Denizli CCPP Environmental and Social Impact Assessment

Denizli CCPP

Environmental and Social Impact Assessment

Draft Final Report

February 2010

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Frankfurt Siemensstrasse 9 D-63263 Neu-Isenburg Tel.: +49 (0) 61 02/206-0 Fax.: +49 (0) 61 02/206-202 E-Mail: [email protected] Denizli CCPP http://www.erm.com

Environmental and Social Impact Assessment

Final Draft Report

Büros

Hamburg Daimlerstrasse 71b D-22761 Hamburg Tel.: + 49 (0) 40/8 97 20 76-0 Fax: + 49 (0) 40/8 97 20 76-76

Köln Gustav-Heinemann-Ufer 58 D-50968 Köln Tel.: + 49 (0) 2 21/37 95 47-0 Fax: + 49 (0) 2 21/37 95 47-66 February 11, 2010 Stuttgart Kurze Straße 40 D-70794 Filderstadt Tel.: +49 (0) 7 11/77 39 55-50 Fax: +49 (0) 7 11/7 739 55-70

Geschäftsführer Martin Gundert

Amtsgericht Offenbach HRB 42108 Prepared for: Ust.-Id Nr. (VAT No.) DE248679829

RWE & Turcas Güney Elektrik Üretim A.Ş., Bankverbindungen Offıce Istanbul, Please remit to Commerzbank, Neu-Isenburg Nisbetiye Caddesi; Konto-Nr.: 4 078 788 BLZ: 500 400 00 Ergin Sokak No: 5, SWIFT: COBADEFF 504 34337 Beşiktaş - Istanbul (Etiler) IBAN DE24 5004 0000 0407 8788 00

Deutsche Bank, Darmstadt Konto-Nr.:2 100 840 BLZ: 508 700 05 SWIFT: DEUTSCHDEFF 508 IBAN DE12 5087 0005 0210 0840 00

PROJECT NO. P0084930 Mitglied der Environmental Resources Management Group

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This report has been prepared by ERM GmbH (ERM) with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating Environmental Resources Management’s General Terms and Conditions of Business and taking account of the manpower and resources devoted to it by agreement with the client.

ERM GmbH disclaims any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and ERM GmbH accepts no responsibility of whatsoever nature to third parties whom this report, or any part thereof, is made known. Any such party relies upon the report at their own risk.

ERM GmbH Neu-Isenburg, February 11, 2010

Klaus Kaiser Margarete Langer Project Director Project Manager

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 2

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CONTENTS

1 INTRODUCTION 1-1

1.1 PURPOSE OF THE STUDY 1-1 1.2 PROJECT PROPONENT 1-2 1.3 BACKGROUND TO PROJECT 1-3 1.3.1 Project Type and Size 1-3 1.3.2 Location of the Project 1-3 1.4 STAGE OF PROJECT PREPARATION 1-4 1.5 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT FOR THE PROJECT 1-5 1.6 BRIEF OUTLINE OF THE CONTENTS OF THE REPORT 1-6

2 DESCRIPTION OF THE PROJECT 2-1

2.1 NEED FOR THE PROJECT 2-1 2.2 PROJECT SETUP AND INFRASTRUCTURE CONNECTION 2-2 2.3 LEVEL OF PLANNING DETAIL 2-3 2.4 PROJECT SITE 2-3 2.5 SALIENT FEATURES OF THE PLANT 2-5 2.6 DESCRIPTION OF THE ELECTRICITY GENERATING PROCESS 2-6 2.7 PLANT OPERATION 2-8 2.8 SITE LAYOUT 2-10 2.9 OPERATIONAL CONSUMPTION AND RELEASES TO THE ENVIRONMENT 2-11 2.9.1 Overview 2-11 2.9.2 Fuel Consumption 2-11 2.9.3 Air Emissions 2-12 2.9.4 Noise Emissions 2-15 2.9.5 Water Supply and Wastewater 2-15 2.9.6 Hazardous Materials 2-24 2.9.7 Solid Wastes 2-25 2.9.8 Summary Consumption and Releases 2-25 2.10 POLLUTION ABATEMENT MEASURES AND MONITORING 2-27 2.10.1 Air Emissions 2-27 2.10.2 Noise Emissions and Vibrations 2-27 2.10.3 Monitoring of Effluents 2-28 2.11 FIRE PROTECTION , SAFETY AND SECURITY FEATURES 2-28 2.12 OPERATIONAL MANAGEMENT AND STAFFING 2-31 2.12.1 The Plant Operation 2-31 2.12.2 Staffing 2-32 2.12.3 Plant Management 2-33 2.13 ENVIRONMENTAL AND HEALTH AND SAFETY (EHS) MANAGEMENT 2-34

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2.14 CONSTRUCTION ACTIVITIES AND SCHEDULE 2-36 2.14.1 General 2-36 2.14.2 Construction Activities 2-36 2.14.3 Construction Programme and Schedule 2-38 2.14.4 Construction Workforce 2-40 2.14.5 Construction Site Security 2-41 2.14.6 Environmental, Health and Safety Management during Construction 2-42 2.15 BENCHMARKING OF THE PROJECT 2-42 2.15.1 General 2-42 2.15.2 Performance Indicators 2-48

3 DESCRIPTION OF THE ENVIRONMENT 3-6

3.1 OVERVIEW OF THE AREA 3-6 3.1.1 General Consideration 3-6 3.1.2 Study area 3-6 3.1.3 Data Sources 3-6 3.1.4 Structure of the Baseline Report 3-7 3.2 PROJECT SITE LOCATION 3-7 3.3 TOPOGRAPHY , LAND USE AND SPATIAL PLANNING 3-7 3.3.1 Topography 3-7 3.3.2 Land use 3-8 3.3.3 Spatial planning 3-11 3.4 GEOLOGY 3-13 3.4.1 Regional Geology 3-13 3.4.2 Geology of the Site 3-14 3.4.3 Areas with special precautionary measures 3-16 3.4.4 Tectonics 3-17 3.5 SOILS 3-22 3.6 HYDROGEOLOGY 3-23 3.6.1 Groundwater Quality 3-25 3.6.2 Use of Groundwater 3-27 3.7 HYDROLOGY 3-27 3.8 SURFACE WATER QUALITY 3-30 3.9 CLIMATE 3-31 3.9.1 General Climatic Conditions 3-31 3.10 AMBIENT AIR QUALITY 3-33 3.10.1 Area of Interest and Available Data 3-33 3.10.2 Emission Sources in the Project Area 3-34 3.10.3 Monitoring of Ambient Air Quality 3-35 3.10.4 Assessment of Ambient Air Quality 3-39 3.11 ENVIRONMENTAL NOISE 3-43

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

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3.11.1 Introduction 3-43 3.11.2 Environmental Noise Measurements 3-44 3.11.3 National and International Environmental Noise Standards and Guidelines 3-47 3.11.4 Evaluation of the Environmental Noise Situation 3-48 3.12 FLORA AND FAUNA 3-48 3.12.1 General Considerations 3-48 3.12.2 Ecological Setting of the Area and the Project site 3-49 3.12.3 Habitats 3-49 3.12.4 Flora 3-51 3.12.5 Fauna 3-52 3.13 LANDSCAPE AND SCENERY 3-57 3.14 CULTURAL HERITAGE 3-57 3.15 SOCIO -ECONOMIC CONDITIONS 3-57 3.15.1 Introduction 3-57 3.15.2 Methodology for the Collection of Baseline Information 3-58 3.15.3 Administrative Institutions/Socio-Cultural Networks 3-63 3.15.4 Demographics 3-65 3.15.5 Land Tenure 3-78 3.15.6 Livelihoods and Employment 3-79 3.15.7 Infrastrucure 3-90 3.15.8 Key Development Issues in the Area 3-94

4 ALTERNATIVES 4-1

4.1 THE ”N O ACTION ” OPTION 4-1 4.2 ALTERNATIVE SITES 4-1 4.3 POWER GENERATION TECHNOLOGY AND FUEL ALTERNATIVES 4-3 4.3.1 Fuel Alternatives 4-3 4.3.2 Alternative Power Generation Techniques 4-4 4.3.3 Process Technology 4-5

5 ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES 5-1

5.1 IMPACT ASSESSMENT PROCESS 5-1 5.1.1 General 5-1 5.1.2 Introduction 5-1 5.1.3 Assessment Methodology 5-2 5.1.4 Assessment Content 5-2 5.2 AMBIENT AIR QUALITY 5-3

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5.2.1 General 5-3 5.2.2 National and International Environmental Standards and Guidelines 5-4 5.2.3 Atmospheric Emissions during Plant Operation 5-6 5.2.4 Ambient Air Quality Assessment for the Power Plant Operation 5-7 5.2.5 Mitigation 5-16 5.2.6 Atmospheric Emissions during Construction Activities 5-16 5.2.7 Mitigation Measures during Construction 5-18 5.3 IMPACTS ON CLIMATE 5-18 5.3.1 Local and Regional Climate 5-18 5.3.2 Local Temperature 5-19 5.3.3 Greenhouse Effect 5-20 5.4 NOISE IMPACT 5-20 5.4.1 Introduction 5-20 5.4.2 Noise Impact Modelling of the New Power Plant Operation 5-21 5.4.3 Mitigation 5-24 5.4.4 Construction Noise 5-25 5.4.5 Vibration 5-26 5.5 IMPACTS ON LAND USE 5-26 5.6 IMPACTS ON SOILS AND GEOLOGY 5-27 5.6.2 Mitigation measures during construction 5-28 5.6.3 Mitigation measures during operation 5-29 5.7 IMPACTS ON GROUND AND SURFACE WATER 5-29 5.7.1 Potential Construction Impacts 5-29 5.7.2 Impacts of Groundwater Abstraction 5-30 5.7.3 Mitigation Options 5-31 5.7.4 Further Potential Operation Impacts 5-32 5.7.5 Impacts of Wastewater Discharge 5-32 5.8 IMPACTS ON FLORA , FAUNA AND HABITATS 5-35 5.8.1 Potential Impacts as a Result of the Power Plant Operation 5-36 5.8.2 Impacts during Construction 5-36 5.9 VISUAL IMPACTS 5-39 5.9.1 Mitigation 5-40 5.10 ARCHAEOLOGY , HISTORICAL AND CULTURAL HERITAGE 5-41 5.11 SOLID WASTE MANAGEMENT 5-41 5.12 ELECTRIC AND MAGNETIC FIELDS (EMF) 5-42 5.13 MAJOR ACCIDENT HAZARDS 5-44 5.13.1 Identification of Hazards 5-44 5.13.2 Operational Health and Safety 5-44 5.13.3 Emergency Response Plan (ERP) 5-45 5.14 NATURAL DISASTER RISKS 5-46 5.14.1 Seismic Risk 5-46 5.14.2 Flooding Risk 5-46 5.15 INTERFERENCE WITH OTHER FACILITIES OR ACTIVITIES 5-46

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5.15.1 Industries 5-46 5.15.2 Air Traffic 5-47 5.15.3 Local communication and pathways 5-47 5.16 SOCIAL AND SOCIO -ECONOMIC IMPACTS 5-48 5.16.1 Introduction 5-48 5.16.2 Loss of Land and Natural Resources 5-48 5.16.3 Pressure on Social Networks and Infrastructure 5-50 5.16.4 Increased Health Risks 5-52 5.16.5 Economic Impacts 5-55 5.16.6 Mitigation Measures 5-56

6 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) 6-1

6.1 GENERAL 6-1 6.1.1 Construction 6-1 6.1.2 Operation 6-3

7 PUBLIC CONSULTATION AND DISCLOSURE 7-1

7.1 INTRODUCTION 7-1 7.2 CONSULTATION OBJECTIVES 7-1 7.3 CONSULTATIONS WITHIN THE SCOPE OF ESIA 7-3 7.3.1 Overall Plan for Consultation 7-3 7.3.2 Summary of Consultation Activities 7-3 7.3.3 Initial findings of Consultation 7-8 7.4 COMMUNICATION STRATEGIES DURING PRE -CONSTRUCTION , CONSTRUCTION AND OPERATION PHASES 7-11 7.5 GRIEVANCE MECHANISM 7-11

ANNEXES

Annex A: Project Maps, Layouts Annex B: Air Dispersion Modelling Annex C: Result of Noise Prediction Annex D: Geology Annex E: Flora & Fauna Survey Annex F: Socio-economic Survey

NOTE The Final Draft Report has been worked out and certified in English language by ERM. For the purpose of publication this document will be translated to Turkish language. In case of any contradiction or discrepancy the English version shall prevail.

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ERM GmbH FINAL DRAFT REPORT Environmental Resources Management

Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

1 – Introduction

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 1-I

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CONTENTS of Section 1

1 INTRODUCTION 1-1

LIST OF FIGURES

Figure 1-1 Project Area and Location of the Project 1-4

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 1-II

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1 INTRODUCTION

1.1 PURPOSE OF THE STUDY

RWE & Turcas Güney Elektrik A.Ş. (RWE & Turcas), a joint venture corporation of the German RWE and Turkish Turcas Elektrik Üretim A.Ş, intends to build and operate a combined cycle power plant (CCPP) near Denizli, Turkey with an installed capacity of approximately 800 MW (the Project).

For the Project an environmental impact assessment (EIA) is mandatory according to Turkish environmental regulations. In February 2008, RWE & Turcas (former E.ON & Turcas1) contracted the local consulting company Tugal Environmental Technologies (TCT) from Istanbul together with Ekotest Environmental Consultancy Testing Co. Ltd, (Ekotest) from Ankara for carrying out the EIA to be submitted to the Ministry of Environment and Forest (MoEF) as an application document for the environmental approval of the Project.

In addition, to fulfil the policy requirements of RWE as well as expectations of potential international Project lenders, RWE & Turcas in May 2008 has contracted a consultant team led by ERM (Frankfurt office/ Germany) locally supported by TCT together with Ekotest to prepare additional studies and compile supplementary information in a wider scoped Environmental and Social Impact Assessment (ESIA) report: the ESIA is designed conform to international standards and practice such as Equator Principles and IFC Performance Standards. ERM assists RWE & Turcas in public consultation and disclosure activities for the Project.

The ESIA Report will serve as input for the environmental and social appraisal of the Project by potential lenders. An Environmental and Social Management Plan (ESMP) outlines the mitigation and monitoring measures, necessary to ensure that the design, construction, operation and decommissioning of the Project will be in an environmentally and socially acceptable manner and compliant with both national and international standards.

1 E.ON sold its share in the project to RWE (see also section 1.2 for more information).

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

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1.2 PROJECT PROPONENT

The Project is owned by RWE & Turcas Güney Elektrik A.Ş. (RWE & Turcas, the Developer), a joint venture corporation of Turkish ‘RWE Holding A.Ş.’, fully owned by the German RWE AG, and Turkish ‘Turcas Elektrik Üretim A.Ş’ with a share proportion of 70 % to 30 %.

In March 2009, E.ON Holding A.Ş. sold its shares in ‘E.ON & Turcas Güney Elektrik Üretim A.Ş.’ to RWE Holding A.Ş. and then the company was renamed as ‘RWE & Turcas Güney Elektrik Üretim A.Ş.’ in June 2009. This company (the Developer) is responsible for the design, construction and operation of the natural gas fired power plant with an installed capacity of approximately 800 MW. All relevant permits and approvals necessary for the construction and operation of the CCPP which were originally issued on the name of the former company are still valid for the renamed company RWE & Turcas such as the positive EIA decision issued by the Ministry of Environment and Forestry, the groundwater abstraction permit issued by DSI and the Energy Generation Licence issued by EMRA (see also Section 2.2). Moreover, all these relevant authorities were informed about this share transfer and name change.

RWE AG is a German energy utility company with almost 66,000 employees and a turn over of almost 49 bn. Euro (2008) RWE is one of the leading privately owned energy companies in Europe. RWE’s business fields are:

 Generation of electrical energy  Transmission  Distribution and wholesale  Sales and trading  Natural gas

In 2008 RWE decided to enter the fast growing Turkish energy market. The Turkish daughter company “RWE Holding A.Ş.” was founded in Istanbul in February 2008.

TURCAS Petrol A.Ş. is the successor of Türk Petrol ve Madeni Yağlar A.Ş., which was founded in 1931 as the first private oil Distribution Company in Turkey and transformed into a joint stock status. Türk Petrol, then in 1988 established Turcas Petrolcülük A.Ş. with the partnership of British CASTROL. In 1992, Tabaş Petrolcülük A.Ş. bought most of the stocks of the company. In 1999, with the unification of Tabaş Petrolcülük A.Ş. and Turcas Petrolcülük A.Ş. the company changed its name to Turcas Petrol A.Ş. In 2005 TURCAS;

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 1-2

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established a new partnership called Shell & Turcas Petrol A.Ş. (STAŞ) as a result of Associated Enterprise Contract in accordance with Partial Separation Announcement with Shell Turkey in the fields of fuel, mineral oils (naphtha), retail and commercial sale, marketing and distribution. Obtaining the necessary documents from EMRA, STAŞ, the stocks of which TURCAS holds 30%, began operating on July, 2006. STAŞ, markets its oil products over 4 million tons per year at its approximately 1300 gas stations (Shell brand) all around Turkey. With its 75 year old past and global cultural richness emerging from its experience and partnerships it established at the oil industry, the only free branch in Turkish energy industry, TURCAS, advances to its aim to become a “Regional and Integrated Energy Corporation” that produces and invests on the other branches of energy industry which are liberalized such as electrical power and natural gas. Established as a petroleum products retailer, Turcas is transforming itself into an energy holding company. Turcas currently holds 30% stake in Shell & Turcas Partnership and working on expanding to other segments of the energy sector.

1.3 BACKGROUND TO PROJECT

1.3.1 Project Type and Size

The CCPP Project involves the design, engineering, construction, commissioning, operation and maintenance of an approx. 800 MW combined- cycle gas-fired power plant adding electricity generating capacity to the national grid.

The facility will be configured with two heavy duty gas turbine generators, two heat recovery steam generators and one steam turbine generator together with all necessary auxiliary and ancillary systems and equipment. Transmission lines and the gas pipeline are not part of the Project and are under the responsibility of Turkish Electricity Transmission Company, TEIAS, and Turkish National Petroleum Pipeline Corporation, BOTAS.

The total capital investment of the CCPP Project amounts to roughly 600 million EURO.

1.3.2 Location of the Project

The selected site of the Denizli CCPP is located in the Aegean region, 280 km southeast of Izmir, approximately 35 km east of the city of Denizli. The site is

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 1-3

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situated 1.8 km north of Kaklık Municipality in Honaz District, Denizli Province.

Figure 1-1 Project Area and Location of the Project

1.4 STAGE OF PROJECT PREPARATION

RWE & Turcas has already selected a qualified international turn key EPC contractor, ‘METKA’ and a contract was signed between the parties on October 27, 2009.

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

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

The commencement of construction is tentatively scheduled for second quarter of 2010. Start of electricity generation is targeted for end of 2012.

1.5 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT FOR THE PROJECT

RWE & Turcas, at the time of ESIA preparation, had already submitted the Turkish EIA to the Ministry of Environment and Forest (MOEF) and received a positive decision by MOEF, on 5th of November, 2008, which is a prerequisite for the construction permit.

While the local EIA prepared by TCT-Ekotest aimed at reaching an environmental consent from the Turkish regulators, the present ESIA Report has been prepared in order to meet the environmental and social requirements of potential project lenders, including Equator Principles Financial Institutions (EPFI). The ESIA Report will serve as input for their environmental and social appraisal of the Project.

According to Turkish legislation, a formal public meeting was performed on 17th of June, 2008, where the project was presented to the public in Kaklik by TCT-Ekotest and MOEF. For the international ESIA study, this meeting served in principle as scoping meeting. In order to be in line with international best practice for ESIA scoping meetings, the following additional activities were performed before the June 2008 public meeting: A Project Brochure (June 2008) was drafted to provide initial information for interested stakeholders. Stakeholders were identified in a public consultation and disclosure plan (PCDP). Information was also made available by the Developer in Turkish and English on a website2 first in June 2008.

Additional public information meetings took place in July 2008 (c.f. Section 7).

This ESIA presents the findings of an assessment of the likely environmental and social impacts associated with the construction and operation of the power plant.

2 Originally on www.eonturcasdenizlienerjisantrali.com, now on available on www.rweturcasdenizlienerjisantrali.com

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

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It further describes the measures to avoid or mitigate identified likely impacts and to manage their implementation, and monitor compliance with relevant standards. This is included in the Environmental and Social Management Plan (ESMP) section of the ESIA to ensure that the design, construction, operation and decommissioning of the Project will be in an environmentally and socially acceptable manner and compliant with both national and international standards.

Based on the Project details provided by RWE & Turcas, the ESIA includes the assessment of potential environmental and social/socio-economic impacts for the Project components at plant site. Assessments are made for construction and operation including risks of non-regular operation and impacts related to the presence of the Project structures in relation to the existing baseline conditions. Also, cumulative impacts with other existing or planned developments are considered.

National and international standards are used as references for the evaluation of the impacts. Standards of reference are in particular the International Finance Cooperation’s (IFC) environmental and social guidance documents and Performance Standards (PS) and the European Union’s Best Available Techniques (BAT) Reference Documents (BREF).

This ESIA report was prepared by ERM (Frankfurt office) and locally supported by TCT-Ekotest. TCT-Ekotest compiled the baseline and acted as a liaison partner with local people, governmental and non-governmental organisations and institutions during site visits, field inspections, and consultation meetings.

1.6 BRIEF OUTLINE OF THE CONTENTS OF THE REPORT

The structure of an ESIA Report is guided by established international ESIA practice. The remainder of the report is structured in sections as follows:

 Section 2 is a description of the Project including project rationale, location, Project type and layout, components of Project, magnitude of operation including any associated activities required by or for the Project and proposed schedule for approval and implementation;  Section 3 provides the description of the baseline conditions in the area around the Project, including physical and ecological resources and socio- economic conditions;

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

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 Section 4 is an analysis of alternatives considered by the proponent for the Project and includes a benchmarking of the Project against present gas fired power industry standards;  Section 5 predicts and assesses the Project’s likely positive and negative environmental and social impacts and identifies appropriate mitigation measures;  Section 6 sets out the Environmental and Social Management Plan (ESMP) which describes necessary actions, monitoring and responsibilities for implementation of the mitigation measures; and  Section 7 describes the process undertaken to involve the public and stakeholders in the Project development process and reports on stakeholder comments received.

Supplementary information is provided in the Annexes, including:

Annex A: Project Maps, Layouts

Annex B: Air Dispersion Modelling

Annex C: Result of Noise Prediction

Annex D: Geology

Annex E: Flora & Fauna Survey

Annex F: Socio-economic Survey

PROJECT NO. P0084930, RWE&TURCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI, TURKEY 1-7

ERM GmbH FINAL DRAFT REPORT Environmental Resources Management

Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

2 – Description of the Project

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

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CONTENTS of Section 2

2 DESCRIPTION OF THE PROJECT 2-1

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2.15.1 General 2-42 2.15.2 Performance Indicators 2-48

LIST OF TABLES

Table 2-1 Composition of the Fuel (Natural Gas) 2-12 Table 2-2 Emission characteristics of the power plant and applicable emission standards 2-14 Table 2-3 Stack specifications and emission parameters 2-14 Table 2-4 Water demand of the combined cycle power plant (CCPP) (figures to be revised during the detail engineering phase) 2-16 Table 2-5 Wastewater Quality Levels for Discharge into a Surface Water Body 2-23 Table 2-6 Turkish Irrigation Water Classes 2-24 Table 2-7 Consumption and releases of the power plant 2-26 Table 2-8 CCPP organization 2-32 Table 2-9 Number of power plant personnel 2-33 Table 2-10 Key Phases and Activities of Plant Construction – Preliminary Schedule 2-39 Table 2-11 CCPP efficiency and emission parameters compared to IFC and EU benchmarks 2-48

LIST OF FIGURES

Figure 2-1 Electricity Demand and Supply forecast 2-1 Figure 2-2 CCPP Site Location Map 2-4 Figure 2-3 General flow diagram of a CCPP (configuration with two GT/HRSG units plus one ST) 2-8

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2 DESCRIPTION OF THE PROJECT

2.1 NEED FOR THE PROJECT

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

Electricity Demand and Supply forecast estimated by TEIAS (2008) are shown in Figure 2-1. The forecasts are based on two different supply scenarios (high demand and base demand). As a result of the continuing growth in electricity demand and the slow growth in generating capacity, Turkey is expected to face supply shortages between 2013 and 2015 depending on the assumptions made. According to TEIAS’s projections, Turkey was expected to face supply shortages between 2008 and 2010. Due to the financial crises in 2008, the increase in electricity demand is slowed down, and the slowdown in economies in 2009 deferred the possible supply shortage to later years.

Figure 2-1 Electricity Demand and Supply forecast

Denizli region is one of the areas with the highest consumption on electricity although it is far away from other electricity generating facilities. In addition, the forecasted growth rates of energy demand in Denizli region higher than

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the Turkish average. In western Turkey, the consumption exceeds generation which is the reason why the Ministry of Energy and Natural Resources is requesting an additional capacity for this region.

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

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

Therefore, the construction of an 800 MW (774 MW net as per Performance Guarantees) base load gas fired power plant in Denizli region would be a benefit to the region and the whole country.

2.2 PROJECT SETUP AND INFRASTRUCTURE CONNECTION

The CCPP will be developed by RWE & Turcas as a Build-Own-Operate basis with, RWE & Turcas being overall responsible for financing, construction, operation and maintenance. For design and construction, RWE & Turcas have engaged the Greek EPC contractor METKA S.A..

For the generation of electricity an application for a licence for 49 years was submitted to EPDK ( Enerji Piyasası Düzenleme Kurumu, Energy Market Regulatory Authority) on July 9, 2008. The evaluation of the application was completed and the ‘Generation License’ was issued on 22 April 2009 for a period of 49 years. According to a letter form the Turkish Electricity Transmission Company, TEIAS, (October 6, 2008), the CCPP shall be connected to Denizli – Afyon 380 kV transmission line by two parallel transmission lines of a length of 13 km each. In addition a third transmission line of 18 km length shall connect the power plant to the Denizli substation. TEIAS will be responsible for construction and operating the electrical interconnection facility which is required to connect the plant to the national electricity supply grid.

The CCPP will be supplied with natural gas via a pipeline by Turkish national petroleum and natural gas company, Petroleum Pipeline Corporation, BOTAS. The power plant will be connected via a spur pipeline to the main gas pipeline Isparta – Nazilli passing approx. 255 m south of the site. A gas

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receiving station will be installed in a separate building on the CCPP site. The station will serve to reduce the gas pressure from 40 -70 bar present in the main gas pipeline from BOTAS to approx. 30 bar required for the operation of the gas turbines. Minimum fuel gas pressure at terminal point upstream the gas receiving station is 40 bar. The gas receiving station will be operated by BOTAS.

The establishment of the infrastructure to connect the CCPP to the electrical network is not part of the CCPP project as the routing under responsibility of TEIAS is not yet finally decided. However, due to TEIAS’s deficits of funds the electrical interconnection facilities will be pre-financed by RWE & Turcas and reimbursed by TEIAS during operation of the plant.

2.3 LEVEL OF PLANNING DETAIL

The Project has been contracted to the Greek EPC contractor METKA S.A. in October 2009. Thus, the detail of planning is at concept layout level. The detailed design will be the task of the EPC contractor who will be free to propose engineering solutions within the given layout framework which shall include the environmental provisions as specified within this ESIA report.

The information on the plant design as presented in this section is based on the preliminary design by the EPC contractor and details submitted to the competent authorities (MoEF) with the Turkish EIA Report (Denizli Natural Gas Combined Cycle Power Plant Denizli Province, Honaz District, Kaklik Town, Final EIA Report, TCT-Ekotest, November 2008 ).

The information provided by EPC contractor is intended to provide details on a level which ensures that modifications in the detailed design would be only of minor significance for the content and results of the ESIA.

Therefore, figures given at the present planning stage are preliminary. However, the figures and assumptions made for this ESIA are based on experience with similar installations and power station equipments and are hence considered on the safe side from environmental perspective.

2.4 PROJECT SITE

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

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The site will be connected by an upgrading of the existing road to the national road D595 and finally D320, connecting Denizli with Ankara via Afyon-Usak.

The region is agriculturally and industrially used by marble quarries, leather factories and a cement factory in a distance of approx. 4.5 km west of the site.

The Project has an area of approx. 26.7 ha and is subdivided in 19 land parcels which have been owned by mainly private land owners (approx. 60 owners). Three of the parcels are state owned. The complete land of the private owners has been purchased by RWE & Turcas through negotiated contracts. During the second phase of the zoning plan, all parcels were unified and rental applications for the state owned shares have been addressed to the relevant authorities.

Figure 2-2 provides a map of the site location and the site itself.

Figure 2-2 CCPP Site Location Map

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2.5 SALIENT FEATURES OF THE PLANT

The planned Denizli Power Plant is an 800 MWel Combined Cycle (CCPP)

natural gas-fired plant. The net guaranteed capacity is 774 Wel . The CCPP will be a high efficiency state-of-the-art power plant for economical production of electricity for at least 25 years operation time (200,000 operational hours). The power plant will burn natural gas as sole fuel. The Project utilises the combined cycle technology (CCPP) with efficiency up to 57 %.

The central unit consists of two heavy duty industrial gas turbines equipped with dry low-NOx combustion systems. The exhaust gas of each gas turbine is fed into an associated heat recovery steam generator (HRSG). The steam from both HRSGs serves one common steam turbine.

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

The main installations are as follows:

• 2 x 268 MWel gas turbines (GT) and associated generators; • Two heat recovery steam generators (HRSG) to generate steam from the waste heat of the GTs to be utilized in the steam turbine (ST); • One steam turbine (ST) and generator with a nominal electrical capacity of

264 MWel ; • Each of the HRSGs has its own stack of 60 metres height above ground level for discharge of waste combustion gas; • Cooling of the closed loop steam/water circuit by means of Air Cooled Condensers (ACC); • Appropriate facilities will serve for raw water conditioning and wastewater treatment; • A high voltage switchyard with power transformers and power distribution systems;

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• A small laboratory for testing of lubricants used for operation of the plant as well as for wastewater quality testing; • Storage tanks for de-mineralised water; • Natural gas receiving metering station; • Buildings (particularly for the Central Control Room), roads, parking and fencing.

Details of the site layout are shown in Annex A2. Consumption and releases related with plant operation are summarised in section 2.9.8.

Transmission lines and gas pipelines required to connect to the national grids are not part of the Project. However, the presently available information is provided in Section 2.2. Access to the site will be via a 1 km long existing road which will be upgraded for accessing an industrial zone and will branch off the main road near the settlement Kaklik (cf. Figure 2-2).

2.6 DESCRIPTION OF THE ELECTRICITY GENERATING PROCESS

The plant will be a combined cycle power plant (CCPP) operated with natural gas fuelled gas turbines (combined cycle gas turbine - CCPP). For illustration of the CCPP process, a flow diagram is depicted in Figure 2-3.

The natural gas is fed into the two gas turbines, where it is mixed with compressed air. For this purpose, ambient air is filtered and compressed in the compressor section of each turbine. The mixture of natural gas and

compressed air is ignited in the dry low-NO x technology burner.

The hot exhaust gas produced by combustion of the fuel expands through the turbine section which causes rotation of the turbine. The turbine is connected to the shaft of a generator by which the energy of the rotation is converted into electrical energy. This part of the process (simple cycle) has an efficiency of about 35 %.

In the combined cycle power plant, the efficiency is increased up to about 57 % by utilizing the heat remaining in the gas turbine's waste gas.

From each turbine the waste gas (flue gas) is routed through interconnecting ducts to an associated heat recovery steam generator (HRSG). The HRSGs are heat exchangers to utilise the waste heat of the flue gas for heating and evaporation of the water in a water/steam circuit. The flue gas leaves the HRSG via a stack. The transferred heat generates steam which drives a steam turbine at three different steam pressure levels (about 130 / 30 / 5 bar). The

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steam turbine is coupled with a power generator. Once the steam has passed through the steam turbine, it is condensed by means of an air cooled condenser (ACC). The ACC serves as heat exchanger for transfer of the remaining energy of the steam into the ambient air by condensation. This is achieved by an array of fin tube heat exchangers where the steam/condensate is flowing inside and the ambient air passes-by outside the tubes. The air stream is forced by large fans in order to get a high volume flow rate for achievement of high exchange rates for the waste energy combined with a relatively low temperature increase in the ambient air. The ACC is designed for an average cooling capacity of 450 MW and requires an area of approximately 95 m x 50 m (cf. Annex A2). The flow of cooling air through the fans is 22,000 m³/s on average.

The water/steam circuit is operated in a closed loop to reduce water consumption. Demineralised make-up water is used to cover the loss of water that has to be drained off the circle.

The electricity generated by the plant will be fed into step-up transformers where the generation voltage is transformed to the 380 kilovolt (kV) level of the national grid. Two overhead transmission lines will connect the site with the transmission line between Denizli substation and Afyon substation. In addition it is presently planned that a third 380 kV transmission line will connect the site directly with the Denizli substation.

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

(50 MWth ).

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Figure 2-3 General flow diagram of a CCPP (configuration with two GT/HRSG units plus one ST)

Exhaust stack Exhaust stack

MW e l

HRSG HRSG Generator

Steam turbine

Air Cooled Condenser

Gas MW el Gas MWel turbine turbine Pump Steam Generator Generator Water (Closed Hot Turbine Exhaust Air Air Cooled Exhaust Natural gas Natural gas Air Intake

2.7 PLANT OPERATION

The power plant is designed for 800 MWel rated power output under combined cycle operation in base load mode; i.e. mostly continuous operation with at least 85% capacity. The two gas turbines and the steam turbine will

provide an average electrical power of 2 x 268 MWel and 264 MWel .

Operating time per year will be some 8,000 hours; design life time is 200,000 operating hours meaning about 25 years. The average annually generated

electricity amounts to an average of about 6,400 GWh el .

The GT exhaust gas has a temperature of about 585°C when entering the HRSG. For optimal utilisation of the exhaust gas energy, water of the water/steam cycle is heated and evaporated in the HRSG at three pressure levels.

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The two HRSGs are equipped with one stack each. Silencers are installed to abate noise emissions generated by the waste gas streaming out the stacks. Exhaust gas temperature is about 104°C.

The generators deliver their electricity to a substation with three step-up transformers for the connection with the national electricity grid.

For the cooling of the steam in the steam-water cycle, air cooled condensers are used which consist of roof-shaped condenser arrays (cf. Annex A3). Slowly rotating, large fans draw ambient air from underneath the ACC and blow it vertically through the heat exchanger bundles. The steam condensates in roof- shaped condenser arrays and is pumped back to a feed water tank.

For operation of the plant, the following ancillary services will be provided:

• For start-up and shut-down operation: one natural gas fired auxiliary boiler; • For cooling of the turbines' and generators cooling circuit: a water based auxiliary cooling system; • Compressed air from compressors; • Condensate treatment; • Fire fighting; • For black-out: an emergency system (UPS - Uninterruptible Power Supplies and an emergency generator set); • Raw water pre-treatment for de-mineralisation; • Instrumentation and control; and • A substation for the connection to the national grid.

The EPC contractor will install equipment which complies with international and national safety requirements.

Monitoring and control of the entire electrical system will be executed in the Central Control Room (CCR). The control system is designed for full control and supervision of the plant from the CCR. Additional local electronic rooms are present at the turbines, HRSGs and water treatment for assistance in certain operations like start-up or maintenance.

The following functions will be performed at the CCR for each power unit:

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• Start-up, synchronisation and loading of the gas turbine units, the heat recovery steam generators and the steam turbine by using an automatic start-up step program (also allowing for manual mode); • Automatic operation co-ordinated by a unit master controller; starting or stopping a turbine unit on required load change will be done on the operator's decision using full automatic sequence; • Complete supervision of the whole plant from the control system workstations; and • Safe shut-down of a turbine unit or the entire plant.

2.8 SITE LAYOUT

The proposed property for the plant covers an area of about 26.7 hectares. The average elevation is 545 m above sea level (asl). The area which will be used for the Power Plant Project will be roughly 300 m x 300 m and will observe a distance of 20-30-50 meters to the site borders as health protection zone which was determined according to local site requirements and Turkish legislation.

Annex A2 gives an overview of the site layout.

In order to provide a flat terrain for the installations, the site will be levelled. The excavation volume is estimated to be about 100,000 m³ of sand, clay and gravel. The excavated soil may be used for levelling the site or shall be stored in a determined area up to 20 km away from the site. It shall be evaluated by the EPC contractor if the abandoned quarry on site can be refilled and the technology of refilling shall be approved by the relevant authorities and confirmed by RWE & Turcas.

The buildings will have one or two storeys (i.e. administration, electrical building).

The CCR will be part of the two storey administration building. A storage room for oils, lubricants, and other hazardous materials like paints and solvents will be located in the maintenance workshop. Chemicals used for the raw water and wastewater treatment will be stored at the designated locations.

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

The site will be fenced and access will be given through a main gate with gate house.

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An existing local access road of about 1 km length will be reinforced by gravel and later asphalted in order to gain access to the site and to enable delivery of heavy loads. A smaller bridge over a dry river bed will also be reinforced.

2.9 OPERATIONAL CONSUMPTION AND RELEASES TO THE ENVIRONMENT

2.9.1 Overview

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

• Fuel consumption; • Air emissions with the waste combustion gas; • Noise emissions from the turbines, the ACC, and other equipment; • Raw-water demand particularly for the water/steam cycle, and; • Wastewater discharge from wastewater streams (e.g. steam cycle blow down, raw-water pre-treatment residues, wastewater neutralisation, oil/water separators, sanitary purposes); • Hazardous materials, used for construction, operation and maintenance; • Solid wastes, including sludge from wastewater treatment.

2.9.2 Fuel Consumption

The power plant will be fuelled with natural gas supplied by BOTAS. The site will be connected to a spur gas pipeline which passes the site in the South and Southeast at a distance of about 60 m to 250 m. The section is part of the Isparta-Nazilli Main Pipeline (pipe diameter: 200-250 mm). There is also a branch to this pipeline serving the cement production plant (Denizli Çimento) about 1.2 km west of the power plant.

In Table 2-1 an analysis of the composition of the natural gas is provided. The main component is methane with more than 91 %by volume.

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Table 2-1 Composition of the Fuel (Natural Gas)

Compound Vol-%

Methane 91.7

Ethane 3.4

Propane 0.96

Butane 0.42

Pentane and other heavy carbons 0.21

Nitrogen (N 2) 2.83

Carbon dioxide (CO 2) 0.47

S (total) 115 mg/m³*

* Maximum value estimated by Botas

Prior to the use in the power plant the gas will be cleaned (i.e. dust filtered) and the pressure adjusted as required in the gas regulation and metering station. From the gas station interface the fuel gas is fed into moisture separators, where the gas is purified from moisture and dust. From this pre- treatment station, each gas turbine will be served by an own gas pipeline. A third one will be installed as back-up in case of maintenance etc. The auxiliary boiler will also have a separate pipe. Thus, the gas turbines and the boiler can be operated independently.

The consumption of natural gas will be 2 x 14 kg/s (145,000 m³/h) for base load operation of both turbines (2 x 100%). The total thermal energy input of

the CCPP will be approx. 1,400 MWth. The ambient air which is used for the combustion in the gas turbines (GTs) will be cleaned from dust by fabric filters. The fuel supply installations will have to meet the gas supplier's technical requirements particularly with respect to safe operation incl. safety shutoff valves.

2.9.3 Air Emissions

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

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For normal operation 1 the maximum concentrations in the flue gas will be

50 mg/Nm³ 2 for nitrogen oxides (NOx expressed as NO 2). This low value is reached due to the installation of dry low-NOx burners. For carbon monoxide (CO) the maximum concentration will be 50 mg/Nm³.

Based on the maximum value guaranteed by the gas supplier BOTAS (cf Table

2-2) , Sulphur content in the fuel is low and the concentration of emitted SO 2 will be below 5 mg/Nm³. Emissions of particulate matter (PM) will also be negligible since the combustion process does not generate PM. Only particles passing through the intake filters will appear in the flue gas.

The maximum emission rates of NOx (as NO 2) as well as of CO are 95 kg/h for each gas turbine at base load. Carbon dioxide (CO 2) content in the flue gas is approximately 138 t/h per gas turbine (GT).

1 Normal operation means a load range between 60 % and 100 %

2 Nm³ stands for "normalized cubic meters" which means that the volume is referenced to a temperature of 273 K and a pressure of 101.3 kPa

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Table 2-2 Emission characteristics of the power plant and applicable emission standards

Substanc Denizli CCPP Emission Standards [mg/m³] ** e

Maximum Emission TR IFC EU Emission rates Concentration at baseload

O2 15 % 15 % 15 % 15 %

NOx 95 kg/h < 50 [mg/Nm³] 75 51 (25 ppm) 50 (as NO 2)

CO 95 kg/h < 50[mg/Nm³] 100 Not specified Not specified

SO 2 < 5 [mg/Nm³] 60 Not specified 35 (3 % O 2)

PM 5 * [mg/Nm³] Not specified Not specified 5

CO 2 138 t/h per GT 76 g/m³ No concentration specified

* designated to meet the EU standard **Sources: TR: RCAPOIP – Regulation on Control of Air Pollution Originating from Industrial Plants No 26236, 2006, IFC: EHS Guidelines for Thermal Power Plants, December 19, 2008 EU: EU DIRECTIVE 2001/80/EC on large combustion plants, 2001

The dimension of the stacks and the parameters of emission are summarized in Table 2-3.

Table 2-3 Stack specifications and emission parameters

HRSG stack (each) Auxiliary boiler

Stack height 60 m 25 m

Stack diameter circa 7 m 0.8 m

Temperature of flue gas 104 °C 120 °C

Flue gas volume flow rate 1.9 million Nm³/h 14,000 Nm³/h

Waste heat emission About 70 MW About 0.6 MW

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2.9.4 Noise Emissions

The relevant sources of noise at the power plant are the gas turbines, the HRSGs, the steam turbine, the air cooled condenser, compressors, and the steam pressure pipeline. The equipment will be fitted with noise attenuation packages so that the applicable limit values will be kept. More details are provided in Section 5.4 where the results of noise modelling are documented.

2.9.5 Water Supply and Wastewater

A water flow diagram of the power plant based on the assumptions of the EPC contractor METKA during the bidding phase of the project showing both the water supply and wastewater streams and flow rates is provided in Annex A4. The Employer requested the Contractor to improve the technical solutions of the demineralization plant, the water treatment plant and to install a condensate polishing plant with the aim to minimize the raw water consumption and the wastewater amount to be discharged. The flow diagram shown in Annex A4 will be revised accordingly during the detail engineering phase.

2.9.5.1 Water Demand and Supply (all figures will be revised during the detail engineering phase of the plant)

The CCPP will employ closed loop air cooled condenser cooling technology. This concept constitutes a system intrinsic water resources saving technology; typical adverse impacts on water resources associated with wet cooling are avoided.

The water demand expected for operation of the plant is summarized in Table 2-4.

As there is no suitable open surface water source in the vicinity of the site, it is planned to establish groundwater wells. The groundwater will be filtered and demineralised as required. A related groundwater study has been finalized to identify suitable aquifer and define well locations in a reasonable distance to the site. Two groundwater wells have been drilled and the Turkish Water Authority (DSI) has issued permits to utilize a total water amount of 11.5 litres/s (5 l/s from RWE well #1 and 6.5 l/s from RWE well #2). Two additional stand-by wells will be drilled by the EPC contractor. Water will be provided to the site by pipelines.

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In addition to regular operational water demand, washing of gas turbine compressors is only required a few times per year. Washing water will be stored and disposed according to applicable standards (see below).

Table 2-4 Water demand of the combined cycle power plant (CCPP) (figures to be revised during the detail engineering phase)

Water Use Quality required Quantity (approx.)

Potable water system Filtered, treated according to 3 m³/d WHO standards in potable water treatment plant

Service water system Filtered 0-1 m³/h

Gas turbine and Filtered, demineralised 3 m³/h during washing per gas compressor washing turbine

Water/steam cycle and Filtered, demineralised 10-18 m³/h, other plant services (e.g.

auxiliary boiler) Total average Approx. 10-20 m³/h

Which is expected to be reduced to approx. 9.5 m³/h by optimization of the water treatment processes (such as including the condensate polishing plant, etc.).

The average daily water consumption after optimization of the water demineralization and waste water treatment process may be expected in a range of around 200 – 260 m³/d. In this case the amount of water demand will be in a range of approx. 2 to 3 l/s but will significant increase during start-up and maintenance (acid cleaning of the boiler, filling of water and steam cycles, auxiliary cooling system and auxiliary boiler), emergencies and special operation modes. The total water amount of approx. 1000 m³/d which is allowed to be abstracted from the wells according to the DSI permits will not be exceeded even during peak times of raw water demand.

Optimization may be reached by introduction of the following possible water saving features as:

• Re-use HRSG blow down as raw water • Re-use some of the regeneration effluent

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• Optimise pH-value in water / steam cycle in accordance with the reached condensate quality to minimise ammonia requirement which will result to a reduction of loading on the cation bed in the condensate polishing plant • Re-use backwash water from the cartridge filters and multi-media filters

Regeneration effluent which are expected to be discharged or to be transported to a nearby larger waste water treatment plant after optimization of the process are possibly expected in a range of 20 to 30 m³/day. Final values will be determined during the detail engineering phase.

Raw-Water System (figures to be revised during the detail engineering phase)

Raw-water is required for operation of the plant (see Annex A4) and will be stored in a 1000 m 3 combined raw water / fire fighting tank.

The water will be used for:

• Raw-water for the demineralisation plant (water/steam cycle, auxiliary boiler, auxiliary cooling system); • Fire fighting water; • Water for other services; • Make-up water for heating, ventilation and air conditioning (HVAC); and • Potable water.

For the purification of raw water it is planned to install two gravel pressure filter (2x100%) to remove suspended solids and iron- and manganese- compounds. The preliminary purified water is intermediately stored in a raw water tank. The filter backwash water is led to the wastewater treatment plant.

Demineralised Water Plant (figures to be revised during the detail engineering phase)

The demineralised water plant will produce process water for the water and steam cycle, the auxiliary boiler and the auxiliary cooling water system. The used procedure depends on the raw water quality. Depending on this, the actual intention to install are multimedia filters, reverse osmosis membrane technology combined with mixed beds (ion-exchanger ) and regeneration facilities, capable of treating the raw water to meet the necessary demineralised water quality. Alternatively the reverse osmosis is substituted by a cation- and an anion exchanger. After that the demineralised water is

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stored in the 700 m 3 demi water storage tank before it is distributed to the plant by demi water pumps.

The demineralisation process divides the raw water into very clean demineralised water and waste water. In addition the process needs backwash or ion exchanger regeneration. The waste water and neutralised regeneration effluent are neutralised in the neutralisation tank by dosing of acid/caustic.

The demineralisation plant will comprise the equipment required for chemical handling, mixing, dosing, and exchanger regeneration. The regeneration chemicals are stored in chemical tanks and are transferred using dosing pumps.

Water/Steam Cycle (figures to be revised during the detail engineering phase)

The steam cycle is close looped and, therefore, requires only a minor amount of demineralised water to compensate the blow-down losses of usually less than 7 m³/h (max. 18 m³/h). The water for the steam cycle will be pre-treated in a demineralisation plant.

A minor part of the demineralised water will be chemically treated (approx. 1 m³/h). Dosing systems will be provided for the steam cycle water for conditioning by dosing of (i) ammonia solution (NH 4OH, CAS No: 1336-21-6) as corrosion inhibitor, (ii) an oxygen scavenging agent 3 (corrosion inhibitor used alternatively to ammonia during plant shut-down), and (iii) trisodium phosphate sodium phosphate (Na 3PO 4, CAS No: 10101-89-0) solution to avoid scale deposition on the heat exchanger surfaces.

The chemical dosing system will supply the steam cycle with the necessary chemicals to attain and maintain the water and steam quality for optimum quality operation.

The dosing systems and installations needed for the combined cycle block will be housed in containers on the ground floor. All drainage from this area will be collected in a blow-down pit near the Steam turbine building. In chemical loading facilities loading will be done by completely closed systems for personnel safety. A common dosing system will be used for both HRSGs.

3 For the often used highly toxic and water endangering Hydracine (NH 2NH 2, CAS No: 302-01-2), non-toxic alternatives are available. E.g. Sodium erythorbate is a possible oxygen scavenger substitute for boiler water treatment.

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The preparation of the oxygen scavenger agent, ammonia and sodium phosphate solutions and their injection to the water/steam cycle will be done fully automatically. There will be three chemical tanks capable to store commercial available chemical solution mixtures, each having a net capacity of two weeks maximum load operation of the unit. Under each tank a safety retention basin of adequate capacity (110% of tanks' capacity) will be constructed. The internal surfaces of the retention basin will be properly protected.

Condensate from the water/steam cycle is collected in a condensate storage tank, on the bottom of the air cooled condenser. The condensate and make-up water accumulating in the condenser storage tank is pumped to the feed water tank by two of the three 50% condensate pumps and is conditioned by chemical dosing, pre-heated by the low pressure steam and does subsequently serve the water/steam cycle as feed water again.

The blow-downs from the HRSG will be hot but only slightly polluted with conditioning chemicals. The blow-down water will be cooled down in a blow- down cooling basin of 40 m³ prior to discharge into the neutralising tank.

Auxiliary Cooling Water System

The closed-loop cooling water system will serve all equipment that requires auxiliary cooling, such as:

• turbine lube oil cooler (separate circuit); • generator cooler; • lube oil cooler and control oil cooler of the boiler feed pumps; • compressor coolers; • coolers for bearing and stuffing boxes of pumps etc.;

The auxiliary cooling water system will be served by demineralised water. Re- circulated water in the system is treated with a corrosion inhibitor to protect the system components against corrosion.

Chemical conditioning for the closed cooling system will be performed by phosphates and ammonia dosing, in order to avoid corrosion and scaling. One phosphate storage tank with a net capacity of 200lt will be supplied. The tank will be located as close as reasonably feasible to the closed cooling system heat exchanger. The phosphate solution and its injection to the demineralised water filling the closed cooling water system will be done fully automatically.

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Ammonia will be supplied from the above mentioned ammonia storage tank by dedicated pumps, which will be controlled by the pH measurement of the demineralised water of the closed cooling system. Chemical conditioning for the closed cooling system could also be performed by NaOH only (thus no Phosphates would be needed).

The conditioned water will be pumped into the closed cooling system which is cooled by fin fan coolers and is distributed to the individual component coolers (e.g. feedwater pumps, HRSG condensate pumps, generators` coolers and sampling coolers). An expansion tank shall ensure a constant pump suction pressure. Water losses will be compensated by make-up water from the demineralisation water system. The cooling water for the separate circuit for the cooling of turbine lube oil will be cooled with three 50% chiller units (two operating, one back-up).

Service Water System

Service water for a variety of purposes will be required in the plant (up to approx. 1 m³/h). The service water will be taken from the raw-water storage tank and distributed via service water pipes to the respective consumers.

Service water will be used for the following functions:

• General cleaning purposes • Emergency shut down purposes (e.g. blowdown)

Potable Water System

For potable water supply, an amount of up to 3 m³/d water from the raw- water tank is pre-treated in the potable water treatment tank by pressure filters and stored in the 5 m³ potable water tank. From this tank, water is distributed via a local potable water pipe grid to the on-site consumers.

2.9.5.2 Effluent Discharge

The employed ACC technology has no major evaporation losses like wet cooling towers. Under the condition of the optimization of the water / wastewater treatment process the wastewater amounts will be expected in a range of 20 to 30 m³/d (to be determined during detail engineering phase, see above).

The effluent discharge streams in the power plant are originating from:

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-20

ERM GmbH Environmental Resources Management

• Rainwater; • The neutralisation tank; • Industrial waste water • Sanitary waste water.

Rainwater

Rainwater runoff from roads, paved areas and building roofs is anticipated to be clean and is planned to be drained either to the closest river bed or will be collected and re-used as irrigation water.

The areas, where rainwater can be contaminated with oil will be drained. The water will be send to the waste water treatment plant through oil separators.

Industrial wastewater

A separate drainage network will collect all waste water, blow downs, effluents from the chemical injection area, water and steam sampling etc, and transfer them to the wastewater treatment plant. The effluents from various sources will be collected separately before treatment at the WWTP. Areas of concern are the workshop, the gas and steam turbine halls, and the transformer yard.

Suitable retention pits will be provided in the turbine generator block area and in the workshop area.

In the eventuality of fire, the oil/water separator will not be able to treat the oil water mixture. The retention pit in the transformer yard will be sized to retain the oil of the largest transformer and fire fighting water.

Wastewater from the neutralisation tank

Wastewater from ion-exchanger regeneration in the demineralisation plant will be neutralised in the neutralising tank. Acid or alkali will be dosed as required to balance the pH level, which will be controlled by an on line pH meter.

The neutralized water contains dissolved non-toxic salts and will be lead to the wastewater treatment plant.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-21

ERM GmbH Environmental Resources Management

Gas Turbine Wash Water

Washing of gas turbine compressor is an occasional maintenance task. The wash water (3 m³ per washing cycle) will be collected by special facilities and stored in an underground sump of the gas turbine area. The gas turbine wash water will be tested and disposed regarding the applicable standards.

Sanitary waste water

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

Waste Water Treatment

All the collected wastewater will be directed to the wastewater treatment plant. Due to the request of the Employer during the detail engineering phase of the plant the design shall be changed in such a way that the wastewater stream can be divided in a reusable flow which will be re-circulated to the demi plant and in a minimized flow of wastewater which has to be discharged or transported to nearby located larger waste water treatment plant for further treatment. During detail engineering phase it will be determined whether the effluent of the wastewater treatment plant will be dischargeable to a nearby stream or will be transported to a nearby larger wastewater treatment plant for further treatment.

Potentially oil containing waste water from drains of the plant area is treated by an oil/water separator. The oil phase will be separated and collected for recycling, and sludge is collected for off-site disposal by a licensed company via tanker truck on demand.

Only a few and very small amounts of water-endangering substances will be used in the plant. These include, in particular, lubricant oils (e.g. motor oil, transformer oil) and small amounts of chemicals within the chemical dosing system ( e.g. scale inhibitors). The requirements of applicable regulations for wastewater discharge will be fulfilled and monitored in the on-site wastewater laboratory.

The facilities for storing, filling and using water-endangering substances will be designed to meet good design and practice standards (BREF) and the legal requirements and to ensure appropriate protection against spillage and escape into surface water.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-22

ERM GmbH Environmental Resources Management

Table 2-5 Wastewater Quality Levels for Discharge into a Surface Water Body

Substance IFC EHS Turkish Standard Turkish Standard Standard* Composite Sample Composite Sample 2 h** 24 h**

Chemical Oxygen mg/l 125 60 30 Demand (COD)

Biological Oxygen mg/l 30 - - Demand (BOD)

Suspended Solids (SS) mg/l 50 150 100

Oil and Grease mg/l 10 20 10

Total Phosphorus mg/l 2 8 -

Total Cyanide (CN -) mg/l - - 0.5

pH pH 6 – 9 6 – 9 6 – 9

Total coliform bacteria MPNb / 400 - - 100 ml

Temperature - 35 °C

* IFC EHS Guideline Wastewater and Ambient Water Quality 2007; applicable for discharge into surface water ** Turkish "Water Pollution Control Regulation (WPCR, No. 25687, dated 31.12.2004); applicable for discharge into surface or groundwater MPN: Most probable number There are no general EU standards for discharge of industrial wastewater. This is regulated in each member state separately.

In case there will be any wastewater which will meet the Turkish discharge standards and Turkish Irrigation Water Class III such potential flow may be discharged to Surface Water Bodies or used for irrigation purposes. Waste water discharge limit values for water discharge are given in Table 2-5.

The wastewater which may be re-used as irrigation water shall comply with the following standards according to Turkish legislation:

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-23

ERM GmbH Environmental Resources Management

Table 2-6 Turkish Irrigation Water Classes

Parameter Classes I II III IV V

pH 6.5 – 8.5 6.5 – 8.5 6.5 – 8.5 6 -9 < 6 or > 9 BOD 5 (mg/l) 0 - 25 25 - 50 50 – 100 100 – 200 > 200 SS (mg/l) 20 30 45 60 > 100 Electrical conductivity 2000 – 0 – 250 250 – 750 750 – 2000 > 3000 (µs/cm at 25°C) 3000

Sodium (%) < 20 20 – 40 40 – 60 60 – 80 > 80 Boron (mg/l) 0 – 0.5 0.5 – 1.12 1.12 – 2 2 -1) Fecal coliform bacteria (Number/100ml) 0 – 2 2 – 20 20 – 10 2 10 2 – 10 3 > 10 3 Chloride mg/l 0 – 142 142 – 249 249 – 426 426 – 710 > 710 meq/l 0 - 4 4 -7 7 – 12 12 – 20 > 20 Sulphate mg/l 0 – 192 172 – 336 336 – 575 576 – 960 > 960 meq/l 0 - 4 4 -7 7 – 12 12 – 20 > 20

I: very good; II: good; III: usable; IV: only to be used if necessary; V: unsuitable 1) No value given Source: Water Pollution Control Regulation (Official Gazette No. 20748 R. G.) from 07.01.1991, Table 4

2.9.6 Hazardous Materials

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

• Diesel fuel is stored for the operation of the emergency generators and fire fighting pumps. • Lubricants and hydraulic oils for maintenance are stored in the oil storage at the workshop; • Acids and caustics for wastewater treatment and for regeneration of the demineralisation plant; • Additives for the closed water circuits (antiscaling, anticorrosion, antifouling agents) • Small volumes of solvents and paints for repair purposes; • Small volumes of chemicals for the laboratory; and

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-24

ERM GmbH Environmental Resources Management

• Potentially hazardous wastes (used lubricants, paints)

For the storage areas, safety measures imposed by international standards and regulations will be applied (e.g. contained storage, fire alarm, fire fighting equipment). The estimated storage volumes of the substances are below the applicable thresholds of Seveso II directive on the control of major-accident hazards involving dangerous substances.

The fuel for the power plant (natural gas) is delivered by pipeline via the gas receiving station. Other materials such as hydraulic oil, lubricants, and chemicals will be delivered by road in shipments of drums, packages or road tankers.

2.9.7 Solid Wastes

Given the nature of operation as a natural gas fuelled CCPP, only minor amounts of wastes are generated. Beside conventional solid waste, i.e. office and household wastes, and waste packaging material, various water endangering or hazardous wastes from repair and maintenance of the equipment has to be disposed of. Hazardous wastes generated on-site comprise, e.g. waste laboratory chemicals, waste lubricants, oily sludge from oil/water separators. All waste will be properly segregated, stored on site and managed.

All waste will be disposed of by the municipality or (licensed) contractors in accordance with the Turkish environmental regulations and international good practice standards. Hazardous waste shall be disposed off at a licensed facility e.g. to the hazardous waste landfill in Izayda ş, Izmit or to the sanitary landfill in Denizli (comprising special compartment for hazardous waste storage).

2.9.8 Summary Consumption and Releases

In Table 2-7 a summary of environmentally relevant input and output data is given for the plant's operation.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-25

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Table 2-7 Consumption and releases of the power plant

Combined Cycle Power Plant *

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

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

Air emissions (main sources) (for both gas turbines )

volume flow rate 3.8 million Nm³/h

pollutant emission rate: - CO 190 kg/h - NO x 190 kg/h - CO 2 276 t/h - SO 2 17 kg/h - PM 19 kg/h

stack height 2 x 60 m exhaust gas temperature 104 °C

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

Wastewater Treatment by wastewater treatment plant (neutralisation, oil/water separation etc). It is intended to reuse the water at a maximum extent in a closed cycle system of the demi plant and the wastewater treatment plant. A minimum wastewater amount which is not subject to further treatment inside the own wastewater treatment plant of the power plant will be discharged or transported to a nearby larger wastewater treatment plant to be treated in accordance with the relevant environmental standards (Relevant figures of the flows will be defined during the detail engineering phase).

Sanitary wastewater discharge 3.0 m³/d treatment septic tank

max. discharge levels - COD 120 mg/l - BOD 45 mg/l - SS 45 mg/l - pH 6.0 – 9.0

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-26

ERM GmbH Environmental Resources Management

Combined Cycle Power Plant *

Wastes sludge disposed, treated, reused via licensed waste disposal waste oils contractors waste chemicals and paints non-hazardous waste

Noise for details see section 5.4

Source: Feasibility Study of Denizli Project and EPC Contractor information

2.10 POLLUTION ABATEMENT MEASURES AND MONITORING

2.10.1 Air Emissions

The plant is fuelled with natural gas which is the cleanest fossil fuel available. The utilised natural gas is primarily containing methane and ethane. Minor proportions are other hydrocarbons and inert gases such as nitrogen and carbon dioxide. The natural gas is almost free of sulphur and particles.

Carbon dioxide (CO 2) emissions will be relatively low by using a high efficiency CCPP design for the power plant.

The only relevant air pollutants emitted by the plant will be carbon monoxide

(CO) and nitrogen oxides (NO x). For NO x reduction, the gas turbines will be

equipped with dry low-NO x combustion burners. For the planned configuration, no further treatment of air emissions is required. Measurement equipment will be installed at each HRSG stack for continuous monitoring of

NOx and CO. Additionally oxygen (O 2) content in the flue gas will be monitored for the standardisation calculation of the NOx and CO emissions

which standards are referenced to an O 2 content of 15%.

The stack heights have been designed to facilitate undisturbed and free dispersion of the emitted air pollutants.

2.10.2 Noise Emissions and Vibrations

Noise abatement measures to avoid adverse noise impact on the neighbourhood are considered within the plant design (see Section 5.4).

In particular, significant noisy components such as the turbine/generator sets and compressors are placed in buildings. In order to avoid adverse levels of

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-27

ERM GmbH Environmental Resources Management

vibrations which would increase the wear of the machines, the turbine/generator sets will be placed on island structures.

The EPC contractor will have to optimise the plant layout in such way that the noise impact to the settlements will meet the standards for environmental noise. In particular, the design, sound shielding, and placement of the air cooled condenser may require revision of planning details.

No specific continuous monitoring of environmental noise is envisaged. An initial check of relevant equipment's noise emissions and vibrations will be performed during the trial phase.

2.10.3 Monitoring of Effluents

Chemical Laboratory

A chemical laboratory will be installed on-site for analyses of the various water streams (e.g. steam cycle condensate and feedwater, wastewater) and surface water samples.

The laboratory will be equipped with state-of-the-art instrumental analysis equipment like UV/VIS-spectrometers, chromatograph, flow computer, flow meter and others as well as specialised laboratory furniture and safety devices.

The lab will be able to analyse for BOD 5 (biological oxygen demand), COD (chemical oxygen demand), pH, TSS (total suspended solids), TDS (total diluted solids), oil and grease, heavy metals, etc.

Monitoring System for Effluents

The efficiency of the wastewater pre-treatment unit which will be installed on site will verified by continuous monitoring of pH, temperature, TSS, BOD and COD ( e.g. monthly).

2.11 FIRE PROTECTION , SAFETY AND SECURITY FEATURES

At the present stage of project preparation, the safety features are designed in conceptual stage. It will be the obligation of the EPC contractor to design the structure in detail to observe life and fire safety of Turkey and in accordance with internationally accepted standards. However, the general requirements of such systems and the principal layout are described in the following.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-28

ERM GmbH Environmental Resources Management

The main function of the Fire Protection System is to provide the following:

• Early detection in areas where a risk of fire is considered to exist, • Means of detecting gas leaks which could lead to an explosive atmosphere, • Means of local alarm in the event of fire and of remote alarm and monitoring in the main control room for the gas and fire detection systems, • Means of extinguishing fire using fixed systems, manual hoses, hydrants and portable fire extinguishers.

The fire alarm system will be designed in accordance with internationally accepted standards with automatic sensors and manual alarm push-buttons. The plant will be divided into different alarm sectors for quick detection and identification of the affected area.

An emergency diesel generator unit (1 MW) will be installed for uninterrupted power supply (UPS). This unit will provide power in case of blackouts and will automatically take over, particularly emergency lube oil pumps. It will enable the shutdown of the plant under safe conditions. The fuel tank will last for 10 hours full capacity operation. The unit is not capable to start the entire plant in case of grid blackout (black start).

A complete fire protection system will be provided for the Project. Fire fighting is provided by automatically/manually operated CO 2 fire fighting system at the turbine units and conventional fire fighting water. The fire protection system will include one 100 percent capacity electric motor driven fire pump, one 100 percent capacity diesel engine driven fire pump and a motor driven jockey pump for the hydrant and deluge sprinkler systems. The gas turbine is enclosed and has own ventilation, gas detection system, fire suppression system and fire fighting system. They will be protected by a low pressure CO 2 protection system. The turbine enclosures will be designed and constructed with sound attenuating material and will have a full flooding, self-contained CO 2 fire protection system. The CO 2 system will be sized for double shot protection. The basic enclosure structure will be equipped with access doors, interior lighting and adequate ventilation to keep the enclosure interior at proper equipment operating temperatures. Rooms with higher fire risk have a special fire protection design.

Additional fire extinguishing systems will be installed, such as automatic spray water systems for the transformers (oil cooled), automatic deluge sprinkler systems for the lube oil tank room, and for cable floors and cable ducts within the electrical building. Extinguishing systems for further rooms

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-29

ERM GmbH Environmental Resources Management

may be necessary depending on the type of use.

The Power Plant will operate a computer and manually controlled fire and gas leak detection system incl. panels in the CCR, alarms, automatic shut-down, UPS, safety valves etc.

Fire boundaries will be constructed between the transformers, diesel generator, lube oil tank room, electrical switchgear room, DC panel room, battery room, motor control boar doom, emergency staircases and escape routes et al. The heating, ventilating and air conditioning system (HVAC) will be equipped with fire dampers. The construction and interior finish materials used in the turbine building shall meet the definition of non-combustible or limited combustible. For the panelling of walls and ceilings, as well as for cubicles and cabinets incombustible materials shall be used. Floor coverings shall be flame resistant.

In addition, th e Power Plant will operate a safe system of work, e.g. permit-to- work system, for any activity in a potentially hazardous area of the facility.

The plant parts will be provided with all protection and safety areas, such as traffic, escape and rescue routes, explosion protection zones and retention areas for substances hazardous to water.

All systems used for fire protection/fighting shall comply with all Turkish legislation and local laws and requirements. The equipment and components shall comply with the applicable codes and standards set out below the latest edition, such as EN (European Norms), ASTM (American Society for Testing and Materials), ANSI (American National Standards Institute) and DIN (Deutsches Institut für Normung).

Adequate fire water supply will be provided for the hydrant system and for the automatic extinguishing systems.

The natural gas from the pipeline is transferred to the power plant via a gas receiving station which will be set up by BOTAS. The station layout is not yet fixed, but will meet the specific Turkish construction and operation requirements.

The Power Plant will include a site security system comprising features as applied on similar installations. The entire Project site will be secured with a fence using iron poles and a 2.2 m high plastic-zinc coated grid, and a continuous concrete curb. Appropriate gates will be installed for designated ingress and egress locations. The main entrance from the access road will be provided with gates and a security guard house.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-30

ERM GmbH Environmental Resources Management

Alarm and accident response coordination with authorities

RWE & Turcas will coordinate with responsible authorities for civil defence, fire-fighting and hospitals necessary alarm chains and accident response procedures. The agreed procedures to be followed will become part of the power plant’s Operation Manual .

Operation Safety and Accident Prevention

Operational safety and protection of employees and equipment are the most important prerequisites to ensure an optimum operation of the Power Plant characterized by a long service life of the plant, short repair periods and downtimes and absence of accidents.

Operational safety is not limited to the protection of employees and equipment but includes as well the protection of the neighbourhood. Safety measures are guided by several protection goals and will be considered and implemented from the planning stage through the stage of operation. The following directives will constantly be followed:

• laws, ordinances, regulations, guidelines and standards, • inspections by the authorities, independent engineers, independent experts, manufacturers and operators; • operating procedures and operating instructions; • automation as well as instrumentation and control systems; • monitoring and signalling equipment; • continuous monitoring and inspection tours by operators; and • structural fire protection measures and fire alarm and extinguishing systems. RWE & Turcas will implement an Environmental, Health and Safety Management System to control the plant operations.

2.12 OPERATIONAL MANAGEMENT AND STAFFING

2.12.1 The Plant Operation

The Operation and Maintenance (O&M) of the power plant will be performed by RWE & Turcas. RWE & Turcas will provide personnel dedicated to the operation and maintenance services for the power plant.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-31

ERM GmbH Environmental Resources Management

The organisation of the plant will be headed by a management group, including a Plant Manager and an Assistant Plant Manager.

2.12.2 Staffing

The following listing gives a general description of the duties and the expected staff to operate an 800 MW CCPP. The total number of required personnel amount to approx. 35 – 40 FTE. The overall organization is given in Table 2-8

Table 2-8 CCPP organization

Power Plant Management (T)

• HSE • Public Relations / Community liaison • Office & Communication • Business Administration • Operation • Maintenance Operations (TO) Maintenance (TM) Service (TS)

• Shift operation • Mechanical • Process • Day shift • I & C Optimization • • Supply & Disposal • Electrical Chemistry • • Plant System Engineering Electrical Operation • • Work Preparation & Control Heat Economy • • Material Management Storage Assistant • • Infrastructure Documentation • • Process IT Permits, Requirements • IT • Plants Conformity • Supply Materials & Services Plant officers

• Safety Specialist • Safety Officer • Emergency Management officer • Fire Protection Officer • Pollution Control Officer • Water Conservation officer • Waste Officer • Dangerous Substances Officer • Security Officer

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-32

ERM GmbH Environmental Resources Management

Table 2-9 Number of power plant personnel

Responsibility No. of plant personnel in full time equivalent (FTE)

Power Plant Management 1

Heads of departments 4

Number of shift personnel in responsible positions:

Shift Leader 1

Shift Leader Deputy 1

Shift operation 1

6 shifts: total operations 18

Number of maintenance personnel and technical experts approx. 10

Number of Plant officers approx. 3

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

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

2.12.3 Plant Management

Duties

Duties will include the obligation to ensure that the plant is satisfactorily operated and maintained.

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

Plant management will also implement and produce internal standards and procedures (i.e. working instructions).

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-33

ERM GmbH Environmental Resources Management

Operations Management

The plant management is responsible for the operation of the plant. It is responsible for:

• Receipt, preparation and handling of fuel; • Managing of the water system including water supply, water pre- treatment, general purpose water and wastewater treatment; • Laboratory operations; • Steam and power generation; • Grid liaison; • Emission control equipment; and • Environmental monitoring.

Maintenance Management

The plant management is responsible for the maintenance of the power plant and is responsible for providing maintenance service for the power station equipment and structures.

2.13 ENVIRONMENTAL AND HEALTH AND SAFETY (EHS) MANAGEMENT

RWE has established its specific HSE policy for construction and operation phase of their power plants. The health and safety of the employees and the local population, as well as protection of the environment are of high importance during construction and operation of the power plant. The IFC Performance Standard (IFC PS) 2 on Labour and Working Conditions and Turkish and European requirements for health and safety shall form the basis of an Operational Environmental, Health and Safety (EHS) policy of the power plant, which will be applied during both construction and operation. This includes:

• To establish, maintain and improve the worker-management relationship, • To promote the fair treatment, non-discrimination and equal opportunity of workers, and compliance with national labour and employment laws, • To protect the workforce by addressing child labour and forced labour, • To promote safe and healthy working conditions, and to protect and promote the health of worker,

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-34

ERM GmbH Environmental Resources Management

The Turkish laws and standards regarding labour and occupational health & safety and the implementing ordinances must be met (e.g. labour law no. 4875, May 22, 2003; Decree No. 717583, December 4, 1973 concerning the health of workers and the safety or the workplace).

RWE has established behaviour guidelines and group wide minimum standards for health, safety and the environment. All of the management systems used by RWE companies are based on the HSE feedback loop which encompasses the development of guidelines, their translation into business processes, reporting, evaluation and management review. In addition, the RWE Group Policy on Environmental Management will be part of the operational EHS policy which comprises among others the core ILO standards which are also referred to in IFC PS2 (e.g. no child labour or forced labour, non-discrimination, and freedom of association and collective bargaining).

The operation of the power plant will follow the Environmental and Health and Safety Guidelines of RWE and Turcas.

Major issues for operation and construction of the CCPP, therefore, are:

• As part of the procedures which will be implemented, personnel shall receive training in safety procedures and safety awareness. Appropriate safety measures shall be observed for all operations. Where appropriate, the necessary protective clothing shall be provided. • A detailed record will be kept of any injuries and accidents and a monthly report will be prepared with the aim of undertaking corrective action to prevent them from re-occurring. • Routine inspections shall be carried out on particular items of equipment according to specified schedules. Only approved equipment will be installed and used. The plant will be maintained in a state of safe operation and repair such that it is in accordance with all relevant statutory regulations and environmental requirements. This will include staff training plans, shut-down plans, emergency response plans, emergency contacts etc. which will be adopted during both the construction and operation of the plant. • The operational environment, health and safety procedures include provisions to monitor compliance with the key provisions of the Turkish and IFC guidelines. Monitoring measures are described in Chapter 6.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-35

ERM GmbH Environmental Resources Management

2.14 CONSTRUCTION ACTIVITIES AND SCHEDULE

2.14.1 General

The plant will be constructed pursuant to a turnkey engineering, procurement, and construction (EPC) contract.

Where possible, local subcontractors will be used under the direct supervision of the EPC contractor’s superintendents in order to combine technical experience with the local experience and knowledge of construction in Turkey.

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

The EPC contractor will be responsible for training of the operations personnel. All project’s operational and management personnel will receive on-the-job training. In addition, classroom equipment for orientation training will be provided by the EPC contractor or major equipment suppliers.

2.14.2 Construction Activities

Site Access

The Site can be accessed from a 1 km long local road which connects to the national road D595 to Denizli-Usak. The local road will be upgraded to allow heavy goods transport. The design of the conjunction to the national road D595 is not yet available.

Transportation

As most of the power plant equipment, e.g. electromechanical parts and units are manufactured outside of Turkey these parts will reach the country via sea ports.

For onward transportation to the CCPP site road transport is foreseen. The EPC contractor will be required to study early within his activities, the transport logistics conditions in detail and propose a feasible solution. The gas turbine is considered to be the biggest component with a diameter of 5.2 m, a length of 10 m long and a weight of 310 t. Thus, the expected height of

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-36

ERM GmbH Environmental Resources Management

transport is estimated to approx. 6.3 m which is higher than the average height of a typical highway bridge in Turkey of 4.4 m.

A railway connection exists in Kaklik. However, it can generally be said that the rail network appears not to be in a position to carry heavy cargo.

Establishment of the Site

Site Levelling

Since the site shows elevations between approx. 555 and 595 m above sea level, site levelling has to be carried out. It is estimated that for the construction of CCPP approx. 100,000 m³ of soil will be excavated. The excavation material shall be temporarily stored in the project area and may be used for levelling the site or shall be stored in a determined area up to 20 km far away from the site. It shall be evaluated by the EPC contractor if the abandoned quarry on site can be refilled and the technology of refilling shall be approved by the competent authorities and confirmed by RWE & Turcas.

Foundation

Geotechnical studies have been carried out and determined the soil bearing capacity. In addition, the seismic risk was investigated and revealed a seismic ground acceleration of 0.4 g. In a geological study carried out for the development of the spatial plans of the area, two areas in the site where identified where special measures have to be taken due to slopes and another area was delineated where special precautions have to be taken due to the presence of a former river bed in line with Zoning Plan notes.

Overall, the type and the depth of the required foundation has to consider the results of the geological studies but is not yet finally decided by the EPC contractor. It can be assumed that the required foundation of the heavy components of the CCPP will be built on piles.

Each Gas Turbine & Generator set is supported on a single foundation block separated from the building structure to avoid vibration transmission between each other. The same is valid for the Steam Turbine & Generator set.

Erection of Structures

Subsequently to the piling and foundation works the construction of buildings and erection of structures will be carried out. Buildings and supports may be

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

ESIA 800 MW CCPP, DENIZLI , TURKEY 2-37

ERM GmbH Environmental Resources Management

constructed in situ with steal framework and insulated walls or reinforced concrete structures.

Road Works

Inside the Power plant boundaries a perimetric road and access roads to all buildings and structures of the main parts of the CCPP will be provided. Pavements of a width of 1 m will be established along the roads inside the site borders. Pavements may be paved with prefabricated cement tiles and encased with concrete kerbs. An alternative solution may be asphalted roads. Lighting posts alongside the roads inside the power plant boundaries will be provided. All above mentioned roads will be of 6m width.

An access road to the plant (approx. 1 km) will be provided and shall follow the routing of the existing earth country road. The road will have a roof profile section with low points on either side of the road. The level of the centre line of the traffic course will be at 0.20 m in relation to the surrounding area. The road width will be 6 m according to technical planning. In the Kaklik Development Plan (1:5000) and Kaklik Implementation Plan (1:1000) the space for the site connection road to the national road D595 Denizli-Usak is given with a width of 20 m (cf. section 3.3.3). No kerbs will be used. The rain water will drain to the surrounding area. It is assumed that no retaining measures are needed. No lighting, signs or traffic lights are planned along the road.

Cleaning Flushing of Installations

After assembly and welding, the HRSGs and pipe duct system requires thorough cleaning before test operation. This will be a source of polluted wastewater which requires adequate treatment. Typically hot water dosed with alkaline cleaning agents, e.g. trisodium-phosphate, is used in the washing waters. Several flushings are usually necessary. Wastewater will be treated and discharged.

2.14.3 Construction Programme and Schedule

2.14.3.1 Construction Schedule

It is planned that establishment of the complete CCPP combined cycle power plant, will be accomplished within an estimated 2 - 3 years.

PROJECT NO. P0084930, RWE&T URCAS FINAL DRAFT FEBRUARY 2010

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

A preliminary schedule indicating key phases and activities of the construction programme are given in Table 2-10. However, this is to be understood as a preliminary overview for the purpose of the present ESIA and evaluating potential construction impacts. The detailed and final construction schedule will be subject to the contractual provision among the Project Proponent and the EPC contractor.

Table 2-10 Key Phases and Activities of Plant Construction – Preliminary Schedule

Item Duration Schedule (months)

Start of Mobilization at site 2010

Construction phase 20

Overall Foundation work 12 2010 – 2011

HRSG foundation work 7 2010

Turbine building foundation work 5 2010 - 2011

ACC erection 9 2010 – 2011

Gas and Steam turbines erection 7 2011 – 2012

HRSG erection 10 2011 – 2012

Transformer erection 4 2011

Erection of rest of CCPP parts 14 2011 – 2012

Pre-commissioning and trial operation 11 2012

Start of commercial operation End of 2012

2.14.3.2 Construction Machinery Requirements

For the levelling of the site and during excavation 2 bulldozers, 5 trucks, and 1 water pump truck are planned to be operated. In addition further construction machinery such as excavators, cranes, etc. and auxiliary equipments such as compressor, generator, concrete mixers etc. will be used.

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Vehicles will be used by the construction worker to move around the construction site.

The detailed type and number of vehicles to be used will be determined by the EPC contractor.

2.14.3.3 Construction Traffic and Transportation of Equipment

In the first stage of construction, the main traffic generated will be from civil works activities (fill materials, concrete materials, reinforcement, earth moving equipment, construction materials, paint, steel structure, concrete pipes etc.).In the second stage, heavy equipment will be transported on site. Oversize transport will also be used for the transport of special equipment such as turbines and condensers.

A detailed transportation logistics concept which will be elaborated by the EPC contractor is not available at present stage of project planning. Details on the traffic volumes and frequencies will be provided by the EPC contractor at a later stage of project realisation.

A road transport will be most likely. It is estimated that in the time of site levelling (approx. 2 months) about 7 trucks are assumed for material transport within the site.

The transport of the biggest components such as the gas and steam turbines is envisaged for 2011.

It is assumed that the bulk of construction materials and plant parts would be brought to the site by road (truck), it is estimated that on average 20 trucks per day would have to deliver construction material for civil works. As adverse estimate, peak traffic may increase. This would mean about 20 trucks per hour, most of them leaving the highway and driving along the new access road.

2.14.4 Construction Workforce

During the construction period, it is anticipated that depending on the construction activities approximately 200 to 500 employees will be accessing the site. Typically, the employees will work regularly in one shift (06:30-18:30 hours). For special activities (like piling, etc) also two or three shifts may be required.

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About 60 – 80 % of the labourers for civil and structural works are assumed to be unskilled or semi skilled. For mechanical and electrical work, it assumed that some workers (30 – 40 %) with higher skills will be needed.

The EPC contractor is the Greek company METKA S.A.. RWE & Turcas intends that local Turkish labour should be recruited by the EPC Contractor wherever possible and sufficiently skilled workers are available. The maximum use shall be made of Turkish subcontractors and suppliers wherever possible.

Information about work opportunities in relation to the project will be made available to the local population by RWE & Turcas and the EPC contractor.

The EPC contractor will be required to issue a Work Site Regulation and a Workers Code of Conduct, both to be approved by RWE & Turcas, in order to reduce the potential for cultural related conflicts among foreign (if present) and local workforce and the local population.

The vast majority of on-site construction personnel will be male. Regarding the Project Office staff also female staff is anticipated.

Details of workers logistics will need to be developed by the EPC Contractor. It is assumed that a construction worker’s camp needs to be established on site, since it is very likely that not enough skilled workers can be found in the surrounding area.

Fully operating medical and social facilities (canteen; sanitation, amenities) and services is anticipated to be provided within the boundaries of the Site for the construction workers.

The EPC contractor will be required to set-up a program for demobilization of workers after construction is finished supporting the re-employment of local workforce or implementing a Return Procedure for foreign workforce, respectively

Further information on social aspects of construction workforce (such as measures to minimise potential negative influence of the construction workforce on local population) is provided in Section 5.16 (Social Impacts) and Section 6 (ESMP).

2.14.5 Construction Site Security

The construction site will be fenced and secured by a gate with gate house. The EPC contractor will establish a security system to control access to the site.

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2.14.6 Environmental, Health and Safety Management during Construction

RWE & Turcas will obligate the EPC contractor to issue a health & safety plan which has to be complied with, by both workers of the contractor and all subcontractors. This plan shall be guided by the IFC General EHS Guidelines (Section 4 on Construction activities) and must meet, as a minimum standard, the specific requirements of RWE and Turcas.

The EPC contractor will be responsible for regular inspections and controls of compliance.

Besides general construction site EHS hazards, particular attention will need to be paid to working at great heights when the turbine buildings, the ACC and the stack are erected (30 - 60 m). Also, strong winds are a safety issue to be considered for civil construction activities in particular for the erection of high structures.

General supervision of construction activities will be exercised by RWE & Turcas as part of the developer responsibility. RWE & Turcas will dedicate an appropriate staff team for this.

Beside the EPC contractor, each subcontractor working on the site will be responsible for the tidiness of its own working areas as well as for the transport and correct disposal of all his waste, scrap and spills, in accordance with all local laws and regulations.

Wastewater generated during construction will be treated and discharged according to the applicable Turkish standards.

2.15 BENCHMARKING OF THE PROJECT

2.15.1 General In this section the planned CCPP project is compared against national and international standards applicable to new power plants. Reference is made to documents published on the international level which outline the Best Available Techniques (BAT) for the process in order to achieve a good environmental performance.

The following guidelines are used as references for evaluation on the Project:

• Environmental, Health and Safety Guidelines for Thermal Power Plants, IFC (International Finance Corporation), December 19, 2008;

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• Reference Document on Best Available Techniques for Large Combustion Plants (BREF), European Commission, July 2006.

The IFC guideline provides performance levels and measures which generally should be considered for new facilities. Their applicability, however, has to take into account the site specific situation such as country context, sensitivity and assimilative capacity of the environment, and the results of the ESIA. Hence, IFC performance levels have to be understood as references rather than limit values.

The EU BREF document reflects the current performance of installations operated in the thermal power plant sector in the European Member States. Based on this collection, Best Available Techniques (BAT) have been identified in the BREF document that should be selected for a new installation. BAT related parameters are no legally binding standards. Respective limits for emissions are set forth in the European Directive on Large Combustion Plants (2001/80/EC).

The best environmental performance is usually achieved by the installations of the best technology and its operation in the most efficient and effective manner. The guidelines provide various technological and/or management measures “ to achieve the performance levels ” (IFC) and to aim for a “good environmental performance ” (EU BREF).

Inter alia , the following major measures are stated in the IFC Guideline and BREF document as best practice:

• Use of the cleanest fuel economically available (natural gas is preferable to oil, which is preferable to coal); • Selection of the best power generation technology for the chosen fuel; • Increase of energy efficiency by application of gas turbine combined cycle operation (CCPP) and/or use of combined heat and power (CHP); • Design stack heights according to Good International Industry Practise (GIIP) to avoid excessive ground level concentrations and minimize impacts; • Advanced computerized control system and high performance monitoring in order to achieve increased combustion conditions (reduction of emissions); • Preheating of natural gas (through exhaust gas from cooling) for efficiency improvement;

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• A highest possible pressure and temperature of the working medium (gas, steam); • Fuel gas leak detection systems and alarms should be implemented; • Minimising the heat loss:

• due to unburned gases while combustion, • through the flue-gas (utilisation of residual heat), • through conduction and radiation by isolation; • Cooling system for steam turbines with boiler and HRSG used in combined cycle units and to prevent, minimize and control thermal discharges: closed circuit dry cooling system (e.g. ACC); • Measures to prevent, minimize and control noise (turbines, auxiliaries):

• Noise control techniques such as acoustic machine enclosures, noise isolation of buildings, mufflers or silencers in intake and exhaust channels, sound-absorptive materials in walls and ceilings, vibration isolators and flexible connections, • Modification of the plant configuration in such way that buildings and noise absorbing structures reduce noise impacts on receptors; • An Environmental Assessment (EA) should be carried out (collection and evaluation of baseline ambient air quality data). Suggested air quality impact assessment approach is:

• Baseline air quality collection: seasonal manual or continuous automatic sampling, • Baseline meteorological data collection: continuous one-year data for dispersion modelling from nearby existing meteorological station or site-specific station, • Air quality impact assessment: incremental and resultant levels assessed by refined models; if needed; modification of emission levels to ensure that incremental impacts are small (e.g. 25% of relevant ambient air quality standard levels) and that the air shed will not become degraded. • Particulate matter and sulphur dioxide emissions of natural gas-fired

combustion plants: very low (dust < 5 mg/Nm 3 and SO 2 < 10 mg/Nm 3

(15% O 2) can be achieved without any additional technical measures being applied);

• For reduction of nitrogen compounds (NO and NO 2) (dry) low-NOx burners should be used;

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• Use of water injection for combustion turbines; • Minimisation of CO emissions should be achieved by complete combustion (achieved by e.g. good burner design, high performance process control techniques and maintenance of the combustion system). An optimised system to reduce emissions of NOx will also keep the CO levels below 100 mg/Nm 3;

• Prevention, minimization and control of CO 2 by use of:

• Less carbon intensive fossil fuels (e.g. natural gas), • High energy conversion technology, • High performance monitoring and process control; • Measures to prevent, minimize and control wastewater effluents (from demineralisation, lubricating, chlorine, biocides and other chemicals used to manage the quality of water in cooling systems): • Oil-water separators for treatment of low-volume wastewater streams (collected in turbine room sumps) before discharge, • Treatment of acidic low-volume wastewater streams by chemical neutralisation in-situ, • Elimination of metals such as chromium and zinc from chemical additives used to control scaling and corrosion in cooling towers, • Use the minimum required quantities of chlorinated biocides (no brominated biocides); • Implementation of an Occupational Health and Safety Program which covers measures to prevent, minimize and control Health and Safety impacts of particular concern (with respect to heat, noise, confined spaces, electrical hazards, physical hazards, and chemical hazards):

• Regular inspection and maintenance of equipment (e.g. pressure vessels, piping, powered lines, chemicals storages and handling areas); • Reduction of working time and number of employees exposed in noisy or hot environment; • Shielding surfaces of hot equipment; • Avoidance of, to the degree feasible, the existence and adverse character of confined spaces, provision with (permanent) safety measures for venting, monitoring and rescue operations; • Identification and labelling of e.g. explosion and fire risk areas, hot surfaces, high noise areas, chemicals handling areas;

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• Hazard warning lights, voltage sensors, deactivation and proper grounding of live power equipment; • Storage of flammables away from ignition sources and oxidizing materials; • Implementation of engineering and administrative control measures to avoid the release of hazardous substances into the work environment; • Safety controls and systems, proper maintenance, fire detectors, alarm systems and fire-fighting equipment; • Provision of personal protective equipment (PPE) as appropriate (e.g. hearing protection, glasses, gloves, shoes), • Adequate and appropriate training on e.g. handling of hazardous substances, mitigation of explosion and fire risks, work in confined spaces, noise exposure, • Evaluation of working place exposure against internationally published exposure guidelines (e.g. Threshold Limit Value (TLV), Biological Exposure Indices (BEI) 4, Permissible Exposure Limits (PEL) 5, limits for occupational exposure to electric and magnetic fields ICNIRP 6, or respective European directives 7; • Minimisation of Accident and Fatality Rates aiming for a rate of zero of the number of accidents among project workers. The rates may be benchmarked against the performance of facilities in this sector through consultation with published sources (e.g. US Bureau of Labour Statistics and UK Health and Safety Executive 8);

4 Published by American Conference of Governmental Industrial Hygienists (ACGIH),

Available at: http://www.acgih.org/store/

5 Published by the Occupational Safety and Health Administration of the United States (OSHA), Available at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id= 9992

6 International Commission on Non-Ionizing Radiation Protection

7 e.g. 2004/40/EC (electromagnetic fields), 2003/10/EC (noise exposure), 1991/322/EC (work place exposure limits)

8 Available at: http://www.bls.gov/iif/ and http://www.hse.gov.uk/statistics/index.htm

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• Maintaining a record of occupational accidents, diseases, dangerous occurrences and accidents, • Minimisation of community health and safety impacts during the construction, operation, and decommissioning:

• Water consumption: the project will not compromise the availability of water for personal hygiene, agriculture, recreation, and other community needs; • Traffic Safety should be promoted by all project personnel, by adoption of best transport safety practices across all aspects of project operations Almost all of the above aspects are taken into account for the CCPP Project as far as the technical and operational layout of the project is known to date.

The following exemptions apply:

• The plant is located in the direct neighbourhood of a planned industrial zone. Currently, except the cement factory no major industrial facilities are established yet and there is presently no demand for heat. Thus, the use of combined heat and power (CHP) is not planned due to a lack of potential consumers of the waste heat remaining after maximal utilization for power generation in the plant (reflected by the CCPP's high efficiency). However, coupling out of low temperature water or steam might be an option in case respective consumers will be established in the site's vicinity and the demand can be covered in a economically feasible way; • Water injection is not employed since thermal NOx formation is suppressed by the chosen burner type. Thus, additional consumption of water for injection is avoided; • It has been decided which groundwater wells will be used for the project (cf. Section 5.7). The relevant permits have been issued by the Turkish Water Authority, DSI. However, the final concept shall ensure that the project will not compromise the availability of water for the surrounding areas (cf. Section 6 Environmental and Social Management Plan - ESMP). • Noise emission mitigation of equipment on the preliminary design level is based on standard measures. Improved measures might become necessary to meet standards for environmental noise (cf. Section 6 ESMP); • For the ESIA, the baseline air quality collection was limited to two months during summer time and was deemed to be sufficient since the CCPP’s calculated incremental concentrations are too low to be directly detectable by ambient air quality measurements.

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2.15.2 Performance Indicators

Air Emissions

Performance indicators set out in the BREF and IFC guidance documents are compiled in Table 2-11 for benchmarking of the Project.

In general, the maximum emission values for the CCPP are in the range of the reference values. Furthermore, it can reasonably be assumed that actual emission values will be lower than the maximum values provided as design parameters and respective guarantee values by manufacturers.

Table 2-11 CCPP efficiency and emission parameters compared to IFC and EU benchmarks

Parameter CCPP IFC Performance EU BREF Indicator BAT level

Efficiency

Efficiency of gas-fired 56.72 % 51 - 58 % 54 - 58 % combustion plants (net)

Emissions

Specific CO 2 emission in 356.5 348 - 396 -- g/kWh (related to net power output)

NO x, mg/Nm³ < 50 51 (25 ppm) 20 - 50

CO, mg/Nm³ < 50 Not specified 5 – 100

Particulate Matter < 5 Not specified < 5 (PM 10 ), mg/Nm³

SO 2, mg/Nm³ < 5 Not specified < 10

O2 reference level, % 15 15 15

Wastewater

The general requirement by IFC and the EU BREF is that international and local standards shall be met by appropriate treatment of wastewater discharge streams. In section 2.9.5.2 it is stated that the plant will be designed in such manner that the requirements for effluents as stipulated in the IFC EHS Guidelines will be met.

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Denizli CCPP

Environmental and Social Impact Assessment

FinalDraft Report

3 – Baseline

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CONTENTS of Section 3

3 DESCRIPTION OF THE ENVIRONMENT 3-6

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3.12.1 General Considerations 3-48 3.12.2 Ecological Setting of the Area and the Project site 3-49 3.12.3 Habitats 3-49 3.12.4 Flora 3-51 3.12.5 Fauna 3-52 3.13 LANDSCAPE AND SCENERY 3-57 3.14 CULTURAL HERITAGE 3-57 3.15 SOCIO -ECONOMIC CONDITIONS 3-57 3.15.1 Introduction 3-57 3.15.2 Methodology for the Collection of Baseline Information 3-58 3.15.3 Administrative Institutions/Socio-Cultural Networks 3-63 3.15.4 Demographics 3-65 3.15.5 Land Tenure 3-78 3.15.6 Livelihoods and Employment 3-79 3.15.7 Infrastrucure 3-90 3.15.8 Key Development Issues in the Area 3-94

LIST OF TABLES Table 3-1 Geological formations in the site area 3-14 Table 3-2 Geological characteristics of RWE well#1 3-24 Table 3-3 Geological borings on site 3-25 Table 3-4 Results of groundwater sampling at RWE well#1 3-26 Table 3-5: Groundwater abstraction in Denizli Region 3-27 Table 3-6 Turkish Surface Water Quality Classes and sampling results 3-30 Table 3-7: Ambient air quality monitoring - results of passive sampling 3-38 Table 3-8: National and international ambient air quality standards 3-42 Table 3-9 Examples of noise sources and their sound pressure level 3-44 Table 3-10: Description of the noise receptor points 3-45 Table 3-11 Measured environmental noise levels in the project area 3-46 Table 3-12 Turkish and IFC standards for environmental noise 3-48 Table 3-13 Endangered fauna species identified in the study area 3-56 Table 3-14 Number of surveys conducted at each settlement and coverage rates 3-60 Table 3-15 Number of and type of focus group meetings conducted 3-61 Table 3-16 Administration units of the settlements within the 5 km radius of the project site 3-63 Table 3-17 Population, population growth rates and population densities of Turkey, Denizli, Honaz, Kaklik and the villages close to the project area (TUIK, 2007) 3-65 Table 3-18 Crude birth, death and general fertility rates and natural population change 3-66 Table 3-19 Population distributions according to age groups (TUIK, 2007) 3-70 Table 3-20 Youth and Adult literacy rates 3-73

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Table 3-21 Cross tabulation of education level and sex for persons 15 years and older in the project area 3-74 Table 3-22 Cross tabulation of education level and sex for youth (15-24 years old) in the project area 3-74 Table 3-23 Infant, child and adult mortality rates 3-75 Table 3-24 Prevailing infectious diseases 3-76 Table 3-25 Diseases transmitted through food and water 3-77 Table 3-26 Sexually transmitted diseases 3-78 Table 3-27 Average earnings from the main income sources observed in the project area 3-80 Table 3-28 Mean annual costs of commonly observed expenditures 3-82 Table 3-29 Major occupations in the project area 3-85 Table 3-30 Agricultural lands and major products in the project area 3-87 Table 3-31 Schools and student numbers in Kaklik (Source: Honaz District Management of Education Services) 3-93 Table 3-32 Public health facilities in the project area 3-94

LIST OF FIGURES Figure 3-1 Regional plan for the project area (incl. project location) 3-11 Figure 3-2 Areas where precautionary measures are required (ÖA1, ÖA2) as identified in the development plan 1:5000 3-16 Figure 3-3 Tectonic Map of Denizli and its vicinity (cf. Görkem report, Aydan and others., 2001). 3-17 Figure 3-4 Active Fault Map pertaining to Denizli and its vicinity (black line –active fault; grey line – potentially active fault) 3-19 Figure 3-5 Earthquake Risk Map of Denizli 3-21 Figure 3-6 Main soil groups on site and its vicinity 3-23 Figure 3-7 Surface waters and irrigation channels 3-29 Figure 3-8 Dry creek that passes through the Project Site 3-30 Figure 3-9 Directional frequency of wind measured at Denizli station, 30 years average 3-32 Figure 3-10 Sulphur dioxide and PM10 monitoring at Denizli ambient air quality station 3-34 Figure 3-11 Ambient air sampling locations 3-36 Figure 3-12 Noise sampling locations 3-46 Figure 3-13 Main vegetation types on site and in the study area 3-51 Figure 3-14 Share of natural population change and net migration rate on the annual population growth for 2007 3-66 Figure 3-15 Results of the migration related questions in the survey – summative for Kaklik, Yokusbasi, Asagidagdere and Alikurt 3-68 Figure 3-16 Population Pyramids for Turkey, Denizli and the project area 3-69 Figure 3-17 Histogram of household sizes in the project area 3-70 Figure 3-18 Prevailing diseases in the project area 3-77 Figure 3-19 Income sources of households in the project area N=217 3-79 Figure 3-20 Histogram of annual cash household earnings in the project area 3-80

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Figure 3-21 Histogram of annual value of subsistence farming in the project area 3-81 Figure 3-22 Histogram for the amount of debts in the project area 3-83 Figure 3-23 Percentage of economically active and inactive populations 3-84 Figure 3-24 Major occupation groups for males and industries of employment 3-84 Figure 3-25 Major occupation groups for females and industries of employment 3-85 Figure 3-26 Sectors and types of industries where the waged labour work (N=111) 3-86 Figure 3-27 Causes of agricultural decline – as perceived by farmers 3-88 Figure 3-28 Reasons cited for increase and decrease in the standard of living 3-89

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3 DESCRIPTION OF THE ENVIRONMENT

3.1 OVERVIEW OF THE AREA

3.1.1 General Consideration

Baseline data on environment is important to understand region’s existing physical, biological, cultural and social environmental characteristics. This information forms the basis to analyse the probable impacts of the Project activities vis-à-vis the background environmental quality of the region. The main objective of examining the present environment is to provide an environmental and social baseline against which potential impacts from construction and operational phases of the project may be compared. The collection of baseline data therefore focuses on information requirements which are relevant to ESIA analysis in the context of the Project and its likely effects on the environment and social situation. Based on the above, the existing environmental and social baseline of each environmental component and the social situation is presented in following sections.

3.1.2 Study area

An area of 3 km radius (aerial distance) from the site centre was determined as main study area since this constitutes the relevant airshed 1. However, the baseline information was collected for a wider area of ca. 5 km around the site.

3.1.3 Data Sources

Some of the information and data presented in this section is based on primary surveys and environmental quality monitoring (for ambient air quality, and noise level etc.) carried out by Tugal Environmental Technologies from Istanbul together with Ekotest Environmental Consultancy Testing Co. Ltd from Ankara (TCT-Ekotest) for the period during June 2008 to August 2008. Secondary data and information has been collected by TCT-Ekotest from various governmental departments and agencies and from other study reports available related to the subject area. In addition a socio-economic household survey was undertaken in Kaklik and the nearest villages.

1 There is no Turkish or EU guideline how to determine the air the relevant air shed, which for most plants includes the point of maximum impact. Therefore the airshed is determined according to the German regulations (TA Luft – Technical Instruction Air as 50 times the stack height ( i.e. 50 x 60 m=3 km) which is an internationally accepted approach.

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3.1.4 Structure of the Baseline Report

Based on the above, the existing environmental conditions for each environmental component are discussed in following sections. The Baseline is presented in the following order:

• Overview of the area (topography, general land use) • Physical environment conditions and resources (soils, climate, surface water, ground water, geology/seismology, air quality). • Biological and ecological resources • Human and socio-economic conditions, quality of life values; and • Cultural heritage.

3.2 PROJECT SITE LOCATION

The proposed site of the Denizli CCPP is located in the Aegean region, 280 km southeast of Izmir, approximately 35 k m east of the city of Denizli. The site is situated 1.8 km north of Kaklık, 1.7 km west of Yoku ba ı and 4.2 km northeast of A ağıda ğdere village, all located in Honaz District and 3.5 km northwest of Alikurt village in Bozkurt District, Denizli Province.

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

Kaklik area is mainly under agricultural use. There is also industry such as marble quarries, leather factories. A cement factory is located approximately 4.5 km west of the site. A touristic travertine cave is located approximately 2 km west of the site.

An overview on the 5 kilometre area around the Site is given in Annex A.

3.3 TOPOGRAPHY , LAND USE AND SPATIAL PLANNING

3.3.1 Topography

The region is structured by a valley extending in west-eastern direction with mountainous areas in the north and south. The site is located at the foothills of a mountainous area in the north with Mali Dagi Mountain as highest elevation (1275 m a.s.l.). To the south, mountains reach levels around 2600 m a.s.l. (Honaz Mountain).

The site has an elevation between approximately 545 and 595 m a.s.l and the terrain is ascending to the north and the east. In the north-western part of the

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site an open pit is located . Slopes vary between 10-20% and are located in south-southwest direction.

3.3.2 Land use

The Denizli region is characterised by agricultural and industrial activities. Approximately 20% of the area in the province is settled area (settlements and commercial/industrial areas). From the remaining 80% about half is forest area, the other part is agriculturally used with mainly agricultural fields and only few meadows or pastures. The main land uses are described in the following:

Industry

Industry is an important economic factor in the Denizli region. The main industries of the area are leather and textile industry as well as mining (limestone/marble).

The textile and leather production in Denizli region contributes to a very large amount the country’s production for export. Thus, 60% of the Turkish exports of towels/bathrobe and 90% of the Turkish export of leather are produced in Denizli region (Denizli Environmental Status Report, 2007). Adjacent to the west of the Project site an industrial zone is planned to be established with the purpose of leather production (see below section 3.3.3).

Denizli region comprises the country’s second biggest marble and limestone/travertine deposits. Approximately 70 marble quarries and 90 marble cutting and handling factories are present within the province and export worldwide. Further deposits such as gypsum, magnesite, chrome, sodium salt, anthracite coal, are explored in the area.

A cement factory is located 4.5 km west of the site. Marble quarries located north of the site (approximately 300 m). In the northern part of the site an abandoned quarry is present which was reportedly used for the excavation of clay by the adjacent cement factory. In the quarry some excavated materials apparently from the marble industry (marble debris, gravels and sands) were observed.

According to information from the Ministry of Energy and Natural Sources, General Directorate of Mine Affairs, no natural resources are registered on site.

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Settlements

Besides Kaklik town, there are three villages, i.e. Yokusbasi, Alikurt and Asagidagdere, within the 5 km radius of the project site.

Kaklik is the biggest settlement in the study area and is located approximately 1.8 km south of the site at the national road interchange D320 (to Denizli) and D595 to Afyon/Ankara. Kaklik has approximately 4.500 inhabitants. Approximately 2 km east of the site directly at the D595 Yokusbasi is located with approximately 425 inhabitants. Alikurt (approximately 650 inhabitants) is located further east at a distance of 3.5 km at the D320. All these three settlements are located in the main valley area at altitudes around 550 m a.s.l. Asagidagdere is located approximately 4 km south of the site where the main valley is ascending to the southern mountains at an altitude of approximately 600 m a.s.l. Alikurt has approximately 675 inhabitants. All settlements experienced significant population growth of about 10 - 20% since 2000 (cf. also 3.15.4).

Agriculture

In Denizli province approximately 83% of the agricultural area is used as fields, 12% are vineyards and 4% each are fruits and vegetables. Olive trees are grown to insignificant extent (1%) in the area. Presently approximately one third of the agricultural area is irrigated. This will extend up to 50% when all presently planned irrigation projects are finalized. On the fields, mainly wheat, corn, barley, sun flowers and anise are grown. Export of cherries and grapes (as fruits and as wine) are a significant part of the agricultural sales of the area. Further fruits and vegetables produced in the area are tomatoes, pomegranates and quinces. Besides land cultivation also livestock breeding is performed (sheep, goat poultry and recently also milk cattle).

The site is classified as marginal agricultural land and was mainly used as agricultural land with dry farming of wheat and barley. A very small part shows macquis vegetation with shrubs and single trees such as wild pears (for details see section 3.12 on Flora and Fauna)

The agricultural fields adjacent to the west and south are irrigated (corn, sun flower, anise, pomegranates and grape). An irrigation well is located southwest of the site and an irrigation channel is leading through the site along the western site border. The irrigation channel has initially been constructed by the General Directorate of Rural Affairs and is currently being operated by the Kaklık Irrigation Cooperative.

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For the Project, a land re-designation procedure was carried out to take out the site from agricultural use and to allow ‘energy generation’ onsite (see section 3.3.3 below).

Forest

The forests in the region comprise mainly coniferous woods such as Calabrian Pine, Black Pine, juniper and some cedar. Deciduous forests are less common and comprise mainly oaks and some chest nut. The forest in the region in general belongs to the state and is mainly used for production of logs, poles, industrial woods, paper, chip wood and burning fuel. No forest is present on site. Forest areas are directly north of the site as well as in a distance of approx. 2km east and south of the site (at the hill slopes on the southern part of the valley) (for details see section on Flora and Fauna 3.12).

Transport Infrastructure

Kaklik town is located at the junction of Denizli-Afyon-Usak national roads. A railway runs through Kaklik and connects to the main railway lines of the country. The Denizli airport Cardak is located approximately 20 km east of the site.

The approximately 1 km long road connection from the Uak-Kaklik highway to the site is presently an earth road. The road will be upgraded and asphalted in the course of the project.

Tourism

Approximately 2 km west of the site, the Kaklik cave is located. The cave is a nature protection area and was opened to tourism in 2002. It was formed approximately 2.5 Mio years ago through thermal waters washing out the limestone. Travertine ponds and small terraces have formed due to a carbonate containing creak flowing through the cave coming from an arthesian well approximately 80 m to the west. The cave consists of two parts being up to 190 m x 40 m wide and 2 to 5 m high. The cave has an opening of 11 x 13 m to the above ground. In the close vicinity of the cave a swimming pool, a small amphitheatre and a cafeteria were opened in 2002 for the public. Approximately 40000 people are visiting the facilities per year. The cave can be accessed from the D320 Kaklik – Denizli via an approximately 3 km long earth road. An alternative route leads from the cave along the south-western corner of the site to road D595 (Kaklik – Yokusbasi) and is also about 3 km long.

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3.3.3 Spatial planning

Since 2007, most of the provinces of Turkey have new 1:100.000 scale Regional Master Plans where land uses and the land use designations for future developments are defined. The provincial directorate of Environment and Forestry (the local representation of the Ministry) publishes on its web site 2 the 1:100.000 scale regional plan as approved on 25 August 2009 (see copy of the plan in Figure 3-1). The site is designated as natural gas fired combined cycle power plant. The site is bordering to an organized industrial zone (OIZ) in the west which shall be used by leather industry.

Figure 3-1 Regional plan for the project area (incl. project location)

2 http://denizli-cevreorman.gov.tr/

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At municipal level, no spatial plans were present for the site, so that two plans had to be prepared for the Project. The site is within the municipal boundaries of Kaklik. Therefore physical planning competency lies with the municipality. The process for establishment of the municipal spatial plans is regulated by the Zoning Law (#3194 ) and its regulations. The municipality is responsible for the preparation or commissioning of plans (Law #3194, article 8.b.). The plans were prepared by Kutluay Planning Company in two successive scales:

1) Development Plan (Nazım Đmar Planı) at the scale of 1:5000; and

2) Implementation Plan (Uygulama Đmar Planı) at the scale of 1:1000.

The planning phase included collection of approvals and positive statements from various authorities that are also involved in the regional plan change procedure (if there is any). These institutions have been also consulted by the Developer during the EIA process.

Both plans, the 1:5000 scale Development Plan and 1:1000 scale Implementation Plan were approved by Kaklık Municipality on 5th September, 2008 and were announced for 30 days on the municipal billboard. No objection was raised. The implementation plans for the unification were approved by the Municipal Council on 3rd of August 2009 and were announced for 30 days on the municipal billboard. Also no objection was raised.

According to the plans, the site is now designated as area to be used for energy generation.

In the course of the development of the spatial plans a geological survey was carried out (cf. Section 3.4). Based on the outcomes of the survey, three areas were indicated where special geotechnical measures should be taken due to significant slopes or special underground characteristics which are explained in Section 3.4 in more detail. The plans indicate the connection of the site to the national road D595 Denizli-Usak by a 20 m wide road.

One important step in the approval process of the above plans was to change the present agricultural use to industrial use. For that purpose an application by the Kaklik Municipality has been made to Denizli Agricultural Directorate via Denizli Governship for the determination of the area as the “Energy Generation Area”. In order to do this, this directorate applied at the ‘Soil Protection Committee’ for an approval. A decision has been taken by Denizli Province Soil Protection Committee on 22 August 2008 to use the project area for other than the agricultural purposes provided that a Soil Protection Project is prepared by a certified company. The Soil Protection Project was submitted

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to Denizli Agricultural Directorate and requested final approval from Ministry of Agriculture and Rural Affairs (MARA). It was approved by the MARA on 24 September 2008 and is mainly related to prevention of soil erosion during earthworks.

3.4 GEOLOGY

3.4.1 Regional Geology

In the following, geological formations of the region are described (cf. Table 3-1). The description is based on the geological report prepared by Görkem Engineering ( Mevzii Imar Planina Esas Gözlemsel, Jeolojik Etüt Raporu, Suat Kirmizi , 2008) in the course of the investigations for the development plan.

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

The investigation site was uplifted during the late Pliocene and in Quaternary time, and an east-west graben was formed as a result of tensional forces applied to the regions where the earth’s crust was relatively thin. Magma rose to the surface, and hydrothermal circulation systems developed along the graben faults causing the subsequent hydrothermal karstification of the limestone strata (e.g. Kaklik cave).

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Table 3-1 Geological formations in the site area

Age Symbol Formation Lithology Lithology

QAl 1-QAl 2 New alluvium pebble,

sand, clay, silt

QTç Alluvium pebble stone QUATERNARY QUATERNARY

Kızılburun Pebble stone, sand Tmkb stone, silt stone, clay

CENOZOIC CENOZOIC Formation stone, clayey lime

stone, with lignite levels

Karadere Pebble stone, pebbly

NEOGENE NEOGENE Tok Formation sand stone, pebbly mud stone

Çökelez Jkcc Limestone Limestone

Malı da ğı Sandstone and shale Kmf MESOZOIC MESOZOIC intercalation with Formation crystallized limestone intermediary level, JURASSIC-CRETACEOUS JURASSIC-CRETACEOUS

3.4.2 Geology of the Site

A large part of the site is located in Neogene aged Kızılburun Formation, Plio- Quaternary aged old alluvium terraces, and Quaternary aged alluviums.

Neogene Aged Units

Kızılburun Formation Kızılburun Formation which constitutes the base of the study site and covers a wide area comprises blocky pebbles, pebble stones, sandstones, clay stones, silt stones, and occasionally clayey-limestone insertions. The formation starts with severely graded pebble stone, pebble stone and sand stones at the base. The pebble stones are usually granule supported and those sections where sandstones and mud stones with coarse granules form a matrix do not exceed 20%.

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The pebbles are little or semi rounded. The elements are usually schist, marble, ultra basic, ophiolite pebbles and quartzite compounds. Towards the top, the formation also contains pebbles from tertiary sedimentations which are older than itself. The lateral continuity being directly proportional with increases in thickness exhibits very thick beddings as well. All the data available show that the blocky pebble stones, pebbled sand stones, and coarse sand stones placed at the base are alluvium range sedimentations. Its typical colour is reddish brown. Gradual lightening in colour and thinning in granules is observed towards the top.

Both the alluvium range and the braided river sediments characterize an oxidized environment with their reddish brown and yellowish colours. The formation also exhibits at some places a pile composed of clayey limestone, clay, lime-sand stones with mica-clay, clayey limestone, pebble stones, sand and pebbles. Details of the excavated pits in this formation can be found in Annex D.

Quaternary

Alluvium Terraces; (QTç)

The alluvium terraces are Plio-Quaternary aged. The formation is composed of flat or cornered pebbles. Sandy, silty, clayey levels are found between pebbles and it is occasionally loosely tied. The unit placed on Kızılburun formation at the study site has a thickness of 3-5 meters (cf. pit 4 in Annex D).

Alluvium (QAl)

Old Alluvium (QAl1) The old alluvium in the study site comprises pebbles, sand, silt and clay, and is observed in the southern and western part . The thickness of the alluvium is variable, about 93 meters of alluvium thickness has been measured in geothermal surroundings (KD9 drilled in Büyük Menderes Rift Valley, Sun, 1990).

New Alluvium (QAl2) The sediments constituting the dry stream bed at the south of the lots 160,129,138,137 in the study site are named as new alluvium. The new alluvium unit constitutes of materials carried by the stream and comprises in general pebbles. The thickness and spread of the formation is limited.

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3.4.3 Areas with special precautionary measures

Based on the observations in the geological study, some areas were identified where special precautionary measures shall be carried out (ÖA1 and ÖA2) (cf. Figure 3-2). For the quarry, a separate study shall be carried out.

Figure 3-2 Areas where precautionary measures are required (ÖA1, ÖA2) as identified in the development plan 1:5000

Area with precautionary measures #1 (ÖA1)

In the area ÖA1 special measures should be taken due to the existing slopes in the site. One area is located in the centre of the site and stretches in north- southern direction with a width of approximately 20-40 m. The second area is located at the southern border of the quarry (10-25 m wide and 160 m long). These areas should be flattened and during construction phase excavation slopes have to be supported. Foundation piles have to be at the same lithologic level, different settlement levels should be avoided. The static has to be determined according to results of the geotechnical survey. In the area at the quarry, a buffer zone to the quarry has to be considered where only roads can be placed.

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Area with precautionary measures #2 (ÖA2)

The former dry river bed has been determined as ÖA2 and the area is 350 m long and 30-65 m wide. During construction phase, the soft ground in the creek bed has to be excavated and building foundation piles have to be settled on a safe ground. The static of the buildings has to be determined according to the results of the geotechnical survey, ground and base surveys (incl. analysis of stability, compaction and settlement). In addition, the recommendations from DSI have to be observed.

3.4.4 Tectonics

Çukurova Basin complex in which the study site is included is located to the east of the region where Büyük Menderes and Gediz Rift Valleys converge in the West Anatolia expansion area of the Denizli Rift basin towards the left direction of Göksu. The generally NW-SE oriented rift valley system is surrounded by oblique throw normal faults. Pamukkale-Karahayıt fault with NW-SE orientation in the North, Babada ğ-Denizli fault with NW-SE orientation in the south, and Honaz fault with approximately E-W orientation in the east of the basin are the main earthquake producing faults in the region (cf. Figure 3-3).

Figure 3-3 Tectonic Map of Denizli and its vicinity (cf. Görkem report, Aydan and others., 2001).

Earthquakes to affect Denizli and its vicinity may be expected from those normal oblique throw faults constituting Büyük Menderes Rift Valley. The fault segments constituting Büyük Menderes Rift Valleys have caused a large number of earthquakes in the past and will likely cause earthquakes in the

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future as well. Earthquakes with low-mid magnitudes (M: 4.9-6.8) may be expected in Denizli and its vicinity 3.

Denizli basin is located to the east of the region where Büyük Menderes and Gediz rift valleys cross each other, and exhibits a morphology which is related to expansion tectonics. The rift valley which is generally NW-SE oriented in general comprises Quaternary and Neogene sediments. Denizli rift valley is surrounded by normal faults in the north and south.

Active and potential faults identified in the vicinity of Denizli are Pamukkale- Karahayıt, Honaz, Kareteke, Babada ğ, Acıgöl, Çivril-I, Çivril-II faults. The Denizli basin -on which eastern end the power pant is located- is situated in the crossing of three major E-W grabens structures (Gediz, Kucukmenderes and Buyukmenderes).

The centre of Denizli province, its districts and towns are recognized to be within the 1st degree earthquake risk region. The district Çivril only, is in the 2nd degree earthquake risk region.

According to the Görkem report, there are lots of faults at the site. By recent investigations, “Elmalı” Fault has been identified to the north of Elmalı Mountain. This fault is a vertical throw towards 1.5 km northwest of the project site. Earthquake studies have shown that Elmalı Fault is not active. A map of the active faults in the Denizli area is given in Figure 3-4.

3 A directly proportional relation between the lengths of the fault segments to cause the earthquakes and the magnitudes of the earthquakes is widely accepted. This hypothesis is valid for normal faults. When calculating the seismicity of a region, the length, type, direction of the fault causing the quake, the periods of the earthquakes caused by the fault, the distance from the fault to the site studied and the characteristics of the ground at the study site should be assessed all together. A weak ground is identified by characteristics such as landslide sites, the closeness of the groundwater to the surface, the thicknesses of untied or loosely tied units like alluvium (20 meters or thicker) their lithological structures. Weak grounds are intensity amplifying factors in cases of earthquakes.

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Figure 3-4 Active Fault Map pertaining to Denizli and its vicinity (black line –active fault; grey line – potentially active fault)

In Denizli basin, more than 200 earthquakes have occurred within 6 months after the Honaz centred earthquake with magnitude 5.2 on date April 21, 2000. 69 people have been injured due to panic resulting from the earthquake with magnitude 4.7 that occurred October 4, 2000. The focus centres of the earthquakes in 2000 were mostly highly urbanized zones.

In a monthly seismic monitoring study conducted by TÜB ĐTAK Marmara Research Centre in order to explore the micro earthquake activity in Denizli Region, it is indicated that the focus centres of micro earthquakes up to magnitudes of 2.8 have been populated around Üzerlik and Kaleköy located in Denizli plain. A total of 440 earthquakes with magnitudes 2.5-5.5 have occurred between dates July 23, 2003 and July 31, 2003. According to a final damage assessment issued following the earthquake disaster in Denizli province, Buldan District, 327 heavily, 495 moderately, and 465 lightly damaged buildings were identified.

According to the “Map of Earthquake Regions of Turkey” issued by the Ministry of Public Works and Settlement of Republic of Turkey, the province of Denizli is within an earthquake belt of the 1st degree with basic seismic coefficient 0.4. As result, the land buildings and land based structures for this project should be designed to withstand ground accelerations of 0.4g.

The study site is located on alluvial deposit of quaternary age with a varying thickness between 50 to 150 meters. Fault zones under the alluvium are traceable in the bedrocks.

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An earthquake hazard assessment was carried out by Prof. Erdik, Bogazici University in July 2008 using a two-tiered approach. For the so-called Operation Basis Earthquake (OBE) that the plant can likely be exposed during its lifetime (50% probability of exceedance during its lifetime of about 50 years) the power plant should remain operational. For the Maximum Considered Earthquake (MCE) that would be associated with a 2% probability of exceedence in 50 years the power plant should be safely shut down (for inspection and repair of structures and systems) without endangering human lives and the safety of the environment.

For the OBE scenario it is very likely that the power plant will be exposed to an earthquake of a magnitude of about 5. The seismic centre will be either right underneath the site at a depth of about 10km or in the vicinity within a rupture distance of 10km. Such an earthquake can create median peak ground acceleration (PGA) of about 0.10g (deterministic approach). An event with a magnitude of 4.8 took place about 15 km southwest of the Power Plant Site. A probabilistic approach reveals 0.16g as reasonable PGA level for OBE.

The maximum considered earthquake (MCE) will likely originate from Gediz, Kucukmenderes and Buyukmenderes Grabens with a minimum rupture distance of about 20 km. The magnitude of this earthquake would be around 7 considering the historical seismicity of the region. Another seismic center would be the Baklan Graben associated with a magnitude of 6.5 at a rupture distance of about 6-7km. Both scenarios would be earthquakes with a “normal” rupture mechanism and the associated PGA levels are calculated with respectively 0.27g and 0.48g (deterministic approach). The estimate for the MCE according to the probabilistic approach is 0.56g.

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Figure 3-5 Earthquake Risk Map of Denizli

1. Degree 2. Degree 3. Degree 4. Degree 5. Degree Province center District center Subdistrict center Live faults Road Express way Railway River District border Province border

The above mentioned Görkem report was approved by Denizli Directorate of Public Works and Settlement on September 5, 2008. Thus, according to Turkish legislation the relevant provisions of the “Regulation on the Buildings to be constructed in Disaster Areas” shall be strictly complied with during the planning stage of the buildings to be constructed during the construction phase of the proposed project, and if necessary, separate ground studies and earthquake risk analysis for each building to be constructed shall be carried out. All studies shall be carried out in reference with the opinions of the Directorate of Public Works and Settlement and other authorized institutions.

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3.5 SOILS

In the study area, mainly brown forest soils and alluvial soils are present. The brown soils are observed in the mountains under forest and show shallow thickness. Due to the slopes the brown soils in that area suffer from erosion. Carbonates are washed out where precipitation is high. Such soils exhibit acid reaction. Carbonates accumulate at the B horizon where precipitation is less. Such soils exhibit slight basic reaction (forest soils with lime).

Brown soils are present on site in the northern and southeastern parts. The brown soils in the project area are classified as soil type VII according to a classification for land use capacity. Type VII comprise no fertile soils which are strongly influence by water erosion, stoniness and saltiness (cf. Figure 3-6).

Colluvial soils are present at the bottom parts of the slopes and in the river valley since they are formed by sediments that are washed out from areas which a located on a higher elevation. They are usually fertile soils but often needs to be irrigated. Colluvial soils are found in the middle and in western parts of the site (not irrigated) and are classified as soil type II i.e. fertile soils. However, due to the slopes, the colluvial soil is endangered by erosion.

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Figure 3-6 Main soil groups on site and its vicinity

3.6 HYDROGEOLOGY

In the course of a geotechnical study ( Geoteknik Etüd Müavirlik ve Mühendislik A. ., June 2008) eleven soil borings were carried out to investigate geotechnical and hydrogeological conditions on site (cf. Table 3-3).

In general, the borings revealed Quaternary alluvial deposits with a thickness of about 32 m and conglomeratic bedrock. The alluvial layer comprises Neogene and late Miocene units consisting of sand, clay, gravel and mixtures of these. Shallow groundwater was encountered in the alluvial deposits and

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upper layers of conglomerate between 26 and 38 m below ground level (bgl). This shallow groundwater is assumed to be locally perched groundwater. The main aquifer is expected in greater depths.

The RWE well#1 has been drilled on the site and is approx. 150 deep. The main geological layers are given in Table 3-2.

Table 3-2 Geological characteristics of RWE well#1

Depth (m) Soil Type

0-8 Fine gravel

-16 Conglomerate

-25 Clay gravel

-32 Clay

-56 Sand with clay and gravel

-58 gravel

-66 Gravel with sand

86 conglomerate

-93 Gravel with sand

-117 Sand silt

-150 Layers of gravel with sand and silt, gravel with silt

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Table 3-3 Geological borings on site

Unit Boring logs Thickness Lithology [m]

Upper unit S-1, S-3, S-8 and S-9 ~ 12 (34) light brown, gravelly-sandy clay

Upper unit S-2, S-4, S-5, S-6, S- ~ 9 (23) light brown clayey-sandy gravel 7, S-10 and S-11

Medium unit S-1, S-2, S-3, S-6, S- ~ 28 (50) clayey gravel, gravely clay, coarse gravel 8, S-10 and S-11

Medium unit S-2, S-4, S-5 and S-7 ~ 34 (55) consolidated clay, light yellow

Lower unit S-1, S-4, S-6, S-10 ~ 39 (55) reddish-pinkish conglomerate units and S-11

Lower unit S-2, S-3, S-7, S-8 and ~ 31.5 (55) Clayey gravel, gravel S-9

3.6.1 Groundwater Quality

A groundwater sample was taken from the RWE well#1 and analyzed for water quality (cf. Table 3-4) and compared against Turkish Water Polution Control Regulation (Water Pollution Control Regulation, published in Turkish Official Gazette 25687 on 31.12.2004) and German and Dutch reference lists.

According to Turkish regulation, the groundwater is classified as quality class IV poor quality due to elevated Sulphate values. Compared to international reference standards, the water quality can be evaluated as follows: Within the German Soil Protection Ordinance (BBodSchV) groundwater trigger values (quality check values) have been established to assess impacts to groundwater originated from contaminated soil (pathway soil – groundwater). Exceedances of trigger values imply further investigations and a case-by-case study. The Dutch List issued by the Dutch Ministry for Environment, Housing and Spatial Planning updated latest in 2000, is a Europe-wide recognised tool for the assessment of impacts to soil and groundwater. Exceedances of intervention values indicate a severe impact to soil/groundwater and require detailed assessment, and most likely remedial activities.

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Table 3-4 Results of groundwater sampling at RWE well#1

Parameter RWE Turkish German Dutch List well#1 Water BBodSchV Intervention Quality Trigger Value

Class* Value

Physical and inorganic - chemical parameters :

pH 7.4 I

Dissolved Oxygen (mg O 2/L) 5.2 I Chloride (mg/L) 14.63 I Sulphate (mg/L) 807 IV Nitrogen of Ammonium (mg/L) 0.39 II Nitrogen of Nitride (mg/L) not I detected Nitrogen of Nitrate (mg/L) 0.87 II Phosphor (Total ) (mg/L) Not I detected Total Dissolved Matter (mg/L) 1388 II Sodium (mg/l) 17.08 I

Đnorganic Pollution parameters :

Cadmiyum (µg Cd/L) Not det. I 6

Mercury (µg/L) 0.15 II 1 0.3

Lead (µg Pb/L) Not det. I 75

Arsenic (µg/L) Not det. I 60

Chrome (Total ) (µg Cr/L) 7 I 30

Nickel (µg Ni/L) 45 II 75

Zinc (µg Zn/L) 2 I 500 800

Floride (µg/L) 820 I 750

Iron (µg Fe/L) 7 I

Manganese (µg Mn/L) 24 I

Boron (µg B/L) 685 I

Barium (µg/L) 34 I

Aluminum (µg/L) 48 I

* Water Quality limit values specified in the Regulation on Protection of Water Quality (Quality Criteria According to Continent Water Sources Classes). ** German Drinking Water Ordinance, 2001

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The laboratory testing show elevated concentrations for sulphates. Other analysed parameters indicate on normal water conditions. The elevated sulphate concentration is regarded to be related to elevated geogenic background levels in the area.

As conservation of evidence it would be helpful to analyze the groundwater during detailed design stage for anthropogenic substances such as oil and grease.

3.6.2 Use of Groundwater

Groundwater is used for irrigation and also drinking water purposes in the region. Besides groundwater, also surface water reservoirs are used for drinking water in the Denizli region.

In the vicinity of the site, groundwater is used by the irrigation cooperatives in Kaklik and Yokusbasi (cf. Table 3-5). The depths of the wells are between 150 to 200 m bgl and abstraction rates vary between 15 and 50 l/s. Approximately 15 Mio. m³ groundwater per year are used for irrigation purposes in the vicinity of the site.

Decreasing groundwater levels in the Kaklik area are observed within the last 10 years.

Table 3-5: Groundwater abstraction in Denizli Region

Type of well Use Number of wells Yearly withdrawal

[approximately m 3]

Kaklik Irrigation Irrigation 7 wells 4,000,000 Cooperative

Kaklik Irrigation Irrigation 5 wells (artesian) 10,000,000 Cooperative

Yoku ba ı Irrigation Irrigation 6 wells 1,000,000 Cooperative

Total 15,000,000

3.7 HYDROLOGY

The project area drains to the west and finally to Büyük Menderes River which is the largest river in Denizli Province and one of the biggest rivers in Turkey. Büyük Menderes River has an average flow rate of 38.8 m³/s and

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flows into the Aegean Sea. Büyük Menderes River is located approximately 40 km to the northwest.

Approximately 2.8 km south of the site, the Çürüksu (Aksu, Emir) River passes by. Çürüksu River collects waters from the Honaz Mountain in the south, as well as from the Kaklık regions and flows finally into the Menderes River. It has a length of 101 km and an average flow rate of 9.26 m³/s. Çürüksu river 4 is usually almost dry during the summer months.

Approximately 500 m to the northwest, Çaykara creek passes the site. Approximately 500 m east of the site Hasıl creek is located (cf. Figure 3-7). Both creeks are temporary streamlets. A former branch of Hasil creek diverts from the creek to the west and passes through the site (cf. Figure 3-8). This former branch was identified in the geological investigations as dry river bed. According to DSI information, the river has lost its stream characteristics due to excavation works approximately 25 years ago.

According to information from DSI, the site was never flooded. DSI estimated the potential flow rates of floods after 50 and 100 years 2.8 m³/sec and 3.7 m³/sec.

An irrigation channel passes through the western part of the site approximately 300 m from the western boundary (cf. Figure 3-7). This irrigation channel starts in the vicinity of cement factory with low capacity. It passes the site for a length of 200 m and runs south towards Kaklik afterwards. The channel irrigates an area of approximately 60 ha. The owner of the irrigation channel is the Kaklik Irrigation Cooperative.

4 The translation of “Çürüksu River” means "rotten water" which is related to its high calcium concentrations.

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Figure 3-7 Surface waters and irrigation channels

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Figure 3-8 Dry creek that passes through the Project Site

3.8 SURFACE WATER QUALITY

In Turkey the Water Pollution Control Regulation (WPCR, Official Gazette No. 25687 R.G.) from 31.12.2004, Table 1 establishes classes for surface water quality classes. In the following:

Table 3-6 Turkish Surface Water Quality Classes and sampling results

Parameter Classes I II III IV

pH 6.5 – 8.5 6.5 – 8.5 6.0 – 9.0 < 6 or > 9 BOD 5 (mg/l) 4 8 20 > 20 COD (mg/l) 25 50 70 > 70 Chloride (mg/l) 25 200 400 > 400 T. coli (EMS/100ml ) 100 20,000 100,000 > 100,000

Class 1: High Quality Water, Class 2: Less Polluted Water, Class 3: Polluted Water, Class 4: High Polluted Water. Note: There is no limit value for suspended solid (SS).

In Denizli Province the major source of water pollution is the increasing industrial and domestic waste water discharge because of industrialization and urbanization in and around Denizli City. Agricultural fertilizers and chemicals also contribute to water pollution. Meanwhile, almost all private companies that produce polluted waste waters have built and are operating waste water treatment facilities.

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No sampling results are available for surface waters in the vicinity of the site. However, the creeks come from the mountainous area in the north, thus it is estimated that the streamlets are not polluted by industries but may only be influenced by agricultural activities (e.g. fertilizers).

3.9 CLIMATE

3.9.1 General Climatic Conditions

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

The meteorological station measuring the needed meteorological data located nearest to the project site is located in Denizli (37 047’ North 29 005’ East; 426 m above sea level) and has a distance of 30 km to the project site. Characteristic meteorological data like rainfall, temperature, relative humidity, and wind speed are described in following sections. Data from the Denizli meteorological station has been averaged over a period of approximately 30 years (1975 – 2006).

3.9.1.1 Precipitation and Snowfall

The average annual precipitation in the region is 556 mm. During the observation of 30 years a daily maximum of 106 mm was recorded. Monthly averages range between 8 mm in August and 79 mm in January. Winter and spring show higher precipitation values than the summer.

Only about 3 foggy days and 8 days with snowfall are recorded on average. Highest snow cover in January and February is about 30-40 cm with a life time of about 2 days.

3.9.1.2 Temperature and Sunshine

The temperature variation ranges from -10.5 °C to 42.4 °C with an average of 16.1 °C.

January is the coldest month with a monthly average of 5.8 °C. However, the highest temperature of this month can be rather high which is indicated by the highest recorded temperature of 21 °C.

Annual number of days with temperatures below 0 °C (frost) is 38 days on average.

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July and August are the hottest months with 27 °C as average temperature. The maximum temperature can reach about 42 °C.

The average monthly sunshine hours range between 3.75 hours in January and 12 hours in July. The solar radiation can reach 1.8 kW per square meter.

3.9.1.3 Evaporation

Average daily evaporation (potential evapotranspiration) is about 0.35 mm however with a broad variation throughout the year. Almost no evaporation occurs in the wintertime, whereas for the hottest months July and August the average evaporation is about 20 – 23 mm per month.

3.9.1.4 Wind Characteristics

The wind regime in the Denizli region exhibits prevailing wind directions from northnorthwest (NNW) and westnorthwest (WNW).

A wind rose diagram of the frequencies of wind directions for the years 1975 to 2006 is given in Figure 3-9. This provides the long-term average of abundance of a wind direction. The northwestern (WNW to NNW = sector of 70 °) wind directions were observed in about 40% of the year. Winds from the NE to the S (sector of 150 °) are relatively seldom with only 21% of a year abundance.

Figure 3-9 Directional frequency of wind measured at Denizli station, 30 years average

N % NNW 16 NNE 14 NW 12 NE 10 8 WNW ENE 6 4 2 W 0 E

WSW ESE

SW SE

SSW SSE

S 1975 - 2006 long-term average

Source: Denizli Meteorological Station

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While the long-term average wind speed is only 1.1 m/s (4 km/h), strong winds of up to 29 m/s (105 km/h, hurricane) were also recorded. The annual average of stormy days with more than 17 m/s (62 km/h) is 4.6 days. The number of windy days between 11 m/s and 17 m/s (39-62 km/h) is about 26 days. Please note that the number of windy or stormy days indicates the days when such situation was encountered. The figures do not provide the duration of the windy episodes which might be only few hours of a day (in general 1 – 3 hours/episode).

3.10 AMBIENT AIR QUALITY

3.10.1 Area of Interest and Available Data

A project’s airshed can be defined as the area where the plant's emissions can potentially cause adverse impacts. As a first approach, this so-called air shed can be calculated from the height of the highest emission source. For the planned power plant this air shed is approximately a radius of 3 km around the plant 5.

For the characterization of the ambient air quality in the project area measurements of the closest ambient air quality monitoring station are available which is located in Denizli at about 30 km west of the proposed site (cf. Error! Reference source not found. ). The monitoring shows elevated levels close or above international quality standards during winter time (cf. Table 3-8). However, given the distance to the site and the presence of close-by urban emission sources like a large number of households, high traffic, and industries in and around Denizli, the measurements at this station have only very limited representativeness for the site area.

5 The relevant air shed, which for most plants includes the point of maximum impact, is determined according to the German regulations (TA Luft – Technical Instruction Air as 50 times the stack height ( i.e. 50 x 60 m=3 km)

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Figure 3-10 Sulphur dioxide and PM10 monitoring at Denizli ambient air quality station

In order to obtain local data for the ambient air quality baseline monitoring were performed in the course of the EIA for nitrogen dioxide, sulphur

dioxide, and particulate matter (PM 10 ).

3.10.2 Emission Sources in the Project Area

Air quality is a dynamic function of chemical, physical and biological elements of the environment and is primarily influenced by the existence of emission sources for air pollutants. Local air quality is influenced by the pattern of air pollutant emission sources located in the project area and its vicinity but also by dominant sources further away. Types of emission sources are industries, residential areas, traffic, and natural sources (e.g. dust blown from arid areas).

The Project area of the CCPP can be characterized as a mixture of primary rural land use with some industrial sources as well as roads.

Industries and other important air emission sources located in the project's vicinity are, inter alia :

• A cement production plant is located about 2.5 km west of the site; • Limestone and marble quarries are located in the area extending west of the cement plant and also on the slopes of the mountain ranges south of the valley; • A major road (Denizli–Ankara Highway) is running at a distance of about 1.5 km south of the site; • A railway track (diesel traction) is aligned in parallel to the highway;

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• Agricultural activities can be a source of dust emissions under dry and strong wind conditions; • Settlements, e.g. Kaklik, with residential and commercial activities (heating, cooking, wood burning)

The cement plant is an emission source of, in particular nitrogen oxides (NOx), carbon monoxide (CO), and dust (particulate matter –PM). Quarry activities pose local sources for dust.

Further emissions of NOx, CO, SO 2, VOC, and PM are related to traffic and households (cooking, heating). Agricultural activities or arid land may cause dust emissions through physical disturbance of the soil surface (e.g. by wind erosion and vehicle movements).

3.10.3 Monitoring of Ambient Air Quality

For characterisation of the current ambient air quality, nitrogen dioxide (NO 2),

sulphur dioxide (SO 2), and particulate matter (PM) are the pollutants of

interest. For the EIA, NO 2 and SO 2 concentrations were measured at 35 sampling locations for two one month periods between June and August 2008 by means of passive sampling. Additionally, spot samplings for particulate matter (PM10) were taken in June 2008 at two locations on the proposed power plant site. The sampling locations are shown in Figure 3-11.

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Figure 3-11 Ambient air sampling locations

Measurement of NO 2 and SO 2

Passive air sampling of NO 2 and SO 2 was performed by means of diffusive samplers to receive information on monthly concentration in an expanded area around the site.

The sampling tubes, which are specific to the compound being sampled, are designed to allow air to circulate by passive diffusion during long-term sampling (produced and analysed by Passam AG, Switzerland). Each tube contains a small quantity of a chemical that reacts with the subject substance

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in the air. The tubes are exposed to the ambient air for a certain period of time, resealed and returned to the laboratory for determination of the average concentration during the sampling period.

The sampling locations were chosen to cover an area with 5 km radius around the CCPP site (cf. Figure 3-11). The results are listed in Table 3-7.

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Table 3-7: Ambient air quality monitoring - results of passive sampling

Nitrogen dioxide (NO 2) (µg/m³) Sulphur dioxide (SO 2) (µg/m³) June 14 – July July 15 – August June 14 – July July 15 – August 15, 2008 13, 2008 15, 2008 13, 2008

Location 1 6 s.l. 14 s.l. Location 2 4 24 5 9 Location 3 5 s.l. 6 s.l. Location 4 4 26 7 8 Location 5 6 s.l. 6 s.l. Location 6 9 16 5 8 Location 7 11 17 6 10 Location 8 14 23 s.l. 9 Location 9 14 18 s.l. 9 Location 10 25 s.l. 13 s.l. Location 11 s.l. 5 2 s.l. Location 12 10 5 11 6 Location 13 10 5 7 4 Location 14 10 4 8 9 Location 15 13 6 15 5 Location 16 s.l. 12 4 7 Location 17 13 9 4 s.l. Location 18 8 s.l. 5 15 Location 19 10 11 <1 8 Location 20 8 s.l. 6 s.l. Location 21 38 s.l. 5 s.l. Location 22 s.l. 4 4 5 Location 23 22 17 s.l. 6 Location 24 3 s.l. 2 s.l. Location 25 4 7 s.l. s.l. Location 26 s.l. 5 5 9 Location 27 15 s.l. s.l. 6 Location 28 16 6 5 s.l. Location 29 12 5 7 5 Location 30 7 14 s.l. 7 Location 31 3 24 5 10 Location 32 3 12 6 8 Location 33 4 12 9 9 Location 34 3 12 5 6 Location 35 4 4 <1 9 Monthly average 10 (3 – 38) 12 (4 – 26) 6.1 (1 - 15) 7.8 (4 - 15) (min – max) Average of 11 6.9 2 months

s.l. - sample lost

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The results obtained at the sampling locations revealed a broad variation for

NO 2 ranging from 3 µg/m³ to 38 µg/m³. Elevated values (above 20 µg/m³) occurred at locations scattered throughout the area. During the summer months the wind frequency shows the same pattern as the annual average with winds mainly from the west-northwest and north-northwest. Thus, it is

very likely that the elevated NO 2 levels at sampling location 31 are related to

the cement factory emissions. The elevated NO 2 concentrations at sampling locations 4 and 9 are assumed to be related to the road traffic. Differences

between the two sampling months were unspecific. The average NO 2 concentration of the samples was 11 µg/m³.

The variation of SO 2 results was between <1 µg/m³ and 15 µg/m³. There was no distinct pattern of impact or for the two sampling months. The average

concentration of all samples was 6.9 µg/m³ for SO 2.

PM10 measurements

PM10 6 measurements were performed by determining the mass of particulates that accumulate on a filter cartridge over time when air is sucked through the filter. The spot check measurements were performed on June 29, 2008 at the south-western and the south-eastern corner of the site (cf. Figure 3-11). The measured concentrations were about 10 µg/m³.

3.10.4 Assessment of Ambient Air Quality

For the evaluation of the results of ambient air measurements national and international air quality standards are taken as reference.

The Turkish air quality standards are specified by the Air Quality Evaluation and Management Regulation (AQEMR) published in the Official Gazette number 26898, dated June 6, 2008. In Table 3-8, these standards are compiled together with international standards published with the IFC General Environmental and Health and Safety Guideline (2007) 7. Additionally, the ambient air quality standards of the European Union are included 8. In order to evaluate substances not covered in these guidelines, ambient air quality

6 PM 10 stands for particulate matter with size below 10 µm which, with respect to human health, is considered the relevant portion of dust.

7 Formally the international standards are to be used for an environmental assessment only in absence of local ambient air quality standards.

8 Council Directive 2008/50/EC on ambient air quality

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standards specified in the German Technical Instruction on Air Quality Control (TA Luft, 2002) are used for reference.

Different standards and reference values are established for annual average and short-term ambient air concentrations. Annual (long-term) standards are specified to avoid adverse cumulative effects on human health and/or the environment during long-term exposure. Short-term standards of 1-hour, 8- hours, or 24-hours average concentrations are to avoid acute adverse impact on human health caused by short time exposure to high intake levels of a pollutant.

No evaluation of background air quality was possible against hourly standards since the passive sampling do not provide for short term sampling.

Based on the air sampling results in Table 3-7 the sampling results can be evaluated as follows 9:

• Based on the monthly concentrations, the applicable national and

international standards were met for nitrogen dioxide (NO 2). The highest measured concentration for a single monthly average was 38 µg/m³ at Location 21 which was situated north of Yokusbasi 10 . All other values were below 26 µg/m³ and the average of all samples was 11 µg/m³. The highest two-months average was 20 µg/m³ which, compared to the most stringent international standard of 40 µg/m³ (IFC, EU), means a portion of 50%.

• The measured sulphur dioxide (SO 2) concentrations were below 15 µg/m³ for a single month. The two-months averages were below 10 µg/m³ which

9 •Since no standards are defined for a monthly average, the measured monthly averages can be taken for comparison with annual average standards. While doing so, the results will be a conservative (more adverse) overestimation. The two-months average is the better choice but might still be an overestimation. This evaluation approach can be followed as long as seasonal heating is not the predominant source of emissions in the close vicinity of a sampling location. In case heating could be present, concentrations during winter time can be higher than those measured in the summer. Therefore, and since heating sources may contribute NOx and SO2 emissions, the sampling is representative for summer time and ambient air quality may change in the winter. Some of the samples could have been affected by nearby road traffic (e.g. due to access restrictions) or could have been prone to unidentified local sources (e.g. occasional local activities). Therefore, local peak results may have happened.

10 The standards were met, since the EU annual average of 30 µg/m³ applies only for remote ecosystems without emission sources.

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also represents a 50% portion of the most stringent standard which is 20 µg/m³ (EU). The overall average of all samples was 7 µg/m³. • A concentration of about 10 µg/m³ was found from the short-term spot- check sampling of PM10 performed at the proposed site's boundary. Compared to the most stringent international standard of 50 µg/m³ for a daily average, the measured portion was 20%. • For all analysed substances, no specific correlation of the measured values to local structural conditions could be identified. • All applicable national standards were met. Furthermore also the international ambient air quality standards (IFC; EU) were met.

Overall, the Project airshed shows a moderate background pollution.

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Table 3-8: National and international ambient air quality standards

Substance Turkey * IFC guideline value European Commission

Daily Annual Hourly Daily Annual Hourly Daily Annual average average average average average average average average

Carbon monoxide 30,000 10,000 - - -- 10,000 (CO) in µg/m³ (8 hrs)

Nitrogen dioxide 300 100 200 (G) 11 - 40 (G) 5 200 12 40 (NO 2) in µg/m³ 30 13

Sulphur dioxide 400 150 500 125/50/20 - 350 14 125 [50] (SO 2) in µg/m³ (10 min) (T1/T2/G) * 20 15

PM 10 (airborne 300 150 - 150/ 70/ - 50 17 40 particles with 100/ 50/ aerodynamic 75/ 30/ diameter of 10 µm 50 16 20 * or less) in µg/m³

Dust deposition in - 450 ** - - - - - [350] mg/(m²*d)

[] Values in [] indicate additional specifications as per the German Technical Instruction on Air Quality Control (TA Luft) for parameters not included in the regulations of the European Commission. * Air Quality Evaluation and Management Regulation (AQEMR) published in the Official Gazette number 26898, dated June 6, 2008 ** Regulation on Control of Air Pollution Originating from Industrial Plants (RCAPOIR) published in the Official Gazette number 26236, dated 22.07.2006

11 T1/T2/T3/G – IFC interim target-1 / interim target-2 / interim target-3 / Guideline value: The guideline values provided in the IFC General EHS Guidelines are adopted from the WHO Ambient Air Quality Guideline 2005. The guideline values cascade down from higher to lower levels indicated as ‘interim-target 1’ through ‘interim-target 3’ to end up at the ‘guideline value’ with the lowest concentration and highest ambient air quality. Interim-targets take into consideration that achievement of the guideline value in undeveloped or developing countries requires long-term development and improvement effort. 12 The standard may be exceeded up to 18 times per year. 13 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project. 14 The standard may be exceeded up to 24 times per year. 15 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project. 16 T1/T2/T3/G – IFC interim target-1 / interim target-2 / interim target-3 / Guideline value (see footnote for gaseous substances above). 17 The standard may be exceeded up to 35 times per year.

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3.11 ENVIRONMENTAL NOISE

3.11.1 Introduction Sound is a variation of air pressure affecting the ear. The measuring unit of sound pressure level is decibel (dB) which is the logarithm of the ratio of the actual air pressure over a reference air pressure. The human hearing perceives identical sound pressure levels of different frequencies with different strength. For the adaption to human hearing, it is therefore common to use a frequency weighted noise pressure level scale of such kind that the level will match the subjectively perceived level. This is commonly done by implementing the so- called A-weighting scheme indicated by the unit dB(A).

Due to the logarithmic decibel scale, the doubling of a source means a sound pressure level increase of 3 dB(A). However, the doubling of a source will not result in a doubled impression of loudness people have. This is reflected in findings of physiological studies where the human perception was compared against noise levels. Increases in sound pressures levels were evaluated as follows: • < 3 dB(A) insignificant (imperceptible) • 4 – 5 dB(A) threshold of perceptibility • 6 to 9 dB(A) minor significant increase • > 10 dB(A) significant increase, representing a subjective doubling of loudness.

Since sound pressure levels often scatter over a wide scale, they are commonly

shown as the so-called Equivalent Continuous Sound Pressure Level (L eq ) which is the energetic average over the time period of the measurements. The

Leq is the specific parameter used for evaluation of noise against noise

standards which are also L eq .

For better understanding of various noise levels, Table 3-9 provides some examples of noise sources and the associated noise levels.

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Table 3-9 Examples of noise sources and their sound pressure level

Noise source/threshold Approximate Sound Pressure Level

(L eq ) in dB(A)

Pain in the ears 140 Jet take-off (30m) 140 Hearing damage (short-term exposure) 120 – 135 Non-comfort, first pain 120 Jack hammer, Chain saw 100 – 110 Heavy diesel truck (3 m distance) 80 – 90 Hearing damage (long-term exposure) 85 Major road (boardwalk) 70 – 80 Busy restaurant 70 Passenger car (1 m distance) 65 – 75 Normal conversation 45 – 60 Whispered conversation 35 – 45 Breathing 25 Very calm room 20 – 30

3.11.2 Environmental Noise Measurements

Monitoring of current noise levels in the vicinity of the site were carried out as baseline for comparison against applicable noise standards.

In June 2008 the baseline of ambient noise was measured at five locations (receptor points) (Source: Acoustic Report, Ekotest, 2008). Twenty (20) minute intervals were measured to determine daytime (afternoon), evening, and night time (midnight) noise levels.

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Table 3-10: Description of the noise receptor points

Receptor Location Distance to the Area use Point Site Characterisation

1 Southwestern corner of Site boundary Agricultural the project site

2 Southeastern corner of Site boundary Agricultural the project site

3 Eastern boundary of the Site boundary Agricultural project site

Kaklik Northern part of the approximately Mixed area township 1,200 m south of the site

Yokusbasi Western part of the approximately Settlement village 1,500 m east of the site

Receptor points for measurement and calculation of noise levels were selected in the vicinity of the proposed CCPP site (see Error! Reference source not found. ). Three locations were selected at the southern site boundary as required for local EIA. However, the ESIA is focussed on nearest residential receivers so that two other locations were chosen in Kaklik and Yokusbasi. Table 3-10 summarises the location, characterisation and area-use classification of the receptor points. The area-use categories were derived from the observations made at the locations.

A noise level meter was used with the filter setting ‘A’ to receive standardised noise level readings which are adjusted to the human hearing. ‘A’-weighted readings are also required to compare measurements against the noise level standards.

Results and evaluation

The averages of the measured A-weighted noise levels are shown in Table 3-11.

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Figure 3-12 Noise sampling locations

Table 3-11 Measured environmental noise levels in the project area

Location Time and Date of Noise Level (L eq ) * Measurement Day Time Evening Night Time

Site 1 12.06.2008; 17:43 47.6 12.06.2008; 20:27 38.6 13.06.2008; 00:19 37.7

Site 2 12.06.2008; 18:11 50.4 12.06.2008; 19:55 36.8 13.06.2008; 00:47 41.0

Site 3 12.06.2008; 19:04 36.0 12.06.2008; 19:28 36.4 13.06.2008; 01:09 38.1

Kaklik 12.06.2008; 16:45 51.6 12.06.2008; 21:01 51.7 12.06.2008; 23:46 52.7

Yokusbasi 12.06.2008; 15:51 50.5 12.06.2008; 22:47 39.2 12.06.2008; 23:11 40.0 * Leq - equivalent noise pressure level (cf. section 3.11.1)

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The measured day time levels range between 36 dB(A) and 52 dB(A) with the higher values in the settlements. The measured night time levels range between 38 dB(A) and 53 dB(A).

Given similar noise levels measured throughout the entire day at the receptor point in Kaklik, the traffic of the nearby highway is assumed to have been influencing the measurement.

A level of 36 to 38 dB(A) can be assumed as general baseline value for the site neighbourhood.

3.11.3 National and International Environmental Noise Standards and Guidelines

For assessment of the ambient noise situation, Turkish and international noise standards are used (Table 3-12).

Turkish environmental noise standards are specified in the Regulation on Evaluation and Management of the Environmental Noise (CGDYY) dated 07.03.2008 (number 26809). The standards are set forth for different activities (i.e. operation, construction).

For the evaluation of the ambient noise situation against international standards, the standards on environmental noise as published in the IFC General EHS Guidelines are used as reference 18 . These standards differentiate between two principal area use categories: residential and industrial.

18 There are no EU wide noise standards (noise limit values are member state specific).

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Table 3-12 Turkish and IFC standards for environmental noise

Land Use Type (Receptor) Noise Standard (dB(A)

Turkish Requirements as per CGDYY Daytime Evening Night Time (07:00 - (19:00 - (22:00 - 07:00) 19:00) 22:00)

Operation: Areas with land-use 65 60 55 vulnerable to noise impact (e.g. hospital, school), areas with high building density (settlements)

During construction • of roads 75 - • of buildings, others 70 -

IFC Guideline Values (L Aeq )*

Daytime (07:00-22:00) Night Time (22:00-07:00)

Residential 55 45

Commercial/industrial 70

* Noise abatement measures should achieve either the levels given above or a maximum increase in background levels of 3 dB(A) at the nearest off-site receptor location shall be met (IFC General EHS Guidelines, 2007).

3.11.4 Evaluation of the Environmental Noise Situation

The measured day time levels ranged between from 36 dB(A) and 52 dB(A) with the higher values in the settlements. These results meet the Turkish day time noise standard of 65 dB(A) as well as the IFC standard for residential areas (55 dB(A)).

The measured night time levels ranged between 38 dB(A) and 53 dB(A). While the Turkish standard (55 dB(A)) therefore is met, the IFC night time standard of 45 dB(A) was exceeded at the receptor point located in Kaklik. The latter is considered to being affected by the highway traffic.

3.12 FLORA AND FAUNA

3.12.1 General Considerations

The objective of this chapter is to provide qualitative and quantitative information on various biological species on the site and Project’s potential

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study area (5 km radius around the project site). A field study was carried out in June 2008 19 . In addition to field studies, data and information was collected from secondary sources and consultations with local people in the study area. Lists of Flora and Fauna species found in the study area are provided in Annex E.

3.12.2 Ecological Setting of the Area and the Project site

The site is located within Kaklik District (Denizli Province, Aegean Region of Turkey), 35 km west from Denizli. The Site covers 26.7 hectare of land. A significant part of the site is used for dry agricultural activities. Triticum sp. (wheat) and Hordeum sp. (barley) are cultivated in this area. The remaining parts are covered by fallow land and maquis. In the northern part of the area a former quarry is located. The altitude of the site is about 545-595 m. Hardly no natural vegetation within the area except some scrubby vegetation in the east part was found during the field study.

The site is encircled by Çaykara plateau in the south, Çaykara brook approximately 500 m to the west, arlak Hill (722 m) in the north and Karatepe hill in the east. Out of the northern and eastern boundaries of the site, there is a Turkish pine ( Pinus brutia ) plantation of approximately 15 years. The western and southern parts of the study area are mainly used for agricultural activities (Triticum sp. (wheat), Hordeum sp. (barley) and Olive Trees - Olea europaea ) and very few maquis. Further forest area is located in the eastern and southern part of the study area in a distance of approx. 2 km to the site.

3.12.3 Habitats

As the study area is a transition point between Mediterranean floristic region and Irano-Turanian floristic region, it is suitable for various plant species. The terrestrial ecosystem can be divided into two categories, natural vegetation and human influenced vegetation. The natural vegetation of the area is Calabrian cluster pine or Turkish pine ( Pinus brutia ).

The vegetation of the site is influenced by human activities such as cultivated dry agricultural lands and the area of the former quarry. Vegetation and species variety are found as very limited also at the borders of the cultivated

19 The fauna study was carried out by two experts from Gazi University and Hacettepe University, Ankara. The flora study was carried out by Prof. Dr. Hayri DUMAN (Gazi University, Faculty of Science and Literature, Department of Biology) who is one of the authors of "The Red Data Book of Turkish Plants”

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land. Vegetation patterns on the site and its vicinity can be classified into four major types: dry agricultural and fallow land, maquis, steppe and forest. In general, the site comprises approximately 83% agricultural lands and therefore has rather low biological diversity (including the borders of agricultural and fallow lands as well as the area of the dry creek). The remaining parts are mainly covered by the quarry and a small area of maquis (< 3%). The identified vegetation types are presented in Figure 3-13. No natural forest exists in the study area.

There is no concept or defined conservation status for certain habitat types in Turkey.

Vegetation types are dominated by the Triticum sp . (wheat) and Hordeum sp . (barley) (dry cultivated area) and a few maquis species such as Juniperus oxycedrus, Picnomon acarna, Echium italicum, Buglossoides arvensisand, Parentucellia latifolia.

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Figure 3-13 Main vegetation types on site and in the study area

3.12.4 Flora

The flora of the project site has been determined during the field study by observation and collecting samples. Additionally previous floristic studies in the area and literature review were used as references. “ Flora of Turkey and the East Aegean Islands " (1965-1985 and 1988) was used for further identification of plant species.

The observed species are presented in Annex E. Turkish names of plant species are taken from " Türkçe Bitki Adları Sözlü ğü" (Dictionary of Turkish

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Plant Names, Baytop, T., 1997). In addition, Annex E lists phytogeographic regions, habitat types, abundance, endemism and threat categories for endemic and rare species (IUCN and Turkish Red List for plant species, Ekim et. al., 2000) of the species that are found in the area (or found by literature or previous studies).

The Aegean region, especially Denizli and its vicinity is well known regarding their floristic diversity. As result of the field studies, 163 species and sub- species belonging to 40 families were identified in the study area. The distribution of the plant species concerning their phyto-geographic regions is:

• Mediterranean Region (36 species) • Iranian-Turan Region (18 species) • European-Siberian Region (4 species) • Common (103 species)

Among these 163 species, nine are endemic to Turkey. Based on this the endemism ratio in the site is approximately 5%, which is lower than for Turkey in general (30%). One of those endemic species ( Phlomis carica ) is classified as regional endemic. Eight of them are common endemic which means that they are wider spread than regional ones - either in Aegean Region or in whole Turkey. Phlomis carica is abundant in Denizli and its vicinity.

Endangered Species

According to IUCN categories (Ekim et. al., 2000) the common endemic species Allium deciduum and Salvia potentillifolia are classified as "not threatened (NT)". Alyssum pateri, Astragalus ptilodes, Anthemis coelopoda, Moltkia aurea, Phlomis carica, Phlomis nissolii and Stachys tmolea are classified as "least concern (LC)" category.

3.12.5 Fauna

Field observations, surveys and literature reviews were carried out during the fauna studies on the site and its vicinity (approximately 10,000 ha) in June 2008 20 .

In order to determine species and their habitats, nests offspring-footprints (especially for determination of birds and mammals), excreta-food leftovers

20 The fauna studies were carried out by Ass. Prof. Dr. Zafer AYA , Hacettepe University, Ankara, Department of Biology, Zoology Section

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(especially in the determination of mammals), skin-horn-shield (e.g. carapax) and dust were examined. During the identification process, the species were not hunted, collected or killed. Direct observations with binoculars were applied in the identification of mammals and birds. Nets, landing nets, live traps were used in the identification of smaller mammals, reptiles, and amphibians. Following the identification process, the species were set free. In the identification of bird species, instead of netting and mantrapping methods, route and point counting methods were used.

The faunistic observations were carried out on foot and/or by vehicles. Maps at 1/25 000 scale were used during the field work. Besides, GPS was also used in the determination of geographic coordinations and elevations. The observations were carried out from early in the morning till late in the afternoon.

Data regarding biotopes, biogenetic preservation areas, endemic species, threatened species and habitats for wild life were evaluated according to Turkish Red List and international standards such as IUCN catergories and Bern Convention 21 . Within the study area, no wildlife protection area is present according to Decree 9453 (2005). The status of birds and mammals in respect of Central Hunting Commission Circular (2008-2009) is also shown in Annex E.

Mammals

Seven mammals belonging to 6 families were identified in the study area. Three mammal species - brown hare (Lepus europaeus ), European ground squirrel (Citellus citellus ) and blind mole-rat (Spalax ehrenbergi ) were identified by direct observation, respectively only nest holes of ground squirrels were found. Other mammals were not directly observed but were reported by local inhabitants. Literature information confirms their occurrence in the area. Social vole ( Microtus socialis ) was the only mammal which was observed on the site.

The mammal species in the area occur in various habitat types; most of them use at least two habitats (steppe and maquis). These habitats are very limited (10 % and 15 % of the study area). One of the seven observed mammals -

21 According to the Bern Convention, 90% of the Turkish fauna appear as those species requiring protection. This is due to the fact that 80% of the West Paleartic animal population is found in Turkey and that adequate information on the Turkish fauna was not available at the meetings of the Bern Convention.

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European ground squirrel ( Citellus citellus ) - is classified as "vulnerable (VU)" by IUCN (see Table 3-13), but is common and widespread in Turkey.

Birds

18 bird species (14 families) were found in the study area. Among these, 11 are non-passerines and 7 are passerines. The bird species composition in the study area is rather homogenous, from raptors to small passerines, since suitable feeding habitats are present. Most are resident (native) species that are observed throughout the year in the same area, but are not nesting or breeding in the site. Others are summer visitors that are widespread in several regions in Turkey. Five bird species were found to be nesting in the study area: Pigeon ( Columba livia ), Magpie ( Pica pica ) and House sparrow (Passer dometicus ) are nesting in the open lands of the area. In addition: Hoope ( Upupa epops ) and Mountain sparrow (Passer montanus ) are breeding in the forest area in low population (1-2 nests were found).

From 18 bird species observed in the study area, 10 bird species were observed on the site feeding or passing by. None species was found nesting on the site. The three species bee-eater ( Merops apiaster ), Hoope ( Upupa epops ) and swallow ( Hirundo rustica ) observed on site are listed in Annex 2 of Bern Convention (strictly protected species). Five species – Rocke dove ( Columba livia ), Colared dove ( Streptopelia decaocto ), Swift ( Apus apus ), Crested Lark (Galerida cristata ) and Tree sparrow ( Passer montanus ) – observed on site are listed in Annex 3 of Bern Convention “protected species”. No endemic or IUCN listed bird species were found. The site and its vicinity are not within bird migration routes.

Amphibians

Two amphibian species (belonging to 2 families) were identified in the vicinity of the water channel on the site and in the study area: European green toad (Bufo viridis) and Marsh Frog (Rana ridibunda ). European green toad is listed in Annex 2 of Bern Convention as “strictly protected”, Marsh Frog is listed in the Annex 3 “protected”.

Reptiles

Six reptile species (belonging to four families) were identified in the study area: Mediterranean spur-thighed tortoise (Testudo graeca), Agama stellio, Balkan Green Lizard (Lacerta trilineata), Snake-eyed Lizard (Ophisops elegans), Grass Snake (Natrix natrix) and colubrid (Coluber juglans). Balkan Green Lizard was also observed on the site.

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The Mediterranean spur-thighed tortoise ( Testudo graeca) is classified as "vulnerable (VU)" by IUCN (see Table 3-13). Lacerta trilineata is classified as strictly protected (Annex 2) according to Bern Convention. These are a common and widespread species in Turkey. One individual of Grass snake (Natrix natrix ) was found near the water channels in the vicinity of the site. The other reptiles were observed in cultivated lands, steppes and maquis.

All of the reptile and amphibian species identified in the study area are widespread either through Turkey or Aegean Region.

Endangered Species

The fauna species listed by Turkish Red List, Bern Convention, IUCN, and CITES are summarized in Table 3-13.

Out of 33 fauna species that were found in the study area in total, 30 (90%) are listed on Annex 2 or Annex 3 of the Bern Convention, while 3 (9%) are classified in any of the IUCN Red List categories and no species are listed on the CITES appendices.

In Turkey national Red Lists regarding protection or threat status of fauna species are not compiled yet, but are presently being developed. The national criteria regarding the protection of these species are hunting restrictions. Hunting restrictions are defined by the "Central Hunting Commission (MAK)" for each year based on the terrestrial Hunting Law of Ministry of Environment and Forestry and published in the Official Gazette as a Circular.

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Table 3-13 Endangered fauna species identified in the study area

IUCN Turkish Red BERN CITES List*

CR EN VU LR LR LR DD NE A.D I.K. Ap 2 Ap 3 Ap1 Ap2 Ap3 cd nt lc

Mammal - - 1 - - - - - 3 O 4 3 - - - 1 R 1 V

Bird ------6 O 11A4 8 7 - - - 1 R 1 A2 7 V 3 E

Reptile - - 1 - - - - - 5 1 - - -

Amphibian ------1 1 - - -

total - - 2 - - - - - 9 O 11A4 18 12 - - - 2 R 1 A2 8 V 3 E

Protection status according to IUCN, Bern and CITES including threat status according to Prof Dr. Ali Demirsoy (A.D. 2002) and Prof Dr. Đlhami Kiziro ğlu (I.K., 1989) IUCN categories: CR = Critically Endangered, facing an extremely high risk of extinction in the wild in the immediate future. EN = Endangered. not Critically Endangered but is facing a very high risk of extinction in the wild in the near future. VU = Vulnerable. LR = Lower Risk. Can be separated into two subcategories: cd = Conservation Dependent. nt = Near Threatened, do not qualify for Conservation Dependent, but which are close to qualifying for Vulnerable. DD= Data Deficient. Well known, but appropriate data on abundance and/or distribution is lacking. Data Deficient is therefore not a category of threat or Lower Risk. NE = not evaluated. Bern Categories: Ap 2 : strictly protected fauna species. Ap 3 : protected fauna species CITES: Ap1 : Species threatened with extinction. Trade in specimens of these species is permitted only in exceptional circumstances. Ap2 : Species not necessarily threatened with extinction, but their trade must be controlled to avoid utilization incompatible with their survival. Ap3 : species protected in at least one country, and their trading is under control by CITES. *Turkish Red list (not yet finalized but under preparation. Instead textbooks Prof Dr. Ali Demirsoy (2002) and Prof Dr. Đlhami Kiziro ğlu (1989) are used): A.D.: O: Out of Danger, R: Rare,V: Vulnarable, E: Endangered. I.K.: A2 : Endangered, A4 : Lower Risk

Additionally, Prof Dr. Ali Demirsoy (2002) and Prof Dr. Đlhami Kiziro ğlu (1989) have published textbooks on Turkish terrestrial fauna indicating threat statuses, which are often used in Turkey. 23 fauna species are listed on the Turkish Red List out of which 3 as endangered, the others are vulnerable (8),

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rare (2) or observed (9). Most of these fauna species are widespread in Aegean Region as well as in whole Turkey.

3.13 LANDSCAPE AND SCENERY

The power plant will be located at the foot of the Mali Dagi mountainous area in the northern part of the valley east of Denizli. The mountainous area is mainly covered with forest ( Pinus brutia ) whereas the valley is agriculturally used or is covered with maquis/steppe vegation. South of the plain the mountain area of Honaz is located. The elevation difference between the valley and the northern mountain is approximately 700 m to the southern mountain approximately 1100 m.

Greenish-brown colours from the forest are prevailing in the mountains, beige-brown colours from rare vegetation and agricultural fields are prevailing in the plain. In the foot areas of the mountains quarries (marble, travertine) are located and cause dust emissions in the vicinity.

Besides the mountain, a further prominent landscape feature in the vicinity of the site is the cement factory approximately 4.5 km west of the site. The height of the structure is not known but is estimated to be in the order of magnitude of the planned power plant (approximately 60 m).

The settlements in the vicinity are not dominating landscape elements since most of the buildings are limited to two stories. The scenery is rural, especially in the villages of Yokusbasi, Alikurt and Asagidagdere. Kaklik appear less rural since there are some greater settlement structure such as schools and multi storey houses (approximately 3-4 storeys).

3.14 CULTURAL HERITAGE

Turkey is rich with archaeological monuments of different types and periods. However, according to information from the Directorate of Museum of the Denizli Provincial Culture and Tourism Directorate no cultural heritage is present in the site or its vicinity. The Kaklik cave is a touristic site but is not regarded as cultural heritage.

3.15 SOCIO -ECONOMIC CONDITIONS

3.15.1 Introduction

This chapter presents a description of the social characteristics of the project area, and where relevant provides national and regional level data for the wider context.

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The field studies were conducted in an integrated manner with stakeholder participation and consultation efforts; the information obtained from each fostering the other. While this chapter focuses on the findings and main data collection tools of baseline, the approach and findings of the stakeholder consultation efforts are described in detail in Section 5.16.

3.15.2 Methodology for the Collection of Baseline Information

The main objective of the social baseline study was to identify the key socio- economic conditions within the project area with a view to assess the potential impacts and to inform the development of mitigation measures. The study sought to enable thorough information exchange with all the stakeholders and to understand the expectations and concerns regarding the project. The baseline presented hereby also aims to present a benchmark to monitor the future socio-economic changes and evaluate the efficiency of mitigation measures in the future.

The social baseline analysis is based on:

• Primary data, i.e. qualitative and quantitative information obtained through field studies; and • Secondary data, compiled from international and national databases.

3.15.2.1 Primary Data Collection

The social survey was carried out over a period of three weeks by a team of six specialists from the University of Pamukkale. The 5 km radius of the project site is taken as the study area and the socio-economic conditions of the four settlements located nearest to the site (Kaklik town, Alikurt, Asagidagdere and Yokusbasi villages) were studied. The methodology for the collection of primary data consisted of:

• Household surveys; • Key informant questionnaires held with village headmen; • Semi structured interviews with government officers, interested NGOs, workers/officers at marble and textile industries • Focus group meetings with potential vulnerable groups (i.e. women, women headed households, poorer residents, disabled, elderly).

Focus group discussions and semi-structured interviews were undertaken in order to provide detailed information on qualitative, non-measurable issues and to ensure a more inclusive, participatory approach than would have been

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possible from individual questionnaires. Besides the above given structured tools, the study team also made use of informal discussions and direct observation where applicable.

Household Surveys

The household survey was used as the main tool to obtain quantitative as well as qualitative information about the socio-economic situation of the project area. With an aim to minimize sampling bases and cover households with different socioeconomic status, simple random sampling was chosen as method. Detailed information regarding the survey design and methodology is presented in Annex F.

The household surveys were aimed at gathering information concerning:

• Basic characteristics of the households and individuals (e.g. sex, age, marital status, education level, occupation); • Income and expenditures; • Land use and agriculture; • Housing and infrastructure; • Access to education and health services; • Social integration; • Attitudes towards the project.

A total of 217 surveys were conducted, which provided coverage of 10.3% of the households and 12.4% of the population at the four settlements (cf. Table 3-14). At a confidence level of 95%, this sample size limits the sampling error to a maximum of ±6.3%.

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Table 3-14 Number of surveys conducted at each settlement and coverage rates

Settlement Number of Population Number of Number of Household Population households surveys people coverage coverage conducted covered in rate (%) rate (%) the surveys

Kaklik 1350 4 529 145 538 10,7 11,9

Yokusbasi 180 425 23 70 12,8 16,5

Asagidagdere 258 675 26 88 10,1 13,0

Alikurt 182 649 23 81 7,2 12,5

Total 1970 6278 217 777 10,3 12,4

Key informant questionnaires

A total of seven key informant questionnaires were conducted with the three village headmen of Asagidagdere, Alikurt and Yokusbasi and four quarter headmen of Kaklik. The questionnaire aimed at collecting information about the entire community/settlement and involved questions regarding demographics, administration/leadership patterns, local economy and livelihoods, access to natural resources, community infrastructure, migration and potentially vulnerable groups.

Focus Group Meetings

Focus group discussions were carried out with a variety of groups in each of the villages. These groups included farmers, women, women headed households, poorer residents, disabled, elderly and workers/officers at marble and textile industries.

The number and type of focus groups are presented in Table 3-15. Through focus group meetings and semi-structured interviews, information was collected on:

• Demographic profile; • Local employment, livelihoods and natural resource use; • Public services and infrastructure (waste, water, energy etc); • Health and education facilities; • Community development issues; • Attitudes to the proposed project.

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Table 3-15 Number of and type of focus group meetings conducted

Settlement Number of focus Number of Type of focus group group discussions participants

Kaklik 1 8 Women and women headed households

1 7 Young women

1 8 Poorer residents

1 13 Farmers

1 5 Elderly men

1 5 Male workers

1 6 Female workers

1 4 Disabled and ill people

Yokusbasi 1 8 Women

1 7 Farmers

Asagidagdere 1 8 Elderly women

1 9 Farmers

Alikurt 1 7 Women

Total 13 95

Semi Structured Interviews

Semi structured interviews were held with the Kaklik mayor, gendarme, education, health and agriculture officers in the region. The semi structured interviews were designed to get specific information regarding the responsibility area of each institution and understand the expectations/concerns of these local institutions relating to the project.

3.15.2.2 Secondary Data

Secondary data was drawn from regional, national and international databases including:

• Online database of Turkish Statistical Institute (TUIK) available at http://www.tuik.gov.tr • Interactive WEB Portal for Turkish Local Governments (YerelNET) which is developed by the Local Government Research and Training Centre of The Public Administration Institute for Turkey and the Middle East, available at http://www.yerelnet.org.tr/

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• Online database of Statistical Office (Eurostat) available at http://epp.eurostat.ec.europa.eu/ • World Health Organisation Statistical Information System (WHOSIS) at http://www.who.int/whosis/en/ • Statistics of Turkish Ministry of Health available online at http://www.saglik.gov.tr/ • Statistics of Denizli Provincial Health Directorate at http://www.denizli.saglik.gov.tr/ • European Training Foundation (ETF) Country Report for Turkey available at http://www.etf.europa.eu • United Nations Statistics Division (UNSD) Millennium Development Goals Indicators available online at http://mdgs.un.org/unsd/mdg/Default.aspx

3.15.2.3 Limitations to the Social Baseline

Accuracy of Demographic Data

Demographic information is drawn from the online databases of YerelNET (for 2000 figures) and TUIK (for 2006 and 2007 figures). The population counts in 2000 are based on general census, whereas the 2007 counts are based on Address Based Population Registration System (ABPRS), which is considered to be more accurate when compared to the census methodology. This causes a break in the data series. The 2000 counts appear to be higher than the actual populations as population numbers were used to be frequently swelled by local politicians to increase votes.

Difficulty of Describing Trends

The statistical parameters used by TUIK are not always consistent with internationally accepted indicators/parameters and longitudinal data is not available for most parameters (or recently adopted international parameters). This has caused some difficulty in describing the trends and putting forward comparative statistics. Furthermore most data is only available at the district level and it is not always possible to achieve data regarding the villages and the municipality.

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3.15.3 Administrative Institutions/Socio-Cultural Networks

3.15.3.1 Government Administration

The project site is located in Denizli Province, within the borders of Honaz District Governorship and Kaklik Town. Besides Kaklik town, there are three villages, i.e. Yokusbasi, Alikurt and Asagidagdere, within the 5 km radius of the project site. The governance units for these settlements are presented in Table 3-16. Other than the official administration units, no traditional leadership patterns (such as powerful landlords or other influential individuals/groups) were identified in these settlements.

Provincial and District Governorships

The provincial and district governorships are an extension of the central government in Turkey and both the governors and the district governors are assigned by the Ministry of Interior Affairs. They represent the highest authorities (i.e. at the province and district levels) and are responsible to enforce national legislation and coordinate and monitor all the governmental institutions within their purview (i.e. at the province and district levels).

Table 3-16 Administration units of the settlements within the 5 km radius of the project site

Settlement Quarters Highest authority in District level Provincial level the settlement administration by administration by

Kaklik Kaklik Mayor, the Honaz District Denizli municipal assembly Governorship and the council Cumhuriyet Quarter headmen and Denizli assembly Hurriyet Quarter headmen and Denizli assembly Istiklal Quarter headmen and Denizli assembly Istasyon Quarter headmen and Denizli assembly Asagidagdere - Village headmen and Honaz District Denizli assembly Governorship Yokusbasi - Village headmen and Honaz District Denizli assembly Governorship Alikurt - Village headmen and Bozkurt District Denizli assembly Governorship

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Municipal administration

Municipalities are public corporate entities that administer the common needs of a region including services related to health and social assistance, public works, education, agriculture, the economy and the well-being of the citizens.

Municipal administration comprises an assembly, a council and a mayor. The Municipal Assembly, elected by popular vote, varies in size with the population and approves the annual budget of the municipality, plans projects related to public works and city planning and determines taxes, rates of duties, fees and tariffs of various sorts.

Municipal Council members are elected by the proportional representation system from the Assembly members. The council acts as a collateral decision making and advisory body.

The Mayor is the chief executive and representative of the municipality. He is elected for a term of five years. The last election took place in March 2009.

Kaklik municipality is divided to four quarters as shown in Table 3-16. Similar to the village administrations, each quarter has a headmen (muhtar) and a council (ihtiyar heyeti) elected by popular vote. Unlike the villages though, the quarter administrations do not have a legal status, a budget, personnel or an office. They mainly act as traditional governance units and assist municipalities in executing some civic services.

Village Administration

Villages are the smallest units of local government in Turkey. They are administered by the village headmen (muhtar) and an assembly. Members of the assembly and the village headmen are elected for five year terms.

The village headman supervises the planning and operation of communal projects and services and administers directives from higher authorities. The headman hosts government officials, maintains order and presides at civil ceremonies. The village assembly supervises village finances, purchases or expropriates land for schools and other communal buildings, and decides on the contributions in labour and money to be made by villagers for road maintenance and other community improvements.

3.15.3.2 Community-Based Organisations

In addition to the government institutions, there are few informal groups and cooperatives (otherwise known as Community Based Organisations) in the

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project area. Each settlement has its irrigation cooperative and Kaklik has further agriculture and housing cooperatives. There is also an informal group in Kaklik established by university graduates who meet seldomly to discuss about the development issues of Kaklik and advice to the municipality.

3.15.4 Demographics

3.15.4.1 Population Distribution

Turkey has a growing population which has reached 70 million in 2007 (cf. Table 3-17). Denizli Province, in the same year, had a population of 907,325 (TUIK, 2007).

As presented in Table 3-17 and Figure 3-14 the population in the project area continues to increase with natural growth and migration. These two phenomenons are briefly discussed in this section.

Table 3-17 Population, population growth rates and population densities of Turkey, Denizli, Honaz, Kaklik and the villages close to the project area (TUIK, 2007)

Name of Population Population in Annual population Population settlement in 2000 (1) 2007 (1) growth rate for the 2000- Density 2007 period (‰) (3) (cap/km 2)

Turkey 67 804 000 70 586 256 12,7 (2) 92

Denizli Province 850 029 907 325 31.33 (2) 78

Honaz District 24 553 28 941 16.58 (3) 58

Project area 5179 6278 19.43 (3) -

Kaklik Town 3 614 4 529 22.83 (3) -

Yokusbasi 377 425 17.27 (3) -

Asagidagdere 630 675 9.90 (3) -

Alikurt 558 649 21.82 (3) -

(1) The population counts in 2000 are based on general census (obtained from YerelNET), whereas the 2007 counts are based on Address Based Population Registration System (ABPRS) (drawn from the website of TUIK). This causes a break in the data series. The 2000 counts are apt to be higher than the actual populations as population numbers were frequently swelled by local politicians to increase votes. (2) Due to the reason explained in note (1), the population growth rates for Turkey and Denizli are calculated for only 2006-2007 period. The 2006 population count for Turkey (69689256) is obtained from Eurostat (2008), and the population count for Denizli (878899) is obtained from the statistics of Denizli Provincial Health Directorate (DPHD) (2008). (3) Due to the reason explained in note (1) the population growth rate calculated here can be expected to be lower than the actual figures.

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Figure 3-14 Share of natural population change and net migration rate on the annual population growth for 2007 22

32 28 24 19.4 14.2 20 2.0 Net migration rate for 2007 (‰) 16 0 Natural Population 12 Change in 2007(‰) 14.6 8 12.7 11.9 13.7 Population change (‰) 4 0 Turkey Denizli Honaz Kaklik, Yokusbasi, Asagidagdere, Alikurt

As shown in Table 3-18 both the crude birth rates and the death rates in the project area are lower than the national rate. Likewise, the general fertility rate is lower for the project area, indicating a higher level of development than the country average.

Table 3-18 Crude birth, death and general fertility rates and natural population change

Name of Crude birth Crude death Natural Population General fertility rate in settlement rate in 2007 (‰) rate in 2007 (‰) Change in 2007(‰) 2007 (per 1000 women)

Turkey(1) 19.4 6.7 12.7 71,6 (3)

Denizli (2) 14.8 2.9 11.9 54.1

Honaz (2) 16.7 2.1 14.6 63.8 Project area (2) 16.3 2.6 13.7 61.6

(1) Data obtained from Eurostat (2008). (2) Data obtained from Denizli Provincial Health Directorate (3) Calculated manually by using data from Eurostat (2008).

22 Net migration rate is the difference between in-migration and out-migration for a specific area during the year. Since the migration data for 2007 is not presently available, net migration rates presented in this table are estimated on the basis of the difference between population change and natural increase in 2007. The statistics on net migration are therefore affected by all the statistical inaccuracies in the two components of this equation.

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3.15.4.2 Migration and Natural Population Change

According to the official data, the net migration rate (immigration minus emigration rate) for Turkey appears to be zero. However the Turkish Statistical Institute acknowledges that there has not been a system to register international migrations until very recently. Therefore the actual emigration and immigration rates will only be available after 2009 (TUIK, 2007).

Throughout Turkey, approximately 10% of the population migrates across places of residence within 5 years (TUIK, 2008:50). Most of this migration (57%) consists of movements from one urban area to another, or from cities to rural areas (20%). 17% of population movements involve a rural-to-urban shift and 5% are from one rural area to another (TUIK, 2008:50).

Denizli has long been receiving migration. The migration rate has particularly climbed up after the 1960s due to the blooming industries and the tourism sector. The net migration rate for Denizli is currently 19.4‰.

As shown in Figure 3-15, the project area (i.e. Kaklik, Yokusbasi, Asagidagdere and Alikurt) also has high rates of migration. The close proximity of the area to the marble quarries and Denizli Organized Industrial Zone make these settlements an attraction point for job-seekers.

According to the survey results, 33% of the population in the project area are in-migrants. The majority of migrants (76%) stated that they came to the area for employment purposes, whereas 16% stated they were returning migrants. Most of the migrants are either coming from other parts of Denizli or from close by cities in the Aegean Region.

The survey suggests half of the migrants had a relative who had previously settled in the area. In many cases, those former settlers had helped the newcomers to find jobs, houses and the get used to the area.

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Figure 3-15 Results of the migration related questions in the survey – summative for Kaklik, Yokusbasi, Asagidagdere and Alikurt

Migration route - Former place of residence (n=71)

South-eastern Foreign country Marmara Anatolia Aegean 1% 10% 10% 27% Eastern Anatolia 7%

Central Anatolia 3%

Denizli Mediterranean 29% 10%

Black Sea 3%

The reason for migration n=71

Other 3% I like here and/or to spend my retirement 6%

Returning migrants 15% Job placement 25%

To look for a job opportunity 51%

3.15.4.3 Age structure

Turkey has a relatively young population with the highest percentage (67%) of people being in the economically active group (between 15-65 years) and older population (65+ years) accounting for only 7%. This trend is also reflected in the project area, with 68% of settlement population falling between 15 and 65 years of age.

The population pyramids of Turkey and the project area appear to have shifted from expansive to a more constrictive type in the recent years, indicating that the ratio of younger population is decreasing. This is a result of declining fertility trends and increasing life expectancy which has reached 71.7

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by the year 2007 (TUIK, 2008:74). The median age for the project area and Denizli are higher that the national median age demonstrating a slightly older population.

Figure 3-16 Population Pyramids for Turkey, Denizli and the project area

Turkey (2007) Denizli Province (2007) Age Age group group 80+ 80+ Males Females Males Females 70-74 70-74 60-64 60-64 50-54 50-54 40-44 40-44 30-34 30-34 20-24 20-24 10-14 10-14

0-4 0-4

12 8 4 0 4 8 12 12 8 4 0 4 8 12 % in each age group % in each age group

Honaz District (2007) Kaklik, Yokusbasi, Asagidagdere and Age Age Alikurt (Survey results, 2008) group group 80+ 80+ Males Females Females 70-74 70-74 60-64 60-64 50-54 50-54 40-44 40-44

30-34 30-34 20-24 20-24 10-14 10-14

0-4 0-4

12 8 4 0 4 8 12 12 8 4 0 4 8 12 % in each age group % in each age group

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Table 3-19 Population distributions according to age groups (TUIK, 2007)

Name of N Percentage of Percentage of Percentage of Median age settlement children (<15 persons between older persons years) (%) 15 and 65 (%) (≥65 years) (%)

Turkey 70 586 256 26 67 7 28.3

Denizli 907 325 23 68 9 31.0

Honaz 28 941 25 68 7 29.4

Project area 777 23 68 9 33.0

3.15.4.4 Household size

At 3.58 persons, the average household size in the project area is lower than both the national average of 4.5 and of Denizli, which is 3.85. The range of household size in the project area is 1 to 9 people per household. The histogram of household sizes in the project area is provided in Error! Reference source not found. .

Figure 3-17 Histogram of household sizes in the project area

50 Mean: 3.58 40 Standard deviation: 1.429 30 Frequency N= 217 20

0 1 2 3 4 5 6 7+ Household size

3.15.4.5 Ethnicity, Language and Religion

Following the national trend, the project area is found to be very homogenous in terms of ethnicity and religion. No other religion was identified other than Muslim.

Turkish is the native language of all people in the project area. The household surveys put forward that 3.5% of the population could also speak Kurdish, and 0.5% also knew Laz language.

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3.15.4.6 Vulnerable Groups

By Turkish national standards, the overwhelming majority (84%) of people in the study area are poor 23 . The most vulnerable, i.e. people that are less able to cope with sudden changes or economic shocks, include the elderly (approximately 9% of the population is over 65), the disabled, and female- headed households.

3.15.4.7 Gender Issues

Women and Economic Activities

Men are unexceptionally the breadwinners of the household in the region. Women can and sometimes do participate to the household economy but the income-earning activities they participate remain limited predominantly to agriculture and textile labour.

Women’s primary function is often perceived as reproductive and domestic work. Although not easily valuable, when the unpaid care work is considered, women’s contribution to the household economy appears to be significant. The unpaid care work undertaken by women primarily consists of housework, cooking, caring for children, the elderly, the sick or disabled.

Access to land resources and property ownership

In the project area, the males and females are generally treated equal regarding property ownership. Male and female siblings mostly get equal shares from inheritance and women can decide on how to use their property.

In few families, on the other hand, the house is handed down to the males, as females are expected to get married and move to their husband’s house. In these situations, female siblings are sometimes compensated with a share of equal value to the house.

According to the surveys, amongst the families who were dealing with agriculture 90% (N=75) stated the males and females were getting equal

23 The Turkish national standards define “poverty” with regards to the size and monthly income of a household. For one member 265 YTL/month; for two members 401 YTL/month; for three members 507 YTL/month; for four members 598 YTL/month; for five members 682 YTL/month; for six members 759 YTL/month, for seven members 834 YTL/month; for eight members 905 YTL/month, and for nine members 962 YTL/month are threshold values determined for poverty (TUIK, 2008).

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shares from the inherited lands, whereas 10% reported females were either taking less or not getting at all.

Decision Making and Power

Women have a say in decisions at household level, especially in relation to children’s welfare, education and marriage, and resource allocation in the household. Amongst the families who are dealing with agriculture 96% reported women can freely decide how to use their own lands and can also contribute to the decisions on how to use the family lands.

At community level, on the other hand, women hardly, if ever, raise their voice. The community level decisions are left to men and community politics are purely a male domain.

Female-Headed Households

Women headed households (a total of 20) comprised approximately 9% of the households surveyed in the project area. Most of the women heads are over 45 years old and the main reason for becoming the head appears to be the death of the husband. It was understood that many women who were widowed due to death or divorce preferred to move to their parents’ or children’s houses.

Key Problems Facing Women

Lack of employment opportunities appeared to be the main concern of women in the area. Many women complained working as agricultural labour was their only option which was seasonal and small-scale. Women in the villages also cited lack of transportation networks as an obstacle to employment opportunities. Other problems stated by women included high illiteracy rates, financial dependency on males, and lack of social activities and occupational trainings for women.

3.15.4.8 Education

The overall educational attainment levels are quite low in Turkey. The average duration of education is 6.8 years for males and 5.3 years for females (ETF, 2006). Early school leaving and inequalities in access to education by gender, rural/urban and social background remain to be national problems (ETF, 2006).

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Table 3-20 Youth and Adult literacy rates

Adult literacy rate (+15 Youth literacy rate years) (%) (15-24 years old) (%)

Total Males Females Total Males Females

Turkey (1) (for 2006) 88 95 80 96 98 94 Project area 88 96 81 99 99 99 (1) Adult literacy rates obtained from EFT, 2006. Youth literacy rates obtained from the official UN site for MDG indicators http://mdgs.un.org/unsd/mdg/SeriesDetail.aspx?srid=656&crid=792

In the project area, amongst the people 15 years old an over, 48.6 % of the males and 48.7 % of the female population have only completed primary school (Table 3-21). The adult illiteracy rate is 3.8% for males and 19% for females.

The higher literacy rates (15-24 years old) for younger people suggest the situation is improving at the project area; which is also reflected in the current 100% schooling rate. Still, approximately 13% of the young people between 15- 24 years old (8%of males and 18% of females) appear to have left schooling recently, after the compulsory primary education. It was understood that the persons who left –or were taken off from- schooling were expected to work to support the family.

The higher drop out rate for female students puts forward the ongoing gender gap in access to educational facilities. Although most families are aware of the importance of education for both genders, it is mostly the females who are taken off from schooling when there are financial strains or family reasons (need to care after sick etc.). The unwillingness to send the female children away also contributes to the lower tertiary education attendance rates for women.

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Table 3-21 Cross tabulation of education level and sex for persons 15 years and older in the project area

Name of settlement N Males (N=310) Females (N=292) Total (N=602) (%) (%) (%)

Illiterate 70 3,8% 19,0% 11,6% Only literate 15 2,4% 2,6% 2,5% Primary school graduate 293 48,6% 48,7% 48,7% Junior high school graduate (1) 60 15,8% 4,5% 10,0% High school student 42 5,8% 8,1% 6,9% High school graduate 88 16,1% 13,2% 14,6% Vocational school student 4 1,0% ,3% ,7% Vocational school graduate 12 2,4% 1,6% 2,0% University student 9 2,1% 1,0% 1,5% University graduate 9 2,1% 1,0% 1,5% Total 602 100,0% 100,0% 100,0% (1) In 1997, Junior high school education was combined with primary schools and the compulsory education (which was previously 5 years) was extended to 8 years. All %-values are rounded to first digit.

Table 3-22 Cross tabulation of education level and sex for youth (15-24 years old) in the project area

Name of settlement N Males (N=66) Females(N=71) Total (N=137) (%) (%) (%)

Illiterate 2 1,5% 1,4% 1,5% Only literate 1 1,5% 0% 0,7% Primary school graduate 18 7,6% 18,3% 13,1% Junior high school graduate (1) 20 24,2% 5,6% 14,6% High school student 37 24,2% 29,6% 27,0% High school graduate 37 19,7% 33,8% 27,0% Vocational school student 4 4,5% 1,4% 2,9% Vocational school graduate 4 3,0% 2,8% 2,9% University student 9 9,1% 4,2% 6,6% University graduate 5 4,5% 2,8% 3,6% Total 137 100,0% 100,0% 100,0% (1) In 1997, Junior high school education was combined with primary schools and the compulsory education (which was previously 5 years) was extended to 8 years.

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3.15.4.9 Health Status

The public health situation in Turkey has some weaknesses including infant and adult mortality rates, malnutrition, high prevalence of communicable diseases, unequal distribution and access to healthcare services and poor information systems (Reig and Valverde, 2006:3).

Yet, the health services -thus the health situation- differs greatly in the east and west part of the country. Denizli, when compared to other regions, benefits from higher densities of health professionals, better access to preventive health care and lower rates of infectious diseases.

In general the health conditions in the project area were observed to be good. The better health status of Denizli and the project area are well reflected in the comparison of infant, child and adult (65+) mortality rates with national averages (Table 3-23).

Table 3-23 Infant, child and adult mortality rates

Infant mortality rate Under five mortality Adult (65+) mortality (2006) (0-12 months) (‰) rate (2006) (‰) rate (2006) (‰)

Turkey (1) 22.6 25.1 123.0

Denizli (2) 10.5 2.6 28.0 Honaz (2) 19.4 3.4 30.3 Kaklik (2) 8.8 1.7 24.2

(1) Infant and under five mortality rates obtained from TUIK (2007), adult mortality rate obtained from World Health Organization (2008). (2) Data obtained from Denizli Provincial Health Directorate (2006).

Communicable Diseases

Turkey has a number of infectious diseases as shown in Table 3-24 and Table 3-25. Yet, few diseases prevail in Denizli. Amongst the diseases observed in the project area, Tuberculosis has a higher rate of incidence than the national average ( Error! Reference source not found. ). In 2007, 5 Tuberculosis cases were resulted in death in Denizli.

As the water is frequently checked by the Provincial Directorate of Health, water-borne diseases are not a problem in the project area. The only food- related disease was identified to be Brucellosis 24 (Table 3-25), which is mostly

24 Brucellosis is an infectious disease due to the bacteria Brucella that causes rising and falling (undulant) fevers, sweats, malaise, weakness, anorexia, headache, muscle and back pain.

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transmitted through contaminated or untreated milk (and its derivatives) or through direct contact with infected animals (sheep, goats, dogs etc).

The current data suggests sexually transmitted diseases (STDs) and HIV/AIDS maintains low in Turkey and is not a relevant health problem in Denizli. No STD cases were reported for the project area (Table 3-26).

Table 3-24 Prevailing infectious diseases

Turkey (2006) Denizli (2007) Kaklik (2007) Number of Incidence Number of Incidence Number of Incidence cases rate per cases rate per cases rate per 100 000 100 000 100 000

Whooping cough 57 0 0 0 0 0

Measles 34 0 1 0 0 0

Tetanus (1) 10 0 0 0 0 0

Mumps (5) 0 1 0 1 16

Hepatitis C 800000 (2) 1148 7 1 1 (6) 16

Scarlet fever 1979 3 0 0 0 0

Meningitis 183 0 0 0 0 0

Rabies 1 0 0 0 0 0

Malaria 796 1 2 0 0 0

Tuberculosis 18544 27 178 20 2 32

(1) Does not include neonatal Tetanus (2) No official national data is available for Hepatitis C cases. NGO estimations range between 600 000 and 1 million. Here the average of estimations is used. (3) Cases observed in 2003, data obtained from TUIK (2008). (4) Cases observed in 2001, data obtained from MOH statistics. (5) Data not available. (6) This case was reported during the surveys.

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Table 3-25 Diseases transmitted through food and water

Turkey (2006) Denizli (2007) Kaklik (2007) Number Incidence Number of Incidence Number of Incidence of cases rate per cases rate per cases rate per 100 000 100 000 100 000

Acute diarrhoea (1) - - 13 1 0 0

Typhoid fever 1518 2 0 0 0 0

A Dysentery 15527 22 0 0 0 0

B Dysentery 331 0 0 0 0 0

Hepatitis A 7137 10 81 9 0 0

Brucellosis 10644 15 65 7 4 64

(1) Nation wide data is not available.

Figure 3-18 Prevailing diseases in the project area

Kaklik 80+80 Denizli 60 Turkey 40 Turkey

20 Denizli Rate of Rate of 0 incidence (‰) incidence Kaklik Mumps Brucellosis Tuberculosis HepatitisC

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Table 3-26 Sexually transmitted diseases

Turkey (2006) Denizli (2007) Kaklik (2007) Number of Incidence Number of Incidence Number of Incidence cases rate per cases rate per cases rate per 100 000 100 000 100 000

AIDS 2544 4 14 2 0 0

Syphilis 4179 6 5 1 0 0

Gonorrhoea (1) - - 0 0 0 0

Hepatitis B 6612 9 15 2 0 0

(1) Nation wide data is not available.

Cancer

According to the statistics of MoH, the cancer rates are higher in the western parts of the country. The cancer rate is currently 77 per hundred thousand people in Denizli (Provincial Health Directorate, 2007) 25 . The most frequently observed cancer cases are lung, uro-genital, breast and stomach cancers. Cancer rates are not available at the local level.

Other Health Issues

Other frequently reported health problems in the project area include asthma, diabetes, Chronic Obstructive Pulmonary Disease, hearth diseases, herniated disk, rheumatism and hypertension. Smoking was observed to be widespread amongst adults, and rare cases of alcoholism were reported during the women’s focus group meetings. Although Crimean-Congo haemorrhagic fever (CCHF), transmitted through ticks, has been a major health issue in Turkey in the recent years, no cases were reported in Denizli.

3.15.5 Land Tenure

The cadastral works for the land is completed and therefore all the lands are registered in the project area. The majority of the farmers hold title deeds for their lands and informal agreements are not common in the area. Buying/selling, renting of agricultural lands are generally made through the formal means of Land Register Office. Very poor farmers rarely prefer informal contracts to avoid the land register fees.

25 According to the available data, the country average was 71 per hundred thousand in 2003 (MOH, 2004).

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The males and females are usually treated equal regarding property and land ownership. %90 percent of the households dealing with agriculture stated that male and female siblings got equal shares from inheritance and women can decide on how to use their property, whereas 10% of the families stated that women get less or no share from land.

3.15.6 Livelihoods and Employment

3.15.6.1 Income source and levels

Primary income sources

According to the surveys, salaried jobs, pensions and agricultural activities comprise the main income sources in the project area. 69% of the households have at least one member who has a salaried position, 33% have at least one member who has a pension and 26% of households deal with agriculture (Error! Reference source not found. ).

The annual incomes earned from waged positions vary greatly between 720- 33600YTL/year, with an average of approximately 10.000YTL/year. The lower wages mostly represent the irregular or seasonal agricultural works, which last only a few months every year. The pensions provide an income of approximately 7000YTL/year and agricultural activities provide around 6500 YTL/year (Table 3-27).

Figure 3-19 Income sources of households in the project area N=217

Other 4% Trading 3% Support of family/relatives 4% 100% Livestock Breeding 5% Poverty funds 4% Rental income 7% 90% Agriculture 26% 80%

70% Pension 33%

60% Wage/Salaries 50% 69%

40%

30%

20%

10%

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Table 3-27 Average earnings from the main income sources observed in the project area

Income source N Percentage of Range (YTL/year) Mean Standard households with Income deviation the income (YTL/year) (YTL/year) source (%) (app.) (app.) Min. Max.

Wage/Salaries 149 66 720 33600 10000 5800 Pension 72 32 2400 27600 7000 3750 Agriculture 57 25 100 30000 6500 6400 Livestock Breeding 10 4 240 5000 2500 1400 Trading 6 3 600 12000 5000 5350 Rental income 16 7 500 12000 3500 3200 Support of 500 6000 2000 2100 family/relatives 8 4 Other 9 4 1000 3600 2500 1800

The average cash household earning is approximately 11500 YTL/year in the project area: 42% of the households earning less than 10000YTL/year and 40% earning between 10000 and 20000YTL/year ( Error! Reference source not found. ).

Figure 3-20 Histogram of annual cash household earnings in the project area

20 Mean =11 500 15 Std. Dev. = 7100 N = 215 10 Missing=2

Frequency(%) 5

0 0 10000 20000 30000 40000 50000 60000 Annual cash earnings (YTL/year)

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Subsistence farming

Approximately 32% of the families are engaged in subsistence farming and the average economic value of the produced fruit and vegetables is 720 YTL/year. A wide range of vegetables, fruit and grain (including tomato, eggplant, bean, cucumber, pepper, onion, wheat, barley, corn, grape and quince) is produced for household consumption. The crops are harvested in the summer months and processed and/or frozen to consume in winter time.

Except for a few households, husbandry and poultry are done for subsistence in the area. According to the survey, only 8% of the households have poultry. One of the main reasons for this low rate of poultry farming is reported to be 26 the outbreak of avian influenza pandemic in Turkey in 2005 .

5% of the households have sheep and another 5% have cows in the area. Reportedly, the amount of milk, milk derivatives and eggs for subsistence are worth an average of 560 YTL/year and the economic value of the meat produced is 540 YTL/year.

Figure 3-21 Histogram of annual value of subsistence farming in the project area

50 Mean=1400 40 Std.Dev.=1700 30 N=76 Missing=0 20

Frequency(%) 10 0 0 2000 4000 6000 Approximate annual value of subsistence farming (net) YTL/year

3.15.6.2 Expenditures, Savings and Debts

An average household spends around %30 of its income on food and beverages and 13% on heating, electricity, telephone and water services in the

26 In 2007, the Ministry of Agriculture and Rural Affairs declared the pandemic risk was over in Turkey.

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region. Education expenditures cost around 16% and health expenditures cost 3% of an average income. The mean annual costs of the common expenditures are provided in Table 3-28.

Table 3-28 Mean annual costs of commonly observed expenditures

N Expenditure (YTL/year)

Food and beverage 217 3300 Heating, electricity, water and telephone 217 1460 Health 217 400 Education 101 1800 Rent 21 2200 Cigarette 12 2250 Garden care 24 2300

The survey put forward that approximately 52% of the households had a debt, while only 4% were able to save. Although the mean debt amount was found to be 7900 YTL, a majority of the households (64%) had a debt less than 5000 YTL.

The mainstream of the debts were bank loans, whereas smaller amounts tended to be owed to relatives and friends. The survey suggested that it was mostly the waged labour that were indebted and the higher the income, the higher was the debt 27 . No relation was identified between debt amounts and other income sources, which implied waged labour might have better access to bank credits.

27 Pearson’s correlation for amount of debt and amount of income from waged labour was found to be 0.371.

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Figure 3-22 Histogram for the amount of debts in the project area

40 35 30 Mean=7900 Std.Dev.=10500 25 N=109 20 Missing=5 15

Frequency (%) 10 5 0 0 10000 20000 30000 40000 50000 Amount of debt (YTL)

3.15.6.3 Livelihoods

In the project area, traditionally it is the male members who work for the family. Although the number of women getting involved in economic activities has been increasing in the recent years, female participation in the workforce remains very low at 19%. Women are primarily engaged in family duties such as caring after youngsters and elderly and doing the regular house works.

The employment rates are quite low in the area, with 68% for males and only 12% for females. The majority of people are employed as workers in the nearby industries. Farming comes as the second most common occupation for both males and females. These two main livelihood sources are explained in the following sections.

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Figure 3-23 Percentage of economically active and inactive populations

Males (15-65 years old), N=265 Females (15-65 years old), N=273

Disabled/ Unemployed Retired 14% ill 2% Employed 5% 12% Student Unemployed 11% 7%

Disabled/ Retired ill 2% 2% Engaged in Employed Student family 68% 11% duties 63%

Economically inactive population 27% Economically inactive population 81% Economically active population 73% Economically active population 19%

The occupation groups other than industrial labour and farming appear to have very small shares in the employment profile of the area. Unlike many rural areas, livestock breeding and poultry farming are not common, and most of the existing ones are at subsistence level. Contrasting many poorer rural areas where people are engaged in diverse livelihood activities, few people have a second job -which is mostly farming- in the project area.

Figure 3-24 Major occupation groups for males and industries of employment

Major occupation groups for males (N=193)

Office works 1% Other 10% Industries of employement (N=95)

Driver 8% Marble & stone Public Waged ind. 18% officer 2% labour Shop 45% Cement industry 11% keeper 6% Construction ind. 5% Craftsman 3% Livestock Leather & textile ind. 4% Breeder 1% Public sector 3% Other 3% Food industry 2% Farmer 19%

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Figure 3-25 Major occupation groups for females and industries of employment

Major occupation groups for females (N=34)

Teacher 2% Other 3% Public officer 3% Industries of employement (N=15)

Shop keeper 12% Textile & leather ind. Waged 30% labour 44% Marble & stone ind. 6%

Agriculture 9% Farmer 34% Food industry 3%

Table 3-29 Major occupations in the project area

Total number Percentage of Percentage Percentage of of people total working of working working females working people (%) males (%) (%)

Waged Labour - total 111 50 50 46 Marble and stone Industry 41 18 21 6 Cement industry 21 9 11 0 Leather and textile 19 8 5 29 Construction 11 5 6 0 Public sector 6 3 3 0 Food 5 2 2 3 Agriculture 4 2 1 9 Other 4 2 3 0 Farmer 48 21 19 34 Driver 16 7 8 0 Shop keeper 15 7 6 11 Craftsman 5 2 3 0 Public officer 4 2 2 3 Teacher 2 1 1 3 Livestock breeder 2 1 1 0 Office worker 2 1 1 0 Other 19 8 10 3 Total 224 100 100 100

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Waged labour

Waged labour is the most important income source in the area. As shown in Table 3-29, half of the working population is waged labour. The males predominantly work for the marble and stone quarries or at the cement factory close to Kaklik, while the females work in textile and leather factories (Table 3-29 and Figure 3-25). Most people working in the industries earn the minimum wage (gross 639 YTL, net 458 YTL per month for the period 01.07.2008 - 31.12.2008).

The marble sector has been adversely affected from the low dollar rates and the mortgage crises in the USA. Currently many factories are working at a lower capacity (sometimes as low as 30%) and the industry is in general on the downgrade.

Having been affected by the low prices of China, the textile industry is getting worse as well. Many factories are working less than half capacity, preferring night shifts to minimize electricity costs (as the electricity rates are lower at night hours).

Figure 3-26 Sectors and types of industries where the waged labour work (N=111)

25 20 15

Frequency (%) 10 5 Medium/large enterprise (50+ emp.) 0 Micro/small ent. (0-49 employees) Own or small family business Other Agriculture Construction Cement Cement industry Marble/stone ind. Marble/stone

Leather and textile

Construction, public sector, food and agriculture are reported to be the other sectors, where people can find permanent as well as daily and monthly works. The businesses in these sectors are more likely to be small and/or family type

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businesses whereas the marble, cement and textiles sectors are dominated by medium and large enterprises (Figure 3-26).

The project team has not encountered any child labour, less than 15 years old. Yet, it is reported that many employees were working uncovered, particularly in the textile sector.

Farming

With 17% of the labour force being farmers, agriculture comes as the second most important income source in the project area. According to the survey results, 41% of the agricultural activities are at a micro (less than 2 hectares) and 36% are at a small scale (between 2 and 5 hectares). Medium level enterprises (5 to 20 hectares) comprise only 23% of the farms.

Table 3-30 Agricultural lands and major products in the project area

Settlement Total dry Total Major agricultural products land irrigated (1000m2) land (1000m2)

Alikurt 8000 0 Wheat, barley, cumin, walnut

Asagidagdere 1.340 5.500 Wheat, barley, corn, grape, quince, opium, peach

Yokusbasi 1.900 2.000 Wheat, barley, grape, opium, cumin

Kaklik 2.900 15.000 Wheat, barley, grape, cumin, cotton, quince, peach, sunflower

The sizes of irrigated and dry lands at each settlement are outlined in Table 3-30. Currently there is no irrigation in Alikurt. Although the irrigation wells are drilled, the irrigation pipes have not been placed yet, due to lack of sufficient community budget.

The average farm size is 3.2 hectares in the area. Wheat, barley, grape, cumin, cotton, quince, peach, sunflower, opium and cumin are the principal crops in the region. Grape and quince are exported to overseas markets, whereas others are produced for domestic consumption and/or subsistence.

85% of the farmers possess their own lands whereas 13% rent (all or a part of their lands) or get into share cropping agreements. A very small percentage (2%) of farmers uses their relative’s lands without giving rent.

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The majority of the crops are sold to traders and cold storage houses to be sent to domestic and international markets. The villagers themselves sell a very small portion of the products in the local markets.

Almost all farmers reported that the agricultural production had been waning in the recent years. In Kaklik the farmers alleged they had to increase the amount of fertilizers every year as the high hardness level of their irrigation water was causing salinization in the soil. Thereby the production was directly affected from the increases in input prices.

Droughts were found to be another reason for the agricultural decline in the recent years. Low product prices, dust emissions caused by the quarries and the cement factory, lack of sufficient labour force, irrigation facilities and agricultural mechanization are other reasons frequently cited by farmers (Figure 3-27).

Figure 3-27 Causes of agricultural decline – as perceived by farmers

Particulate matter casued by quarries and cement Shrinkage of the cotton Low product factory 4% market 2% prices 14% Lack of irrigation Drought 37% facilities 3%

Lack of labour force 3%

Other 1% Increases in the input prices (Diesel oil, Lack of mechanization 5% fertilizers, pesticides etc.) 31%

3.15.6.4 Standard of Living

28 Households were asked about the change in their standard of living over the last five years. 22% of the households reported that it had improved, 24% stated it remained the same and 54% said it had declined.

The most common reason cited for the decline of living standards was the relative decrease of income levels and purchasing power due to the high inflation rates. Unemployment and decreases in agricultural income (due to

28 Standard of living refers to overall welfare, including income, health, access to services, etc.

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the increases in input prices) and nutrition problems due to poverty were also counted reasons (Figure 3-28).

Most common reason cited for the increase of living standards was getting a regular or better paid job. The general development of the area (mainly in terms of public services) and technological advancements appear to have also contributed to increase the quality of living.

Figure 3-28 Reasons cited for increase and decrease in the standard of living

Reasons for increase in the standard of living (N=47)

Getting a regular/formal or a Moving to their own better paid job house 61% 9% Increase in the number Decrease in the of working household Other household Development of the members 2% expenditures (e.g. area and technological 7% Children moving out) advancements 5% 16%

Reasons for decrease in the standard of living (N=117)

The relative decrease of the income level Nutrition problems and purchasing power due to poverty with inflation 3% 75% Increase in household Other expenditures 3% Unemployment 4% Decline of agricultural 6% income 9%

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3.15.7 Infrastrucure

3.15.7.1 Transport Infrastructure

All the settlements in the project area have asphalt roads connecting them to Denizli and other districts. Most of the inner roads of settlements have interlocking pavers, whereas some roads in Yokusbasi, Kaklik and Asagidagdere remain unimproved.

Kaklik town is located at the junction of Denizli–Ankara-Afyon-Usak intercity highways. There is an efficient means of transportation to Denizli with buses leaving at every half an hour (between 6:30-11:00), at a price for 3YTL (one way trip). The private services of nearby industries also serve to Kaklik.

Other than Kaklik, none of the settlements have their own public transportation. Residents of Alikurt and Yokusbasi mainly use the public buses passing through their villages. As there are no buses passing close to Asagidagdere, Kaklik-Denizli buses climb up to this village twice every morning and evening. In Yokusbasi and Asagidagdere, where industry services do not serve, lack of transportation facilities were reported as a major obstacle to women’s employment.

3.15.7.2 Water Supply

Groundwater is the main source of water in all the settlements. While Asagidagdere, Alikurt and Yokusbasi have their wells inside their borders, Kaklik’s water is piped from the neighbouring Sapaca village (approximately 6 km southeast of Kaklik). There is currently an ongoing court case with Sapaca village on the usage rights of this well.

Water is pumped with electric motors and chlorinated automatically. The Provincial Directorate of Health periodically monitors the water quality at all the settlements. No water-borne diseases were detected in the area during the last 5 years.

Despite random cuts, water is available throughout the year. As the water table is already very low, approximately at 150 m depth, one of the main worries is a possible risk of further drop of the water table. High level of hardness is another problem reported by the residents.

The majority of people (98%) have water taps in their houses, whereas a very small proportion (2%) have taps outside their houses. 90% of the residents use the tap water for also drinking purposes while the rest buy bottled water or have installed water filters.

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3.15.7.3 Wastewater Systems

The study found out that all the residents had access to improved sanitation 29 in the project area. According to the survey, 80% of the households had indoor toilets/latrines (amongst which 64% are flush and 16% are pour-flush 30 ) and 20% had outdoor latrines (2% flush and 18% pour-flush).

There are presently ongoing works to establish sewage systems in all the settlements. The surveys suggest that 80% of the houses are presently connected to the sewage system while 20% use septic tanks.

There is a natural wastewater treatment plant (reed bed) in Alikurt; nevertheless it is no longer working due to lack of maintenance. In Yokusbasi, the wastewaters are collected in a septic tank before discharge. There are no treatment systems in Kaklik and Asagidagdere. All the wastewaters are discharged into dry and semi-dry river beds close to the settlements.

3.15.7.4 Housing and Accommodation

A vast majority (77%) of the residents own the houses they accommodate, while 13% are renters and 10% live in a house that belongs to a close family member without paying rent.

Most of the houses are detached with small gardens, but there are also apartments in Kaklik and Yokusbasi. The main construction materials are brick and concrete, whereas it is possible to observe older houses made of stone or mud-bricks as well as recently built prefabricated houses.

Houses are generally composed of a living room, a kitchen, a bathroom, a toilet and bedrooms. According to the survey, houses have usually 2 to 4 bedrooms and average bedroom number per household member is 1.0 room/capita. 80% of the houses have an indoor toilet, whereas others have a pit latrine outside.

3.15.7.5 Electricity and Energy

All the houses in the project area have electricity. Electricity cuts (1 to 3 times per month, lasting for 10-150 minutes) and repeated changes in voltage are commonly reported problems. Some people also complain about the high prices of electricity.

29According to UNICEF and WHO (2008) improved sanitation facilities are those ensuring hygienic separation of human excreta from human contact. 30 Pour flush (in contrary to flush) means that water is poured manually by a bucket.

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Coal and wood are the main sources of heating fuel. People usually buy around 1.5-2 tons of coal and a few cubic meters of wood (mainly for ignition) per year. The heating stoves are also used for cooking during winter and LPG gas is used for cooking during summer.

Yokusbasi is considered as a Forest Village, which provides the right to collect 5 cubic meter woods (at a very low price) to its residents. The other settlements need to pay -albeit not much- more for fuel wood. It is reported that, although at very low rates, some illegal cutting might exist in the area.

3.15.7.6 Telecommunications

Telecommunication facilities are good in the project area. Most houses have televisions, radios and line telephones. Internet is available in Kaklik and usage of computers is increasing amongst the youth. It is also very common (mostly amongst males) to have mobile phones.

3.15.7.7 Waste Management

The domestic wastes of Alikurt and Kaklik are collected by the Kaklik municipality and dumped into the designated garbage disposal site for Kaklik. In Kaklik, a few houses share the same collection bin. As the wastes accumulate for a few days before collection, there are some complaints regarding odour and anaesthetic views.

Other villages do not practise any waste management and dump their wastes irregularly. This is likely to create unsanitary environmental and health conditions and a general unsightliness to the local area.

3.15.7.8 Education Infrastructure

There are two primary schools, a nursery and a high school in Kaklik. The students of Yokusbasi, Alikurt and Asagidagdere villages are transported to the schools in Kaklik with government sponsorship. According to the surveys 79% of the parents are satisfied with the education facilities in the project area, whereas 21% complain about crowded classes and frequent change of teachers.

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Table 3-31 Schools and student numbers in Kaklik (Source: Honaz District Management of Education Services)

Name of school Number of Males (%) Females (%) students

Kaklik Primary school and Nursery 692 48% 52%

Sehit Eyup Altun Primary School 234 41% 59%

Osman Evren High School 190 47% 53%

The names and current enrolment numbers of the schools in Kaklik are presented in Table 3-31. While Sehit Eyup Altun Primary School and Osman Evren High School provides full-day classes, Kaklik Primary School offers half-day education in shifts (i.e. morning classes and afternoon classes) due to insufficient number of classrooms.

As many students prefer the high schools in Denizli and also due to the drop outs, the demand on high school is not as much in the area. Thereby, despite its low capacity, Osman Evren High School was reported to be sufficient to meet the demand in the area.

According to the statements of officers of Honaz District Directorate of Education, all three schools have further capacities to take 100 more students. Reportedly, there is also a consideration to construct an additional building to Kaklik Primary School, albeit there area no plans and no budget allocations yet.

3.15.7.9 Healthcare Facilities

Denizli Provincial Health Directorate is the main authority responsible for service planning and provision at provincial level. Primary health care is provided through health centres, health posts, Maternal and Child Health (MCH) and Family Planning (FP) centres and tuberculosis dispensaries.

The public health facilities in the close vicinity of the project area are presented in Table 3-32. A doctor is always present at Kaklik Health Post during the weekdays (from 09:00-17:00), whereas the health posts at the villages are visited by a doctor regularly once/twice every week. It is mainly the outpatient treatments that can be done at health posts and for severer illnesses people go to the hospitals in Denizli or Honaz.

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Table 3-32 Public health facilities in the project area

State and Public and Health Dental Health Tuber- -112- Branch Family Post Health Center for culosis Emergency hospitals Health Center Mothers and dispen- Health Center Children sary Station

Denizli 2 44 142 1 1 1 6

Honaz 1 4 8 - - - 1

Kaklik - 1 - - - - -

Yokusbas - 1 - - - - - i Asagidag- - 1 - - - - - dere

Alikurt - 1 - - - - -

According to the survey, 75% of the locals are satisfied with the health facilities in the area. The main of concern of the others is lack of a doctor in attendance at all times in Kaklik and in the villages.

3.15.7.10 Other Communal and Recreation Facilities

There is a football field in Kaklik. The other villages do not have any recreational facilities. Males mainly meet at the coffee houses to play games such as backgammon, cards in their spare times. Lack of recreational facilities (particularly for women, youth and children) was frequently reported as a concern in the area.

3.15.8 Key Development Issues in the Area

A number of key development issues were identified in the project area. During the surveys the respondents were asked to list what areas they would like to see developed in their respective communities and rank them according to their importance. The key development issues reported by the people are outlined below.

Need for investments and employment opportunities: The majority of the respondents asked for investments and employment opportunities in the area. Currently, the two major industries, namely textile and marble, are at a decline and thereby many people are worried about how the employment

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situation will be in the long run. With a view to participate the labour force, many women also demanded occupational trainings.

Construction of roads: The construction of inner roads of the settlements is another concern in the project area. The inner roads of settlements, except for Alikurt where all the roads are built with either asphalt or interlocking pavers, are only partially paved. Dust emissions from the roads are a problem at the streets where the roads remain unimproved.

Transportation facilities: Establishment of better transportation facilities to Denizli and industrial workplaces is required by villagers to have access to more employment opportunities.

Recreational facilities: Many people, especially in Kaklik, believe recreational facilities are a great requirement in the area. While men make use of coffee houses to meet friends, there are no places for women, youth and children. Many people complain about the lack of facilities where they can go altogether with their family. Suggestions for recreational facilities include a park and community center where people at all ages can socialize (i.e. playgrounds for children, library, cinema facilities, restaurants etc).

Education: As mentioned above, the primary schools in Kaklik do not meet the demand entirely. Therefore construction of a new school is considered as an important issue. Some women also indicated that pre-school facilities were needed in the villages as they were not able to send their young children to Kaklik.

Waste management: Another commonly raised issue was solid waste management. Especially in Yokusbasi and Asagidagdere, waste management is a major concern as indiscriminate dumping wastes cause unsightliness as well as creating unsanitary conditions. The locals also indicated that the waste disposal site of Kaklik also needs to be improved for sanitation purposes.

Irrigation facilities: Lack of sufficient and better quality water resources and infrastructure for irrigation is an imperative issue for farmers in the area.

Other mentioned development issues include provision of better quality water for domestic uses, improving the health services in Kaklik, improving the security measures against theft in Kaklik, better application of the zoning plan (e.g. not allowing any illegal constructions, completion of the roads) and landscaping in Kaklik, completion of the sewage system in all the settlements, constructing a pedestrian subway at Yokusbasi and provision of micro credits to farmers and poor people in the area.

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Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

4 – Alternatives

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CONTENTS of Section 4

4 ALTERNATIVES 4-1

4.1 THE ”NO ACTION” OPTION 4-1 4.2 ALTERNATIVE SITES 4-1 4.3 POWER GENERATION TECHNOLOGY AND FUEL ALTERNATIVES 4-3 4.3.1 Fuel Alternatives 4-3 4.3.2 Alternative Power Generation Techniques 4-4 4.3.3 Process Technology 4-5

LIST OF TABLES

Table 4-1 Overview on alternative sites 4-2 Table 4-2 General Comparison of Cooling Systems Alternatives 4-6

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4 ALTERNATIVES

This section provides a summary of the alternatives considered already by E.ON & Turcas and reviewed by RWE & Turcas for the development of the Project for various aspects including their environmental relevance.

4.1 THE ”NO ACTION” OPTION

The need for the project has been described in Section 2.1. The “no action” alternative, i.e. not to pursue with the implementation of the Project, would result in an increasing electricity supply deficit as demand increases in future years. A lack of a secure and reliable electricity generation and supply system raises significant social, economic and environmental implications, since it will:

 Constrain existing and future economic development and investment through lack of energy resources to meet industrial demand; and  Restrict socio-economic development through lack of electricity supply, or poor reliability and shortages in electricity supply for domestic users, community and other public facilities and public services.

As a result, the”no action” option is not a viable or acceptable alternative to the proposed Denizli Combined Cycle Power Plant.

4.2 ALTERNATIVE SITES

As described above Turkey has a severe need of additional power supply. The Denizli region is experiencing ongoing growth and industrial development in recent years and development is hindered by risks of an unreliable power supply to consumers. However, in this environment of industrial development, there is only very limited choice in lands which are both suitable and available for development of a new large facility such as a power plant. The availability of land is a major determinant for the selection of a site. Considering the above, the envisaged site was earmarked by the project proponent. Alternative sites were also considered as described in Table 4-1.

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Table 4-1 Overview on alternative sites

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Location Denizli Province Samsun Adana Province İzmir Province Province

Strategical Economically Little demand Little demand in Economically considerations fast growing Gölovası’s fast growing (---) area surrounding area area (+++) (+++) (---)

Infrastructure Close to Significant Grid connection Close to intersection of reinforcement of will be very intersection of 380 kV grid 380 kV grid expensive 380 kV grid required (+++) (---) (+++) (---)

Gas pipeline Adjacent to site Located near Close to gas Close to gas “Blue Stream” pipeline pipeline (+++) pipeline (+++) (+++) (+++)

Seismicity First degree Third degree First degree First degree earthquake area earthquake area earthquake area earthquake area

(---) (++) (---) (---)

Number of All lands have Owner of the site Land purchase & Land owner parcels been purchased builds a CCPP at land usage EGEGAZ shows amicably. the same estate negotiations by no interest Turcas because (+++) (---) (---) of refinery project which includes PP-area

(+++)

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

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Since the Kaklik site is agriculturally used it was also investigated whether there is an available site in an industrial zone in Denizli region. One planned organized industrial zone (OSB) adjacent to the site and further OSBs in Bozkurt, Denizler, Acıpayam (Yumrutaş) and Tavas were checked but did not show any available or suitable site for the power plant.

Thus, Kaklik was selected as the site which is best suitable for the development of the CCPP.

4.3 POWER GENERATION TECHNOLOGY AND FUEL ALTERNATIVES

4.3.1 Fuel Alternatives

The CCPP will be fuelled solely by natural gas. Alternative fuels for power generation are fossil (coal, oil) or based on biomass.

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

 No on site storage requirements for natural gas, whereas big storage tanks are required for oil and large stockpiles for coal. Oil storage tanks pose a risk for soil contamination in case of a spill. Coal stockpiling is a source of coal dust emissions caused by wind erosion in case of inappropriate storage facilities and operation.  Transportation of natural gas and oil is by pipeline which causes no traffic. Transportation of oil by tank truck is no adequate option since operation of a power plant requires large quantities of oil. Coal is transported by various types of vehicles depending on the delivery route and the available infrastructure, meaning by rail or ship.  Combustion of natural gas generates less emission to the atmosphere than burning of oil and coal. While natural gas burning generates significant emissions only of CO and NOx, the emissions from oil additionally

comprise SO2 and soot. Emissions from coal in addition to this comprise particulate matter and heavy metals which requires additional technical air purification measures to minimize air pollution  The specific emissions of pollutants (quantity of pollutant per unit energy generated – i.e. kg/kWh) are less for natural gas fuelled power plants.  The emissions of greenhouse gases (in terms of specific emission) are the lowest for natural gas combustion.  In general, burners for natural gas have higher energy generating efficiency than those for coal and oil.

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 Discharge of waste heat is the lowest for natural gas fuelling due to the higher energy efficiency. The waste heat has to be disposed of via the cooling system.  Combustion of natural gas generates no solid wastes whereas combustion of coal generates significant amounts of slag which has to be recycled and/or disposed of. Furthermore filter ash from air emission control systems has to be disposed of as hazardous waste.  Design, construction and commissioning period of CCPP is less than the other types of power plants which allows a comparable quick project implementation time.

Disadvantages when using natural gas are the potential hazard risk related to the handling of a flammable gas, the requirement of pipeline infrastructure, and the general consumption of a fossil resource which generates greenhouse

gas (CO2) emissions.

The burning of gas from biomass or of solid biomass itself in a power plant could be an option only in case the required large quantities would be available for base load operation, which is not anticipated for the mid or even long-term. Furthermore, respective transportation and storage capacities would be required.

4.3.2 Alternative Power Generation Techniques

Non fossil power generation

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

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

 Burning of biomass was mentioned above. Since biomass is generated decentrally and in comparably small rates in agriculture or forestry, utilisation in large power plants is not feasible in the region of Denizli.  Power generation from wind power requires very large wind farms to

reach the 800 MWel capacity of the CCPP with a respective occupation of land which is not available in the region of Denizli.  For solar energy the same applies given the requirement of large mirror

arrays. Solar power plants of 800 MWel capacity to date are not available as

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standard and cannot serve for base load electricity generation due to their dependency on sunlight fluctuation.  Hydropower can only be utilized in regions where large quantities of water are available in combination with the ability to collect water by means of a dam and/or to utilize a difference in height. In general, large areas are required for large capacity hydropower plants. Such situation is not given in the region of Denizli.  From their nature, wind and solar energy are no continuous energy sources and not reliable to provide for a base load. Efficiency and continuity of wind and solar energy generation strongly depend on wind and sunlight fluctuations. Wind farms shall be situated in wind prone regions.

Currently the existing grid structure and capacity in Turkey does not allow significant peak loads, caused by wind and solar energy production and significant investment is required to secure the framework condition within the transmission net for inserting of energy peak loads.

Non-fossil, renewable sources like solar, wind or biomass to date cannot be utilised for large scale and stable base load capacity generation in Turkey.

4.3.3 Process Technology

Power Generation with Combined Cycle Power Plant

Power plants for electricity generation from natural gas firing are based on gas turbines. Open cycle gas turbines can achieve an efficiency of some 30-35 %. By coupling with a steam turbine, the efficiency is extended significantly.

With an efficiency of approximately 57 % (56.72 % net as per Performance Guarantees at 15 °C), the combined cycle technology of the Denizli CCPP will make a most efficient use of the natural gas fuel. This technology represents the best available technology in terms of both efficiency of electricity

production and minimisation of environmental impacts (low-NOx).

The combination of two gas turbines as chosen for the CCPP provides a higher power supply safety than only one gas turbine (i.e. if one gas turbine is disconnected).

Other electricity generating technologies are not feasible for gas fired power plants.

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Cooling Design Alternatives

The key plant layout decision is about the cooling technology. Following Table 4-2 summarises the advantages and disadvantages of the potential cooling system alternatives from the environmental perspective.

The CCPP will be equipped with air cooled condensers (ACCs) which decision is based on the determinants as follows:

 There is no river in the vicinity which could serve as viable source for water supply.  Extraction of large volumes of groundwater for wet cooling is no viable and sustainable option in the Denizli region, because it would lead to depletion of groundwater resources.  ACC technology requires comparatively little raw water and allows for water resources saving operation of a combined cycle plant. Cooling water is circulated and only a low share needs to be inserted into the water circulation (below than 0.1% of the amount needed for direct cooling system). ACC technology is the Best Available Technology (BAT) for the Denizli CCPP, it is especially designed for dry regions.

Table 4-2 General Comparison of Cooling Systems Alternatives

Alternative Advantage Disadvantage

Cooling System Alternatives

Direct (once - highest energy - high water flow rate (roughly 70 -

through) water efficiency; 100,000 m³/h for 800 MWel) and cooling therefore feasible only at large - low visual impact rivers or water bodies / sea; - thermal plume from cooling water discharge into the river; - intake and outfall installations; (land consumption); - high potential for impacts on aquatic life (physical entrainment / impingement and pollution by chemical dosing). Indirect water - lower water demand - medium water demand (approx cooling by means compared to direct 1,000 – 2,000 m³/h; needed for of evaporative cooling make-up water to compensate

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Alternative Advantage Disadvantage cooling towers evaporation losses); - thermal plume from cooling water discharge into the river; - visual impact by the hyperbolic cooling towers, - land consumption for cooling towers; - visible vapour plume; increased fog formation; - considerable source of noise; Air cooled - minor water quantity - lower energy efficiency compared condensers (ACC) (10-40 m³/h; for make- to wet cooling; up purposes); - significant noise source which - no discharge of cooling requires mitigation; water, no thermal - annual cleaning of ACCs required plume; (wastewater); - no vapour plume; - land consumption for installation - no cooling tower. of the condensers. Cooling Water Supply Alternatives River water - low consumption of - Depends on presence and extraction land compared to ACC. sufficient yield of the river especially during dry season (once through cooling not possible); - pre-treatment required; - waste sludge is generated. River bank - no intake of cooling - increased land consumption; filtration (limited water directly from the - pre-treatment required; to wet cooling). river. - depends on the river's flow rate; - potential impact on groundwater table. Abstraction from - no water from a river - pre-treatment required; deep wells required; - groundwater draw-down effect (limited to ACC) - only make-up water, no possible cooling water; - small sized installations for wastewater

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Alternative Advantage Disadvantage treatment.

Additional Water Saving Techniques

In addition to the installation of the ACC cooling system further water saving technologies will be applied.

A condensate polishing plant will be installed which will remove solved and dissolved solids from the main condensate. The condensate can then be reused in the water-steam cycle so that less raw water is needed for this.

A further water saving measure is to treat internal water flows such as HRSG blow down or regeneration effluent as well as filter flushing flows to a maximum extent so that these flows can be re-used in the demineralization plant (replacing a certain amount of raw water) or it can be re-used in the wastewater treatment plant.

These measures will reduce the overall amount of raw water needed for operation of the Denizli CCPP by approximately 50 %.

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Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

5 – Anticipated Environmental and Social Impacts and Mitigation Measures

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CONTENTS of Section 5

5 ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES 5-1

5.1 IMPACT ASSESSMENT PROCESS 5-1 5.1.1 General 5-1 5.1.2 Introduction 5-1 5.1.3 Assessment Methodology 5-2 5.1.4 Assessment Content 5-2 5.2 AMBIENT AIR QUALITY 5-3 5.2.1 General 5-3 5.2.2 National and International Environmental Standards and Guidelines 5-4 5.2.3 Atmospheric Emissions during Plant Operation 5-6 5.2.4 Ambient Air Quality Assessment for the Power Plant Operation 5-7 5.2.5 Mitigation 5-16 5.2.6 Atmospheric Emissions during Construction Activities 5-16 5.2.7 Mitigation Measures during Construction 5-18 5.3 IMPACTS ON CLIMATE 5-18 5.3.1 Local and Regional Climate 5-18 5.3.2 Local Temperature 5-19 5.3.3 Greenhouse Effect 5-20 5.4 NOISE IMPACT 5-20 5.4.1 Introduction 5-20 5.4.2 Noise Impact Modelling of the New Power Plant Operation 5-21 5.4.3 Mitigation 5-24 5.4.4 Construction Noise 5-25 5.4.5 Vibration 5-26 5.5 IMPACTS ON LAND USE 5-26 5.6 IMPACTS ON SOILS AND GEOLOGY 5-27 5.6.2 Mitigation measures during construction 5-28 5.6.3 Mitigation measures during operation 5-29 5.7 IMPACTS ON GROUND AND SURFACE WATER 5-29 5.7.1 Potential Construction Impacts 5-29 5.7.2 Impacts of Groundwater Abstraction 5-30 5.7.3 Mitigation Options 5-31 5.7.4 Further Potential Operation Impacts 5-32 5.7.5 Impacts of Wastewater Discharge 5-32 5.8 IMPACTS ON FLORA , FAUNA AND HABITATS 5-35

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5.8.1 Potential Impacts as a Result of the Power Plant Operation 5-36 5.8.2 Impacts during Construction 5-36 5.9 VISUAL IMPACTS 5-39 5.9.1 Mitigation 5-40 5.10 ARCHAEOLOGY , HISTORICAL AND CULTURAL HERITAGE 5-41 5.11 SOLID WASTE MANAGEMENT 5-41 5.12 ELECTRIC AND MAGNETIC FIELDS (EMF) 5-42 5.13 MAJOR ACCIDENT HAZARDS 5-44 5.13.1 Identification of Hazards 5-44 5.13.2 Operational Health and Safety 5-44 5.13.3 Emergency Response Plan (ERP) 5-45 5.14 NATURAL DISASTER RISKS 5-46 5.14.1 Seismic Risk 5-46 5.14.2 Flooding Risk 5-46 5.15 INTERFERENCE WITH OTHER FACILITIES OR ACTIVITIES 5-46 5.15.1 Industries 5-46 5.15.2 Air Traffic 5-47 5.15.3 Local communication and pathways 5-47 5.16 SOCIAL AND SOCIO -ECONOMIC IMPACTS 5-48 5.16.1 Introduction 5-48 5.16.2 Loss of Land and Natural Resources 5-48 5.16.3 Pressure on Social Networks and Infrastructure 5-50 5.16.4 Increased Health Risks 5-52 5.16.5 Economic Impacts 5-55 5.16.6 Mitigation Measures 5-56

LIST OF TABLES

Table 5-1: National and international ambient air quality standards 5-5 Table 5-2: Composition of flue gas as per the design data 5-6 Table 5-3: Emission Parameters for the HRSG stacks 5-9 Table 5-4 Modelling results of the calculated increments of ground level concentration and deposition 5-12 Table 5-5 Results of the modelling provided with the local EIA (ISCST3); concentration of

NO 2 5-13 Table 5-6 Comparison of incremental concentrations predicted for the power plant operation against national and international standards 5-15 Table 5-7 Noise Sources used for the Noise Prediction of the new CCPP 5-22

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Table 5-8 Cumulative noise levels at the settlements; in dB (A) 5-23 Table 5-9 Wastewater Quality Levels for Discharge into a Surface Water Body 5-34 Table 5-10 Turkish Irrigation Water Classes (optional use for wastewater) 5-35 Table 5-11 EMF Recommended Distance related to ICNRP limit values 5-43

LIST OF FIGURES Figure 5-1 Wind roses of Denizli meteorological station for the 30 years long-term average and for the year 2006 (22.5°-sectors) 5-10 Figure 5-2 Wind rose of Denizli meteorological station for 2006 (the 10°-sectors required by the AUSTAL model were randomized from 22.5°-sectors) 5-11 Figure 5-3 Noise pressure levels (Leq) during operation 5-23 Figure 5-4 People’s perceptions about whether they would get on with the newcomers 5-51

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5 ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES

5.1 IMPACT ASSESSMENT PROCESS

5.1.1 General

The assessment of the environmental and social impacts for the CCPP Project is based on the information available at the present project preparation level as described in Section 2. This includes information from Project’s feasibility study and information from subsequent tender information.

5.1.2 Introduction

This section identifies and evaluates the environmental and social impacts of the development and operation of the proposed Project. The impact assessment considers effects from:

• Presence of physical project structures, • Construction, • Operation & Maintenance, • Decommissioning.

After reaching the end of its designated operational lifetime (25 – 40 years), the CCPP will be decommissioned and dismantled. The site could be re-used as brownfield site for future industrial development. This would need to undertaken according to the pertinent EU or best practice standard at the respective decommissioning time. Potential follow-up use after decommissioning and dismantling of the CCPP and site cleanup will be up to the decision of the owner.

For each relevant issue ( e.g. air quality, noise), the nature of the impact is discussed along with its potential significance. For impact valuation, criteria such as legal standards, limit values, recommendations, guidelines and practise standards are used as applicable. This includes pertinent Turkish

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environmental standards, and the IFC guideline for new thermal power plants 1, as well as EU environmental standards.

Where potentially significant adverse impacts are identified, mitigation measures are discussed wherever possible to avoid or ameliorate the impact to an acceptable level.

Where identified, beneficial or positive impacts/effects of the project are also highlighted.

The assessment is also considering interactions and cumulative impacts with existing installations in the neighbourhood, where applicable.

5.1.3 Assessment Methodology

Identification and assessment of impacts has been undertaken through a process comprising on-site observations, consultation with RWE & Turcas experts, literature review and experience from similar projects. In addition, environmental impact modelling was carried out for the relevant effects for the Project:

• Atmospheric dispersion modelling of the stack emissions (cf. Section 5.2); and • Noise dispersion modelling (cf. Section 5.4).

In order to determine potential social effects of the project, the comprehensive socio-economic baseline study (cf. Section 3.15) was used as basis for the impact assessment.

The results of this assessment process are documented in this ESIA along with indication and recommendations for further work and investigations.

5.1.4 Assessment Content

The following items are examined in the corresponding subsections of this chapter:

• Air Quality;

1http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_T hermalPower/$FILE/FINAL_Thermal+Power.

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• Climate; • Noise and vibration; • Land use and communication; • Soil; • Groundwater and surface water; • Flora and fauna; • Visual impacts; • Archaeology, historical and cultural heritage; • Natural disaster risks; • Interference with other facilities or activities; and • Social and socio-economics impacts.

For each of these topics, a description and evaluation of the significance of potential impacts of the project is presented. Where modeling has been undertaken, a description of the model as well as corresponding maps summarising the results of the assessment are provided.

Where mitigation measures are considered to be necessary, these measures are presented and taken into account in order to estimate the predicted impacts. The methodology and scope employed in the ESIA is consistent with international practice, such as required by IFC, EBRD and other financing institutions.

5.2 AMBIENT AIR QUALITY

5.2.1 General

Air pollutant impact calculations were performed to evaluate the air impact of the planned Denizli 800 MW Combined Cycle Power Plant's (CCPP). Present ambient air background levels were determined by ambient air measurements in June - August 2008 ( cf. section 3.10 ).

In order to determine the effect of operation of the power plant on the environment, the increments of the ground level concentration caused by the plant emissions is calculated by means of dispersion modelling.

Based on the results, the air impact is discussed with respect to Turkish and international standards in view of the existing pollution levels. If considered

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necessary, mitigation measures are proposed that are considered feasible to meet the applicable standards.

5.2.2 National and International Environmental Standards and Guidelines

Standards for Emission Limits

Air emission standards applicable for the power plant are compiled in section 3.10 and compared to the emissions of the Project.

Given the use of natural gas as fuel for the CCPP, the only significant air pollutant emissions to be expected from plant operations are nitrogen oxides

(NO x) and carbon monoxide (CO). For both substances, the emission concentrations will be below 50 mg/m³ (as per BREF 2).

Due to solely fuelling of the power plant with natural gas, emissions of sulphur dioxide and particulate matter are negligible. Based on a maximum sulphur content of 115 mg/m³ in the natural gas supplied by BOTAS (low- sulphur gas), the maximum hourly emission rate with the exhaust gas is about

8.5 kg SO 2 for each stack (total 17 kg SO 2/h).

For power plant operation, it is of vital interest to have almost no particles in the gas turbines to avoid wear of the high-tech material. Therefore, the intake air will be dust filtered. The concentration of particle emissions from the stacks will be below the European standard of 5 mg/m³ for gas turbines.

Ambient Air Quality Standards

A compilation of the standards for ambient air quality is found in Section 3.10(cf. Table 5-1). The international standards are taken from the IFC – General EHS Guidelines and regulations issued in the European Union. 3

2 Reference Document on Best Available Techniques for Large Combustion Plants (BREF), European Commission, July 2006 3 For the application of ambient air quality standards, it is important to take into consideration that measurement and/or modeling sometimes constitute a system together with the standard. In this respect, some ambient air quality standards have to be linked to a certain modeling approach. The European standards, for example, require modeling which is adapted to the standards, to evaluate a standard allowing for a certain number of exceedings as a statistical parameter.

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Table 5-1: National and international ambient air quality standards

Turkey * IFC guideline value European Commission Averaging period 24 calendar 1 hour 24 hours calendar 1 hour 24 hours calendar hours year year year

Carbon monoxide (CO) 30,000 10,000 - - -- 10,000 in µg/m³ (8 hrs)

Nitrogen dioxide (NO 2) 300 100 200 - 40 (G) 5 200 5 40 in µg/m³ (G) 4 30 6

Sulphur dioxide (SO 2) 400 150 500 125/50/20 - 350 7 125 [50] in µg/m³ (10 min) (T1/T2/G) * 20 8

PM 10 (airborne particles 300 150 - 150/ 70/ - 50 10 40 with aerodynamic 100/ 50/ diameter of 10 µm or 75/ 30/ less) in µg/m³ 50 9 20 *

Dust deposition in - 450 ** - - - - - [350] mg/(m²*d)

4 T1/T2/T3/G – IFC interim target-1 / interim target-2 / interim target-3 / Guideline value: The guideline values provided in the IFC General EHS Guidelines are adopted from the WHO Ambient Air Quality Guideline 2005. The guideline values cascade down from higher to lower levels indicated as ‘interim-target 1’ through ‘interim-target 3’ to end up at the ‘guideline value’ with the lowest concentration and highest ambient air quality. Interim-targets take into consideration that achievement of the guideline value in undeveloped or developing countries requires long-term development and improvement effort. 5 The standard may be exceeded up to 18 times per year. 6 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project. 7 The standard may be exceeded up to 24 times per year. 8 The standard is applicable only for remote areas and ecosystems with no industries within about 30 km distance. Thus it is not applicable to the Project. 9 T1/T2/T3/G – IFC interim target-1 / interim target-2 / interim target-3 / Guideline value (see footnote for gaseous substances above). 10 The standard may be exceeded up to 35 times per year.

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5.2.3 Atmospheric Emissions during Plant Operation

The power plant will solely be operated with natural gas. There is no use of e.g. heating oil for back-up purpose. During operation, the exhaust gas of the gas turbines will be released to the atmosphere via two 60 m high stacks.

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

At standard design conditions, where the plant emissions are commonly guaranteed by the gas turbine manufacturers, a flue gas volume flow rate of about 1.9 million Nm³/h (dry) will be emitted from each stack at a temperature of 104°C for base load operation. It has to be noted that flue gas temperature and volume flow depend on the actual temperature, humidity, and pressure of the ambient air as well as on the operation load of the plant. However, the effect of these variations on modelling results is not significant. The composition of the exhaust gas is shown in Table 5-2.

Table 5-2: Composition of flue gas as per the design data

Concentration Emission Rate (both gas turbines at 100% load)

O2 15 Vol-% as reference * -

CO 2 ** 276 t/h

NO x (as NO 2) 50 mg/Nm³ * 190 kg/h

CO 50 mg/Nm³ * 190 kg/h

Particles <5 mg/Nm³ ** < 19 kg/h (particles from air intake)

SO 2 <5 mg/Nm³ *** < 19 kg/h

* Design specifications ** Based on the assumption that the standard is complied with *** Calculated from project data like natural gas composition

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5.2.4 Ambient Air Quality Assessment for the Power Plant Operation

5.2.4.1 Atmospheric Dispersion Modelling

General

Atmospheric dispersion modelling of stack emissions has been carried out for the CCPP in order to assess the impact of plant operation on ground level concentrations. Two different models were used for the local EIA compiled by TCT (2008) and in this ESIA. Parameters for comparison against different standards can be obtained by this approach. It has to be noted that the models have different calculation methods which could lead to differing results:

Gaussian Dispersion Model

The Gaussian ISCST3 model approved by the US EPA 11 was used by TCT- Ekotest. The basis of the model was developed in 1979 and subsequently modified to include modules which to some extend can consider topography and meteorological specifics. While since 2006 a new Gaussian model (AERMOD) is preferred in the USA, the ISCTS3 model is still accepted for use in less complex situations. The use of AERMOD requires significantly more meteorological and topographic information.

Lagrangian Dispersion Model

The Lagrangian particle model AUSTAL2000 was used to estimate the ambient air impact resulting from atmospheric dispersion of the pollutants which will be emitted from the planned power plant. AUSTAL2000 is the official reference model of the German Instruction on Air Quality Control (TA Luft) and required for pollutant dispersion modelling in the German permitting process. The model is set up and verified in conformance with the German guideline on atmospheric particle models - VDI 3945/3 12 .

Lagrangian particle models are advanced models which consider local topography and meteorological situations in more detail than Gaussian models. Comprehensive meteorological parameters are used in form of a

11 Environmental Protection Agency of the United States of America 12 VDI – Society of German Engineers; the VDI publishes technical guidelines and norms comparable to ISO standards

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dispersion class statistics utilizing the parameters wind direction, wind speed, and atmospheric stability. Thus, the dispersion of substances follows the wind streams modulated by topography. This might be relevant in a complex terrain like it is present in the site vicinity. In addition, the model allows accounting for high abundance of calm wind situations.

Emission sources can be defined as point, line, area, or volume source. The results of the dispersion calculation are substance-specific quantities according to EU directives.

The modelling in this ESIA was performed by means of the AUSTALView software 13 which utilizes the AUSTAL2000 model.

Emission Parameters used for the Dispersion Calculation

The emission source parameters and the mass flows for modelling were taken as already provided in Section 3.10. Table 5-3 provides a summary of the parameters used for the modelling.

For the calculation, operation throughout an entire year (8,760 hours) was presumed, which neglects that operation actually is interrupted by e.g. maintenance and thus reduces the annual operation time. Calculations were performed for an area of 16 km x 16 km (10 km x 10 km with ISCST3 in the EIA).

13 Version 5.0 by Lakes Environmental (http://www.weblakes.com )

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Table 5-3: Emission Parameters for the HRSG stacks

Parameter Respective Value

Planned stack height / diameter (2 x HRSG stacks) 2x 60 m / 7 m

Exhaust gas temperature 104°C

Flow rate of the dry exhaust gas at reference conditions 2 x 1,900,000 Nm³/h *

Reference conditions 273 K; 101.3 kPa

Waste heat emission About 70 MW

Maximum emission rates for both gas turbines kg/h operating 2 x 95 - NOx (as NO 2) 2 x 95 - CO < 38 - PM10 < 38 - SO 2 276 t/h - CO 2

* Nm³ - Gas flow for dry standardized gas (273 K, 101.3 kPa)

Meteorological Parameters

Meteorological data representative for the project area are fed into the dispersion model by means of a three-dimensional statistics in the special format required by the software. 14

As described in Section 3.9, the nearest meteorological station is located in Denizli about 30 km west of the site. In Figure 5-1 the wind rose for Denizli is shown based on the 30 years long-term data. The data are provided in 22.5°- sectors (TCT-Ekotest EIA 2008). For the modelling, hourly wind data of the year 2006 was used which is also included in this figure. The AUSTAL model requires 10°-sectors, the corresponding wind rose is shown in Figure 5-2.

The statistics of Denizli station were transposed to the area of interest by wind field simulation. This means that the statistical data of the station were

14 This data format represents the relative probability of all possible combinations of wind direction (36 wind direction classes), wind speed (9 classes) and stability of the atmosphere (six stability classes ranging from very stable to very unstable). In optimum situation the statistics comprises these data for each hour of a year.

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modulated via the region's topography. By this approach the Denizli statistics can be adopted and considered representative for the site area 15 .

Figure 5-1 Wind roses of Denizli meteorological station for the 30 years long-term average and for the year 2006 (22.5°-sectors)

NNW 20 NNE

NW 15 NE

10 WNW ENE 5

W 0 E

WSW ESE

SW SE

SSW SSE

S Long-term average 2006

As can be seen, the shapes of the 30 year long term average and the 2006 wind rose are very similar, meaning that the 2006 data can be adopted in the model since it is representative. Additionally, it can be seen from the comparison of the wind roses that in 2006 winds coming from the West and the North were more frequent than in the long-term. Given the locations of Kaklik south and of Yokusbasi east of the site, the calculated air pollutant impact on the settlements might rather be overestimated by this. Thus, in the model are more adverse meteorological situations covered than it is expected from the long-term statistics.

15 However, various assumptions had to be made which influence the accuracy of the modeling results, which is estimated to be around 20%.

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Figure 5-2 Wind rose of Denizli meteorological station for 2006 (the 10°-sectors required by the AUSTAL model were randomized from 22.5°-sectors)

5.2.4.2 Ambient Air Impact - Results and Discussion

Modelling Results

The assessment of ambient air pollution impact is based on modelling of the increments of pollutant ground level concentrations resulting from operation of the plant. In the following, all results are discussed based on the maximum impact level within the area for the calculation (16 km x 16 km).

The calculated maximum ambient concentration increments of the studied pollutants are summarized in Table 5-4. Contour plots of calculated

increments are shown in Annex B for NO 2 as the substance of most interest. The spatial distributions of the following parameters are provided:

• Annex B 1: Annual average concentration of nitrogen dioxide (NO 2)

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• Annex B 2: Hourly concentration of NO 2 resulting from the hour with the most adverse meteorological situation of the entire year • Annex B 3: Hourly concentration which is exceeded 18 times (18 hours) of the year (as allowed per the standard of the European Directive 1999/30/EC).

Table 5-4 Modelling results of the calculated increments of ground level concentration and deposition

Pollutant Reference Period Calculated Maximum Increment Air Shed Kaklik Yokusbasi Alikurt Asagidagdere

NO 2 (µg/m³) 1 year 1.2 0.5 – 0.8 0.1 - 0.2 0.3 0.7 - 0.8 1 hour; 18 33 14 – 24 7 – 14 22 - 24 23 – 26 exceedings* Maximum hour 76 15 – 26 10 – 19 26 - 33 24 - 28 of year

CO (µg/m³) Since the maximum emissions are equal to NO 2, the

increments for NO 2 can be taken for CO

SO 2 (µg/m³) 1 year <0. <0.1 1 1 hour; 24 <4 <3 exceedings* Maximum hour 8 <3 of year

PM10 Since the maximum emissions are equal to SO 2 and PM10

(µg/m³) particles behave like gases, the increments for SO 2 can be taken for PM10 * Value according to the European ambient air quality standards defined as 1 hour limit but allowing for a number of exceedings. This means that the 18 highest averages of the year are excluded. As a first and conservative approach, the calculated values can be interpreted as reference 24 hours maximum, however, overestimating the actual 24- hours average.

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Table 5-5 Results of the modelling provided with the local EIA (ISCST3); concentration of NO 2

Reference Calculated Maximum Increment of NO 2 (µg/m³) Period Model Shed Kaklik Yokusbasi Alikurt Asagidagdere (10x10km)

Annual Average 17 0.2 0.2 0.3 0.1 average meteorology Adverse 23 <0.1 0.3 0.3 0.1 meteorology 16 24 hours Average 75 1.3 1.6 1.9 0.6 average meteorology Adverse 157 <0.1 1.8 2.4 0.7 meteorology Source: EIA, TCT 2008

The ISCST3 modelling yielded highest values for the mountain tops. The hourly maximum is higher than calculated with AUSTAL. This is most likely due to the fact that the ISCST3 model can not consider the air streams as they are modulated by the terrain and thus results in higher ground level values which often are found as local and small sized peak on a hilltop. On the other side, the ISCST3 results for the settlements are similar or lower than those calculated with AUSTAL. With respect to the applicable standards, the ISCST3 results meet all standards with the only exception found on top of the hill 2.5 km east of the site between Yokusbasi and Alikurt adverse meteorological situation. The adverse meteorological situation used in the ISCST3 modelling refers to a wind speed of 0.1 m/s (calm) combined with an atmospheric stable situation which is the most adverse to dispersion because the mixing height for dispersion of substances is equal to the stack height. However, at the nearby settlements low levels are calculated for this adverse meteorological condition which underlines the local peak character of the maximum.

The dispersion graphs obtained with AUSTAL are provided in Annex B. The following general results can be deduced from the map presentations:

• The maximum of the annual average concentration is located about 3.5 km southeast of the site and is dominated by the prevailing north-western winds. • Given the negligible frequency of winds from the South and the East, the increments west and north of the site are less than 10% of the maximum.

16 The adverse meteorological situation used in the ISCST3 modeling refers to a wind speed of 0.1 m/s (calm) combined with an atmospheric stable situation which is the most adverse to dispersion of emissions since the mixing height for dispersion is equal to the stack height

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• The maximum of all the one hour short-term increments is predicted for some high hills surrounding the valley which raise some 500 m above the site level. The high increments are caused by the slowed-down wind streams at the slopes of the hills. • When excluding the 18 highest hours of the year (0.2% of a year's hours), a value is determined which depends less on singular and rare

meteorological conditions. The respective map for NO 2 shows relative homogeneous distribution of 20 – 25 µg/m³ increments in the southern half of the modeling area. North of the site the short-term increments drop below 5 µg/m³ (cf. Annex B2).

• Similar patterns and data are obtained for CO. SO 2 and PM10 levels are a factor of 10 smaller but the spatial pollutant distribution patterns are comparable.

Evaluation of Incremental Ambient Air Impact

For the comparison of the modelled results against the national and international standards an increment-to-standard ratio (hereafter "increment ratio") is calculated. The ratio is calculated from the increments provided in Table 5-6 against the most stringent applicable standard of Table 5-1. The calculated ratios summarized in Table 5-6 show that no standard for an annual average or short-term value will be exceeded.

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Table 5-6 Comparison of incremental concentrations predicted for the power plant operation against national and international standards

Pollutan Reference Most Increment-to-standard Ratio given as t Period stringent percentage (%) standard * Air shed Kaklik Yokus- Alikurt, (µg/m³) maximum basi Asagi- dagdere NOx Annual average 40 IFC, EU 3 1 - 2 <0.5 < 2 24 hours average 300 TR 52 <1 <1 <1 ** 1 hour average; 200 EU 18 7 - 12 3 - 7 11 – 13 18 exceedings Maximum hour 200 IFC 38 8 - 13 5 - 10 12 – 17 of year

CO Maximum hour 10,000 TR, < 0.5 <0.1 of year EU

SO 2 Annual average 20 EU 0.5 0.5 1 hour average; 350 EU <1 <1 18 exceedings Maximum hour 400 TR 2 <1 of year

PM 10 Annual average 20 IFC 0.5 0.5 1 hour average; 50 EU <8 <6 35 exceedings

* Standards as per Table 5-1 and as far as applicable (units are shown in that table). In case various standards are applicable, the strictest standard is listed in the table.

** Values obtained with the ISCST3 modeling for the national EIA (TCT-Ekotest 2008)

Sources: Table 5-1, Table 5-4, Table 5-5

Conclusions

In summary, the calculated increments of the new power plant will meet the applicable national and international standards. The contribution of the incremental NO2 concentration to the standards (increment-to-standard ratio) in the settlements is very low for the long-term averages. With regard to the 1- hour short-term standard for NO2 the contribution is below 20% which is also not considered significant, since this short-term value is predicted only for one hour of a year. For the other modelled substances CO, SO2 and PM10, the increment-to-standard ratio is very low, meaning that the operation of the CCPP will not significantly affect the ambient air quality.

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Total Concentrations Including Results from the Baseline Measurements

The evaluation of the future situation with operation of the CCPP including the present background levels uses the measurements described in Section 3.9.3. For the accumulation it is presumed that the background level will not be increased by any emission source other than the power plant.

The baseline value for NO 2 was 15 µg/m³ in Kaklik and 16 µg/m³ in Yokusbasi. With the increment of 0.8 µg/m³ calculated for Kaklik and 0.2 µg/m³ for Yokusbasi, the cumulative concentrations will be about 15.8 µg/m³ and 16.2 µg/m³ respectively which is a minor contribution. The

baseline value for NO 2 was 12 µg/m³ in Alikurt and 7.5 µg/m³ in Asagidagdere. With the increment of 0.3 µg/m³ calculated for Alikurt and 0.8 µg/m³ for Asagidagdere, the cumulative concentrations will be about 12.3 µg/m³ and 8.3 µg/m³ respectively which is a minor contribution. No ambient air standard will be exceeded by this.

Given that the ambient air quality measurements and modelling show concentrations well below the limit values the ambient air quality sampling during two months was deemed to be sufficient. Based on Table 5-6 and the above discussion regarding the expected future total concentration, the CCPP's incremental concentrations are most likely too low to being directly detectable by ambient air quality measurements.

5.2.5 Mitigation

The results of the dispersion modeling show that no further mitigation

beyond the planned use of natural gas and low-NO x burners are required to reduce the stack emissions. The stack heights of 60 m satisfy the requirement of undisturbed dispersion of the emitted pollutants. The emissions will meet the applicable national and international emission standards. Continuous monitoring of relevant air pollutants and technical reference parameters will enable operation of the plant under optimum operating conditions. Irregular emission levels will be identified by this and appropriate counter measures can be taken in short-term (cf. section 6, Action O3).

5.2.6 Atmospheric Emissions during Construction Activities

Particulate Matter

During construction activities, dust can be generated on-site. Activities of dust emitting potential are:

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• Delivery and on-site transport of construction material and equipment with vehicles and trucks; • Earthmoving operations on the site (filling, excavation and removal of surface material/sand); and • Wind erosion.

Due to the extended on-site earth works for site leveling, the potential for generation of dust is high during the respective period of about 2 months. For the EIA an estimation of dust emissions was provided based on emission factors for construction works provided by the Turkish Ministry of Environment and Forestry (TCT-Ekotest, 2008). The dust emissions were calculated to amount to about 13 kg/h. Based on this figure, the modeling results were as follows:

• The maximum daily average for dust concentration was predicted in the direct neighborhood of the site at 390 µg/m³. The values in the settlements are much lower; 95 µg/m³ at Kaklik, 167 µg/m³ at Yokusbasi, and 30- 40 µg/m³ at Alikurt and Asagdagdere. • The calculated annual average values are 68 µg/m³ for the maximum located on site, 14 µg/m³ for Kaklik, 25 µg/m³ at Yokusbasi, and 2- 4 µg/m³ at Alikurt and Asagdagdere. These annual values, however, will not be reached when considering the anticipated duration of two months for the respective works. • The maximum value for dust deposition will be 21 mg/(m²*d). For Kaklik the deposition is predicted at 12 mg/(m²*d), for Yokusbasi at 8 mg/(m²*d) and for Alikurt and Asagdagdere below 2 mg/(m²*d). • Compared to the Turkish standards for PM10 and dust deposition, no exceeding is anticipated even when the existing dust concentration is included in the assessment. • Compared to international standards for PM10 and dust deposition, no exceeding is anticipated in Kaklik, Alikurt and Asagidagdere even when the existing dust concentration is included in the assessment. However, in Yokusbasi, the short term daily standard will be exceeded.

Other Emissions

The movements of vehicles will result in emission of airborne pollutants from the exhausts of the vehicles. The amount of such emissions depends on the number of vehicles, vehicle type, and their technical condition. Throughout the construction of buildings and structures, approximately 16,000 tonnes of

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material will be transported to the site. As rough estimate a loading capacity of 7 t per truck can be assumed, meaning a number of about 2,300 trucks riding on and off the site throughout the construction period. Based on this, a number of 10 trucks per day can be expected on average. As adverse estimate, peak traffic may increase to the 10-fold on some rare days. This would mean about 20 trucks per hour, most of them leaving the highway and driving along the new access road. However, this effect will be limited to areas of Kaklik located to the national road. Some nuisance can be expected from the site related traffic in case of a peak day. In general, no significant emissions or other impact is anticipated. The emissions from construction related traffic are considered to be not significant.

5.2.7 Mitigation Measures during Construction

In order to limit the impact of the construction activities on air quality, the following mitigation measures shall be implemented:

• Material transport and stockpiling of material shall be managed carefully to minimize particle abrasion; • In general, generation of dust emissions should be mitigated during construction works by spraying with water under dry weather conditions. • Roads shall be compacted during construction and graveled if necessary; • Roads shall be maintained in good condition; • Access to the site shall be regulated; • Engines of vehicles shall be in a good state of maintenance (e.g. no soot cloud); • Vehicle speed shall be limited on-site;

5.3 IMPACTS ON CLIMATE

5.3.1 Local and Regional Climate

The site is located in a valley. Therefore the buildings of the power plant will not form a significant hindrance for local wind field and air transport. As there are no high buildings in the neighbourhood no wind funnel or other effects on the local wind fields are anticipated.

The operation of ACC will not produce a vapor plume like it is known from cooling towers where high volumes of vapor is drafted into the atmosphere.

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Therefore no effects like increased humidity or additional fog creation on cool days in the neighbourhood of the power plant are expected to occur.

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

5.3.2 Local Temperature

During public consultations concerns were raised that the operation would cause a local warming and impact to agriculture.

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

transfers about 450 MWth into the air.

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

From the ACC approximately 32 degrees warm air is rising (air throughput of 22,000 m³/s). The dilution factor required to ensure a temperature increase of less than 1 °C is about 1:12. It can be assumed that such dilution is reached in the ACC's air stream after only a short time and distance. Since the ACC fans lift the up-heated cooling air into the atmosphere, no significant waste energy flow will reach the ground 17 .

It has also to be noted that the issue of potentially increased ground level ambient temperature caused by operation of a cooling tower or an ACC is no matter of concern for power plant projects. Neither the IFC guideline nor the EU BREF or international regulations address this topic due to the non- existing relevance.

17 Also from operational view the CCPP is designed that waste heat is directed upwards so that the temperature of the intake is not increased by the ACC waste heat emissions. In such case of heat circulation, the cooling process would become inefficient. Therefore, a waste heat related significant temperature increase at the intake is contra productive and can be excluded.

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5.3.3 Greenhouse Effect

The power plant will be solely fired with natural gas. Carbon dioxide (CO 2) is generated by combustion of carbon containing fuels. Burning of natural gas,

therefore, generates CO 2 which contributes to the Greenhouse Effect and

Global Warming. However, no other greenhouse gases like i.e. methane (CH 4),

nitrous oxide (N 2O), are generated by combustion of natural gas.

The specific CO 2 emission rate of the Denizli power plant will be approximately 356.5 g per kWh of electricity generated. Carbon dioxide emissions are estimated to be about 2.4 million tons per year (based on

8,400 hours base load operation and 276 t/h CO 2 emission).

The emissions of CO 2 from fuel burning in Turkey amounted to around 313 million t/a in 2005 (1 st National Communication , 2007) 18 . Compared to

these CO 2 emissions, the Project will account for approximately 0.8 %.

The operation of a natural gas fired power plant is in accordance with the policies and measures addressed in the 1 st National Communication. The most important measure listed is the promotion of wide use of natural ga s.

5.4 NOISE IMPACT

5.4.1 Introduction

This section presents an assessment of the noise impacts potentially arising from the construction and operation of the Project. In the baseline Section 3.10, a general introduction to the environmental factor noise is given. Measurements in the vicinity of the site were performed in June 2008. The results are also provided in the baseline section (cf. section 3.10.2).

In Table 3-6 of Section 3.10.3 the applicable national Turkish and international (IFC) standards for environmental noise are compiled.

Noise modelling was performed for the impact assessment of the new CCPP.

18 Source: Turkey's First National Communication under the United Nations Framework Convention on Climate Change, 2007

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5.4.2 Noise Impact Modelling of the New Power Plant Operation

Noise Sources

Operation of the new CCPP will involve significant sources of noise, e.g. turbines, air cooled condenser. The actual sound characteristics of the noise sources will be specified through the detailed design by the EPC Contractor. Additionally, the detailed design will specify the sound absorbing features of buildings, silencers, etc. To assess the impacts of operation noise of the CCPP two indicative noise predictions were conducted. A first preliminary modelling was conducted in the course of the EIA-process under Turkish law and already demonstrated compliance with Turkish law, based on the engineering available at the time (August 2008). In line with the progress in planning and engineering of the CCPP a second prediction was carried out in January 2010 (cf. Annex C). The aim of the study was to answer the question on whether or not an adverse noise exposure has to be expected for the neighbourhood settlements and which mitigation measures should be considered, if required to meet the international noise standards. This modelling is based on a conservative “plausible worst-case” approach.

For the modelling of the future situation, the plant layout and major noise sources were considered. General input parameters were the location and sound power levels of the noise sources. Also considered in the modelling were the following aspects:

• Prevailing climatic conditions, • Ground and meteorological correction, • Detailed topography, • Attenuation characteristics and insertion losses of buildings, etc., • Directivity factors applicable to certain noise sources. i.e. air intake, stack opening, etc., • Plant layout effects, i.e. the use of plant structures and buildings to screen or prevent noise transmission in particular directions as well as reflections.

The major noise sources of the Project are listed in Table 5-7 with their sound power levels.

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Table 5-7 Noise Sources used for the Noise Prediction of the new CCPP

Noise Source Sound power level (L W) of noise sources in dB(A)

Overall sum for the CCPP 122

Air intake opening 106 Air intake duct 99 Turbine building 114 Turbine building ventilation intake 110 Turbine building ventilation outlet roof fans 106 Generator 99 Exhaust diffuser 103 HRSG incl. transition duct, stack body and 107 pipe work Stack mouth 105 Feed water pump set 112 Main transformer 104.3 Aux. transformer 90 Atmospheric drain vessel, start up ejector 105 Gas receiving and metering station 99 ACC 114 Combustion turbine, generator, re-cooler 111

Results of Noise Modelling

The predicted noise levels L Aeq are shown in Figure 5-3.

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Source: Acoustical study far field noisePro-Acoustics Ltd, Jan 2010

Figure 5-3 Noise pressure levels (Leq) during operation

The nearest residential houses are located outside of the closed settlement areas of Kaklik at the northern side of the national road D320 in a distance of approx. 1 km to the site (IP2). The expected noise level in this distance is 43 dB(A). However, the nearby national road will overweigh the noise levels coming from the CCPP. Second nearest residential area is the village of Yokusbasi (IP1) to the East of the site. The predicted noise level at this village is 40 dB(A).

Since the noise standards apply to the cumulative noise, the results of the baseline measurements have to be considered. The cumulative noise levels are listed in Table 5-8.

Table 5-8 Cumulative noise levels at the settlements; in dB (A)

Kaklik (IP2) Yokusbasi Turkish IFC (IP1) Standard Standard

Daytime Leq Baseline 51.6 50.5

Daytime Leq Modeling 43.0 40.0

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Kaklik (IP2) Yokusbasi Turkish IFC (IP1) Standard Standard

Daytime Leq Cumulative 52,2 50.9 65 55

Night time Baseline 52.7 40.0

Night time Modeling 43.0 40.0

Night time Cumulative 53.1 43.0 55 45

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

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

Given these results, the Turkish noise standards are met at the two settlements for both, the day and the night time. With respect to the IFC standards, the cumulative daytime levels and the night time level for Yokusbasi (IP1) will meet the respective standard. However, for the night time the levels in Kaklik (IP2) exceed the standard. On the other side the contribution of the CCPP to the cumulative noise level of 53.1 dB(A) during night time is a mere 0.4 dB(A) which effect will not be perceptible. The additional criterion that the incremental noise from a plant shall not increase the baseline by more than 3 dB(A) was met for Kaklik and Yokusbasi.

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

5.4.3 Mitigation

The noise abatement requirements mentioned before can be met by the EPC Contractor's selection of equipment, sound absorbing equipment, and noise barriers on site so that the level of 40 dB(A) at Yokusbasi and 43 dB(A) at Kaklik are met.

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In addition, the sound power level on site shall not exceed 85 dB (A) at accessible points in a distance of 1 m to the noise source as 85 dB (A) is an international standard for occupational health and safety 19,20 . According to IFC EHS Guidelines the use of hearing protection should be enforced actively when the noise level is 85 dB(A) during 8 hours.

5.4.4 Construction Noise

During construction, vehicles will be moving on the site area and on the access road. Noisy activities may occur over short periods during piling, concrete pumping, outdoor usage of machines (e.g. saw, compressed air tools) and activities like hammering. All these noise sources are typical for construction activities and may temporarily cause elevated noise levels in the site's vicinity.

For the levelling of the area and during construction 2 bulldozer, 5 trucks, and 1 water spraying truck will be operating. Additionally, vehicles for employee and (sub) contractors may move around. Noisy activities by the workforce using handheld machines may add.

Based on this, the following situation can be anticipated as the average: 8 machines with about 101 dB(A) sound power level (Lw), less than 20 vehicles with Lw below 90 dB(A), less than 20 handheld machines with Lw below 100 dB(A). These sources add-up to a total noise power of less than 114 dB(A) as estimate for the entire construction site.

A comparison with the results for the plant operation which is based on a Lw of 119 dB/A shows that the estimated impact caused by sound sources at the construction site will be about 3 dB(A) lower than predicted for the operation and provided in Table 5-821 . Based on this, the noise impact for Kaklik and Yokusbasi caused by the construction works will be around or below 40 dB(A).

Operation of noisy equipment normally will be limited to the daytime. The baseline measurements show that the daytime noise levels at the receptor points are higher than the estimated construction noise.

19 BGVB3-Lärm, VDI 2058 Bl. 2 by Berufsgenossenschaft (German occupational Accident Prevention & Insurance Association): below 85 dB(A) no hearing damages are to be expected. 20 IFC EHS Guideline 2 on Occupational Health & Safety 21 Given the distance to the receptor points, the site can be taken as a point source in terms of sound propagation. Thus the location of noise sources makes not much difference.

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However, the potentially sporadic operation and unpleasant sound of some machines may cause nuisance for the neighbourhood in some cases. However, given the distance and the presence of other noise sources like public traffic, it can be expected that the noise impact is acceptable for the neighbourhood.

The overall duration of the civil works is envisaged to last for approx. 26 - 30 months. The activities will change over time and the noise sources will vary accordingly. Activities are inter alia: site levelling, road works, piling, concrete mixing, foundation and structural works, construction of switchyard, construction of the buildings, on site assembly of machines and structures.

5.4.5 Vibration

Construction of the new CCPP will ensure that rotating equipment is correctly balanced and that equipment is vibration isolated.

Vibration from plant operation will be imperceptible beyond the site boundary.

5.4.5.1 Vibration during Construction

Measurement of vibration from construction plants have shown that, even from heavy construction activity, i.e. percussive piling, vibration levels typically fall to imperceptibility beyond approximately 100 m from the vibration source. From other sources of vibration, such as excavators, bulldozers and heavy goods vehicles, imperceptibility levels are reached at much shorter distances. Furthermore, construction activities are expected only for a limited period of time and will be limited to the daytime.

5.5 IMPACTS ON LAND USE

Actual land use on site

The present agricultural land use of the site (dry farming) will be changed to industrial land use and lands were acquired through negotiated contracts from the owners.

The formal administrative land use assignment procedures were completed in September 2008 as described in section 3.3.3 and the local development plan 1:5.000 and implementation plan 1:1.000 were set up. The authorities (Denizli Province Soil Protection Board and finally Ministry of Agriculture) approved

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to use the project area for energy generation purposes. In November 2009, the implementation phase of the zoning plan was completed. Also in the actual regional plan the site is designated for energy generation by a gas-fired combined cycle power plant.

In summary, land acquisition and spatial planning designation for the site has been settled. The potential impact on the economic situation of the farmers is dealt with in section on social and socio-economic impact (section 5.16).

5.6 IMPACTS ON SOILS AND GEOLOGY

Soils at the power plant site comprise colluvial soils and brown forest soils. The surface topography of the site will be changed. The areas where the plant structure will be located will be sealed. The remaining areas of the site which will be used for construction activities will be inevitably compacted by the movement of machinery, storage etc.

The affected soil types are abundant in the region. Thus, the Project does not affect special, sensitive or protected soils or geological features or mineral deposits within and around the site.

Risk of ground contamination

Due to the land use as agricultural land, the area around the site can be considered as uncontaminated, since no obvious signs of pollution were observed.

The Project has some limited potential to cause contamination through spillages and leaks, especially around fuel storage areas during construction and chemical storage areas for operation.

Potential contaminating substances, which will be present on the site during construction and operation, will include fuels, lubricating oils, hydraulic fluids, water treatment chemicals, plant cleaning chemicals, sanitary effluent and detergents.

The risk of ground contamination will be minimized through a range of mitigation measures (see below). These are considered as appropriate to the construction and operation phases of the power plant.

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Risk of soil erosion

The soils in the steeper areas in the northern parts of the site already suffered from erosion. The soils in the lower site area are susceptible to soil erosion. Thus, soil movement and soil piling should be carried out carefully during construction in order to prevent soil erosion by wind or by precipitation.

5.6.2 Mitigation measures during construction

The potential for soil and subsurface pollution from construction will be minimized by proper construction site management. The EPC contractor will prepare a construction site management plan which includes aspects of proper handling and storage of materials and collection and disposal of solid and liquid wastes. This plan may comprise but will not be limited to the following measures (cf. section 6, Action C 2)

• Stripping of soils before construction (separation between top soil and sub soil). Reapplication of top soil for landscaping purposes and the green belt. • Provision of engineered site drainage systems during construction and operation to collect, balance, treat as required and control the discharge site run-off; • Protection of the soil from accidental pollution by installation of secondary containment at proposed storage areas for fuel and chemicals; • Provision of oil and suspended solid interceptors, such as oil/water separators for the removal of pollutant loading from the site drainage and for the retention and containment of any accidental discharges during construction; • Removal of waste materials unsuitable for re-use on site during construction to appropriate licensed sanitary landfill sites; • Management of excavations and drillings during construction of the piles so as to avoid the generation of drainage pathways to underlying aquifers; and • Provision of impermeable bases in operational areas to prevent absorption of any spillage of process materials. • Any spills during construction will need to be cleaned up by the EPC contractor. • Temporary stockpiles of soil (height should be less than 3 m.) should be protected from erosion by using a reduced slope angle where practical and by incorporating sediment traps in drainage ditches.

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5.6.3 Mitigation measures during operation

Potential impacts on soil and subsurface during operation will be minimized through implementation of the following mitigation measures:

• Secondary containment or sumps will be installed on-site to isolate areas of potential oil or other spillages, such as transformer bays, from the site drainage system; • Oil and chemical storage tanks will have a retention basin that will hold 100% of the content of the relevant storage tank; • Areas for unloading oil and hazardous chemical materials will be isolated by kerbs and provided with a sump, equipped with a manually operated valve; • Surface water runoff from equipment slabs that may be subject to oil contamination exposure will be collected and channelled through an oil/water separator prior to discharge into the discharge structure. • Any spills during operation needs to be cleaned up by the operator (RWE & Turcas).

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

5.7 IMPACTS ON GROUND AND SURFACE WATER

5.7.1 Potential Construction Impacts

5.7.1.1 Impacts on Surface and Groundwater

Construction activities could potentially result in the release of effluents to surface or groundwater and pollution of land with solid wastes. However, potential impacts on surface and groundwater during construction are likely to be limited when good site practice is applied by the contractors.

After assembly and welding, the HRSGs and pipe duct system requires thorough cleaning before test operation. This will be a source of polluted waste water which requires adequate treatment. The use of acid fluids, like fluoric acid or alkaline fluids is state of the art. Several flushes of the pipe and boiler systems are usually necessary to clean out welding residuals.

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The auxiliary boiler also needs a chemical cleaning.

The pipe system of the auxiliary cooling system and other facilities, like the fire fighting system etc. need a water flushing and a pressure test before commissioning. The washing water may contain suspended solids. It has to be discharged as waste water after the separation of the solids and testing by laboratory. These wastewater streams will be announced to the authorities and respective permits will be obtained.

5.7.1.2 Mitigation Measures during Construction

The contractor should implement following measures to protect surface and groundwater resources during construction (cf. section 6, Action C 2):

• Any flows of potentially contaminated washing waters e. g. from chemical cleaning will be stored temporarily in a dedicated basin and will be disposed off site only after suitable neutralization and treatment (incl. filtering of particles) by a licensed Contractor. The Contractor will apply suitable laboratory testing equipment to ensure that the Turkish standards will be met for the final discharge of any treated effluents. • Sanitary wastewater will be collected in a septic pit which serves as a settling tank (septic basin) for the solid ingredients. The solid – free water will be transferred in a collecting basin and transported by truck to a near by located wastewater treatment plant. Solid wastes will be disposed of by a licensed contractor. • Solid wastes will be collected and adequately treated and disposed outside the project area. • Inert materials and soils will be stored and used inside the site for levelling measures

Summarizing, no construction time impacts could be identified relating to water quality, provided above described construction management measures are properly applied by the construction contractor as means of prevention and mitigation.

5.7.2 Impacts of Groundwater Abstraction

For the planned power plant several water saving measures are included in the design (such as ACC cooling, condensate polishing plant etc.) resulting in an average water need of approx. 200-260 m³/d (approx. 2-3 l/s). It shall be mentioned that water demand will significant increase during start-up and

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maintenance (acid cleaning of the boiler, filling of water and steam cycles, auxiliary cooling system and auxiliary boiler), emergencies and special operation modes. The total water amount of approx. 1000 m³/d which is allowed to be abstracted from the wells according to the DSI permits (see below) will not be exceeded even during peak times of raw water demand. The exact water need will be determined during detail engineering phase when the water saving technologies will be developed in detail.

Two groundwater wells have been drilled and the Turkish Water Authority (DSI) has issued permits to utilize a total water amount of 11.5 litres/s (5 l/s from RWE well #1 and 6.5 l/s from RWE well #2) for the use in the power plant. Two additional stand-by wells will be drilled by the EPC contractor. Water will be provided to the site by a pipeline. A groundwater study has been prepared by the Istanbul University to evaluate the best location for the new groundwater wells.

The Kaklik Irrigation Cooperative is presently the main groundwater user in the area (see Section 3.22 and uses approximately 3 Mio m³ of groundwater per year. The estimated total amount of groundwater needed for the operation of the CCPP is approximately 70,000 to 100,000 m³ per year which amounts to less than 3% of the amount used for irrigation.

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

5.7.3 Mitigation Options

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

To verify the assumptions of the above mentioned groundwater study a groundwater monitoring should be carried out to observe the long-term development of the groundwater levels. This can be done in cooperation with

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already existing monitoring programs out by other parties such as DSI or the irrigation cooperatives.

In case negative effects on neighbouring groundwater users occur during operation of the power plant, the Developer will seek cooperation with the affected parties with the aim to develop appropriate mitigation measures. Such measures could comprise supporting the improvement of the irrigation system of the Kaklik Irrigation Cooperative to reduce the amount of water needed for irrigation.

5.7.4 Further Potential Operation Impacts

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

5.7.5 Impacts of Wastewater Discharge

Regeneration effluent which are expected to be discharged or to be transported to a nearby larger waste water treatment plant after optimization of the process are possibly expected in a range of 20 to 30 m³/day. As described in section 2 the Project includes several water treatment units and aims to re-use treated water for the operation to the maximum extent possible.

During detail engineering phase it will be determined whether the effluent of the wastewater treatment plant will be dischargeable to a nearby stream or will be transported to a nearby larger wastewater treatment plant for further treatment. In both cases, the effluents will be treated to the quality required by Turkish and international standards for discharge to receiving water body or if possible to irrigation water standards (see Table 5-9 and Table 5-10).

Sanitary wastewater will be collected in a septic pit and the solid – free water will be transferred to a collecting basin and discharged together with the effluents (see above).

Compliance with Standards

Drains from sumps of the well water treatment plant, chemical storage and handling facilities, floor drain at machine sets, boiler area, battery room, as

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well as stack drain and compressor wash waters will be collected in a wastewater storage and treatment tank. In this tank, the collected wastewater will be treated by dosing of precipitation agents, followed by sludge removal. After analytical check, the purified water will be discharged. The oil free water from the oil/water separators, the boiler blow-down and the neutralized wastewater from the demineralization plant will be collected and treated.

The major water treatment steps include:

• Oil separation of any wastewater that may be contaminated with oil or grease; • Flocculation and filtration of any wastewater that may contain high concentrations of suspended solids; • Neutralization of any wastewater that has a pH outside the range of 6 to 9.

As described in section 2 and above, the plant's wastewater streams, after respective adequate treatment will be collected and only be released for discharge into the creek or an irrigation channel after testing.

Particular attention is required regarding the discharge of salt from the water demineralization facility. This is also a crucial factor if it would be the case that the water will be re-used for irrigation purposes. The concentration in the effluent will be about 120 mg/l chloride (estimated from similar facilities). There is no standard for the discharge of chloride in the surface water but classification regarding irrigation water in Turkey. According to this classification chloride concentrations of up to 142 mg/l are considered as very good quality (cf. Table 5-10). A decision regarding the use of any treated wastewater or intermediate stream from the CCPP for irrigation purposes will be taken after the final design of the demi water plant and the wastewater treatment plant.

Effluent management measures will be implemented on site. The oil/water separators will operate continuously. Storm water run-off from potential contaminated areas will be routed to the oil separator.

Impacts on surface water quality during plant operation will be negligible as the main potential impact factor, i.e. a cooling water discharge with large quantities of heated effluent is not given due to the ACC technology.

The Project will comply with the ‘Turkish effluent standards for industrial discharge and should meet the limit values set out in the IFC Environmental Health and Safety Guideline 1.3 on Wastewater and Ambient Water Quality. A comparison of both standards (Turkish waste water limit values as set by

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WPCR, 2004 and the IFC EHS guideline for effluents) is provided in Table 5-9. As previously explained, the power plant will be equipped with the necessary water treatment facilities in order to keep wastewater quality within these regulatory requirements.

Table 5-9 Wastewater Quality Levels for Discharge into a Surface Water Body

Substance IFC EHS Turkish Standard Turkish Standard Standard* Composite Sample Composite Sample 2 h** 24 h**

Chemical Oxygen mg/l 125 60 30 Demand (COD)

Biological Oxygen mg/l 30 - - Demand (BOD)

Suspended Solids (SS) mg/l 50 150 100

Oil and Grease mg/l 10 20 10

Total Phosphorus mg/l 2 8 -

Total Cyanide (CN -) mg/l - - 0.5

pH pH 6 – 9 6 – 9 6 – 9

Total coliform bacteria MPNb / 400 - - 100 ml

Temperature - 35 °C

In Turkey the Water Pollution Control Regulation (WPCR, Official Gazette No. 20748 R.G.) from 7.1.1991 establishes classes for irrigation water quality which are given in the following table.

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Table 5-10 Turkish Irrigation Water Classes (optional use for wastewater)

Parameter Classes I II III IV V

The strictest limit values from Table 5-9 and Table 5-10 (at least Class III values) will be implemented in case the wastewater will be re-used for irrigation purposes. In the event of an interruption of the regular service of the wastewater treatment plant it should be verified that the wastewater will not be discharged untreated. The operation of the wastewater treatment plant and discharge of the wastewater will be continuously monitored (cf. section 6, Action O2).

5.8 IMPACTS ON FLORA , FAUNA AND HABITATS

As described in the baseline a significant part of the study areas (Site + 5 km) is used for dry agricultural activities and forest, other parts are covered by fallow land, maquis and steppe. The forest is formed as monoculture plantation and therefore shows hardly any plant variation; the same applies to the agriculture lands. About 75% of the study area comprises forest plantation and agricultural land, i.e. non-natural habitats. However, fallow lands, maquis and steppe areas do show some biological diversity (cf. section 3).

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5.8.1 Potential Impacts as a Result of the Power Plant Operation

It is not anticipated, that there will be adverse impacts to fauna and flora as a result of the power plant operation. The project site and its surrounding is already used for agricultural and industrial (quarry) purposes. It is expected that the plant operation will not significantly affect flora or fauna.

Noise will be mitigated to comply with noise standards for the neighbouring settlements. Wastewater streams and run-off will be treated before disposal as described above. No poisonous heavy metals, no dust which may hinder plant transpiration are emitted. Night time light emissions will be limited to the Site and immediate vicinity.

National and international ambient air quality standards (IFC, EU and Turkish Standards) are given in Section 5.2. Due to the operation of the CCPP none of

the air quality standards will be exceeded. NO 2 may have an impact on

sensitive plants. However, the expected loads for NO 2 will be clearly below

Turkish and international standards. No notable SO 2 which may react as an aggressive acid and may harm plant leaves will be emitted. No adverse impacts on the biological environment are therefore anticipated.

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

5.8.2 Impacts during Construction

5.8.2.1 Anticipated Construction Impacts

Site Formation

Due to the land requirement for CCPP structure, habitats within the project site will be lost. The power plant structure will be located in the southern and south-western area of the site which is presently agriculturally used. The areas in the north (west and east of the quarry) and east of the site will be used during construction time but will not be permanently covered with power plant structures. In these temporary used areas, fallow land, maquis and steppe area as well as agricultural land (officially converted to Energy Generation Area by Zoning Plan) is present.

Some plant species which are listed on IUCN Lists were found on the project area and its surroundings. An aromatic herb ( Phlomis carica ) is classified as

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“regional endemic”. This species is endemic to Denizli Region, but widespread and abundant in that region. Other IUCN listed species (8) are widespread and abundant in either whole Turkey or Aegean Region. In addition, their density in the direct project area is low. They were found on cultivated land, steppe and maquis area.

Except the two amphibian species (which were observed at the irrigation channel), all of the fauna species with a listed in either the Bern, IUCN or Turkish red lists were also observed in maquis and steppe area, some also on the cultivated fields. None of the observed species were observed breeding on site but were only present for bypassing or feeding purposes.

The amphibian species were observed around the irrigation channel. After decision of the relevant authority, the irrigation channel may be relocated.

Since the power plant will be located on former agricultural area only parts of the flora and fauna habitats will be permanently lost. The remaining areas on site (cultivated, fallow and maquis area) will be temporarily used. Since in the area similar habitats are present, it is very likely that fauna species will have sufficient feeding habitats in the immediate vicinity of the site. Thus, the listed fauna species are not expected to be significantly at risk.

Since in the vicinity of the area similar habitats are present, the impact on flora and fauna species is considered limited.

Mitigation measures

After end of construction works, the areas on site which are not covered by power plant structures shall be established as maquis and steppe area to provide suitable habitats for the listed species.

In addition, trees will be planted in the health protection zone around the site as a compensation of the lost areas.

If relocation is requested by the authority, the re-located irrigation channel will be established in a way that it suits as habitat for amphibian species.

Construction time impacts

Construction works which are likely to occur over a period of approximately 26 – 30 months for site formation and construction will generate increased noise, dust and movements of construction workers and equipment around

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the site. However, this will be to a limited extend as for the protection of the nearby settlements adequate mitigation measures will be taken.

Temporary affects by site formation works like dust and noise are not considered to be significant due to the fact that no breeding or nesting species was determined within the near vicinity of the site. Therefore the affects are limited to the loss of moving or feeding areas. No endemic fauna species was found in the project or study area.

5.8.2.2 Mitigation during Construction

International best practice 22 requires that biodiversity issues are recognized and mitigated by adequate measures. In particular a net loss should be avoided.

Possible construction related impacts will be avoided or mitigated by following measures:

• Although no breeding birds were found on the project site, five bird species were observed nesting and breeding in the study area. Out of these species Rock dove and Tree sparrow are protected according to Bern Convention and Hoope is strictly protected according to Bern as well as endangered according to Turkish red list. Since site formation activities are planned to be started in second quarter of 2010, if necessary, relevant mitigation measures will be taken to minimize potential negative impacts. • Good site management practices will be enforced to ensure that the construction site is kept clean and tidy. • All construction teams employed and contracts commissioned will incorporate these mitigation measures as a part of the operational procedures in contracts and briefs. • It is possible that either the drainage channel or an adjacent creek will be used for water discharge. The respective water course should be established in a way that it poses a suitable habitat for amphibians identified on site. The discharge points will be determined with the relevant authorities i.e. DSI, Irrigation Cooperative and Directorate of Environment and Forestry.

22 incl. IFC Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource Management

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• Noise will be controlled during construction and operation, and will dissipate rapidly with distance from source. Disturbance during construction and operation will therefore be localized; • Run-off from construction activities and any movement of contaminants will be attenuated and disposed of in a controlled manner (as described above) to ensure that surrounding species and their habitats are not significantly affected.

The impacts on the biological environment during construction are likely to be limited. It is not possible to avoid the loss of habitats in the area of the power plant due to sealing of areas. After evaluation these impacts on areas with low biological diversity are found to be limited.

5.9 VISUAL IMPACTS

The present landscape in the region is dominated by the mountains in the north and south, as well as man made installations such as the cement factory. The cement factory is located on the same altitude (between 550 and 600 m a.s.l.) compared to the other landscape elements such as the valley plain in the south and the mountains in the north.

The CCPP installation will be noticeable in the landscape. The stacks of the CCPP will be about 60 meters in height, and the ACC installation will reach a height of about 35 meters. However, it should be noted that the proposed ACC technology will avoid the adverse visual impact of traditional hyperbolic cooling towers and the generation of large visible plumes of uncondensed water vapor. Due to their dimensions the stacks and the ACC will be visible from a larger distance. However, it is not expected to dominate the landscape because of the high mountains in the background. Although the exact height of the cement factory structures are not known, it can be assumed that the CCPP installation will not be bigger than that factory.

In the near field the building structures will change the view shed for the neighboring agricultural sites, the national road to Denizli and partly also from the nearest villages Kaklik and Yokusbasi. From Alikurt, the CCPP will hardly be visible. From Asagidagdere, the CCPP will only be visible from the borders of the settlement or from the higher parts within the village (such as from the second floor/roofs) due to shielding effects of houses and trees.

Exterior lighting will be provided for operations and maintenance of the plant in accordance with established international standards for power-generating facilities and industrial lighting .Lighting will be provided for structures and

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equipment operating areas, as required to meet safety standards. The switchyard and gas receiving will be equipped with, high-pressure sodium floodlights installed on poles. Roadway lighting will be high-pressure sodium roadway lamps installed on poles with arms. Roadway lighting will be on at all times during the night and during other low-light conditions (e.g. weather events). Material loading and unloading and gate entrance locations will be illuminated from high-pressure, sodium roadway lamps, installed on high poles.

The exhaust stacks will be equipped with obstruction lighting for aircraft security, red marker lights will be placed on the stacks and will operate continuously during the night hours. The lights will be either steady or pulsing. The impression is similar to what can be seen on radio or television towers.

Each exterior light will produce some glow and reflections from the plant surfaces. This will be visible from some offsite locations.

Given the relatively open and undeveloped nature of the project site, some of the light or glow will be visible at some distance from the facility. However, the visual impact of these lights is not considered to disturb the neighbouring villages due to the distance.

5.9.1 Mitigation

The sensitive receptors in the area are the villagers in the vicinity of the plant. To soften the view of the power station from ground level and to improve the aesthetics of the site area, a green belt should be developed at the perimeter of the power plant. As a side effect it will assist to filter dust (also dust coming from outside to the site) and provide some noise attenuation effect.

The green belt composing local trees and bushes with a width of at least 15 meters should be planted along the boundaries of the project site, with exceptions where technical restrictions exist for the connection to the transmission line and the access road.

Visual impacts of the higher structures such as the stack will be mitigated by using greyish-brown façade colors which visually blend the installations with the prevailing background.

Night time light impact to the neighbouring settlements will be reduced by the design, arrangement and operation of the lighting installations. The EPC contractor will be required to design lighting installations aiming to keep

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exterior lighting to a minimum. Structure and equipment operating areas will be lighted by high pressure sodium lamps should be equipped with prismatic glass optics that produce a controlled light distribution in a downward direction where the light is needed.

5.10 ARCHAEOLOGY , HISTORICAL AND CULTURAL HERITAGE

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

The EPC Contractor will be required to report any potential finds to the competent administrative authority (Museum Directorate of Denizli, Provincial Directorate of Culture and Tourism) and follow the requirements of the authorities and arrange for recording and recovery of finds of significance.

5.11 SOLID WASTE MANAGEMENT

A natural gas fuelled power plant produces no ash and only a low quantity of other solid wastes during construction and operation which were described in Section 2.9.7.

The amounts of sludge residuals from raw water treatment and wastewater treatment will be limited.

Wastes generated at and by the plant will be disposed of from the site by licensed contractors. Final disposal of wastes will be to waste treatment plants or sanitary landfill sites (i.e. sanitary landfill in Denizli), as agreed by the relevant competent administrative authority.

To ensure that impacts from solid waste generation and disposal are successfully avoided, the following mitigation measures will be undertaken during plant construction and operation:

• All waste taken from the site will be carried out by a licensed waste contractor and the Operator will audit the disposal procedure; • Solid waste will be segregated into different waste types, collected and stored on site in designated storage facilities and areas prior to release to off-site recycling where possible and disposal facilities; • All relevant consignments of waste for disposal will be recorded, indicating their type, destination and other relevant information, prior to being taken off site; and

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• Standards for storage areas, management systems and disposal facilities will be agreed with the relevant parties. • Hazardous wastes will be stored separately and transported to a licensed facility for final disposal.

An environmental engineer will be responsible for solid waste management at the site and will ensure that all wastes are managed to minimize any environmental risks.

With the adoption of these mitigation measures, there will be no impacts of solid waste generated by the construction and operation of the power plant.

5.12 ELECTRIC AND MAGNETIC FIELDS (EMF)

Evaluation Standards

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

• 100 µT magnetic field • 5 KV /m electric field

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

EMF sources of the CCPP

Sources of EMF from the project basically are:

• Generators, • Transformers

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• Switchyard; and • Transmission line connection.

EMF Strength and Reach

In principal, the highest magnetic fields will occur inside the switchyard perimeter fence and under the power export transmission lines. Electrical fields from the switchyard will be blocked by the metal perimeter fence. EMF levels decay with increasing distance from the transmission lines and the transformers.

Inside the CCPP sources of EMF will be the generators and the transformers. To obtain optimum efficiency this equipment will be designed to keep the majority of the electro magnetic fields within its shell. In addition, the facilities will be designed to meet the applicable operational health and safety standards. Thus, EMF from generators and transformers are not considered relevant outside the CCPP.

The comparison with established planning guides suggests that the connected transmission lines and switchyards will be of no concerns provided that relevant distances to residential and publicly used areas will be kept (cf Table 5-11). The German Federal/Laender Immission Protection Committee (LAI, 2004) and the Distance Decree of NorthRhine-Westphalia (NRW) provide planning guidance in form of precaution EMF safeguard minimum distance for 50 Hz installations to areas with permanent general public exposure (e.g. residential) in relation to the voltage level (cf. Table 5-11).

Table 5-11 EMF Recommended Distance related to ICNRP limit values

Installation Type Voltage Recommended distance (meters) (AC 50 Hz) Level Overhead Transmission 380 kV 40* m From outside Lines (OHL) of conductors 220 kV 20* m 110 kV 10** m < 100 kV 5** m Underground Cables 1** m radius Substations / Switchyards 1** m from fence * Distance Decree NRW ** LAI 2004

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5.13 MAJOR ACCIDENT HAZARDS

5.13.1 Identification of Hazards

A major accident is defined as a physical situation with a potential for harm to individuals, infrastructure and buildings or for impairment and environmental damage. Major accident hazards of concern with respect to the construction and operation of the power plant are those with the potential for injury, impairment and/or damage external to the power plant perimeter.

An assessment of major accident hazards associated with the construction and operation of the power plant should consider the potential risk of the operation of the power plant to third parties, facilities, or populations.

The types of major disasters or emergencies that may occur in thermal power plants are:

• Fire; • Explosion; • Electrocutions; and • Spillages (oil, acid, chemicals).

In addition, hazards particular to gas fuelled facilities are basically:

• Loss of containment; • Internal gas explosion; and • Catastrophic failure of rotating machinery.

Given the measures incorporated into the design of the plant to minimize the risk from fire and explosion as described in section 2, major disasters are considered as unlikely and the plant is not anticipated to pose a potential risk of significance to third parties.

In addition, since natural gas will be delivered to the plant by pipeline, there will be no natural gas storage facilities on site. Furthermore, no hazardous chemicals will be held on site in quantities sufficient to pose a major hazard.

5.13.2 Operational Health and Safety

Risks were identified at different operation units of the power plant, and in particular with regard to the following areas of the plant:

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• Generator area; • Turbine area; • Electrical rooms; • Transformer area; • Cable tunnel; and • Storage facilities for chemicals.

As described in section 2, measures have been incorporated into the design of the plant to minimize the risk from fire, explosion, electrocution and spillages.

Employees will be trained on how to avoid accidents. Training programmes will be implemented for:

• Emergency response and fire fighting; • Rescue, first aid; and • Emerging assistance (cordon and reserve group).

Fire fighting is provided by:

• Automatically/manually operated CO 2 fire fighting system at the turbine units; and • Fire fighting water.

5.13.3 Emergency Response Plan (ERP)

The project operator will develop an Emergency Response Plan (ERP) which includes emergency response instructions for the operation of the power plant. The ERP will be part of the Operation Manual of the power station. The manual will be based upon established standard manual (cf section 6, Action O1).

The Emergency Response Plan will cover inter alia:

• Chemical spills and releases • Disasters like fire and explosions, • Natural hazards management (e.g. earthquake, storms), • Civil unrest

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5.14 NATURAL DISASTER RISKS

The CCPP installations will be designed to withstand natural disaster impacts according to the applicable design standards and criteria.

5.14.1 Seismic Risk

As described in Section 3.4, the Project is located in an active seismic region. All construction activities shall abide to the relevant laws and legislations, and the buildings and structures shall be constructed according to the building construction rules and legal regulations (Building Inspection Law, Building Inspection Regulation) for earthquake zones.

The new CCPP will be designed to withstand seismicity coefficient of A= 0.40 g. The plant design and construction must satisfy the relevant provisions of the “Regulation on the Buildings to be Constructed in Disaster Areas”. If necessary, separate ground studies and earthquake risk analysis for each building to be constructed shall be carried out. All studies shall be carried out in reference with the opinions of the General Directorate of Disaster Works and other authorized institutions.

5.14.2 Flooding Risk

According to the competent agency DSI, flooding of the site did not take place in the past and is unlikely to occur in the future. The 50 year and 100 year floods are estimated by DSI to approximately 2 and 3 m³/s. Appropriate measures such as surface drainage are intended to be incorporated in the design.

5.15 INTERFERENCE WITH OTHER FACILITIES OR ACTIVITIES

5.15.1 Industries

The CCPP plant is located in a mixed agricultural (former) and industrially used area. The existing cement factory and marble quarries are a source of dust emission. The air intake of the CCPP will be equipped with appropriate filters to prevent the intake of dust.

Directly bordering to the west, an organized industrial area for leather industry is planned. It is assumed that the planned facilities will not have any

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interference with the power plant regarding air emission, noise or other emissions.

5.15.2 Air Traffic

The CCPP site is located about 20 km to the west of Denizli airport (which is situated near Cardak, approx. 50 km east of Denizli). The site is not in a direct approach route for civil aviation. The exhaust stacks of the new CCPP will be equipped with obstruction lighting as per international practice23 and the specific requirements of the Aviation Authority. The red marker lights on the stacks will continuously operate during night time.

5.15.3 Local communication and pathways

No local communication routes or pathways are located on the site of the planned CCPP. The existing earth road connecting the site with the national road will be asphalted which is also in benefit to other users of the road (marble industry, farmers). The enhancement of the road lies within the responsibility of the Kaklik Municipality. The Kaklik Implementation Plan 1:1000 foresees the enlargement of the existing road to a width of 20 m. According to the municipality of Kaklik the land needed for an enlargement of up to 10 m already today is owned by the municipality and it is used as agricultural land by local farmers. Since RWE & Turcas do not ask for an enlargement of more than the said 10 m the municipality of Kaklik does not need to buy further land with respect to the CCPP project. Since only small strips of land will be needed from the existing agricultural fields it is considered unlikely that the land requirements for the road enhancement may have any negative (economic) effect on the owners or agricultural land users.

The increased traffic during construction time may pose a safety risk on the conjunction of the site connection road with national road D595. The EPC contractor will implement appropriate measures to mitigate safety risks from traffic related to the construction site. (cf. Section 6, Action C3).

23 e.g. as specified in the FAA Advisory Circular guide AC 70/7460-1J, Obstruction Marking and Lighting

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5.16 SOCIAL AND SOCIO -ECONOMIC IMPACTS

5.16.1 Introduction

This analysis of social, health and economic impacts is based on social survey results detailed in section 3 and available secondary information. It considers permanent and temporary impacts owing to:

• Loss of land and natural resources; • Pressure on social networks and social infrastructure; • Increased health risks; • Economic changes;

• Potential impacts of in-migration 24

A series of possible mitigation measures are set out at the close of the chapter.

5.16.2 Loss of Land and Natural Resources

The designated project area is 26.7 hectares, amongst which 18.9 hectares is dry agricultural land and 7.8 hectares is rocky land and former riverbed.

5.16.2.1 Loss of Land

As mentioned above 18.9 hectares of the project area consists of dry agricultural lands. Yet, 3.4 hectares of this land is no longer farmed, as the land is not irrigated –thus not lucrative- and most of the lands have been divided into unprofitably small pieces due to inheritance. As there are no irrigation facilities, wheat and barley are the only crops farmed in the project area.

The cadastral works of the project area was already completed and the ownership status of the lands was registered by the Land Office. No customary ownerships were identified related to the site. Most of the owners had a title-deed, whereas some needed to complete hereditary transition. The hereditary transitions were made according to the Turkish Civil Code, which ensured equal shares amongst male and female siblings.

24 The terms in-migration and out- migration refer to migration within a country whereas immigration and emigration refer to migration from one country to another.

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The purchases of all private lands were made through negotiations. Firstly a land unit price was determined for the area through a meeting attended by the Kaklik Mayor, Yokusbasi village headman and available land owners. In addition, a real estate appraisal report was prepared to determine the market value of the land.

Negotiations were made separately for each parcel. When the shareholders were offered the options for cash or a replacement land, cash was the sole choice of all. At present stage, all private parcels were purchased by successful negotiations.

According to the statements of Kaklik Mayor, Yokusbasi village headman and land owners, the acquisition price was sufficient to replace the land with a similar size and similar/better quality land. The average price which was finally paid to the land owners is higher than the price determined in the real estate report and much higher than the price which was determined by the local officials. In addition, it is very likely that interested land owners could buy replacement land in the area as there are land plots available for sale in the area of Kaklik since many elderly people give up agriculture and the younger people prefer other jobs than farming. Sample interviews with owners during the field studies conveyed that land acquisition did not cause grievances. 25

As the land owners are compensated at least replacement cost through negotiations and are able to buy a similar/better quality lands in the region, this impact is considered to be minor.

5.16.2.2 Pressure on water resources

Interviews carried out as part of the social study found that drop of water table is one of the main concerns about the proposed project. In the case the project becomes a competitive user and causes a drop in the water table (cf. Section 5.7.2), this impact was regarded as significant and permanent by the

25 The project team was able to reach four land owners during the surveys. These land owners confirmed that the price was sufficient to buy a land of similar and/or better quality and size. None of the land owners had any grievances about the negotiation and purchasing process. Three of the land owners stated they were earning an insignificant part of their income from the land whereas one did not earn any income. As they did not earn much from the lands, none of the land owners intended to restore the income they would loose. When they were asked about how they would use the compensation money, one reported he would do a wedding ceremony for his daughter and one stated she would give it to her children. The other two had not decided how to use the compensation money yet.

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people, as the plant will continue using water during the operation. However, the hydrogeological study revealed that sufficient groundwater is available and in case of local effect on nearby wells appropriate mitigation measures will be agreed between the Developer and the affected parties.

5.16.2.3 Pressure on forest resources

As there are forests around the settlements and Yokusbasi is considered a Forest Village. Poorer migrants might be tempted to cut fuelwood during the winter which is regulated. Yet, as the controls are quite efficient in the region, the significance of this impact is expected to remain moderate.

5.16.3 Pressure on Social Networks and Infrastructure

Impacts on social support networks and infrastructure are predicted as follows.

5.16.3.1 Disruption to social networks

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

During the surveys no major social discordance was reported by former residents or by in-migrants. A majority of the migrant families said it was very easy to settle to the area, whereas only 11% of the in-migrants stated that they had some difficulty in social integration.

When the people were asked whether they would get on well with potential newcomers due to the project, 85% stated they would not have any problems whereas 15% denoted a number of conditions as shown in Figure 5-4.

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Figure 5-4 People’s perceptions about whether they would get on with the newcomers

Depends on how I would get on people behave well with potential 6% newcomers 85%

There might be cultural problems 5%

If the newcomers take away our job Security might be opportunities, an issue when new social problems people come may arise 3% 1%

Although people appear to be generally open to different cultures and are at ease with in-migration, the relatively sudden influx of possibly up to 700 - 800 (mostly) male workers (and possibly several hundred opportunist migrants) with different backgrounds may affect the social structure and networks. It is presently not known whether Turkish or mainly third country nationals (TCN) will be employed during construction.

Due to the conservative local culture, prostitution is less likely to increase; yet, increases in crime (particularly thefts) should be anticipated which may cause social tension between the locals and outsiders. In case of TCN further tension might occur due to language problems and different cultural background.

This impact is judged to be of major significance, but temporary, as the number of employees will decrease significantly after the construction.

5.16.3.2 Pressure on social infrastructure from an influx of migrants and workers

Establishment of shanty settlements

Presently, the number of illegal buildings is very low in the project area. Yet, in case a significant sudden in-migration occurs, it is likely that this number would increase. Depending on their size and location, shanty towns may challenge urban plans and may pose communal health and safety problems. In case mitigation measures are not taken, the significance of this impact is likely to be major.

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Pressure on Education facilities

This study found that the high population growth rate already poses a pressure on education facilities in the area i.e. the Kaklik primary school presently offers half-time education in two shifts as there are not enough classrooms. The project, in particular job opportunities during construction, is likely to cause in-migration. In the unlikely case a high number of workers bring along their families and children, this could worsen the pressure on education facilities. But, by adoption of a local employment strategy and transportation of the workers in the vicinity of the area to the project site the number of the in-migrant will be limited and thus also the number of their children attending the school will be limited. In addition to that most of the construction workers will be present onsite only for a few months so that the motivation to bring their families will be low. As the number of employees will decrease to 60 in the operation phase, this impact - if at all - is expected to be temporary and will be addressed in a constructive manner between the RWE & Turcas and the Municipality of Kaklik if it occurs.

Pressure on Health facilities

Most people surveyed in the area felt that the health facilities were sufficient in the area for the existing population. All villages are visited by a doctor regularly once/twice every week for outpatient treatments. For severer illnesses people go to the hospitals in Denizli or Honaz. Yet, if health care facilities are not provided for the workforce, the arrival of considerable number of workers and camp followers may have a major impact on access to health care in the project area. Assuming the project will establish its own facilities for the workforce, no significant pressure on health services is expected. Thus, the impact is judged to be minor. This impact will last for the duration of the construction phase and thus will be temporary until the construction workers and camp followers leave.

5.16.4 Increased Health Risks

Impacts on health arising are predicted as follows.

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5.16.4.1 Permanent Health Impacts Arising from In-migration

Introduction of communicable diseases due to in-migration

The extent of disease transmission between the communities and in-migrants will depend on the level of interaction between the two, the workforce size and health status of the workforce and casual migrants, and their susceptibility to disease infection. In addition the living conditions, access to healthcare and workforce management will determine the significance of disease transmissions.

The impact due to Acute Respiratory Infections is expected to be minor , as the symptoms are easily treated, assuming diagnosis early on and access to healthcare is sufficient. The significance of the impact of acute communicable diseases such as HIV/AIDS or Tuberculosis – which require immediate or complex treatment, are life threatening and/or are irreversible, is considered major. Nevertheless, as the incidence rates of communicable diseases are either very low or zero at the project area, and considering the general conservative nature of the society and intolerance towards pre-marital sex, the probability of an increase in such acute communicable diseases is found to be low.

Poor housing and sanitation in shanty settlements leading to an increase in disease

The migrants who construct/settle in unlawful buildings (or possibly tents) are likely to suffer from communicable diseases as such buildings are not provided with water, electricity or sewage facilities. Hygiene related health problems (i.e. skin and eye infections), respiratory infections and Tuberculosis may increase in prevalence. Although the likelihood of unlawful settlement into the area is not high, and the existing health facilities is generally capable of coping with immediate situations, the significance of this impact is judged to be moderate , since the poorest/unemployed who are not covered with any health insurance may not have access to healthcare facilities.

Solid Waste and Wastewater related health issues

As explained in Section 3.15.7 the solid waste and waste water management systems are not sufficient in the area. An increase in the amount of solid wastes and wastewaters due to in-migration might cause odor-related disturbances, as well as vector-borne diseases. Although the incidence of malaria is very low in the region, it is not completely eradicated.

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Inappropriate practices during construction (i.e. unmanaged pits, ditches) may introduce malaria into the area, as a consequence of the increased number of breeding sites for the mosquitoes (intermediate host). In the unlikely case considerable in-migration occurs this effect could be major if not properly managed

5.16.4.2 Temporary Health Impacts during Construction

During construction, works will include excavating and concreting, and there will be increased levels of traffic in the area. As a consequence, it is likely that respiratory infections, hearing impairment, work-related accidents, and traffic accidents may increase in incidence; this impact is judged to be moderate but will be mitigated by a proper construction and operation H&S Management.

Increased respiratory health incidence

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

Increased incidence of accidents

As the project site is quite far from settlements, the likelihood of a third party accident occurring (for example a young child falling into an excavation area) is low. The significance of the impact is likely to be minor .

Increase in traffic accidents

Construction traffic movements (of materials and workforce), in addition to general project traffic vehicles, may result in an increase in traffic levels on the local roads. Kaklik, Yokusbasi and Alikurt are more prone to risks of increased traffic as there are highways passing through these settlements.

Although the connection roads between settlement and Denizli are all asphalt, road safety features (e.g. traffic lights, pedestrian crossings, lane lines) are not given much importance. The people are quite used to high rates of traffic; yet, there is still a limited understanding of road safety amongst drivers and

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pedestrians. Thereby, traffic accidents and number of killed or seriously injured cases might increase in the project area. In case mitigation measures are not taken, the significance of the impact is likely to be major, but this may reduce depending on the safety measures and availability of emergency health care to deal with the increased number of incidents.

5.16.5 Economic Impacts

5.16.5.1 Local price inflation

As the project area is very close to Denizli, which is the main determinant of local prices, no significant impact is expected on the prices of basic goods. However, in case a significant in-migration occurs, this may cause an increase in house rents which would mainly affect poorer renters. Considering a vast majority of people (87%) are living either in their own houses or in their relatives’ houses, this impact is judged to be moderate. This will be temporary until the construction workers leave after the construction phase ceases.

5.16.5.2 Changes to local livelihoods due to increased economic opportunities

Most of the people surveyed are hoping that the in-migration of several hundred workers into the area will provide a stimulus to the local economy. The in-migration will provide a larger market for local shops and farmers and others to whom to sell their goods.

As most of the economically active population is already workers, no great difference is expected between the purchasing power of construction workers and local residents. Many unemployed people and those who are not earning well enough are likely to seek work on the project. Some may turn to trading or even the supply of materials to the construction site ( e.g. food, water) if this becomes more profitable. This impact is judged to be major and positive if it is managed and monitored, and it will last for the duration of the construction phase.

5.16.5.3 Depression of local economy and out migration of workers and local population

Construction-related work opportunities will last only 2-3 years, after which the workers will need to be laid off as the plant moves into an operational phase. The reduction in the workforce will result in the out migration of workers as they leave to seek job opportunities elsewhere.

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This may normally result in the depression of the local economy as the market for local goods and services declines. However, as there are a few development projects in the pipeline (i.e. Logistic Railway Center in Kaklik, Leather factory in the Leather Industrial Zone close to Kaklik), those are likely to minimize this impact. Thereby the significance of this impact is judged to be moderate.

5.16.6 Mitigation Measures

In this concluding section, mitigation measures are identified to address the social, health and economic impacts that have been discussed in the preceding sections.

5.16.6.1 Mitigation Measures at the Detailed Design/Preparatory stage

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

• Confirm if construction workers camp will be there or local accommodation will be organized. Locate traffic routes in order to minimize impacts on neighbouring communities; • Confirm the route for transmission lines and necessary permanent and temporary land take; and • Confirm the need for a transformer station (related to the new transmission lines), its possible location and necessary land take.

5.16.6.2 Mitigation Measures: Construction Phase

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

• Construction Management Plan; • Employment and Workforce Policies; • Community Support Measures;

Construction Management Plan

The contractor will be required to adhere to a detailed Construction Management Plan. Measures to be incorporated into this plan in order to reduce or avoid social, health and economic impacts are:

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• Inform local communities of major activities in advance; • Ensure all dangerous construction sites are fenced off; • Strictly enforce and monitor road safety standards (cf. Section 6, Action C3); • Identify water sources for construction that will not deplete local water supplies and ensure that construction minimizes its use of water; • Follow best practice to prevent the creation of stagnant water or other breeding areas for mosquitoes; • Spray construction areas and roads regularly with water to suppress dust emissions; • Monitor dust emissions and noise levels in settlements adjacent to construction activities; and • Improve quality of roads being used by the project.

Employment and Workforce Policies

The EPC contractor shall be required to adhere to a policies and codes of conduct concerning employment and workforce behaviour. Measures to be incorporated into these policies in order to reduce or avoid social, health and economic impacts are:

• Screen the health of possible employees ( e.g. for Tuberculosis, COPD, flu) as part of the recruitment process; • Ensure that the workers camp and construction areas are open only to formal employees; • Develop and enforce a strict code of conduct for workers to regulate behaviour in the local communities including road safety • Provide awareness training to the workforce, in particular regarding the transmission of STDs and other prevailing diseases in the region (e.g. Tuberculosis, brucellosis) • Provide training for traffic safety awareness to the workforce; • Build adequate facilities for workers and their families (housing, water facilities, etc ); • Provide the workforce with access to primary healthcare on site, providing prescriptions, condoms, basic testing for Tuberculosis etc . The healthcare facilities should provide their own medicines and equipment, in order to prevent the depletion of local healthcare facilities; and

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• Conduct regular fitness and medical tests on the workforce.

Community Support Measures

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

• Ensure that the responsible organizations (i.e. Kaklik municipality, Honaz district governorship) have a good understanding of the potential social and environmental impacts in order to be able to cope with them; • As the Kaklik municipality is in charge of enforcing zoning rules and construction licenses, it is particularly important to inform the municipality regarding the potential risk of increase illegal buildings and establishment of shanty settlements; • A local employment and sourcing policy to discourage in-migration, entailing a ban on the employment of casual migrants at the project site; • Inform local communities of employment and procurement opportunities and provide avenues applications of village locals;´ • Develop and implement a social impact monitoring plan to assess the efficiency of mitigation plans regularly in order to improve the measures/implementations • Frequent and rapid assessments (i.e. every 3-4 months) to appraise the efficiency of the plan with a view to identify improvement opportunities. • Regular meetings with representatives from the communities in the vicinity of the project to receive their impressions on local impacts of the project during construction and (to a lesser extend) during operation. • Development of appropriate mitigation measures together with the communities for social and health related problems occurring during construction and operation of the CCPP. • Grievance redressing mechanism and records used for continuous assessment during the operation phase.

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5.16.6.3 Mitigation Measures: Operation

Most of the in-migration related impacts are likely to seize after the construction phase. Yet the consultation/communication with stakeholders should continue through grievance redressing mechanism (briefed in Section 7) and social impact monitoring works. The project related concerns/issues should be learnt timely with a view to avoid/mitigate them.

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Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

6 – Environmental and Social Management Plan (ESMP)

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CONTENTS of Section 6

6 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) 6-1

6.1 GENERAL 6-1 6.1.1 Construction 6-1 6.1.2 Operation 6-3

LIST OF TABLES

Table 6-1 Environmental and Social Management Plan (ESMP) 6-5

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6 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

6.1 GENERAL

This section summarises the organizational requirements and monitoring plans required to ensure that the necessary measures are taken to avoid potentially adverse effects of the Project on environmental and social (ES) as well as health and safety (HS) aspects. These specific steps are outlined in an Environmental and Social Management Plan (ESMP). Some of these measures have already been specified by RWE & Turcas at the present state of project planning. Since an ESMP continues to evolve in scope and depth with subsequent stages of the project preparation and implementation (e.g. construction, operation, decommissioning), the ESMP contained in this ESIA provides a first outline.

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

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

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

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

6.1.1 Construction

RWE & Turcas will nominate a responsible person (Supervisor) for supervision of the environmentally and socially relevant activities of the EPC contractor.

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The Supervisor will be responsible to carry out inspections during construction and to supervise the EPC contractor's activities to ensure that the ES&HS requirements are met during construction (e.g. based on the EPC contractor's ES&HS plans). Observations will be reported regularly to the RWE & Turcas and EPC contractor management team where corrective measures will be discussed, if necessary.

In addition, RWE & Turcas will perform inspections on environmental approval of installations and supervise measurements to verify whether the environmentally relevant specifications given to the manufacturers are met (e.g. air pollutant emissions, noise emissions, dry process efficiency, energy efficiency).

The EPC contractor will be obliged to provide all necessary skilled and trained ES&HS staff to ensure that all activities are carried out in accordance with the EHS regulations, and guidelines of Turkey and the project owners RWE and Turcas. Potential risks at work places have to be assessed, like chemicals, mechanical and electrical risks, working at heights, confined space, hot work. A monthly report shall be delivered by the EPC contractor which includes detailed information on safety issues, incidents/accidents, need for corrective measures, conflicts amongst construction workforce or with local residents, grievances of workforce or stakeholders. Sub-contractor related issues shall be included.

An emergency response plan shall be elaborated, including the location and proper use of emergency equipment, procedures of alarm raising and emergency response team notifying, and proper response actions for each foreseeable emergency situation (incl. earthquakes). Accident reporting shall be a standard procedure. Workers, including subcontracted workers, shall have access to free medical service, healthcare treatment and preventative treatment.

The EPC contractor will have to demonstrate the appropriate skills, qualification and/or working experience of his staff and subcontractors to the Supervisor. Construction workforce and sub-contractors will receive comprehensive H&S training at the beginning of an appointment, thereafter on a regular basis throughout the entire construction period. Special safety instructions will be provided for temporary workforce and for young workforce.

RWE & Turcas's appointed personnel for operation of the CCPP will appropriately be trained by the EPC contractor. The entire project’s operational and management personnel will receive on-the-job training.

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The ESMP outline for the construction activities is given in Table 6-1 below.

Standards and guidelines relevant for the detailing of the ESMP action items include, but are not limited to:

• IFC Performance Standards on Social and Environmental Sustainability, 2007, particularly Performance Standard 2 • ILO Best Practice Guide “Safety and Health in Construction” ILO-OSH (2001) • Recommendation Concerning the List of Occupational Diseases and the Recording and Notification of Occupational Accidents and Diseases (ILO Recommendation 194) • Labour Law of the Turkish Republic (Law No. 4875, 22 May 2003 and related ordinances), • Decree on Health and Safety of workers and the safety or the workplace (Decree No. 717583, dated 4th December, 1973), • Relevant legislation in Turkey, • RWE Code of Conduct, including the Global Compact principles regarding Human Rights, Labour Standards, Environment and Anti- Corruption,

• RWE Environmental Management Guideline,

• Turcas’ Health, Safety and Environment (HSE) Policy enacted in 2001.

6.1.2 Operation

RWE & Turcas is responsible for the operation and maintenance of its installations. Operation will be in an environmentally sound manner, in particular to ensure compliance with any environmental provisions set out by the competent licensing authority.

An ES&HS team will be set-up in the new CCPP who will handle environmental & social and health & safety issues during operation of the plant. An environmental & social management system will be installed.

The ES&HS team will ensure that all legal requirements for RWE & Turcas are met and all necessary environmental protection measures are taken to avoid potentially adverse effects of plant operation on the environment. The head of the ES&HS team will ensure that the operation of the plant complies with high

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An E&S Supervisor will also deal with all issues related to local community and public.

The ESMP outline for the operation is also given within Table 6-1 below.

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Table 6-1 Environmental and Social Management Plan (ESMP)

General Notes:

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

All activities related to construction and operation will be subject to official Turkish environmental and social inspection within the mandate of the relevant authorities.

Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

D1 Noise emissions of Selection of equipment, sound absorbing equipment, Selection, arrangement and Observe international noise standards regarding power plant and noise barriers so that sound pressure levels of design of necessary equipment by ambient noise levels and occupational health & 40 dB(A) at Yokusbasi and 43 dB(A) at Kaklik are EPC Contractor. safety. met. Thus, the IFC criterion that the incremental Implementation of design by EPC Compliance confirmed by off site noise noise from a plant shall not increase the baseline by Contractor throughout measurements in testing and acceptance stage more than 3 dB(A) will be met for Kaklik and construction Yokusbasi.

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

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

D2 Groundwater Design of the CCPP with suggested water saving RWE & Turcas, EPC Contractor Sustainable groundwater use abstraction technologies (ACC, condensate polishing plant etc) to To verify the assumptions of the groundwater reduce the water needs of the power plant. study prepared during concept stage a In case negative effects on neighbouring groundwater monitoring should be carried out groundwater users occur during operation of the to observe the long-term development of the power plant, the Developer will seek cooperation groundwater levels. This can be done in with the affected parties with the aim to develop cooperation with already existing monitoring appropriate mitigation measures. Such measures programs carried out by other parties such as could comprise supporting the improvement of the DSI or the irrigation cooperatives. irrigation system of the Kaklik Irrigation Cooperative Provision of sufficient amount of groundwater to reduce the amount of water needed for irrigation. for CCPP and neighbouring users.

D3 Routing of Transmission line routing study shall consider Routing and implementation of Routing and implementation of transmission line Transmission Line environmental constraints; the impacts of the transmission line by TEIAS by TEIAS according to Turkish regulations for grid connection transmission lines for grid connection shall be Accompanying land acquisition Support of TEIAS if needed related to assessed taking into account the requirements of plan and EIA and ESIA by TEIAS implementation of international standards international standards(biodiversity/avifauna, Right of Way (RoW), property issues/resettlement, EMF The project developer will etc. to be adequately addressed) emphasize the need to address potential impacts according to international standards in negotiations with TEIAS and support TEIAS if needed with the implementation

D4 Life and Fire Safety Design and construction of power plant to observe Overall responsibility by RWE & Required permits and approved plans in place relevant legislation and international techniques to Turcas such as. “Regulation on the Buildings to be

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

Seismic Risk withstand seismic risk Design and construction by EPC Constructed in Disaster Areas”.

Design and construction of CCPP to observe with Compliance check by Owner of detailed design Turkish and RWE (German/European) Standards on by EPC Life and Fire Safety. Regular inspection of construction site to check construction process for compliance with the requirements for buildings in seismic risk regions.

Regular inspection of construction site to verify implementation of applied measures

D5 Groundwater As conservation of evidence analyze groundwater RWE & Turcas, EPC Contractor Groundwater sampling results documented Quality from the CCPP wells during detailed design stage for anthropogenic substances such as oil and grease.

C1 Environmental & Construction Supervision Plan Set up by RWE & Turcas before RWE & Turcas Supervisory team in place Social Performance construction; including ES&HS and CSR responsible Appointment of RWE & Turcas supervisor team; of construction Implementation RWE & Turcas Monthly reporting of environmental, health & activities Regular site inspections and meetings of RWE & throughout construction safety and social performance issues incl. Turcas with EPC; workers and community issues and follow up of Regular review of reports of EPC and supervision of deficiencies implementation of EPC Contractor’s Management Plans.

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

C2 Environmental, Construction Site Management Plan including sub-plans: Setup by EPC prior to EPC’s Site Manager and EHS-Responsibles in Performance of construction; implementation by place; Spill Prevention and Contingency Plan; construction EPC throughout construction Construction site management plan and activities / Good Materials Handling and Storage Instructions under supervision of RWE & subplans incl. work instructions for Practice Turcas. Hazardous Material Handling Plan acc. to RWE environmental aspects in place and (German/European) and Turkish standards, Material implementation monitored; internal auditing and Safety Data Sheets (MSDS) reporting by EPC Construction Waste Management Plan;

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

Construction Site Closure Plan;

Construction Traffic Management Plan (on site and off site)

Designated EPC’s Site Manager and EHS-Responsibles

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

C3 Construction Construction Health and Safety Plan, inter alia Setup by EPC before construction; Work Place Risk assessment undertaken before Health and Safety including provisions for: start of operations; Implementation by EPC workplace risk-assessments, permit to work, personal throughout construction under Health ad Safety Plans and plan for emergency protective equipment (PPE) supervision of RWE & Turcas. preparedness in place and implemented;

construction workers training and awareness (in coordination with relevant HSE Instructions and PPE available agencies: fire brigade; hospital ground disturbances, lifting operations, working at Performance according to RWE & Turcas and relevant district agencies; HS heights and confined spaces Standards for all operations. checks by Turkish Social Security working under ongoing plant operation / stack Agency) emissions Safety measures in place construction traffic safety on- and off-site (transport Implementation by EPC before Recording of violations and corrective measures traffic routing, safety measures for junction of site start of works under supervision connection road with national road, instruction of Number of accidents (target = 0) of RWE & Turcas. workforce and drivers) Number of grievances (target = 0)

Emergency Response Plan for accidents response

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

C4 Construction Social Facilities and Services Plan; Implementation by EPC under Social services and needs assessment undertaken workers welfare Provision of sanitation, social and medical facilities supervision of RWE & Turcas. (in by EPC/RWE & Turcas staff before start of /workforce social and services; workers accommodation (in –migrants addition: official supervision by operations; including special requirements for issues / disputes or third country nationals - TCN) and transport (TCN Turkish Work Inspection) third country nationals (TCN) (socio-cultural and local workers); aspects) Social facilities and services plan set up and Provision of facilities and opportunities for workers’ recreation and social after work activities; implemented (EPC)

Provision of sufficient infrastructure (e.g. health Facilities and services in place at commencement facilities) of construction In case pressure on educational facilities will occur Documentation of audits, grievances and (should a large numbers of workers bring their remedial action where necessary

families – which is not expected) this will be Regular reporting (medical reports and social addressed in a constructive manner between the reports) (EPC) RWE & Turcas and the Municipality of Kaklik. Regular social supervision (RWE & Turcas) Social supervision audits incl. workers interviews; Individual Information of workers at start of Workers Grievance Mechanism; employment performed (EPC) In line with RWE Standards, application of ILO Core TCN’s informed in TCN language (EPC) Labour Standards by EPC and subcontractors Continuous availability of bilingual (English or Workplace Regulation German) staff Workers Code of Conduct Sufficient number and equipment of medical and sanitation facilities according international Workers information/training (under consideration standards (EPC) of specific socio-cultural aspects of TCN, local Turkish workforce) Work site regulation, workers code of conduct and grievance mechanism set up and

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

implemented

Documents in place and communicated

Number of conflict incidents (target = 0) Number of grievances (target =0)

C5 Community Community Liaison Plan inter alia including: Setup by EPC in coordination Community Liaison and Public Health & Safety relations / with RWE & Turcas at start of Plan Set up and implemented Appointment of EPC Community Liaison Officer Construction works; participation of local (EPC-CLO) and E&S supervisor (RWE & Turcas); Regular report by RWE & Turcas community related community community administration and establishment of local community liaison committees liaison supervisor including improvements and grievances / representatives if applicable remedial actions agreed with EPC E&S Public Health and Public Information and Awareness campaign; Supervisor if required Safety issues / measures for maintaining good relationship; Local employment Regular feedback meetings with local and procurement Public grievance mechanism incl. conflict resolution community representatives. KPIs: Liaison

procedure officers in place. Worker’s code of conduct set up

and in place. Information and awareness raising Addressing public road safety (construction campaign performed before start of construction. transport and traffic); vibration, noise and dust; Follow up and solution of grievances and health risks related to presence of large number of issuesraised during meetings, documentation. construction workforce (e.g. sexually transmittable diseases (STD), and public safety issues (such as: Information events for local communities and potential risk of social unrest because of presence of contractors (if applicable) performed (number of

TCN) participants)

Dust abatement during construction, e.g. spraying of Number of grievances (target = 0) soil with water Number of social unrest incidents in context of

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

A framework for the recruitment of local workforce construction (target = 0) and local procurement to be performed wherever Number of incidents of transmitted diseases in possible. Information about work and business context of construction, (target = 0) opportunities will be made available to the local population (under consideration of RWE & Turcas Job posting and information in local contractors policy) communities and transparent recruitment procedure in place

C6 Construction site Site Access and Security Plan; Setup and implementation by Completion of implementation before start of access and site installation of a system for safe site access; training of EPC + RWE & Turcas before start construction security guards/security staff of works Installation of an appropriate site access system

C7 Archaeological Chance Finds Procedure, Setup: by RWE & Turcas before Implementation of procedure before start of finds during Awareness training of workforce construction works construction ground works Implementation by EPC under Chance finds report by EPC supervision of RWE & Turcas. Documentation of involvement of authorities

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

C8 Impact on habitats Set-up of ecological management plan for construction Set-up of ecological management Monitor flora and fauna species 3 years after end and end of construction, incl. at least following plan by RWE & Turcas. of construction and determine additional issues: Implementation by EPC measures if necessary. Avoid disturbance of birds during nesting period by Contractor. taking appropriate measures before start of construction if necessary. Establishment of maquis and steppe habitats areas after finish of construction Planting trees around the site.

O1 Environmental, • Operation Management Plan including sub-plans: Setup by and implementation by RWE & Turcas’s Operations Manager and EHS- Performance of - Spill Prevention and Contingency Plan; RWE & Turcas. Responsibles in place; operation/ Good - Materials Handling and Storage Instructions Operation site management plan and subplans Practice incl. work instructions for environmental aspects - Hazardous Material Handling Plan (incl. international labelling system, MSDS) in place and implementation monitored; internal auditing and reporting by RWE & Turcas - Wastewater Monitoring Plan as described below - Emergency Response Plan (for types of emergencies such as accidents, spills, fire, earthquake et al.) Designated RWE&Turcas Operations Manager and ES&HS-Responsibles

O2 Discharge of Waste Water Monitoring Plan (implemented in operation Set up and implementation by Compliance with local and international wastewater manual): RWE & Turcas wastewater discharge standards (target = all Regular monitoring of on-site WWTP effluent. (frequency at start up as per met) manufacturer recommendation; Regular report on WWTP effluent monitoring monthly for regular operation) data in compliance with relevant standards.

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

O3 Noise Noise Monitoring Plan: Set up and implementation by Noise measurements Compliance with local and international emissions/impact Regular monitoring of off site community noise at RWE & Turcas; Reference environmental noise standards (cf. ESIA Section dedicated reference locations; day and night time measures before start of Project 3.9.2) measurements during 1st year of operation operation

O4 Air emissions • Air Emissions Control Plan: Procedure set-up and Monthly report on continuous air emissions Regular (i.e. daily) evaluation of continuous stack implementation by RWE & monitoring data including maintenance and emissions monitoring (NOx) against emission Turcas with start of operation inspections standards, optimization of operation in order to reduce the emissions; ensure calibration of Compliance with local and international air monitoring equipment emission standards (cf. ESIA Section 2.15) (target = all met) Report on calibration of monitoring equipment; every 3rd year

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Action Potential Impact / Mitigation / Management Responsibility / Implementation Monitoring / Key Performance indicators Item # Issue

O5 Storage and Work Place Risk Assessments & Exposure Monitoring Procedure set-up and Work Place Risk Assessment undertaken before handling of Plan: implementation by RWE & start of operations (target: completeness status = hazardous Identification of hazardous materials related work Turcas 100%); materials and places; identification of work places with high noise Prior to start of operation Health and Safety Plans in place and Noise Exposure on levels; prevention and mitigation measures; potential implemented; site exposure; regular monitoring of exposure and HSE Instructions and PPE available (target = employee health check-ups 100% where applicable); Monitoring of workplace exposure regarding hazardous substances and noise (target: all identified areas of potential risks) Performance according to RWE & Turcas Standards for all operations

O6 Community Community Liaison Plan inter alia including: Set-up and implementation by Community Liaison Plan Set up and implemented relations Appointment of E&S supervisor (RWE & Turcas); RWE & Turcas before operations establishment of local community liaison committees Regular report by RWE & Turcas community (based on present RWE & Turcas community liaison) liaison supervisor including improvements and remedial actions agreed with EPC E&S Public Information and Awareness campaign; Supervisor if required Public grievance mechanism incl. conflict resolution Setting up a communication system for the local procedure community via phone, e-mail and a dedicated staff.

Information to public during operations in case of abnormal conditions i.e. strange noise etc.

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Denizli CCPP

Environmental and Social Impact Assessment

Final Draft Report

7 – Stakeholder-Engagement

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CONTENTS of Section 7

7 PUBLIC CONSULTATION AND DISCLOSURE 7-1

7.1 INTRODUCTION 7-1 7.2 CONSULTATION OBJECTIVES 7-1 7.3 CONSULTATIONS WITHIN THE SCOPE OF ESIA 7-3 7.3.1 Overall Plan for Consultation 7-3 7.3.2 Summary of Consultation Activities 7-3 7.3.3 Initial findings of Consultation 7-8 7.4 COMMUNICATION STRATEGIES DURING PRE-CONSTRUCTION, CONSTRUCTION AND OPERATION PHASES 7-11 7.5 GRIEVANCE MECHANISM 7-11

LIST OF TABLES

Table 7-1 Turkish Regulations relating to Public Consultation 7-2 Table 7-2 IFC Regulations relating to Public Consultation 7-2 Table 7-3 Stakeholder groups and consultation tools 7-4

LIST OF FIGURES

Figure 7-1 Main information sources for the project and local news 7-6

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7 PUBLIC CONSULTATION AND DISCLOSURE

7.1 INTRODUCTION

This chapter presents the plans for consultation as part of the Environmental Social Impact Assessment studies as well as the communication strategies during the implementation of the project. It first identifies who the key stakeholders are, explains the convened consultation exercises and outlines the initial findings of consultation. It then summarizes the planned communication strategies during pre-construction, construction and operation phases and delineates the grievance redressing mechanism.

7.2 CONSULTATION OBJECTIVES

Stakeholder consultation to support the ESIA and Resettlement Planning Framework processes specifically aim to achieve the following objectives:

 To provide information about the project and its potential impacts to those interested in or affected by the project, and explore their opinion in this regard;  To provide opportunities to stakeholders to discuss their expectations and concerns;  To manage expectations and misconceptions regarding the project;  To verify the significance of environmental, social and health impacts identified; and  To inform the process of developing appropriate mitigation measures;  To build up a continuous communication with stakeholders to assess the efficiency of mitigation measures and improve the implementations during the life of the project.

Standards for consultation

The public consultation process has been guided by the following legislation and standards:

 Turkish regulations (summarized in Table 7-1);  Guidelines established by international financing institutions, specifically the World Bank Group (summarized in Table 7-2).

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Table 7-1 Turkish Regulations relating to Public Consultation

The Republic of Turkey is not a signatory to the Aarhus Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters of 1998.

Public participation and access to information in project decisions is governed by the EIA regulation of 2003.

Public Participation Process

 A Project Definition Report (PDR) is submitted to the MoEF as start of the EIA procedure. The Project Definition Report contains general information on the planned facility, a basic characterization of the project area and anticipated environmental impacts.

 After receiving the PDR, the MOEF sets up a public information meeting where the public can raise concerns regarding the project.

 Date, hour and location information of the public participation meeting is published at the local and national newspapers 10 days before the meeting.

 The attendants of this meeting and raised issues are registered by the MoEF, to be considered during the evaluation of the EIA.

No further public consultation efforts (such as disclosure of final ESIA etc.) are required by the Turkish legislation.

Table 7-2 IFC Regulations relating to Public Consultation

The IFC Performance Standard 1 on Social and Environmental Assessment and Management System requires that:  Project-affected groups and local non-governmental organisations (NGOs) be consulted about the project’s potential environmental and social impacts during the ESIA process; and

 Local views are taken into account in designing the environmental and social management plans as well as in designing the project.

In addition to the requirement for consultation with stakeholders, IFC has specific requirements for disclosure of documentation resulting from the ESIA process. These include:  Preparation and publication of a Public Consultation and Disclosure Plan (PCDP) for consultation;

 Disclosure of the draft ESIA in public places in-country; and

 Preparation of an Environmental and Social Action Plan (ESMP) containing social as well as environmental measures designed to manage, mitigate and monitor the impacts identified during development of the ESIA. This must be made available locally.

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7.3 CONSULTATIONS WITHIN THE SCOPE OF ESIA

7.3.1 Overall Plan for Consultation

During the scoping phase of this study, four phases of consultation were proposed to be carried out as part of the ESIA:

Phase 1 – Scoping study including stakeholder identification, baseline data collection and preparation of information tools (e.g. information brochures, website, phone line);

Phase 2 – First round of consultation meetings;

Phase 3 – Second round of consultation meetings, social baseline study and trip to a similar power plant;

Phase 4 – Disclosure incl. public consultation.

7.3.2 Summary of Consultation Activities

Phase 1 – Scoping: Stakeholder Identification and preparation of information tools

During the Scoping Phase, meetings were held with MoEF in order to identify the main stakeholder groups. The project team also made a number of visits to the project site to undertake an initial stakeholder assessment. After the stakeholders were identified, the consultation tools were determined for each stakeholder group. Table 7-3 lists the groups of stakeholders and consultation tools identified.

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Table 7-3 Stakeholder groups and consultation tools

Stakeholder Group Consultation tool

Residents within the 5 km radius of the project area – i.e. Public participation meeting Kaklik town, Asagidagdere, Alikurt and Yokusbasi (official), community meetings, villages (women, men, village headmen, vulnerable focus group meetings, household groups) surveys, free phone line and project website

Kaklik and Bozkurt Municipalities Semi structured interviews and individual consultations

Government Departments and Agencies (including Semi structured interviews and MoEF, Provincial Directorates of Agriculture and Rural individual consultations Affairs, Health, Education etc.)

Newspapers and television Public participation meeting and individual consultations

Environmental and Social Development NGOs including Public participation meeting and women’s organisations, trade chambers and academic individual consultations institutions (i.e. University of Pamukkale)

Following the scoping studies, the team prepared the information and consultation tools which included:

 A public consultation and disclosure plan;  A project information document containing the key facts and figures about the proposed project and outlining the studies which are undertaken to assess the environmental and social impacts, the envisaged timelines and next steps;  Project information brochure briefing information about the project and advertising project website and free line;  Project website containing information about the project and disseminates public consultation plan (www. rweturcasdenizlienerjisantrali.com);  A free phone line.

Phase 2 – First Round of Consultation Meetings

As part of the formal Turkish EIA process a formal public information meeting took place on the 17th June 2008 - Within international ESIA practice, this would correspond to a so-called Scoping meeting.

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The general public was informed by a timely notice in the newspaper (national newspaper e.g. Aksam Gazetesi; local newspaper e.g. Denizli Objektif Gazetesi) and project information posters and brochures were made available at the local municipality offices 10 days in advance. The public in the villages affected by the project were additionally informed via the local community administrations. Relevant national and local NGOs (a total of 51 organisations), local authorities, government institutions and local media organisations were sent invitation letters. Information was also made available on the Project website.

The meeting was well attended by over 80 participants from a wide range of organisations and institutions with an interest in the Project. The meeting enabled participants to discuss the information document that outlined the project baseline and the preliminary identification of potential impacts. It also enabled participants to officially register their concerns and opinions about various aspects of the project and its likely impacts. The results of the consultation have been used in the analysis of the environmental and social impacts presented in Section 5-16.

Phase 3 – Second round of consultation meetings, social baseline study and trip to a similar power plant

Community-level consultation: The second round of consultation meetings started with community meetings held on the 17th and 18th July 2008, in four settlements. At the three villages, the community meetings were organised with the village headmen and in Kaklik, the meeting was set up with the Mayor and four quarter headmen. During the meetings, the project was explained to the residents and potential impacts and possible mitigation measures were discussed. The residents were also informed about the continuous communication channels (i.e. project website); imminent social baseline studies and the disclosure activities that are to take place at the completion of the environmental and social assessment works.

Social baseline survey: Following the community meetings, a social baseline survey was conducted (between 20th July and 4th August 2008) as described in Section 3-15. Besides gathering socio-economic data, the household surveys were also used to assess whether the people were informed about the project and to gather information about the main concerns and expectations.

According to the survey results, the majority (89%) of local people was informed about the project and the foremost information source was the community meetings (35%) followed by town talks with friends/neighbours (30%) and announces of Kaklik municipality (10%).

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Figure 7-1 Main information sources for the project and local news

Main information source for the project Main information source for local news

9 Community Meetings 35 Neighbours/friends 41 30 16 Municipality 10 15 Village/Quarter headmen 8 0 Posters/brochures 2 4 Local press 1 5 Local televisions 1 1 Internet 1 1 Imam/Teacher 1 7 None 11

0 5 10 15 20 25 30 35 40 45 Frequency (%)

As part of the social baseline studies, interviews and meetings were held with the Governor and Deputy Governors of Denizli Province, Mayors of Honaz and Bozkurt, local health, education and agriculture officers, gendarme, officers at Kaklik health centre and Honaz Hospital. Furthermore focus group meetings were held with different groups including women, poorer residents, farmers, elderly, male and female workers, disabled and ill residents. During these meetings, people were asked for their perceptions and expectations with respect to the proposed project. The findings of these consultations are incorporated into Section 3.15.

Trip to a similar power plan

During the community meetings and social baseline, it was understood that many people, including local authorities and NGOs, had misperceptions regarding the potential environmental impacts of the natural gas power plants, i.e. that the temperature would increase, the birds would die and the agricultural production would diminish. In order to eliminate such misbelieves, a trip was organised to a similar combined cycle gas power plant (1400MW) in Bursa. A total of 51 people were taken to the plant including Kaklik mayor and members of municipal assembly, village/quarter headmen of all settlements and members of the assembly/quarter assemblies, local

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Phase 4 - Disclosure

In line with accepted international practice, the Draft Final ESIA report and a summary will be made available to all stakeholders and the public for a period of at least 1 month (30 days).

Authorities, administration of the district, municipalities and local communities and NGOs will receive hardcopies of the ESIA Summary (Project Information Brochure) document by mail. The general public will be informed by notification in newspapers about the possibility to review the ESIA. The residents in the project area will be additionally informed via the local community administrations and by placards posted in the settlements.

Interested public will be able to access the Summary ESIA and ESIA documents at the municipality of Kaklik. Details about the locations and accessibility hours will be provided in the newspaper announcements and the placards posted in the villages.

With the day of public availability of the ESIA document, comments and suggestions can be submitted in writing to the Project Developer directly or be left at the municipality offices for a 1 month period.

Within this period, the Project Developer will organise a public hearing in Kaklik to explain the planned project, to inform on the outcomes of the ESIA study and to address questions. The public hearing will be prepared and announced in the same way as the first public meeting. Statutory stakeholders and NGOs will be sent a copy of the ESIA summary and be asked to provide written feedback and comments to the Project Developer if they wish. The general public will be informed in the same way as above. All information will also be made available on the project website: www.rweturcasdenizlienerjisantrali.com

Additional Disclosure of Information

In General information on the Project development has been and will continue to be made available on the website of RWE/Turcas (www.rweturcasdenizlienerjisantrali.com) including contact details for inquiries or request for further information.

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Information provided will comprise topics such as the actual status of planning and permitting process project implementation status, the ESIA Report and other information materials.

7.3.3 Initial findings of Consultation

The social baseline had put forward that a majority of the people (72 %) supported the implementation of the project, whereas 22 % disapproved, and 6 % were indecisive (Figure 7-1). The people mainly wanted the project for the economic development that it will bring and possible employment opportunities.

It was observed that some of the oppositions to the project were grounded in political reasons since local elections were to be held a few months after the first consultation.

During the social baseline, the project team had encountered many misbeliefs about the potential impacts of the project, i.e. that the temperature would increase, the birds would die and the agricultural production would diminish. Nevertheless most residents, unless they were politically committed, were open to discussions and changed their views quickly when the facts were explained by the project team. Furthermore, the later conducted trip to the combined cycle gas power plant (1400MW) in Bursa is expected to have greatly helped to eliminate any persisting misperceptions.

The findings (i.e. expectations and concerns) of the consultations performed within the scope of ESIA are summarised below, categorised by impact. The summary is based on the public participation meeting, community and focus group meetings, interviews and meetings with local authorities and NGOs and results of social baseline survey.

7.3.3.1 Environmental and agricultural concerns

Temperature/humidity change. Several people in the project area raised concern about whether the plant would cause any temperature or humidity increase.

Acid rains. Some NGOs wanted to learn about the possibility of acid rains.

Agricultural production. Many people dealing with agriculture are concerned with how/whether the project would effect the agricultural production.

Air pollution. NGOs and local residents wanted to learn about the emissions of the power plant. As many of them had observed or heard about high emission

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levels at an old coal power plant (Yatagan) located in a nearby city (Mugla), they were concerned that the project would cause similar air pollution. NGOs also wanted to learn how the emissions would be monitored by the plant and by the government institutions.

Wastewaters. People wanted to learn about how the wastewaters of the plant would be treated and how/where it would be discharged.

Potential Shortage of Water. Many people were concerned about whether the water supplies were sufficient in the area. People wanted to learn how much water would be used by the plant and where this water would be supplied from. People were mainly concerned with a possible risk of drop of the water table and shortage of water in the future.

Effects on biodiversity. Some people asked whether the project would affect the biodiversity, particularly the birds in the area. They also wanted to learn if the plant could dry out the trees in the area.

Noise. People wanted to learn whether they would hear any noise in the settlements.

7.3.3.2 Health impacts

Many people wanted to learn whether the project would cause any adverse impacts on the public health. People were concerned with health effects of the potential emissions (particularly NOx) of the plant.

7.3.3.3 In-Migration related issues

Population increase. Local people in the study area believed that there would be an increase in population due to in-migration. Most seemed to feel this would be positive since it would bring increased economic opportunities such as trading and a larger market for agricultural products.

Crime. Some villagers were concerned about the possible increase in crime, particularly thefts, in the local area.

7.3.3.4 Employment/Procurement Opportunities and Development of the region

Employment. Many respondents in the villages wanted to learn whether priority would be given to current residents.

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Increased markets. A number of villagers believed that the project would increase the market for goods that the villages produce (e.g. bread, vegetables etc.) due to an increased population.

Increase rental incomes. Some people thought they would have better opportunity to sell/rent their houses when the in-migration occurs.

Income for the Municipality. As the project will provide an income to Kaklik municipality (as income tax), many people thought it would be a great development opportunity for Kaklik.

7.3.3.5 Technical Issues

The site location. NGOs and many people wanted to learn why this particular site was chosen.

The possibility of explosions and safety plans to avoid/mitigate accidents. Some women raised their concerns regarding the risks of explosion and wanted to learn how such accidents would be avoided/mitigated.

Dependency on foreign countries for energy. As the natural gas will be imported, NGOs and people asked whether this would create (more) dependency for Turkey. People also wanted to learn what would have happened if the gas transfer was stopped by the exporting country.

Alternative fuels. People wanted to learn whether the plant could later be converted to a coal fired power plant or whether it was possible to use alternative fuels in the case natural gas was not available.

Natural gas usage. People wanted to learn how much natural gas would be used daily/monthly by the power plant.

Cooling systems. People and NGOs frequently asked about whether air or water cooling systems would be used in the plant. People also wanted to learn what would have happened if the cooling system broke down.

Earthquake zone. As the area is located in an earthquake zone, people wondered what would have happened in case of an earthquake.

7.3.3.6 Electricity production

Most stakeholders acknowledged the increasing electricity need in Turkey and the project would greatly benefit the country in this regard.

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7.3.3.7 General Issues around the ESIA Process

Public disclosure. People wanted to learn when the results of the ESIA studies would be available, and how the information would be disclosed.

Environmental monitoring. Participants of the public participation meeting were concerned that the ESIA recommendations might not be well monitored.

7.3.3.8 Response to Comments Raised During Consultation

All comments raised during the consultations have been fully taken into account in preparing this hereby presented ESIA report and addressed in the relevant chapters concerning with the environmental and social impacts (Sections 5 and 6).

7.4 COMMUNICATION STRATEGIES DURING PRE-CONSTRUCTION, CONSTRUCTION AND OPERATION PHASES

Stakeholder engagement and consultation will be carried out through the life of the project by the project developer. During pre-construction, construction and operation phases the public will have the possibility to contact the project developer via the responsible point of contacts (per telephone or post) and the website mentioned above.

Especially during construction and operation phases, a free phone line will be established and an officer will be available in the project area (generally between 09:00-17:00 hours) where people can directly get information on the project stage and ask questions, or raise concerns.

The questions and concerns communicated to the project developer will be addressed as described in the grievance mechanism (see Section 7.5) and recorded for overall performance assessments. As mentioned in Section 5.16, a social impact monitoring plan will also be developed to enable formal consultation with local residents. Together with the grievance records, the social monitoring results will be used to assess the efficiency of mitigation measures with a view to improve implementations as necessary.

7.5 GRIEVANCE MECHANISM

Following process, adopted from international standards, is foreseen by which people affected by the project can bring their comments, concerns, and grievances to the project developer, for consideration and redress is described.

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The Project Developer will designate a staff member who will be responsible for grievance response during project preparation, construction and operation. This person will take the role of a community liaison officer (CLO) and be responsible for recording and responding to comments and grievances.

During project preparation stage written comments in response to information disclosed for the project can be sent to the project developer per e-mail / mail/telephone or fax or be left at comment boxes which will be installed at Kaklik municipality administration office.

Grievances in relation to construction or operation can be addressed directly to the project developer. Grievances will in general be responded to within 2 weeks after receipt. Should the need arise project developer will consider the establishment of a conflict resolution "committee" (RWE & Turcas representatives, EPC contractor, village council representatives) for the management of complex grievance issues. The received grievances will be recorded to be used for performance assessment purposes.

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