek opportunities outside the project area.

5.17.2 Operation phase impacts

As described in Section 4, no areas protected under the Bulgarian Law of Protected Areas have been identified in the project region. Rozov Kladenetz Lake is not a Ramsar Convention site, and has not been officially proposed to be listed. Nonetheless, Rozov Kladenetz Lake serves as an important over-wintering area in Bulgaria for waterbirds, and is known to support wintering populations of several globally protected bird species. Additional detail regarding potential construction and operation phase impacts to avian species is presented in the threatened and endangered species impacts assessment.

The project is not expected to adversely affect recreational opportunities in the project area nor affect the visual quality of the area. Those seeking recreation related to fishing or bird watching will be aware of little change from what is currently experienced. There may be some change in the composition of fish in Rozov Kladenetz Lake as the temperature slowly lowers due to reduction in the heated discharge from the existing Maritza East 1 power plant. To the extent that birds that feed on the current fish population experience a decline in food supply, there may be a change in the population of birds that frequent the reservoir. There will be no change in recreational opportunity or attractiveness of the area to outside visitors.

Likewise there will be no change in the visual landscape. The proposed project will be integrated into the current plant site. The addition of the cooling tower will be consistent with the stacks that already exist.

5.18 Impacts on cultural resources

5.18.1 Construction phase impacts on cultural resources

As proposed, the project is not expected to impact known and identified archaeological or historic resources. Most of the development will take place on already disturbed lands. Of the two Class 1 sites identified in archaeological investigations undertaken for this project, one is within the Maritza East 1 power plant site and already protected by a fence; the second is off site and outside the area of planned construction.

Encroachment into either of the two identified areas would result in additional investigation to further determine archaeological significance. This would be done by the local museum located in Radnevo. The outcome of additional investigation would be designation of one of the following:

• movement of the site to a museum

• movement of the site to another location

• development of the site as a tourist attraction

• leaving the site in place and restricting further development PBPower Section 5 Page 63

The opinion of the registered archaeologist who performed the site-specific studies is sufficient for approval of the Bulgarian EIA. The opinion presented in the EIA was that the implementation of the project, specifically development within the existing plant site and in the area of the new coal stockpile, will not have a destructive impact on the cultural and historic heritage provided that construction does not encroach on the two identified areas, in particular the one off site.

Subsequent to the approval of the Bulgarian EIA, the project will prepare and submit final construction plans. At this point, the Minister of Culture or the Director of the National Institute of Cultural Monuments will again review the project to give their approval to the final version of the construction permit application. At that time they can approve the project with no conditions, approve it with conditions, or reject it based on a finding of significant and immovable archaeological findings. Studies for the project were undertaken in consultation with the local museum responsible for protection of cultural resources and have concluded that as proposed, the project would be approved for construction by the ministry.

5.18.2 Operation phase impacts on cultural resources

Once construction is completed, there is nothing in the on going plant operations that should affect identified cultural resources. The integrity of the protected cultural resource that is on the project site will continue to be maintained so as to insure that routine plant operations do not affect this area.

5.19 Impacts of solid waste production and disposal

5.19.1 Construction phase impacts- solid waste production and disposal

Disposal of construction solid waste, under Bulgarian "Restriction of Harmful Waste Impact on the Environment Act" (S.G. No 86/30.09.1997, Amended by S.G. No 56/1999), is the responsibility ofthe local municipality. The Municipality of Galabovo has deSignated an area that is being used for the current demolition activities that are NEK's responsibility (demolition of structures to existing grade). A separate area will be requested for disposal of the excavated building foundations and underground utilities (eg pipelines, manholes, and cable galleries), and other demolition-related wastes, the removal of which will be the project's responsibility. This landfill will be operated in accordance with Bulgarian Ordinance No 13 on the Conditions and Requirements for the Construction and Operation of Waste Landfills (S.G. No 152/22.12.1998).

Disposal of routine paper, packaging material, and municipal solid waste associated with the construction process will be in the existing municipal landfills. The Municipality of Galabovo operates 12 landfills with a total capacity of 125 290 tonnes sufficient to accommodate the estimated 1,300 tonnes of municipal waste expected to be generated during construction.

Consistent with current plant operations, used oils will be collected and recycled. To the extent possible, large packing materials will be collected and shipped off site for recycling.

5.19.2 Operation phase impacts - solid waste generation and disposal

The largest amount of solid waste associated with facility operation will be the estimated 7000 tonnes per day of ash and gypsum generated in association with the combustion and air quality control processes. The project company is responsible for disposal of these materials in a new landfill that PBPower Section 5 Page 64

will be dedicated to the project. The area identified for development of the new landfill, the current Dryanovo overburden disposal site, is approximately 5 km southeast of the project. This has previously used by the mining company for disposal of mine overburden materials. An estimated potential storage capacity of a developed Dryanovo landfill facility would be approximately 110 million tonnes, which would provide sufficient capacity for planned facility ash and gypsum waste disposal. The expected annual formation of process by-products included:

• 143424 tonnes/annum Furnace Bottom Ash (FBA)

• 1 300 000 tonnes/annum Pulverized Fuel Ash

• 1 250 000 tonnes/annum Gypsum

The project is studying the economics of using the gypsum by-product in the manufacture of wallboard. To the extent that this is financially viable, this would reduce the total volume of solid waste requiring disposal in the new landfill.

The water treatment process will generate a residual solid waste, consisting primarily of calcium carbonate and ferric hydroxide solids. These will be used in the FGD plant. The sanitary wastewater treatment process will also generate residual solids. Sanitary treatment residuals, estimated at approximately 1 tonne per day, will either be used as a soil amendment or disposed in a municipal landfill.

Day-to-day operation of the plant will generate typical domestic office wastes (paper, packaging materials, general refuse) and process related solid wastes (disposable filters, rags, spent desiccant material, machine shop wastes, empty drums and containers). These wastes, estimated at approximately 1 tonne per day, will be disposed of in one of the existing municipal landfills. Options for recycling wastes (eg drums, containers, etc) will be evaluated. Consistent with current plant operations, used oils will be collected and recycled.

Sufficient capacity is available in the municipal landfills and in the planned ash and gypsum disposal site to handle the quantities of solid wastes generated by the project. Constructed and operated consistent with Bulgarian regulations, these landfills will have no significant environmental impact.

5.20 Impacts of hazardous substances

5.20.1 Construction phase impacts from hazardous substances

During the construction phase of the project, various fuels, chemicals, and raw materials will be used and stored on-site. Some of these may be classified as hazardous materials. Examples include:

• diesel fuel for vehicles and generators

• gasoline

• various lube oils, hydraulic oils, and greases

• paints PBPower Section 5 Page 65

• concrete related raw materials and chemicals (sand, cement, aggregate, admixtures)

• solvents

Measures will also be taken to minimize the exposure of storm water to construction-related chemicals and raw materials. Specific staging areas will be established for the storage of construction vehicles, construction materials, and any fuels or chemicals to be used during construction. To the greatest extent practicable, measures will be taken to limit the exposure of construction-related raw materials, fuels, and chemicals to precipitation. Covered storage areas and/or secondary containment will be provided where required. Implementation of structural and procedural control measures will ensure that potentially hazardous materials will have no significant impact during the construction of the project.

5.20.2 Operation phase impacts from hazardous substances

Flammable and hazardous materials will be used and stored on-site in support of the operation of the power plant. These will include Heavy Fuel Oil (HFO), Diesel Fuel Oil (DFO), lubricants and hydraulic oils, and chemicals associated with water and wastewater treatment operations. Structural and procedural safeguards will be implemented to ensure that these materials are stored and handled in a manner that will minimize the possibility of a release.

HFO will be transported to the site by rail (as is currently the practice) and transferred to the new HFO storage tank (2000 m\ This tank will have impervious secondary containment (a concrete bund), that would contain any leaks or releases from the tanks. The fuel tank containment areas will be equipped with pumps which route storm water to an oillwater separator prior to discharge.

The rail tanker unloading process will involve connection of flexible hoses, heating of the oil (using a non-contact HFO/steam heat exchanger), and pumping the oil by suction into the respective tanks. Fuel unloading will be supervised by facility personnel trained in spill response and supplies of spill containment and clean-up equipment will be readily available in the fuel unloading area.

DFO will be stored near the point-of-use at various locations on-site including at the auxiliary boiler and the emergency diesel generator. Diesel tanks (either separate or as integral components of equipment) will be stored within impervious secondary containment. DFO will be transported to the site by truck and unloading will be supervised by fully trained facility staff. Supplies of spill containment and clean-up equipment will be readily available in the vicinity of each of the DFO unloading areas.

3 Each steam turbine generator will be equipped with a large (approximately 50 m ) lube oil reservoir and other mechanical equipment (eg boiler feed pumps, fan mills, induced draft fans, crushers, conveyors, etc) will contain lesser quantities of lube oil and/or hydraulic oil. The large turbine generator oil reservoirs and much of the smaller oil-filled equipment will be located indoors. The turbine generator reservoir will be equipped with level gauges that will allow for regular monitoring of oil levels. Leak detection for smaller units will based on implementation of a program of regular facility inspections and associated preventative maintenance. PBPower Section 5 Page 66

The facility's electrical substation (which mayor may not be located on-site) will likely include transformers, capacitors, circuit breakers, and switches, each likely containing from 1 litre to several hundred litres of mineral oil dielectric fluid or other similar transformer oil. NEK will be responsible for the construction and operation of this substation and for the implementation of inspection and preventative maintenance programs to minimize the potential for releases from such equipment.

Various water and wastewater treatment chemicals will be used on-site. Table 5.20 presents a list of these chemicals and the anticipated quantities that will be used and stored. Large outdoor bulk storage tanks will be provided for sulphuric acid and sodium hypochlorite. Storage of other chemicals will mainly be in 55 gallon drums or other smaller storage tanks. Except for the large bulk storage tanks, all other water and wastewater treatment chemicals will be stored indoors. Outdoor chemical storage tanks will have secondary containment dikes and will be equipped with visual level gauges to allow for monitoring. Bulk chemical unloading and drum unloading will be fully monitored by trained facility personnel. Spill containment and clean-up equipment, specifically selected for the nature of the chemicals handled and stored, will be available in the vicinity of chemical unloading areas.

The structural measures presented above (secondary containment, level gauges, etc) and the implementation of procedural safeguards (supervision of loading/unloading, regular inspections and preventative maintenance, etc) will ensure that potentially hazardous materials will have no significant impact during the operation of the project.

TABLE 5.20 CHEMICALS TO BE USED AND STORED ON SITE

Chemical name Formula System used in Storage Storage tank location size 3 Ferric Chloride 40% FeCb Pre-treatment Indoor 30 m 3 Lime, hyd rated Ca(OHh Pre-treatment Indoor 150 m 3 Soda Ash Na2C03 Reverse Osmosis Outdoor 100 m 3 Sulphuric Acid, 98% H2SO4 Demineralizer Outdoor 5 m

Caustic Soda, 50% NaOH Demineralizer Indoor 10 m3

Sodium Hypochlorite, 10% NaOCI Service/Potable wtr. Outdoor 100litres 3 Ammonium Hydroxide, NH40H Cycle Chem Feed Indoor 1 m 28%

Scale inhibitor - Circulating water Indoor 30 m3 3 Trisodium Phosphate Na3P04.H20 Cycle Chem Feed Indoor 1 m 3 Sulphuric Acid, 96% H2SO4 Circulating Water Outdoor 12 m 3 Hydrazine N2H4 Cycle Chem Feed Indoor 1 m

Sodium Hypochlorite, 10% NaOCI Circulating Water Indoor 5 m3

Sodium Hypochlorite 10% Na(OClh Sanitary Wastewater Indoor 500litres ------

PB Power Section 5 Page 67

5.21 Occupational health and safety hazards

5.21.1 Construction phase impacts on occupational health

During construction, occupational health and safety hazards will be those typically associated with major construction works. There are no aspects of facility development that are outside the norm of what is typical for power plant construction. Those firms selected for the construction phase of the project will be properly qualified and experienced in the type of construction anticipated. Their worker health and safety programs will be reviewed prior to initiation of construction. Their staff will be trained in the measures to be included in the project's Environmental Management and Monitoring Plan which will include plans for compliance with Bulgarian and World Bank health and safety requirements.

5.21.2 Operation phase impacts on occupational health

Plant operations will be conducted in accordance with all Bulgarian regulations relating to worker health and safety. Applicable regulations include:

• Ordinance No 6 on general labour safety requirements and responsibilities (SG No 75/1996);

• Ordinance No 4 on labour safety and fire-protection marking and signals (SG No 77/1995);

• Secondary legislation that requires the establishment of industrial safety, labour hygiene and fire prevention (ISLHFP) instructions for each operational position;

• Ordinance No 3 on mandatory preliminary and regular medical examinations of all workers (SG No 16/1987 and as amended in 1991 and 1994); and

• Ordinance No 11 (SG No 34/1995) that requires employers to provide special work clothes and personal protection equipment.

Through routine maintenance it can be expected that the new facility will be a much safer facility than the current plant. Employees will be trained in the proper use of all equipment within their area of responsibility. This will include initial orientation training as well as regular refresher training. Health and safety statistics will be collected and maintained by the plant and included as part of the plants annual reporting requirements.

As with all AES plants, there will be an annual audit by an outside team. An important component of this audit will be worker health and safety and the plants achievement of its health and safety goals.

5.22 Impacts of anCillary facilities associated with the proposed project

The major ancillary facilities associated with the proposed project are the ashlgypsum disposal area, the lignite mining area, and the limestone quarry. The ash disposal area for the project will be lined to prevent any leaching to ground water. The landfill area will be operated in accordance with all Bulgarian and EU requirements. Approximately 7000 tonnes per day of combustion wastes (ash and PBPower Section 5 Page 68

gypsum) will be generated and transported to the off-site ash/gypsum disposal area. Transport of combustion waste to the off-site disposal area will be performed using 20 ten car trains per day. The transportation of combustion wastes will result in an increase in local rail traffic and the construction of the combustion waste disposal area will temporarily remove the land from other uses.

There will be indirect impacts on the regional topography related to the raw materials to be supplied to the facility. Approximately 9 million tonnes per year of lignite and 750 000 tonnes per year of limestone will be transported to the site from off-site lignite mines and limestone quarries, respectively. Transportation of the lignite from the mine to the power plant will involve 48 ten car trains each day, with a ten car train arriving at the site approximately once every 30 minutes. Transportation of the limestone from the off-site quarry to the power plant will involve 3 ten car trains each day. Excavation of the lignite and limestone will disturb the existing off-site land surface and the transport of the materials to the site will result in an increase in local rail traffic. Unloading of lignite and limestone at the site and subsequent handling (crushing, stacking, reclaiming, etc) will generate noise and dust. PBPower Section 6 Page 1 of 7

6. MITIGATION MEASURES

The Project Company is committed to minimizing environmental impacts of the project during construction and operation. The project is designed to achieve compliance with applicable regulatory limits as they relate to air emissions, water withdrawal and discharge, noise and solid waste management. This Section discusses project design-related mitigation measures as well as mitigation measures that the Project Company is committed to implementing as best management practices during construction and operation of the proposed project to ensure compliance with Bulgarian and European Union environmental regulations and World Bank guidelines.

6.1 Project design-related mitigation measures

The proposed AES-3C Maritza East power plant will be located on the existing Maritza East 1 plant site, north of the current power plant. It will take advantage of some of the existing facility's infrastructure including rail lines, cooling water and fire water intake structure and pumping facilities. As the redevelopment of a brownfield industrial site, there is less potential environmental impact than there would be in developing a comparable facility at a greenfield site. Specific project design mitigation measures are described below.

6.1.1 State-of-the-art pollution control technology

The proposed project will be more efficient and have lower emissions of SUlphur dioxide per MW of electricity generated than the existing Maritza East 1 facility. The facility will have a low NOx emissions, use an electrostatic precipitator to control the emissions of particular matter and a flue gas desulphurization system to control emissions of sulphur dioxide.

The existing Maritza East 1 plant discharges heated cooling water to Rozov Kladenetz Lake and stormwater and waste water to an existing ash pond. In contrast, the new facility will have zero discharge of waste water. Condenser cooling will be provided by a natural draft cooling tower fed in part by process waters. This recycling of water for the cooling tower will significantly reduce the amount of water withdrawn from the lake. In addition, cooling tower blowdown and other potential facility discharges (eg boiler blowdown, plant drains, and demineralisation system reject waters) will be used within the wet limestone flue gas desulphurization system.

6.1.2 Physical plant layout

The location of the cooling tower, in the north-west section of the site, is well removed from nearby residential areas that are south-east and south-west of the site and is beneficial from the standpoint of potential noise impacts. The location of the lignite and limestone unloading facilities is also such that off-site noise impacts are minimized.

A comprehensive list of features built into the design of the project that serve to minimize the potential for environmental impact are summarized below in Table 6.1.

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TABLE 6.1 PROJECT DESIGN FEATURES THAT MITIGATE POTENTIAL ENVIRONMENTAL IMPACTS

Feature Environmental influence

Low NOx burners • Reduces nitrous oxide (NO.) emissions, ensuring compliance with regulatory emission limits and ambient air quality standards.

Electrostatic precipitators • Reduces particular emissions by >99.5 per cent, ensuring compliance with regulatory emission limits.

Wet limestone flue gas • Reduces sulphur dioxide (S02) emissions by >95 per cent, desulphurization system ensuring compliance with regulatory emission limits.

Use of process water for cooling • Reduces cooling water withdrawals from the lake. and the FGD system

Zero discharge of process • Eliminates thermal and chemical impacts associated with waste water discharges to Rozov Kladenetz Lake.

Redevelopment of existing • Reduces construction of new infrastructure brownfield industrial site • Avoids conversion of land resources to industrial uses, as well as impacts on terrestrial ecology • Minimizes or eliminates visual impact of new facility. Enclosure of conveyors, • Reduce noise levels at off-site receptors. crushers, boilers, and air pollution control systems and provision of outlet silencers on induced draft fans

Placement of cooling tower at • Reduce noise levels at off-site receptors. the rear of the property

Secondary containment of fuel • Reduces the possibility of a release and the contamination oil storage areas of soil and/or ground water.

6.2 Mitigation measures during construction

The main environmental, social and economic impacts during the construction period are those typical or any large construction project. These include traffic congestion and delays due to the transportation of workers and materials, noise resulting from the operation of machinery, the temporary accumulation of soil and equipment, generation of dust from the movement of heavy vehicles, and localized noise and air pollution from the diesel exhausts of such equipment. These impacts will be temporary and are not expected to be significant due to the site location and favourable conditions of the existing infrastructure in the region.

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6.2.1 Storm water management and erosion control

Construction will be performed using methods that will minimize soil erosion, control sediment loads in storm water discharges, and reduce potential exposure of storm water to construction-related chemicals and raw materials. Grading and materials stockpiling will be performed using techniques designed to minimize the potential erosion of site topsoils. If appropriate and/or as needed, sediment control measures such as slit fencing, hay bales, and/or on-site sediment basins will be installed to reduce sediment in runoff. To the extent possible, construction-related raw materials, fuels, and/or chemicals will be stored in areas not exposed to precipitation or in areas equipped with secondary containment.

6.2.2 Excavated material

Since the project site is relatively flat, quantities of excess materials generated during construction should be limited. Excavated materials suitable for plant construction needs and excess materials will be redistributed on site as practical. Materials and/or debris not suitable for use in plant construction will be disposed of, with the approval of local authority, at an appropriate off-site location. Similarly, all construction debris that would result from removal of underground foundations, pipes and utilities will be disposed of off-site in an area designated by municipal authorities.

Given the historical industrial use of the project site, a series of soil samples from different areas of the site will be collected and analysed for potential contamination. Soil sampling will be performed both in areas where historic operations indicate a potential for contamination and in areas where considerable excavation is anticipated (eg the planned main power block area). Should areas of significant soil contamination be identified, their location will be noted, and during construction, soil excavated from these areas will be separately stockpiled, further tested and either redistributed on site or disposed on off-site (depending on testing results) in accordance with the requirements of the Galabovo municipality.

6.2.3 Liquid effluents

Liquid effluents associated with project construction will consist of sanitary waste water generated by on-site labour forces and discharges of ground water associated with construction dewatering activities.

Temporary sanitary facilities will be provided for the construction workforce. Construction-phase sanitary waste water will be collected in on-site holding tanks and will be transported off-site for appropriate treatment and disposal.

Prior to the initiation of construction, several (at least two) ground water wells will be installed on-site, both to identify the local ground water table elevation and to allow for testing of ground water quality. Water samples from each of the wells will be tested for potential contamination. If contamination is detected, ground water dewatering discharges (during construction) will be subject to further testing and treatment (if required), prior to discharge to the local storm drainage system. Dewatering discharges will be handled using sediment and erosion controls measures similar to those used for storm water discharges.

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6.2.4 Air emissions control

Air emissions resulting from construction activities will be of a temporary and intermittent nature. Air pollutant emissions will primarily consist of fugitive particulates that result from earthwork and vehicle traffic, wind erosion of exposed soil surfaces, emissions from the operation of vehicles and heavy equipment, other internal combustion engine-powered equipment, and volatiles from paint solvents, cleaning solvents and asphalt paving operations.

EmiSSions produced by construction activities on the project site will be controlled by a variety of means. Exposed earth surfaces will be watered (as necessary) to control fugitive dust from vehicle and equipment traffic. To limit construction-related generation of diesel exhaust emissions, construction equipment will be maintained in proper running order. Paints and solvents will be stored, handled and used or applied in compliance with applicable requirements and best management practices to minimize the incidental loss of volatile components.

6.2.5 Noise

Construction of the project will generate noise. Earth moving equipment will be the source of the loudest and potentially most disturbing noise. Although temporary, such noise has the potential to adversely impact both construction personnel and off-site receptors. On-site personnel will be equipped with appropriate hearing protection to limit exposure and to comply with worker health and safety requirements.

The noisiest phase of construction is at the beginning and will last for only a few months. Existing structures of the existing Maritza East 1 facility will tend to shield residences from construction noise from the area of the new power plant. Noise generated in other areas of the site, such as from movement of equipment to and from stockpiles and laydown areas, will be unavoidable. Construction work is not expected to routinely occur during night-time hours.

6.2.6 Chemical/fuel storage

Specific construction staging areas will be established for the storage of construction vehicles, construction materials, and any fuels or chemicals to be used during construction. To the extent practicable, measures will be taken to limit the exposure of construction related raw materials, fuels, and chemicals to precipitation. Covered storage areas and/or secondary containment will be provided where appropriate and practicable.

6.2.7 Accidental releases

Project construction will involve the on-site use of diesel fuels, hydraulic oils, and other chemicals. Accidental releases of oil and/or chemicals could potentially contaminate local soils, ground water or adjacent surface waters.

During construction, oil will be handled and stored in a manner designed to prevent leaks and spills. Vehicle refuelling, when performed on site, will be in dyked areas designed to contain spills associated with fuelling operations. Temporary oil and chemical storage areas will be equipped with secondary containment capable of holding the contents of the oil/and or chemical storage tanks or

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drums. Supplies of sorbent material (eg speedy-dry, sorbent pads, sorbent booms, etc) will be maintained at strategic locations on site to allow for a rapid response to spills.

6.2.8 Solid wastes

Construction wastes will consist primarily of empty containers, packaging materials, and scrap metals. These wastes will be collected and either recycled or disposed of off-site in compliance with direction from Galabovo municipality. The project-related construction waste will not be co-mingled with wastes from previous demolition activities or with municipal solid waste.

6.3 Mitigation measures during power plant operation

The power plant has been designed to meet Bulgarian, European Union and World Bank guidelines. Table 6.1 listed the many design features that will minimize the project's impacts to the environment. Additional measures that are anticipated as part of plant operation are summarized below.

6.3.1 Storm water management

The proposed AES-3C Maritza East 1 power plant will have three distinct areas with respect to storm water runoff: the lignite pile area, several outdoor oil handling and storage areas, and the remaining main power block area. Stormwater runoff from the lignite pile and lignite train unloading area will be routed to a newly constructed lignite pile runoff pond. This pond will be sized to store runoff from precipitation events of to and including the 10 year 24 hour storm event (estimated at approximately 122 mm of rainfall). Water collected in the pond will be treated (eg pH neutralization, if required) and routed to the raw water treatment plant.

Storm water from the bermed HFO oil storage tank areas, from the HFO unloading area, from any outdoor DFO storage handling areas, and from the planned electrical substation area could potentially contain oil and will, therefore, be routed to one or more oillwater separator units. Clarified effluent from the oil water separators will be routed to the raw water treatment plant.

Storm drainage for the new main power block area will be routed to a small runoff pond, sized to store runoff from the 1 year 24 hour storm event (estimated at approximately 50 mm of rainfall). This smaller pond will be sized to capture and allow settling of "first flush" suspended solids typically runoff from the first 30 minutes of the rainfall event).

Occasional storm water overflows from the smaller power block storm water pond and less frequent overflows from the larger lignite pile runoff pond are expected to be generally free of suspended sediment. These overflows will be routed to the Sazlijka River and will be discharged at a point prior to the Sazlijka River's confluence with the Sokalitsa River.

6.3.2 Solid and liquid waste management

Solid and liquid wastes generated during the operations phase for which the project company is responsible for disposal will include domestic office wastes (paper, packaging materials, general refuse), non-toxic industrial solid wastes (disposable filters, rags, spent desiccant material, machine shop wastes, empty drums and containers) and waterlwaste water treatment residuals.

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Water treatment process residuals, consisting primarily of a calcium carbonate and aluminium hydroxide sludge, will be discharged to the FGD plant for reuse. Sanitary waste water treatment plant sludge will be tested and, if acceptable, used as fertilizer or for land reclamation. If necessary, and if approved by the municipality, this sludge will be dewatered and disposed of in the municipal solid waste landfill.

Operation of the power plant will generate other non-hazardous wastes, in addition to those previously discussed. These will include domestic office wastes (paper, packaging materials, general refuse) and non-toxic industrial solid wastes (disposable filters, rags, spent desiccant material, machine shop wastes, empty drums and containers). These miscellaneous non-hazardous solid wastes will be collected and, with local approval, disposed of at the Galabovo municipal solid waste landfill.

Ash and gypsum will be disposed of in a landfill (former mine overburden area) that will be designed and managed according to Bulgarian, EU and World Bank standards.

6.3.3 Spill prevention

The following general rules for prevention of spills, and protection of the environment in the event that there is a spill, will be incorporated during facility construction and operation.

• Spills will be contained and cleaned up at once. Any polluted material will be safely stored before being transported to its place of disposal. Such material will be disposed of in a proper manner, depending on its nature.

• Areas identified as potentially affected by previous site activities will be inventoried before beginning construction. Contaminated soils, if found, will be stockpiled to avoid reintroduction to the environment.

• Staff will follow safe construction practices, and will be trained in the operation and maintenance ofthe construction equipment in order to prevent spills or overflowing fuel, oil and lubricants.

• Staff will also be familiar with all pollution control laws pertaining to their work.

• Fuel tanks, valves, pipes and hoses will be examined regularly to verify that they are in good general condition. This test will detect any kind of damaged that could lead to an overflow, leak, and the accumulation of fluids. Faulty equipment will be repaired and/or replaced.

• Vehicles working on site will carry a sufficient amount of absorbent material to be used in case of a spill or overflow. Staff will be trained in the proper use of these materials.

6.3.4 Accidental spills

The project will also include the handling and storage of non-fuel oil (ie lube oil, hydraulic oil, etc) and chemicals. Oil and chemicals will be handled and stored in a manner designed to prevent leaks and

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spills. Some water treatment chemicals will be stored in 55 gallon drums. Certain chemicals may also be stored in bulk storage tanks. Most drum storage areas will be located indoors. Any outdoor drum storage area will have a secondary containment berm or dyke. Outdoor bulk storage tanks will similarly be surrounded by a secondary containment bund.

Oil storage tanks will be located in bunded areas sized, at a minimum, to provide impervious secondary containment for the contents of the largest tank stored, Similar containment will be provided for any new diesel fuel oil storage tanks. Storage tanks will be equipped with level detectors and level alarms capable of alerting plant personnel of potential leaks and/or accidental overfills. All underground tanks and pipelines will be protected from corrosion and will be provided with leak and overfill detection systems/alarms. Drains from tank storage bunds will be equipped with a normally closed shut-off valve, ensuring that leaks and/or spills will be contained. Drainage from such areas will be routed to an oillwater separator.

Supplies of sorbent materials (ie speedy-dry, sorbent pads, sorbent booms, etc) will be maintained at strategic locations on site to allow for a rapid response to spills.

6.3.5 Lighting

Several studies have been conducted to evaluate the efficacy of alternate lighting schemes to reduce the number of bird casualties associated with man-made structures. Potentially successful lighting schemes include use of minimum intenSity intermittent illumination, or use of obstruction lighting along (eg without floodlights). General outdoor security lighting, such as the lights at gates or around fence lines, can have an adverse effect on birds and attract them during inclement weather.

No site-specific information is available to assess the impact of the existing Maritza East 1 power plant buildings on migratory birds. Given the plant's river location it is likely that migratory birds may periodically have some contact with the facility. In the event that it becomes necessary, the project company will explore alternative lighting strategies that would help minimize any avian mortality from interactions with its various new structures.

6.3.6 Dust control

The AES-3C Maritza East 1 power plant, as proposed is fully in compliance with all applicable air emission and ambient air quality guidelines. The studies conducted for this project indicate that the many non-point sources in the area, most notably the existing ash pond and the large number of transport trucks that pass through town and in front of the plant site, are likely the principal reason for the elevated particulate levels. Unlike the existing facility, the new power plant will not have an ash pond. All ash and gypsum will be disposed of in a new, off-site landfill. The potential for dust emissions from this facility will be minimized due to the moisture content of the waste produced and the solidification that occurs as gypsum becomes dewatered. Ash will be kept in moist conditions and thus there is no chance of dust formation from this source.

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7. AL TERNA TIVES

The project as proposed is the development of a 670 MW lignite-fired power plant. Both the site and fuel were dictated by the Bulgarian Government and its strategy to replace aging generation capacity. The larger Maritza energy-producing region was targeted in the 1998 National Energy Strategy report as a priority in the country's efforts to improve air quality and improve the efficiency of energy production. The 2002 Energy Strategy identifies lignite fired power plants and nuclear power as twin pilots of Bulgaria's Energy Strategy. Alternatives to the project plans, therefore, centre on the choice of technology and means of exhausting waste gases. Water supply and discharge alternatives were considered, but not evaluated in detail, because they are either not feasible or not significantly different in terms of environmental impact.

The following discussion focuses on the technology and exhaust alternatives that are relevant to the project. This discussion reflects design issues that were addressed as part of the development of the project specifications that were used for the bidding and selection of an EPC contractor.

7.1 Alternative technologies

Large power plants designed to provide electricity on a continuous basis can be designed using a renewable resource, such as water, or a non-renewable resource such as coal, gas or nuclear energy. Wind energy, which applicable on a small scale, is not typically considered appropriate for base load operation. Given both the absence of a significant surface water resource in the site area and the desire to replace the existing Maritza East 1 power generation capacity, hydro technology was not appropriate. The two local rivers and Rozov Kladenetz Lake, which is an impoundment of these rivers, would not be considered adequately large water sources and do not have the appropriate hydrologic and hydraulic characteristics. The absence of substantial surface water resources, along with safety and political considerations, likewise precluded consideration of nuclear power as a replacement technology.

In terms of fuel alternatives, gas and oil are not readily available in the area and any choice of fuel not involving lignite would have had a significant adverse employment effect on the nearby mines that are dedicated to the three Maritza East thermal power facilities.

The remaining feasible candidate technologies for the scale of plant needed to meet the projected electrical demand were the following:

• circulating fluidised bed coal (CFB)

• pulverized coal (PC).

These two technologies are described below and are compared in terms of differences that are significant from an environmental standpoint. Integrated coal gasification combined cycle (IGCC) technology and pressurized f1uidised bed combustion (PFBC) technology were not considered because they are still uproven technologies that are in the process of development. The World Bank recognizes pulverized coal and fluidised bed as conventional technologies that will continue to be used in the near future. The selection of one technology is governed by a combination of demonstrated performance, economics and environmental factors.

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PC boilers are a well-established and demonstrated coal-burning technology. PC units range in size from less than 100 MW to very large utility boilers of 1000 MW or more. PC technology is the most widely used coal combustion technology worldwide for boiler sizes up to 1000 MW. Fly ash emissions from these units are controlled using an electrostatic precipitator (ESP) or baghouse with additional post-combustion treatment such as flue gas desulphurisation (FGD) systems to control S02 emissions. In addition, PC units require more space (for add on controls such as the FGD system) than comparable CFB units.

The CFB boiler is a combustion technology designed to reduce emissions by altering the basic combustion process instead of relying on add-on controls. CFB combustion reduces emissions by controlling combustion parameters and injecting a sorbent (such as crushed limestone) into the combustion chamber along with the fuel. The solid particles of fuel, inert materials (ash) and limestone are suspended (fluidised) by, and burned in an air stream that creates a highly agitated mass.

Utility-type CFB boilers in the 100 to 180 MW range are not uncommon and have a proven operating record. Utility CFB units in the 250 MW range have been designed and are under construction. Larger facilities such as 2 x 230 MW units firing brown coal in Poland and 2 x 250 MW units firing soft, low sulphur coal in Puerto Rico are under contract. Larger units are commercially available but are not widely used due to site specific conditions that make then uneconomic or less preferred from an environmental standpoint.

For the proposed project, the size of the project site was not a limiting factor so the additional space required for the PC system add-on controls did not preclude consideration of this technology. Those factors that did dictate the technology choice, as summarized below, were the system ability to achieve the necessary emission rates, the amount of solid waste generated and the performance record of the technology for a plant of the size proposed.

7.1.1 Record of performance

As noted, the PC boiler is widely used and effective at a range of sizes. The proposed 2 x 335 MW system is well within the range of what has been developed and qualifies as a proven technology. The CFB system, however, is proven only at smaller sizes than that required by the proposed plant.

A 2 x 335 MW CFB plant could only be built using prototype equipment. The limited experience in handling and feeding of the expected clayey, very low-grade lignite to the CFB boilers suggests that there could also be problems in meeting the plant availability requirements.

7.1.2 Limestone requirements for S02 control

Both systems rely on the use of limestone to achieve control of S02 emissions. Preliminary small scale tests indicate that a CFB system could require from three to five times more limestone than the FGD system for the PC units. While the dry waste from the CFB system might have more favourable handling and disposal characteristics, the substantially larger quantity makes it a relatively unfavourable option with regard to limestone consumption and waste disposal costs when compared to a similar sized PC system.

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7.1.3 Emission rate limitations

In addition to needing large quantities of limestone for so control, the chemistry in a CFB system is such that beyond a certain input level the sorbent is rendered ineffective. It is questionable whether the CFB boiler could achieve the necessary emission limitation for a 670 MW plant. A PC system, with add-on controls, can consistently and reliably achieve the desired emission levels and vendors are willing to offer the requisite guarantees.

Based on the combined performance record, emission control reliability, cost and solid waste implications, the preferred is a PC system with add-on controls. Analysis of design alternatives

7.1.4 Alternative stack design

The basic power plant design evaluated in Section 5 involves the release of treated combustion gases through a natural draft cooling tower with the cooling of water used for electrical generation achieved using the same cooling tower. An alternative design that may be used involves a separate stack consisting either of a single or multiple flues protected by a concrete wind shield and a natural draft cooling tower. This configuration is the stack design used by all three existing Maritza Power Plants The technique involves using the heat of the gases emitted from the boilers to draw the flue gases out through the stack. Stacks of this nature vary greatly in height depending on a number of factors such as flue gas volumes, velocities as well as specific pollutant emissions levels. To help with the dispersion of the large quantities of Sulphur Dioxide resulting from the high Sulphur content of the lignite mined locally the existing stack at the original Maritza East 1 is 245 m, with the stack for Maritza East 3 being 325 m.

The alternative design has potential advantages and disadvantages. Advantages of this design include:

• the method is well established unlike the cooling tower approach that has only been used on plant since the mid 1980's.

Disadvantages of the alternative design include:

• the use of a stack increases the visual impact ofthe project on the surrounding landscape (the likely height for a stack for the project would be of the order of 250 m

• use of a separate stack would increase the cost of the project.

• should the project have used a standalone stack there would have been additional plume visibility that would otherwise have been incorporated within the cooling tower plume.

7.1.5 Environmental considerations of the alternative design

The primary difference between the tall stack and hyperbolic tower design in terms of potential environmental impact is how the stack effluent disperses in the atmosphere. For the conventional stack design, because of the large vertical separation, there is virtually no interaction of the flue-gas

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plume from the stack with the vapour emissions from the cooling tower. For the natural draft, hyperbolic tower configuration, both the cooling tower vapour and flue gases are emitted in a single plume. Plume rise and dispersion from isolated tall stacks can be simulated with standard dispersion modelling techniques, such as the US EPA's AERMOD that was used for the dispersion analyses described in Section 5. Simulation of the plume rise and dispersion of emissions from a combined hyperbolic cooling tower is more complex for a variety of factors, including:

• release parameters (effective release temperature, velocity and humidity) are not constant but depend on environmental factors, such as ambient temperature, dew point and wind speed, that vary continuously

• the rate and degree of plume rise are affected by initial warming caused by the condensation of water vapour into water droplets and the eventual cooling of the plume as the droplets evaporate further downwind

• the aerodynamic effects of the large cooling tower structure on near-field dispersion

• the initially large lateral dimensions of the plume.

All air dispersion models currently accepted by the US EPA, Bulgarian Authorities and the World Bank are designed to most effectively model emissions from standalone stacks such as those found at Maritza East 2 and 3. It is however, as described in Section 5 necessary to make alterations to allow for the factors listed above that make the emission of flue gas through the cooling tower differ to those through a conventional stack. These alterations allow for a reasonable estimation of the likely ground level concentrations but do not allow for an easy comparison between conventional stack and cooling towers. It is generally observed in scientific studies that have been made of the subject that emissions are lower for cooling towers than for conventional stack.

7.2 Other alternatives considered

Development at the proposed site with a ready source of water and existing infrastructure were significant considerations in the choice of water supply. A summary of the review of alternative water sources is provided below along with a summary of the reasons for the water discharge decision.

• Surface water withdrawal. Cooling and process water needs will be met through withdrawal from the nearby Rozov Kladenetz Lake. This reservoir was constructed at the time of the original development of the Maritza East 1 power plant in the early 1960s. Based on the condition of existing equipment and/or cost efficiency, it is possible that components of the existing intake structure and pumping system for the cooling water/fire water intake (eg travelling screens, pumps, motors, piping) will be replaced. Such modifications would not be expected to affect overall impacts associated with water withdrawals. There are currently no plans to construct a new intake structure at the Rozov Kladenetz Lake and/or the Sazlijka River.

• As an alternative, as is the case at the existing Maritza East 1 power plant, boiler make-up water for the AES-3C Maritza East 1 power plant could be withdrawn

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from the Sazlijka River rather than from the lake. This withdrawal would likely be implemented by installing a new connection and pump at the existing Sazlijka River pump station. Withdrawal of water from the river rather than the lake would have a negligible impact on the overall regional water balance, since the river is currently a major source of water supply to the lake. Water treatment for river water could vary somewhat from that required for lake water, but not significantly.

• Groundwater supply. Water for plant cooling and process needs will come from Rozov Kladenetz Lake (with the possibility of boiler make-up water being withdrawn from the Sazlijka River). Although the quantity otwater to be withdrawn for the proposed project (approximately 1222 cubic meters per hour) is less than current power plant water supply withdrawals, this quantity is much greater than that would could reasonably be supported by groundwater withdrawals in the region. Since surface water resources and existing infrastructure are available and sufficient for plant needs, use of ground water supplies was not evaluated in detail.

• Water discharge. Consistent with the overall project objective of minimizing environmental impacts, the facility has been designed to have an effective zero discharge of process waste water. Current plant once-through cooling operations 3 generate as much as 33000 m /h of heated cooling water discharge to Rozov 3 Kladenetz Lake. Also, as much as 100 m /h of facility process waste water (boiler blowdown, water treatment reject waters, plant drains and sanitary waste water) are currently discharged to the facility's ash pond. As a zero discharge plant, the proposed facility will not discharge to either the existing ash pond or to the lake. Therefore, the proposed plant will not contribute to any temperature increases via thermal discharge to the lake. In addition, there will not be an ash pond associated with the proposed facility.

7.3 No action

Without refurbishments and/or new generating capacity (such as the proposed project) in the Maritza region, air quality would remain above the Bulgarian and EU standards set for human health. The existing Maritza East 1 plant equipment is well past its useful life and to conform with the EU Large Combustion Plant Directive will either have to fit FGD or limit the number of running hours to 20 000 after January 2008. Based on operation for 20000 hours decommissioning is expected to occur by about 2011 regardless of whether the AES-3C Maritza East 1 power plant is approved. If the AES-3C Maritza East 1 power plant project is not implemented, there will be reduction in the market for locally produced lignite. This could have an effect on the existing mines. The overall result could be a major decline in regional employment as both plant and mine positions are closed. While the regional economic development agency has an aggressive plan to bring new industry to the area, without such initiatives as the AES-3C Maritza East 1 power plant project, success of regional development is unlikely.

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8. ENVIRONMENTAL MANAGEMENT AND MONITORING

The project company is committed to responsible environmental management and monitoring in accordance with applicable regulations. This section provides the outline of the management structure that will be use during construction and operation and summarizes the currently anticipated monitoring and reporting requirements. It is expected that both of these will be expanded upon and formalized later in the project's Environmental Management and Monitoring Plan (EMMP).

8.1 Environmental management

During the construction phase of the project, AES/3-C will establish a three level organizational structure to manage environmental and safety issues. The construction phase of the project is defined as actual construction activities, start-up and commissioning activities, and any other relate activities that occur before the project is certified as operational. This organization will be modified and supplemented as the project moves towards operation, such that at project start-up, a new operational phase organization will be in place.

The Construction Manager, as the first level of organizational structure, will assume primary responsibility as the "Environmental Director" for the construction phase programme. Senior staff, such as the activity based Construction Management Team members, will make up the second level of the organizational structure and will be responsible for ensuring that environmental, health and safety plans and programmes are properly implemented. Construction Management Team members will also monitor contractor's compliance with environmental mitigation measures and contingency plans. The construction contractors, both prime and subcontractors, (ie EPC contractor, construction supervisors, construction works, shift technicians, maintenance technicians etc) will make up the third level of the organizational structure and will be responsible for effectively implementing the directives of the EMMP.

The Plant Manager, as the first level of the organizational structure, will assume primary responsibility as the "Environmental Director" for the operational phase of the programme. It is often the case on AES projects that the Plant Manager will have previously served as the Construction Manager and so will already have a good understanding of the project. During operation, function based Areas Superintendents will make up the second level of the organizational structure and will be responsible for ensuring that environmental, health and safety plans and programmes are properly implemented. The plant operation and maintenance personnel will make up the third level of the organizational structure and will be responsible for effectively implementing the directives of the EMMP.

To ensure co-ordination among the groups to have the responsibility for various project related activities, it is expected that this will most effectively be accomplished through the formation of the Maritza East 1 Environmental Co-ordination Committee (MEECC). This group will report to the Inter-Ministerial Group (IMG) (or its equivalent successor govemment body should it be disbanded) that his been formed to facilitate development of this project. The IMG includes representatives from the Ministry of Environment and Water (MEW) and other ministries responsible for environmental stewardship. The relationship of the project to the local MEECC and the IMG is central to achieving the environmental stewardship that AES/3-C expect from the EPC contractor and all third parties participating in this project.

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The AES/3-C Environmental Director (Construction Manager or Plant Manager) will represent the project on the MEECC. In addition to monitoring and reporting on AES/3-C activities, the Environmental Director will also be responsible for monitoring the environmental compliance of the related third parties. Should deficiencies be identified, the Environmental Director will work through the MEECC or the IMG to ensure that compliance is realized in a timely manner.

8.2 Environmental monitoring

Preliminary monitoring plans have been developed for the construction and operation phases of the proposed power plant. An environmental sampling programme has been designed to assess any background contamination at the site. The plans have been designed and will be implemented to collect data on project related releases of pollutants of concern and on ambient environmental conditions, to ascertain the impact of these potential releases. The main elements of the monitoring plans are identification of the parameters of concern, specification of the methods of collecting and handling of samples (including the location, frequency, type and quantity of samples, and sampling equipment), sample analysis, and a format for reporting the results.

Some limited pre-construction site investigations and monitoring are anticipated to address those areas where existing data is insufficient to completely characterize current conditions. A programme of soil and ground water testing and analysis has been initiated to more fully evaluate areas that will be affected by the construction of the power plant. Depending on location, soil and ground water samples will be tested for PCBs, metals, semi-volatile organic compounds, volatile organic compounds, total petroleum hydrocarbons, and pH. Off-site monitoring of ambient air quality will be initiated prior to operation so that a complete comparison to applicable standards can be made and source contributions fully identified. The programme will include monitoring of meteorological parameters (wind speed, wind direction, precipitation, etc) and ambient air quality in terms of concentrations of SUlphur dioxide, nitrogen dioxide, PM10 and carbon monoxide.

Power plant air emissions, water effluents, noise and solid waste management practices will be monitored to assure compliance with regulations and to minimize impacts of the facility on the environment. Table 8.1 presents plans for construction phase monitoring, record keeping, and reporting. A summary of the proposed monitoring plan during operation of the proposed power plant for air emissions, liquid effluents, solid wastes and noise emissions is presented in Table 8.2. These will be updated and revised to reflect the final site design. A programme for monitoring of the soil and air and water discharges for radioactivity will be developed per the requirements of the MEW.

8.3 Employee training

Employee training will be an important component of project development. The project anticipates training relative to all aspects of Bulgarian regulations (environmental as well as occupational health and safety) with which many employees may already be familiar. Just as important it anticipates training relative to its own health and safety standards as well as those of the EU and World Bank. AES corporate goals on health and safety and environmental improvement will be part of the orientation programme conducted for all people employed at the facility, both during plant construction

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and operation. AES operates an intensive global safety monitoring programme with "task forces· carrying out routine safety audits that will include the Maritza East 1 facility when it is operational. Under the direction of the Maritza East 1 Construction Manager (during construction) or Plant Manager (during operation), employee training programmes will be developed that are specifically designed to address the health and safety and environmental issues that will be faced by the employees working on site.

All employees scheduled to work on site during construction will be briefed on the contents of the more detailed Environmental Management and Monitoring Plan (EMMP) that will be developed for the project. The project site is immediately adjacent to the area that is important for migratory bids and local NGOs have expressed concern about the hunting of protected bird species. The EMMP, therefore, will include training to ensure that any workers from outside the area are fully informed about hunting restrictions and in particular about the protected status of species known to frequent the lake. On an as needed basis, as determined by the Construction Manager and Construction Management Team members, additional training will be provide to specific groups of employees with regard to activity specific health and/or environmental issues and with regard to the specific requirements of the various construction phase monitoring programmes. As construction progresses, additional health and safety or environmental management training may be required to address specific issues that arise.

During operation, all new employees, as a condition of employment, will receive training in health and safety and environmental management prior to beginning work at the facility. Depending on their respective duties, certain personnel will receive additional training related to materials handling, environmental monitoring, environmental compliance auditing, environmental compliance document preparation, emergency response, and other function specific topics. Refresher training will be provide to employees on an annual basis.

Prior to the start of construction a project Environmental Management and Monitoring Plan (EMMP) will be developed. This document will provide an overview of the planned construction and identify the parties responsible for site environmental management. Standards that must be followed to ensure regulatory compliance will be detailed along with procedures to follow in the event of a spill or accidental release. In addition, the EMMP will identify any required monitoring and reporting and the procedures to be followed. As the project nears operation, this will be revised to include reporting and procedures applicable to that phase of operation. The EMMP will include a plan to report environmental improvements over the project life. This information will be provide to lenders and other interested parties.

Document No. 62160AlPBP/OOOOO1 0774R080.00ClS113NV TABLE 8.1 di CONSTRUCTION PHASE MONITORING PROGRAMME -a ~ Activity to be monitored Parameters to be monitored Monitoring frequency Record keeping and reporting

Air quality No formal monitoring. AES/3-C to periodically observe On-going throughout the No formal record keeping or outside reporting. Identified (related to dust and emissions EPC's implementation of mitigation measures (eg vehicle construction of the project issues to be addressed and resolved during construction from construction equipment) maintenance, site watering for dust control, etc) and their progress meetings effectiveness in limiting off-site impacts ! ! Water quality AES/3-C to monitor EPC's implementation of mitigation Structural inspections once per Records of structural inspections and observations of the (related to the management of measures, including visual inspection of storm water week. Runoff examination as structural components of storm water quality will be storm water discharges) sediment and erosion control structures. The EPC will appropriate, based on rainfall maintained in log books by the EPC. Records of observed conduct periodic visual examination of storm water runoff frequency/intensity deficiencies to be recorded on a deficiency form and quality (colour, odour, clarity, floating solids, settled forward to AES/3-C. Records to be maintained for the solids, suspended solids, foam, oil sheen) duration of the construction project.

Water quality Monitoring of structural components and discharge quality Structural inspections once per Record keeping similar to storm water related record (related to the management of identical to storm water monitoring. If ground water week. Dewatering visual keeping ground water dewatering contamination is suspected (based on pre-construction examinations once each day. discharges) ground water quality analysis and/or visual observations Formal sampling and analysis, if during construction), chemical analysis will be conducted required, to be performed as for suspended pollutant parameters. If required, AES/3-C necessary, based on evaluation and the EPC will identify and implement appropriated by AES/3-C and the EPC treatment systems for dewatering discharges

Non-hazardous wastes The EPC to monitor waste management practices via Inspections performed and logs Daily log books to be maintained on site and made (construction debris, packaging visual inspections on an on-going basis. If >100 kg/day of maintained daily available to the Municipality, RIEW, and MEW, upon materials, refuse, etc) non-hazardous waste is generated, RIEW certified daily request. If >100 kg/day of waste is generated, the EPC log books will be kept per Bulgarian Law for the will develop annual reports summarizing waste activities Reduction of Harmful Impact of Waste upon the for submittal to RIEW. Reports will be prepared in Environment (S.G. 86/1997 and S>G. 56/1999). Waste to accordance with Bulgarian Ordinance No 10 on the Filling be disposed, with local approval, in the Municipality's out of the Report and the Waste Management Information landfill or in alternate location as directed by the Documents, dated 6.11.1998. Municipality

Hazardous wastes EPC to monitor waste management practices via visual Inspections performed and logs Daily log books to be maintained on site and will be made (significant quantities not inspections on an on-going basis. EPC to keep RIEW maintained daily. Hazardous available to the Municipality, RIEW, and MEW, upon anticipated; could include minor certified daily log books per Bulgarian Law for the waste manifests to be completed request. The EPC will develop annual reports quantities of spent lubrication oil, Reduction of Harmful Impact of Waste upon the by EPC to coincide with off-site summarizing waste activities for submittal to RIEW. chemical solutions, grease Environment. Any hazardous wastes generated will be shipping of hazardous wastes Reports will be prepared in accordance with Bulgarian soaked material, cleaning temporarily stored on site and transported to a licensed Ordinance No 10. Manifests associated with shipping of I facility for appropriate off-site treatment and disposal. hazardous wastes will also be completed by the EPC ~ solutions, and used batteries) !;l", EPC will be responsible for completing manifests contractor, in accordance with Ordinance No 10 .... '" associated with off-site shipment of hazardous waste (f) -0 CD III a ~! (C 0 8-'" CD :::J ~~ .J:>.OO ~~,L Activity to be monitored Parameters to be monitored Monitoring frequency Record keeping and reporting til Endanger waterfowl AES/3-C will conduct mid-winter waterfowl surveys on Avian surveys will be performed The surveys, each 2 to 3 days in duration, will record the dJ Rozov Kladenetz Lake, and maintain records at Rozov Kladenetz Lake three numbers of endangered waterfowl using the lake during (including pygmy cormorants ~ and Dalmatian Pelicans using documenting the occurrence and abundance of times each winter during the first the am and pm hours. The results of the surveys will be ., Rozov Kladenetz Lake) threatened and endangered species two winters of project activity summarized in reports that will be available to the RIEW and interested NGOs

Avian collision with stack AES/3-C will monitor for bid impacts during spring and Inspections performed and logs A detailed log book will be maintained for avian records. (monitoring required only if autumn migration. Monitoring will be accomplished by maintained daily during peak The results of the surveys will be summarized in annual pre-construction data indicate searing the top of the stack, all catwalks, and the ground autumn and spring migration reports available to the RIEW and interested NGOs , I avian mid-air collisions with around the base of the stack out to a distance of 30 m from the base. Dead or injured birds will be collected, existing plant stacks during I spring or autumn migration) identified, and the numbers and locations recorded. Descriptions of the meteorological conditions on the previous day/night will also be recorded. I Soils Soil excavated from areas with suspected contamination Screening level evaluation of The EPC will maintain records of required soil evaluations. (monitoring required only if (if any) will be separately stockpiled and screening level soils suspected to be Results of any formal soil analyses performed as a result pre-construction sampling contamination evaluations (visual, odour, etc) will be contaminated (based on findings of screening level findings will be maintained both by the indicates potential contamination performed by the EPC. If the EPC observations indicate of pre-construction sampling) will PC and AES/3-C. All records will be made available to the in areas to be disturbed during potential contamination, AES/3-C will be notified and, if be performed as the excavated municipality, RIEW, and/or MEW, upon request construction) deemed necessary, further sampling and analysis for materials are stockpiled, as pollutant parameters will be performed. Soil will either be often as once each day redistributed on site or disposed of off-site (depending on testing results), in accordance with the requirements of the Municipality. Notes: EPC = EPC Contractor AES/3-C = AES/3-C Construction Project Manager RIEW = Regional Inspectorate for Environment and Waters (Stara Zagora) MEW = Bulgarian Ministry of Environment and Waters Municipality = Municipality of Galabovo

~ :a~ ;,: ~9 ~~ (J) ggj !=>~ ;;?g 8", (C 0 ()"O CD ::J cn~ CJ'1(x) I£~ ~§ TABLE 8.2 ~ OPERATIONS PHASE MONITORING PROGRAMME ~ ~ Activity to be monitored Parameters to be monitored Monitoring frequency Record keeping and reporting ...

Air quality In accordance with Bulgarian Ordinance No 6 of Continuous AES/3-C to prepare monthly and annual reports of 23.3.1998 and Ordinance No 15 of 29.7.1999. Continuous emissions data. for submittal to RIEW. as required by Emissions Monitoring Systems (CEMS; one per flue) will Bulgarian Ordinance No 6 of 23.3.1998 be installed to monitor stack concentrations of S02. NOx• carbon monoxide. and particulates. Additional non-pollutant related parameters that will be monitored on a continual basis include flue gas temperature. pressure. volume flow. oxygen content. and water vapour content

Water quality Since the facility will be a zero discharge facility as related Internal monitoring will be AES/3-C will keep records of internal system water quality. to waste water. liquid effluent monitoring will not be performed on a daily basis Since the facility will be zero discharge. no formal reporting required. Internal monitoring will be performed to confirm to outside agencies will be required the operational efficiency of water pre-treatment systems. sanitary waste water treatment systems. demineralization treatment systems. the neutralization system. oil/water separator systems. and lignite pile run-off treatment systems

Noise A noise survey to define ambient levels in the vicinity of A noise survey will be conducted A report will be developed detailing the results of the noise the nearest receptors has been conducted as part of the three months after the plant survey. This report will remain on site and will. upon EIA. After the plant has been operational for three becomes fully operational request. be made available for review by the Bulgarian months. a second survey will be conducted to define the Ministry of Health Care. levels at the property boundary with the plant running at full load. At the same time. the noise levels at the major point sources will be measured. Results of these surveys will be compared with applicable Bulgarian workplace noise standards (Bulgarian State Standard 14478-82) and Bulgarian (Hygienic Norms No 0-64) and World Bank residential area noise standards. to demonstrate compliance

Non-hazardous wastes RIEW certified daily log books will be kept per Bulgarian Logs maintained daily Daily log books to be maintained on site and will be made domestic and office wastes. Law for the Reduction of Harmful I mpact of Waste upon available to the Municipality. RIEW. and MEW. upon non-toxic industrial solid wastes the Environment (S.G. 8611997 and S.G. 56/1999). request. AES will develop annual reports summarizing (disposable filters. rags. spent Waste to be disposed. with local approval. in the waste activities for submittal to RIEW. Reports will be desiccant material. machine Municipality·s landfill or in alternate location as directed by prepared in accordance with Bulgarian Ordinance No 10 I shop wastes. empty drums and the Municipality on the Filling out ofthe Report and the Waste ~~ containers Management Information Documents. dated 6.11.1998 ------~R3 ::0_ (IJ "U~ ~~ Q) ~ to 0 ~!ll (I) ::J ~~ O>CXl ~- Activity to be monitored Parameters to be monitored Monitoring frequency Record keeping and reporting tg Non·hazardous wastes Water treatment residuals to be dewatered and disposed, Logs maintained daily. Testing Daily logs books to be maintained on site and will be made ~ (water treatment residuals with local approval, in the Municipality's landfill. Sanitary of sanitary residuals (if to be available to the Municipality, RIEW, and MEW, upon sanitary waste water treatment waste water treatment residuals will be tested and, if used as fertilizer or for request. AES/3·C will develop annual reports ~ residuals) acceptable, will be used as fertilizer or for land reclamation) to be performed summarizing waste activities for submittal to RIEW. reclamation. Alternatively, sanitary residuals will be 4 times per yea r Reports will be prepared in accordance with Bulgarian disposed of, with approval, in the Municipality's landfill. Ordinance No 10 on the Filling out of the Report and the As with other solid wastes, RIEW certified daily log books Waste Management Information Documents, dated will be kept per Bulgarian Law for the Reduction of 6.11.1998. Results of testing for the purpose of using Harmful Impact of Wastes upon the Environment sanitary residuals as fertilizer or for land reclamation will be made available, upon request, for the review of the Ministry of Agriculture, Forests and Agriculture Reform and the Ministry of Health Care

Non·hazardous wastes Ash and gypsum will be tested by AES/3·C to determine Logs maintained daily Daily log books to be maintained on site and will be made (bottom ash, fly ash, and its disposal hazard·related characteristics. As with other available to the Municipality, RIEW, and MEW, upon gypsum) solid wastes, RIEW certified daily log books will be kept request. AES/3·C will prepare annual reports summarizing per Bulgarian Law for the Reduction of Harmful Impact of waste activities for submittal to RIEW. Report will be Waste upon the Environment prepared in accordance with Bulgarian Ordinance No 10 on the Filling out of the Report and the Waste Management Information Documents, dated 6.11.1998

Hazardous wastes AES/3·C to monitor waste management practices via Inspections performed and logs Daily log books to be maintained on site and will be made (significant quantities not visual inspections on an on·going basis. AESI3·C to keep maintained daily. Hazardous available to the Municipality, RIEW, and MEW, upon anticipated; could include minor RIEW certified daily log books per Bulgarian Law for the waste manifests to be completed request. AES/3·C will develop annual reports quantities of spent lubrication oil, Reduction of Harmful Impact of Wastes upon the by AES/3·C to coincide with off· summarizing waste activities for submittal to RIEW. chemical solutions, grease Environment. Any hazardous wastes generated will be site shipping of hazardous Reports will be prepared in accordance with Bulgarian soaked material, cleaning temporarily stored on site and transported to a licensed wastes Ordinance No 10. Manifests associated with shipping of solutions, and used batteries) facility for appropriate off·site treatment and disposal. hazardous wastes will also be completed by AES/3·C, in AES/3·C will complete manifests associated with off·site accordance with Ordinance No 10 shipment of hazardous waste

Notes: EPC = EPC Contractor AES/3·C = AESI3·C Construction Project Manager RIEW = Regional Inspectorate for Environment and Waters (Stara Zagora) MEW = Bulgarian Ministry of Environment and Waters Municipality = Municipality of Galabovo w

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9. PUBLIC CONSULTATION

This section summarizes the project's ongoing public consultation programme to elicit public input and ensure maximum local awareness of the project. A separate Public Consultation and Disclosure Plan document includes comprehensive details of the initiatives to date and future programme plans. Copies of the most important public consultation materials including the public hearing announcements, public hearing attendance list, various newspaper articles and the MEWs minutes of the public hearing are contained in Appendix D.

9.1 Regulations and requirements

Bulgaria has a well-developed set of environmental regulations that include the requirement for comprehensive review of a project as well as selected resource-related permits that govern plant activities. As part of the 1991 Environmental Protection Act, which requires preparation of an EIA for all thermal plants more than 50 MW in size, there is a specific provision for a public hearing. In addition, Regulation No 4 that was promulgated on 7 July 1998 sets forth EIA procedures for projects specified under Article 20, section 9 of the Environmental Protection Act. According to Article 17 of Regulation No 4, following submittal of the EIA to the MEW, a hearing date must be set and announced in the press at least 30 days in advance of the hearing. The MEW is required to issue a report on the hearing within 14 days of the hearing date and its determination of the acceptability of the EIA within 3 months of the EIA submittal date (Article 21, Regulation No 4).

The content of the Bulgarian EIA is specified in Attachment No 3 to Article 13( 1)3 of Degree No 4, 7 July 1998. Impacts to all natural resources such as air, water and ecology must be addressed. Attention to social and economic conditions is focused more on worker health and safety that it is on conventional social and economic conditions. The formal public hearing on the EIA report for the project that was submitted to the MEW on 16 December 1999 was held on 16 February 2000 in Galabovo.

The incorporation of the EU Integrated Pollution Prevention and Control Directive into Bulgarian law required further public consultation in 2004.

9.2 Previous public consultation and disclosure

Public consultation and disclosure for the proposed project has paralleled the development efforts.

9.2.1 Disclosure during initial project development

Development of the proposed project began locally in mid-1997. Consistent with the national energy strategy, the private development of the project was announced by NEK and project award was pursued by 3-C. The construction of new facilities to replace the existing ME 1 plant was discussed in newspapers published nationally as well as internationally. Sofia newspapers "Capital", "Standard", and "Now" discussed the proposed construction and invitation to foreign bidders. "The Financial Times" and "Project Finance International" both made note of the invitation for bids and the procedures to be followed. As appropriate to this phase of the project, the development team participated in numerous meetings with the parties participating in the project award and gave

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frequent interviews to the above mentioned newspapers and journals. Any public disclosure of the bid review and award process was the responsibility of NEK.

Following NEK's selection of 3-C in 1998, there were a number of newspaper announcements, first about the selection and later about AES joining the development team. The Sofia newspapers "Capital", "24 Hours" and "Banker" all noted AES's future involvement in AES-3C Maritza East 1 power plant. During the course of 1998 and 1999, the project company made a number of presentations at international and domestic conferences that focused on the energy section and international investment.

9.2.2 Disclosure during host country environmental review

AES formally entered the project during the second half of 1999 and took on a majority role in September 1999. Following submittal of the Bulgarian EIA to the NEW on 16 December 1999, AES- 3C assumed an active role in the preparations for the public hearing. In accordance with Bulgarian regulations, the project (and its public hearing planned for 16 February 2000) was announced in several newspapers: the "Galabovo News" (Galabovski Vesti) in Galabovo, "Maritza East" (Maritza Iztok) in Radnevo, and "Stara Zagora News" (Starozagorksi Novini) in Stara Zagora. In addition, announcements were made on the Galabovo cable TV channel, which is viewed by 80 per cent of the local population, and at the Troyanovo North mine and the existing Maritza East power plant. Also in February, at AES's headquarters in Arlington, Virginia, USA, the AES Corporation issued a Press Release on the project development activity in Bulgaria.

In addition to complying with the host country regulatory requirement of announcing the hearing 30 days prior to the event, AES followed World Bank guidelines on public consultation and disclosure in an effort to ensure that potentially affected local stakeholders were aware of the meeting and could attend. Two thousand large posters were prepared and placed in local stores, bus stops, main information points and municipal buildings in Galabovo, Radnevo and surrounding villages. Additionally, 6000 leaflets detailing information on the project and its sponsors were placed throughout Galabovo and mailed to peoples; homes in advance of the public hearing.

To ensure that as many people who wanted to could attend the meeting, a free shuttle bus service was provided. The project company arranged for six 40-seater buses through the Maritza East bus company, while the ME-1 power plant also provided two buses. Some buses came from villages as far way as 45 km. SpeCific groups that were assisted were local residents and workers at the Maritza East power plants and the mine. The six bus routes included the villages of Mustachevo, Sarveo, Razdelna, Velikovo, Aprilovo, Pomoshtnik, Glavan, Mardec, Iskritza, Mednikarovo and Obruchishte. Announcement ofthe bus schedule was made in the local press, on Galkabovo cable TV and in the flyers distributed throughout the town.

9.2.2.1 Public hearing in Galabovo (16 February 2000)

The day before the meeting, the project company project team met with representatives of Galabovo municipality and the mayors of 11 nearby villages. In addition to providing an overview of the project, the group was told of the detailed plans for the public meeting and encouraged to attend. This was followed by a smaller meeting with representatives of national and local labour unions and a dinner with both the union and major groups and representatives of the project company.

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In order to give the local stakeholders an opportunity to meet with the project sponsors and their environment consultants, and discuss issues related to the project, a morning "information session" was held in the Galabovo Hall of Culture on the day of the Public Heating. Approximately 250 people attended the information session, including residents of nearby villages, members of non governmental organizations (such as Green Balkans). Martiza East 1 plant employees, miners, unemployed residents, pensioners, students, teachers and municipal representatives. Information on the project and AES in written and audio-visual format (most of it in Bulgarian) was made available to all that attended. Ten members of the development team were available to answer questions. Several interpreters were present to assist with the English/Bulgarian translation. A feedback form, handed out at both the information session and public hearing, asked attendees their opinions on the project, the public hearing, and how they wanted to be informed in the future of project activities. The form came in a stamped, self-addressed envelope. Sixty-four forms were returned either that day or by post later on.

Approximately 510 people attended the public hearing. To accommodate this number and ensure that all could sign-in, the meeting hall was opened early. As the number exceeded what had previously been estimated and for which headsets for simultaneous translation were available, presentation slides were written in B,ulgarian, and sequential translation was provided for those presentations that were made verbally in English.

The main subject matter of the questions that were asked during the information session and public hearing were the following:

• project company background and projects in other countries

• the technical design of the project

• the anticipated effects of the project on nearby villages and Rozov Kladenetz Lake due to air emissions and water discharges

• employment during construction and operation

• the future for employees of the existing ME1 power plant

• the future of the Troyanovo 1 mine and the briquette factory

• the provision of district hearing in Galabovo

• the project company social responsibility programme and possible assistance for local educational institutions, pensioners and hospitals.

A press conference followed the close of the public hearing at 4.30 pm. Writers from the newspapers "Standard" (Standart), "Word" (Duma), "Labour" (Trud), "24 Hours" (24 Tchasa), "Democracy" (Demokratzia), "Stara Zagora News", and "Galabovo News" along with radio Domino and Vesselin, BNT (Bulgarian National Television), Stara Zagora Vereya Cabel and Galabovo cable television continued discussions started during the public hearing. Bulgarian National Television mentioned the public hearing during their evening broadcast and the Galabovo cable television company made a full recording of the public hearing which was shown later on the local channel.

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AES answered all the questions and concerns raised in the public hearing and in the feedback forms that were distributed and returned to the sponsors that day. Questions submitted on firms received after the public hearing have been answered in regularly published project updates.

9.3 Stakeholders

Early in the process of public consultation and disclosure, the project company identified the main stakeholders of the project as local residents, employees at the three Martiza power plants, the briquette factory and the mine, local and international non-governmental organizations, and local, regional and national governments. Direct efforts were made to ensure that all of these groups were aware of the public hearing and able to attend. In addition, through various secondary means (such as research via the internet and discussions with private groups and regulatory agencies) a lengthy list of potentially interested non-governmental organizations was identified. Due to the ecological importance of nearby lakes, a number of these groups were specially interested in biodiversity issues and the protection of birds. Efforts were made to contact many of these organizations. In some cases, contact was made with individual members; in other cases it was found that the group had disbanded and reconstituted itself or joined another group. Green Balkans appears to be the most active, well organized and well funded and the one that has expressed most interest in the project.

9.4 Public consultation programme

The purpose of the project's public consultation programme is twofold:

1. fully inform the affected public as well as other stakeholders of the project's plans and progress;

2. solicit local input to the development of a meaningful social responsibility programme. The latter is one of the project company's core values and a fundamental part of the project.

9.4.1 IPPC Consultation

The application for an IPPC (complex) permit was submitted to the MEW in March 2004. The application was made available to the public and if sufficient interest was shown a further public meeting would have been held. In fact there was very little public interest shown and MEW did not require a further public meeting. The draft IPPC (complex) permit was issued in February 2005. Again this draft permit is available to the public for comment though to date no comments have been received.

9.4.2 Open house

An open house/information session was held prior to the public hearing. From the feedback forms that were returned, this was well received and a successful vehicle for presenting information and promoting local input. Once the project EPC contractor is selected and construction plans are finalized, a second open house will be held. The purpose of this open house will be to meet with the EPC contractor, update the public on the selected final design of the plant and review plans for

Document No. 62160AlPBP/OOOOO1 0774R090.00C/S1/5NV PBPower Section 9 Page 5

construction. Of special note during this meeting will be the need for any road closure, interruptions or changes in regular bus service, disruption to site utilities that might create questions relative to local municipal service and any other activities that could be perceived as affecting municipal services.

Just prior to construction, another open houselinformation session will be held to update the public on the project development and specific information will be provided on employment procedures for the construction and operation phases of the project.

9.4.2.1 Project Contact

A single point of contact will be established and local residents informed that this is the person to whom they should direct project-related questions. This person will regularly be on site in Galabovo. The phone number of how to contact them will be published in the local newspaper and posted at the mayor's office.

9.4.3 Operation

9.4.3.1 Open house

Once the plant is commissioned, another open house would be held prior to the start of operation. At the time of the open house small group tours would be arranged so that residents could visit the facility. It is anticipated that those hired to work in the plant would lead these tours.

9.4.3.2 Project contact

As with construction, a single point of contact will be identified for public consultation during plant operation. This person will be a member of the plant staff, reachable through the plant main phone number and resident in Galabovo.

9.5 Resources and responsibilities

Initially, responsibility for public conSUltation will rest with the development team. They are actively involved in all negotiations associated with project development, including the discussions with MEW and NEK, and therefore in the best position to discuss the course of the project. Meetings to date with majors of local communities, labour leaders and the public have been conducted in an open and forthright manner. Direct answers have been provided about possible sale of the existing plant, possible unemployment, as well as the existence or lack thereof of special agreements with NEK. The Project Company is committed to continuing this policy of open communication. At least two development team members will have responsibility for public communication and disclosure. They will track issues raised in the press and work to ensure consistency of information presented about the project to the public, governmental agencies and local muniCipal authorities.

Document No. 62160AlPBP/OOOOO1 077 4R090. OOCIS 1/5"'" PBPower Appendix A

A. AIR QUALITY INFORMATION (43 pages)

Document No. 62160NPBP/oooOOl on4R110.docJS1/1tIN Appendix A PBPower Page A 1 of A43

A. AIR QUALITY INFORMATION

Figure A1 to A21 presented in this Appendix show the ground level concentration distribution for the worst.case metrological year for the 3 significant pollutants (S02, NOx and PM_10). Isopleths are provided with relation to the appropriate Bulgarian/EU standards regarding highest hourly, daily and annual concentrations for scenarios described in section 5.

Isopleths are presented with and without a base map for ease for easy interpretation, with "a" denoting isopJeths with a base map and "b" referring to the same data but with out the base map.

Document No. 6216OA1PBP/oOO001 On-4R110.docIS2I431w mlcrog)D'Slmsicublc mstm

N ~ 'i'"" "V II E 4615000.0 eIll) -~ E 1: ~ l:! CJ 0 .5 z E ::::I E

"=~ N II ~ .! ...c:

~0 0

fasting) (m)

~ ~------~--S--3-C------'------~-P-E-ND-IX-A-1-~-}-:-2-5-~-H-i9~--t-ho-~-Y-&1------~~~-'--~~~tI~p-s--p-owe--r--~~ MARITZA EAST IPOWER PLANT Ground level Concentration for the proposed ~S- C3 Maritza East I (1997) ~. o eop,r;cjlt PO Powor Section A PB Power Page 3

FIGURE A1b 25TH HIGHEST HOURLY S02 GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1997)

micrograms/cubic metre

4685000.0

C\I CC! ...- '

4660000.0

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Documont No. 621!lOAlPBPJOOOOO1 0774R110.DOC/S2/43IW mlcrogramsiClUblc metre

an ~ 'F'on e00 E 4615000.0 GD C) E -~ i::~ = €0 ~ E :::J E i ::E N DO ~ ! b. ::;J ~ 8

ESisfoirr'Dg (nrn)

, ~ ~------~--S--3-C------'------A-P-PE-N-D-IX-~-(a-)-:--4t-h-Hi-g~--td-a-ily-s-02------~~=-~--~~~II~~-s-~-o-we--r--~~ MARITZA EAST IPOWER PLANT Ground level Concentration for the proposed ~S- C3 Marilla East I (1998) ~ CCop)ric1rtPBP.... PBPower Section A Page 5

FIGUREA2b

4TH HIGHEST DAILY S02 GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1998)

micrograms/cubic metre

4685000

L() ~..... 10 4680000 II ...... c @ 0 (J) eE (.) c E 4675000. E :::J -C) E c 'x C\l €o :2: z C\i II ~ ~ .E .... :::J ...... 0 c 0 U

4660000

Easting (m)

Document No. 6216OA1PBPIOOOO01 0774R1 10.DOClS2l43IW mlcrogtrams!cublc msn

~ 'F' ....DO 55 E -E 4675000.0 G -~ £ 1: E t:: :J 0 E z .~ ~

'l"'" ci DR ~ S .5 L. ::;, .ec 8

fEasting (tm)

, ~ ~------~--S--3-C------'------~--E-N-D-IX-~-(a-)-:--M-~-'m-u-m-M-n-ua-,s-o-2------'~-;~~--~~~II~P-s-~-o-we--r--~~ MARllZA EAST IPOWER PLANT Ground level Concentration for the proposed ~S· C3 Maritza East I (1997) ~ o Cof>Iri

FIGURE A3b

MAXIMUM ANNUAL S02 GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1997)

micrograms/cubic metre

4685000.

":t ": ..-- 4680000 II c -CD 0) 0 E ~ (.) c E E 4675000 0.20 ::::l E -0) ·x c Cll :c ::2 1:: 0 ...... - Z ci 4670000. II 0.50 ~ 0.20 CD -C ..... ::::l .9 4665000 c 0 ()

4660000.

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 Easting (m)

Document No. 62160AlPBP/OOOOOl 0774Rl10.DOClS2I43MI mlcrogll'8msicublc mmm

~ ~ II &:: -GI) E 4575000.0 E

C) -&:: ~ l: 1: ~ E 0 ::J ;z E .~ ~ ~ II ~ ~ Ib ::J S C 0 (.)

lEes1l:lng (m)

~ AES - 3C APPENDIX M(a) :- 25th Highest hourly SO, P8 PB Power i MARITZA EAST I POWER PLANT Ground level Concentration for the other Maritza East power plant (1998) _. C CIlj»I'icjlt P8 "'""" Section A PBPower Page 9

FIGUREA4b

25TH HIGHEST HOURLY S02 GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1998)

micrograms/cubic metre

~ " E .!;;; 'x ..r::::: ttl t: ::E z0 o· "

4660000.

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Document No. 62160AIPBPIOOOOOl 0774R110.DOCIS2I43NV mlcrog)D"8mS/cu~lc meh

~680000 ___.~- nu • .- "",~.a-... ,.____ " .. , ...... ,_;_. .. ,-_'"' ,A_' ' ...... ', ..- ..., ...... ~,-, ..... -~ 'I"" (If) W 0 N DB c -GD E ~675000.0 E g) ! - (J r: 1: I:: '& E 0 ::::I ~ E ~S70000.0 "i ~ 0 'I""' II

'~~- ~ ~SS50000o--tk~~lm~·• • '" __ ' f '. : _ 4 - t'~. , .~,. > ,- F .... '~~~~U:iJJ~:DIIfI- .! £i b ::J S ~ 8 ~6S0000

lEasttlng (l11l'i)

~ ~------~--S--3-C------'------A-P-PE-N-DI-X-~-~-)-:--4~--Hig-h-es-th-o-Url-Y-SO-,------'~~n-'----~~II~p-s--p-o-we--r---1~ MARITZA EAST I POWER PLANT Ground level Concentration for the other Maritza East power plant (1998) ~

C ~t PO Power Section A PB Power Page 11

FIGURE A5b

4TH HIGHEST DAILY S02 GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1998)

micrograms/cubiC metre

4685000 50

..... ('I) <0 0 N 4680000 II C E ~ 0 c: - E S ::l C) c: ·xE :.2 til 1::: 0 :2: z .....0 4670000. 1/ til i:: (I) -c: ::l... 0 4665000 c: -0 U

4660000

Easting (m)

Document No. 62160AlPBPIOOOOO 1 0774R110.DOClS2143IW mlcroglT'8msicufblc men ~ ~ 10 C aD E G ~ E g ::J - E ~ "I € ~ o lit) ;z: N DO ~ .! ~

~ :I .9 8

IESlstil'1lQl (0111)

, ~ ~------~-S---3-C------'------~--E-N-D-IX-M-(-a)-:--M-~-im-u-m-M-n-u-al-s~------'~~~-r--~~~II~-p-s-P-o-we--r--~~ MARITZA EAST IPOWER PLANT Ground level Concentration for the other Maritza East power plant (1997) ~. c Cop)ricjrt PB P...... PBPower Section A Page 13

FIGURE A6b

MAXIMUM ANNUAL S02 GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1997)

micrograms/cubic metre

4685000.

N 0) It:i v 4680000 .....II C Q) E ~ o c E 4675000.

0) -c € zo 4670000

~ ::J .9 4665000. c o U

4660000.

405000.00 410000.00 415000.00 Easting (m)

Document No. 62160AlPBPfOOOOO1 0774R110.00ClS2I43IW mlcrog)mmsicLDblc msn

41680000 ------..-~ Ilf.) C» 81 c: -GD E 4615000.0 E eg -~ .s € E 0 ::;:J ;Z E 41670000.0 i 0 '

41665000.0(}-i{1{~

IESlstirag (m)

~ ~------~-S---3C------'------~--PE-N-DI-XA-7-~-)-:-2-5-~-H~-~--too-u-~-Y~------~=-~-'--~~~II~~-s-p-o-we--r--~~ MARITZA EAST I POWER PLANT Ground level Concentrations for all the Maritza East power plants (1998) ~. o Cop)ticjlt PO Power PBPower Section A Page 15

FIGUREA7b

25TH HIGHEST HOURLY 502 GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1998)

micrograms/cubic metre

4685000

C\I C\!..... L() en 4680000 II ...... c Q) E ~ u c: -E E ~ -Clc: E :c 'xcu 1:: 0 ~ z ...,.0 4670000 /I cu ~ ...... Q) ..5 L.. ~ 4665000. 0 c: -0 ()

4660000.

Easting (m)

Documenr No. 621 BOAlPBPIOOOOOl 0774Rl10.DOCIS2I43IW mlcrogmmsicLDlblc metre

N W ~ 0 N &I ....«= GD E t» r: G 1: .E i:! E 0 :J Z E

'=~ c:i or- II ~' .!c b :;;J Sc: 0 0

lE81sting (m)

~ r------~--S--3-C------.------A-P-PE-N-D-IX-M-(-a)-:--4-th-H-i9~--td-a-ilY-S-O'------<=~=-~--~~~Ir~-p-s-Po--we--r--~~ MARllZA EAST IPOWER PlANT Ground level Concentrations for all the Maritza East power plants (1998) _. o CopJricjlt P9 Power Section A PB Power Page 17

FIGUREA8b

4TH HIGHEST DAILY S02 GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1998)

micrograms/cubic metre

'"LO ~ 0 '"II c:: -Q) E ~ 0 c:: :[ 4675000. E :J C) E c:: 'x E co t::a ::E z c:i ~ II til ~ Q) -c:: '- :Ja 0 -ac:: 0 C,)

4660000

420000.00 425000.00 430000.00 435000.00 Easting (m)

Dor:umenINo. 62160AlPBPIOOOOO1 0774R110.DOClS2J431W mlcrogmms/culblc matm

g cd '¢ II !;;;: -Q) E 4675000.0 E ~ -~ ~ E €0 :::J Z E .~ ~ nrl' N 01 ~ .! .5 Ib. ::::J ~ 8

IESlsting (011'1)

~ ~------.------,~-;~~--~~------~~ AE5 - 3C APPENDIX AS(a) :- Maximum Annual SO, PB PB Power 8 MARllZA EAST I POWER PLANT Ground level Concentrations for all the Maritza East power plants (1997) _.

C Cop)IigIt P8 Power PBPower Section A Page 19

FIGUREA9b

MAXIMUM ANNUAL 502 GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1997)

micrograms/cubic metre

10 4680000.

E 4675000. -C) :cc 1::o Z 4670000 15

...::J .9 c 8

10 ---___ 10 4660000

.. ",),,,,,,,_00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Document No. 62160AlPBP/OOOOOl on4Rll0.DOC1S2I43IW mlcrog)rrams/cub!c mstm ~ ~ -81 16 E

=~ """'"" ~1'Joc:wel'\"" S E ~ ~ .~ €o ~ ;z C'Ii II ~ .! .5.... ~ 8

IESlStirog em)

~ ~------~--S--3-C------~------A-P-PE-N-D-IX-A-10-(a-)-:--1~--H-i9h-~--hO-U~--N~------"~~~.=-~--~~~II~-p-s-p-o-we--r--~~ MARI1ZA EAST IPOWER PLANT Ground lavel Concentration for the proposed AES-C3 Maritza East Ipower plant (1996) ~.. ~ ~. o Cop)rigrt P8 Ponr Section A PBPawsr Page 21

FIGURE A10b

19TH HIGHEST HOURLY NOX GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1996)

micrograms/cubic metre

4685000

N .....<'? ~ 4680000 II c: -Q) E ~ 0 c: E 4675000 12 E ...... ~ 0) E c: 'x :E co 1:: ~ 0 z N II co ..-C\I c: 2 ...c: ~ .9 c: 0 U

Easting (m)

Docum.. nl Nu. 6216OA1PBP/ooOOOl 0774R110.DOCIS2I43M1 mlcrog)IT'8B'1T1lsicLDbIC metre

g.... CO 0 II -=-c:;:: G!) E '1:: E 4515000.0 () C g) ~ -r:: E :I €0 E :z .~ ~ W e d II ~ .! £; b. ::I C. Sc <3

tEasting (m)

I ~ ~------.------'~-m--~--~~------~~ AES - 3C APPENDIX A11(a) :- Maximum Annual NO. P8 PB Power 8 MARITZA EAST I POWER PlANT Ground level Concentration for the proposed AES-C3 Maritza East I power plant (1996) ~ ...~ _.

O~P8P .... Section A PBPower Page 23

FIGURE A11b

MAXIMUM ANNUAL NOX GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1997)

micrograms/cubic metre

....co Q II t: -Q) E 0 ';: 8 (J .E E :s E 4675000, E -CJ .5 .. .c :E'= 1: Iff 0 0 z .~ . .- Q 4670000 II 0.25 ca S'= .E :sL. 4665000. 0 c -0 (J

4660000

405000.00 430000.00 435000.00 Easting (m)

Document No. 6216OA1PBP/ooo001 0774R110.DOCIS2/43M1 mlcrog)IT8ms/cublc mGfom

..= g(;) T'" II ....I: 41675000.0 Q) -E E ~ -~ u :2 £: 'i::! 0 E Z ::::t E .~ ~ L6 II ~ .! .5... ::J S S ()

fEasting (m)

~ ~------~-S---3C------'------AP-P-EN-D-IX-A-12-(a-)-:-1-~--Hi-9h-~-h-OU-~-N-O-'------~~~~---~~II~~-s--p-owe--r--~~ MARllZA EAST I POWER PLANT Ground level Concentration for the other Marilla East power plant (1999) ~. CCot>!ri9'rtP8_ PBPower Section A Page 25

FIGURE A12b

19TH HIGHEST HOURLY NOX GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1999)

micrograms/cubic metre

4685000.0

..- cg~ 4680000.00 ...... 25 .....II C CD E ....CD 0 c E 4675000.0 E _. :::J -C) -.. C E :E 'x t ro 0 :::2: z. .n 4670000.0 II ro ~ 25 .sac .... :::J 0 4665000.00 .....c 0 a ()

4660000.0

410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Docum8llt No. 82160AlPBPIOOOOO 1 on4R11 O.DOC1S2143M' mlcrog]U'8ms/cublc mstre

C\I 0) o.ri II -i E 41575000.0 E CD ~ -r:: .5 E € :J 0 e z ·1 :IE ~ ci DB .e~ .5 Ib.. :::::I

.sII:: 0 0

lEastting (m)

, ~ ~------'------~~~PE~N~D~~A1~3(~a)~:~-M~~~im-u-m-a-nn-~~I~NO~,------~~~'-'---I~~II~~=s~p~owe--r--~~AES -3C MARIlZA EAST I POWER PLANT Ground level Concentration for the other Mariiza East power plant (1996) ~ o ~ PO Power PB Power Section A Page 27

FIGURE A13b

MAXIMUM ANNUAL NOX GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1996)

micrograms/cubic metre

4685000.0

C\I 0) Lri 4680000.0 II c:: -CI) eE ,\p (,) c:: E E 4675000.0 :::J E -C> ·x c:: ctI :2 t:: ~ 0 M Z 1.S 0 4670000.0 II ,,~

~Q) -c:: L.. :::J 0 4665000.0 c:: -0 u

1.$ 1.5 4660000.00

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Dccumonl No. 62160AlPBP/oOOOO1 0774R110.DOCIS2I43IW m~crog]Dl!lms/CUIlblc rmtra

W II'-- d N 'i"" 01 C E 4615000.0 -GD E ~ -~ (.) c: €0 E Z ::l E .~ ~ Ill) II ~ ~ b ::l .9 c 0 0

lEasting em)

I ~ ~------'------~------~~'-r-~~~~-----,~ AES-3C APPENDI~A14(a) :-19th Hi~hesthourtyNo. PB PB Power ~ MARITZA EAST I POWER PlANT Ground level Concentrations for all the Mantza East power plants (1999) _. o Cop)r91t PO Power- PBPower Section A Page 29

FIGURE A14b

19TH HIGHEST HOURLY NOX GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1999)

micrograms/cubic metre

4685000.0

co el"- N 4680000.0 ...... II c: -Q) E ~ c:0 4675000.00 E E 50 ::l ---C) c: E :2 'x t::: to 0 :! z It) II m 2: ~ ..s... ::J .9 4665000.0 c: 0 U

4660000.0

4050(j0.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Drx:umttnl No. 6216OA1PBP/oooo01 0774R 11 O.D0CiS2I43M1 mlaoglT'SlmslcL8blc metre

~ W II 1: G!) E ~675000 E G - c:: E f ::l zo E -'-~T4- .~ ~ o.n C\I d II ~ J2 £: ' :;:J ~

fasting (rnn)

, ~ ~------~------~~~~,---~~------~~ AES - 3C APPENDIX A15(a) :- Maxlmum Annual NO, DR PB Power 8 MARITZA EAST I POWER PLANT Ground level Concentrations for all the Maritza East power plants (1996) ~ C Cop)ricjlt P8 P..... PBPower Section A Page 31

FIGURE A15b

MAXIMUM ANNUAL NOX GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1996)

micrograms/cubic metre

4685000.0

1.25 LO C'! (0 4680000.0 .....II c: CD E ...CD (J .5 '\?,.~ E E 4675000.0 ::::J E -C> ·x c: C\3 E :E t:: LO 0 N Z 0 4670000.0 II "'ffi ~ .....CD .E... ::::J .9 4665000.0 c 0 U

4660000.00

405000.00 410000.00 415000.00 420000.0-0 425000.00 430000.00 435000.00 Easting (m)

Document No. 6216OA1PBP/oooOO1 on4R110.DOC/82143M' mlaog]mms/culblc m€ih

en N ci .....DO t: G!) E E 41(615000.0 "6 ~ -Q) i:: E 1:: :] ~ E (;) ~ "~ ~ N q c 00 ~ .m !: b :] .9 16 10 (,)

lEatsting em)

~ ~------,------rn=~~-'~--~~------~~ AES -3C APPENDIXA16(a) :-36th Highest daily PM_10 .R PB Power 8 MARITZA EAST I POWER PLANT Ground level Concentration for the proposed AES-C3 Maritza East I power plant (1997) :::-:!.D2":oo. ~ o ~P8Pow ... PBPower Section A Page 33

FIGUREA16b

36TH HIGHEST HOURLY PM_10 GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1997)

micrograms/cubic metre

4685000.0

C> N d II 4680000.0 ~ r::::: Q) 0 E 00 ·5 r::::: E ::J E 4675000.0 E ·x - co ::E 0.06--_ N- <::! 0 4670000.0 II co 2: Q) -...r::::: ::J 0 4665000.00 r::::: -0 c...> o 0.06

4660000.0

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Documenf No. 62160AlPBPI000001 0774Rll0.DOCIS2143JW mlcrogrntmsicLnrolc m€ih

C') 'i'" ci e80 GD E E 41515000.0 ~ ~ -ct» :.e E '& :J 0 E ~ .~ ~

'i'" 0 ci 00 ~ .! ~ b .s::I ~ 8

4050l00.0l0 4~0000,oo 4~5000.00 420000.00 425000,00 430000.00 43500l0.00 IESlstirig) (m)

, ~ r------,------.~~m__,----~~------~~ AES - 3C APPENDIXA17(a) :- Maximum Annual PM_10 DB PB Power ~ MARI1ZA EAST I POWER PlANT Ground level Concentration for the proposed AES-C3 Maritza East I power plant (1997) ~"~006 ~. C eowq.t P8 P_ Section A PBPower Page 35

FIGURE A17b

MAXIMUM ANNUAL PM_10 GROUND LEVEL CONCENTRATION FOR THE PROPOSED AES -C3 MARITZA EAST 1 POWER PLANT (1997)

micrograms/cubic metre

4685000.

M..... c:i II 4680000.0 c: -Q) 8) 0 E ~ 0 C,.) c E 4675000.0 ::J E E 'x -- (\l ~ 0.02 .....- 0 c:i 4670aoo.0 II (ijc: Q) ,. .E-... ::J 0 4665000.0 c: -0 0

4660000.0

,. It' 405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

,~ ".

Document No. 621S0NPBP/OOO001 0774R110.DOClS2143IW m!crog)mrnrns/cub!c m~

CD ~ 'F' nn ..", f;:; ~ G g) r;: !: J:: E 1:::: :::::! :z0 E '=~ 'F'- ci no ~ .mt: 16 :J .9 t: 8

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 IESlsltll'1g) (m) , AES-3C APPENDIXA18(a} :-361hHighestdailyPM_10 .R PB Power ~ MARI1ZA EAST I POWER PLANT Ground level Concentration for the other Maritza East power plant (1996) ~ o Cowi<1't PO Power Section A PBPower Page 37

FIGURE A18b

36TH HIGHEST DAILY PM 10 GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1996)

micrograms/cubic metre

4685000.0

'x C co E ~ t:: ...... - z0 0 4670000.0 II

~Q) c -.... ::l 0 c -0 ()

4660000.0

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Document No. 62160AlPBPIIl00001 0774R110.DOCIS2I43M1 mlcrogmmslcLBblc msibm

(j) 00 e ....00 ~ ~ E G g) c:: ~ 1: E '& ::I 10 ~ ~ .§ ~ nri' 0 ci 00 ~ .m £: '- ::;J S 8~

~05iOOOJ))O 410000.00 415000.001 ~2000!O.OO ~25000.00 ~30O!OO.OO 435000.00 IESlstinlg) em)

~ ~------~-S---3-C------'------AP--~-N-D-IX-A-1-9~-)-:--M-~-im-U-m-M-n-Ua-I-PM-_-10------r.=~m-~--~~=II~-~-B-P-O-we--r--~~ MARITZA EAST IPOWER PlANT Ground level Concentration for the other Maritza East power plant (1996) ~. o Cop)ric1II P8 P..... Section A PB Power Page 39

FIGURE A19b

MAXIMUM ANNUAL PM 10 GROUND LEVEL CONCENTRATION FOR THE OTHER MARITZA EAST POWER PLANT (1996)

micrograms/cubic metre

4685000.0

co0'> d II 4680000.0 c: -Q) E ~ (,)~~ 0 c: E ::l E 4675000.0 E 'x -c:C> to :E ~ ~ t6 z0 0 (,)ZI5 0 4670000.0 II co ~ Q) -c: '- ::l 0 4665000.0 c: -0 q.- ()

0.<5 0.25 4660000.0

405000.00 410000.00 415000.00 420000.00 425000.00 430000.00 435000.00 Easting (m)

Document No. 62160NPBPIO00001 0774R 11 D. DOClS2143iW m!crog)mmsicublc msftm

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FIGURE A20b

36TH HIGHEST DAILY PM 10 GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1996)

micrograms/cubic metre

4685000.0

II C -Q) E ~ .E E g 4675000.0 ::l E ·x ~ C\:l :c ~ t::o ...... Z ci 4670000.0 II

~Q) .E- L.. ::l .9 c oo

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lE81sting) (m)

, ~ AES-3C APPENDIXA21(a) :-MaximumAnnuaIPM_10 .R PBPower ~ MARITZA EAST I POWER PLANT Ground level Concentrations for all the other Maritza East power plants (1996) ~. C Cop)ri9o\ PI! Power Section A PB Power Page 43

FIGURE A21b

MAXIMUM ANNUAL PM_10 GROUND LEVEL CONCENTRATION FOR ALL MARITZA EAST POWER PLANT (1996)

micrograms/cubic m~tre

-~:,... 4685000.0

~ ci II 4680000.0 C -Q) E ~ ()').~ (,) ~ ..5 ,.(-:.. E ::l :- 4675000.0 E :;.. 'x IV 2> ::2 -: 1.0 0 5 0 ~ ()~15 II ro ~ Q) .E- '- ~.. ::l ~.;,' '; 0 4665000.0 c ~@. -u0

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Document No. 62160AlPBP/OO0001 0774R110.DOCJS2I43M1 5/20/2005 12:13:47 PCARD CHARGES FOR FUND CENTER REPORT ---~------.~~--~~------FUND CENTER CARDHOLDER G/L ACCOUNT MERCHANT POSTING DT TRANSAC DT TOTAL CHARGES FI DOCUMENT# FY ------e e 500411400 Misc Pur - Chrg Card 15.00 e GECPS- FEES AND CHARGES 15.00

._ ... ,. . t!'" ..... "., .,.t!1.;t·~.L29'0491- __l,~.L2,3,~=!-Qq-~ .. , -. .- ,'-_ ,J.5 .2,~ 2005 e MAC_¥',. ... :qS.J1!1'!~,;!!!-)ii::~wl:~ !\!:!!f;;'!':fY;.J:~!,!!Z;!.-'\'~!~ .~~_:-!-~~' !iiii;!! '. ~~! !! ~!~~I¥! e 500411400 Misc Pur - Chrg Card 83.50 e CVS PHARMACY #0057 Q03 29.50 08/13/2004 07/08/2004 29.50 1910003183 2005 e UNITED NATIONS 54.00 1910003268 2005 e SH~'VE, ~1;dft--§i5_-'i~j:!~i'~t~1_ e 500406210 Hospitality 546.28 e TRADER JOE'S #00006429 175.36 01/13/2005 12/18/2004 15.98 1910003421 2005 04/15/2005 03/10/2005 16.43 1910003584 2005 05/16/2005 04/15/2005 19.63 1910003658 2005 01/13/2005 12/08/2004 19.90 1910003419 2005 01/13/2005 01/02/2005 48.40 910003423 2005 04/15/2005 03/19/2005 55.02 1910003586 2005 e WHOLE FOODS MARKET #03 105.00 11/16/2004 10/15/2004 105.00 1910003318 2005 e WHOLE FOODS MARKET#047 7.98 05/16/2005 04/06/2005 7.98 1910003654 2005 e WORLD BANK CON30091599 257.94 04/15/2005 03/22/2005 257.94 1910003587 2005 e 500411060 Office Eqpt Purchase 116.83 e AFS*PC MALL GOV 37 116.83 05/16/2005 04/07/2005 116.83 1 2005 e 500411380 Books & Periodicals 219.82 e ENG*THE ECONOMIST MAG 136.42 02/15/2005 01/20/2005 136.42 9 00Ll3474 2005 e SUB SCRIP TO FT COM 83.40 01/13/2005 12/31/2004 83.40 19 0003422 2005 e 500411400 Misc Pur - Chrg Card 3,777.34 e CVS PHARMACY #0057 Q03 55.34 PCARD CHARGES FOR FUND CENTER REPORT 5/20/2005 12:13:47 ------~------FUND CENTER CARDHOLDER G/L ACCOUNT MERCHANT TRANSAC DT TOTAL CHARGES FI DOCUMENT# FY POSTING DT ~------~--'------05/16/2005 04/13/2005 5.17 1910003655 2005 03/15/2005 02/25/2005 7.47 1910003537 2005 03/15/2005 03/03/2005 8.04 1910003538 2005 05/16/2005 04/06/2005 8.67 910003652 2005 05/16/2005 05/03/2005 11.87 1910003659 2005 12/16/2004 12/02/2004 14.12 91000 376 2005 e HAR*HARVARD BUSNSS SCH 660.00 04/15/2005 03/10/2005 660.00 19 003533 2005 e I.I.F. PUBLICATIONS 1,100.00 05/16/2005 04/19/2005 550.00- 57 2005 05/16/2005 04/15/2005 1,650.00 2005 e INTERNATIONAL MONETARY 99.00 01/13/2005 12/10/2004 99.00 ',q 0003420 2005 e NEWS EXPRESS 39.00 04/15/2005 03/14/2005 39.00 1910003585 2005 e STRATFOR COM 1,824.00 1910003256 2005 tIPPIiiBA"f;6¥fo"'I{!'I:If'ii~~~,*t,1i ~i?i~m;01!! ~l'~'/';i~,.. i~~i,m;;; ,.,.;h~ j;a.~~ ~';L e S _ ~_ _'0 :;",p~, -~:, _,~~-,,~ '('~Rlr" +\iGt:;l:,,< ~:~'-¥,{. ':~;:;;:;r /~:~,.: :n:, ,:~~>~:o -~.p;, 'Q;0:'" /w~ , 'i-~~7:<>. . ~!:;~!ti~:~!'!!~tr~,:t < e 500411340 General Supplies 2,742.77 ««< e CORP EXPR 800-582-4774 2,742.77 09/13/2004 08/19/2004 123.62- 1910003228 2005 02/15/2005 02/05/2005 1.64 1910003469 2005 01/13/2005 12/28/2004 3.40 1910003412 2005 03/15/2005 02/11/2005 7.92 1910003505 2005 01/13/2005 12/28/2004 13.60 910003411 2005 07/14/2004 07/02/2004 13.95 1910003180 2005 03/15/2005 02/15/2005 15.84 1910003508 2005 01/13/2005 12/11/2004 17.03 1910003390 2005 12/16/2004 11/18/2004 18.48 1910003344 2005 01/13/2005 12/16/2004 18.48 1910003397 2005 12/16/2004 11/10/2004 19.24 1910003363 2005 01/13/2005 12/22/2004 24.34 191000:5408 2005 12/16/2004 11/20/2004 26.72 1910003345 2005 02/15/2005 01/14/2005 27.72 1910003453 2005 05/16/2005 04/14/2005 27.72 1910003620 2005 04/15/2005 03/25/2005 30.07 1910003571 2005 12/16/2004 11/16/2004 31. 55 1910003368 2005 12/16/2004 11/10/2004 37.52 1910003364 2005 12/16/2004 11/12/2004 40.04 1910003367 2005 01/13/2005 12/18/2004 51.46 1910003403 2005 01/13/2005 12/16/2004 54.24 9100(13394 2005 04/15/2005 03/18/2005 70.18 191000356 2005 12/16/2004 11/25/2004 78.20 1910003356 2005 12/16/2004 12/03/2004 82.73 19 0003362 2005 10/14/2004 09/17/2004 90.54 1910003245 2005 01/13/2005 12/18/2004 108.00 1910003398 2005 12/16/2004 11/19/2004 110.40 1910003346 2005 03/15/2005 02/26/2005 118.07 1910003521 2005 05/16/2005 04/20/2005 132.26 J.91000 624 2005 5/20/2005 12:13:47 PCARD CHARGES FOR FUND CENTER REPORT ------FUND CENTER CARDHOLDER G/L ACCOUNT MERCHANT TOTAL CHARGES FI DOCUMENT# FY POSTING DT TRANSAC DT ------.-~------09/13/2004 08/12/2004 155.18 1910003225 2005 05/16/2005 04/30/2005 155.86 1910003639 2005 05/16/2005 04/28/2005 164.27 19 0003637 2005 09/13/2004 08/12/2004 176.68 1910003226 2005 05/16/2005 04/08/2005 196.54 1910003611 2005 08/13/2004 07/31/2004 219.98 1910003206 2005 08/13/2004 07/10/2004 247.24 910003191 2005 04/15/2005 03/29/2005 279.30 1910003 4 2005 TOTAL 7,501.54 PBPower Appendix B

B. FAUNA SPECIES LISTS (17 pages)

Document No. 6216ONPBP/OOOOOI 0774RI20.doclSl/11w 1 Table B-1 Mammal Species Potentially Occurring at or Near the Maritza East I Power Plant ,2

Micromys rnrrl1lT1'S

Lakes, rivers, Bulgarian Red Data Book Table B-2 List of Bird species Observed in the Maritza Territory

Table 8-3 Protected Birds Known to Occur or That Could Potentially Occur At or Near the Maritza East Region

~, x

avos etta

Stone curlew

movements WIM

Panurus biarmicu5

Table B-4 Endangered and Extinct Animal Species Listed In the Red Data Book of Bulgaria (Volume II, 1985) Known to Occur in the Maritza Region

the towns Harmanli and SvUengrad. Nadezhden

Episodic near Maritza and Tundzha Rivers. viUage Opylchenets. town Stara Zagora. reseNe "Balabanan near Elhovo Harmanli, Lyubimets, Nadezhden, Svilengrad region Birds That Could Potentially Nest in the Proiect Area

World Conservation Union (IUCN) "Red Ust" Threatened Species:

1. Phalecrocorax pyameus - Pygmy connorant

Status: Near Threatened. Status could be moved to Threatened (which includes Endangered, Vulnerable, Rare) in the future. Main nesting colonies are along the Danube River. Total breeding population in Bulgaria is 90-150 pairs. Has been reported to nest along the Maritza River. This species does not currently nest within the project area, but has been recorded on Rozov Kladenetz Lake.

2. Avthva nyroca - Ferruginous duck or White-eyed bochard

Status: Vulnerable. May be moved to Endangered status. Estimated 50-100 pairs in Bulgaria, nesting primarily in central Bulgaria, along the Danube River and Black Sea coast.· Habitat includes shallow lowland lakes and marshes. Not expected to nest at Rozov Kladenetz Lake.

3. Aquila elanqa - Greater spotted eagle

Status: Vulnerable (see above). Estimated 20-25 pairs nationwide, nesting mainly in eastern Bulgaria, but also reported along the Tundzha River. May nest in large trees or cliffs, and may nest within the region, but not near Rozov K1adenetz Lake.

4. Aquila helieee - Imperial eagle

Status: Vulnerable (see above). Estimate of 20-25 pairs in Bulgaria, with widely scattered nests over most regions of Bulgaria. Nests on wooded ridges or mountain hillocks. Hunts over open flat or hilly terrain. Not expected to next close to Rozov Kladenetz Lake.

5. Fa/co naumanni - Lesser kestrel

Status: Vulnerable. Estimated 60-120 pairs nationwide, with 57 breeding pairs confirmed during the period 1980-1990. Known to nest in upper Thracian region. Nests in mountain slopes, gorges, deep ravines (52 percent); settlements (fonnerly 32 percent of nests); and trees (21 percent). Also nests in rock quarries. Primary breeding elevation is 100-200 meters, but nests may occur greater than 800 meters. Nesting could occur within the region of the project site. 6. Crex crex - Comcrake

Status: Vulnerable. Estimated 100-1,000 pairs nest in Bulga'ria. Species nests at scattered locations across Bulgaria, but confined to wetland habitats. Not expected to nest at Rozov Kladenetz Lake, but could nest at other wetlands in region.

Species of European Conservation Concern (SPEC)- Category 1 Species (Globally Threatened)

1. Avthya nvroca - Ferruginous duck or White-eyed bocharcf (discussed previously). Status: SPEC Cat. 1 - Vulnerable (Low population levels and/or declining - less than 2,500 breeding pairs' worldwide).

2. Aguila clanga - Spotted or greater spotted eagle (discussed previously).

Status: SPEC Cat. 1 - Endangered (Low population levels and/or declining - less than 250 pairs worldwide).

'3. Aguila heliaca - Imperial eagle (discussed previously).

Status: SPEC Cat. 1 - Endangered (see above).

4. Falco naumanni - Lesser kestrel (discussed previously).

Status: SPEC - Gal 1 - Vulnerable (see above).

5. Crex crex - Corncrake (discussed previously),

Status: SPEC - Cat. 1 - Vulnerable (see above).

Species of European Conservation Concern (SPEC).- Category 2 Species (more than 50 percent of world population occurs in Europe, and species hasunfavorab/e status)

1. Phalacrocorax pyqmeus - Pygmy cormorant (discussed above).

Status: SPEC cat. 2 - Vulnerable (see above).

2. Ciconia ciconia - White stork

Status: SPEC Cat. 2. Nesting occurs across Bulgaria, with an estimate of 5,000-5,200 pairs. Can nest in villages. Feeds in wetlands and grainfields. Expected to nest near project site. 3. Accipiter breviPes - Levant sparrowhawk or Short-toed hawk

Status: SPEC Cat. 2 - Rare (fewer than 10,000 breeding pairs worldwide). Estimated 20-25 pairs in Bulgaria, nesting mostly in eastern and western Bulgaria. Nests in small woodlands in open cultivated terrain. Could nest in region of project site.

4. Tringa fotanus - Redshank

Status: SPEC Cat. 2 - Declining (declining, but more than 10,000 breeding pairs worldwide). Estimated 30-100 pairs nest at scattered locations across Bulgaria. Nesting primarily in wetlands and wet fields. Could nest within local region, but not expected at Rozov Kladenetz.

5. Otus scops - Scops owl

StabJs: SPEC Cat. 2 - Declining (see above). About 10,000 pairs breed across Bulgaria. Nests in small woodlands in open country. Could nest at or near Rozov Kladenetz in small forest plantings.

6. Caprimulgus europaeus - Nightjar

Status: SPEC Cat. 2 - Declining (see above). Estimated 1,000-5,000 pairs breed across Bulgaria. Nests in open areas along edge of woodland, larger woodland openings, drier areas and semi desert. Expected to nest in local region.

7. Coracias garruJus- Roller

StabJs: SPEC Cat. 2 - Declining (see above). Estimated 1,000-5,000 pairs nest across Bulgaria. Nests in open woodlands and open habitats with scattered trees. Nests in tree cavities, sometimes dirt banks. Expected to nest at or near Rozov Kladenetz.

8. Picus viridis - Green woodpecker

Status: SPEC cat. 2 - Declining (see above). Estimated 5,000-10,000 pairs nest across Bulgaria in woodlands, open woodlands, parks, and areas with scattered trees. Expected to nest at Rozov Kladenetz, or nearby.

9. Phoenicurus phoenicufUs - Redstart

Status: SPEC Cat. 2 - Vulnerable (see above). Estimated 500-5,000 pairs nest across Bulgaria. Nests in woodlands, open parklands, gardens with stonewalls, scattered trees. Expected to nest at Rozov Kladenetz or nearby. r--

10. Oenanthe hispanica - Black-eared wheatear

Status: SPEC Cat. 2 - Vulnerable (see above). Estimated 1,000-10,000 pairs nest across Bulgaria. Nest in open habitats with shrubs and scattered trees. Expected to nest near Rozov Kladenetz.

11. Hippo/ais olivetorom - Olive tree warbler

Status: SPEC Cat. 2 - Rare (see above). Estimated 100-1,000 pairs nest at scattered locations in Bulgaria. Usually nest in olive or oak trees in dry areas. Species could possibly nest near Rozov Kladenetz.

12. Ficedula semitorauata - Semi-collared flycatcher

Status: SPEC Cat. 2 - Endangered (see above). Estimated 500-5,000 pairs nest mainly in northern Bulgaria.

13. Lanius minor - Lesser gray shrike

Status: SPEC Cat. 2 - Oedining (see above). Estimated 1,000-10,000 pairs nest across Bulgaria. Nests in open country with trees and shrubs. Expected to nest in local region.

14. Lanius senator- Woodchat shrike

Status: SPEC Cat. 2 - Vulnerable (see above). Estimated 300-3,000 pairs nest over mostly southern Bulgaria. Nests in dry open country with shrubs and trees; maqius scrub. Could nest in local region.

15. Lanius nubicus - Masked shrike

Status: SPEC Cat. 2 - Vulnerable (see above). Estimat~50-100 pairs nest over mostly southem Bulgaria. Nest in open forests, shrubs, gardens, olive groves. Expected to nest at or near Rozov Kladenetz.

16. Emberiza hortulana - Ortolan bunting

Status: SPEC Cat. 2 - Vulnerable (see above). Estimated 10,000-100,000 pairs nest across Bulgaria. Nests in open areas with scrub trees, woodland edges, near water. Expected to nest near Rozov Kladenetz Lake. 17. Emberiza melanocepha/a - Black-headed bunting

Status: SPEC Cat. 2 - Vulnerable (see above). Estimated 5,000 - 50,000 pairs nest across southern Bulgaria. Nests in open areas with scattered trees and shrubs, gardens. Expected to nest near Rozov K1adenetz Lake.

Birds Expected to Occur Primarily During Migration or in the Winter Near the Project Site

1. Bmnta roflCOllis - Red-breasted goose

Status: IUCN Vuln: SPEC Cat. 1 - winter, Bulgarian Protected. Most of world population winters along the Black Sea coast in Bulgaria (about 50,000 -60,000 birds). A few individual birds have been reported in the region of the project site, possibly with flocks of other geese. Could be avery rare visitor to local region.

2. Anser ervthropus - Lesser white-fronted goose

Status: IUCN Vuln: SPEC Cat. 1 Vuln., Bulgarian Protected. Winters in the region and could occur sporadically with much. larger flocks of white-fronted geese (Anser alblfrons) [winter population about 150,000]. The lesser white-fronted goose has been reported at Ovcharitza Dam, and could rarely occur at Rozov Kladenetz. Other species of internationally protected waterfowl could occur in the region, but these species would be rare. Appendix C PBPower

c. NOISE MONITORING DATA (15 pages)

Document No. 6216OA1PBP/o00001 0774R130.doclS1f11w Maritza East 1 Construction No/se AnaJysis 1IardI,2000

X Y !iGO meters 1640 0 Estimated EsIimIIed AInIas.& ActiVi)' ActMty EqaipmeIIt Usage LwehUO' IIIIIIIber of EJPpmeIIt AnOIIIIIous Equip. Number Name NanIe Factor (Fable2) AtIII XI Yl DiSt 1 Macbines SPL I\.".) AII!naIIion t....

SITE PREPARATION DUMP TRUCK 0.16 91 0 0 0 1640 12 61 2 62 SITE PREPARATION SCRAPER 0.14 88 0 0 0 1640 2 58 2 50 SITE PREPARATION BACKHOE 0.04 85 0 0 0 1640 1 55 2 39 SITE PREPARATION GRADER 0.05 85 0 0 0 1640 1 55 2 40 SITE PREPARATION DOZER 0.04 so 0 0 0 1640 1 ·SO 2 34 SITE PREPARATION FRONT LOADER 0.16 79 0 0 0 1640 3 49 2 43 SITE PREPARATION GENERATOR 0.4 78 0 0 0 1640 4 48 2 48 LInaI: &1 l.eq: 62

2 exCAVATION ROCK DRill 0.04 9S 0 0 0 1640 1 68 3 51 2 EXCAVATION DUMP TRUCK 0.16 91 0 0 0 1640 12 61 2 62 2 EXCAVATION BACKHOE 0.16 85 0 0 0 1840 1 55 2 45 2 EXCAVATION DOZER 0.16 eo 0 0 0 1640 1 50 2 40 2 EXCAVATION FRONT LOADER 0.16 79 0 0 0 1640 3 49 2 43 2 EXCAVATION AIR COMPRESSOR 1 81 0 0 0 1640 1 51 2 49 2 exCAVATION GENERATOR 0.4 78 0 0 0 1640 4 48 2 AS 2 exCAVATION JACKHAMMER 0.1 88 0 0 0 1640 1 58 3 45 2 EXCAVATION PUMP 0.4 76 0 0 0 1640 6 46 2 1,7 2 EXCAVATION SHOVEL 0.2 82 0 0 0 1640 2 52 2 46 LmIlc A ~ &3 3 FOIJIIDATlONS JAa

5 RNSHING ROCK DRill O.OS 98 0 0 0 1640 1 68 2 53 5 RNlSHlNG DUMP TRUCK 0.16 91 0 0 0 1640 2 61 2 54 5 FINISHING AIR COMPRESSOR 0.4 81 0 0 0 '1640- . 1 51 2 45 5 FINISHING BACKHOE 0.04 85 0 0 0 1640 1 55 2 39 5 F1NISHING CONCRETE MIXER 0.16 85 0 0 0 1640 1 55 2 45 5 FINISHING CONCRETE PUMP 0.08 82 0 0 0 1640 1 52 2 39 5 FINlSIfNG DERRICK OWIE 0.02 88 0 0 0 1640 1 58 2 39 5 FINISHING MOBILE CRANE ·0.04 83 0 0 0 1640 10 53 2 47 5 FINISHING DOZER 0.04 so 0 0 0 1640 1 50 2 34 5 FlNISlfNG GRADER 0.02 85 0 0 0 1640 1 55 2 36 5 FINISHING JACK HAMr.t:R 0.04 88 0 0 0 1640 1 58 3 41 5 FINISHING FRONT LOADER 0.04 79 0 0 0 1840 1 49 2 33 5 FINISHING PAVER 0.12 89 0 0 0 1640 1 59 2 47 5 FINISHING PNEUMATIC TOOl 0.04 85 0 0 0 1640 2 55 3 41 5 FINISHING ROLLER 0.1 74 0 0 0 1640 1 44 2 32 5 FINISHING SCRAPER 0.08 88 0 0 0 1640 1 58 2 45 5 FINISHING SHOYEL 0.06 82 0 0 0 1840 1 52 2 :rT I.max: 88 leq: 58

Table 1 MariIza East 1 Construdion Noise Analysis MardI.2IlGO

X Y 7511met!1S 24iO G Estimated Estim3IId Almas. & ActmlY At:tNty E",ipment Usage UnlitSO' Namberof Equipment An~_ Equip. N1rier NzIe Name FactDr (Tallie 2) AlIn XI VI list 1 MacIIines SPL (L,.J AIIenuaIioft t...

''- SITE PREPARATION DUMP TRUCK 0.15 91 0 0 0 2460 12 57 3 57 SITE PREPARATION SCRAPER 0.14 88 0 0 0 2460 2 54 3 46 SITE PREPARATION BACKHOE 0.04 85 0 0 0 2460 1 51 3 35 SITE PREPARATION GRADER 0.05 85 0 0 0 2460 1 51 3 35 SITE PREPARA110N DOZER 0.04 80 0 0 0 2460 1 46 3 30 SITE PREPARATION FRONT LOADER 0.15 79 0 0 0 2460 3 45 3 39 SITE PREPARATION GENERATOR 0.4 78 0 0 0 2460 4 44 3 44 1.InaI: 51 L.eq: 58

2 EXCAVATION ROCK DRILL 0.04 98 0 0 0 2460 1 64 4 47 2 EXCAVATION DUMPTRUCK 0.16 91 0 0 0 2460 12 57 3 51 2 EXCAVATION BACKHOE 0.16 85 0 0 0 2460 1 51 3 41 2 EXCAVATION DOZER 0.16 80 0 0 0 2460 1 46 3 36 2 EXCAVATION FRONT LOAtER 0.16 79 0 0 0 2460 3 45 3 39 2 EXCAVATION AIR COMPRESSOR I 81 0 0 0 2460 1 47 3 45 2 EXCAVATION GENERATOR 0.4 78 0 0 0 2460 4 44 3 44 2 EXCAVATION JACKHAMMER 0.1 88 0 0 0 2460 1 54· 4 41 2 EXCAVATION P\.IIoP OA 76 0 0 0- 2460 6 -42 3 43 2 EXCAVAllON SHOVEL 0.2 82 0 0 0 2460 2 48 3 42 I.ma: &4 riQ: 59

3 FOUt«lAllONS JACKIWtNER 0.04 !18 0 0 0 2<160 1 54 4 37 3 FOUt«lATiONS CONCRETE t.IXER 0.4 85 0 0 0 2460 6 51 3 52 3 FOUt«lATlONS CUMPTRUCK 0.16 91 0 0 0 2460 6 51 3 54: 3 FOUNDATIONS PILEDRIVER 0.04 101 0 0 0 2460 1 rr 4 50 3 FOUNDATIONS AIR COMPRESSOR 0.4 B1 0 0 0 2460 1 47 3 41 3 FOUNDATIONS CONCRETE PUMP 0.4 82 0 0 0 2460 1 48 3 42 3 FOUNDA~S PUMP I 76 0 0 0 2460 6 42 3 47 3 FOUNDATKNI SAWS 0.04 78 0 0 0 2460 2 44 3 31 I.ma: rT Leer. 58

4 ERECTION DERRIa< CRANE 0.04 88 0 0 0 2460 1 54 3 38 4 ERECTION JACKHAMMER 0.04 88 0 0 0 2460 1 54 4 37 4 ERECTION SAWS 0.1 7B 0 0 0 2460 2 44 3 36 4 ERECTION AIR CCNPRESSOR 0.4 81 0 0 0 2460 1 47 3 41 4 ERECTION C<»ICRETE MIXER 0.16 85 0 0 0 2460 2 51 3 44 4 ERECTION MOBILE CRANE 0.08 83 0 0 0 2460 10 49 3 48 4 ERECTION PNeUMATIC TOOl 0.1 85 0 0 0 2460 2 51 4 41 4 ERECTION PUMP 0.4 76 1 0 0 2460 6 42 4 41 4 ERECTION ROCK DRILL 0.05 98 0 0 0 2460 1 64 4 48 !.max: &4 !:5 52 5 FINISHING ROCK DRILL 0.05 98 0 0 0 2460 1 64 3 49 5 FINISHING DUMP TRUCK 0.16 91 0 0 0 2460 2 57 3 50 5 FlNISIING AIR COMPRESSOR 0.4 81 0 0 0 24SO 1 47 3 41 5 FINISHING BACKHOE 0.04 85 0 0 0 2460 1 51 3 35 5 FINISHING CONCRETE MIXER 0.16 85 0 0 0 2460 1 51 3 41 5 FINISHING CONCRETE PUMP o.oa 82 0 0 0 2460 1 48 3 35 5 FINISHING ~RRla< CRANE 0,02 88 0 0 0 2460 1 54 3 35 5 FINISHING MOBILE CRANE 0.04 83 0 0 0 2460 10 49 3 43 5 FINISHING DOZER 0.04 80 0 0 0 2460 1 48 3 30 5 FINISHING GRADER 0.02 85 0 0 0 2460 1 51 3 32 5 FINISHING JACKHAMMER 0.04 88 0 0 0 2460 1 54 4 37 5 RNiSHING FRONT LOADER 0.04 79 0 0 0 2480 1 45 3 29 5 FINISHING PAVER 0.12 89 0 0 0 2460 1 55 3 43 5 AtiSHIfG PNElJdATiC TOOL 0.04 85 0 0 0 2460 2 51 4 37 5 FINISHING ROLLER 0.1 74 0 0 0 2460 1 40 3 28 5 F1I1SHING SOW'ER O.OB 8B 0 0 0 2460 1 54 3 41 5 FINISHING SHOVEL 0.06 82 0 0 0 2460 1 46 3 33 Lmax: 64 Leq: 54

Table 2 Maritza East 1 ConstJUctIon NoiSe Analysis Mardi. 2000

X Y l000melers 3280 D EsIimlIIId EsIimIted Atmos.& Activity Idiit'I Equipllltllt Usage Level at5D' Number of Equipment AltOlllllous Equip. Number Name Name FadIIr (lab/d) AlbI Xl Yl DisH Machines SPL (l".J AItenuaIion L..

SITE PREPARATION DUMP TRUCK 0.16 91 0 0 0 3280 12 55 3 54 SITE PREPARATION SCRAPER 0.14 B8 0 0 0 3280 2 52 3 43 SITE PREPARATION BACKHOE 0.04 85 0 0 0 3280 1 49 3 31 SITE PREPARATION GRADER 0.05 85 0 0 0 3280 I 49 3 32 SITE PREPARATION DOZER 0.04 III 0 0 0 3280 1 44 3 26 SITE PREPARATION FRONT LOADER 0.16 79 0 0 0 3280 3 43 3 36 SITE PREPARATION GENERATCfl 0.4 78 0 0 0 3280 42 ·3 40 "I..maz: 55 leq: 55

2 EXCAVATION ROCKORIU 0.04 98 0 0 0 3280 1 62 5 43 2 EXCAVATION OUt&' TRUCK 0.16 91 0 0 0 3280 12 55 3 54 2 . EXCAVATION IlACl

3 FOUNDATIONS JACK HAMJ.ER 0.04 88 0 0 0 3280 1 52 5 33 3 fOUN)ATlONS CONCRETE MIXER 0.4 85 0 0 0 3280 6 49 3 49 3 FOUNDATIONS OUMPTRUCI< 11-16 91 0 0 0 3280 6 55 3 51 3 FOlJN)ATlONS PILEDRIVER 0.04 101 0 0 0 3280 1 65 5 .es 3 FOI.JWATIONS AIR COMPRESSOR 0.4 81 0 0 D 32110 1 45 3 '1T 3 FOUNDATIONS CONCRETE PUMP 0.4 82 0 0 0 3280 1 46 3 38 3 FOUNDATIONS PU .... 1 76 0 0 0 3280 5 40 3 44 3 FOUNDATIONS SAWS 0.04 78 0 0 0 3280 2 42 3 'Zl L.mIII: &5 leq: 55

4 ERECTION DERRICK CRAtE 0.04 88 0 0 0 3280 52 3 34 ERECTION JACKHAMMER 0.04 88 0 0 0 3280 1 52 5 33 " ERECTION SAWS 0.1 78 0 0 0 3280 2 42 3 31 4" ERECTION AIR COIII'RESSOR OA 81 0 0 0 3280 1 45 3 '1T ERECTION CONCRETE IlXER 0.16 85 0 0 0 3280 2 49 3 40 "4 ERECTION MOBILE CRANE 0.08 83 0 0 0 3280 lD 47 3 42 4 ERECTION PtEUMATlC TOOL 0.1 85 0 0 0 3280 2 49 5 '1T 4 EREC1lON PUMP 0.4 76 1 0 0 3280 6 40 5 38 4 ERECTION ROCKIlRILL 0.05 98 0 0 0 3280 1 52 5 44 J..mu: &2 Leq: 49

5 FINISHING ROCKIlRILL 0.05 98 0 0 0 3280 1 62 3 45 5 RNISHING DUMP TRUCK 0.16 91 0 0 0 3280 2 55 3 46 5 FINISI-IING AIR COMPRESSOR D.4 81 0 0 D '32S0' 1 45 3 '1T 5 RNlSHING BACKHOE 0.04 85 0 0 0 3280 1 49 3 31 5 FINISHING CONCRETE MIXER 0.16 85 0 0 0 3280 1 49 3 '1T 5 FINISHING CONCRETE PUMP O.os B2 0 0 0 3280 1 46 3 31 5 FINISHING DERRICK CRANE D.02 88 0 0 0 3280 1 52 3 31 5 RNISHING UOBILE CRANE 0.04 83 0 0 0 32110 10 47 3 39 5 FINISHING DOZER D.04 80 0 0 0 32110 1 44 3 26 5 FINISHING GRADER 0.02 85 0 D 0 3280 1 49 3 28 5 FINISHING JACKHAMMER 0.04 88 0 0 0 3280 1 52 5 33 5 RNSHING FRONT LOADER 0.04 79 0 0 0 3280 1 43 3 25 5 FINISHING PAVER 0.12 89 0 0 0 3280 t 53 3 40 5 RNiSHING PNEUMATIC TOOL 0.04 es 0 0 0 3280 2 49 5 33 5 FINISHING ROLLER D.l 74 0 0 0 3280 1 38 3 24 5 FINISHING SCRAPER 0.08 88 0 0 0 3280 1 52 3 ~ 5 FINISHING SHOVEL 0.06 82 0 0 0 3280 1 46 3 30 lIIIax: 62 Leq: 51

Table 3 Maritza East 1 Construction Noise Analysis MaIdI,2000

X Y 15Otmel!rS 4920 0 EstimIIId EstImated AImos.& AcIIvly AcMy Equiplllllrt Usage LewlatSO' Number of Equlpmlnt AnoInaIaus eqaip. Nalllber HallIe IiaIIII Factor (Table 2) AIbI XI Y1 !list 1 IIadIIMs SPL!L-) Alllnntioll ..... ,. SITE PREPAAATION DUMP TRUCK 0-16 91 0 0 0 4920 12 51 5 49 SITE PREPARATION SCRAPER 0.14 88 0 0 0 4e2O 2 48 5 38 SITE PREPARATION BACI

2 EXCAVATION ROO

3 FO\JIDATIONS JACK HAMf,ER 0.04 as 0 0 0 4920 1 48 7 27 3 FO~DATIONS CONCRETE MIXER OA 85 0 0 0 4920 6 45 5 44 3 FOUNDATIONS DUMP TRUCK 0.16 91 0 0 0 4920 6 51 5 <16 3 FOUNDATIONS I'lLEDRlYER 0.04 101 0 0 0 4920 1 61 7 40 3 FOUNDATIONS AIR COMPRESSOR 0.4 81 0 0 0 4920 1 41 5 33 3 FOUNDATIONS CO~PU"P 0.4 82 0 0 0 4920 1 42 5 34 3 FOUNDATIONS PUMP 1 16 0 0 0 4920 5 36 5 39 3 FOUNDATIONS SAWS 0.04 78 0 0 0 4920 2 38 5 23 IJna: 61 r;q: 50

4 ERECTION CERRJCK CRANE 0.04 BB 0 0 0 4920 1 48 5 30 4 ERECTION JA{;t( HAMMER 0.04 88 0 0 0 493J 1 48 7 27 ERECTION SAWS 0.1 78 0 0 0 4920 2 38 5 27 4" ERECTION AIR COMPRESSCR 0.4 81 0 0 0 4920 1 41 5 33 4 ERECTION COI«:RETE MIXER 0.16 85 0 0 0 4931 2 45 5 36 4 ERECTION MOEiLE CRANE 0.08 83 0 0 0 493J 10 43 5 3B 4 ERECTION PNEUMATIC TOOl 0.1 85 0 0 0 493J 2 45 7 31 4 ERECfION PLNP 0.4 76 1 0 0 4920 6 36 7 32 EREcrION ROCK DRILL 0.05 98 0 0 0 4920 1 58 7 3B " u-: 58 Leq: 44

5 FINISHING ROCKCRll 0.05 9B 0 0 0 4920 1 58 5 41 5 Flt.lSHING IUIPTRUCK 0.16 91 0 0 0 4920 2 51 5 42 5 Flt.lSHlNG AIR COMPRESSOR 0.4 81 0 0 0 492Q- 1 41 5 33 5 FINISHING BACKJ«)E 0.04 85 0 0 0 4920 1 45 5 27 5 FINISHING CONCRETE MIXER 0.16 85 0 0 0 4920 1 45 5 33 5 FINISHING CONCRETE PUMP 0.08 82 0 0 0 4920 1 42 5 27 5 FINISHING DERRICK CRANE 0.02 BB 0 0 0 04920 1 48 5 27 5 F1N1SIING MOBIlE CRANE 0.04 83 0 0 0 493J 10 43 5 35 5 FINISHING DOZER 0.04 eo 0 0 0 4920 1 40 5 22 5 FINISHING GRADER 0.02 85 0 0 0 4920 1 45 5 24 5 FINISHING JACKHAMMER 0.04 BB 0 0 0 4920 1 48 7 27 5 FINISHING fRa\IT LOADER 0.04 79 0 0 0 4920 1 39 5 21 5 FINISHING PAVER 0.12 89 0 0 0 4920 1 49 5 35 5 FINISHING PNEUMATIC TOOL 0.04 85 0 0 0 4920 2 45 7 27 5 FINISHING ROLLER 0.1 74 0 0 0 4920 1 34 5 20 5 FINISHING SCRAPER 0.08 88 0 0 0 4920 1 48 5 33 5 FtllSHING SHOVEL 0.06 82 0 0 0 4920 1 42 5 25 lmII: 58 Leq: 46

Table 4 Maritza East 1 Construction Noise Analysis MaIdI,2000

X Y 2DOOmeierS 6560 0 EsIIII1idId EstimatId AImDs.& Activity Adivily Equipment Usage livelliSO' NInnIIw riI EquipIIIenl AllDlllllDus Equip. Number Name Name FIdDr (f1ble2) AIIR X1 Yl !list 1 MacIIIDes SPL (I..,.) AItenuIIion L...

sITe PREPARATION DUMP TRUCK 0.16 91 0 0 6!i6O 12 49 46 SITE PREPARATION SCRAPER 0.14 88 0 0 0 6!i6O 2 46 6 35 sITe PREPARATION BAa

2 EXCAVATION ROCKDRIU 0.04 98 0 0 0 65IiD 1 5& 8 33 2 EXCAVATION CUMPTRUCK 0.16 91 0 0 0 65eO 12 49 6 46 2 EXCAVATION BACKHOE 0.16 85 0 0 0 6560 1 43 6 29 2 EXCAVATION DOZER 0.16 eo 0 0 0 6560 1 38 6 24 2 EXCAVATION FRONTLOAOER 0.16 79 0 0 0 65eO 3 "S1 6 2B 2 EXCAVAilON AIR COMPRESSOR 1 91 0 0 0 65eO 1 39 6 33 2 EXCAVATION GENERATOR 0.4 78 0 0 0 6560 4 36 6 32 2' EXCAVATION JACKHAMMER 0.1 88 0 0 0 65BO 1 46 8 'IT 2 EXCAVA110N PUMP 0.4 78 0 0 0 6560 6 34 6 32 2 EXCAVATION SHOVEl 0.2 82 0 0 0 6560 2 40 6 30 I.nIIIc 5& Leq: 41

3 FOlJNDof.TlONS JACKHAMMER 0.04 88 0 0 0 6560 1 46 8 23 3 FOUNDATIONS CONCRETE MXER 0.4 85 0 0 0 6560 6 43 6 41 3 FOUNDA11ONS DlN'TRUCK 0.16 91 0 0 0 6560 6 49 6 43 3 FOlWDA11ONS PILEDRIVER 0.04 101 0 0 0 65eO 1 59 8 36 3 FOUNDA11ONS AIR COMPRESSOR 0.4 81 0 0 0 6560 1 39 6 29 3 FOUNDATIONS CONCRETE PUMP OA 82 0 0 0 6560 1 40 6 30 3 F0IJN0A11ONS PUMP 1 78 0 0 0 6560 6 34 6 36 3 FOUNDATIONS SAWS 0.04 78 0 0 0 6560 2 36 8 19 Lma: 51 L8q: 46

4 ERECTION DERRICK CRANE 0.04 88 0 0 0 6560 1 46 6 :16 4 ERECTION JACKHAMMER 0.04 88 0 0 0 6560 1 46 8 23 4 ERECTION SAWS 0.1 78 0 0 0 6560 2 36 6 23 4 eRECTION AIR COMPRESSOR 0.4 81 0 0 0 6560 1 39 6 29 4 ERECTION CONCRETE MIXER 0.16 85 0 0 0 6560 2 <43 6 32 4 ERECTION MCBLECAANE 0.08 83 0 0 0 6560 10 41 6 34 4 ERECTION PNElJMl.TICTOOI. 0.1 85 0 0 0 6560 2 43 8 Z1 4 ERECTION PUMP 0.4 78 1 0 0 6560 6 34 8 2B 4 ERECTION ROCK DRILL o.os 98 0 0 0 6560 1 56 8 34 Lma: 56 1Aq: 40

5 FINISHING ROCK DRILL 0.05 98 0 0 0 65eO 1 5& 6 "S1 5 FINISHING DU"" TRUCK 0.16 91 0 0 0 65e0_ 2 49 6 38 5 FINISHING AIR COLFRESSOR 0.4 91 0 0 0 65al 1 39 6 29 5 FINISHING BACKHOE 0.04 85 0 0 0 65eO 1 43 6 23 5 FINISHWG CONCRETE MIXER 0.16 85 0 0 0 65IiD 1 43 6 29 5 FINISHING CONCRETE PU"" 0.08 82 0 0 0 6560 1 40 6 23 5 FINISHING DERRICK CRANE 0.02 68 0 0 0 6560 1 46 6 23 5 FINISHING MOBILE CRANE 0.04 83 0 0 0 6560 10 41 6 31 5 FINISHING DOZER 0.04 80 0 0 0 6560 1 38 6 18 5 FINISHING GRADER 0.02 85 0 0 0 6560 1 <43 6 20 5 FINISHING JACK HAtooWER 0.04 . 68 0 0 0 6560 1 46 8 23 5 FINISHING FRONT lOADER 0.04 79 0 0 0 65BO 1 37 6 17 5 FINISHING PAVER 0.12 89 0 0 0 6560 1 47 6 32 5 FINISHING PNOUMATIC TOOl 0.04 85 0 ,0 0 6560 2 43 8 23 5 FINISHING ROLLER 0.1 74 0 0 0 6560 I 32 6 16 5 FINISHING SCRAPER 0.08 68 0 0 0 6560 1 46 6 29 5 FINISHING SHOVa 0.06 82 0 0 0 6560 . 1 40 6 22 LnIax: 56 Leq: 43

Table 5 Maritza East 1 Construction Noise Analysis IIarCh, 2000

X Y 3000meten 9840 0 Estimated EstiIIIiIIId Abnos.& ActivIty ActivIty EquIpmIDt Usage Level It SII" Number of Equipmlnt Ananafous Equip. Number Name NaIne Factor (Table2) AIIn X1 Y1 Dist1 IIacIIIa. SPL II-) Allenuatioll t.... ,. SITE PREPARATION OUMPTROO< 0.16 91 0 0 0 9840 12 45 7 41 SITE PREPARATION SCRAPER 0.14 88 0 D 0 9840 2 42 7 30 SITE PREPARATION BACl

2 EXCAVATION ROO< DRILL 0.04 98 0 0 0 9840 1 52 10 28 2 EXCAVATION OUMPTRIJCK 0.15 91 0 0 0 9840 12 45 7 41 2 EXCAVATION 'BACl

3· FOUNDATIONS JACKHAMPIS 0.04 88 0 0 0 9B4O 1 42 10 18 3 FOUNDATIONS CON~MIXER 0.4 as 0 0 0 9B4O 6 39 7 36 3 FOUNDATIONS DUMP TRUCK 0.16 91 0 0 0 9B4O 6 45 7 38 3 FOUNDATIONS PILEDRIVER 0.04 101 0 0 0 9840 1 55 10 31 3 FOUNDATIONS AIR COMPRESSOR 0.4 81 0 0 0 9840 1 35 7 24 3 FOUNDATIONS cONCRETE PUMP 0.4 82 0 0 0 9840 1 36 7 25 3 FOUNDAllONS PUMP 1 76 0 0 0 9840 6 30 7 31 3 FOUNDATIONS SAWS D.D4 78 0 0 0 9B4O 2 32 7 14 IJna: I !:!I: 41 4 ERECTION DERRICK CRANE D.D4 88 0 0 0 9840 1 42 7 21 4 ERECTION JACKHAMMER 0.04 88 0 0 0 9B4O 1 42 10 18 4 ERECTION SAWS 0.1 78 0 0 0 9B4O 2 32 7 18 4 ERECTION AIR COMPRESSOR 0.4 81 0 0 0 9840 1 35 7 24 4 ERECTION CONCRETE MIXER 0.16 as 0 0 0 9B4O 2 39 7. 27 4 ERECTION MOBILE CRANE 0.08 83 0 0 0 9840 10 37 7 29 4 ERECTION PNEUMATICTOOL 0.1 as 0 0 0 9840 2 39 10 22 4 ERECTION PUMP 0.4 76 1 0 0 9840 6 30 10 23 4 ERfCTION ROa

5 FINISHING ROa

TableS Maritza East 1 Power Plant Octave spectra of the sources in dB(A)

81.7 97 JJ 108.0 112.5 114.9 114.1 112.3 109.1 99.0 Cooling Tower Une 120.4 0.0 65.6 84.8 99.9 110.4 110.8 112.0 110.2 104.0 95.9 BulldoZer 2 Point 117.3 0.0 65.6 84.8 99.9 110.4 110.8 112.0 110.2 104.0 95.9 Bulldozer 1 Point 117.3 ·0.0 55.6 68.8 73.9 78.4 92.8 100.0 108.2 108.0 103.9 PrecipitatorS Point 112.2 0.0 79.6 89.8 98.9 102.4 102.8 104.0 101.2 97.0 87.9 10 Fan 2 Point 109.5 0.0 79.6 89.8 98.9 102.4 102.8 104.0 101.2 97.0 87.9 10 Fan 1 Point 109.5 0.0 73.7 84.9 96.0 99.5 101.9 102.1 99.3 96.1 89.0 iConveyor 12 Une 107.6 0.0 73.4 84.6 95.7 99.2 101.6 101.8 99.0 95.8 88.7 'COnveyor 9 Line 107.4 0.0 73.4 84.6 95.7 99.2 101.6 101.8 99.0 95.8 88.7 COnveyor 10 Una 107.4 0.0 .70.6 84.8 90.9 95.4 101.8 101.0 98.2 97.0 85.9 StackerlReclaimer 2 Point 106.5 0.0 70.6 84.8 SO.9 95.4 101.8 101.0 98.2 97.0 85.9 StaCl

3.0 87.0 78.2 86.3 87.8 83.2 81.4 80.6 75.4 65.3 Transfer Tower 1 East Alea 92.1 3.0 67.0 78.2 86.3 87.8 83.2 81.4 80.6 75.4 65.3 TransferTower 1 West Area 92.0 3.0 a6.6 77.8 85.9 87.4 82.8 81.0 80.2 75.0 64.9 Tl8nsfer Tower 1 South Area 91.6 3.0 66.6 n.8 85.9 87.4 82.8 81.0 80.2 75.0 64.9 Transfer Tower 1 Nor1h Area 91.6 3.0 66.5 77.7 85.8 87.3 82.7 80.9 80.1 ·74.9 64.8 Transfer Tower 5 North Area 91.5 66.5 77.7 85.8 87.3 82.7 80.9 80.1 74.9 64.8 Transfer Tower 3 South Area 91.5 3.0 3.0 66.5 77.7 85.8 87.3 82.7 80.9 80.1 74.9 64.8 TransferTower2 East Area 91.5 3.0 66.5 77.7 85.8 87.3 82.7 80.9 SO.1 74.9 64.8 Transfer Tower 5 SOuth Area 91.5 3.0 61t5 77.7 85.8 87.3 82.7 80.9 SO.1 74.9 64.8 Tl8nsferTower 3 North Area 91.5 66.4 77.6 85.7 87.2 82.6 80.8 80.0 74.8 64.7 Transfer Tower 5 West Area 91.5 3.0 3.0 66.4 77.6 85.7 87.2 82.6 80.8 SO.O 74.8 64.7 Tl8nsfer Tower 5 East Area 91.5 66.4 77.6 85.7 87.2 82.11 80.8 SO.O 74.8 64.7 Transfer Tower 2 South Area 91.5 3.0 66.4 85.7 87.2 82.6 80.8 . 60.0 74.8 64.7 Transfer Tower 4 NOrth Area 91.4 3.0 n.6 66.4 77.8 85.7 87.2 82.8 BO.8 BO.O· 74.8 64.7 T ...... srerTower 4 SOUIh Area 91.4 3.0 68.4 77.6 85.7 87.2 82.6 BO.8 80.0 74.8 64.7 jTrans1erTower4 East Area 91.4 3.0 66.4 77.6 85.7 87.2 82.6 BO.8 80.0 74.8 84.7 jTransferTower 2 North 91.4 3.0 !Area 66.3 77.5 85.6 87.1 12.5 BO.7 79.9 74.7 64.6 jTransferTower 4 West Area 91.4 3.0 3.0 &6.3 77.5 85.6 87.1 82.5 80.7 79.9 74.7 64.6 ITransfer Tower 3 East 91.3 !Ar- 66.3 77.5 85.8 87.1 82.5 SO.7 79.9 74.7 64.6 Transfer Tower 3 West Area 91.3 3.0 tl6.2 77.4 85.5 87.0 82.4 80.& 79.8 74.6 64.5 TransfarTower 2 West 91.2 3.0 /Area 0.0 82.8 13.8 81.9 83.4 78.8 77.IJ 76.2 71.0 60.9 Transfer Tower 6 Roof Area 87.6 61.1 72.3 11004 81.9 77.3 75.5 74.7 89.5 59.4 TransterTower 1 Roof Area 86.2 0.0 0.0 60.3 71.5 79.6 81.1 76.5 74.7 73.9 68.7 58.6 Transfer Tower 5 Roof Area 85.3 0.0 60.3 71.5 79.6 81.1 78.5 74.7 73.9 88.7 58.8 Transfer TCMer 3 Roof /Area 85.3 .0.0 60.3 71.5 79.6 81.1 78.5 74.7 13.9 68.7 58.6 ITransfwTower 2 Roof Area 85.3 71.2 79.3 BO.8 76.2 74.4 13.6 68.4 58.3 Transfer TCMer 4 Roof ArM 85.1 0.0 eo.o

Sound Sources

SrcType Leq dB(A)

Cooling Tower Une 33.0

Sta~rlRec;laimer 2 Point 23.6 Boiler 2 South Area 22.5 S1adcerlRecJamer 1 Point 21.3 COnveycr12 line 20.6 Precipilatols Point 19.8 Fine Crusher South Area 19.5 ~ Crusher West Area 19.4 co.sa Crusher South !Area 19.3 Fine Crusher West Area 19.0 Fine Crusher East Area 18.3 Conveyor 14 Une 17.4 Boiler 2 West Area 17.4 TUlbine Building South ~ 16.5 T~~rTower6Sp~ Area 15.9 Bulldozer 1 Point 15.4 tier' West Area 15.0 Boller 1 South Area 14.8 Transfer Tower.5 west 14.6 Transfer Tower 5 South 14.6 Conveyor 15 Une 13.8 =Area 13.4 Boiler Support SOuth '1'ransfer Tower 6 West ~ 13.2 Conveyor 6 Une 13.2 Conveyor 7 Une 13.1 Bulldozer 2 Point 12.8 ConveyorS Line 12.5 Boiler 2 Roof 12.4 Transfer Tower 6 East 12.4 Boiler 1 Roof ==Area 11.7 TransferTower4 So~ Area 11.6 Transfer Tower 4 west Area 11.4 Conveyor 13 Ule 11.3 Coanre Crusher Roof Area 10.7 Fine CruSher Roof Ar8a 9.6 Conveyor 8 U1e 9.1 Transfer Tower 3 SO~ Area 8.8 Conveyor:! Une 8.5 10 Fan 2 Point 6.3 Turbine Building East Area 6.2 10 Fan 1 Point 6.0 COI1V!lYDl' 1 Line 5.8 Conveycr1D Une 5.6 ConveyorS line 5.5 Conveyor " Une 4.7 Transfer Tower 1 West Area 4.4 Boler Support Roof Area 4.1 Transfer Tower 6 Roof Area 3.6 Fine Crusher NOr1h Area 3.6 TransferTower 3 West Area 3.5 Transfer Tower 1 South Area 3.5 Coarse Crusher North Area 3.4 Transfer Tower 2 West. Area 3.3 qonveyor4 Une 3.2 3.2 ~IConwyor3 Une Coarse Crusher East . Area 3.0 I ~ell SoundPlAN 5.0.-1/1712000 (c) 1986·2000 Braunstein+Bemdt GmbH Maritza East 1 Power Plant Source Contribution Levels dB(A)

I SrcType Leq cIB(A)

Boiler 2 North 2.9 T~rTower2~ Area 2.9 Boiler 1 North Area 2.5 TurtJine BUilding Roof Area 2.0 Boiler Support East Area 1.1 Transfer Tower 1 Roof Area 1.0 TransferTawer 2 Roof Area -0.4 Transfer Tower 5 Roof Area -0.5 Transfer Tower 4 Roof Area -0.6 Boiler 2 East Area -0.7 Transfer Tower 3 Roof Area -0.8 Boller 1 East Area -1.0 Turbine Building North -1.1 Transfer Tower a Ncrth -1.9 Transfer Tower 1 Ncrth -2.6 Transfer Tower 1 East -2.8 Transfer Tower 2 Ncrth -2.8 Transfer Tower 5 Ncrth -3.1 Transfer Tower 3 Ncrth -3.7 Transfer Tower 4 Ncrth -3.8 Transfer Tower 4 East -3.8 TransfarTower 2 East -3.8 Transfer Tower 5 East -4.0 Boiler Support Nor1h -4.1 Transfer Tower 3 East -4.1 Transformer 1 Point -5.9 Transformer 2 Point -7.0

Buldozer2 Paint 26.2 Boiler 2 South 21.1 stackerJRecJaimer 2 Point 18..9 Fine Crusher South Area 17.9 Fine Crusher West Area 17.9 ConYeyor12 Line 17.8 Boiler 2 West Alee 17.5 StackerIReclaJmer 1 Point 17.3 Coarse Crusher West Area 16.11 Turbine BuiJcJing South Area 16.9 Coarse Crusher SOuth Area 16.8 Precipitators Point 16.0 Cooling Tower Une 15.3 Conveyor 14 Une 15.1 Boiler 1 West Area 13.4 Transfer Tower 1 West Area 13.0 Buldozer 1 Point 13.0 BoBer Support Seuth Area 13.0 Transfer Tower 1 South Area 12.6 TranSfer Tower 5 South Area 12.3 Transfer Tower 4 West Area 12.2 Transfer Tower 4 South Area 12.2 Transfer Tower 5 West Area 12.2 Transfer Tower 6 South Area 11.B TransferTower 6 weSt Area 11.5 Beiler 2 Roof Area 10.7 Conveyor 7 Line 10.3 Boiler 1 Roof Area 10.3 Conv 6 Line 10.2

Page 2

9.8 9.3 8.4 8.2 7.8 8.1 5.9 5.9 5.6 5.5 4.9 4.9 4.6 3.6 3.2 3.2 3.2 2.7 2.4 1.6 1.3 1.0 1.0 1.0 0.8 0.8 0.7 0.3 0.2 -0.3 -1.5 -1.8 -1.7 -2.4 -2.7 -2.9 -3.0 -3.4 -4.4 -4.4 -5.2 -5.2 -5.3 -5.4 -5.5 -5.S -5.8 -6.3 -6.4

37.7

32.0 30.8 I SoundPLAN 5.0 -1/17/2000 (e) 1986-2000 Braunstein+Bemdt GmbH Maritza East 1 Power Plant Source Contribution Levels dB(A)

Name SrcType Leq dB(A)

10 Fan 2 Point 29.5 Boiler 2 sOuth Area 25.2 rrurbine Building East Area 24.7 PreoipitatOrS Point 23.8 BoRer Support East Area 22.8 Conveyor 12 Une 22.S eooRng Tower Une 22.4 Boiler 2 East AJea 22.3 BoiIer1Eas1 Area 21.5 Turbine BuIldIng Roof ~ 21.2 Stacker/ReClaimer 1 Pcmt 20.7 Slad

(e) 1986-2000 Braunstein+Bemdt GmbH SoundPLAN 5.0 -1/17/2000 Maritza East 1 Power Plant Source Contribution Levels dB(A)

1.0 1.0 0.6 0.5 0.0 0.0 -0.4 -1.2 -1.3 -1.5 -1.8 -1.8 -1.9 -2.1 -2.8 -3.2 -3.6 -3.7

Turbine Building East 26.1 Bulldozer 2 24.5 ButIcIozer 1 23.9 Boiler 2 South 21.8 Boiler Support East 20.4 Boiler 2 East 1a9 Boller 1 East 1a7 Boiler 1 SOUth 18.7 Boler Support Roof 17.5 Tumln. Building Roof 17.4 Conveyor 12 15.3 Coarse Crusher East 15.3 coarse Crusher SOUIh 15.0 SlacketiReclaimer 1 14.6 Slacka1Reclalmer 2 . 13.9 U/bine Buildil1:l South 13.3 Boiler 2 Roof 12.5 Boiler 1 Roof 12.1 Conveyor 10 11.4 Tl1lnsfer Toww 1 East 11.3 TranSfel'Tower 5 South 11.1 Transfer Tower 5 East 11.1 Conveyor 7 11.0 Transfer Tower 4 East 10.9 T~ferTower4Sou~ 10.9 Transfer ToWer 1 South 10.8 Transfer Tower 2 East 10.6 Transfer TO\NeI" 2 South 10.4 Conveyor 14 10.3 Transfer Tower 3 South 10.3 10.1 10.1 9.9

Name I SItlType Leq dB(A)

Boiler Support South Area 9.8 ConveyorS Line 7.9 ConveyorS Line 7.6 10 Fan 1 Point 7.5 ~8 Line 7.2 Transfonner1 Point 8.8 Conveyor 11 Une 6.7 10 Fan 2 Point 6.6 Coar.se CllISher Roof Area 6.0 Conveyor 4 Une 5.6 Boiler Support North Area 5.6 Conveyor 3 Une 5.6 BoIer2Na1h Area 3.4 Boiler 2 West Area 2.9 Turbine Buading North Area 2.8 Boiler 1 West ~ 2.7 Boiler 1 Nor1I1 Area 2.8 Conveyor 2 Une 2.4 Fine CruSher West (Vee 2.2 Fone Crusher South Area 2.2 Fine Crusher East Area 1.8 Fine Crusher North Area 1.8 Prac:IpItators Point 0.5 COmeyor15 Line 0.1 Conveyor 1 Une 0.0 ! CoaIse Crusher North Area ~.7 '~ Coarse Crusher West Area -1.1 Transl'erTower1 Reof Area -3.4 Transl'erTowere South Area -3.6 TransferTawer6 North Area -3.8 Transfer Tower 6 Roof -3.8 TransterTower 6 West :: -3.8 Transfer TCJWeI' 6 East -3.8 TransferTower4 Root :: -4.2 Transfer Tower 2 Root Area -4.4 Transfer Tower 3 Roof Area -4.6 Fine Crusher Roof Area -5.1 Transfer Tower 5 North Area -6.2 Transfw Tewer 1 West Area -6.5 Transfer Tower 4 North Area -8.8 Transfer Tower 1 North Area -8.7 Transfer Tower 6 West Area -B.6 Transfer Tower 4 West Area -B.9 Transfer Tower 2 North Area -7.0 Transfer Tower 3 North Area -7.5 TransterTower2 West Area -7.5 Transfer Tower 3 West Area -7.8 Conveyer 13 Une -6.4 Transfer Tower 6 Roof Wea -11.8

I P~6

I~ Appendix D PB Power

D. PUBLIC CONSULTATION AND DISCLOSURE MATERIALS (53 pages)

Document No. 62160AlPBP/000001 0774R140.dodS1/11w PBPower

NEWSPAPER AND MAGAZINE ARTICLES ABOUT THE PROPOSED AES-3C MARITZA EAST 1 POWER PLANT

Document No. 62160AJPBP/OOOOOl 0714R140.doclS2I2Iw Newspaper and Magazine Articles About the Proposed 600 MW (Net) Maritza East 1 Power Project:

January 12-18, 1998 Newspaper "Kanman" ("Capital") page 20 "He MO>Ke eHeprl1t1HI1 ll06J.1Ta ,Qa ynpaBJ1~saT nosu1TYlKaTa Ha HEK" "Energy lobbies are not allowed to manage NEK's policy"

January 12 ,1998 Newspaper "CTilH~apT" ("Standard") page ... "TE~"Pyce" 06HBeH 3a npHBaTM3a~HSI" ·TPP Rousse put up for privatizationn

March 25,1998 Newspaper"Cera" ("Now") page •.. ''HEK KaHM 'Iy)K,QeH~M 3a "Map .. ~a -M3TOK"" "NEK invites foreigners to participate in the bid for the Maritza East 1 TPP'

March 25, 1998 Newspaper "Financial Times" page 18 Invitation for offers for the implementation of the Maritza East 1 power project; includes procedures for evaluation, award and execution of proposals

March 25,1998 Newspaper "napM''''Money'' page 17 Invitation for offers for the implementation of the Maritza East 1 power project; includes procedures for evaluation, award and execution of proposals

March 30, 1998 Newspaper "SaHKep'b" ("Banker") page_ "3anO'IBa npO~a)K6aTa Ha 22 BE~-a" "The sale of 22 HPPs starts"

April 8,1998 Newspaper "napM" ("Money") page_ "rOTOBa e eHep rM MHa Ta cTpaTe rMH ,QO 2001 r." ·The energy strategy up to year 2001 is ready"

April 8,1998 Magazine "Project Finance International" pag&48" Power bids invited

May 29,1998 Newspaper "SaHKepD"{"Banker") page 13 "4y)K,QeH~M ••3 Kynyaa T en e KTpo~eHTpanMTe" • Foreigners buyout power stations'

June 1 -7,1998 Newspaper "SaHKepb" ("Banker") page 12 "3aB'bpWM eAHa ronHMa 6MTKa cpel14Y SlApe HOTO no6 .." " A big battle against nuclear lobby has finished" June 11, 1998 Newspaper "CTaH,QapT" ("Standard") page 9 "HEK: CaMO 3 ~eHTpan .. OCTaBaT A'bplKaBHM" • NEK : Only 3 power plants will remain state owned'

June 15 - 21, 1998 Newspaper "Kanwran" ("Capital") "T'hprbT 3a "MapM ... a-M3ToK 1"Mo)l(eAa ce KOMnpoMeTHpa" • Bid for" Maritza East 1" TPP could be discredited'

June 20, 1998 Newspaper "Cera" ("Now") page 5 "HoB .. Te eHepr""HM MOIQHOCTl'IlQe 6'hABT 'tacTHH" • New power generating facilities will be private owned'

July 01, 1998 Magazine "Project Finance Intemational" page _ • EBRD to find advisers·

August 1 -7,1998 Newspaper "Kanwran" ("Capital") page 16 "'KpeA" CYMc"lQe npoAaBa 22-TSBEU" ""Credite Suisse" will sell 22 HPPS'

August 8 -14,1998 Newspaper "Kan'wran" ("Capital") page 20 '''PM ne'fen6a nOA 10% HEK He Mome Aa M3n'hnHM MHBeCTM", .. OHHaTa CM npo rpaMa" "NEK can not fulfill its investment program if its profit is to be lower than 10%"

September 18,1998 Magazine "Project Flnanciallntemational" page 11 "Bulgaria to shut down 1,760 MW of nudear capadty, seek US $946 million in new power projects"

October 17,1998 Newspaper"AeMolCp8.~MJ1" ("Democracy") page 7 "Bna raT 780 MnH.lUaTcK M AonapM B TEU "MapM3a iI13TOK 1"" • US $780 million will be invested in Maritza East 1 TPP'·

October 17,1998 Newspaper "TPYA" ("Labour") page •• "AMepMKaH",M BnaraT 700 MnH.lQaTCKM ,QonapM B Hawa TEU" • Americans will invest US $700 million in the Maritza East 1 TPP'

October 18,1998 Newspaper ''TPY,Q'' ("Labour") page 8 ''700MnH.~aTcKM AonapM AaBaT CALLt3a TEU"Map .. 3a M3TOK 1"" .. USA invests US $700 million in the Maritza East 1 TPP" October 18,1998 Newspaper "24 '1aca" ("24 hours") page 2 'lUaTcKa 6aHKa lI.\e HM npaBM HOB a TELf' "USA Bank will construct a new TPP'

October 18, 1998 Newspaper "SaHKepD" ("Banker") page •• "HEK H3Ka'tM MHseCTMLlMOHHHJI 011MMn" "NEK climbed the Olympic of investments"

October 20,1998 Newspaper "Cera" ("Now") page 15 ''Ocj:JwOPHH MHBeCTMTopH noeMaT M3Hoca Ha TOK" "Off-shore investors will take command over the export of electricitY'

October 23 - 29,1998 Newspaper "168 'Iaca" ("168 hours") page_ ''06eaqaHMTe MHl1MapAH 3a eHepreTHKaTa -APyrMJI seK" "Billions of US dollars promised for the energy sector in the next millenium"

October 18,1998 Newspaper "KanMTaI1" ("Capital") page 15 "TbproBeTe C HEK - KaTO nperoBopM c nOTeH~HaneH lCynYBa't" • NEK's bids - negotiations with a potential buyef

October 26 - November 1,1998 Newspaper "SaHKep'b" ("Banker") page 13 "EHep rH "HaTa HM cTpaTe rMJI npe r'bpHa KIOMlOpa" "Coal energy strategy"

October 31 - November 6, 1998 Newspaper "KanHTal1" ("Capital") page 19 ''CBeTOBHaTa 6aHKa OTXB'bpnH eHeprM"HMJI 3aKOH M cTpaTerHJlTa" "World Bank rejected the energy act and coal energy strategy"

November 4, 1998 Magazine "Power Finance International" page _ "Power developer chosen"

November 19, 1998 Newspaper "TPYA" ("Labour") page _ ._ "HEK CMaJi Espona C 6anKaHcKM T'bP r 3a HaA 700 MnH. ~aTCKM Aonapa"

"NEK astounded Europa with a K Balkan" style bid for over US $700 million"

November 20, 1998 Newspaper "TPYA" ("Labour") page_ ''CKaHAan c nHCMOTO 3 a 6apTepMTe M Te~OBeTe" "Scandal with a letter for barters and TPPs" January 4, 1999 Newspaper "MOHMTOP" ("Monitor") page_ "K.,QMMMTPOB MM Ka3a, 'Ie MO>Ke Aa Me CB'bp>Ke C HEK" • K.Dimitrov told me he can arrange a contact with NEK"

"H$lMaWe Tbpr 3a "3 CM"" "There was no bid for 3 Cn

"TEU "MapM~a L>13TOK 1" ABAeHa 6e3 Tbpr" ·"Maritza East 1 TPP given without a bid:

"CAenKaTa aqe e nOPeAHM$lT npoBan" "The deal will be a failure"

January 06, 1999 Newspaper "C1'aHAClPT" ("Standard") page 7 "Cpeaqy eHep rent KaT a HMa AMpMlKHpaHa aTa Ka" "There is -a concerted attack against the energy secto('

January 07,1999 Newspaper "MOHMTOP" ("Monitor") page 15 "PennMKa" ·Rema~'

"HEK C'bBCeM 06'bpKa KOH~MTe C TEU "MapMQa-L>13ToK"" • NEK is in a mess with" Maritza East 1 TPP"

January 10, 1999 Newspaper "MoHHTOp" ("Monitor") page 2 ''OBliapOB 06BHHH npeMMepa 3a napH OT eHeprocAenKa" " Ovtcharov accused the Premier Minister for getting money from a deal for a power station"

January 26, 1999 Newspaper "MOHHTOP" ("Monitor") page 2 "B repMaHM$I He 3HaenM HMaqO 3a npMBaTH3a~H$lTa Y Hac" "In Germany people haven't known anything about the privatization process in Bulgaria"

January 27,1999 Newspaper "Penopyep" ("Reporter") page 4 "E6BP MCKa Aa MHBecTH-pa B TEUMapM~a-M3TOK 1" "EBRD wants to invest in Maritza East 1 TPP"

January 27, 1999 Newspaper "MOHMTOP" ("Monitor") page "_ "3CM" 06el1.\aaa cpMKcHpaHa LleHa Ha TOKa 3a 15 rOAMHM" "3 C promises flat price for electricity for a 15-year period" January 27,1999 Newspaper "Cera" ("Now") page 5 "TE'-"'MapMQa ~hTOK 1"l.I.\e npaBM TOK Ha MwneMe" U" Maritza East 1 TPP will generate electricity on a tolling basis"

January 27,1999 Newspaper "Tpy,Q" ("Labour") page 6 "Ao 920 MnH.l.I.\aTC KM ,Qonapa l.I.\e cTPYBa TE'-' "MapMQa-M3 TOK 1"" "Up to US $920 million total investment in Maritza East 1 TPP'

January 27, 1999 Newspaper ",QeMoKpaQMJI" ("Democracy") page ._ "920 MnH.l.I.\aTCKM Aonapa l.I.\e cTpYBa HOBaTa MOI.I.\HOCT B TE,-,"MapMQa-M3TOK 1"" "Maritza East 1 TPP will cost US $920 million"

January 27, 1999 Newspaper "A}'Ma" ("A word~') page _ 'tI-'e npo,QaBaT TOKa OT "MapMlla-M3ToK 1" Ha cpIIIKcKpaHH lleHM" • Electricity generated by Maritza East 1 TPP will be sold at a fixed price"

January 27, 1999 Newspaper "CTaH,QBpT" ("Standard") page 9 ''810MnH.~aTcKM Aonapa snara 3CM a "MapMQa-1II3ToK 1"" "3-C will invest US $810 million in Maritza East 1 TPp·

January 28, 1999 Newspaper "AHeaeH TpYA" ("Daily labour") page._ ''QcIIWopKa l.I.\e B'bpTM na pM Te 3a TE'-' "MapMQa-M3 TO K 1,m "Off-shore company will invest in Maritza East 1 TPP'

January 29 - February 4,1999 Newspaper "168 '1aca" ("168 hours") page 13-18 "CAenKaTa "MapMt,ta-M3ToK 1"=6 QeHTa 3a KlilnOBaT'IaC" "The Maritza East 1 deal =6 cents per one kwh"

January 29 - February 4,1999 Newspaper "KanMTan"("capital") page 18 'tI-'e nell en 111M OKono 30 MMnKOHa Aonapa "rO,QKWHO 3a 15 rOAMHK" "Eamings of US $30 million per year for a 15-year period"

February 6 -12,1999 Newspaper "KanKTan" ("Capital") page_ ''HJlKOnKO AYMM 3a eHepreTMKaTa" " A few words about the energy sector"

March 8, 1999 Newspaper "Financial Times" page_ "Action plan aims to raise power profile" AprilS -11,1999 Newspaper "168 'Iaca" ("Banker") page 14 "TEU"MapMQa - M3TOK 1" ce npeBp'bma B 3naTHa KOKOWKB 3a HEK" ""Maritza East 1 TPP is going to be a golden hen for NEK'

June 18,1999 Newspaper "r'bn'b60BCKM Becnt", page 4 ~IItHATClltPAHETO MO>KE AA 6'bAE rOTOBO nO-PAHO Interview with Jacob Menahem of Access International about the financing of the Maritza East 1 project

September 18-25,1999 Newspaper "KanMTal1" ("Capital") page._ "RWE me MHBecTMpa 1 MnpA.MapKM B eHepreTMKaTa" • RWE to invest OEM 1 billion in the energy sector"

September 21, 1999 Newspaper "CTaHAapT" ("Standard") page 9 "repMaHQM AaBa T 1 MnpA. MapKM 3a "MapMQa-M3 TO K"" "Germans ready to pay OEM 1 billion for Maritza East Complex"

October 11, 1999 Newspaper "24 'Iaca" ("24 hours") page ._ '~TCKM rMraHT BnM3a B"MapMQa M3TOK 1" " USA giant enters Maritza East 1 Project"

October 9 -16, 1999 Newspaper "KanMTal1" ("Capital") page 15 "AMepM KaHCKaTa AES lQe CTPOM "MapMQa M3TO K 1"" • American AES will build Maritza East 1 TPP"

October 11-17, 1999 Newspaper "SaHKep'b" ("Banker") page 1,11,13 "'AMepMKaH EneKTpMK CMcTeMc" ce 3aeMa c "MapMQa IIt3TOK 1"" • AES will invest in Maritza East 1TPP"

October 14, 1999 Newspaper "r'bn'b60BCKM BeCTM", page 1 3HEPrMEH ntrAHTmE M3rpA>K,IlA TEU "MAPlltUA-M3TOK 1" Article describes the first visit of the AES representatives to the Maritza East 1 plant site and discusses AES becoming a major stakeholder of the 3-C project development. company, responsible for constructing and operating the new plant for a 1S-year period.

November 14, 1999 Newspaper "24 '1aca" ("24 hours") page 10 '''KHMraTa Ha rMHec"Ha 6'hnrapCKM" ·"Guiness boo\( in Bulgarian"

November 19 - 25,1999 Newspaper "168 '1aca" ("168 hours") page 13,18 "B"MapMQa M3TOK" 3aAeHcTBa npMHQMn'hT "MeraBaT -'iOaeK"" "The principle of" 1 MW -1 man" put into motion for the Maritza East 1 Project" November 26,1999 Newspaper "r'bJ1'b60BCKH BecTH" ("Galabovski news"), page 2· 3 AESmE 1.13rPAAI.1 EAHA OT HA~·4MCTMTE LtEHTPAmt HA BbrnKUA B CBETA Interview with Richard Marclon about the major financial, technical, environmental and socio-economic aspects of the AES Maritza East 1 project.

December 29, 1999 Newspaper "r'hJ1D60BCKH BeCTM" ("Galabovski news"), page 3 AYMATA HA O6I.UMHATA Letter by the mayor of Galabovo, Mr. Stoyanov, addressed to the Prime Minister of Bulgaria. Letter expresses concerns of the Galabovo community in regard to the issues of employment and other socio economic aspects associated with the proposed Maritza East 1 project, as well as the Maritza East 2 power plant, the briquette factory, Energoremont, and the Troynaovo 1 mine.

January ii, 2000 Newspaper "Cera" ("Now") page 6 "AMepM Ita HC Ka c1JHpMa oTKpMBa 3000 pa60TH M MeCTa B rbn'b6oBO" • American company projects up to 3,000 construction jobs in Galabovo'

January 13, 2000 Newspaper "CTapo3aropcKH HOBMHM" ("Stara Zagora News") page 2 C'b06~eHHe 3a o6~ecTBeHo o6c'b*AaHe Ha AOKnaAa 3a OBOC 38 HOBaTa TE~ "MapML\a M3TOK 1'''' "Public Hearing Announcement for the Maritza East 1 TPP EIA Reporf'

January 13, 2000 Newspaper "MapML\a M3TOK" ("Maritza East") page 11 C'b06~eHMe 3a o6~ecTBeHo o6c'b*AaHe Ha AOKnaAa 3a OBOC 3a HOBaTa TE~ 'MapHLta 1.13TOK 1'·' "Public Hearing Announcement for the Maritza East 1 TPP EIA Reporf'

January 13, 2000 Newspaper "Starazagorski Novini", page 2 CbO~EHME Public hearing announcement to the Galabovo community re: Maritza East 1 project public hearing date of February 16, 2000 at the House of Culture, Galabovo at 1:30 pm.

January 15·21,2000 Newspaper "Kamrran" ("Capital") page 17 "EneKTpoKoMnaHMRTa K AES npeAoroBapRT npoeKTa 3a TE,","MapMLta M3TOK 1"" • National electric utility and AES renegotiate the project terms for Maritza East 1 TPP·

January 20, 2000 Newspaper "TPYA" ("Labour") page _ "HEK nMwe MepKM 3a 3aMeCTsaHe Ha AE~" "NEK prepares measures for replacement of NPP" January 26, 2000 Newspaper "r'bn'b60BCKM BeCTH" ("Galabovski news") page 4 C'b06~eHMe 3a o6~ecTBeHo o6c'b*AaHe Ha AOKnaAa 3a OBOC 3a HOBaTa TE~ 'MapHQa ~3TO K 1'''' Public hearing announcement to the Galabovo community re: Maritza East 1 project public hearing date of February 16,2000 at the House of Culture, Galabovo at 1;30 pm.

January 29 _ February 4, 2000 Newspaper "KamlTaJ1" ("Capitar') page 17 "Kora H KaK ~e ce npMBaTM3Mpa HEK" "When and how NEK will be privatized"

February 07, 2000 Newspaper "MOHMTOP" ("Monitor") page 12 "npepa3 r n e*AaT cAen UlTe 3a "MapM Qa ~3 TO K" -1 M 3" "Deals for Maritza East 1 and Mantza East 3 TPPs under re-consideration"

February 14, 2000 Newspaper "r'bn'b60BCKH BeCTM" ("Galabovski news") page,1,3 C'bo6~eHMe 3a o6~ecTBeHo o6c'b*AaHe Ha AOKnaAa 3a OBOC 3a HOBaTa TE~ 'MapMQa ~3TO K 1'" Public Hearing Announcement for the Maritza East 1 TPP EIA Report. Article also mentions participation of Richard Mardon, the Maritza East 1 project manager, in an energy projects investment meeting organized by the International Investments Agency in Sofia, 4 February 2000.

TpaHcnopTHO pa3nHcaHHe Ha cneQHaJ1HMTe aBT06ycH 3a o6114eCTBeHOTo 06C'bl1CAaHe Shuttle bus schedule

"AES MapHQa ~3TOK 1" TOnpoeneKTJ)H'IecKa QeHTPana C MOIl4HOCT 670 MBT (6pYTo) M3no.myBall4a 3a ropHBo nHrHHTHM B'brnHlQa" "670 W.J (gross) lignite-firing AES Maritza East 1 TPP"

February 17, 2000 Newspaper ",QeMoKpaQHH" ("Democracy") page 3 "180MnH.,Qonapa AaBaT aMepHKaHQM 3a TEU"MapHQa H3TOK 1"" "Americans give US $180 million for Maritza East 1 TPP"

February 18, 2000 Newspaper "Kew" ("Cash") page 4 "ESBP MHBeCntpa 100 MnH. lUaTcRH Aonapa cpelQY AHnOBe B eHep rOAPy*ecTBa" "EBRD will invest US $100 million in private power plants"

February 22, 2000 Newspaper "r'bITb60BCKM Becm" ("Galabovski news") page 3 "AMepMKaHcKaTa AES nOKaHH Ha oTBopeHa cpe~a llCMTenMTe M pa60TeIQHTe B pe nioHa" "American company AES invited people from local communities to an open discussion forum D February 26 - March 03, 2000 Newspaper "KamtTan" ("Capitaf') page 16 "CAen KaTa C HeMC Ka Ta RWE 3a "MapM~a lo13TOK 2" 3acera ce OTna ra" "The deal for Maritza East 2 TPP with German company RWE postponed for the time being" PBPower

OFFICIAL MEW MINUTES OF PUBLIC HEARING

Document No. 6216ONPBP/OOOOOl 0774R140.doclS2I2!w \ MINUTES OF PUBLIC HEARING

A Public Hearing with participation of all interested physical. and juridical persons/entities was carried out this 16th day of February 2000 (Wednesday), at 01.30 p.m., in the Big (Cinema*) Hall of the "ENERGETIC· House of Culture in Galabovo town , Stara Zagora County of the Environmental Impact Assessment Report (EIAR) on the Project "Implementation of new 600 MWe power generating facilities at the site of existing "Maritza East 1" Thermal Power Plant (TPP).

Public Hearing was attended by representatives of : Ministry of the Environment and Waters *(MEW), AES Electric - UK*, Access International - USA*, 3C - Mauritius*, ENSR - USA, State Energy Regulatory Commission*, Natsionalna Elektricheska Kompania EAD (NEK) - Sofia, Energoproekt - Sofia, Minproect - Sofia*, Regional Inspection of Environmental Preservation (RIEP) - Stara Zagera*, Indipendent Trade Union Federation of Energy Sector Workers (ITUFESW) in Confederation of Independent Trade Unions in Bulgaria (CITUB) - Sofia and "Maritza East 1" TPP*, Federation of Energy Sector Workers (FESW) in ·Podkrepa" Confederation of Labour _ Sofia* and "Maritza East 1" TPP*, National Federation of Energy Sector Workers (NFESW) - Sofia·, "Maritza East Mines" EAD - Radnevo town, "Maritza East 1" TPP*, "Maritza East 2" TPP*, Galabovo Municipality Management and Administration, Municipal Council of Galabovo*, mayors and mayors' proxies of the settlements in Galabovo Municipality, government and non government organizations, establishments, schools, local press and the press in the region, residents of the settlements in Galabovo Municipality.

The Public Hearing was chaired by Mrs. E. Zgurovska - MEW, Sofia.

Record-keeper: Mrs. S. Shikova - junior expert "Forecasts, analyses, researches and ecology-, Galabovo MuniCipality.

Public Hearing was opened by Mr. Richard Mardon - Senior Project Director, AES and Director, 3-C. He expressed his gratitude to a/l participants in the Public Hearing for manifested by them great interest to AES Corporation project.

Chairperson - Mrs. Zgurovska briefly presented to the audience the Public Hearing procedure pursuant to the provisions of Regulation No.4/07.07.1998 for Environmental Impact Assessment and stated that:

- All Regulation requirements concerning announcement, organization and holding of the Public Hearing have been met.

- Information for the set place, date and time for the Public Hearing as well as the place and time for public access to the EIA documentation has been spread by Galabovo Municipality through mass media - local newspaper "Galabovski vesti· , newspaper aMaritza Iztok" - Radnevo town, newspaper "Starozagorski novini" - Stara Zagora town , local cable TV "Galabovo" and distributed at appropriate places in Galabovo town and villages announcements.

- The dead-line for announcement of the a.m.data for the Public Hearing has been kept.

Prior to the date of Public Hearing AES distributed posters and leaflets in Galabovo town, Radnevo town and Stara Zagora town.

J:\Pubs'mw97\Projecls\OO52024\400a\mlnutes.dot 1 The Public Hearing went off under the following agenda:

1. Brief introduction to AES Corporation and special purpose project company 3-C - Richard Mardon and Ivan Chonkov 2. Introduction to the Project - Jim Bodies and Alexander Metchkarov 3. Overview on environmental impacts - Patricia Fleischauer and Boris Ivanov 4. Special focus on socio-economic issues . - Richard Mardon and Ivan Chonkov 5. Questions and Answers

Mr. Richard Mardon delivered a brief introduction to AES Corporation and special purpose project company 3-C .

Mr. Jim Bodies delivered Introduction to the Project according point 2 of the Agenda: Background to the Project Project overview: • Key parameters • Current status • Detailed design • Environmental

Mrs. Pat Fleischauer presented an overview of Environmental Impact Assessment (EIA) Purposes of the EIA Bulgarian EIA for -Maritza East 1a Additional EIA for Lenders Significant project design features Short term environmental effects Long term environmental effects EIA - conclusion

Mr. Richard Mardon acquainted people attending the Public Hearing with socio economic aspects of the Project : Social responsibility Project by project analysis - Plans for Galabovo region • Social welfare projects Hungary case study Panama case study

Enclosure: AES Maritza East 1 Presentation

Questions and answers :

Q. Konstantin Ditchev - "Green Balkans· :

I would like to thank Mrs. Pat Fleischauer for presented by her environmental aspects of the Project. Errors and discrepancies in regard to ecological variety occur in the presented Project. Very old information has been used. I hope this information shall be amended and updated in the new Environmental Impact Assessment report by the help of "Green Balkans·. We saw presented "fly-over" and liked it very much, but in regard to the re-cultivation of the natural system there is still much to be expected. J:\Pubs\mw97\Projeds\o052024\400a\minutes.dot 2 We would like to meet you and to thresh out these issues.

A. Mrs. Pat Fleischauer:

Thank you, Mr. Ditchev. We had a meeting with "Green Balkans" and discussed mainly questions in this field. We had a talk about "Green Balkans" projects and the ideas, we could implement together.. We have in mind new meetings with "Green Balkans", Prof. Mitchev and other· knowledgeable in this field people. The information, we could obtain from them, will be included in our EIA report for the lenders. It is necessary to keep a close watch on strict execution of preliminary undertaken obligations.

Q. Mr. Ivo Bozhkov - oensioner :

You mentioned you were lucky including Mr.Chonkov in your team. In Galabovo town and the region you will find first class professionals in the field of power engineering. The best investment you could do is the one in the human factor and in this case the latter exists. I understood that the value of the boiler efficiency factor will be equal to 87 %. What will be efficiency factor value of the whole thermal power plant?

A. Mr. Richard Marden :

It is envisaged efficiency factor value of the new power plant to be 35 - 36 %.

Q. Mr. Georqi Anqelov - Briquette Plant:

The technology you are offering to be implemented is a modem and state of the art one and can not be compared to the Russian technology. So, should the "Blake lake- be converted into "White lake"?

About 1000 people are employed in Briquette Plant. From the technological point of View the Briquette Plant is bound to AMaritza East 1" thermal power plant. As far as I understood it is envisaged "Maritza East 1" thermal power plant to be shut down.

A. Mr. Boris Ivanoy :

State Agency of Energy and Energy Resources is conSidering problems of Briquette Plant. The project explains how the disposal of waste products will be carried out

Q. Mr. Nichtyan Stoiloy - "Maritza East 1 .. TPP employee:

All of us breathe polluted air of Galabovo town. Does such air pollution exist indeed? Mentioned in the project simultaneuos work of existing power plant and the new one bothers me. Do you expect a greenhouse effect to take place in Galabovo town climate?

J:\Pubslmw97\Projects\o052024\400almlnutes.dot 3 A. Mr. Richard Mardon :

As you were already told, the issue of parallel operation of the new and the existing thermal power plant lies beyond our competence and its solution belongs to Bulgarian State institutions and State Agency of Energy and Energy Resources. Both thermal power plants could operate simultaneously but there is no guarantee that environmental requirements shall be kept. In the State Agency of Energy and Energy Resources policy it is envisaged Briquette Plant and "Maritza East 18 Thermal power plant to be shut down in a 3 year period. It is contemplated in our Bulgarian EIA report the new thermal power plant to meet admissible norms in accordance with the regulations regarding air quality. Bulgarian Government; the World Bank, European Union consider 5 components and the quality of the ambient air shall be evaluated towards content of Sulphur Dioxide, Nitrogen Oxide, ash, Carbon Oxide and Lead in the air. Presented in the report analysis indicate what the present environmental state is according existing regulation and an assessment on the environmental state in the future is presented also.

Q. Mr. Milko Ivanov - Municipal Councellor 1 Bulgarian Euroleft Partv :

Today about 93 % of the buildings in Galabovo town (public buildings, town hospital, schools, kinder gardens, main part of housing estates and houses) are connected to' the central heating system - steam is supplied by "Maritza East 1- thermal power plant. You mentioned that at this stage it is not envisaged the project to supply steam to the central heating system of Galabovo town. Does it mean that after implementation of the new thermal power plant there will be no more central heating in our town?

A. Mr. Richard Mardon :

"m sorry, there is a misunderstanding. We very clearly pointed out that we bear into account further supplies of steam to central heating system of Galabovo town alth9ugh in the contract, we have signed, there is no such clause and we have not any such obligation. In the same manner we provided central heating to the people in many other countries, where we have implemented our projects.

Q. Mr. Milko Ivanov:

The town central heating is one of the social issues, because of the price of this . service. Now we pay a price almost equal to the total· production costs. If somebody plans to sell heat energy at a higher price in the future it will create social problem.

A. Mr. Richard Mardon :

The future will prove will it happen.

Q. Mr. Christo Gerdzhikov :

Do you plan implementation of water treatment facilities? Should they be effective? Should the pollution of water resources be under control?

J:\Pubslmw97\Projects\OO52024\400alminutes.dot 4 A. Mr. Boris Ivanov:

After besprinkling of the ash, cinder and slag they will be disposed at Dryanovo dump area. Contamination of water resources by waste products will not exist.

Q. Mr. Milen Ditchev - student:

What requirements have to be met by the future employees of the new thermal power plant?

A. Mr. Richard Mardon :

As it was already mentioned Bulgarian people and people from the region are well educated and qualified. This is a factor you dispose with. This factor could attract investments for Galabovo Municipality. I can not explain now the procedure for selection of employees, but all well educated and qualified people from the region could work: in the new thermal power plant. There will be few foreigners, who will run technological issues, but their number will be no more than 5 people.

Questions asked in written by Mr. Gotcho Dobrev - Municipality councellor representing coalition "Popular Union" (Bulgarian Agrarian Popular Union - Democratic Party) :

Quote

To : Mr. Richard Mardon

To : Mr. Alexander Metchkarov

Re : AES Maritza East 1 Project, Bulgaria

From: Gotcho Dobrev - MuniCipal councellor , Bulgarian Agrarian Popular Union member of Popular Union coalition,Galabovo

Dear Sirs, In connection with announced by AES public hearing (PH) in Galabovo town on 16.02.2000 on the energy project and particularly on the Environmental Impact Assessment Report (EIAR) I take the liberty to present my standpoint of view, to ask some questions and even to submit some useful recommendations. First of all let me express one common opinion in a metaphorical style - the local community in Galabovo adopts the AES project as a tenderly outspread over the land and the people of Galabovo white dove wings. In the implementation of the Project we see our economic rising up as well as multibranch economic development, ecology prosperity and cultural raising of the local community. Me and many other people are at the opinion that it is possible, if we reach a synergy etween the interests and actions of the members of the local community and AES. I have following questions: 1. In connection with Section "Waters" of EIAR do you envisage implementation of faecal and every day used waters treatment facility and another one for waters contaminated with oil products? Do you intend to share your experience and construction works capacity with Galabovo Municipaliity ?

J:\Pubs\mw97\Projects\ooS2024\400a\minutes.dot 5 2. Very dangerous situation in the ecology of the Maritza East Complex creates the emanation of a Radon (Rn). How do you plan to lead a battle against it? 3. What kind of solutions you have chosen for minimizing of ecological damages in case of accidental ufussilade" discharges of contaminated water and gases? 4. Having chosen a new method for segregation and burying of the combustion waste would you be so kind to inform what will happen with the "black" lake (used now for ash disposal) ? Do you deem AES as an assignee and future owner of it? Have you been acquainted with projects (such as a project of Mr.G.Babatchev) offering the opportunity to convert slag into cement using night electric loads? 5. Should you give technical and financial support to an initiative for cleaning of Rozov kladenetz from phytoplankton and zooplankton? In case of prove of such technologies should you participate together with Galabovo Municipality in erection of sport and entertainment SWimming pools? 6. Our municipality is located in a region, whose average year temperature is 13 centigrades and sunshining during the year is good. Those are good preconditions for growing of wine yards, fruit trees, etc. and production of grape, fruits, etc. Do you think you could support technically and financially an initiative for development of different industries in order "not to have all eggs in one basket" ? If you do this the local community will be grateful and your commercial image will be certainly improved. 7. Should you participate in a co-financing of projects developed by Galabovo Municipality under the program SAPARD provided you will be invited by Galabovo Municipality, private entities or consortiums of private entities? 8. The new Bulgarian Inventions and patent Act doesn't include/recognize the term "rationalization". Have you ·any plans to use the creative initiative of local people which have already proved themselves as rationalizators ? Do you intend to open although a small scientific-technical library equipped with PCs offering opportunity for searching data in different specialized data bases recorded on CDs?

Yours faithfully G.Dobrev 16.02.2000 E-mail address:[email protected]

Unquote

Answer to first question

Mrs. Pat Fleischauer

A very small quantities polluted water will be produced by the new thermal power plant. Water discharged from the new power plant-will be preliminary treated and purified.

Answer to second question

Mr. Dimitrov :

The Earth soil contains radioactive elements. It is normal. Their quantity is very small. These elements do not create a danger.

Answer to third question

J:\Pubs\mw97\Projects\oo52024\40Dalminutes.dot 6 Mr. Richard Mardon :

In regard to "fussilade" discharges you will find a developed section in the project , which concerns such issues and prevention of such discharges. In case that such discharge will take place we shall close the thermal power plant and will do our best to cope with the problems.

Answer to fourth question

Mrs. Pat Fleischauer:

Waste products from the new thermal power plant will be deposited on Dryanovo ash dump site. The "Black lake" is located outside the site of the new thermal power plant. It is envisaged this· part of the "Black lake", which will be not more in use, to be re cultivated. As far as utilization of waste products is concerned such utilization is forseen to be implemented in the future.

Q. Mr. Vladimir Yanev - "Maritza East 1" TPP employee:

The ash together with another waste products and the end-products of the duct gases desulphurization process will be deposited on Dryanovo ash dump site. Who will be responsible for the deposition and related to it re-cultivating activities and how it will be done?

A.Mr. Richard Mardon:

We are now in the process of particularization of these issues with NEK Costs will be paid by AES Le. the bottom of the ash dump site will be covered with a layer of water proved concrete. Global systems for covering of the dump site surface will be applied after filling the dump site in. An implementation of a re-cultivation process will follow. All incurred costs shall be paid by AES nevertheless that all these activities are part of the obligations , undertaken by NEK. That's why it is necessary these issues to be defined more accurately with NEK ..

Mr. Vasko Stoyanov - Mayor of Galabovo Municipality :

Galabovo Municipality is not indifferent to this Project. We deem, that everything will be performed very proffesionnaly. It is important, that implementation of this Project shall have favorable impact on the environment in Galabovo Municipality as well as on socio-economic climate in the region.

Mr. Richard Mardon:

Mr. Stoyanov, thank you for placed in AES trust.

The Public Hearing was closed by· Mr. Richard Mardon. He hanked everybody who attended the Public Hearing and for asked questions. Mr. Mardon expressed his longing for a good co-operative work in the future.

Record-keeper: (signature) (Sv. Shikova)

J:\Pubs'rnw97\Projects\o052024\400a'minutes.dot 7 PBPower

ATTENDANCE LIST

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PUBLIC HEARING I INFORMATION SESSION ANNOUNCEMENT FOR THE MUNICIPALITY OF GALABOVO (IN BULGARIA)

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PUBLIC HEARING f INFORMATION SESSION ANNOUNCEMENT POSTER IN ENGLISH

Document No. 62160AlPBPIOO0001 0774R140.doc/S2I2Iw AES MARITZA EAST 1 670 MW (GROSS) LIGNITE FIRED THERMAL POWER PLANT

NOTICE OF THE PUBLIC HEARING ·OPEN FOR ALL TO PARTICIPATE IN ADDITIOII Between 09:30 to 12:00 itor Date: Wednesday 16th, . malion on lhe projacl will be made ,a . available lor Ihe pubHc with experts .. February 2000 pl8sent to answer questions.

~ Time: 13:30 hrs Fl88l1111rn sh~lIIe b~stS to Galabovo I'rin run fl8!Jlln:t{ from OIlllllIOUS pick-~p paints in Ibe surrollKling fa Place: Hall of Culture, YiI/ages (see seperale sheet .., Central Square, 1~""""lIl'V' fordelals~

g/ The AES Corporation (USA) through its majority owned subsidiary, 3-C, is plaming III replace the aged Maritza East 1 power plant by constructing a new 670 MW (gross), lignite-fired plant at the existing site. V' Construction will commence by the end of 2000 and will las! three years. II" Some of the long term benefits of the project are: o significant improvement In local air quality, • securing future regional employment, o no adverse impact on water supply, o a mora efficient and reliable electricity supply, and o other significant community benefits. 0/ The public hearing forms an important part of the review of the projeers impact on the environment, as laid down in the Bulgarian environmental legislation. PBPower

PROJECT SUMMARY LEAFLET DISTROBUTED AT PUBLIC HEARINGIINFORMATION SESSION (IN BULGARIAN)

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PROJECT SUMMARY LEAFLET IN ENGLISH

Document No. 621S0AlPBPf1l00001 On4R140.doclS2I2Jw AES MARITlA EAST 1 670: MVI CGRQS$) L..IGN.ITl·FIRED

DII.: 11.12.2000 ..... : - Ho ... 01 CullufI, ClDlrll .....,., DilllIOYD

11m.: 01:30 III 1Z:f10 Pllbllc Inform.llon 1I ...lon 13:30 ..war ... PubIIo H,.,lng on BA Rep."

PBPower

FEEDBACK FORM IN BULGARIAN AND ENGLISH

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-I InOAY4aTeA: IF. r'I:Jl'1EOID

T m It MAPHUA R3TOK"u - 1 tiPEB Y1IP .ABMr E,lJff 3A PMtlAP)J; MAP)J;OR L / npOeET AE$ :a-a TEr~-l / ~ We Want Your Feedback

Thank you for visiting with us today. We would appreciate your feedback on the materials pres the meeting in general. Please take a few minutes to provide us with your comments on the ( meeting.

1. How useful was the information that was presented about the company proposing the proje plans for the new Maritza East 1 Thermal Power Plant (O-not useful, 5 somewhat useful, 10 very u

1a. Learning about the project 3C company 1b. Learning about the new Maritza East I Thermal Power Plant 1c. Having your interests and concerns addressed 1d. Hearing interests and concerns of others

2. Were your interests and questions concerning the new AES Maritza East 1 Thermal Pt addressed to your satisfaction? Yes No.___ _ (If no, please indicate in the space provided below what AES could do to address them)

3. What is your opinion of the new Maritza East 1 Thermal Power Plant? Very desirable_Desirable__ OK __ Undesirable __

4. How would you like to receive information regarding the project in the future? (Please rank in order of your preference, 1 being first, 4 being last)

Group presentations (such as today) Letters to the community______TV and/or radio.______Newspaper,______Other (please specify),______

5. What groups or organizations do you think should be kept informed about the Maritza East 1 ~ development?

Would you like to be on our mailing Hst? If so, please fill in the information below.

Name:, ______Address:______Telephone: ______