SANKO GEOTHERMAL POWER PLANT PROJECT Environmental and Social Impact Assessment Report March 2018 ANKARA SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment SANKO GEOTHERMAL POWER PROJECT ENVIRONMENTAL and SOCIAL IMPACT ASSESSMENT REPORT Revision Version Date Prepared by Checked by Approved by January 15, 2018 December 14, 2017 Evren Arı Celal Denizli G. Ozenirler Elçin Kaya Y. Çelikel Z. Çeliker Turgay Eser Chemist, Biologist, Env. Eng, Sociologist Social Expert Env. Eng. Env. Eng. Env. Expert Ecologist M.Sc. Draft A.2 Evren Arı Celal Denizli G. Ozenirler Elçin Kaya Y. Çelikel Z. Çeliker Turgay Eser Chemist, Biologist, Env. Eng, Sociologist Social Expert Env. Eng. Env. Eng. Env. Expert Ecologist M.Sc. Final C.1 Evren Arı Celal Denizli G. Ozenirler Elçin Kaya Y. Çelikel Z. Çeliker Turgay Eser March 07, 2018 Chemist, Biologist, Env. Eng, Sociologist Social Expert Env. Eng. Env. Eng. Env. Expert Ecologist M.Sc. Final C.2 Revision Codes: A: Draft, B: Final Draft, C: Final Project No: 17/010 March 2018 Client: Consultant: 15 Temmuz Mah. Gülbahar Cad. Tepe Prime İş ve Yaşam Merkezi No: 43 K: 6-7 34212 Mustafa Kemal Mahallesi Güneşli – İSTANBUL / TÜRKİYE Dumlupınar Bulvarı No: 266 B-Blok Kat: 2 Daire: 37 : +90 444 87 65 06800 Çankaya - ANKARA / TÜRKİYE : +90 (212) 410 46 66 : +90 (312) 287 25 07-08 : +90 (312) 287 25 09 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment TABLE OF CONTENTS EXECUTIVE SUMMARY ....................................................................................................................1 1. INTRODUCTION .........................................................................................................................3 1.1 Objectives .......................................................................................................................................... 3 1.2 Scope of the Report ........................................................................................................................ 3 1.3 Limitations of the Study ............................................................................................................... 4 2. PROJECT DESCRIPTION ..........................................................................................................5 2.1 Purpose of the Project .................................................................................................................. 5 2.2 Energy Production Technology ................................................................................................. 7 2.3 Project Location .............................................................................................................................. 7 2.4 Project Components ................................................................................................................... 11 2.4.1 Drilling of Geothermal Wells ......................................................................................................... 11 2.4.2 The Power Plant ................................................................................................................................. 12 2.4.3 Energy Transmission Line.............................................................................................................. 14 2.4.4 Access Roads ........................................................................................................................................ 14 2.4.5 Pipeline................................................................................................................................................... 14 2.5 Project Proponents ..................................................................................................................... 14 2.6 Project Schedule .......................................................................................................................... 14 2.7 Project Alternatives .................................................................................................................... 16 2.7.1 Site Location ......................................................................................................................................... 16 2.7.2 Technology Alternatives ................................................................................................................. 16 2.7.3 Other Energy Generation Alternatives ...................................................................................... 18 2.7.4 No Project Alternative...................................................................................................................... 19 3. LEGAL FRAMEWORK............................................................................................................. 20 3.1 Turkish Legislation ..................................................................................................................... 20 3.1.1 Turkish Environmental, Health and Safety (EHS) Legislation ........................................ 20 3.1.2 Turkish Energy Legislation ............................................................................................................ 22 3.1.3 Turkish Legislation on Land Use ................................................................................................. 23 3.1.4 Turkish Legislation on Conservation of Nature and Wildlife .......................................... 24 3.2 International Standards ............................................................................................................ 25 4. METHODOLOGY ...................................................................................................................... 27 4.1 Area of Influence .......................................................................................................................... 27 4.2 Methodology for the Baseline Assessment......................................................................... 29 4.3 Methodology for the Impact Assessment ............................................................................ 30 5. ENVIRONMENTAL BASELINE ............................................................................................. 33 5.1 Geology and Earthquake Risks ............................................................................................... 34 5.2 Surface Water and Groundwater Quality ........................................................................... 38 5.3 Climate............................................................................................................................................. 43 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 5.4 Soil Quality ..................................................................................................................................... 44 5.5 Air Quality ...................................................................................................................................... 45 5.6 Environmental Noise .................................................................................................................. 46 5.7 Ecology ............................................................................................................................................ 52 5.7.1 Flora......................................................................................................................................................... 58 5.7.2 Fauna ....................................................................................................................................................... 65 5.7.3 Habitat Assessment ........................................................................................................................... 68 6. SOCIAL BASELINE ................................................................................................................... 70 6.1 Demography and Population .................................................................................................. 71 6.2 Livelihoods and Employment ................................................................................................. 73 6.3 Education ........................................................................................................................................ 74 6.4 Health............................................................................................................................................... 75 6.5 Infrastructure and Services ..................................................................................................... 75 6.6 Vulnerable Groups ...................................................................................................................... 76 6.7 Project Information Level ........................................................................................................ 77 7. ENVIRONMENTAL IMPACT ASSESSMENT ...................................................................... 79 7.1 Construction Stage Impacts ..................................................................................................... 80 7.1.1 Impacts on Ecology ........................................................................................................................... 80 7.1.2 Water Supply .............................................................................................................................................. 82 7.1.3 Wastewater Generation .......................................................................................................................... 82 7.1.4 Impacts of Geothermal Fluid ................................................................................................................. 83 7.1.5 Impacts of Solid Wastes on Soil and Groundwater .............................................................. 84 7.1.6 Impacts on Air Quality ..................................................................................................................... 87 7.1.7 Noise Impact ........................................................................................................................................ 90 7.2 Operation Phase Impacts .......................................................................................................... 91 7.2.1 Impacts on Ecology ........................................................................................................................... 91 7.2.2 Water Supply ....................................................................................................................................... 91 7.2.3 Wastewater Generation................................................................................................................... 91 7.2.4 Impacts of Spent Geothermal Fluid ............................................................................................ 92 7.2.5 Impacts of Solid Wastes................................................................................................................... 93 7.2.6 Impacts of Storage of Chemicals .................................................................................................. 95 7.2.7 Impacts on Air Quality and Odor Impacts................................................................................ 97 7.2.8 Environmental Noise Impacts ...................................................................................................... 98 7.2.9 Climate Change Impacts ............................................................................................................... 100 7.2.10 Impacts on Landscape ................................................................................................................... 101 7.3 Closure Phase Impacts .............................................................................................................104 7.3.1 Impacts on Ecology ........................................................................................................................ 104 7.3.2 Water Supply ........................................................................................................................................... 104 7.3.3 Wastewater Generation ....................................................................................................................... 104 7.3.4 Impacts of Geothermal Fluid .............................................................................................................. 104 7.3.5 Impacts of Solid Wastes on Soil and Groundwater ........................................................... 105 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.3.6 Impacts on Air Quality .................................................................................................................. 105 7.3.7 Noise Impact ..................................................................................................................................... 105 7.4 Impacts of the Energy Transmission Line ........................................................................105 8. SOCIAL IMPACT ASSESSMENT ........................................................................................ 110 8.1 National Economy .....................................................................................................................110 8.2 Land Acquisition ........................................................................................................................111 8.3 Local Economy and Livelihood .............................................................................................115 8.3.1 Employment ...................................................................................................................................... 115 8.3.2 Local Economy ................................................................................................................................. 117 8.3.3 Labor Influx ....................................................................................................................................... 117 8.4 Transportation / Traffic .........................................................................................................119 8.5 Community Health and Safety...............................................................................................121 8.6 Occupational Health and Safety ...........................................................................................123 8.7 Cultural Heritage .......................................................................................................................126 8.8 Closure Phase Impacts .............................................................................................................129 8.8.1 Economy and Employment ......................................................................................................... 130 8.8.2 Land Use.............................................................................................................................................. 130 8.8.3 Visual and Landscape .................................................................................................................... 130 8.8.4 Community Health and Safety ................................................................................................... 130 8.8.5 Occupational Health and Safety ................................................................................................ 130 8.8.6 Cultural Heritage ............................................................................................................................. 131 9. CUMULATIVE IMPACTS ..................................................................................................... 132 10. INSTITUTIONAL ARRANGEMENTS ................................................................................ 134 11. E&S Mitigation and Monitoring Plan ........................................................................... 137 11.1 Construction Stage ....................................................................................................................137 11.2 Operation Stage ..........................................................................................................................144 12. REFERENCES ......................................................................................................................... 150 LIST OF ANNEXES ANNEX-1 Test Results ANNEX-2 Stakeholder Engagement Plan ANNEX-3 Cultural Heritage Management Plan ANNEX-4 Public Interest Decision ANNEX-5 Construction Emergency Response Plan ANNEX-6 Operation Emergency Response Plan ANNEX-7 Occupational Health and Safety Plan ANNEX-8 Traffic Management Plan ANNEX-9 Waste Management Plan ANNEX-10 Effluent Management Plan ANNEX-11 Hazardous Chemical Management Plan Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment LIST OF TABLES Table 2-1. Project Reinjection and Production Wells ............................................................. 6 Table 2-2. Future Planned Capacity Increase........................................................................ 6 Table 2-3. Future Planned Wells ........................................................................................... 7 Table 2-4. Energy Production of the Project with Regards to Months .................................. 13 Table 2-5. Project Schedule ................................................................................................ 15 Table 3-1. Turkish EHS Legislation Related to the Project .................................................. 21 Table 3-2. Turkish Energy Legislation Related to the Project .............................................. 22 Table 3-3. Project-related Turkish Legislation on Land-use ................................................. 23 Table 3-4. Project-related Turkish Legislation on Conservation of Nature and Wildlife ........ 24 Table 3-5. Permits Required for the Project ......................................................................... 24 Table 4-1. Impact Types and Definitions ............................................................................. 31 Table 4-2. Impact Criteria .................................................................................................... 32 Table 4-3. Significance Rating ............................................................................................. 32 Table 4-4. Overall Impact Rating ......................................................................................... 32 Table 5-1. Scoping of Environmental Issues........................................................................ 33 Table 5-2. Gutenberg-Richter Parameters ........................................................................... 37 Table 5-3. Earthquake Occurrence Probability .................................................................... 37 Table 5-4. Groundwater Analysis Results regarding “Regulation on Water for Human Consumption” ...................................................................................................................... 39 Table 5-5. Results of Ground Water Quality Analysis regarding “Regulation on Monitoring of Surface Water and Groundwater” ........................................................................................ 43 Table 5-6. Results of Soil Quality Analysis .......................................................................... 44 Table 5-7. Results of PM10 Measurements .......................................................................... 45 Table 5-8. Coordinates of H2S Sampling Points .................................................................. 45 Table 5-9. Results of H2S Measurements ............................................................................ 46 Table 5-10. Coordinates of Noise Sensitive Receptor ......................................................... 46 Table 5-11 Distance of Noise Sensitive Receptor to the Project Area.................................. 47 Table 5-12. Background Noise Measurement Results (daytime, evening and nighttime) ..... 48 Table 5-13. Background Noise Measurement Results (daytime and nighttime) ................... 50 Table 5-14. Ecological Survey Points .................................................................................. 56 Table 5-15. Flora in the Project Area and its Environs ......................................................... 62 Table 5-16. Species of Reptiles and Amphibians in the Project Region ............................... 65 Table 5-17. Bird Species in the Region ............................................................................... 66 Table 5-18. Mammals in the Project Region ........................................................................ 68 Table 6-1. Scoping of Social Issues..................................................................................... 71 Table 6-2 Population Figures of the Area of Impact ............................................................. 72 Table 6-3. Population Dynamics .......................................................................................... 73 Table 6-4. Type of the lands within the AoI .......................................................................... 73 Table 6-5. Common Economic Activities within the AoI ....................................................... 74 Table 6-6. Vulnerable Groups.............................................................................................. 77 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 6-7 Suggested Information Disclosure and Grievance Tools ..................................... 78 Table 7-1: Impacts of Construction Stage on Ecology ......................................................... 81 Table 7-2: Expected Domestic Wastewater Parameters ...................................................... 83 Table 7-3: Impacts of Drilling Effluents ................................................................................ 84 Table 7-4: Impacts of Waste Storage .................................................................................. 87 Table 7-5: Controlled Dust Emission Factors according to Turkish IAPCR .......................... 88 Table 7-6: Construction Phase Dust Emissions ................................................................... 88 Table 7-7. Impacts of Construction Activities on Air Quality ................................................. 89 Table 7-8. Noise Impacts of the Construction Stage ............................................................ 90 Table 7-9. Impacts of Spent Geothermal Fluid .................................................................... 92 Table 7-10. Impacts of Waste Generation and Storage at Operation Stage......................... 95 Table 7-11. Impacts of Chemicals Storage .......................................................................... 96 Table 7-12. Air Quality and Odor Impacts During the Operation Stage ................................ 98 Table 7-13: Operation Equipment and Sound Power Levels ............................................... 98 Table 7-14: IFC/WB Noise Limits ........................................................................................ 99 Table 7-15: Noise Levels for Operation Phase .................................................................... 99 Table 7-16. Noise Impact of the Operation Stage .............................................................. 100 Table 7-17. Impact on Landscape ..................................................................................... 103 Table 7-18. ICNIRP Exposure Limits for General Public Exposure to Electric and Magnetic Fields ................................................................................................................................ 106 Table 7-19. Minimum Horizontal Distances of the Overhead Line Conductors to the Structures with Maximum Oscillation ................................................................................. 108 Table 7-20. Minimum Horizontal Distances of Overhead Line Conductors to Trees .......... 108 Table 7-21. Minimum Vertical Distances of Overhead Line Conductors to the Places over which They Pass with Maximum Sag ................................................................................ 108 Table 8-1. Impacts on Local Employment .......................................................................... 111 Table 8-2. Land Purchased for the Project Activities ......................................................... 112 Table 8-3. Impacts of Land Acquisition on Local Communities .......................................... 114 Table 8-4. Impacts on Local Employment .......................................................................... 115 Table 8-5. Impacts on Local Economy............................................................................... 117 Table 8-6. Impacts on Labour Influx .................................................................................. 118 Table 8-7. Impacts of Project Transportation Activities ...................................................... 119 Table 8-8. Impacts on Community Health and Safety ........................................................ 121 Table 8-9. Impacts on Occupational Health and Safety ..................................................... 125 Table 8-10 Coordinates of Wells ....................................................................................... 128 Table 8-11. Impacts on Cultural Heritage .......................................................................... 129 Table 10-1 Roles and Responsibilities ............................................................................... 136 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment LIST OF FIGURES Figure 2-1. Project Area and Associated Facilities................................................................. 9 Figure 2-2. Process Flow Chart ........................................................................................... 13 Figure 4-1. AoI of the Project ............................................................................................... 28 Figure 5-1. Geology in the Region ....................................................................................... 35 Figure 5-2. Topographical Map of the Region...................................................................... 36 Figure 5-3 Closest Noise Receptor ...................................................................................... 47 Figure 5-4. Ecological Survey Point ..................................................................................... 57 Figure 5-5. Grid System for Flora of Turkey......................................................................... 58 Figure 5-6. Project Area and Protected Areas ..................................................................... 61 Figure 6-1. Age Distribution of Survey Population on the Basis of Neighbourhoods ............ 72 Figure 6-2 Education indicators of the community members within the AoI ......................... 75 Figure 7-1 Visibility Analysis Map ...................................................................................... 102 Figure 8-1 Organization Chart ........................................................................................... 124 Figure 8-2 Project License Area and the Ancient City of Sardis ......................................... 127 LIST OF PHOTOS Photo 2-1. General View of the Project Site-1 ..................................................................... 10 Photo 2-2. General View of the Project Site-2 ..................................................................... 10 Photo 2-3. General View of the Project Site-3 ..................................................................... 11 Photo 5-1. Agricultural Areas Around the Project Site ......................................................... 59 Photo 5-2. Agricultural Areas Around the Drilling Well ......................................................... 59 Photo 5-3. Agricultural and Residential Areas Around Power Plant ..................................... 60 Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment ABBREVIATIONS 2U1K 2U1K Engineering and Consultancy Inc. AoI Area of Influence CO2 Carbon Dioxide EA Environmental Assessment EHS Environment, Health and Safety EIA Environmental Impact Assessment EMF Electromagnetic Field EPRP Emergency Preparedness and Response Plan ESA Environmental and Social Assessment ESDD Environmental and Social Due Diligence ESMMP Environmental and Social Management and Monitoring Plan GD NCNP General Directorate of Nature Conservation and National Parks DSI General Directorate of State Hydraulic Works GPP Geothermal Power Plant HS Health and Safety H2S Hydrogen Sulphide IFC International Finance Corporation MoEU Ministry of Environment and Urbanization NGO Non-Governmental Organization NCG Non-Condensable Gas OHS Occupational Health and Safety ORC Organic Rankine Cycle PDR Project Description Report PPE Personal Protective Equipment PS Performance Standards SEP Stakeholder Engagement Plan TEDAŞ Turkish Electricity Distribution Corporation Final Report March 2018 Project No: 17/010 ix / ix SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment EXECUTIVE SUMMARY Sanko Enerji Sanayi ve Ticaret A.Ş. (Sanko) has committed to operate Sanko Geothermal Power Plant (the Project) with capacity of 15 MW in Salihli District of Manisa Province. The Project is planned to provide contribution to the national grid with generation of 118.7 GWh electricity annually. This Environmental and Social Impact Assessment report has been prepared for this Project development and includes project description, project components, schedule and alternatives, legal framework, ESIA methodology, environmental and social baseline conditions, impact assessment, institutional arrangements and environmental and social mitigation and monitoring plan. Along with the ESIA report a Stakeholder Engagement Plan (SEP) and Cultural Heritage Management Plan have been prepared for the Project. The Project is expected to have environmental and social impacts for which the details are discussed in the following sections. Main environmental issues focused in the report are; impacts on ecology, air quality, surface water, groundwater and soil, landscape, noise impacts, climate change, water supply and wastewater generation. After the impacts are defined, mitigation measures are described related to the impacts. Mitigation measures have been defined for environmental issues that may occur during geothermal power plant generation: o An impermeable collection pond of 1,400 m3 was constructed to be used in case of any failure during reinjection, operation of the power plant or during maintenance of the wells. If the volume of the collection pond is exceeded due to malfunction, extraction of geothermal fluid will be stopped in order to prevent adverse impact of geothermal fluid on soil and groundwater. o Reinjection is employed provided leak-proof well casings. o H2S emissions will be monitored regularly in order to determine compliance with legislation requirements. o Drilling mud generated during drilling is stored in mud ponds covered with impermeable material. o Emergency Response Plan has been developed and implemented for Project activities. The Project is established on privately owned agricultural lands therefore most significant social impact of the Project is land acquisition. Sanko used voluntary purchase method for land take of the area required for the Project. Land take process and payment for the purchased lands have been completed and there will be no more land acquisition for the Project. There has been no physical displacement occurred for the Project. Sanko has secured geothermal resource operation license for an area of 2,267.97 hectares. The Project will be located on an area of 84,841 m2 within the license area. The license area comprises of Ancient City of Sardis which is at a distance of 4 km to the Project area. Final Report March 2018 Project No: 17/010 1 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Although any impact on the Ancient City of Sardis due to Project activities is not expected, a Cultural Heritage Management Plan has been developed for the Project and will be implemented during the life span of the Project. Also, the requirements of Chance Find Procedure which is prepared for the Project will be met in case archaeological remains are met during Project activities. Therefore impact on cultural heritage is expected to be insignificant. Legally protected and internationally recognized areas close to the Project area are Gölcük Lake Wetland, Marmara Lake Wetland, Ovacık Wildlife Development Area, Spil Mountain National Park, Kula Fairy Chimney Nature Monument at a distance of 10 km, 10 km, 34 km, 48 km and 63 km respectively. Impact is not expected on these areas due to Project activities. The Project is located in a modified habitat, under intense human pressure due to animal grazing and agricultural activities. Although excavation and drilling activities might cause dust and noise impact on flora and fauna, impact is expected to be insignificant since there are no critical habitats or species and existing species will be able to adapt changes. Effective community engagement for the Project will be assured through the implementation of SEP prepared for the Project. The stakeholders of the Project will be informed and also be involved in identifying important issues of the Project through the implementation of SEP. Final Report March 2018 Project No: 17/010 2 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 1. INTRODUCTION 1.1 Objectives 2U1K has been appointed by Sanko Enerji Sanayi ve Ticaret A.Ş. (hereinafter the Project Company) for the Environmental and Social Impact Assessment (ESIA) of the Sanko Geothermal Power Plant Project (hereinafter The Project). The Project is planned to be realized in three phases; in the first phase, 15 MWe energy is planned to be generated. In the second phase, additional 15 MWe and, finally with additional 20 MWe a total of 50 MWe will be achieved. The Project Company seeks for potential financing for the first phase with 15 MW capacity from Türkiye Kalkınma Bankası (TKB), the financial intermediary. Therefore this ESIA study is conducted by 2U1K on behalf of the Project Company to identify potential impacts of the proposed project and to recommend appropriate mitigation measures to reduce adverse potential impacts. The ESIA process is comprised of baseline environmental and social assessment, environmental and social impact assessment, designation of mitigation measures, stakeholder consultations and cumulative impact assessment. Baseline information in the Report is supported with field studies that include:  Overall site observations of drilling wells, mud-pits, storage conditions of chemicals and fuels and waste management;  Observations for the flora and fauna assessments;  Sampling for air quality measurements, groundwater sampling, and environmental noise measurements;  Social surveys including household surveys, focus group meetings, interviews with mukhtars;  Consultations with key stakeholder groups. Results of field tests and measurements are provided in Annex-1. Stakeholder Engagement Plan prepared for the Project is given in Annex-2. 1.2 Scope of the Report The Report is comprised of 10 Sections. Brief description about these sections is as follows:  Section 1 is an introductory part that gives overall objectives of the ESIA Report, its contents and limitations in undertaking the associated studies.  Section 2 describes the Project components that are subject to assessment of environmental and social impacts.  Section 3 gives the legal framework including national and international legislative requirements as related with geothermal drilling and power generation. National frame compiles the Project-related laws and regulations on the basis of concerns of Final Report March 2018 Project No: 17/010 3 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment the environmental and social assessment. EHS, permits, energy generation, land use and biodiversity conservation. International legal frame focuses on requirements of the World Bank operational procedures and the pertinent risk categorization for the specific Project.  Section 4 defines the methodology of data collection and impact assessment.  Section 5 gives environmental baseline situation to be considered in the long term monitoring process as well as the scoping of impact assessment process.  Section 6 gives social baseline situation to be considered in the long term monitoring process as well as the scoping of impact assessment process.  Section 7 is assessment of impacts on the environment. Focus is given on soil and groundwater contamination from discharge of geothermal drilling and operation stages, from mud pits opened during drilling stage and H2S emissions during operation.  Section 8 is assessment of impacts on the communities. Social and economic impact assessment is backed up by a Stakeholder Engagement Plan (SEP) and the Community Profile of Social Surveys. The SEP prepared by 2U1K is available in Annex-2 of the Report.  Section 9 discusses cumulative impacts of the Project in conjunction with other geothermal projects in the region.  Section 10 presents the mitigation plan and the monitoring plan for environmental and social aspects to be complied with during both construction and operation stages. 1.3 Limitations of the Study Besides site observations performed by 2U1K, the ESIA Report is limited to the statements of Project Company representatives and former reports (EIA Report for the proposed geothermal power plant) prepared during the course of project planning and license applications. In this respect, no modeling studies are performed in relation to environmental and social parameters. The ESIA process builds upon the available reports and supports them with additional baseline measurements of critical parameters and social surveys. Potential financing will apply for only Phase-1 of 15 MW capacity, therefore this ESIA study focuses on the impacts of Phase-1 activities. Energy Transmission Line (ETL) which will transmit the generated energy by the Power Plant to the national grid is under the responsibility of Turkish Electricity Distribution Corporation (TEDAŞ). Expropriation process for the lands required for the ETL is on-going, therefore not finalized yet. Potential impacts of the ETL and mitigation measures are provided in the impact assessment section. Final Report March 2018 Project No: 17/010 4 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 2. PROJECT DESCRIPTION 2.1 Purpose of the Project Sanko Enerji Sanayi ve Ticaret A.Ş. (Sanko Enerji) plans to develop and operate Sanko Geothermal Power Plant with a capacity of 15 MWe electric power by means of utilizing geothermal water in Salihli District of Manisa Province. The Project will generate 118.7 GWh electricity annually. The power generated by the Project will be connected to the national grid through 34.5 kVa energy transmission line between the Project site and Salihli Substation. Sanko Enerji secured Geothermal Resource Operation License for an area of 2,267.97 hectares with license no.143 from Manisa Provincial Administration on May 21, 2009 for the purpose of geothermal energy production for 30 years. Although the operation period is planned as 30 years at this stage of the Project, with maintenance and rehabilitation of the system and equipment, drilling of new wells and preservation of geothermal resources life span of the plant could be longer than 30 years. The license can also be extended for 10 years period after the expiration. Drilling studies for the Project started on 2010 at the licensed area in order to make use of the energy potential of the region therefore the Project was subject to the former Regulation on Environmental Impact Assessment (EIA) (dated June 17, 2008; No: 26939). According to the former EIA regulation geothermal power plants with thermal power capacity of and higher than 5 MWt were subject to preparing a Project Description Report and submit to the former Provincial Directorate of Environment and Forestry for Environmental Impact Assessment decision. The Project secured “EIA is not required” decision on May 21, 2010 for 3 production and 2 reinjection wells with a capacity of 29 MW. During the development of the Project the resources from the existing wells have been found insufficient therefore the company applied for the development of additional 5 drilling wells for the same capacity in the scope of the EIA Regulation. “EIA exclusion decision” for the additional wells was secured from the Provincial Directorate of Environment and Urbanization on January 01, 2016. In the course of site investigations in the area, energy generation of 50MW has been considered at the licensed area. According to the EIA Regulation in force (dated November 25, 2014; No: 29186 and amended on May 26, 2017; No: 30077) geothermal power plants with a thermal capacity of and higher than 25 MWt are subject to preparing “Environmental Impact Assessment” Report and submit to the Ministry of Environment and Urbanization. National EIA procedure for the Project was started in August, 2016. Public Participation Meeting according to the EIA Regulation took place on August 27, 2016 at Yılmaz Neighbourhood, Salihli District. EIA report was submitted to the Ministry of Environment and Urbanization and “EIA positive” decision was secured on February 14, 2017. Sanko Enerji has already secured Production License” for 15 MW capacity from the Energy Market Regulatory (EPDK). Final Report March 2018 Project No: 17/010 5 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 84,841 m2 of the licensed area in Sıraağaçlar Quarter, Yılmaz Neighbourhood, Salihli District, Manisa will be utilized for the Project activities. Land acquisition for the area required for the Project has been completed. Voluntary purchase method has been applied by the Project Company for land acquisition. The Project comprises of drilling and operation of 4 geothermal production wells and 2 reinjection wells in the license area for the first phase. Apart from the production and re- injection wells, the Project also comprises of a power plant, energy distribution center, pipelines and energy transmission line. The coordinates of the production and reinjection wells are provided below in Table 2-1. Table 2-1. Project Reinjection and Production Wells Coordinates Well no Type of Use (WGS84) SAN-3 Reinjection 38.497200°:28.091983° SAN-8 Reinjection 38.484597°:28.094202° SAN-4 Production 38.491547°:28.090448° SAN-5 Production 38.491638°:28.090444° SAN-6 Production 38.491455°:28.090445° SAN-7 Production 38.484507°:28.094177° Sanko Enerji plans for capacity increase of the Power Plant in the future and to achieve 50 MW power generation in total. Planned capacity and number of wells for different phases of Sanko GPP Project are provided below in Table 2-2. Table 2-2. Future Planned Capacity Increase No of Production No of Reinjection Phases Capacity Wells Wells Phase-I 15 MW 4 2 Phase-II 15 MW (additional) 5 2 Phase-III 20 MW (additional) 6 2 Total 50 MW 15 6 The location and type of wells have been described in the EIA Report of the Project but on the other hand, during the course of Project development both the location and type could be changed based on the outcomes of drilling activities. In case new wells are required in the upcoming phases of the Project, all required permits will be obtained from pertinent official authorities such as General Directorate of State Hydraulic Works (DSİ), Directorate of Cultural Heritage Protection Committee and Provincial Directorate of Food, Agriculture and Livestock. The coordinates of the wells planned to be utilized in latter phases are provided below in Table 2-3. Final Report March 2018 Project No: 17/010 6 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 2-3. Future Planned Wells Coordinates Well no Type of Use WGS84 1 Production 38.4955: 28.0831 2 Production 38.5011: 28.0942 3 Production 38.5075: 28.0970 4 Production 38.4936: 28.0977 5 Production 38.4825: 28.0997 6 Production 38.4825: 28.0997 7 Production 38.4749: 28.0967 8 Production 38.4763: 28.0856 9 Production 38.4849: 28.0755 10 Production 38.4973: 28.0775 11 Production 38.4844: 28.0890 12 Reinjection 38.4896: 28.0774 13 Reinjection 38.5011: 28.0668 14 Reinjection 38.4775: 28.0775 15 Reinjection 38.4690: 28.0896 2.2 Energy Production Technology Power generation process will be based on Air Cooled Binary Production Technology, which makes 100% re-injection possible and enables renewability of the energy source and also minimizes the environmental impacts aboveground. Operation will include air-cooled condenser therefore no white plume will be emitted in contrast to flash power plants that uses geothermal steam directly. Environmental impacts of an air cooled binary technology power plant are very low compared to flash technologies. In a geothermal power plant using air cooled binary system, geothermal fluid, is extracted from the underground reservoir and flows from the wellhead through a gathering system of insulated steel pipelines to a heat exchanger, which heats a secondary working fluid which has a low boiling point. In this system secondary working fluid is n-pentane, and is vaporized and used to drive the turbine. The organic fluid is then condensed in a condenser which is cooled by air. The condensed fluid is then recycled back to the heat exchanger, closing the cycle within the sealed system. The cooled geothermal fluid is then reinjected back into the reservoir. 2.3 Project Location The Project area is located in the Yılmaz neighbourhood of the Salihli District of Manisa (see Figure 1-1). Project Company has secured Geothermal Resource Operation License for an area of 2,267.97 hectares with license no.143 and the Production area of the Project covers Final Report March 2018 Project No: 17/010 7 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment an area of 84,841 m2. The Project area is within the boundaries of “Caferbeyli Jeothermal Area” which is the most significant potential geothermal energy areas of Turkey. Yılmaz neighbourhood at northeast is the closest settlement at a distance of 600 m to the Project area. The Project site is surrounded with agricultural lands at east, west and north and İzmir-Uşak highway (E-96) and Manisa-Salihli-Turgutlu Railway at the south. Project area with the associated facilities and the license area is provided in Figure 2-1 below: Final Report March 2018 Project No: 17/010 8 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 2-1. Project Area and Associated Facilities Final Report March 2018 Project No: 17/010 9 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment General view from the Project site is provided below in Photo 2-1 to Photo 2-3. Photo 2-1. General View of the Project Site-1 Photo 2-2. General View of the Project Site-2 Final Report March 2018 Project No: 17/010 10 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Photo 2-3. General View of the Project Site-3 2.4 Project Components 2.4.1 Drilling of Geothermal Wells Exploration and reservoir evaluation activities include geological, geophysical, and drilling surveys for exploratory drilling and reservoir testing. Production field development involves drilling steam or hot water production wells and re- injection wells and processing of the reservoir output for use in the power plant. Drilling will continue throughout the life of the project, as production and injection wells need to be periodically updated to support power generation requirements (IFC EHS Guidelines Geothermal Power Generation, 2007) There are several methods for the removal of rock fragments and mud during drilling process which are cable tool drilling, rotary drilling and air/foam rotary drilling. Rotary drilling is used by Sanko Enerji for the Project. Rotary drilling is a commonly used method operating without interruption since employs a circulation fluid to remove rock fragments. Generally drilling process includes site and pit preparation, erection of drilling tower, mud pond, drilling surveys for exploratory drilling and reservoir testing and laying of the transmission pipes respectively. The tower height which is used for drilling process of the Project is 45 meters. Rotary drill with the capacity of 3,500 m has been employed for the existing wells for 2,500 meters depth Final Report March 2018 Project No: 17/010 11 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment so far. Geothermal fluid which is at 250 °C at the bottom of the well is expected to reach the surface at 150-160 °C and at 100-150 ton/h capacity. There will also be mud ponds near each drilling location for collecting the drilling mud with about 1,170 m3 capacity. The dimensions of the ponds will be approximately 60m*6.5m*3m and covered with impermeable materials such as geomembrane liners preventing leakage. Material collected in the settlement ponds will be analyzed and will be disposed accordingly. 2.4.2 The Power Plant Power plant construction activities include construction of the power plant facility and associated infrastructure, including air cooled condenser, pipelines, and facilities for treatment and reinjection of wastewaters and gases. The Project will operate with air cooled binary system where, geothermal fluid is extracted from the underground reservoir and flows from the wellhead through a gathering system of insulated steel pipelines to a heat exchanger, which heats a secondary working fluid which has a low boiling point. In this system secondary working fluid is n-pentane, and is vaporized and used to drive the turbine. The organic fluid is then condensed in a condenser which is cooled by air. The condensed fluid is then recycled back to the heat exchanger, closing the cycle within the sealed system. The cooled geothermal fluid is then reinjected back into the reservoir. Since the system is planned as closed loop, interference of n-pentane with the geothermal fluid will be avoided. Air-cooled technology will avoid extensive use of water and wastewater discharge. The flow diagram for the system is provided below in Figure 2-2. Final Report March 2018 Project No: 17/010 12 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 2-2. Process Flow Chart The power plant is planned to operate 360 days/year with 3 shifts. Planned energy production with regards to months is provided below in Table 2-4. Table 2-4. Energy Production of the Project with Regards to Months Average Capacity Gross Production Reinjection Months Temperature (°C) (MW) (MWh) Temperature (°C) January 6.4 14.8 11.017,69 70.5 February 7.5 14.7 9.874,34 71.0 March 10.5 14.4 10.705,87 72.1 April 15.3 13.9 9.978,28 74.3 May 20.6 13.1 9.770,40 77.1 June 25.2 12.5 8.938,88 79.7 July 27.5 12.1 8.938,88 81.1 August 26.9 12.2 9.042,82 80.7 September 22.6 12.9 9.250,70 78.2 October 16.9 13.7 10.082,22 75.2 November 11.5 14.3 10.290,11 72.6 December 7.9 14.7 10.809,81 71.1 Final Report March 2018 Project No: 17/010 13 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 2.4.3 Energy Transmission Line The energy produced by the Project will be connected to the national grid through 34.5 kV transmission line of about 6.5 km between Distribution Center/switchyard between the Project Area and Salihli Substation. The official letter from TEDAS and Gediz Elektrik (local electricity distribution company) for the connection of energy generated by the Project has been secured. TEDAS is the responsible authority for the energy transmission line (ETL) and also responsible for the expropriation process for the lands on the ETL route. Since expropriation process is on-going, Project Company has gone to agreements with the land owners to secure access right to the lands before the completion of the expropriation process. According to the agreements negotiated prices for early access have been paid to the land owners. Substation will not be established for the Project with 15 MW capacity. 2.4.4 Access Roads Access to the Project site will be provided through the existing site roads from İzmir-Uşak Highway to the agricultural lands around the Project Area. İzmir-Uşak Highway is at a distance of 1,450 m to the Project Site and new access roads will not be constructed. Project Company will avoid damaging the roads however if any damage occurs due to Project activities, maintenance will be provided. 2.4.5 Pipeline The pipeline route to two reinjection wells (SAN-3 and SAN-8) will be about 700 m and 1100 m respectively. The pipeline to SAN-4 and SAN-7 production wells will be 150 m and 1100 m respectively. Directional drilling has been applied for SAN-5 and SAN-6 in order to minimize the length of aboveground pipeline providing minimum environmental impact in line with the clean production policy requirements of Sanko Enerji. 2.5 Project Proponents Key proponents of the Project are:  Project Company (Sanko Enerji),  Development Bank of Turkey,  International Financing Institution (World Bank),  Contractors. 2.6 Project Schedule The Project comprises of construction and operation phases of the geothermal power plant. The construction of phase of the Project is estimated for 8 months. A total number of 100 workers are planned to be employed during different periods during construction activities. 27 personnel is planned to be working during the operation phase. The Project including pre-engineering design, EIA studies and construction is planned to be completed in 14 months. In other words, the plant will start operating with 15 Mwe capacity at the end of 14 months. Project schedule is provided below in Table 2-5. Final Report March 2018 Project No: 17/010 14 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 2-5. Project Schedule PHASE 1 ENERGY GENERATION Months 1 2 3 4 5 6 7 8 9 10 11 12 13 14 30 Years PRE-CONSTRUCTION PHASE Pre-Engineering Design EIA Process and Permits Drilling Structural Design Mechanical Design Electrical Design I&C Design Fluid Collection System and Injection CONSTRUCTION PHASE Procurement Fluid Collection System and Injection Construction of the Plant Installation of Mechanical Infrastructure Installation of Electrical and I&C Infrastructure Commissioning of Fluid Collection System Commissioning of the Power Plant OPERATION Final Report March 2018 Project No: 17/010 15 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 2.7 Project Alternatives Project alternatives were considered for the aspects listed below:  Site Location;  Technology;  Other Energy Generation Alternatives; and  No Project Alternative. 2.7.1 Site Location The Project is located on an area of 84,841 m2 within the borders of Geothermal Resource Operating License Area with the license no 143. The licensed area is included in “Caferbeyli Geothermal Area” which is acknowledged as “Geothermal Reserve Area” by MTA, therefore is one of the most appropriate areas for geotechnical operations. The region has proved geothermal resources through various research and development studies and accomplished drillings by governmental authorities, academic institutions and private companies as well. The Project area is planned in a proximity to the previous drillings in the licensed area (no. 143), for which the permit had been secured for 2,267.97 hectares on May, 2009. Existing drilling wells and availability to access similar geothermal resources through additional wells have gained importance during project location selection. Project location is at a distance of 1,450 m from İzmir-Uşak Highway. Access to the Project Site will be provided through the existing roads which had been opened from İzmir-Uşak Highway to the lands around the Project Site. Thus, construction of additional roads will not be required and related emissions will not occur. 2.7.2 Technology Alternatives Geothermal power plants use steam produced from geothermal reservoirs to generate electricity. There are three geothermal power plant technologies being used to convert hydrothermal fluids to electricity - dry steam, flash steam and binary cycle (U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy). Resource characteristics such as temperature, pressure, volumes of fluid produced, and chemical properties of the geothermal reservoir are the primary determinants of the size and type of power conversion equipment (Kaplan and Serpen, 2010). Dry steam plants use hydrothermal fluids that are primarily steam. The steam flowing directly through a turbine drives a generator that produces electricity. Hence, the steam eliminates the need to burn fossil fuels to run the turbine (also eliminating the need to transport and store fuels). These plants emit only excess steam and very minor amounts of gases. In flash steam plants, on the other hand, fluid at temperatures greater than 182°C is pumped under high pressure into a tank at the surface held at a much lower pressure, causing some of the fluid to rapidly vaporize, or "flash". The vapor then drives a turbine, which drives a generator. If any liquid remains in the tank, it can be flashed again in a second tank to extract even more energy. Final Report March 2018 Project No: 17/010 16 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Binary cycle geothermal power generation plants differ from dry steam and flash steam systems in that the water or steam from the geothermal reservoir never comes in contact with the turbine/generator units. Heat from the low to moderately heated (below 204°C) geothermal fluid passing through a heat exchanger causes the secondary (hence, "binary") fluid with a much lower boiling point to flash to vapor, which then drives the turbines and subsequently, the generators. Binary cycle power plants are closed-loop systems, and virtually nothing (except water vapor) is emitted to the atmosphere (U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy). With respect to air emissions, in closed-loop systems, which are, binary cycle power plant systems, the geothermal fluid extracted from the well are not exposed to the atmosphere and are injected back into the ground after utilization of their heat, so air emissions are minimal. In contrast, open-loop systems, which are, namely, dry steam and flash steam power plants systems, emit hydrogen sulfide (H2S), carbon dioxide (CO2), ammonia (NH3), methane (CH4), and boron (B2) among which hydrogen sulfide is the most common emission. Once in the atmosphere, hydrogen sulfide transforms into sulfur dioxide (SO2). This contributes to the formation of small acidic particulates that can be absorbed by the bloodstream and cause heart and lung diseases. Sulfur dioxide also causes acid rain, which damages crops, forests, and soils, and acidifies lakes and streams. However, SO2 emissions from geothermal plants are approximately 30 times lower per megawatt-hour than from coal plants. Some open-loop geothermal power plants systems also produce small amounts of mercury emissions, which must be mitigated using mercury filter technology. Scrubbers can reduce air emissions, but they produce a watery sludge composed of the captured materials, including sulfur, vanadium, silica compounds, chlorides, arsenic, mercury, nickel, and other heavy metals. This toxic sludge often must be disposed of at hazardous waste sites. In terms of greenhouse gas emissions, approximately 10 percent of the air emissions are carbon dioxide, and a smaller amount of emissions are methane in open-loop geothermal systems. The amount of greenhouse gas emissions for open-loop systems is estimated as 0.045 kilograms of carbon dioxide equivalent per kilowatt-hour, approximately. In closed-loop systems, these gases are not released into the atmosphere, but there are still some emissions associated with construction of plant and surrounding infrastructure (Union of Concerned Scientists). Currently in Turkey, single flash, double flash and binary cycle power plants are in operation. Since binary cycle is more feasible for low-and medium- enthalpy geothermal fields because of high concentration of calcium carbonate and NCG content of geothermal fluids, it is the most common cycle applied in Turkey (Kaplan and Serpen, 2010). Air-Cooled Binary System will be used in Sanko GPP. In this system geothermal fluid, is extracted from the underground reservoir and flows from the wellhead through a gathering system of insulated steel pipelines to a heat exchanger, which heats a secondary working fluid which has a low boiling point. In this system secondary working fluid is n-pentane, and is vaporized and used to drive the turbine. The organic fluid is then condensed in a condenser Final Report March 2018 Project No: 17/010 17 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment which is cooled by air. The condensed fluid is then recycled back to the heat exchanger, closing the cycle within the sealed system. Cooled geothermal fluid is then reinjected back into the reservoir. Since the system operates in close loop neither the geothermal fluid nor the secondary working fluid has contact with the environment or each other. Therefore binary systems have a longer economical life than the flash type plants. Because of the closed loop there is no loss of working fluid to the environment which is another advantage of the binary systems over flash type systems in terms of environmental impact. In a typical single-phase (pumped) binary power plant, the geothermal fluid is kept in liquid phase throughout the entire process. Usually, the geothermal fluid will have to be pumped from the well, but in exceptional cases, the wellhead pressure is high enough for the well to be self-flowing. To keep the NCGs in the liquid, it is necessary to maintain high pressure through the heat exchanging process. It is also possible to use chemical inhibitors to avoid precipitation of minerals such as calcite that can clog equipment and wells, resulting in additional repair costs. Full reinjection and “zero-emission” is possible for this cycle. If gas emission is to be prevented, the operating pressure needs to be kept high enough to prevent the NCGs from coming out of solution. The NCGs can be vented from the heat exchanger if reinjection is not preferred. In a two-phase (flash) binary power plant, the geothermal fluid is flashed in a separator. The steam and NCGs are used to boil the working fluid in the vaporizer. It may involve a preheater where the brine is used to heat the working fluid before it enters the vaporizer. Another common design is to have brine and steam both enter the vaporizer directly but keeping them separated through the process. As the steam passes through the vaporizer, it condenses and the NCGs are vented out of the vaporizer to prevent pressure build-up (Thrá nn Fridriksson, 2016). Two-phase (flash) binary system will be used at Sanko GPP Project where full reinjection and minimization of CO2 emissions is aimed. CO2 release from the Project is calculated and presented in Section 7.2.9. 2.7.3 Other Energy Generation Alternatives According to the Strategic Plan of Turkey for 2015-2019 published by the Ministry of Energy and Natural Resources, it is in significance importance to utilize the renewable energy resources of Turkey. Therefore increasing the use of renewable energy for electricity generation as well as for heating purposes is an objective of the Strategic Plan. Geothermal power plants based on geothermal resources provide renewable energy generation with low CO2, NOx and SOx gas emissions compared to fossil fuel combustion plants. Geothermal resources also enable various uses such as heating, mineral derivation besides energy generation. If the Project had not been located on a geothermal reserve, development of a solar power plant or thermal power plant could have been considered for the area. Although there would be less environmental issues to govern for a solar power plant much larger area would be Final Report March 2018 Project No: 17/010 18 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment required for the same power generation by the solar power plant i.e. approximately 24 ha would be required for the solar power plant project as compared to 7 ha to be used for the proposed project. Larger areas required for the realization of a solar power plant would lead to considerably high land acquisition costs. Regarding the opportunity for employment, less number of people would be employed during the construction and operation phases. Moreover considering the Project is located in an important geothermal resource area, establishing a solar power plant would lead to potential economic loss. Considering establishment of a coal fired power plant there are several environmental issues including cooling water requirement, disposal of ash, high cost for coal supply along with the need for coal storage areas and also emission control systems. 2.7.4 No Project Alternative The “no project” alternative would result in the continuation of the current situation, which would comprise of agricultural areas and unexploited geothermal water resources, and no development of the power plant planned in the Project. The Project is geared to meeting Turkey’s growing energy demand by means of renewable energy. Therefore, the “no project” alternative would result in a negative impact on national energy policies. The Project is located within a rural agricultural area with no species of conservation status. The level of economic development in the area is poor, so without the Project, there would be no new source of employment for the local communities. On the other hand the Project has environmental and social impacts which would not have occurred in the absence of the Project. Final Report March 2018 Project No: 17/010 19 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 3. LEGAL FRAMEWORK This ESIA study is carried out based on relevant national legislation as well as the lender’s guidelines. The main legislation and guidelines are mentioned in the following sections together with their implications for the Project stages. 3.1 Turkish Legislation The key national laws and regulations presented in this section include the legal requirements to reduce the potential environmental impacts that may arise from the construction and operational activities of the Project. Turkish Legislation related to the Project is presented in the following sections under relevant subtopics. 3.1.1 Turkish Environmental, Health and Safety (EHS) Legislation “Environmental Law”, which is ratified in August 1983 (amended with the Law July 7, 2015; No: 6486), is one of the principal legislation related to the Project. Several by-laws and decrees are enforced under the Environmental Law. The “Regulation on Environmental Impact Assessment (dated November 25, 2014; No: 29186 and amended on May 26, 2017; No: 30077)” defines the administrative and technical procedures and principles to be followed throughout the EIA process. It should be noted that the Project was previously listed under Annex-II, Article 49-a of the Regulation, and a Project Description Report was prepared accordingly. Therefore an EIA report was prepared for the Project and submitted to the Ministry of Environment and Urbanization. “EIA positive” decision was secured on February 14, 2017. The rest of the national EHS legislation that the Project will comply with is presented as Table 3-1 below. Final Report March 2018 Project No: 17/010 20 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 3-1. Turkish EHS Legislation Related to the Project Official Gazette Official Gazette Legislation Implications for the Project Stages Date Issue  Disposal of wastes generated by construction staff during construction Waste Management 02.04.2015 29314 stage and by operation staff during Regulation 23.03.2017 30016 the operation stage  Hazardous wastes generated at construction and operation stages  Discharge of wastewater generated Water Pollution Control 31.12.2004 25687 by site staff at construction stage Regulation 10.01.2016 29589 and by operation staff during the operation stage Regulation on Landfill 26.03.2010 27533  Drilling mud generated during the of Wastes 11.03.2015 29292 construction stage Waste Oil Control 30.07.2008 26952  Waste oils generated at construction Regulation 05.11.2013 28812 and operation stages Waste Vegetable Oil  Waste vegetable oils generated at 06.06.2015 29378 Control Regulation construction and operation stages Packaging Waste  Packaging wastes generated at 24.08.2011 28035 Control Regulation construction and operation stages Medical Waste Control 22.07.2005 25883  Medical wastes generated at Regulation 21.03.2014 28948 construction and operation stages Regulation on the 25.11.2006 26357  End-of-life tires generated at Control of End-of-life 11.03.2015 29292 construction and operation stages Tires Regulation on the 31.08.2004 25569  Waste batteries and accumulators Control of Waste generated at the construction and Batteries and 23.12.2014 29214 operation stages Accumulators Regulation on the Construction of Septic  Septic tanks for the collection of Tanks at Places Where 19.03.1971 13783 domestic wastewater generated at Sewer Construction is construction and operation stages Not Feasible Regulation on the Noise Emission in the 30.12.2006 26392  Noise levels caused by noise Environment from sources within the Project site at the Equipment for Outdoor 06.06.2017 30088 construction and operation stages Use 03.07.2009 27277  Dust emissions at the construction Industrial Air Pollution stage and CO2 emissions at the Control Regulation 20.12.2014 29211 operation stage Regulation on Assessment and 06.06.2008 26898  Emissions originating from the Management of Air 05.05.2009 27219 Facility during the operation stage Quality Regulation on the  Odorous emissions generated during Control of Odorous 19.07.2013 28712 the operation stage Emissions Final Report March 2018 Project No: 17/010 21 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Official Gazette Official Gazette Legislation Implications for the Project Stages Date Issue Regulation on Assessment and  Noise emissions at construction and 04.06.2010 27601 Management of operation stages Environmental Noise Regulation on Soil Pollution Control and 08.06.2010 27605  Risks of soil contamination at Point Source Polluted 11.07.2013 28704 construction and operation stages Areas Regulation on the 18.03.2004 25406  Transportation and disposal of Control of Excavation excavation waste and construction Soil, Construction and 26.03.2010 27533 debris at the construction stage Debris Wastes Law on Occupational Health and Safety 20.06.2012  Health and safety measures to be (6331) (as amended 01.07.2017 28339 taken during construction and with the Law numbered operation stages 7033) Regulation on Buildings to be 06.03.2007 26454  Construction works within the scope Constructed within the 03.05.2007 26511 of the Project Seismic Zones 3.1.2 Turkish Energy Legislation Project-related Turkish energy legislation is presented below in Table 3-2. Table 3-2. Turkish Energy Legislation Related to the Project Official Gazette Official Gazette Legislation Implications for the Project Stages Date Issue Electricity Market Law Rights and responsibilities of the Project No. 6446 (as amended 30.03.2013 Company regarding electricity production with the Law numbered 15.04.2015 28603 and transmission 6639) and relevant 01.07.2017 regulations Expropriation of private properties The Law No. 5346 on the Use of Renewable Procedures and principles of the Resources for the conservation and utilization of renewable Generation of Electrical 18.05.2005 25819 energy resource areas Energy (as amended 30.03.2013 with the Law numbered Certification of the energy generated 6446) and relevant from the utilization of these resources regulations Geothermal Resources and Natural Mineral Monitoring requirements regarding Water Law No. 5686 13.06.2007 geothermal resource preservation and (as amended with the 26551 01.03.2014 being the right-holder for these Law numbered 6527) resources and relevant regulations Final Report March 2018 Project No: 17/010 22 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 3.1.3 Turkish Legislation on Land Use The Project site is located on privately owned agricultural lands and agricultural lands and houses. According to the official letter from Provincial Directorate of Food, Agriculture and Livestock (PDoFAL) (dated 26.09.2016); required lands for the Project are in the scope of “Law on Soil Protection and Land Use”. According to the law agricultural lands cannot be used other than agricultural purposes other than the plans and investments with public interest consent from the Board of Ministry and investments on renewable energy resource areas providing compliance to soil conservation projects. It was stated in the official letter of the PDoFAL that the Project development in the subject area could be consented with the approval of Provincial Board of Soil Conservation. According to the statement of PDoFAL, receiving the required Land-use permits is an obligation for the Project Company. The Project secured public interest consent for Project development on agricultural lands as required on August 23, 2016 from the Energy Market Regulatory (EPDK) (Annex-4) Expropriation did not occur for the Project of 15 MW capacity and land purchase has been completed through voluntary purchase method. On the other hand land acquisition for the ETL is on-going through expropriation under the authority of TEDAŞ. The Project Company has issued agreements with the land owners for access authority to the lands before the completion of the expropriation process. According to the agreements negotiated prices for early access have been paid to the land owners. Project-related Turkish Legislation on Land-use is presented in Table 3-3. Table 3-3. Project-related Turkish Legislation on Land-use Official Gazette Official Gazette Implications for the Project Legislation Date Issue Stages Regulation on Geothermal Area Use for Electricity 14.10.2008 27024 Land acquisition and use Generation Expropriation Law No. 2942 (as amended with the Law 08.11.1983 Expropriation of private numbered 6645) (as amended 23.04.2015 18215 properties with the Law numbered 6754) 24.11.2016 and relevant regulations Pasture Law No. 4342 (as amended with the Law 28.02.1998 Permission(s) required for land numbered 6552) (as amended 31.01.2015 23272 use with the Law numbered 6824) 08.03.2017 and relevant regulations Law on Soil Conservation and Land Use No. 5403 (as 19.07.2005 Permission(s) required for land amended with the Law 25880 15.05.2014 use numbered 6537) and relevant regulations Law on Aquaculture Resources No. 1380 (as amended with the 04.04.1971 Law numbered 5996) ) (as Permission(s) required for land 13.12.2010 13799 amended with the Law use numbered 5957)and relevant 01.01.2012 regulations Final Report March 2018 Project No: 17/010 23 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Official Gazette Official Gazette Implications for the Project Legislation Date Issue Stages Law on Reclamation of Olive Cultivation and Inoculation No. 3573 (as amended with the 07.02.1939 Permission(s) required for land Law numbered 4086) (as 28.02.1995 4126 use amended with the Law 08.02.2008 numbered 5728) and relevant regulations 3.1.4 Turkish Legislation on Conservation of Nature and Wildlife Project-related Turkish legislation on Conservation of Nature and Wildlife is presented below in Table 3-4. Table 3-4. Project-related Turkish Legislation on Conservation of Nature and Wildlife Official Official Implications for the Project Legislation Gazette Date Gazette Issue Stages Conservation of the stream beds Wetland Conservation Regulation 04.04.2014 28962 located within the boundaries of the project site Regulation on the Management of Measures to be taken during Natural Assets, Natural Protected Areas, 02.05.2013 28635 chance finds at the construction and State-Owned Lands Located on stage Environmental Conservation Lands Law on Conservation of Cultural and Natural Assets No. 2863 (as amended 23.07.1983 Measures to be taken during with the Law numbered 6552) (as 20.08.2016 18113 chance finds at the construction amended with the Law numbered 6745) 07.09.2016 stage and relevant regulations Land Hunting Law No. 4915 (as 11.07.2003 Monitoring requirements amended with the Law numbered 6527) 25165 regarding hunting and terrestrial and relevant regulations 01.03.2014 wildlife The Project Company is required to secure the permits mentioned below in Table 3-5. Table 3-5. Permits Required for the Project Permit/License Date Progress “EIA Positive” decision February, 2017 EIA Decision secured from the Ministry of Environment and for the Power Plant Urbanization. “EIA Not Required” for May, 2010 Decision secured from the Provincial Directorate of Environment 3 production and 2 and Urbanization reinjection wells “EIA exclusion January, 2016 Decision secured from Provincial Directorate of Environment and decision” for additional Urbanization. 5 drilling wells Land-use Permit August 23, 2016 Consent secured from the the Energy Market Regulatory (EPDK) Final Report March 2018 Project No: 17/010 24 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 3.2 International Standards Since the potential lender for the Project is Development Bank of Turkey (TKB), the Project must be in compliance with good international practice, including World Bank (WB) Safeguard Policies, guides, performance standards and best practices documents alongside the National EHS Legislation. World Bank governs projects and activities by the Safeguard Policies in order to assure that they are conducted in an environmentally, financially and socially sound manner. Safeguard Policies include Environmental Assessments and other policies that define environmental and social adverse effects of the projects as well as their reduction and prevention. These policies are enlarged upon in “The World Bank Operations Manual”, which also provides guidance on compilation with the Operational Policies (OP), Bank Procedures (BP) and Good Practices (GP). OPS are defined as statements of policy objectives and operational principles including the roles and obligations of both the Borrower and the Bank, while BP are compulsory procedures to be followed by both the Borrower and the Bank and GP are non-compulsory advisory material. Specific policies related to the Project are listed below: Environmental Policies  OP/BP 4.01 Environmental Assessment  OP/BP 4.04 Natural Habitats Social Policies  OP/BP 4.11 Physical Cultural Resources BP 17.50 Bank Disclosure Policy The main objectives and tasks of the Project-related WB Safeguard Policies are explained below: OP/BP 4.01 Environmental Assessment - To ensure the proposed projects’ environmental and social sustainability and soundness - To inform decision-makers about the environmental and social risks - To increase transparency by providing stakeholder engagement in the decision- making process OP/BP 4.04 Natural Habitats - To conserve natural habitats and their biodiversity - To avoid significant conversion/degradation of critical natural habitats - To ensure the sustainability of services and products provided to human society by natural habitats OP/BP 4.11 Physical Cultural Resources Final Report March 2018 Project No: 17/010 25 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment - To ensure the identification and protection of Physical Cultural Resources (PCR), including archaeological and historical sites, historic urban areas, sacred sites, graveyards, burial sites and unique natural values - To ensure the compliance with national legislation regarding the protection of physical cultural property OP/BP 4.12 Involuntary Resettlement - To avoid or minimize involuntary resettlement where feasible, exploring all viable alternative project designs; - To assist displaced person in improving their former living standards; it encourages community participation in planning and implementing resettlement; - To provide assistance to affected people, regardless of the legality of title of land. BP 17.50 Bank Disclosure Policy - To support the decision-making process by allowing public access to information on environmental and social aspects of projects. Under the Operational Policy for Environmental Assessment (OP 4.01), WB conducts an environmental scanning and classifies the proposed projects under Categories A, B and C, based on the level of their likely environmental impacts. Furthermore, Category B projects divide in two within its structure as B and B+, based on the special circumstances of the project in question. Final Report March 2018 Project No: 17/010 26 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 4. METHODOLOGY 4.1 Area of Influence The Area of Influence (AoI) is an important element in assessing environmental and social impacts of a proposed development since it lets us know the physical and/or social extent in which the assessment should be performed. According to the definition given in Performance Standard 1 of the IFC, the AoI encompasses, as appropriate:  The area likely to be affected by: (i) the project1 and the client’s activities and facilities that are directly owned, operated or managed (including by contractors) and that are a component of the project; 2 (ii) impacts from unplanned but predictable developments caused by the project that may occur later or at a different location; or (iii) indirect project impacts on biodiversity or on ecosystem services upon which Affected Communities’ livelihoods are dependent.  Associated facilities, which are facilities that are not funded as part of the project and that would not have been constructed or expanded if the project did not exist and without which the project would not be viable.3  Cumulative impacts4 that result from the incremental impact, on areas or resources used or directly impacted by the project, from other existing, planned or reasonably defined developments at the time the risks and impacts identification process is conducted. The AoI of the Project is provided below in Figure 4-1. 1 Examples include the project’s sites, the immediate airshed and watershed, or transport corridors. 2 Examples include power transmission corridors, pipelines, canals, tunnels, relocation and access roads, borrow and disposal areas, consruction camps, and contaminated land (e.g., soil, groundwater, surface water, and sediments). 3 Associated facilities may include railways, roads, captive power plants or transmission lines, pipelines, utilities, warehouses, and logistics terminals. 4 Cumulative impacts are limited to those impacts generally recognized as important on the basis of scientific concerns and/or concerns from Affected Communities. Examples of cumulative impacts include: incremental contribution of gaseous emissions to an airshed; reduction of water flows in a watershed due to multiple withdrawals; increases in sediment loads to a watershed; interference with migratory routes or wildlife movement; or more traffic congestion and accidents due to increases in vehicular traffic on community roadways. Final Report March 2018 Project No: 17/010 27 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 4-1. AoI of the Project Final Report March 2018 Project No: 17/010 28 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment AoI for Environmental Impacts The AoI was determined mainly to cover the impacts on the footprint and the vicinity of the Project as well as the impact area regarding air emissions. In this respect a 8x8 km impact area was selected for H2S emissions assessment which also covers the area for the closest sensitive noise receptor. For the assessment of construction and operation noise levels due to the Project the closest sensitive receptor which is Yılmaz Neighbourhood at a distance of 600 m was included in the AoI. With regards to groundwater quality, sampling from the existing two wells at the Project site close to the production well SAN-4 has been conducted. Baseline data on soil quality assessment and the ecological surveys were also included in the AoI. AoI for Social Impacts The AoI for social impacts is determined by considering the impacts sourced from land acquisition, workers’ accommodation, noise during construction and operation phase, labour influx, changes on dust and air quality. The settlement in which experienced land allocation due to Project activities and / or the closest settlement to the Project Site that may experience primarily environmental impacts of the Project will be considered as the first impact zone. In other words, the first impact zone may experience direct impacts of the Project. Therefore, Yılmaz neighbourhood, being the closest settlement in which may experience direct environmental and social impacts and experienced almost all land acquisition for the first phase of the Project, is considered within the first impact zone. Sanko used voluntary purchase method for land take of the area required for the Project. Land take process and payment for the purchased lands have been completed and there will be no more land acquisition for the Project. Further information on Project’s land allocation can be found in Section 8.2 of this Report. Last, it is important to note that, there has been no physical displacement caused due to Project activities. Second impact zone may cover majority of the indirect Project impacts such job opportunities, providing of goods and service. Therefore, the second impact zone will cover the settlements as Gaffar Okan, Hasalan and Caferbey. Also, changes on dust and air quality may be experienced in the second zone as well since the most distant settlement, Caferbey, is 2 km away from the Project Site. 4.2 Methodology for the Baseline Assessment Environmental baseline data have been compiled through available reports, literature review and onsite measurements performed by 2U1K. Onsite sampling and measurements include the following:  Background noise measurements at Yılmaz Neighbourhood.  PM10 sampling and analysis at Yılmaz Neighbourhood. Final Report March 2018 Project No: 17/010 29 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment  Passive sampling at Yılmaz Neighbourhood, Power Plant area, Well no: SAN-3, Near Lider Tarım, Caferbey Neighbourhood, Çatılı Neighbourhood, Gaffar Okan Neighbourhood, Karapınar Neighbourhood, Hasalan Neighbourhood, Near the Power Plant  Groundwater analysis Quantitative and qualitative data have been compiled for social baseline of the Project. Primary data obtained for the Project Community level assessments were conducted between July 4-6, 2017 for the purpose of gathering primary data, and include the following:  4 focus group meetings held for each neighbourhood,  5 in-depth interviews with the government agencies and non-governmental organizations in the district and the province.  2 in-depth interviews with the locals who sold their lands to the Project Company,  Community level surveys with the Mukhtars of the AoI. Female Focus Group Discussions were not able to conduct due to cultural conditions of the AoI. All of the Mukhtars of the AoI declined to set a meeting with for female focus group. Secondary data was collected and prepared through regional and national statistics, newspaper archives and project documents. Secondary data holds an important role in reaching key stakeholders and project affected people before designing the field study. Information gathered from the secondary data increases the quality of field study and time efficiency during the field study. Sources of information generally used for the SIA are:  Data from Turkish Statistical Institute (TURKSTAT),  Information from Salihli Municipality,  Evaluation reports of Non-Governmental Organizations,  National EIA Report and its appendices dated on 02.01.2017, Information on social parameters, gathered during public participation meetings. 4.3 Methodology for the Impact Assessment Identification and evaluation of impacts begin with the stage of scoping process. Impact assessment is a result of determining the possible impacts of project related activities within the aspects of physical, biological and social environment. During the impact assessment of the Project, possible interactions between the Project and surrounding environment have been defined, in order to provide the entire potential Project related impacts. In that aspect, impact is defined as changes originated from project and project related activities. In order to recognize impacts, the baseline study of the AoI has been established. General nature and types of the impacts categorized in Table 4-1 shown below. Final Report March 2018 Project No: 17/010 30 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 4-1. Impact Types and Definitions Impact Type Definition Positive Impacts that make positive changes over the current conditions. Negative Impacts that leads to new and undesirable changes over the current conditions. Direct Direct impacts occur through direct interaction of an activity with an environmental, social, or economic component. Indirect Impacts which are not a direct result of the project, often produced away from or as a result of a complex impact pathway. Cumulative Impacts that consist of an impact that is created as a result of the combination of the project evaluated in the current project together with other projects causing related impacts. As seen in Table 4-2, impacts may occur as positive, negative, direct, indirect and cumulative. Determination of the type of impact is the important step of the assessment process. The determination of the impact type is based on geographical size, duration, significance and likelihood of the impact. Table 4-2 below provides information regarding the process of determining impact significance, respectively. Final Report March 2018 Project No: 17/010 31 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 4-2. Impact Criteria Project Area: potential impacts that only cover the borders within the construction site. Impact Extent Local: potential impacts area that covers 20 km within the construction activities of the project. Regional: potential impacts that cover the throughout the district level. National: potential impacts that expected to create changes in national level. Temporary: extend of the impacts expected to be less than 6 months. Short-term: impacts that are expected to only occur during the construction phase of the project. Impact Duration Long-term: impacts that are expected to occur throughout the operation phase of the project. Permanent: impacts that are expected to be permanent to the project affected people. Not likely: impacts that are not likely to occur. Likelihood of Impact Likely: impacts that are likely to occur in most circumstances. Certain: the outcome of impacts will certainly occur. Negligible: There is perceptible change to people’s lives Low: Communities are able to adapt with relative ease Impact Magnitude Medium: Communities are able to adapt with some difficulty High: Affected people/communities will not be able to adapt to changes For the determination of impact significance, the matrix below is used: Table 4-3. Significance Rating Likelihood Unlikely Likely Certain Negligible Insignificant Insignificant Insignificant Low Insignificant Minor Minor Impact Magnitude Medium Minor Moderate Moderate High Moderate Major Major Impact reversibility is used in order to finalize overall impact assessment. Reversibility can be applied with the use of the matrix below: Table 4-4. Overall Impact Rating High Medium Low Impact Reversibility Irreversible Reversibility Reversibility Reversibility Insignificant Insignificant Insignificant Insignificant Insignificant Minor Insignificant Insignificant Low Medium Impact Significance Moderate Low Low Medium High Major Low Medium High Critical Final Report March 2018 Project No: 17/010 32 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 5. ENVIRONMENTAL BASELINE Baseline assessment is comprised of field studies and desk-top review of various sources of information. Baseline assessment is focused on a series of environmental components, as listed below:  Geology and earthquake risks  Climate  Hydrology and surface water quality  Groundwater quantity and quality  Noise  Air quality  Soil quality  Ecology Given that the Project is categorized as a Category B+ investment with limited significant impacts, a partial impact assessment is performed by 2U1K. In this respect, the ESIA Report is based on onsite baseline measurements and social surveys, as well as environmental and social reports developed formerly for the Project. Table 5-1. Scoping of Environmental Issues Project Environmental Possible Impacts Baseline Parameters Activities Issue  Discharge of drilling fluids including extracted water from exploration and operational wells  Groundwater quality Drilling Effluent discharge during testing.  Soil quality  Discharge of domestic wastewater from camp  Surface water quality site  Storage and disposal of drilling mud including  Groundwater quality Drilling Drilling Mud  Soil quality cuttings Groundwater  Contamination of groundwater resources in Drilling case of percolation of thermal groundwater  Groundwater quality contamination during drilling and testing.  Soil quality Drilling Solid Waste  Storage and disposal of solid waste.  Groundwater quality Drilling Noise  Drilling rig, generators, traffic, etc.  Environmental noise  Possible toxic gas emissions during drilling  Climate Drilling, and well testing (hydrogen sulfide) Air Emissions  Air Quality (PM10, Construction,  Dust emission due to site activities, H2S) arrangement of drilling rig area, traffic etc.  Disturbance of natural habitats from Drilling and construction, e.g. dust, noise, un-seasonal  Flora Ecosystem  Fauna Construction working, poor siting of new works, disposal of untreated wastes, etc. Final Report March 2018 Project No: 17/010 33 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Project Environmental Possible Impacts Baseline Parameters Activities Issue  Loss of topsoil during preparation of rig sites, or disposal of excavated materials Drilling and  Damage to soil structure due to material  Soil quality Soil Construction storage, traffic, etc.  Erosion due to uncontrolled surface run-off where vegetation is cleared Emergency and Drilling environmental  Well blowout during drilling - safety  Possible over flow from mud pit. Drilling and  Contamination/pollution of resource, drilling  Soil and groundwater Water Resources quality Operation chemicals, fuel & oil, hazardous wastes, wastewater, etc. 5.1 Geology and Earthquake Risks Geology and earthquake risks for the Project area is assessed in the following section based on the information compiled from the EIA report and Geological-Geotechnical Survey report of the Project area. The Project area is located at the west of Salihli District Center at both sides of İzmir-Ankara Highway. The Project area falls into the southern part of Gediz Graben. Geological feature around Salihli is quite plain: The region is made up of metamorphic rocks and karstic marbles belonging to the Mesozoic Menderes Massif. Gediz Graben is a WNW – ESE trending half graben with a length of 140 km, at the north of Menderes Massif lying between Kemalpaşa-Sarıgöl. Gediz Graben is considered to have an uncommon graben structure and the evolution of the graben is based on late detachment of Menderes Massif under tensile stress. Regional geology is provided below in Figure 5-1. The Project is located on a flat topography without natural disaster risks such as landslide risks, rock fall and avalanche. It is stated in the EIA report that landslide risk is not defined for the Project area according to Turkey Landslide Inventory Map published by The General Directorate of Mineral Research and Exploration (MTA). Final Report March 2018 Project No: 17/010 34 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 5-1. Geology in the Region Final Report March 2018 Project No: 17/010 35 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Manisa Province is within 1. Degree Earthquake Risk Zone. There have been 482 earthquakes recorded in West Anatolian Region and around belonging to historical period. 73% of the earthquakes is recorded with a magnitude of 5.5 M and below. Although Gediz Graben is quite explicit morphologically between Sarıgöl-Salihli, faults which restrict the area, intersect metamorphic rocks, Myosene, Pliosene and Quaternary rocks. Detachment fault which restrain the graben along the southern side is the main structural element of the system. There is a series of synthetic and antithetic fault laying broadly parallel along the of the southern border of the graben. On the northern border of the detachment fault, there is the antithetic structure. Graben with WNW-ESE elongation widens to west direction after passing Salihli and separated into branches. Manisa fault passes at a distance of approximately 2,000 m from the south of the Project area. Manisa fault falls within the northwest branch of Gediz Graben. Closest active fault is Manisa Active Fault at a distance of approximately 2,500 m to the southern border of the Project area according to the MTA Active Faults Map. Topographical map of the region is provided in Figure 5-2. Figure 5-2. Topographical Map of the Region Final Report March 2018 Project No: 17/010 36 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment A Geological-Geotechnical Survey was conducted for the Project Area in October, 2016. Geophysical survey was also conducted for the Project area within the abovementioned study. Seismic tests were performed in order to calculate S and P waves and then ground dynamic elastic parameters are determined using the measured velocity. Earthquake risk analysis was also conducted within the scope of Geological-Geotechnical Survey for the Project area. 100 km radius area between 27.30°-29.36° E and 37.43°-39.24° N is investigated for possible earthquake impacts on the Project area. Seismic risk analysis has been conducted based on 53 earthquakes which occurred between 1900-2010 with magnitude of 4.5 and higher. Data on earthquakes were based on Boğaziçi University, Kandilli Observatory databank. Linear relation between earthquake number and magnitude is determined using Gutenberg- Richter (a and b coefficient) parameters obtained from frequency-magnitude linear regression. Gutenberg-Richter parameters obtained are given below Table 5-2. Table 5-2. Gutenberg-Richter Parameters LogN=a-bM results a 4.90 b 1.11 Coefficient 0.62 Earthquake number-magnitude relation based on Gutenberg-Richter parameters is determined as Log (N)=4.90-1.11M. The probability of earthquake occurrence with a magnitude of higher than 5.0, 5.5 and 6.0 in 5 and 10 years is given below in Table 5-3. Table 5-3. Earthquake Occurrence Probability Earthquake Occurrence Probability Earthquake Return Magnitude N1 5 years 10 years Period 5.0 65.9 88.4 0.53 5 5.5 25.8 44.9 0.1 17 6.0 7.9 15.3 0.04 60 As can be seen at the table, the probability of occurrence of an earthquake with 6.0 magnitude in 10 years is 15% in the project area. The exposure risk to earthquake for the buildings in the investigation area is high regarding the lifetime of the buildings. Therefore all the buildings will be constructed in line with the required structure standards and the outputs obtained from geotechnical study. Since the project area is within the 1st Degree Earthquake Zone all structures will be constructed in compliance with the provisions of the Regulation on the Buildings to be Constructed at Final Report March 2018 Project No: 17/010 37 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Earthquake Zones. The requirements of the regulation apply for the power plant building but not for drilling wells, pipeline or the ETL. However the drillings of deep wells are performed based on critical geotechnical parameters. It was also stated in the report that the investigation area has not been classified as “Zone with Exposure to Disaster”. The Project is located on a flat topography with 1° %-10°% slope. Project area is made up of Quaternary Alluvium (Qal) unit according to MTA 1/25000 scale geological map. Drilling works for the study comprised of 5 geotechnical drilling of 15 meters and 2 geotechnical drillings of 20 meters. Topsoil of 50 cm, and below silty sand up to 20 meters and silty gravel units were observed along with low plasticity inorganic silt. Groundwater level is observed at 10 meters depth. Liquefaction is expected between 13.50-20 meters at SK-1, 13.5-15 meters at SK-2, 12-15m at SK-3, 10.50-15m at SK-4, 10.5-15 at SK-5, 12m-20m at SK-6 and at 12-15 m at SK-7. According to the liquefaction analysis, liquefaction at 10.5 m-20 meters is expected. The area is classified as Areas with Preventive Measures with regards to availability for settlements. The area is suggested to be improved by methods such as injection techniques, jet grouting, cement injection for avoiding liquefaction. 5.2 Surface Water and Groundwater Quality The Project area is within “Gediz River Basin”. According to the topographical map provided in the EIA report, there are 2 rivers, 1 lake and 1 dam pond around the Project area. Gölmarmara Lake is about 11.5 km to the Project area. Demirköprü Dam is at about 24 km. Gediz River and Kurşunlu Stream which is a branch of Gediz River is at about 2 km and 2.2 km respectively. Since the Project area is located in agricultural lands there are irrigation channels close to the Project area. An irrigation channel which connects to Tabakçayı Stream passes at a distance of 1,800 m and another irrigation channel at a distance of 360 m from the west and north of the Project Area respectively. These two channels merge at a distance of 2,350 m northwest. There is also a drying channel at the west of the Project area with a distance of 500 m. No impact is expected on surface water due to the Project activities according to the EIA report of the Project, nevertheless all Project activities will be conducted with compliance to the requirements of the Regulation on Regulation on Conservation of Wetlands (Official Journal Issue: 27684, Date: 26.08.2010). Any intervention to stream beds in or within the vicinity of the Project area will be avoided, cadastral and existing bed widths will be protected and no activity restraining the flow of the water source will be prevented. The borders of the study area will be determined and drying canals or stream beds will not be used in any case. There are 2 groundwater wells within the Project area at a distance of approximately 50 m and 80 m to well SAN-4 respectively. Existing two groundwater wells were selected for Final Report March 2018 Project No: 17/010 38 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment sampling in order to determine the baseline groundwater quality conditions at the Project site. Groundwater analysis has been conducted for physical, chemical and microbiological properties of the groundwater regarding the “Regulation on Water for Human Consumption” (Official Journal Issue: 25730, Date: 17.02.2005) and Regulation on Monitoring of Surface Water and Groundwater (Official Journal Issue: 28910, Date: 11.02.2014) Annex-2 “Minimum Monitoring Parameters” during the EIA process of the Project. Comparison according to the requirements of the “Regulation on Water for Human Consumption” is provided in Table 5-4 below: Table 5-4. Groundwater Analysis Results regarding “Regulation on Water for Human Consumption” Results Results Parameter Unit Limit (Well 1) (Well 2) Fungucites Pencanazole µg/L 0.1 Not detected Not detected Metalaxyl µg/L 0.1 Not detected Not detected Tebuconazole µg/L 0.1 Not detected Not detected Diniconazole µg/L 0.1 Not detected Not detected Herbicites Simazin µg/L 0.1 Not detected Not detected Atrazin µg/L 0.1 Not detected Not detected Carbamates Aldicarb µg/L 0.1 Not detected Not detected Propoxur µg/L 0.1 Not detected Not detected Oxamyl µg/L 0.1 Not detected Not detected Methomyl µg/L 0.1 Not detected Not detected- Methiocarb µg/L 0.1 Not detected Not detected Carbofuran-3-hydroxy µg/L 0.1 Not detected Not detected Carbofuran µg/L 0.1 Not detected Not detected Carbaryl µg/L 0.1 Not detected Not detected Aldicarb-sulfoxide µg/L 0.1 Not detected Not detected Aldicarb-sulfane µg/L 0.1 Not detected Not detected Chemical analysis Boron mg/L 1 1.959 2.045 Manganese µg/L 50 Not detected 9.2 Iron µg/L 200 25,3 34.3 Nickel µg/L 20 Not detected Not detected Mercury µg/L 1 Not detected Not detected Lead µg/L 10 Not detected Not detected Aluminium µg/L 200 21,2 24.4 Final Report March 2018 Project No: 17/010 39 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Results Results Parameter Unit Limit (Well 1) (Well 2) Selenium µg/L 10 Not detected Not detected Copper mg/L 2 Not detected Not detected Chromium µg/L 50 Not detected Not detected Cadmium µg/L 5 Not detected Not detected Arsenic µg/L 10 Not detected Not detected Antimony µg/L 5 Not detected Not detected Acceptable by consumers and Color (Physical) - Compliant Compliant there is no anomaly. Acceptable by consumers and Odor (Physical) - Compliant Compliant there is no anomaly. Acceptable by consumers and Turbidity (Physical) -- Compliant Compliant there is no anomaly. Oxidizability mg/L 5 0.8 0.6 Sodium mg/L 200 49,4 57.7 Ammonium mg/L 0,5 Not detected Not detected Sulfate mg/L 250 81,6 97.7 Chloride mg/L 250 34,1 38.4 Nitrate mg/L 50 68,1 85.1 Fluoride mg/L 1,5 0,13 0.14 Nitrite mg/L 0,5 Not detected Not detected Conductivity 20ºC’de µS/cm 2500 688 824 Bromate µg/L 10 Not detected Not detected Total Cyanide µg/L 50 Not detected Not detected pH pH unit 6,5 – 9,5 6.9 7 Microbiological Analysis Total germ count in 22ºC kob/mL - 8 >300 Enterococci/Fecal kob/100mL 0 0 1 Streptococci Escherichia Coli kob/100mL 0 0 0 Coliform Bacteria kob/100mL 0 0 0 Monomer Compounds Vinyl Chloride µg/L 0,5 Not detected Not detected Epichlorhydin µg/L 0,1 Not detected Not detected Organophosphorus Compounds Chlopyriphos-methyl µg/L 0,1 Not detected Not detected Final Report March 2018 Project No: 17/010 40 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Results Results Parameter Unit Limit (Well 1) (Well 2) Parathion-ethyl µg/L 0,1 Not detected Not detected Quinalphos µg/L 0,1 Not detected Not detected Chlorpyriphos-ethyl µg/L 0,1 Not detected Not detected Methamidophos µg/L 0,1 Not detected Not detected Malathion µg/L 0,1 Not detected Not detected Ethion µg/L 0,1 Not detected Not detected Disulfoton µg/L 0,1 Not detected Not detected Diazinon µg/L 0,1 Not detected Not detected Azinphos-ethyl µg/L 0,1 Not detected Not detected Azinphos-methyl µg/L 0,1 Not detected Not detected Organochloride Compounds Total DDT (op-DDT. Pp- µg/L 0,1 Not detected Not detected DDT.pp-DDD.pp-DDE) Beta-Endusulfan µg/L 0,1 Not detected Not detected Alpha-Endosulfan µg/L 0,1 Not detected Not detected Dieldrin µg/L 0,03 Not detected Not detected Aldrin µg/L 0,03 Not detected Not detected Heptachloreposide(Endo) µg/L 0,03 Not detected Not detected Heptachlor µg/L 0,03 Not detected Not detected Gamma-HCH (Lindane) µg/L 0,1 Not detected Not detected Alpha-HCH (BHC) µg/L 0,1 Not detected Not detected HCB µg/L 0,1 Not detected Not detected Beta BHC µg/L 0,1 Not detected Not detected Endrin µg/L 0,1 Not detected Not detected Chlorfenvinphos µg/L 0,1 Not detected Not detected Total Pesticide µg/L 0,5 Not detected Not detected Polycyclic Aromatic Hydrocarbons Fluoranthene µg/L Not detected Not detected Total PAH µg/L 0,1 Not detected Not detected Indeno(1.2.3-cd)pyrene µg/L Not detected Not detected Benzo (ghi)perylene µg/L Not detected Not detected Benzo (k) fluoranthene µg/L Not detected Not detected Benzo (b) fluoranthene µg/L Not detected Not detected Benzo (a) pyrene µg/L 0,01 Not detected Not detected Volatile Organic Compounds Bromodichloromethane µg/L Not detected Not detected Dibromochloromethane µg/L Not detected Not detected Final Report March 2018 Project No: 17/010 41 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Results Results Parameter Unit Limit (Well 1) (Well 2) Bromoform µg/L Not detected Not detected Chloroform µg/L Not detected Not detected Total Trihalomethanes µg/L 100 Not detected Not detected 1,2 – Dchloroethane µg/L 3 Not detected Not detected Benzene µg/L 1 Not detected Not detected Tetrachloroethene and µg/L 10 Not detected Not detected trichloroethene According to the analysis report groundwater from Well 1 does not comply with the regulation requirements in terms of Boron and Nitrate. Groundwater from Well 2 does not comply with the requirements of the regulation in terms of Boron, Nitrate and Enterococcus/Faecal StreptococciProject is located within agricultural lands, where the use of fertilizers with nitrate content is likely. Nitrate levels in the samples might be considered to be elevated due to the on-going agricultural activities around the Project area. Along with the agricultural areas around the Project area, there are also settlements of which the closest are Yılmaz, Hasalan and Caferbey neighborhoods. Domestic wastewater of Yılmaz and Caferbey neighborhoods is discharged to the sewer system and domestic wastewater of Hasalan neighbourhood is discharged to septic tank. Enterococcus/Faecal Streptococci observed in the samples might be originating due to the anthropogenic activities in the area. Although Boron is found within Manisa Province borders according to the EIA report, there is no information of Boron mining activities in Salihli District. According to the “Background document for development of WHO Guidelines for Drinking-water Quality” the borate content of surface water can be significantly increased as a result of wastewater discharges, because borate compounds are ingredients of domestic washing agents. Naturally occurring boron is present in groundwater primarily as a result of leaching from rocks and soils containing borates and borosilicates. Therefore boron concentration might also be caused due to anthropogenic activities in the region. Final Report March 2018 Project No: 17/010 42 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Comparison of the analysis results with Regulation on Monitoring of Surface Water and Groundwater is provided in Table 5-5 below: Table 5-5. Results of Ground Water Quality Analysis regarding “Regulation on Monitoring of Surface Water and Groundwater” Test Results Test Results Parameter – Unit (Well 2) (Well 1) Ammonium (mg/L) <0.05 <0.055 Dissolved Oxygen (mg/L) 5.06 5.11 Conductivity (µS/cm) 591 679 Nitrate(mg/L) 37.10 70.55 pH 7.07 7.04 It should be noted that the results of analyses are not indicative of contamination, but only a presentation of the baseline groundwater. Hence, the results cannot be attributed to any interpretation of Project impacts. 5.3 Climate Climate properties of the Project region are summarized in the following section based on the information provided in the EIA report. Climate in the region is dominated by Mediterranean climate characteristics, hot and dry summers and warm and rainy winters. The Menderes river valley enhances the warmth of the sea and winds that bring rain towards the inner land. Although different climate characteristics can be observed at the same region in Turkey, temperature and precipitation characteristics are similar both at the coastal parts and the inner parts of Aegean Region. The effects of the sea reach also to the inner parts. However precipitation amount significantly differs seasonally. Precipitation is densely observed as rain at the coasts and as snow at the inner parts in winter. In summer, precipitation is rarely observed due to high temperature and evaporation. Meteorological and climate properties of the Project area have been evaluated based on the data for the years 1960-2015 obtained from Salihli Meteorological Station. It was observed that the average temperature According to the long term data; average annual temperature is 16.6 °C, average highest temperature is 23.1°C and lowest temperature is 10.2 °C. Highest measured temperature is 48°C in July and lowest measured temperature is -13.5 °C in February. Average annual precipitation is 457.9 mm and the highest recorded daily precipitation is on January with 71.2 mm. The highest average precipitation is recorded in December with 78.5 and lowest precipitation is recorded in August with 4.8 mm. Final Report March 2018 Project No: 17/010 43 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Dominant wind direction is West at the Project area. West direction is followed by West- Northwest and West-Southwest directions. Annual average wind speed is 1.5 m/sn with the highest value in July and the lowest value in November. 5.4 Soil Quality During the EIA process of the Project soil quality analysis has been conducted at the Project area in order to define baseline soil conditions regarding the “Regulation on Soil Pollution Control and Point Source Polluted Areas” Annex-1: Limit Values for Generic Pollutants. Range of parameters analysed in soil samples include: total organic halogens, antimony, arsenic, copper, barium, boron, mercury, cadmium, zinc, chromium, lead, molybdenum, selenium and total petroleum hydrocarbons. Test results are given below in Table 5-6. Detailed laboratory reports are available in Annex-1. Table 5-6. Results of Soil Quality Analysis Limit Values Transport of Absorbtion by Inhalation of Pollutants to Test Inhalation of Parameters Ingestion and Volatile Groundwater and Results Fugitive Dust Through Skin Substances Ingestion of Groundwater (mg/kg dry soil) DF*=10 DF=1 Arsenic (mg/ kg) 5.78 0.4 - 471 3 0.3 Antimony (mg/ kg) <2.5 31 - - 2 0.2 Copper (mg/ kg) 57.06 3129 - - 514 51 Barium (mg/ kg) 86.39 15643 - 433702 288 29 Zinc (mg/ kg) 87.49 23464 - - 6811 681 Mercury (mg/ kg) <0.025 23 3 - 3 0.6 Cadmium (mg/ kg) 0.49 70 - 1124 27 3 Lead (mg/ kg) 4.18 400 - 135 14 Molybdenum (mg/ kg) <2.5 391 - - 14 1 Selenium (mg/ kg) 6.98 391 - - 14 1 Total Chromium (mg/ kg) 16.75 235 - 24 900000 1 Total Petroleum Hydrocarbons (Aliphatic) 9.9 4693 - - 4 0.4 (EC5-EC8) (mg/ kg) Total Petroleum Hydrocarbons (Aliphatic) 32.29 7821 - - 7 0.7 (EC8-EC16) (mg/ kg) Total Petroleum Hydrocarbons (Aliphatic) 5.44 156429 - - 146 15 (EC16-EC35) (mg/ kg) Total Organic Halogens 31.47 - - - - - (TOX) (mg/ kg) Boron (mg/ kg) 1209 0.4 - 471 3 0.3 *Dilution Factor Final Report March 2018 Project No: 17/010 44 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 5.5 Air Quality 2U1K has performed air quality analyses in order to define baseline parameters related with PM10 and H2S impacts of the Project. PM 10 measurement was conducted at one location at Yılmaz Neighbourhood on 05-06 July 2017 and 08-09 July 2017 including both weekdays and weekend. Test results for PM10 are presented in Table 5-7, which indicate that the current dust emissions are slightly above limits designated in the Regulation on Control of Industrial Air Pollution (Table 2.2 of Annex-2 of the Regulation). The area is comprised of agricultural lands without any industrial facilities close to the measurement location. Although construction is on-going at the Project area, dust generating activities are limited. İzmir-Uşak highway passes at the south of the project area which may be considered as the dust emission source at the area. The increase on the weekends also might be the indication of the increased traffic on the road. Table 5-7. Results of PM10 Measurements Industrial Air Pollution PM10 Control Regulation Measurement Coordinates Measurement Concentration Air Quality Limits for 2017 Location (UTM ED50) Period 3 3 (µg/m ) (µg/m ) 24-hour value 1-year value E: 0595381 Weekday 71 Yılmaz Mahallesi 70 48 N: 4261099 Weekend 68 Within the scope of air quality sampling studies for the Project, passive sampling for H2S was conducted between 05.07.2017-04.08.2017 and 04.08.2017-03.09.2017 at 10 points for which the coordinates and analysis results are provided below in Table 5-8 and Table 5-9, respectively. Table 5-8. Coordinates of H2S Sampling Points Coordinates(UTM ED50) No Sampling Location E N 1 Yılmaz Neighbourhood 595368 4261090 2 Power Plant Area 595321 4260939 3 Well no: SAN-3 595272 4261561 4 Lider Tarım 594224 4261502 5 Caferbey Neighbourhood 593700 4259049 6 Çatılı Neighbourhood 592412 4259617 7 Gaffar Okan Neighbourhood 596594 4260404 8 Karapınar Neighbourhood 597102 4264803 9 Hasalan Neighbourhood 593196 4262601 10 Near the Power Plant 594378 4260716 Final Report March 2018 Project No: 17/010 45 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 5-9. Results of H2S Measurements Industrial Air Pollution Control Regulation H2S Concentration Air Quality Limits for 2017 No Sampling Location 3 (μg/m ) st nd 1 Period 2 Period 1-hour value STV* value 3 3 (μg/m ) (μg/m ) 1 Yılmaz Neighbourhood 0.27 0.05 100 20 2 Power Plant Area 0.30 0.08 3 Well no: SAN-3 0.39 0.07 4 Lider Tarım 0.38 0.07 5 Caferbey Neighbourhood 0.33 0.05 6 Çatılı Neighbourhood 0.37 0.14 7 Gaffar Okan Neighbourhood 0.35 -** 8 Karapınar Neighbourhood 0.34 0.08 9 Hasalan Neighbourhood 0.42 0.08 10 Near the Power Plant 0.42 0.05 *STV: Short Term Value ; **: Sampling tube missing Table 5-9 above, H2S concentrations at all sampling locations are below the limit values of Industrial Air Pollution Control Regulation. 5.6 Environmental Noise 2U1K performed noise measurements on July, 2017 in order to define baseline parameters as related with noise impacts of the Project. Measurements were conducted on weekdays and weekend days at the nearest settlement unit of Yılmaz Neighbourhood for 24 hours. The coordinates of the noise sensitive receptor is given below in Table 5-10. Table 5-10. Coordinates of Noise Sensitive Receptor Coordinates(UTM ED50) Noise Sensitive Name of the Settlement Receptor E N 1 Yılmaz Neighbourhood 595368 4261092 Satellite image showing the power plant and the closest noise receptor is provided below in Figure 5-3. Final Report March 2018 Project No: 17/010 46 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 5-3 Closest Noise Receptor Distance of the closest noise receptor to the Project units are provided below in Table 5-11. Table 5-11 Distance of Noise Sensitive Receptor to the Project Area Distance of the Noise Sensitive Well No. Receptor Power Plant 179 m Distribution Centre 237 m SAN-3 479 m SAN-4 320 m SAN-5 316 m SAN-6 326 m SAN-7 952 m SAN-8 942 m Noise surveys were conducted on 05-06 July and 08-09 July, 2017 for 24 hours in order to determine existing background noise level at the nearest sensitive receptor. The results of the measurement were compared with the limits of IFC/World Bank Group Environmental, Health and Safety Guidelines and Turkish Regulation on Assessment and Management of Environmental Noise (RAMEN). Since construction works are on-going at the Project area Final Report March 2018 Project No: 17/010 47 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment background noise measurements included the noise generated by Project activities. Therefore measured noise levels are compared with construction noise limit level of 70 dBA of the RAMEN. Table 5-12. Background Noise Measurement Results (daytime, evening and nighttime) Average Measured Measured Noise Date Period Hours Noise Level Level Leq (dBA) Leq (dBA) 07:00-08:00 49.4 08:00-09:00 52.3 09:00-10:00 51.7 10:00-11:00 51.8 11:00-12:00 50.7 Day-time 12:00-13:00 47.8 44.3 (07:00-19:00) 13:00-14:00 51.9 14:00-15:00 50.5 15:00-16:00 52.1 16:00:17:00 55.3 17:00-18:00 56 Weekday 18:00-19:00 55.8 19:00-20:00 51.7 Evening 20:00-21:00 52.7 51.4 (19:00 – 23:00) 21:00-22:00 55.9 22:00-23:00 51.6 23:00-00:00 52.6 00:00-01:00 59.6 01:00-02:00 46.5 Night 02:00-03:00 43.7 50.6 (23:00 – 07:00) 03:00-04:00 40.7 04:00-05:00 46.1 05:00-06:00 48.5 06:00-07:00 47.9 Weekend Day-time 07:00-08:00 51.2 64.0 (07:00-19:00) 08:00-09:00 49.9 Final Report March 2018 Project No: 17/010 48 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Average Measured Measured Noise Date Period Hours Noise Level Level Leq (dBA) Leq (dBA) 09:00-10:00 47.6 10:00-11:00 47.4 11:00-12:00 48.6 12:00-13:00 45.4 13:00-14:00 46.8 14:00-15:00 48.8 15:00-16:00 57.8 16:00:17:00 70.9 17:00-18:00 70.3 18:00-19:00 67.5 19:00-20:00 75.6 Evening 20:00-21:00 74.6 72.1 (19:00 – 23:00) 21:00-22:00 49.5 22:00-23:00 47.3 23:00-00:00 49.2 00:00-01:00 45.8 01:00-02:00 44.0 Night 02:00-03:00 43.8 47.8 (23:00 – 07:00) 03:00-04:00 45.5 04:00-05:00 45.6 05:00-06:00 47.4 06:00-07:00 52.6 According to the results above background noise levels at the nearest receptor are above RAMEN limits for evening-time on weekends. The IFC/WB noise guideline provides limits for daytime (07:00-22:00) and nighttime (22:00- 07:00). Noise limit is 55 dBA for daytime and 45 dBA for nighttime. Measurement results for daytime and nighttime is provided below in Table 5-13. Final Report March 2018 Project No: 17/010 49 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 5-13. Background Noise Measurement Results (daytime and nighttime) Measured Average Date Period Hours Noise Level Measured Noise Leq (dBA) Level Leq (dBA) 07:00-08:00 49.4 08:00-09:00 52.3 09:00-10:00 51.7 10:00-11:00 51.8 11:00-12:00 50.7 12:00-13:00 47.8 13:00-14:00 51.9 Day-time 14:00-15:00 50.5 53.0 (07:00-22:00) 15:00-16:00 52.1 16:00:17:00 55.3 17:00-18:00 56 Weekday 18:00-19:00 55.8 19:00-20:00 51.7 20:00-21:00 52.7 21:00-22:00 55.9 22:00-23:00 51.6 23:00-00:00 52.6 00:00-01:00 59.6 01:00-02:00 46.5 Night-time 02:00-03:000 43.7 52.2 (22:00 – 07:00) 03:00-04:00 40.7 04:00-05:00 46.1 05:00-06:00 48.5 06:00-07:00 47.9 07:00-08:00 51.2 08:00-09:00 49.9 Weekend (07:00-22:00) 09:00-10:00 47.6 68.0 10:00-11:00 47.4 11:00-12:00 48.6 Final Report March 2018 Project No: 17/010 50 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Measured Average Date Period Hours Noise Level Measured Noise Leq (dBA) Level Leq (dBA) 12:00-13:00 45.4 13:00-14:00 46.8 14:00-15:00 48.8 15:00-16:00 57.8 16:00:17:00 70.9 17:00-18:00 70.3 18:00-19:00 67.5 19:00-20:00 75.6 20:00-21:00 74.6 21:00-22:00 49.5 22:00-23:00 47.3 23:00-00:00 49.2 00:00-01:00 45.8 01:00-02:00 44 (22:00 – 07:00) 02:00-03:000 43.8 47.7 03:00-04:00 45.5 04:00-05:00 45.6 05:00-06:00 47.4 06:00-07:00 52.6 According to the background noise measurement results noise level at the nearest receptor is above IFC/WB noise limits at night on weekdays and daytime and nighttime on weekends. Construction activities will not be performed at night therefore nuisance due to noise will not occur at nights. İzmir-Uşak highway passes at the south of the project area on which traffic is increased on the weekends. It may be considered that the noise level during weekend might be due to the increased traffic on the road. Final Report March 2018 Project No: 17/010 51 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 5.7 Ecology Literature search and field surveys have been conducted for the determination of baseline flora-fauna characteristics of the Project area. Field surveys were conducted between 4 and 6 July 2017 at the Project area and its vicinity by 2U1K. The bibliographic references used during the desktop study included:  IUCN Red List Database;  Turkish Red Data Book of plant species;  Important Bird Areas for Turkey;  CORINE Land Cover database;  Documents and studies conducted by the Turkish Government, scientific Institutions and Associations;  Satellite images and aerial photos; and Scientific literature available in public databases and from Universities. A thorough literature research was performed for endemic, restricted-range critically endangered, endangered, congregatory and migratory species (collectively referred to as species of conservation concern) identified. The results of the analysis enabled to identify the presence of habitats with the potential for hosting species in the Study Area (i.e. site located within the species range and ecologically suitable to its habitat requirements). A set of species potentially present in the Study Area was identified for the different taxon (plants, mammals, birds, reptiles and amphibians). The outputs of the field surveys were compared with literature references in order to make an inventory of flora-fauna species present in the Study Area. The Flora list was prepared in accordance with the phylogenetic order in Turkish flora; ferns, open seed plants (Gymnospermae) and closed-seeded plants (Angiospermae). Families under each group were also listed according to the phylogenetic order in the Turkish flora. Species were listed with their Latin name, English name (if available), phytogeographic regions, endemism, threat categories for endemic and rare species, and their abundance in the region. Samples collected in the Project Areas were transformed into herbarium material and identified by using the “Flora of Turkey and the East Aegean Islands” by Davis, 1965- 1988. Threat status of endemic and rare flora species was determined according to the Red Data Book of Turkish Plants (Ekim et al., 2000), which had been prepared in accordance with the IUCN 1994 criteria. Fauna surveys started early in the morning and continued until sunset. Final Report March 2018 Project No: 17/010 52 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Animal species and the existence of habitats apt for the choices of fauna have been determined through several indicators such as nest-youngster-vomit-footprint of these species (especially in the determination of the bird and large mammal species), faeces-food residues-burrow hole (especially in determination of mammals), skin-horn-shield and bone pieces. No hunting-capture-killing has occurred during the identification of species. Observations of non-living material in nature (especially dead reptile individuals and/or skin, shield pieces found on site) are used particularly for reptile and small mammalian species and literature information on fauna elements of these areas, previously collected museum materials and locals contributed to the prepared species lists. The general criteria and their explanations that are used while evaluating the status of the species are given below. CITES CITES is the Convention on International Trade in Endangered Species of Wild Fauna and Flora. CITES is an international agreement between 164 nations (including Turkey) and its aim is to ensure that international trade in specimens of wild animals and plants does not threaten their survival. CITES principles depend on the sustainable trade fundamental that is significant for protection of the ecologic resources (a vast array of wildlife products derived from a great quantity of live animals and plants, products additive to the food, exotic leather goods, etc.) in the future Appendix I lists species that are the most endangered among CITES-listed animals and plants. They are threatened with extinction and CITES prohibits international trade in specimens of these species except when the purpose of the import is not commercial, for instance for scientific research. In these exceptional cases, trade may take place provided it is authorized by the granting of both an import permit and an export permit (or re-export certificate). Appendix II lists species that are not necessarily now threatened with extinction but that may become so unless trade is closely controlled. It also includes so-called "look-alike species", i.e. species whose specimens in trade look like those of species listed for conservation reasons. International trade in specimens of Appendix-II species may be authorized by the granting of an export permit or re-export certificate. No import permit is necessary for these species under CITES. Permits or certificates should only be granted if the relevant authorities are satisfied that certain conditions are met, above all that trade will not be detrimental to the survival of the species in the wild. Appendix III is a list of species included at the request of a Party that already regulates trade in the species and that needs the cooperation of other countries to prevent unsustainable or illegal exploitation. International trade in specimens of species listed in this Appendix is allowed only on presentation of the appropriate permits or certificates. Final Report March 2018 Project No: 17/010 53 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment IUCN Red List of Threatened Species International Union for Conservation of Nature (IUCN) Red List is published to draw attention to the species whose population is under risk or threatened. IUCN includes the species to the Red List after researching the reasons causing decrease in its population. IUCN Red List categories are given below: EX: Extinct EW: Extinct in the Wild CR: Critically Endangered EN: Endangered VU: Vulnerable NT: Near Threatened LC: Least Concern DD: Data Deficient NE: Not Evaluated EXTINCT (EX) A taxon is Extinct when there is no reasonable doubt that the last individual has died. A taxon is presumed Extinct when exhaustive surveys in known and/or expected habitat, at appropriate times (diurnal, seasonal, annual), throughout its historic range have failed to record an individual. Surveys should be over a time frame appropriate to the taxon’s life cycle and life form. EXTINCT IN THE WILD (EW) A taxon is Extinct in the Wild when it is known only to survive in cultivation, in captivity or as a naturalized population (or populations) well outside the past range. A taxon is presumed Extinct in the Wild when exhaustive surveys in known and/or expected habitat, at appropriate times (diurnal, seasonal, annual), throughout its historic range have failed to record an individual. Surveys should be over a time frame appropriate to the taxon’s life cycle and life form. CRITICALLY ENDANGERED (CR) A taxon is Critically Endangered when the best available evidence indicates that it meets any of the criteria A to E for Critically Endangered, and it is therefore considered to be facing an extremely high risk of extinction in the wild. ENDANGERED (EN) A taxon is Endangered when the best available evidence indicates that it meets any of the criteria A to E for Endangered and it is therefore considered to be facing a very high risk of extinction in the wild. VULNERABLE (VU) A taxon is Vulnerable when the best available evidence indicates that it meets any of the criteria A to E for Vulnerable and it is therefore considered to be facing a high risk of extinction in the wild. Final Report March 2018 Project No: 17/010 54 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment NEAR THREATENED (NT) A taxon is Near Threatened when it has been evaluated against the criteria but does not qualify for Critically Endangered, Endangered or Vulnerable now, but is close to qualifying for or is likely to qualify for a threatened category in the near future. LEAST CONCERN (LC) A taxon is Least Concern when it has been evaluated against the criteria and does not qualify for Critically Endangered, Endangered, Vulnerable or Near Threatened. Widespread and abundant taxa are included in this category. DATA DEFICIENT (DD) A taxon is Data Deficient when there is inadequate information to make a direct, or indirect, assessment of its risk of extinction based on its distribution and/or population status. A taxon in this category may be well studied, and its biology well known, but appropriate data on abundance and/or distribution are lacking. Data Deficient is therefore not a category of threat. Listing of taxa in this category indicates that more information is required and acknowledges the possibility that future research will show that threatened classification is appropriate. It is important to make positive use of whatever data are available. In many cases great care should be exercised in choosing between DD and a threatened status. If the range of a taxon is suspected to be relatively circumscribed, and a considerable period of time has elapsed since the last record of the taxon, threatened status may well be justified. NOT EVALUATED (NE) A taxon is Not Evaluated when it has not yet been evaluated against the criteria. 5 different observation points were determined for the surveys of the Project area and its vicinity. Observation points were selected considering their proximity to the Project components, representation of the Project area, capability to create frequency, and ecological characteristics. The coordinates of the observation points are presented below in Table 5-14. Final Report March 2018 Project No: 17/010 55 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 5-14. Ecological Survey Points UTM-ED50 (Zone 35) Observation Points X Y 1 595383 4261100 2 595311 4261719 3 594927 4262479 4 595188 4263467 5 595204 4260466 The map showing the observation points for ecological survey is provided below in Figure 5-4. Final Report March 2018 Project No: 17/010 56 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 5-4. Ecological Survey Point Final Report March 2018 Project No: 17/010 57 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 5.7.1 Flora Vegetation and plant species of the Project site and its immediate environment have been assessed as a result of field studies and literature survey. The entire flora species of the region that is included in the resource “Flora of Turkey and the East Aegean Islands, Volume 1-11, University Press, Edinburgh, 1965-1988 by Davis P.H.” have been reviewed in order to eliminate any potential errors. Endemic species with possible existence due to their habitat characteristics have been considered in particular. Field studies have been conducted in addition to previous studies for determining the plant species within the Project site, and the information obtained have been supported by literature data. Determination of flora species has been based on field investigations while studies in the literature have been made use of for undefined plant species. The Project area is within the Mediterranean phyto-geographical region, and is located in B2 square according to Davis’s Grid System as can be seen in Figure 5-5. Project Site Figure 5-5. Grid System for Flora of Turkey The Project area is dominated by agricultural lands and has the characteristics of a flat topography. The surroundings of the Project area are also composed of highly modified habitats surrounded by road networks, residential buildings and agricultural lands as seen in Photo 5- 1 to Photo 5-3 below. Final Report March 2018 Project No: 17/010 58 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Photo 5-1. Agricultural Areas Around the Project Site Photo 5-2. Agricultural Areas Around the Drilling Well Final Report March 2018 Project No: 17/010 59 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Photo 5-3. Agricultural and Residential Areas Around Power Plant Legally protected and internationally recognized areas in the region have been determined as a result of field surveys and literature review. Closest legally protected and internationally recognized areas are Gölcük Lake Wetland, Marmara Lake Wetland, Ovacık Wildlife Development Area, Spil Mountain National Park, Kula Fairy Chimney Nature Monument at a distance of 10 km, 10 km, 34 km, 48 km and 63 km respectively. In this context, the protected area network of the region has been examined and the possible effects of the Project to these wildlife sanctuaries have been checked to prove that the Project area and the influence zone sufficiently far from the protected area network of Manisa. Protected areas around the Project area is provided in the Figure 5-6 below. Final Report March 2018 Project No: 17/010 60 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 5-6. Project Area and Protected Areas The floristic structure of the project site and its immediate environment was determined by a detailed literature research and field surveys. According to the results of the surveys it can be seen that the area is covered with ruderal herbaceous plants and cultivated plants. Table 5-15 below lists possible flora in the project area and its environs as a result of the field observations and literature survey. Field surveys indicate that the natural vegetation has been destructed by anthropogenic impacts and has been replaced by cultivated plants. The herbaceous vegetation on the Project Site was not in good form, being quite degenerated. The vast majority of the flora elements that identified during the studies area are wide spread species for the Aegean Region. The region is located phytogeographically in the vicinity of the Mediterranean phytogeography. As Table 5-15 shows below, no endemic taxa, nor significance in terms of categorizations of IUCN, CITES and the Bern Convention, are detected among the listed species. In the overall, the flora and the vegetation of the project area are not vulnerable in terms plant biodiversity. Final Report March 2018 Project No: 17/010 61 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 5-15. Flora in the Project Area and its Environs Common BERN Scientific Name Turkish Name Endemism IUCN CITES Name convention SPERMATOPHYTA GYMNOSPERMA PINACEAE Pinus pinea Stone Pine Fıstık Çamı - LC - - ANGIOSPERMAE DICOTYLEDONAE AMARANTHACEAE Amaranthus Amaranth Tilki Kuyruğu - LC - - chlorostachys. Large-Fruit Amaranthus deflexus Sarkıkibik - LC - - Amaranth APIACEAE Daucus carota Wild Carrot Yabani Havuç - LC - - Shepherd’s- Scandix pecten-veneris Kişkiş - LC - - Needle ASCLEPIADACEAE Cynanchum acutum - Bacırgan - LC - - subsp. Acutum ASTERACEAE Anthemis chia Chamomile Garga Çiçeği - LC - - Bellis perennis Common Daisy Koyungözü - LC - - Calendula arvensis Field Marigold Portakal Nergisi - LC - - Centaurea solstitialis Golden Çakırdikeni - LC - - susbs solstitialis Starthistle Chondrilla juncea var. Rush Karakavuk - LC - - juncea Skeletonweed Common Cichorium intybus Hindiba - LC - - Chicory Conyza canadensis Horseweed Selviotu - LC - - Common Pulicaria dysenterica Yaraotu - LC - - Fleabane Silybum marianum Milk Thistle Devedikeni - LC - - Senecio vulgaris Groundsel Taşakçılotu - LC - - Xanthium strumarium Clotbur Pıtrak - LC - - subsp. Strumarium BORAGINACEAE Buglossoides arvensis Field Gromwell Koyunotu - LC - - Johnston Myosotis Forget-Me-Not Taş Boncukotu - LC - - lithospermifolia.. BRASSICACEAE Capsella bursa- Shepherd’s Çobançantası - LC - - pastoris. Purse Erophila verna Chevall Spring Draba Çirçir Otu - LC - - subsp. Verna Raphanus raphanistrum Wild Radish Turp - LC - - Sinapis alba White Mustard Mamanık - LC - - CAMPANULACEAE Legousia pentagonia Venus’ Looking Kadınaynası - LC - - Final Report March 2018 Project No: 17/010 62 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Common BERN Scientific Name Turkish Name Endemism IUCN CITES Name convention Glass CARYOPHYLLACEAE Cerastium anomalum - Tarla Boynuzotu - LC - - Silene conoidea Weed Silene Şıvanan Otu - LC - - Stellaria media subsp. Chickweed Kuşotu - LC - - Pastii CHENOPODIACEAE Lamb’s Chenopodium album Aksirken - LC - - Quarters CONVOLVULACEAE Convolvulus arvensis Field Bindweed Tarla Sarmaşığı - LC - - DIPSACACEAE Scabiosa sicula Scabious Ada Uyuzotu - LC - - EUPHORBIACEAE Euphorbia helioscopia Sun Spurge Sütleğen - LC - - FABACEAE Coronilla varia Crownvetch Yabani Fiğ - LC - - subsp.varia Lathyrus aphaca var. Yellow Pea Sarı Burçak - LC - - aphaca. Blackdisk Medicago orbicularis Yonca - LC - - Medick Yellow Sweet Melilotus officinalis Kokulu Yonca - LC - - Clover Trifolium angustifolium Narrow Clover Nefel - LC - - var. gustifolium Trifolium campestre. Field Clover Üçgül - LC - - Trifolium hirtum Rose Clover Deli Yonca - LC - - GERANIACEAE Erodium cicutarium Redstem Dönbabaotu - LC - - subsp. Cicutarium Filaree JUGLANDACEAE Juglans regia Walnut Ceviz - LC - - LAMIACEAE Mentha spicata subsp. Spearmint Eşek Nanesi - LC - - Tomentosa MALVACEAE Common Malva sylvestris Ebegümeci - LC - - Mallow MORACEAE Ficus carica subsp. Common Fig İncir - LC - - Carica OLEACEAE Olea europaea var Olive Kültür Zeytin - LC - - europaea PAPAVERACEAE Common Papaver rhoeas Gelincik - LC - - Poppy PLANTAGINACEAE Narrowleaf Plantago lanceolata Damarlıca - LC - - Plantain Final Report March 2018 Project No: 17/010 63 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Common BERN Scientific Name Turkish Name Endemism IUCN CITES Name convention POLYGONACEAE Polygonum persicaria Lady’s Thumb Köyotu - LC - - Polygonum longipes. - Tirşon - LC - - Rumex acetosella Sheep’s Sorrel Kuzukulağı - LC - - Rumex patientia Patience Dock Efelek - LC - - PORTULACACEAE Portulaca oleracea Verdolaga Semizotu - LC - - PUNICACEAE Punica granatum Pomegranate Nar - LC - - RANUNCULACEAE Poppy Manisa Dağ Anemone coranaria - LC - - Anemone Lalesi Ranunculus arvensis Corn Buttercup Mustafa Çiçeği - LC - - ROSACEAE Rosa canina Dog Rose Kuşburnu - LC - - Rubus sanctus Holy Bramble Böğürtlen LC - - RUBIACEAE Galium aparine Cleaver Çobansüzgeci - LC - - SCROPHLARIACEAE Veronica arvensis Wall Speedwell Ekin Mavişi - LC - - SOLANACEAE Solanum alatum - İtüzümü - LC - - Solanum melongea Eggplant Patlıcan - LC - - Datura stromarium - Boruçiçeği - LC - - URTICACEAE Urtica dioica Common Nettle Isırganotu - LC - - VIOLACEAE Viola alba Besser White Violet Meşe Menekşesi - LC - - subsp. Dehnhardtii ZYGOPHYLLACEAE Tribulus terrestris Goat’s-Head Çobançökerten - LC - - MONOCOTYLEDONAE CYPERACEAE Cyperus rotundus Java Grass, Topalak - LC - - LILIACEAE Broadleaf Wild Allium atroviolaceum. Lifli Körmen - LC - - Leek Gagea peduncularis - Karga Sarımsağı - LC - - Tassel Muscari comosum Morbaş - LC - - Hyacinth Ornithogalum Garden Star- Sunbala - LC - - umbellatum Of-Bethlehem POACEAE Aegilops biuncialis. Goatgrass İki Kılçık - LC - - Arundo donax Giant Cane Kargı - LC - - Bromus tectorum subsp. Drooping Kır Bromu - LC - - Final Report March 2018 Project No: 17/010 64 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Common BERN Scientific Name Turkish Name Endemism IUCN CITES Name convention Tectorum Brome Cynodon dactylon var. Vilfa Stellata Köpek Dişi - LC - - dactylon Hairy Digitaria sanguinalis. Kızıl Çatalotu - LC - - Crabgrass Eleusine indica Yard-Grass Bahçeçimi - LC - - Hordeum bulbosum Barley Boncuk Arpa - LC - - Phragmites australisn. Common Reed Kamış - LC - - Bulbous Yumrulu Salkım Poa bulbosa - LC - - Bluegrass Otu Piptatherum holciforme Ricegrass Azizi Çimi - LC - - Polypogon Annual Beard- Hıtır - LC - - monspeliensis. Grass Setaria glauca Millet Darı - LC - - Sorghum halepense Johnson Grass Ekin Süpürgesi - LC - - var. muticum Zea mays Corn Mısır - LC - - 5.7.2 Fauna Fauna inventory was prepared based on conducted fieldwork and a wide literature research. The status of the fauna in the region was evaluated according to the biological and ecological perspectives. Risk categories of fauna species were determined according to the IUCN red list categories which were published in Version 2017.1. In the fauna list that has been provided, species are written with the family names to which they belong to. Fifty-one species and sub-species are known to exist in the Project Area and in its surrounding. A fauna inventory was prepared on a large scale so that it also includes many species not observed directly in the Project Area. Endemic species are sensitive in terms of risk status. However, during the site visits it was found that the immediate area of the facility and the close environs are not used by the target species which are known to be endemic. The Project Site includes water courses and rocky areas which are suitable for reptiles and amphibians, which makes the area suitable habitat for both groups. Possible species to be seen in the Project Area are listed in Table 5-16. Table 5-16. Species of Reptiles and Amphibians in the Project Region Scientific Name Common Name Turkish Name IUCN CITES BERN BUFONIDAE European Green Bufotes variabilis Gece kurbağası LC - Ann-3 Toad RANIDAE Pelophylax bedriagae Levant Water Frog Ova kurbağası LC - Ann-3 TESTUDINIDAE Spur-Thighed Testudo graeca Adi tospağa LC - Ann-2 Tortoise GEOEMYDIDAE Final Report March 2018 Project No: 17/010 65 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Scientific Name Common Name Turkish Name IUCN CITES BERN Western Caspian Çizgili Mauremys rivulata LC - Ann-2 Turtle kaplumbağa GEKKONIDAE Geniş parmaklı Hemidactylus turcicus Turkish Gecko LC - Ann-3 keler ANGUIDAE European Legless Pseudopus apodus Oluklu kertenkele LC - Ann-3 Lizard LACERTIDAE İri yeşil Lacerta trilineata Green Lizard LC - Ann-2 kertenkele Tarla Ophisops elegans Snake-Eyed Lizard LC - Ann-2 kertenkelesi COLUBRIDAE Dolichophis caspius Large Whipsnake Hazer yılanı LC - Ann-2 Dolichophis jugularis Black Whipsnake Karayılan LC - Ann-2 Ring-Headed Dwarf Eirenis modestus Uysal yılan LC - Ann-3 Snake Natrix natrix Grass Snake Yarı sucul yılan LC - Ann-3 Regarding Table 5-16 , the scale of IUCN risk category LC stands for “Least Concern”. For the fauna species taken under protection by Appendix – II and Appendix – III of the Bern Convention, measures stated in Article 6 and 7 of the Bern Convention have to be taken. In particular, the following issues will be considered for the species listed in Appendix II in accordance with the 6th Article of the Bern Convention. The species listed in Appendix II of the Bern Convention are strict. The species listed in Appendix III are periodically under protection. Field data and literature research shows that the project area and surroundings are occupied by species which are known to exist in habitats altered by anthropogenic activities. The bird species which were identified through literature and observed from field survey have been presented in Table 5-17. Table 5-17. Bird Species in the Region Scientific Name Common Name Turkish Name IUCN CITES BERN CICONIIDAE Ciconia ciconia White Stork Beyaz leylek LC - Ann-2 ACCIPITRIDAE Accipiter gentilis Northern Goshawk Büyük atmaca LC - Ann-2 Buteo buteo Common Buzzard Şahin LC - Ann-2 FALCONIDAE Falco naumanni Lesser Kestrel Küçük kerkenez LC - Ann-2 COLUMBIDAE Streptopelia decaocto Eurasian Collared Kumru LC - Ann-3 Final Report March 2018 Project No: 17/010 66 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Scientific Name Common Name Turkish Name IUCN CITES BERN Dove STRIGIDAE Athene noctua Little Owl Kukumav LC - Ann-2 MEROPIDAE European Bee- Merops apiaster Arıkuşu LC - Ann-2 Eater UPUPIDAE Upupa epops Hoopoe Çavuşkuşu LC - Ann-2 ALAUDIDAE Alauda arvensis Eurasian Skylark Tarla kuşu LC - Ann-3 Galerida cristata Crested Lark Tepeli toygar LC - Ann-3 HIRUNDINIDAE Hirundo rustica Barn Swallow Kır kırlangıcı LC - Ann-2 Common House Delichon urbicum Ev kırlangıcı LC - Ann-3 Martin MOTACILLIDAE Dağ Motacilla cinerea Grey Wagtail LC - Ann-2 kuyrukkakanı Motacilla alba White Wagtail Ak kuyrukkakan LC - Ann-2 SYLVIIDAE Maskeli ötleğen Sylvia rueppelli Rüppell’s Warbler LC - Ann-2 kuşu TURDIDAE Turdus merula Common Blackbird Karatavuk LC - Ann-3 Turdus pilaris Fieldfare Tarla ardıç kuşu LC - Ann-3 MUSCICAPIDAE Erithacus rubecula European Robin Nar bülbülü LC - Ann-2 Saxicola torquatus Common Stonechat Taşkuşu LC - Ann-2 SITTIDAE Sitta europaea Eurasian Nuthatch Sıvacı kuşu LC - Ann-2 EMBERIZIDAE Cretzschmar’s Emberiza caesia Kızıl kiraz kuşu LC - Ann-2 Bunting FRINGILLIDAE Carduelis carduelis Goldfinch Saka kuşu LC - Ann-3 PLOCEIDAE Passer domesticus House Sparrow Serçe LC - Ann-3 STURNIDAE Sturnus vulgaris Common Starling Sığırcık LC - Ann-3 CORVIDAE Garrulus glandarius Eurasian Jay Kestane kargası LC - - Corvus corax Common Raven Karakarga LC - Ann-3 Corvus cornix Hooded Crow Leşkargası LC - - Pica pica Eurasian Magpie Saksağan LC - - Final Report March 2018 Project No: 17/010 67 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The project area is located on agricultural areas with low fertility and thus its anthropogenic impacts have made the area unsuitable for mammal species, especially larger mammals which require considerably wide ranges. Table 5-18. Mammals in the Project Region Scientific Name Common Name Turkish Name IUCN CITES BERN ERINACEIDAE Erinaceus concolor Hedgehog Kirpi LC - - SORICIDAE Crocidura leucodon Bicolored Shrew Bahçe sivrifaresi LC - - LEPORIDAE Lepus europaeus European Hare Yabani tavşan LC - - SCIURIDAE Caucasian Sciurus anomalus Kafkas sincabı LC - - Squirrel SPALACIDAE Spalax leucodon Lesser Mole-Rat Körfare DD - - MURIDAE Rattus rattus Black Rat Ev Sıçanı LC - - MURIDAE Mus musculus House Mouse Ev Faresi LC - - CANIDAE Vulpes vulpes Red Fox Kızıl tilki LC - - MUSTELIDAE Mustela nivalis Least Weasel Gelincik LC - - Meles meles European Badger Porsuk LC - - SUIDAE Sus scrofa Wild Boar Yabani domuz LC - - 5.7.3 Habitat Assessment Habitats are divided into modified, natural and critical for the implementation of PS6 requirements. Critical habitats are areas with high biodiversity value, including (i) habitat of significant importance to Critically Endangered and/or Endangered species; (ii) habitat of significant importance to endemic and/or restricted-range species; (iii) habitat supporting globally significant concentrations of migratory species and/or congregatory species; (iv) highly threatened and/or unique ecosystems; and/or (v) areas associated with key evolutionary processes. With regards to the above criteria; there are no species identified as endangered or critically endangered or endemic in the area. The Project is not located within an area of importance for migratory or congregatory species nor situated on a major migratory route. Migratory birds were observed quite rarely and no potential resting places for migratory birds were identified. The habitats identified during the field survey were not considered to be “Highly Threatened and/or Unique Ecosystems”. Final Report March 2018 Project No: 17/010 68 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Turkey is located at the junction of three distinct phytogeographical regions and houses 3 of 25 hotspots that are significantly important in terms of biodiversity in global scale. The Project area and its vicinity are not located in the borders of the hotspots in Turkey and do not support key evolutionary processes. Therefore the Project area does not include critical habitats. As explained above the Project area and its surrounding comprises of agricultural lands; defined as modified habitat. Final Report March 2018 Project No: 17/010 69 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 6. SOCIAL BASELINE In this section, baseline data for the socio-economic aspects of the Area of Influence (AoI) is presented in order to provide a current situation against which the impacts of the Project can be assessed. The baseline takes into account present conditions, as well changing conditions (i.e. population, education) apparent in the baseline. The baseline description has the following main objectives to:  focus on receptors that were identified during scoping as having the potential to be significantly affected by the Project,  describe and, where possible, quantify their characteristics (demography, economy, education, health, etc.),  provide data to aid the prediction and evaluation of possible impacts and,  inform judgments about the sensitivity, vulnerability and/or importance of resources/receptors. The aim of the socio-economic baseline study is to describe the socio-economic conditions and trends in the areas potentially affected by the Project to understand potential effects and to develop appropriate mitigation measures. The socio-economic baseline defines the socio- economic issues of importance of provincial and local communities and establishes a baseline of socio-economic data that can be used for monitoring changes in the affected communities after the Project. The following variables were selected for the discussion of the socioeconomic indicators of the settlements area around the Project site:  Demography and Population  Livelihoods and Employment  Education  Health  Infrastructure and Services  Vulnerable Groups Socio-economic data was collected using a combination of research methods. The baseline section was conducted by collecting, reviewing, and analysing a range of secondary data, including data originating from the Turkish Statistical Agency (TURKSTAT), Salihli Municipality, local and provincial Governorates’ Database. In order to provide baseline information on the neighbourhood level, national statistics are supported with information obtained from primary data collected through interviews with Mukhtars which were carried out between the July 4 and 6, 2017. The area of influence of the Project calls for Yılmaz, Gaffar Okkan, Hasalan and Caferbey neighbourhoods. Final Report March 2018 Project No: 17/010 70 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 6-1. Scoping of Social Issues Project Social Issue Possible Impacts Baseline Parameters Activities  The Project is expected to address the  Annual national Operation National Economy energy production electricity needs of people nationally  Livelihood and employment Drilling and  Number of lands that Land Acquisition  Loss of agricultural land have been purchased Construction  Number of affected people  Livelihood and Construction employment Local and  Employment opportunities  Number of the local Employment Operation employees  Pressure on local infrastructure  Demography and Construction Labor influx population  Change in population  Safety concerns  Number of vehicles Transportation /  Damage on existing roads used for the Construction construction phase Traffic  Increase in traffic  Dust  Air Quality Drilling and Community  Increase of noise and dust due to Project  Noise level Construction Health and Safety activities  Air quality  Increase in traffic Construction  Potential for exposure to geothermal gases, Occupational confined spaces and heat  Air quality and  Noise level Health and Safety  Noise exposure during well drilling, steam Operation flashing and venting Existing cultural heritage assets and Drilling and  Damage on cultural assets within or around archaeological areas Cultural Heritage Construction the Project area. in or around the Project area. 6.1 Demography and Population This section presents general demographical information of Manisa Province and Salihli District respectively and move on to further details within the borders of the AoI. Manisa, situated in Aegean Region of Turkey, covers an area of 13,810 km 2 and has been recorded as the 14th most populated city in Turkey with a population of 1,396,935 (Turkish Statistical Institute , 2016). Manisa holds the second place in terms of population density after Izmir within Aegean Region. The annual population growth rate in 2015 was 9.2 per thousand, whereas, the same indicator was 6.2 per thousand in 2014. There are 17 districts within the Province borders and the majority of the population lives in the province and district centres, whereas, remaining population lives in towns and neighbourhoods. The most populous district in Manisa is Yunusemre with 211,673 Final Report March 2018 Project No: 17/010 71 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment inhabitants, on the other hand the least populous district is Köprübaşı with 13,586 inhabitants. Salihli district is placed in fourth in terms of population density within the Province with a population of 158,568 (Turkish Statistical Institute , 2016). As mentioned above, there are four neighbourhoods within the limits of AoI (Yılmaz, Gaffar Okkan, Hasalan and Caferbey). According to social field study, Hasalan neighbourhood has the lowest population figures, whereas, Yılmaz neighbourhood has the highest population figures. Further information regarding the demography of the AoI can be found in Table 6-2. Table 6-2 Population Figures of the Area of Impact Distance to Manisa Distance to Salihli Neighborhood Neighborhood Province District Population (2016) Yılmaz 69 km 4 km 6017 Gaffar Okkan 45 km 1 km 1453 Hasalan 45 km 10 km 269 Caferbey 65 km 6 km 828 Source: Field Study, 2017 The age distribution of each neighbourhood has been received through field study and can be found Figure 6-1 in the below. Before getting into analysing, it is important to note that the population of Yılmaz is higher compared to rest of the neighbourhoods within the borders of AoI. Overall, majority of the community members falls within the age group between 19 to 39. The number of individuals who are aged 65 and over seems to be high in Caferbey, whereas, Gaffar Okkan has the highest number of individuals who are aged between 0 to 5. Figure 6-1. Age Distribution of Survey Population on the Basis of Neighbourhoods Majority of the population figures of the AoI have changed due to various reasons over the course of five years, Table 6-3 below presents the population changes of the neighbourhoods and its reasons within the five years respectively. Final Report March 2018 Project No: 17/010 72 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 6-3. Population Dynamics Neighborhood Population Change within the Last 5 Years Reasons Yılmaz Increased No particular reason Gaffar Okkan Increased Financial difficulties Hasalan Remained the same - Caferbey Remained the same - Source: Field Study, 2017 6.2 Livelihoods and Employment According to information gathered from Manisa Provincial Culture and Tourism Directorate database, the economy of the Manisa is generally based on agriculture, in other words, 35% of the gross income is derived from agriculture. Nearly all of the Province’s population is involved in agriculture as Manisa having the largest vineyard area of Turkey with a viniculture area of 75.401 hectares. Furthermore, Manisa is the source of the grapes in Turkey by having 85% of the national grape production. The other fruits growing in Manisa are peach, cherry, apricot, olive, almond, pear, walnut and pomegranate (Manisa Provincial Culture and Tourism Directorate ). According to the information obtained during field studies conducted within the settlements of the AoI, agriculture is the common economic activity in the four neighbourhoods in the AoI of the Project, as well. According to interviews with the locals, the main sources of local income are farming, retirement pensions, sheep breeding and paid workforce. The common products from agriculture within the AoI are grape, wheat, corn, eggplant and tomato. It is important to note that, Gaffar Okkan neighbourhood has the least agriculture activities among the other settlements in the AoI. The social team conducted Community Level Surveys with the neighbourhood mukhtars in terms of the type of lands within the neighbourhood borders. Table 6-4 below presents the information gathered from the mukhtars on approximate size of the lands of each neighbourhood, respectively. Table 6-4. Type of the lands within the AoI Neighborhood Hasalan Gaffar Okkan* Yılmaz Caferbey Pasture land 56 decare N/A 15,000 decare 95 decare Forest - N/A - 4,000 decare Treasury 205 decare N/A 4,000 decare 3 decare Private 6,5000 decare N/A 13,000 decare 2,000 decare Source: Field Study, 2017 *The Mukhtar of Gaffar Okkan neighbourhood did not have information on size and type of the lands. Final Report March 2018 Project No: 17/010 73 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The land to be used for the Project activities are agricultural lands, owned by private owners and were acquired by voluntary purchase method. During the social field study, two households surveys were conducted with the locals who sold and rented their land to the Project Company. According to both of the locals statement, they have received their payment from the Project Company. Further information on land allocation of the Project Company can be found in Section 8.2 of this Report. In terms of livestock breeding, Yılmaz, Hasalan and Caferbey neighbourhoods use animal husbandry mainly for household purposes. Table 6-5 below presents the top three economic activities of each neighbourhood, respectively. Table 6-5. Common Economic Activities within the AoI Neighborhood Hasalan Gaffar Okkan Yılmaz Caferbey First Common Viticulture Construction Works Retirement Pension Farming Economic Activity Second Common Animal Husbandry Paid Workforce Farming Retirement Pension Economic Activity Third Common Retirement Pension Retirement Pension Paid Workforce Animal Husbandry Economic Activity Source: Field Study, 2017 According to interviews with Mukhtars of the AoI, Yılmaz neighbourhood is observed to have higher economic standards, whereas, in terms of family income, Caferbey neighbourhood has a decreasing trend of economic standards due to decreasing number of market opportunities for agricultural products. 6.3 Education According to National Education Statistics Database of 2016 prepared by Turkish Statistical Institute, the literacy rate of Manisa has increased by 1.4% in 2016 which has resulted the Province to have 97.4% literacy rate in general. Continuing with the 2016 statistics, the highest literacy rate within the Province is located in Sarıgöl district, furthermore, the literacy rate of Salihli district is 97.1%. In terms of comparing education conditions within the AoI through the field study, Yılmaz, Gaffar Okkan and Caferbey neighbourhoods have primary education facilities within their borders (1st through 8th grade), on the other hand, for high school education, students use means of transportation services to the closest high school located in Salihli District. Figure 6-2 presents the education indicators of the people from the AoI, respectively. Final Report March 2018 Project No: 17/010 74 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 80% 70% 60% 50% Gaffar Okkan 40% Hasalan 30% Caferbey 20% Yılmaz 10% 0% Never Primary Middle High University attented to school school school graduate school graduate graduate graduate Figure 6-2 Education indicators of the community members within the AoI As can be seen from the chart above, Gaffar Okkan has the highest percentage for the community members whom never attended to school, whereas, Yılmaz neighbourhood has the highest percentage when it comes to university graduates within their settlement. Furthermore, according to the interviews conducted with the Mukhtar interviews, almost all portion of the AoI are literate with Caferbey neighbourhood having the highest illiterate figures among the settlements within the AoI. 6.4 Health According to Manisa Provincial Health Directorate, there are 14 State hospitals, 8 private hospitals, 9 medicine centres, 4 oral and dental centres, 20 District Health Directorates, 17 Community Health Centres and 26 Emergency Health Services Station in Manisa (Manisa Provincial Health Directorate, 2017). In terms of health services within the AoI, Yılmaz, Gaffar Okkan and Caferbey neighbourhoods have local health clinic, which other neighbourhoods within the AoI prefers to access for minor health issues. For further health services, community members have access to hospitals within the District or Province. 6.5 Infrastructure and Services Infrastructure and services within the AoI can be found in the given list below.  Village rooms and coffee houses available in Yılmaz, Hasalan and Caferbey neighbourhoods provide place for community gatherings.  All the neighbourhoods are connected to the national electricity grid.  Drinking water is received mainly through groundwater and spring water. Final Report March 2018 Project No: 17/010 75 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment  Hasalan neighbourhood uses septic tanks; others use sewer system for wastewater discharge.  Solid wastes are collected from the four neighbourhoods by Salihli District Municipality.  All four neighbourhoods have access to tele-communication services including telephone, mobile communication and internet.  Transportation is through either private vehicles or mass transportation by minibuses to the Salihli District centre. In terms of the economic issues, all four neighbourhoods experienced unemployment which affected income of the families negatively. In terms of economic issues, all four neighbourhoods experienced unhealthy drinking water and malfunctioning sewer system. In terms of health issues, Yılmaz neighbourhood reported cancer as the most common health problem. 6.6 Vulnerable Groups Social baseline study also seeks to identify any potentially vulnerable or disadvantaged group or individuals in the local community. The social team conducted, through community level interviews, that there are number of vulnerable groups within the AoI and they include seasonal workers, females, low income groups, illiterates and mental or physical disabled persons. Seasonal agricultural workers: Informal employment in Turkey is very common, especially in the agriculture sector. This group is considered as vulnerable since their income is seasonal. Females: The patriarchal structure is predominant, and women do not have equal opportunity in education, workplace and inherit issues in the rural areas. It is seen that the women observed in Manisa province are generally employed as daily paid agriculture workers. Low-income groups: In Turkey, the poverty line for a family of four in 2016 is set at about 4500 TL and about 7 million people are employed with a minimum wage of 1400 TL. According to information gathered from muhtars approximately 200 households were defined in the area of influence living with the assistance of district governor of Salihli. Illiterate: The most common group of illiterates is the elderly female population. It was seen that literate rate of the Manisa is higher when compared to the average of Turkey but still there are illiterate population in the settlements. Handicapped: This group is likely to experience the impacts of the Project due to their physical or mental characteristics. Final Report March 2018 Project No: 17/010 76 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Syrian Refugees: According to the Ministry of Interior's Office of Immigration (2016), there are approximately 5,000 Syrian refugees in Manisa Province. According to consultations with the muhtars, it is stated that about 20 households are living in Yılmaz neighbourhood. Majority of the vulnerable groups in the three neighbourhoods comprise mainly of seasonal workers and illiterate people. Yılmaz neighbourhood has the highest figures in terms of individuals with low income and families with female as the head of household. Further information regarding the vulnerable groups is given in Table 6-6 below. Table 6-6. Vulnerable Groups Low Female Illiterate Seasonal Mentally Physically Settlement Income Household Worker People Handicapped Handicapped Group Head Yılmaz 500 80 300 100 20 50 Caferbey 150 52 5 50 4 6 Hasalan 50 30 13 6 1 3 Gaffar 250 4 30 300 10 5 Okkan Source: Socioeconomic Survey, 2017 Further information regarding the vulnerable groups in AoI can be found in Section 5.1.1. of the Stakeholder Engagement Plan. It should be noted that the vulnerable groups is not expected to receive additional Project impacts in the AoI. 6.7 Project Information Level During the social field study, Focus Group Meetings have been conducted at Caferbey, Yılmaz ,Hasalan and Gaffar Okan Neighbourhoods. On each Focus Group Meetings, brief introduction of the Project’s purpose and the Project Company has been presented to the attendees by the social team. Almost all land acquisition has been conducted at Yılmaz Neighbourhood (except for one parcel at Caferbey neighbourhood), where the project information level was observed to be relatively higher than the others. The result of social surveys related to Project information level is presented respectively for each settlements below.  Caferbey: According to the Focus Group Meeting, almost all of the participants stated that they had no specific information regarding the Project. They have overheard that the Project Company has purchased lands from the locals but do not have further information regarding that. Therefore, during the meeting, they requested to receive further information and potential impacts of the Project. Final Report March 2018 Project No: 17/010 77 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment  Hasalan: According to Focus Group Meeting, almost all of the participants stated that they did not have detailed information regarding the Project. During the meeting, they were eager to receive further information regarding the potential social and environmental impacts on the neighbourhood.  Yılmaz: According to Focus Group Meeting, majority of the participants stated that they did not have any information regarding the Project. They have overheard there was a public participation meeting in August 2016, for the National EIA purposes, however, mentioning they have not been informed sufficiently, none of the attendees of this Focus Group Meeting attended. Even so, information level of Yılmaz was considerably higher than other settlements.  Gaffar Okkan: According to Focus Group Meeting, some of the participants overhead about the Project with no detailed information. They are requesting for Project officials to visit the neighbourhood and inform the locals. The information given above shows that, there is request for Project information disclosure regarding the Project from the participants of Focus Group Meeting. Respondents recommended following suggestions to raise their level of knowledge regarding the Project. Different expectations of each settlement and suggested grievance mechanism are presented below. Table 6-7 Suggested Information Disclosure and Grievance Tools Name of the Information Disclosure Tool Suggested Grievance Tool Neighborhood  Project personnel should provide brief information in the neighborhood including the impacts and grievance  Phone –line mechanism for the Project.  Community liaison officer should Caferbey  Brochures can be used to inform phases be hired of the Project.  Project authorities should visit the  Telephone number of the Project settlement. representative should be posted on the Coffee shop of the neighborhood.  Project personnel should provide brief  Community liaison officer should information in the neighborhood be hired including the impacts and grievance Hasalan  Project authorities should visit the mechanism for the Project. settlement.  Brochures can be used to inform phases  Phone –line of the Project..  Project personnel should provide brief information in the neighborhood  Community liaison officer should including the impacts and grievance be Project authorities should visit Yılmaz mechanism for the Project. the settlement.  Brochures can be used to inform phases  Phone –line of the Project.  Project personnel should provide brief  Community liaison officer should information in the neighborhood be hired including the impacts and grievance Gaffar Okkan  Project authorities should visit the mechanism for the Project. settlement.  Brochures can be used to inform phases  Phone –line of the Project. Final Report March 2018 Project No: 17/010 78 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7. ENVIRONMENTAL IMPACT ASSESSMENT Based on an overview of baseline parameters, impact assessment is comprised of the following elements: Assessment of impacts on surface waters and groundwaters:  Degradation of surface water quality affecting local users  Impacts on ecosystems from vegetation clearance and earth moving during construction;  Pollution of surface water from drilling muds or water from testing wells;  Surface and/or groundwater contamination from chemical spills and leaks from storage, transportation and use of chemicals and fuel on Project site;  Cross-contamination of surface aquifer from drilling of new geothermal wells  Surface water impacts from discharges of effluents from reinjection; Assessment of noise impacts on communities:  Noise from construction and drilling activities from site preparation, excavation and foundations, construction and drilling; Assessment of impacts on soil:  Degradation of soil by contamination from drilling mud and cuttings and other potential hazardous wastes,  Degradation of land and soil by contamination from fuel or chemical storage facilities or spent oils, lubricants storage,  Soil contamination from fuel or chemical storage facilities or spent oils, lubricants storage, etc. Assessment of impacts on air quality:  Health effects of hydrogen sulphide (H2S) on the surrounding communities from operational emissions from Power Plant site;  Release of CO2 and other GHGs at operation Final Report March 2018 Project No: 17/010 79 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.1 Construction Stage Impacts 7.1.1 Impacts on Ecology Site observations clearly indicate that the flora has been largely deteriorated due to anthropogenic activities. The Project area is located within the Mediterranean phyto-geographical region and therefore has the characteristics of diverse vegetation along its coastal region. There are numerous fields within the Project area and its immediate environment due to the flat topography and alluvial deposits. Within the Project site, there are ruderal plants along the roadsides and around the irrigation and drainage channels as well as the dominant vegetation of field crops. Although it seems as a rich flora, it has lost its natural vegetation cover due to agricultural fields and gardens. A certain amount of biomass will be lost during excavation works at the construction site. Top soil that will be skimmed from the surface will be reserved and used in site restoration and redevelopment of flora. Up to 300 mm of topsoil will be stripped and stored in appropriate conditions providing loss and degradation. Mitigation measures for the preservation of topsoil are provided below and also in the ESMP. A large amount of the geothermal fluid that is required for energy production will be passed above the ground; therefore, the biomass loss will be minimized during the operations along the pipeline route. The Project pipeline is a fully enclosed system which does not create any adverse effects on the existing vegetation during the transportation of geothermal fluid to the facility. Cooled water that will be generated as a result of the closed-circuit production will directly be pumped back to the thermal reservoir without being discharged to any receiving body. The Project site and its vicinity are under intense human pressure due to animal grazing and agricultural activities. Certain fauna species have previously moved away from the region due to such anthropogenic impacts. The existing fauna species are the ones that have adapted themselves to these impacts. Therefore, there are no species that may be damaged due to the facility construction. Within this framework, noise-induced impact of the facility on the fauna is in question, because of which the faunal elements may abandon their nesting area. However, once the facility construction is over, faunal elements may use the region as their nesting area again. Mitigation measures which are provided below and the ESMP will be in place during construction works in order to avoid nuisance to species which may occur at the site. The cooled water to be generated as a result of the closed-circuit production will directly be pumped back to the thermal reservoir without being discharged to any other receiving body. Final Report March 2018 Project No: 17/010 80 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-1: Impacts of Construction Stage on Ecology Positive Negative Direct Indirect Cumulative Impact Type Impacts of construction activities on the ecology is negative and both direct and indirect. Temporary Short Term Long Term Permanent Impact Duration The impact is temporary as species will possibly adapt to post-construction conditions. Project Area Local Regional National Impact Extent The impact is local, limited to the Project Site and environs. Negligible Low Medium High Impact Magnitude Impact is negligible as there are no critical habitats or species and the existing species will be able to adapt to the changes. Unlikely Likely Certain Likelihood of Impact Impacts are likely as excavation works will remove some vegetation and top soil; and drilling activities will cause unfavorable conditions with dust and noise. Insignificant Minor Moderate Major Impact Significance Impact is insignificant as there are no critical habitats or species and the existing species will be able to adapt to the changes. High Medium Low Irreversible Reversibility of Receptor General ecology will recover in time but it is evident that some species will move to new habitats. Final Impact Insignificant Low Medium High/Critical Assessment Overall ecological impact is insignificant; thereby mitigation measures will not be necessary. Indirect impacts on ecology through emissions of noise and air quality or through discharges of effluent will be mitigated in a large extent through the mitigation measures identified:  Topsoil will be stripped up to 300 mm depth and stored in designated storage areas for further site restoration works.  Storage areas will be prevented from the accumulation of storm water, provided with drainage.  Weed growth in stockpiles of topsoil will be prevented and the stockpiles will be seeded if required.  Existing access roads will be used for Project purposes and off-road driving will be prohibited.  Project activities will be limited in the construction area and construction sites will be surrounded with fences to prevent wild animals intrusion to the site.  Hunting or collection of animals and will be strictly prohibited within the Project area.  Awareness among all construction workers will be provided during the lifetime of the Project for especially the fauna species with limited mobility. If these species, are observed, they will be translocated to undisturbed but similar areas. Final Report March 2018 Project No: 17/010 81 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The residual impacts will be insignificant with the implementation of the mitigations. 7.1.2 Water Supply During the construction stage, water demand will consist of potable water and water to be used for dust emission prevention. Potable water will be supplied as demijohns. Domestic water for the workers and water for dust suppression will be provided by the two wells established by the former owner of the land within the Project area. Sanko Enerji has applied to DSİ for the transfer of the ownership of the wells. A total of 100 personnel is planned to be working in the scope of the construction phase for various works and periods, however number of personnel working at the same time will not exceed 84. Total number of persons engaged: 84 Water required: 0.203 m3/person/day (Turkish Statistical Institute, 2014) Total water requirement: 0.203 m3/person/day x 84 persons = 17.52 m3/day It is assumed that approximately 52.5 m3 water per day will be used for construction activities for preventing dust emission. Regarding the drilling works; 48 personnel is expected to be operating daily. Total water requirement: 0.203 m3/person/day x 48 persons = 9.744 m3/day Water is also required during drilling works. Exact amount of required water cannot be determined due to various factors such as drilling fluid and geological units, however based on the previous drilling studies 630 m3 water is estimated to be used during drilling according to the EIA report. The drilling fluid will be stored in mud storage tanks after solid material is removed and the fluid is re-used afterwards. Therefore water consumption of 14 m3/day will occur in order to supplement the required water during drilling activities. Water required for drilling works are supplied from available wells or surface water sources at the drilling locations after DSI consent and if there are no wells available, water will be transferred by tankers. 7.1.3 Wastewater Generation Only domestic wastewater will be generated during construction stage activities. Considering domestic waste requirement is 17.52 m3/day for 84 personnel, wastewater generated is estimated to be below 17.52 m3/day. Domestic wastewater generated at the construction stage will be collected in a septic tank in compliance with the Regulation on the Construction of Septic Tanks at Places Where Sewer Construction is Not Possible. If the number of employees exceeds 84, wastewater treatment plant will be established for the Project according to the requirements of the Regulation on Water Pollution Control. Below Final Report March 2018 Project No: 17/010 82 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment parameters are expected for the domestic waste water generated during construction phase of the Project according to the EIA report: Table 7-2: Expected Domestic Wastewater Parameters Parameter Concentration (mg/lt) pH 6-9 Suspended Solids 200 BOD 200 COD 500 Total Nitrogen 40 Total Phosphorous 10 7.1.4 Impacts of Geothermal Fluid Test drillings are conducted in order to prove the commercial viability of potential resources. Drilling works are the same for both the production wells and reinjection wells. Type of the wells is decided according to the efficiency assessment of the wells based on properties such as temperature, flow rate and pressure. During the drilling works, liquid drilling mud which is the mixture of different type of chemicals with water will be employed in order to carry rock cuttings to the surface and also lubricate and cool the drill bit. Impacts of drilling mud are provided in the following section. . Rotary drilling is used for the wells within the scope of the Project. Casings of three different diameters were employed during drilling of wells which have diameters of 20’’, 13 3/8’’ and 9 5/8’’. At the end 7’’ production pipes are employed to convey the geothermal fluid to the surface. Cement is applied around the casings and in this way in order to order to contain the geothermal fluid is contained and uncontrolled generation of geothermal fluid or vapour is prevented. The casings at shallow depth prevent loose near-surface material collapsing into the well and casings with intermediate diameter will support successive wellheads.. Casings and concrete wall around casings prevent groundwater and geothermal fluids intervene with each other. No discharge to aquifer will occur due to Project activities. It is planned to extract 420 tonnes/hour geothermal fluid for 15 MW capacity from wells with a depth of 2500-3000 m. Geothermal fluid extracted from the production wells will be reinjected to the original reservoir through reinjection wells. An impermeable collection pond to be used in case of any failure during reinjection, operation of the power plant or during maintenance of the wells has been constructed. The capacity of the collection pond is 1400 m3 with the estimation of use of 1400 tonnes/hour geothermal fluid at maximum for a potential capacity increase of the power plant to 50 MW. The capacity of the pond is calculated based on the estimation that the system will stop maximum for 1 hour duration. As mentioned a total of 1400 tonnes/hour geothermal fluid will be extracted for potential capacity of 50 MW and the collection pond has been constructed to contain the volume of extracted geothermal fluid for Final Report March 2018 Project No: 17/010 83 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment one hour. If the volume of the collection pond is exceeded due to malfunction, extraction of geothermal fluid will be stopped. Geothermal fluid collected in the pond will be reinjected back to the system by reinjection pump. Geothermal fluid discharge to any kind of environment will be prevented during the whole Project lifetime. Groundwater quality monitoring will be conducted at downstream of geothermal fluid storage ponds and reinjection wells quarterly. Upon DSİ approval two locations will be established within the license area and temperature and EC will be monitored in groundwater through installed automated monitoring systems. Table 7-3: Impacts of Drilling Effluents Positive Negative Direct Indirect Cumulative Impact Type Impacts of discharging geothermal test water into the environment in case of a malfunction during reinjection. Temporary Short Term Long Term Permanent Impact Duration The impact is temporary as limited to the construction stage. Project Area Local Regional National Impact Extent The impact is limited to the impermeable collection pond, thereby local. Negligible Low Medium High Impact Magnitude Impact magnitude could be considered low regarding the duration will be temporary and potential impact is local. Yet collection ponds will be established for the Project. Unlikely Likely Certain Likelihood of Impact Impacts of geothermal fluid on soil and groundwater resources are likely at construction stage based on risks of mud-pit overflows or improper waste handling. Impact Insignificant Minor Moderate Major Significance Significance of impact is minor. Reversibility of High Medium Low Irreversible Receptor Soil and groundwater quality can be reversed by restoration activities, at some cost. Final Impact Insignificant Low Medium High/Critical Assessment Impact is low. Mitigation measures are required in the form impermeable collection pond. 7.1.5 Impacts of Solid Wastes on Soil and Groundwater Hazardous and non-hazardous solid wastes expected to be generated during the construction stage are domestic solid waste from construction staff, excavation debris, packaging wastes, recyclable solid waste end-of-life tires, waste batteries and accumulators and drilling mud. Non-hazardous Solid Waste Domestic solid waste is generated by the construction personnel in the construction stage as a result of various consumptions of the field staff. Considering that the number of field staff Final Report March 2018 Project No: 17/010 84 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment will be 84 and taking the daily waste generation per capita value as 1.25 kg/person-day, as indicated by Turkish Statistical Institute’s 2014 data for Manisa province, the total domestic solid waste generation by the field staff will be 105 kg/day. Recyclable wastes such as glass, paper and plastics will be segregated from other wastes and stored temporarily on site for eventual recycling process. Non-hazardous solid waste other than recyclables will be stored in containers and will be disposed by Salihli Municipality. All solid non-hazardous wastes will be disposed according to the Waste Management Regulation. Excavated soil will be re-used for backfilling, landscaping and site leveling purposes. Hence, no excavated soil will be transported and stored outside the Project area. Temporary storage of the excavated material will be performed providing the generation of drainage pathways to underlying aquifers. The height of the stockpiles will not exceed 5 m and the stockpiles will be dampened especially during dry and windy weather in order to prevent dust emissions. If excess material occurs it will be disposed in a landfill approved by Manisa Municipality. Hazardous Waste During the construction phase of the Project hazardous waste will mainly be contaminated packaging wastes, contaminated protective material and waste oil. In case, it is inevitable to perform maintenance of the construction vehicles on site, minor amounts of waste oil will be generated at the site. Oil change of the vehicles will be conducted by machine experts or service staff on leak-proof surface within the construction site, therefore a possible soil contamination will be prevented Generated waste oil will be collected in safe leak-proof containers, stored in an area with a concrete surface and a proper secondary containment to prevent potential spills and leakages reaching to the soil and groundwater. Waste oil will be disposed in accordance with the Waste Oil Control Regulation. Hazardous waste generated due to Project activities will be waste drilling muds in case they are determined as hazardous according to the analysis. Packaging Waste Packaging waste generated during the construction stage will comprise of recyclable materials such as metal, paper, plastics and glass and will be stored separately. Waste Batteries and Accumulators Waste batteries generated during the construction stage will be collected separately in the waste battery containers located at the Project site. Waste batteries will be sent to a Waste Battery Recycling Plant as stated in Section 2, Article 13 of the Regulation on the Control of Waste Batteries and Accumulators Final Report March 2018 Project No: 17/010 85 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Medical Waste There will be an infirmary established at the Power Plant for the personnel. Besides health institutions close to the Project area will be applied if required. Salihli State Hospital is at a distance of 4.5 km to the Project area. According to the EIA Report 10 kg/year medical waste is estimated to be generated. Medical waste which will be generated as a result of on-site first aid applications for injuries; they will be collected, transferred, stored and disposed of in compliance with the Medical Waste Control Regulation. Drilling Mud Drilling mud will be generated as a result of drillings. Drilling mud will be elevated to the ground collecting solid particles. Drilling mud will be sieved for foreign substances and then passed through solid-liquid separator (decanter). Liquid part is pumped back to the mud tankers to be reused. Solid substances on the other hand, are sent back to waste mud pond. The solid material passing through the decanter has some amount of water content therefore collected as liquid waste in the drilling mud pond. Liquid drilling mud is settled in the pond providing solid substances to deposit. For the Project 100 lt of drilling mud is expected to be generated for 1 m drilling. Average depth of the drilling wells is estimated to be 2,500 m therefore the amount of drilling mud at each drilling location is calculated as follows: Amount of drilling mud: 100 lt/m x 2500 m=250,000 lt= 250 m3 Mud ponds with dimensions 60 m x 6.5 m x 3 m with side slope are established for storage of mud at each drilling location. Each pond is covered with impermeable material such as geomembrane and has 1,170 m3 capacity which is above the calculated value above. Mud collected in the pond is settled providing the deposition of solid substances. Waste mud is analyzed for categorization according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery (dated 2012/15) and the Regulation on Landfill of Wastes (Official Gazette dated 26.03.2010, no: 27533). If the waste is deemed hazardous waste, it will be disposed according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery. If the waste mud is determined as inert and/or non-hazardous waste then the mud ponds will be filled with excavation debris and covered with the vegetative soil which was stripped and stored separately during land preparation. After the drilling mud is deposited, remaining water on the mud is evaporated or discharged by vacuum truck if drilling mud is determined as non-hazardous or inert. If the mud is classified as hazardous then the water on the mud is collected into IBC tank and disposed according to the requirements the Regulation on Waste Management. Final Report March 2018 Project No: 17/010 86 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-4: Impacts of Waste Storage Positive Negative Direct Indirect Cumulative Impact Type Impacts of mud-pits and hazardous waste storage are negative and direct. Improper storage of hazardous waste would cause infiltration of hazardous components into sub- layers of soil and the shallow aquifers. Temporary Short Term Long Term Permanent Impact Duration The impact will be long-term if the impact is not detected on-time and cleaning procedures are not applied. Project Area Local Regional National Impact Extent The impact is limited to local soils and the shallow aquifer. Negligible Low Medium High Impact Magnitude Groundwater in the shallow aquifer is not used by local people. Still any contamination is not allowed by regulations. Unlikely Likely Certain Likelihood of Impact Impacts of waste storage on soil and groundwater resources are likely at construction stage based on risks of mud-pit overflows or improper waste handling. Insignificant Minor Moderate Major Impact Significance Significance of impact is moderate as oil contamination from oil based drilling muds can cause long term or permanent changes. Reversibility of High Medium Low Irreversible Receptor Soil and groundwater quality can be reversed by restoration activities, at certain costs. Final Impact Insignificant Low Medium High/Critical Assessment Impact is moderate and requires mitigation measures. 7.1.6 Impacts on Air Quality The emissions during the construction stage will consist of the dust and exhaust gas emissions resulting from operation of onsite diesel vehicles, skimming of topsoil layers, and excavation of mud pits, transportation of ready-mixed concrete for the power plant construction and H2S emissions during drilling although in low concentrations due to the use of binary technology. According to the baseline H2S measurements in the AoI of the Project, it was observed that H2S concentrations are below the regulation limits. Air quality measurements will be conducted in terms of H2S concentrations during drilling works and operation phase in order to prove compliance to the regulation requirements. H2S detectors will also be placed at well heads for monitoring H2S levels. Dust emissions Excavation will be conducted for the power plant, mud pits, administrative building, workshop and storage area and septic tank location. According to the calculation in the EIA report, the amount of excavated material for the Project is estimated as 24,064 m3. Dust emissions caused by each activity of each construction phase are calculated according to the information provided in the EIA Report. In the calculation of dust emissions, the Final Report March 2018 Project No: 17/010 87 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment controlled dust emission factors given in Turkish IAPCR Table 12.6 were used. Controlled dust emission factors are given in Table 7-5 below: Table 7-5: Controlled Dust Emission Factors according to Turkish IAPCR Activity Controlled Dust Emission Factors (kg/ton) Excavation 0.0125 Loading 0.005 Transportation (total distance) 0.35 Unloading 0.005 Dust emission caused by construction activities is calculated using controlled dust emissions: Table 7-6: Construction Phase Dust Emissions Activity Construction Phase Excavation 0.1671 Transport of excavated material to the trucks 0.0156 Loading 0.0668 Transport of the trucks to the landfill 0.0468 Unloading 0.668 Total Hourly Dust Emissions 0.3632 According to Turkish IAPCR, it is stated that if total dust emission from fugitive sources is higher than 1 kg/hr, air quality dispersion modeling should be performed for both total suspended particles and PM10. As seen in the table below dust emissions calculated for construction phase of the proposed project, do not exceed the limit value of 1 kg/hr. Therefore, no dispersion modeling was performed as it is stated in the Turkish IAPCR. Dust emission impacts will be temporary, limited to the construction period. Mitigation measures are currently in place in order to suppress dust emissions by means of water spraying and improvement of road conditions. With the measures taken to minimize nuisance o communities, dust impact will be negligible. Exhaust emissions Diesel fuel will be used by construction vehicles during construction phase. For the calculation of the exhaust emissions from the construction vehicles, it is estimated that the fuel consumption is 15 lt per vehicle in an hour and all the vehicles operate at the same time. Therefore hourly diesel fuel consumption is estimated as 75 lt. The USEPA AP-42 Emission Factors are used in order to calculate emissions generated by the diesel fueled vehicles. Since the emissions, generated due to operation of these vehicles, will include sulphur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), particulate Final Report March 2018 Project No: 17/010 88 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment matter (PM10) and total organic carbon/volatile organic carbon (TOC/VOC), hourly mass flow of these pollutants were calculated individually as can be seen below. Calorific value of diesel = 137,000 BTU/gal x gal/4.54609 l = 30,135.8 BTU/l. Emissions from construction vehicles are calculated as follows; Carbon monoxide; 0.95 lb/(106BTU) x 30,135.8 BTU/l x 75 l/hr x 0,4536 kg/1 lb = 0.975 kg/hr Sulfur oxide; 0.29 lb/(106BTU) x 30,135.8 BTU/l x 75 l/hr x 0,4536 kg/1 lb = 0.3 kg/hr Total Organic Carbon; 0.35 lb/(106BTU) x 30,135.8 BTU/l x 75 l/hr x 0,4536 kg/1 lb = 0.36 kg/hr Nitrogen oxides; 4.41 lb/(106BTU) x 30,135.8 BTU/l x 75 l/hr x 0,4536 kg/1 lb = 4.53 kg/hr Dust (PM10); 0.31 lb/(106BTU) x 30,135.8 BTU/l x 75 l/hr x 0,4536 kg/1 lb = 0.31 kg/hr Table 7-7. Impacts of Construction Activities on Air Quality Positive Negative Direct Indirect Cumulative Impact Type The impacts of dust , H2S and exhaust emissions during construction are direct and negative. Temporary Short Term Long Term Permanent Impact Duration The impact is limited to the construction stage. Project Area Local Regional National Impact Extent The impact is limited to nearby settlements, thereby local. Negligible Low Medium High Impact Magnitude Impact is low as there will be some perceptible changes in people’s livelihoods, but they will adapt with some relative ease. Unlikely Likely Certain Likelihood of Impact Dust emissions during construction stage are certain due to operation of construction vehicles and drilling equipment. Insignificant Minor Moderate Major Impact Significance Significance of impact is minor as the impact is temporary and mitigation measures are in place. Reversibility of High Medium Low Irreversible Receptor Communities will be free from dust exposure once the construction stage is complete. Final Impact Insignificant Low Medium High/Critical Assessment Impact is insignificant, thereby there is no need for additional mitigation measures. Final Report March 2018 Project No: 17/010 89 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.1.7 Noise Impact Noise will be emitted from the onsite vehicles and machinery during the construction stage. However, construction noise is temporary and transient in the environment. Noise impact during construction on a receptor depends on several factors such as number and type of equipment and machinery used, the distance between noise sensitive receptor and the construction site and level of attenuation likely due to ground absorption, air absorption and barrier effects. Environmental noise measurements have been conducted for the Project within the scope of ESIA studies while construction activities were on-going for which the details are provided in Section 5.6. According to the measurement results noise levels exceed RAMEN limit value of 70 dBA for construction activities at evening time during weekend. The IFC/WB noise guideline provides limits for daytime (07:00-22:00) and nighttime (22:00- 07:00) 55 dBA, and 45 dBA respectively. According to the measurement results IFC/WB noise guideline limits are exceeded during night time at weekdays and daytime and nighttime during weekends. It is possible that the increase of the noise levels on weekends is due to the traffic increase on İzmir-Uşak highway which passes on the south of the project area. Besides Construction activities will not be performed at night therefore nuisance due to noise is not expected to occur at nights. Moreover construction noise is temporary and can be controlled through good site working practices and limiting working hours. Table 7-8. Noise Impacts of the Construction Stage Positive Negative Direct Indirect Cumulative Impact Type Noise impact during construction is direct and negative. Temporary Short Term Long Term Permanent Impact Duration The impact is limited to the construction stage. Project Area Local Regional National Impact Extent The impact is limited to nearby settlements, thereby local. Negligible Low Medium High Impact Magnitude Impact is medium as communities can adapt with difficulty. Unlikely Likely Certain Likelihood of Impact Noise during construction stage is certain due to operation of construction vehicles and drilling equipment. Insignificant Minor Moderate Major Impact Significance Significance of impact is moderate as the impact is temporary and mitigation measures are in place. Reversibility of High Medium Low Irreversible Receptor Communities will be free from noise once the construction stage is complete. Insignificant Low Medium High/Critical Final Impact Assessment Impact is low, yet good practices and proper scheduling of construction activities will be applied for decreasing noise levels. . Final Report March 2018 Project No: 17/010 90 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.2 Operation Phase Impacts 7.2.1 Impacts on Ecology Adverse impacts on terrestrial ecology and biodiversity imposed during the construction stage will disappear at the operation stage. No project-related major adverse impacts on the ecology are anticipated for the operation stage. 7.2.2 Water Supply During the operation stage, water demand will consist of domestic water and drinking water for the personnel and for the cleaning of the facility and irrigation of the green area. Process water will not be required for cooling since the plant is designed as air-cooled system. Drinking water will be supplied in demi-johns and Groundwater from the wells within the Project area will be used for domestic purposes after treatment at the treatment facility which will be established at the Project area. Irrigation water will be used from the wells as well. It is planned to employ a total of 27 personnel during the operation phase of the Project. Water required: 0.203 m3/person/day (Turkish Statistical Institute, 2014) Total water requirement: 0.203 m3/person/day x 27 persons = 5.481 m3/day. It is planned to use 1.0 m3/day of water for cleaning purposes of the administrative building and 2.0 m3/day of water for cleaning purposes of the power plant. Also 3.0 m3 of water will be required for irrigation of green area at the Project area. Total water required for the operation phase is estimated as 11,481 m3/day. 7.2.3 Wastewater Generation There will be no wastewater generation due to the process during the operation phase of the Project. Domestic wastewater generated during operation phase is expected to be 5.481 m3/day. Wastewater from cleaning of the administrative building will be 1.0 m3/day. Wastewater generated from the cleaning of the power plant will be collected separately for potential waste oil and/or hazardous material contamination. Also stormwater will be collected in drainage channels established within the power plant area and discharge to the receiving body will be provided after necessary treatment. Interception channels will also be established around the Project area in order to prevent access of stormwater to the area. Total amount of wastewater generated due to operation activities is expected to be 8.481 m3/day of which 6.481 m3/day is domestic wastewater. Domestic wastewater generated at the operation stage will be collected in a septic tank in compliance with the “Regulation on the Construction of Septic Tanks at Places Where Sewer Final Report March 2018 Project No: 17/010 91 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Construction is Not Feasible”. A protocol will be issued with MASKI and discharge of the waste water collected in the septic tank will be provided periodically. Contaminated wastewater from plant cleaning will be collected separately and discharged according to the requirements of Water Pollution and Control Regulation. 7.2.4 Impacts of Spent Geothermal Fluid Geothermal fluid extracted from the production wells will be reinjected to the original reservoir through reinjection wells. With the use of reinjection system, the residual impact associated with operational discharges of brine geothermal fluid is assessed as having negligible significance. It is planned to construct an impermeable collection pond of 1,400 m3 to be used in case of any failure during reinjection, operation of the power plant or during maintenance of the wells. If the volume of the collection pond is exceeded due to malfunction, extraction of geothermal fluid will be stopped. Geothermal fluid collected in the pond will be reinjected back to the system. Geothermal fluid discharge to any kind of environment will be prevented during the whole Project lifetime. Groundwater quality monitoring will be conducted at downstream of geothermal fluid storage ponds and reinjection wells quarterly. Table 7-9. Impacts of Spent Geothermal Fluid Positive Negative Direct Indirect Cumulative Impact Type Impact of reinjection failure is direct and negative. Temporary Short Term Long Term Permanent Impact Duration The impact is temporary. Project Area Local Regional National Impact Extent Failure of a surface pipeline would lead to contamination of a limited area, including soil and groundwater. Negligible Low Medium High Impact Magnitude According to the Regulation on Control of Soil Contamination, it is compulsory to restore contaminated soil. Furthermore, communities have a tendency to fear that spillage from the reinjection system may harm their crops and react to the Project Company. Unlikely Likely Certain Likelihood of Impact Critical failure of the pipeline is unlikely with a good design and good operation practices including system monitoring. Yet it can happen at any time as an out-of-control aspect. Impact Insignificant Minor Moderate Major Significance Significance of impact is moderate. High Medium Low Irreversible Reversibility of Receptor In case of temporary discharge into a creek, local community distress would rise. Discharge of geothermal fluid would destroy aquatic life in the surface water. Insignificant Low Medium High/Critical Final Impact Assessment Impact is high and requires mitigation measures for preventing impacts on soil and groundwater. Final Report March 2018 Project No: 17/010 92 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Mitigation Measures Spent geothermal fluids generated during operation will be re-injected to the host rock formation, resulting in minor effluent volumes involving reject waters. Potential contaminants in geothermal effluents will vary according to the mineralogy of the host geological formation, temperature of the geothermal water, and site-specific facility processes (IFC EHS Guidelines for Geothermal Power Generation). Potential for contamination of groundwater will be minimized by installation of leak-proof well casings in the injection wells to a depth to the geological formation hosting the geothermal reservoir. In case of failure of reinjection line, system will be shut down. Project Company is developing an Effluent Management Plan to minimize risk of effluent discharges before the start of operation. In the event of emergency discharge of geothermal water to surface waters, geothermal water will be discharged into a retained in a thermal pond, where the temperature of water will drop to allowable limits set by the Water Pollution Control Regulation. The storage pond will be lined and of sufficient size to allow for storage and required cooling to be carried out for the potential duration of the reinjection failure. Groundwater sampling will be conducted from the existing wells at the downstream of the reinjection wells for groundwater quality monitoring purposes. The impact of any potential failure of the reinjection system within the Project area can be effectively managed through good design, regular monitoring and development of appropriate emergency responses. Given that a critical failure of the pipeline is extremely unlikely and with a well-prepared management and monitoring plan in place, the residual impacts can be assessed as low. 7.2.5 Impacts of Solid Wastes Hazardous and non-hazardous solid wastes expected to be generated during the operation stage are domestic solid waste from operation staff, medical waste, packaging wastes, end- of-life tires and waste batteries and accumulators. A Waste Management Plan will be prepared by the Project Company for the different types of waste as described below. There will be no solid waste generation from process. Domestic Solid Waste Domestic solid waste in the operation stage is generated as a result of various consumptions of the operation personnel. According to the EIA Report domestic solid waste generation for 27 personnel will be 33.75 kg/day. Domestic solid waste will be collected and stored in the Project area and disposed by Salihili Municipality according to the requirements of Waste Management Regulation. Furthermore, recyclable waste (i.e. glass, plastics, glass) will be collected separately at source as indicated in Article 5 of the Waste Management Regulation. Final Report March 2018 Project No: 17/010 93 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Packaging Waste Packaging waste generated during the operation stage are composed of recyclable materials such as metal, paper, plastics and glass. Packaging waste will be collected in separate containers in order to be reintegrated into the economy without exposed to any chemical or biological process. In addition, compliance with the Packaging Waste Control Regulation will be ensured for their management during the operation stage. End-of-life Tires Maintenance of the vehicles to be used during the operation stage will be performed at authorized technical stations therefore end-of-life tires are not expected to occur at the Project area. In case there are in the area tires will be sent to licensed companies for disposal in accordance with the Regulation on the Control of End-of-life Tires. Waste Batteries and Accumulators Waste batteries generated during the operation stage will be separately collected in the waste battery containers found at the Project site and periodically will be sent to a Waste Battery Recycling Plant. Compliance will be ensured with the Regulation on the Control of Waste Batteries and Accumulators. There will be no accumulator replacement within the Project area. Empty accumulators generated in compulsory cases will be sent to firms to be replaced with full ones as stated in the Regulation on the Control of Waste Batteries and Accumulators. Waste Oils Waste oil is expected to be generated due to transformer oil used in the switchyard and substation. Maintenance of the transformers will be provided by authorized service companies and disposal of the waste oil will be conducted according to Waste Oil Control Regulation. Waste oil is generated as a result of maintenance of vehicles and equipment. In case of waste oil generation during an oil change, it will be stored and disposed off in accordance with the Waste Oil Control Regulation. Vehicle maintenance will be conducted periodically on a daily, weekly and monthly basis, and oil leakage will be avoided by using drip pans. Waste vegetable oil is not expected to be generated since food service will be outsourced during operation phase of the Project. In case of waste vegetable oil generation compliance with the Waste Vegetable Oil Control Regulation will be provided. Hazardous Wastes Hazardous wastes to be generated during operation phase of the Project is expected to be contaminated materials due to maintenance activities, contaminated packaging material wastes, waste electronics, fluorescent and waste toner and cartridge. Final Report March 2018 Project No: 17/010 94 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment A Waste Management Plan will be prepared by the Project Company before operation phase in order to mitigate impacts from storage of different streams of waste. The Waste Management Plan will comprise of mitigation measures on the basis of different lines of waste generation, and emergency response measures against possible emergency conditions associated with hazardous wastes particularly. Table 7-10. Impacts of Waste Generation and Storage at Operation Stage Positive Negative Direct Indirect Cumulative Impact Type Impact of waste generation without waste management is direct and negative on soil and groundwater. Temporary Short Term Long Term Permanent Impact Duration The impact is long term. Project Area Local Regional National Impact Extent The extent of impact is local. Negligible Low Medium High Impact Magnitude Impact will be high if no mitigation measures are taken and direct contact with ground would cause soil and groundwater contamination. Likelihood of Unlikely Likely Certain Impact Impacts are likely if no waste management is implemented. Insignificant Minor Moderate Major Impact Significance Significance of impact is major as lack of waste management practices would cause contamination of soil and groundwater. Reversibility of High Medium Low Irreversible Receptor Soil and groundwater has low reversibility (depending on the contents of waste). Final Impact Insignificant Low Medium High/Critical Assessment Impact is high and requires mitigation measures. Without any mitigation measures, risks of particularly hazardous waste storage would be high. Given the possible impacts, it is significant to implement well established waste management practices mainly for proper storage of hazardous wastes. Through the implementation of the waste management plan, the impact level will be lowered to minor. 7.2.6 Impacts of Storage of Chemicals During the operation stage; fuels, lubricants and other chemicals may pose risks of soil contamination due to poor storage conditions and practices. Chemical dosing systems will be applied in order to prevent clogging of the transmission pipeline caused by the geothermal fluid. Calcification and corrosion prevention inhibitor will be employed in the system through the chemical dosage systems which will be stablished at each drilling well. It is estimated to inject 1 lt/h inhibitor via the dosage system where the amount will be 3 L/h. The chemical will be supplied domestically therefore it is planned to store an amount of 500 L for a use of 1 week on the site. The use and storage of the Final Report March 2018 Project No: 17/010 95 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment chemical will be conducted according to the Material Safety Data Sheet of the chemical which will be available for the operators at the Project site. Pentane will be used as secondary fluid for the Project in a closed loop system therefore there will be no contact with the geothermal fluid. It is planned to store 100 m3 of n-pentane at the Project site. 73 m3 of 100 m3 n-pentane will be recirculated in the system and the remaining 27 m3 will be stored in storage tanks. The notifications of the chemicals will be done according to the requirements of the Regulation on Prevention of Major Industrial Accidents and Mitigation of Impacts (Date: 30.12.2013, no: 28867). When the operation starts risk category of the facility will be defined and relevant documentation such as Major Industrial Accidents Policy, Emergency Action Plan and Safety Plan. The magnitude of potential change in groundwater quality is assessed to be moderate, because the impact would cause a significant change in water chemistry but would be short lived and the impact highly localized. This could impact on water abstraction close to the site for both local residents. The impact of this risk is therefore assessed to be high without mitigation. Table 7-11. Impacts of Chemicals Storage Positive Negative Direct Indirect Cumulative Impact Type Impact of improper chemicals storage is direct and negative on soil and groundwater. Temporary Short Term Long Term Permanent Impact Duration The impact is long term. Project Area Local Regional National Impact Extent Failure of a surface pipeline would lead to contamination of a limited area. Negligible Low Medium High Impact Magnitude Impact is high if no mitigation measures are taken as leakages and spills would cause soil and groundwater contamination. Likelihood of Unlikely Likely Certain Impact Impacts are likely if no measures are taken against soil and groundwater contamination. Impact Insignificant Minor Moderate Major Significance Significance of impact is major. Reversibility of High Medium Low Irreversible Receptor Soil and groundwater has low reversibility (depending on the chemicals spilled or leaked). Final Impact Insignificant Low Medium High/Critical Assessment Impact will be high if no mitigations are taken. Final Report March 2018 Project No: 17/010 96 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The Project Company will prepare and implement a Hazardous Chemicals Management Plan, supported with a Spill Response Plan. Appropriate containers will be used for segregation and permanent storage of chemicals and fuels on site. Suitable sized storage and well maintained containers with appropriate labelling will be ensured. Through the development and implemented Hazardous Chemicals Management Plan, the impact level will be lowered to minor. According to the pentane use and storage requirements of the Regulation on Prevention of Major Industrial Accidents and Mitigation of Impacts will be complied with and relevant documentation such as Major Industrial Accidents Policy, Emergency Action Plan and Safety Plan will be developed and established according to the risk category of the facility. 7.2.7 Impacts on Air Quality and Odor Impacts The major gaseous emissions from the geothermal power generation processes are CO2 and H2S. The Site will be required to comply with limits indicated in the Regulation on Control of Industrial Air Pollution. The release of the H2S gases during the drilling works and operation stage usually accompanies the severe odor problems in the settlements close to the geothermal plants. Given the binary process of the geothermal power generation, the H2S emissions will be minimal as compared to the other technologies. Still, the Project Company will conduct regular air quality measurements for H2S emissions and commit to taking additional measures if the measurements indicate high levels of H2S concentrations. There will be also H2S detectors at the wellheads. Final Report March 2018 Project No: 17/010 97 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-12. Air Quality and Odor Impacts During the Operation Stage Positive Negative Direct Indirect Cumulative Impact Type Odor impacts and H2S emissions on communities are direct and negative, and cumulative. Temporary Short Term Long Term Permanent Impact Duration The impact is long-term throughout operation stage. Project Area Local Regional National Impact Extent Impact can be regional together with cumulative impacts from other projects in the region. Negligible Low Medium High Impact is medium given that communities in the Area of Influence will have to adapt to the Impact Magnitude exposure to nuisance. Communities are sensitive about the odor issue, as it also gives them an indication for their crops exposed to air pollution caused by geothermal power generation. Unlikely Likely Certain Likelihood of The impact is unlikely as the Project will employ closed-circuit system which will minimize Impact odor emissions, except for temporary odor release at times of maintenance and testing that odor will be emitted. Impact Insignificant Minor Moderate Major Significance Significance of impact is minor. Reversibility of Insignificant Low Medium High Receptor Reversibility of impact is high as odor will diminish once the source is closed down. Final Impact Insignificant Low Medium High/Critical Assessment Overall impact is insignificant and does not require additional mitigation measures. 7.2.8 Environmental Noise Impacts Noise sources during the operational phase of the Project will be mainly the cooling fans along with the auxiliary equipment. According to the EIA Report sound power levels of the equipment to be used during operation phase will be as follows in Table 7-13 below: Table 7-13: Operation Equipment and Sound Power Levels Equipment Number Sound Power Level (dBA) Pump 1 99.2 Fan 1 102.6 Air Compressor and Equipment 1 93.7 Reinjection Pump and Equipment 6 110.2 Fire System 1 98.1 Auxiliary Equipment 1 101.3 IFC/WB Guidelines noise levels at the noise sensitive receptor which should not be exceeded are given in Table 7-14. Final Report March 2018 Project No: 17/010 98 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-14: IFC/WB Noise Limits One Hour LAeq (dBA) Receptor Day Time Night Time (07:00-22:00) (22:00-07:00) Residential; Institutional; Educational 55 45 Industrial, Commercial 70 70 RAMEN sets limit noise levels according to the location of the facility and the type of structures at the vicinity of the facility. Limits applicable for the Project are 60 dBA, 55 dBA and 50 dBA for daytime, eveningtime and nighttime respectively. EIA report predicts equivalent noise levels according to distance as follows in Table 7-15: Table 7-15: Noise Levels for Operation Phase Distance (m) Ldaytime (dBA) 10 78 20 72 30 68 40 65 50 64 100 58 200 52 300 48 400 45 500 44 600 42 1,000 38 2,000 32 3,000 28 As seen in the table, predicted noise level at the nearest receptor comply with the daytime, evening-time and nighttime noise limits of Turkish RAMEN and also IFC/WB Guidelines. Regarding the closest dwelling at Yılmaz village which is at 179 m to the plant site the sound level is calculated as 52.94 dBA which exceeds RAMEN limit of 50 dBA and IFC guideline value of 45 dBA. Therefore environmental noise measurements will be conducted after the start of the operation in order to determine if the noise levels comply with limits. If noise levels are above limits mitigation measures such as establishment of sound barriers will be taken. Final Report March 2018 Project No: 17/010 99 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-16. Noise Impact of the Operation Stage Positive Negative Direct Indirect Cumulative Impact Type Noise impacts on communities are direct and negative. Temporary Short Term Long Term Permanent Impact Duration The impact is long-term throughout operation stage. Project Area Local Regional National Impact Extent Impact is local, limited to the settlements in the Area of Influence. Negligible Low Medium High Impact Magnitude Impact is low given that communities in the Area of Influence will have to adapt to the exposure to nuisance. Likelihood of Unlikely Likely Certain Impact The impact is likely. Impact Insignificant Minor Moderate Major Significance Significance of impact is minor. Reversibility of Insignificant Low Medium High Receptor Reversibility of impact is high as noise will diminish once the source is closed down. Final Impact Insignificant Low Medium High/Critical Assessment Overall impact is low and monitoring will be conducted. 7.2.9 Climate Change Impacts Release of non-condensable gases from the geothermal reservoir raises the issue of impacts that cause climate change. Non-condensable gases are mainly composed of CO2, which has no direct impact on local air quality. As greenhouse gas (GHG) CO2 is associated with combustion of fossil fuels. The Project will lead to releases of greenhouse gases. During tests but mostly during operation, CO2 and methane (CH4) will be released. The worldwide calculations show that the total amount of CO2 avoided by implementing geothermal energy in place of coal proves that a beneficial impact of major significance is gained from geothermal power plants. It should be recalled that binary power plants retain non-condensable gases in a closed circle system. The thermal water is reinjected after utilizing its heat at the heat exchanger resulting in near-zero emissions during the power production process as the non-condensable gases are never released to the atmosphere. However if gas separation occurs within the circulation loop, some minor gas extractions and emission are likely. According to the information obtained from the Project Company CO2 release during operation is calculated for 2 reinjection wells (SAN-3 and SAN-8) and 4 production wells (SAN-4, SAN-5, SAN-6 and SAN-7). Operation with geothermal fluid of 420 ton/hour consisting 2.05 % NCG, 99.0 % of which is CO2 will generate 68,191.2 kg CO2 per year given the fact that the Power Plant will Final Report March 2018 Project No: 17/010 100 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment operate for 8000 hours in one year for 118,700,000.00 kWh of annual electricity production. GHG emission for the operation phase of the Project is calculated as 574.48 g/kWh according to the following calculation: 420 tonnes/hour * 2.05/100 (NCG percentage) * 99/100 (CO2 percentage) = 8.5239 tonnes CO2/h 8.5239 tonnes CO2/h * 1,000,000 g/tonnes * 8,000 hours/year * 1 year/118,700,000 kWh = 574.48 g/kWh Still the Project Company will be analysing the amount and quality of CO2 gas release during operation and will decide on a management strategy as to store or dissolve CO2 in the reinjection water. 7.2.10 Impacts on Landscape Establishment of the geothermal power plant on the existing landscape will unavoidably change the visual aspects of the landscape. Construction of the administrative building, power station, the wells, steam coming from temporary testing of wells can affect the landscape by changing its character and change visual aesthetics. Temporary drilling rigs will be visible to the nearby settlements and be contrasting in the landscape. The highest structure within the scope of the Project will be the drilling rigs of 45 meter however will be erected for a limited period of time. Other Project associated structures erected during the operation phase can be designed with low contrast with the existing landscape. It is likely that the Project structures and steam will be visible by the nearby settlements and some of them will be visible from a distance although the effects can be mitigated by appropriate design of structures with the existing landscape. The landscape around the Project site comprises of agricultural lands at east, west and north and railway and highway on the south. The area has flat topography with no specific visual features except for the Ancient City of Sardis whose boundary is at about 2.5 km distance from the Power Plant Visibility analysis for the landscape impacts on the Ancient City of Sardis was conducted and a visibility map was prepared which is provided below in Figure 7-1. The structural features of the Ancient City are located within a limited area surrounded with orchards at about 4 km from the plant. There are also other structures such as dwellings, orchards and road between the existing and planned Project units (the power plant, wells and aboveground pipelines) and the Ancient City which will decrease the visibility of the units. The distance is also relatively long for creating a major negative landscape impact. . Final Report March 2018 Project No: 17/010 101 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 7-1 Visibility Analysis Map Final Report March 2018 Project No: 17/010 102 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-17. Impact on Landscape Positive Negative Direct Indirect Cumulative Impact Type Impact on landscape is direct and negative. Temporary Short Term Long Term Permanent Impact Duration The impact is long-term throughout construction and operation stage. Project Area Local Regional National Impact Extent Impact is local, limited to the nearby settlements Negligible Low Medium High Impact Magnitude Impact is low given that the area does not comprise specific visual characteristics for the communities. Ancient City of Sardis is at a distance with low visibility of Project components. Likelihood of Unlikely Likely Certain Impact The impact is likely. Impact Insignificant Minor Moderate Major Significance Significance of impact is minor. Reversibility of Insignificant Low Medium High Receptor Reversibility of impact is medium as visual impact will diminish after the Project closure. Final Impact Insignificant Low Medium High/Critical Assessment Overall impact is insignificant and does not require additional mitigation measures. Final Report March 2018 Project No: 17/010 103 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.3 Closure Phase Impacts Operation period of the Project is planned to be 30 years at this stage however the duration can be extended based on maintenance and rehabilitation of the equipment and the system. Therefore closure phase impacts can be altered in the future at the end of the operation phase of the Project. Yet estimated impacts are as follows: 7.3.1 Impacts on Ecology Impacts on Ecology during closure phase activities would be similar to that would occur during construction, but at a reduced magnitude. Noise from machineries and demolition can affect animals, disturb them or scare them which could have impact on results from nesting season. Noise generation during closure phase will be temporary and transient in nature and will be controlled through good site working practices, limited working hours and decommissioning will be planned outside breeding season. Therefore noise impact during closure phase of the Project is expected to be insignificant. Closure activities can temporary cause trapping or accidents for wildlife. Entrance of the animals will be prevented by fences surrounding the Project area. Decommissioning will be planned so it will be continuous and surface finish will not leave hazards of abandoned structures for wildlife. Therefore impact on wildlife during closure phase of the Project is expected to be insignificant. 7.3.2 Water Supply Impact regarding water supply during closure phase will be similar to construction phase. Water will be used for dust suppression and domestic uses. It is expected that the impact will be insignificant during closure phase. 7.3.3 Wastewater Generation Wastewater will be generated due to domestic uses of the workers. Domestic wastewater will be collected in septic tanks and discharged by the Municipality. Impact due to wastewater generation during closure phase is expected to be insignificant. 7.3.4 Impacts of Geothermal Fluid Geothermal fluid will be reinjected to the reservoir during the operation phase of the Project. The wells will be closed after the operation phase is over and there will be no use of geothermal fluid during closure phase. Final Report March 2018 Project No: 17/010 104 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 7.3.5 Impacts of Solid Wastes on Soil and Groundwater Impacts of solid waste will be similar to the construction phase of the Project. There will be non-hazardous solid waste generation by the workers and also waste oil and drilling mud. The requirements of Regulation on Waste Management, Packaging Waste Control Regulation, Regulation on the Control of End-of-life Tires, Regulation on the Control of Waste Batteries and Accumulators will be complied with during closure phase and the impacts are expected to be low after mitigation measures. 7.3.6 Impacts on Air Quality Potential impacts on air quality are expected to be similar to the construction phase of the Project however with a smaller extent. There will be limited earth moving activities and less vehicle movement and demolition of Project components will be conducted minimizing the generation of dust. Therefore impact on air quality during closure phase of the Project is expected to be insignificant. 7.3.7 Noise Impact Noise generation during closure phase will be temporary and transient in nature and will be controlled through good site working practices, limited working hours. Therefore noise impact during closure phase of the Project is expected to be insignificant. 7.4 Impacts of the Energy Transmission Line The route of the energy transmission line (ETL) will be about 6.5 .km. Most of the area on the route is agricultural land. It is projected that there will be 14 towers through the route, each of which has 4 legs, each one with a base area of 2 m x 2 m and a depth of 3 m. The potential impacts of the ETL during the construction phase are expected to be mainly on land use, air quality, noise, soil and groundwater and occupational health and safety. The expropriation procedure, which could be required for the lands along the ETL route, will be undertaken by TEİAŞ, however through obtaining of the easement rights, agricultural lands can remain around the ETL components through the operation phase. It is also important to inform the owners of the lands which are close to the route in advance of construction of the electricity transmission line and transmission towers in order to avoid any grievances due to the construction activities. The emissions during the construction phase will be associated with the dust and exhaust gas resulting from the operation of onsite diesel vehicles, skimming of topsoil layers, and excavation for the electricity transmission towers and transportation of the necessary material and equipment for the construction of the electricity transmission line and transmission towers. The existing access roads will be used if possible and unnecessary traffic will be restricted. Excavated material storage will be minimized and will be covered if Final Report March 2018 Project No: 17/010 105 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment required. The construction impacts will be limited in duration and extent, therefore are expected to be negligible. Improper use or handling and spills of hazardous materials such as insulating oils, paints or fuel can lead to soil and groundwater contamination. In case of storage of hazardous material at the site, the materials will be kept in leak proof containments on designated areas with impermeable floor, spill kits will be available at the working site. Maintenance of the construction vehicles will not occur at the site. The impacts on soil and groundwater are expected to be negligible. Noise generation due to the vehicle movement and construction equipment will occur during the construction activities however will be temporary and transient in the environment. Also, the working hours will be limited in order to prevent nuisance. Therefore, the noise impacts are expected to be negligible. Occupational health and safety hazards during the construction activities are primarily due to the live power lines and working at height. The risk of hazard will be minimized through employment of only trained and certified workers and provision of fall protection systems along with required personal protective equipment (PPE). Furthermore, the local communities should be informed about the high voltage before switching on the transmission line. During the operation phase, the potential impacts are expected to be mainly due to the electromagnetic field (EMF) and corona effect. Although the site will be visited regularly by TEİAŞ for maintenance, there will be no generation of domestic or hazardous wastes, air emissions or noise. During the operation of the ETL, plants and trees will be cleared to protect the electric wires if necessary. The ETLs are the source of the high electricity and magnetic fields because of the high voltage and currents. Although there is no proven adverse impact of electromagnetic field on human health, there are still some potential risks depending on the frequency and intensity of the fields. Therefore, some limits were developed for exposure to electrical and magnetic fields. “IFC EHS Guidelines for Electric Power Transmission and Distribution” presents exposure limits for general public exposure to 50/60 Hz electric and magnetic fields published by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) which are provided below in Table 7-18. Table 7-18. ICNIRP Exposure Limits for General Public Exposure to Electric and Magnetic Fields Frequency Electric Field (V/m) Magnetic Field (μT) 50 Hz 5000 100 60 Hz 4150 83 Final Report March 2018 Project No: 17/010 106 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Although there are no limits regarding electrical and magnetic field exposure in national legislation, the Turkish Standards Institute has defined limit values for Exposure of Human to the Electromagnetic Field-Low Frequencies (0 Hz-10 kHz) (given in the standard of TS ENV 5016-1/April 1996 publication and numbered 29020). Accordingly, the public exposure limit to electric field is 10 kV/m and to magnetic field is 6.4 Gauss (=640 μT). The frequency value for the ETLs operated by alternating current is 50 Hz. According to the study carried out by TEAŞ (former Turkish Electricity Generation and Transmission Incorporation) and TUBİTAK (The Scientific and Technological Research Council of Turkey), the National Metrology Institute in 2001, electric and magnetic fields of some high voltage energy transmission lines were determined. According to this study, electric and magnetic fields of high voltage 154 kV overhead ETLs are in the range of 0.3-1 kV/m and 9-14 mG (= 0.9-1.4 μT), respectively. Since the voltage of the proposed ETL is 154 kV, it can be concluded that electric and magnetic fields of the ETL will be significantly below the limit values presented above. The effect of the electromagnetic field decreases when the distance increases. Therefore, negative impact of EMF of the ETL is not expected at the residential areas close to the predicted ETL route. The Regulation on Electric Power Installations (issued in the Official Gazette dated November 30, 2000 and numbered 24246) defines limitations for the distance between energy transmission lines and settlement areas, roads and other structures. The minimum distance between the ETLs and the settlements considering electric and magnetic field effects and safety issues such as collapse of pylons and lines will be 4 m in accordance with the Regulation on Electric Power Installations. In addition, the width of the ETL corridor (right-of-way) which will be cleared from trees and be expropriated as well will be 50 m. Also, the minimum vertical and horizontal distances to safety zones are defined by the Regulation on Electric Power Installations. Article 44 of the Regulation states that the horizontal distances given in below must exist between the overhead line conductors and the most projected sections of the buildings, near which they pass, with maximum oscillation. Final Report March 2018 Project No: 17/010 107 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 7-19. Minimum Horizontal Distances of the Overhead Line Conductors to the Structures with Maximum Oscillation Permitted Highest Continuous Operation Voltage of the Horizontal Distance Line (kV) (m) 0 – 1 (1 included) 1 1 – 36 (36 included) 2 36 – 72,5 (72.5 included) 3 72,5 – 170 (170 included) 4 170 – 420 (420 included) 5 The regulation also states that that all trees violating conductor stringing and line safety must be trimmed or cut. The minimum horizontal distances of the line conductors to trees in maximum oscillation condition are given in Table 7-20. Table 7-20. Minimum Horizontal Distances of Overhead Line Conductors to Trees Permitted highest operational voltage of the line Horizontal distance (kV) (m) 0 – 1 (1 included) 1 1 – 170 (170 excluded) 2.5 170 3 170 – 420 (420 included) 4.5 The minimum vertical distances of the conductors to the locations and objects over which they pass calculated in accordance with Article 46 of this Regulation with maximum sag are given in Table 7-21. Table 7-21. Minimum Vertical Distances of Overhead Line Conductors to the Places over which They Pass with Maximum Sag Maximum Continuous Operational Voltage of the Line (kV) 0-1 1- Locations 36 72.5 170 420 (1 included) 17.5 Minimum Vertical Distances (m) Water with no traffic (in accordance with 4.5* 5 5 5 6 8.5 the highest surface of the water) Pastures, fields, grassland etc. suitable for 5* 6 6 6 7 9.5 passage of vehicles Village and city roads suitable for the 5.5* 7 7 7 8 12 passage of vehicles Final Report March 2018 Project No: 17/010 108 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Maximum Continuous Operational Voltage of the Line (kV) 0-1 1- Locations 36 72.5 170 420 (1 included) 17.5 Minimum Vertical Distances (m) Intercity highways 7 7 7 7 9 12 Trees 1.5 2.5 2.5 3 3 5 Flat roofs that can be climbed by 2.5 3.5 3.5 4 5 8.7 everybody Sloped roofs that cannot be climbed by 2 3 3 3.5 5 8.7 everybody Electric lines 2 2 2 2 2.5 4.5 Petroleum and natural gas pipelines 9 9 9 9 9 9 Water and canals with traffic (these distances must be measured from the 4.5 4.5 5 5 6 9 highest point of the vehicles that may pass on the highest surface of the waters) Communication lines 1 2.5 2.5 2.5 3.5 4.5 Railways without electricity (measured 7 7 7 7 8 10.5 from the rail ) Motorways 14 14 14 14 14 14 (*) The heights shall be decreased by 0.5 m when insulated overhead line cables are used. High electric fields on the lines with very small radiuses causing ionization of the air around conductor and relative discharge is called corona. Corona occurs on all types of transmission lines, but it becomes more noticeable at higher voltages. It causes electrical losses, a crackling or humming sound, light, ozone production, acid impacts with the moisture, interferences in the radio and TVs. According to the “IFC EHS Guidelines for Electric Power Transmission and Distribution”, this effect is greater with high voltage power lines of 400-800 kV. Since the proposed ETL will have a voltage of 154 kV, it is anticipated that the corona effect will be limited. Hence, a potential corona effect such as a sound effect, will not be perceived by the communities. In addition, maintenance of the ETL will be carried out regularly and contamination in the conductors which increases the corona effect, will be cleared periodically. Final Report March 2018 Project No: 17/010 109 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8. SOCIAL IMPACT ASSESSMENT Although there have been innovations in national environmental legislation regarding the social aspects within the framework of the European Union adaptation process, the lack of social impact assessment process still continues. Turkish EIA legislation does not cover social environment and only limited its scope to the physical and ecological environment. The social environment topics that are included in national legislation are limited to stakeholder engagement and resettlement processes. Therefore, in order to cover the national gaps, the international financial institutions are taken into a consideration for investment projects to minimize environmental and social risks and take actions in equitable and transparent forms. This section of the Report assesses the direct and indirect potential socio-economic impacts of the Project. For this section, impacts likely to have the same receptor and similar mitigation measures for both construction and operation phase are presented in the same section.. Major social issues subject to assessment are:  National Economy  Land Acquisition  Local Economy And Livelihood  Labour Influx  Transportation and Traffic  Community Health and Safety  Occupational Health and Safety  Cultural Heritage Both quantitative and qualitative data collection techniques were used during social impact assessment. 8.1 National Economy Operation Phase There are powerful connections between energy provision and socioeconomic development. Energy is an important factor of socioeconomic development. Turkey’s energy demand has grown rapidly almost every year and it will continue to grow. One of the main consequences of the Project is the provision of energy. This will create beneficial effect on the wider community. Final Report March 2018 Project No: 17/010 110 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 8-1. Impacts on Local Employment Positive Negative Direct Indirect Cumulative Impact Type The impact of energy provision is a positive impact. The Project is expected to address the electricity needs of people nationally. Temporary Short-Term Long Term Permanent Impact Duration Operation phase of the project is planned for 30 years. Project Area Local Regional National Impact Extent Extent of the impact will be National level. Produced energy will be connected to national grid. Negligible Low Medium High Impact Magnitude Impact magnitude is high. Likelihood of Unlikely Likely Certain Impact Likelihood of occurrence of impact will be certain. Impact Insignificant Low Moderate Major Significance Impact will be moderate. Final Impact Insignificant Low Medium High/Critical Assessment The impact of the Energy Provision is a positive impact. Enhancement Measures The Project will address the energy needs of Turkey, contribute to national development, and help improve efficiency and quality of infrastructure services. Residual Impacts The impact will be positive. 8.2 Land Acquisition Construction and Operation Phase The Project is planned to be established on agricultural lands of private owners. Land acquisition for the Project has already been completed by voluntary purchase method. Total area of 84,841.00 m2 has been acquired for Project activities and payment for the area has been completed. No physical displacement occurred for the Project. Existing access roads will be used for the Project activities and there will be no additional land acquisition for access roads. In case additional access roads are required in the future, environmental and social impact assessment will be conducted for the proposed route. The information on purchased lands for the Project provided by the Project Company is provided in Table 8-2 below. Final Report March 2018 Project No: 17/010 111 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 8-2. Land Purchased for the Project Activities Size of Land Purchased Land Remaining Land Parcel No. 2 2 2 Type of Land Use of the Land (m ) (m ) (m ) 1182 6.950,00 6.950,00 0 Agricultural Land Power Plant 1182 6.950,00 6.950,00 0 Agricultural Land Power Plant SAN 4, SAN – 5, 1182 6.950,00 6.950,00 0 Agricultural Land SAN-6 wells 1182 27.800,00 27.800,00 0 Agricultural Land Power Plant 1182 6.950,00 6.950,00 0 Agricultural Land Power Plant For Road and 1181 19.600,00 19.600,00 0 Agricultural Land Crane Use SAN-7 and SAN- 40 81,87 81,87 0 Agricultural Land 8 wells SAN-7 and SAN- 40 81,87 81,87 0 Agricultural Land 8 wells SAN-7 and SAN- 40 81,87 81,87 0 Agricultural Land 8 wells SAN-7 and SAN- 40 163,75 163,75 0 Agricultural Land 8 wells SAN-7 and SAN- 40 163,75 163,75 0 Agricultural Land 8 wells SAN-7 and SAN- 40 163,75 163,75 0 Agricultural Land 8 wells SAN-7 and SAN- 40 54,58 54,58 0 Agricultural Land 8 wells SAN-7 and SAN- 40 54,58 54,58 0 Agricultural Land 8 wells SAN-7 and SAN- 40 27,29 27,29 0 Agricultural Land 8 wells SAN-7 and SAN- 40 27,29 27,29 0 Agricultural Land 8 wells SAN-7 and SAN- 40 122,81 122,81 0 Agricultural Land 8 wells SAN-7 and SAN- 40 40,94 40,94 0 Agricultural Land 8 wells SAN-7 and SAN- 40 491,24 491,24 0 Agricultural Land 8 wells SAN-7 and SAN- 40 491,24 491,24 0 Agricultural Land 8 wells SAN-7 and SAN- 40 42,98 42,98 0 Agricultural Land 8 wells SAN-7 and SAN- 40 42,98 42,98 0 Agricultural Land 8 wells SAN-7 and SAN- 40 42,98 42,98 0 Agricultural Land 8 wells SAN-7 and SAN- 40 42,98 42,98 0 Agricultural Land 8 wells SAN-7 and SAN- 40 42,98 42,98 0 Agricultural Land 8 wells SAN-7 and SAN- 40 184,22 184,22 0 Agricultural Land 8 wells SAN-7 and SAN- 40 184,22 184,22 0 Agricultural Land 8 wells SAN-7 and SAN- 40 184,22 184,22 0 Agricultural Land 8 wells SAN-7 and SAN- 40 184,22 184,22 0 Agricultural Land 8 wells SAN-7 and SAN- 40 767,56 767,56 0 Agricultural Land 8 wells Final Report March 2018 Project No: 17/010 112 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Size of Land Purchased Land Remaining Land Parcel No. 2 2 2 Type of Land Use of the Land (m ) (m ) (m ) 28 1175,00 1175,00 0 Agricultural Land SAN-3 well 28 2350,00 2350,00 0 Agricultural Land SAN-3 well 28 293,75 293,75 0 Agricultural Land SAN-3 well 28 293,75 293,75 0 Agricultural Land SAN-3 well 28 293,75 293,75 0 Agricultural Land SAN-3 well 28 293,75 293,75 0 Agricultural Land SAN-3 well 2 Total 84,841.00 m According to the information obtained from the Project Owner, 90% of the purchased land belongs to a total of 5 land owners. The purchased lands were planted with corn except for parcel 40 which was not cultivated. There were no structures on the lands, only a hovel on parcel 1181 which had been used by the land owners during planting activities to rest underneath. The Project Owner has previous experience on land purchase within the license area. During the earlier stages of Project design, lands in the licence area have been acquired through expropriation by the Project Owner. The lands were not utilized due to insufficient resources and are not utilized for the subject Project of this ESIA. Based on their previous experience, the Project Owner decided to conduct land purchase by voluntary purchase method in order to provide better relationship with the land owners and ease the land purchase process for this 15 MW capacity Project which is subject to potential financing. Prices were negotiated with the land owners and the payments were about twice of the previously determined expropriation prices. In case there was no agreement with the owner for particular lands, alternative parcels were investigated within the license area by the Project Owner and negotiations were pursued with the new land owner. Land acquisition process for energy transmission lines is governed by TEDAS. Expropriation is on-going for the lands on the route for ETL. Since expropriation process is on-going, Project Company has gone to agreements with the land owners to secure access right to the lands before the completion of the expropriation process. Payments for the easement rights of the lands have been conducted by negotiations with the land owners. During the one-on-one interviews with the locals who sold their lands to the Project Company, it was stated that expropriation was not preferred for land acquisition since the values might be lower than negotiated prices, therefore they preferred to go on an agreement with the Project Company on land value rather than expropriation. It was observed during the interviews that there was a common concern on loosing profit in a case of expropriation. Land acquisition process was also discussed during the PPM which was held on 27.09.2016 in Salihli district, Yılmaz neighbourhood in compliance with the Environmental Impact Assessment Regulation. The Project Owner attended the meeting and addressed concerns of the participants. The PPM meeting was announced in the national and local newspapers and was also posted on the billboard of the neighbourhood. Due to the high population of the Final Report March 2018 Project No: 17/010 113 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment neighbourhood level of participation was low. Detailed information on the previous stakeholder engagement activities are provided in SEP document. Table 8-3. Impacts of Land Acquisition on Local Communities Positive Negative Direct Indirect Cumulative Impact Type Land acquisition is a direct impact and was performed by means of voluntary land purchase. Temporary Short Term Long Term Permanent Impact Duration The impact is permanent. Project Area Local Regional National Impact Extent Impact is local, limited to the Project area. Negligible Low Medium High Impact Magnitude Impact is rated medium, as some locals who sold their land either invested in other lands through purchasing or renting as some stated that they did not invest their land acquisition money. Likelihood of Unlikely Likely Certain Impact The impact is certain as land is acquired for the purpose of the Project. Impact Insignificant Minor Moderate Major Significance Significance of impact is moderate. Reversibility of Irreversible Low Medium High Receptor Once the land is occupied for the Project, no further agricultural use will be possible. Insignificant Low Medium High/Critical Final Impact Assessment Impact is high and necessary mitigation measures should be applied throughout the future Project phases not to trigger economic displacement of the locals. Mitigation Measures  Grievance mechanism will be disclosed to the affected community and will be provided as a means of encouraging affected people to state their grievances about the land acquisition process.  Project Company will guide the villagers who sold their lands through community engagement (mainly by organization of trainings with the collaboration of NGOs) toward investing in sustainable income sources.  The Project Company will organize cooperation activities with Project affected local communities. This will include social responsibility projects for the benefit of the affected community. Residual Impacts Given that land acquisition for the Project (15 MW capacity) has already been completed on voluntary purchase, providing assistance when needed and establishing good monitoring system will make the land acquisition process more efficient and will eliminate the possible negative outlook for the Project Company. Final Report March 2018 Project No: 17/010 114 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8.3 Local Economy and Livelihood 8.3.1 Employment Construction and Operation Phase The most important contributor of the Project to the local economy is the employment provided in works during construction. Approximately 100 workers will be hired during the construction phase of the Project. On the other hand, it is estimated that a maximum of 27 workers will be required for the operation phases of the Project. The locals will have the priority for the employment opportunities of the construction phase. Opportunities for local people are most likely to be for unskilled staff positions since the information regarding to social baseline, local people do not have professional skills for the construction and operation phases of the Project. Table 8-4. Impacts on Local Employment Positive Negative Direct Indirect Cumulative Impact Type Employment opportunities will create a positive impact directly from the Project. All geothermal projects will contribute to increased local employment and may reverse out- migration in cumulative terms. Temporary Short-Term Long Term Permanent Impact Duration Impact is long-term. Higher employment opportunities will be possible during construction, and less during operation stage. Project Area Local Regional National Impact Extent Impact will provide benefit particularly to Salihli District. Negligible Low Medium High Impact Magnitude Impact magnitude is positive and medium. Unlikely Likely Certain Likelihood of Impact Employment opportunities within the region and the associated improvement of the local economy are certain impacts of the Project. Impact Insignificant Low Moderate Major Significance Impact will be moderate. Final Impact Insignificant Low Medium High/Critical Assessment The Project will contribute to problems of unemployment as a positive impact. The Project Company will be responsible for human resources for the drilling, construction and operation periods. Turkey is currently in the middle of a harmonization process with the European Union and labor laws are being reviewed to ensure alignment. The Project will comply with national labor, social security and occupational health and safety laws as well as the principles and standards of ILO convention. Based on the national principles embodied in the ILO convention, the Project Company will take measures by:  not employing children under the age of 18, Final Report March 2018 Project No: 17/010 115 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment  eliminating forced labor and ensuring a Human Resources Policy compatible with the European Convention on Human Rights and the Turkish Constitution,  eliminating discrimination based on language, race, sex, political opinion, philosophical beliefs and religion in the employment relationships,  ensuring workers’ access to the right of collective bargaining (Act of Collective Bargaining Agreement on Trade Unions Act No. 6356 and 4857 Labor Law)  ensuring access to the Project grievance mechanism that is functional effectively Labor Law (4857) applies to all establishments and to their employers, employees, employer’s representatives and employee representatives, irrespective of the subject matter of their activities. The Project Company is yet to develop a formal grievance procedure for workers although an informal procedure is in place. The Project Company Human Resources Policy will have provisions for age, wages, working hours, disabled employees, non- employee workers (i.e. sub-contractors), health and safety; and workers camps. Enhancement Measures  Project Company will ensure that its HR Policy will maintain that all workers will have contracts that clearly state the terms and conditions of their employment and their legal rights.  The Project Company will have a Human Resources policy which observes wage standards, working hour regulation, freedom of association and staff encouragement. The policy will also eliminate child and forced labor, discrimination on the basis of religion, language, gender or social status, bullying and harassment. This policy will be developed by the Project Company to cover local employment and training of local people.  Workers will be provided with information including, but not be limited to, entitlement to wages, hours of work, overtime arrangements and overtime compensation, and any benefits (such as leave for illness, maternity / paternity or holiday).  All workers will be able to join trade unions of their choice and have the right to collective bargaining.  Contracts will be verbally explained to all workers where this is necessary to ensure that workers understand their rights prior to any employment contract to be signed.  Wages, benefits and conditions of work offered will be comparable to those offered by equivalent employers in Manisa.  The Project and all contractors will put in place a formal worker grievance mechanism. Residual Impacts Positive impacts will be enhanced with the implementation of the enhancement measures described. Final Report March 2018 Project No: 17/010 116 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8.3.2 Local Economy Construction and Operation The Project will be beneficial for the economic growth in the Region. In addition, the Project may create in-direct employment opportunities during the construction period to provide service for the Project Company. According to Focus Group Discussions, the locals are pleased to provide services and have opportunities to increase their economic income for the Project activities. Table 8-5. Impacts on Local Economy Positive Negative Direct Indirect Cumulative Impact Type The Project will provide benefit to the local business and services, in which will create a positive impact directly from the Project.. Temporary Short-Term Long Term Permanent Impact Duration Impact is long-term. Higher employment opportunities will be possible during construction, and less during operation stage. Project Area Local Regional National Impact Extent Impact will provide benefit particularly to Salihli District. Negligible Low Medium High Impact Magnitude Impact magnitude is positive and medium. Unlikely Likely Certain Likelihood of Impact Economic opportunities within the region and the associated improvement of the local businesses are certain impacts of the Project. Impact Insignificant Low Moderate Major Significance Impact will be moderate. Final Impact Insignificant Low Medium High/Critical Assessment The Project will contribute to problems of unemployment as a positive impact. Mitigation Measures  The Project will have a Business Ethics Policy/Good Neighbor Policy that commits the Project to ‘Buy Local’. Residual Impacts  Positive impacts will be enhanced with the implementation of the enhancement measures described. 8.3.3 Labor Influx Construction Phase Final Report March 2018 Project No: 17/010 117 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The labour influx impacts may be expected during the construction phase of the Project. However, considering that employees figure for construction phase will be 100 and operation phases will be 27 people, which can be assessed to not account for a considerable population increase. The participants of the household survey stated that there has currently been no impact of the Project regarding the magnitude of the local population. No population related impacts are anticipated for the future as well. Local people will be employed to the extent possible. Until now, approximately 25% of the Project workers were employed from Salihli and Alaşehir Districts. Occupation types of these 25% of the local employees are namely as; operation manager, office workers, construction workers, technicians and service workers. In which, it is safe to state that, the Project Company considers all type of education backgrounds of the locals in terms of employment. The nearest settlement to the Project site is Yılmaz, which is anticipated to experience impacts related to the population influx. However, during the community level interviews, there have been no complaints or concerns regarding the influx. Table 8-6. Impacts on Labour Influx Positive Negative Direct Indirect Cumulative Impact Type Population influx impact of the Project is expected to occur throughout the construction phase, however, due to low number of construction workers, no significant concern have been stated from the locals. Temporary Short Term Long Term Permanent Impact Duration It is evaluated as an impact during the construction period of the Project at the site. Project Area Local Regional National Impact Extent Population influx was not a concern of the local resident. Negligible Low Medium High Impact Magnitude Impact magnitude is evaluated as low level. Likelihood of Unlikely Likely Certain Impact Occurrence of the impact is considered unlikely . Impact Insignificant Minor Moderate Major Significance Significance of impact is minor. Insignificant Low Medium High Reversibility of Local people will be employed for construction phase as to an extent possible. Furthermore, Receptor due to low number of Project workers and there is no concern of local community, the reversibility is high. Final Impact Insignificant Low Medium High/Critical Assessment The impact is considered as low, with the implementation of below mitigation measures Final Report March 2018 Project No: 17/010 118 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Mitigation Measures  The Project will provide job opportunities for the residents of nearby settlements to the extent possible.  A code of conduct should be developed and implemented for workers, outlining expected behaviour with respect to their daily interactions with local residents and users of public amenities. This will be part of the labour force management plan to be developed for the Project  The locals are willing to contribute for the Project activities once they feel their opinions matter and received sufficient information regarding the Project activities and potential impacts.  The Project Company will establish a grievance mechanism, which will support the information disclosure process. Residual Impacts  No residual impacts are anticipated. 8.4 Transportation / Traffic Construction Phase Increase in local traffic may be one of the impacts that is expected during the construction phase of the Project. Transportation impacts were one of the concern topics regarding the Project during the Focus Group Meetings as well as Mukhtar meetings. According to residents of AoI; heavy vehicles are damaging the roads and they fear that heavy vehicles may cause closure of narrow roads. Furthermore, communities had questions regarding the dust from heavy vehicles may cause community health issues and may pose safety issues especially on children. Table 8-7. Impacts of Project Transportation Activities Positive Negative Direct Indirect Cumulative Impact Type Traffic load caused by heavy vehicles is a direct and negative impact arising from the Projects. Temporary Short Term Long Term Permanent Impact Duration Since the heavy machineries will be used for the drilling and construction period of the Project, it is going to be a short term impact. Project Area Local Regional National Impact Extent Impacts related to transportation and traffic load is expected to be local. Negligible Low Medium High Impact Magnitude Given the public nuisance expressed during surveys, traffic and transportation are assumed to pose a medium level impact. Final Report March 2018 Project No: 17/010 119 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Unlikely Likely Certain Likelihood of Impact Impacts of transportation operations on community health and safety are unlikely with measures taken. Insignificant Minor Medium High Impact Significance Level of impact significance is minor. Irreversible Low Moderate High Reversibility of Impact Health and safety risks associated with traffic loads from heavy vehicles will disappear once the construction stage is over. Insignificant Low Medium High/Critical Final Impact Assessment Given the high reversibility and measures taken, the impact is considered insignificant. Mitigation Measures  The Project Company will prepare and implement site specific Traffic Management Plan so as to adequately manage traffic in the access roads used by communities. In case of disturbing access roads, the Project Company and its contractors will be responsible to improve the roads back to their original status. Communities will be informed about schedules of transportation and also on safety and security measures to be taken at the level of individuals.  The Project will implement an awareness raising information disclosure with local stakeholders regarding the risks related to the movement of heavy vehicles and increased traffic in the area. The main focus of this campaign will be during the construction phase and will focus on local residents and children. It will be implemented in coordination with local community groups such as Mukhtars.  Warning signs will be placed at entrances and exits of site vehicles.  Establishing rights-of-way, site speed limits, vehicle inspection requirements, operating rules and procedures (e.g. prohibiting operation of forklifts with forks in down position), and control of traffic patterns or direction.  Coordination with emergency responders to ensure that appropriate first aid is provided in the event of accidents.  Using locally sourced materials, whenever possible, to minimize transport distances. Locating associated facilities such as worker camps close to project sites and arranging worker bus transport to minimizing external traffic. Residual Impacts Strict health and safety standards will be implemented including traffic management plan to reduce the road related accidents. With the implementation of above mitigation measures the residual impact of the Project are considered to be low. Final Report March 2018 Project No: 17/010 120 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8.5 Community Health and Safety Construction and Operation Community health and safety issues are associated with pollution factors that may arise from drilling, construction and operation period of the Project. During the focus group discussions, the attendees suggested to conduct brief meeting regarding the possible impacts of the Project that may affect the local community, especially during the construction phase. These concerns are mainly rooted in speculative information that rotated among locals. Communities around the Project area may be exposed to physical hazards associated with the Project components such as wells and pipeline. Besides, confined spaces or falling hazards may occur due to unattended infrastructure. Project area is surrounded with fence in order to prevent physical hazards to communities associated with the Project. Table 8-8. Impacts on Community Health and Safety Positive Negative Direct Indirect Cumulative Increase of, dust emissions and noise due to Project activities are a direct and negative Impact Type impact arising from the Project. Based on misinformation, local people have concerns over investment projects, especially for the construction phase. Temporary Short Term Long Term Permanent Impact Duration Since most of dust and noise emissions will occur during construction period of the Project, it is going to be a short term impact. Project Area Local Regional National Impact Extent Impacts related to transportation and traffic load is expected to be local. Negligible Low Medium High Impact Magnitude Given the public nuisance expressed during surveys, traffic and transportation are assumed to pose a medium level impact. Unlikely Likely Certain Likelihood of Impact Impacts on community health and safety are likely to occur if no mitigation measure is taken. Insignificant Minor Medium High Impact Significance Level of impact significance is medium. Irreversible Low Moderate High Reversibility of Impact Community Health and safety risks are mainly associated with construction phase and expected to disappear once the construction stage is over. Insignificant Low Medium High/Critical Final Impact Assessment Given the high reversibility and measures taken, the impact is considered low. Final Report March 2018 Project No: 17/010 121 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Mitigation Measures  The Project area and wells are surrounded by security fence in order to prevent unauthorized entrance. Health protection strip has also been established for the Project which is 15 m. Warning signs will be in place around the Project area, the wells and pipeline in order to inform the locals for Project site associated risks.  Emergency Response Plan prepared for the Project will be improved in order to cover a contingency plan for hydrogen sulphide release events.  The Project will operate on a closed system and the Project Company will take measures for lowering emissions that cause nuisance. Inclusion of buffer strips or other methods of physical separation around project sites to protect the public from major hazards associated with hazardous materials incidents or process failure, as well as nuisance issues related to noise, odors, or other emissions.  Training and licensing industrial vehicle operators in the safe operation of specialized vehicles such as forklifts, including safe loading/unloading, load limits.  The Project Company will monitor emissions and noise and take immediate measures where necessary. However, the locals are currently misinformed and misguided by means of unproven and non-scientific information. A well-structured stakeholder engagement will minimize public concerns by clearly explaining the project operations, mitigation measures and possible residual impacts. It is recommended that the stakeholder engagement process can be backed up with engagement with universities to undertake research studies and monitor interactions between geothermal drilling and agricultural efficiency. A Stakeholder Engagement Plan is prepared by 2U1K.  The Project Company will perform effective public consultation and stakeholder engagement in order to provide correct and unbiased information on possible environmental and health impacts of the Project as well as the mitigation measures that will be taken. Residual Impacts With the mitigation measures mentioned under respective environmental impact assessment sections, the impacts will be minimized to limits set by regulations. Final Report March 2018 Project No: 17/010 122 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8.6 Occupational Health and Safety Construction and Operation Phase Construction and operation phases of the Project can pose accident risks for the workers. Specific health and safety issues in geothermal power projects include the potential for exposure to geothermal gases, confined spaces, heat and noise. Occupational exposure to geothermal gases, mainly hydrogen sulfide gas, may occur during non-routine release of geothermal fluids (for example, pipeline failures) and maintenance work in confined spaces such as pipelines, turbines, and condensers. The significance of the hydrogen sulfide hazard may vary depending on the location and geological formation particular to the facility. Noise is mainly related to well drilling, steam flashing and venting. Other sources include equipment related to pumping facilities, turbines, and temporary pipe flushing activities. Noise abatement technology includes the use of rock mufflers, sound insulation, and barriers during drilling, in addition to silencers on equipment in the steam processing facility. Through a comprehensive OHS Management System risk of accidents will be minimized for the Project activities. A set of procedures and an OHS management plan will be established for the Project in order to assure occupational health and safety requirements of national and international standards. An OHS Manager has been appointed by the General Manager of Geothermal Investments for the Project in order to provide the effective implementation of the OHS Plan. The organization chart established for the Project is presented below in Hata! Başvuru kaynağı bulunamadı.. Final Report March 2018 Project No: 17/010 123 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment General Manager of Geothermal Investments Finance Procurement Project Manager Incentive Implementation Consultant Resource Development and Mechanical Works and Electrical Works Project Construction Works Project Administrative Affairs Administrative Permits Operation and Site Manager OHS Manager Environmental Manager Project Manager Manager Manager Manager Project Manager HS Inspector Figure 8-1 Organization Chart Final Report March 2018 Project No: 17/010 124 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment The potential impacts of the Project on Occupational Health and Safety is provided below in Table 8-9. Table 8-9. Impacts on Occupational Health and Safety Positive Negative Direct Indirect Cumulative Impact Type OHS risks are direct and negative. Temporary Short Term Long Term Permanent Impact Duration Impacts related with OHS issues may occur during the construction and operation phase Project Area Local Regional National Impact Extent Risks are expected to be local as limited with the Project employees Negligible Low Medium High Impact Magnitude OHS impacts in terms of magnitude can be considered as high. Unlikely Likely Certain Likelihood of Impact Risks are likely in case of not implementing appropriate OHS management system throughout the Project phases. Insignificant Minor Medium High Impact Significance OHS risks may cause high significance. Reversibility of Irreversible Low Moderate High Impact Reversibility of OHS related incidents may be resulted as low. Insignificant Low Medium High/Critical Final Impact Assessment Occupational health and safety impacts can be high. Mitigation Measures  Workers will be provided with contracts which clearly state the terms and conditions of their employment and their legal rights. The Project Company will ensure the workers are aware of the OHS risks of the Project activities and the mitigations to be taken through OHS trainings.  The Project Company will take reasonable precautions in order to prevent occupational accidents, injuries and diseases on site, including measures to reduce and prevent the risk of exposure to harmful levels of ambient factors and chemicals, as well as the risk of injury or disease that may arise from the use of equipment and machinery.  There will be H2S detectors on each well head in order to monitor the hazardous levels of hydrogen sulphide, The Emergency Response Plan will include contingency plan for hydrogen sulphide release events, establishing facility emergency response teams, providing adequate ventilation of occupied buildings to avoid accumulation of hydrogen sulfide gas, development and implementation of a confined space entry program, and providing workers with a fact sheet about the chemical composition of Final Report Project No: 17/010 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment liquid and gaseous phases with an explanation of potential implications for human health and safety.  The Project Company will require all employees and contractors to adhere to local and international health and safety legislation and guidelines. This will include the use of suitable personal protective equipment (PPE), hearing protection, and implementation of and adherence to a management system for activities associated with health and safety risks. These would include such aspects of construction such as working at heights and working in confined spaces.  In order to mitigate occupational exposure to heat occurring during construction activities as well as operation and maintenance, the Project Company will ensure that time required for work in elevated temperature environments is reduced, drinking water is accessible; surfaces where workers come in close contact with hot equipment are shielded.  The Emergency Response Plan has been developed by the Project Company which includes response measures for the situations of accidents, sabotages, fire and electricity shocks, commutable diseases, hydrogen sulfide releases, well blowouts, earthquake, floods, storms and chemical spills. Residual Impacts The overall residual impact on occupational health and safety of the labour force will be low to medium when an OHS management system is fully in place and measures are taken. 8.7 Cultural Heritage Site preparation works can disturb archaeological remains or sites of cultural value. Noise from testing of wells and from the operation of the power plant and odor may have nuisance for the people visiting the sites. Closest archaeological site to the Project area is the Ancient City of Sardis which was classified as 1st and 3rd Degree Archaeological Site according to the Ministry of Culture and Tourism, İzmir 2nd Regional Committee of Protection of Cultural Heritage. The site is also defined as 1st and 3rd Degree Archaeological Site according to United Nations Educational, Scientific and Cultural Organization (UNESCO). According to the official letter of Ministry of Culture and Tourism, İzmir 2nd Regional Committee of Protection of Cultural Heritage no 08.12.2016-7394 no physical or construction activity can be conducted without the Committee consent. Although the license area no.143 for the Project intersects the archaeological site as seen in Figure 8-2 below, the Ancient City of Sardis is at about a distance of 4 km to the Power Plant and the wells while the distance to the boundaries of the site is about 2.5 km from Project units. Therefore the area is not expected to be affected due to Project activities. The impact assessment of the Project on the landscape is provided in Section 7.2.10. Final Report Project No: 17/010 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Figure 8-2 Project License Area and the Ancient City of Sardis Final Report March 2018 Project No: 17/010 127 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Moreover official opinion was obtained from İzmir Cultural Assets Regional Committee on the Project area during the national EIA process for the power plant and the well locations for which the coordinates are provided below in Table 8-10. Table 8-10 Coordinates of Wells Coordinates Well no Type of Use (WGS84) SAN-3 Reinjection 38.497200°:28.091983° SAN-8 Reinjection 38.484597°:28.094202° SAN-4 Production 38.491547°:28.090448° SAN-5 Production 38.491638°:28.090444° SAN-6 Production 38.491455°:28.090445° SAN-7 Production 38.484507°:28.094177° According to the official letter there are no registered archaeological or protected sites or cultural heritage assets according to the requirements of Law on “Conservation of Cultural and Natural Assets” (Law No. 2863, amended with the Law No. 5226) within the Project area. However in case any cultural assets are encountered during any Project activity, the work will be stopped and local Department of Culture and Tourism will be informed. The Project comprises of 2 reinjection wells and 4 production wells for which the locations are provided above in Figure 8-2, however in case of establishment of additional wells for future purposes, a Cultural Heritage Management Plan has been developed for the Project (Annex-3). Final Report March 2018 Project No: 17/010 128 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 8-11. Impacts on Cultural Heritage Positive Negative Direct Indirect Cumulative Impact Type The chance of finding cultural heritage within the borders of Project activities will be direct and negative impact. Temporary Short Term Long Term Permanent Impact Duration The impact is short-term. Project Area Local Regional National Impact Extent The impact is limited to the Project Site. Negligible Low Medium High Impact Magnitude The magnitude of the impact is low. Likelihood of Unlikely Likely Certain Impact Archaeological findings are unlikely to be found within the site borders. Impact Insignificant Minor Moderate Major Significance Impact is insignificant as there are no archaeological findings. High Medium Low Irreversible Reversibility of Receptor In the case of finding archaeological features, findings will be protected and necessary steps will be applied according to national and international regulations and standards. Final Impact Insignificant Low Medium High/Critical Assessment Overall impact is insignificant. Mitigation Measures Regarding that the operation licence area of the Project includes a part of the Ancient City of Sardis, a Cultural Heritage Management Plan is prepared for the Project and will be implemented. In the scope of the Project a Chance Find Procedure is prepared, and it will be implemented during the construction phase of the Project to protect the historical and cultural assets. Residual Impacts No residual impacts expected as the Project will comply with the prepared Cultural Heritage Management Plan and Chance Find Procedure throughout its lifespan. 8.8 Closure Phase Impacts Potential social impacts from closure activities are generally similar to those during the construction phase. Following decommissioning, the site would be restored to approximate its original condition or to some standard that results in stable social and environmental conditions. Impacts would be similar to those addressed for the construction above; however, many of these impacts would be reduced by implementing already established good practices. Final Report March 2018 Project No: 17/010 129 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 8.8.1 Economy and Employment Closure of the Project will result in retrenchment of Project workers of the operation phase over a number of years, which may lead to an increase in unemployment at the local level. The Project will implement the Retrenchment Procedure in line with IFC PS2. Impacts related to Project closure will be assessed in detail during the operation phase, 5 years before the Project closure. On the other hand, the creation of temporary employment opportunities for locals during decommissioning activities may arise as well as local businesses may benefit by providing necessary materials during the closure phase. 8.8.2 Land Use Land use impacts resulting from drilling and construction could be largely reversed by closure activities, depending on the further purpose selected for the Project Site. Impacts related to land use and further decision on the post-Project use of the site will be assessed in detail during the operation phase, in advance of closure phase. 8.8.3 Visual and Landscape At the closure phase, the removal of Project components will be planned so that no signs will be left of the abandoned power plant where possible. The Project area will be restored to its natural and pre-Project state as much as possible. 8.8.4 Community Health and Safety Potential community health and safety impacts during closure are expected to be similar to those during the exploration/ drilling and construction phases of the Project. These impacts may be caused due to earthmoving, use of large equipment, dismantling of industrial components, and transportation of overweight and oversized materials. These activities will prevent direct negative impact to the local community if same mitigation measures (See Section 8.5) will be applied as the construction phase of the Project. Besides the wells will be closed and sealed with cement in order to prevent generation of confined space or falling hazard. The area will be surrounded with fence Given the high reversibility and measures taken, the closure impact is considered insignificant. 8.8.5 Occupational Health and Safety Site decommissioning will involve closure and removal of facilities and wells, including linear infrastructures and finally vegetation restoration and landscaping. These activities may not Final Report March 2018 Project No: 17/010 130 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment cause direct negative impact to the Project workers if same mitigation measures (See Section 8.6) will be applied as the construction phase of the Project. Given the high reversibility and measures taken, the closure impact is considered insignificant. 8.8.6 Cultural Heritage Impacts related to closure will be assessed in detail throughout the Project phases, in advance of closure. It is expected that no impacts on physical cultural heritage will occur at Project Closure. Therefore, the closure impact is considered as insignificant. Final Report March 2018 Project No: 17/010 131 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 9. CUMULATIVE IMPACTS There are no planned or operating geothermal power plants close to the Project area. Closest geothermal power plants are located at Alaşehir District of Manisa. Given that the Project is at construction stage, nuisance of dust and noise are associated with the drilling and construction activities and transportation activities. Such nuisance is considered as low and temporary, limited to the construction period. Hence dust and noise impacts are not considered to pose a cumulative impact along with other project in the district. Odor caused by hydrogen sulphide from geothermal fluid can be considered to pose a cumulative impact during the operation stage. Continuous monitoring of hydrogen sulphide levels and grievance from communities will be crucial for determining requirements for extended odor control. Technical measures to abate hydrogen sulphide can be designated once the power plant is operational, given that the sulphide content of geothermal fluid is not known. Still, the closed circuit make-up of the Project will accomplish significant abatement of hydrogen sulfide emissions and related odor. One of the drivers for the Project is clean electricity generation without depleting the resource and minimizing emissions of greenhouse gases (GHGs) associated with combustion of fossil fuels. Yet, the Project will lead to releases of greenhouse gases, mainly CO2. During construction, CO2 will be released from combustion sources such as the diesel generators and the construction plant engines. During tests, but mostly during operation, CO 2 and methane CH4 will be released as non-condensable gases. The impacts of emissions of greenhouse gases are global, hence cumulative. By nature of these emissions, the specific impacts of any single project cannot be easily assigned. The licence area of the Project comprises of 21 wells with geothermal potential. The construction impact of the additional wells will be similar to the subject Project. Operation at the additional wells will increase CO2 release however as mentioned in the previous sections Project Company will be analysing the amount and quality of CO 2 gas release during operation and will decide on a management strategy as to store or dissolve CO2 in the reinjection water. Regarding the H2S emissions which may have effect on locals, the Project Company will continue monitoring H2S levels. Land take will be an issue regarding the change on agricultural land use characteristics permanently. Primary approach of the Project Company will be to negotiate and reach to an agreed price with the land owners in order to avoid involuntary resettlement through expropriation. Although the geothermal capacity is predicted as 31,500 MW by the Ministry of Energy and Natural Resources cumulative impacts of geothermal power plants have not been explicitly determined on the reservoir of the region yet. An extensive study lead by the Association of Final Report March 2018 Project No: 17/010 132 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Geothermal Energy Power Plant Investors has been on-going with the collaboration of stakeholders including Project owners and operators, local authorities and other industry developments in the region. Final Report March 2018 Project No: 17/010 133 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 10. INSTITUTIONAL ARRANGEMENTS The Project will comply with both Turkish legislation and IFC/WB Performance Standards requirements through its lifespan. An Environmental and Social Mitigation and Monitoring Plan (ESMMP) is established for the Project in order to determine the implementation program of mitigation measures and actions associated with the potential environmental and social impacts of the Project. The ESMP sets out the environmental and social impacts of the Project and associated measures to avoid, or where avoidance is not possible, mitigate the adverse on environment and communities. SANKO has the capability in order to implement mitigation measures and monitoring activities effectively and will establish an organizational structure for the implementation of the ESMMP. SANKO will appoint personnel for the implementation of ESMMP activities throughout the Project life. Contractors and subcontractors will also be employed by the Project Company during construction phase of the Project. Project Company will assure that the contractors are aware of the requirements of the ESMMP and will meet the requirements of the ESMMP. An effective contractors’ management will be achieved by;  Assessment of environmental and social risks associated with contractors;  Inclusion of PS and ESMMP requirements in tender documents;  Selection of contractors with knowledge and skills to perform in accordance with PSs and ESMMP requirements;  Monitoring of contractors for the compliance with ESMMP requirements; An Environmental Manager has been assigned for both the construction and operation phases of the Project. The organization chart of the Project is presented in Figure 8-1. The Project Company will ensure the implementation of the ESMMP requirements through continuous supervision of the Environmental Manager including the sub-contractor activities if any. The Environmental Manager and the OHS Manager are responsible for the development of the management plans to provide compliance with the ESIA and the ESMMP requirements and monitor their implementation. The management plans will be issued after the review and approval of Project Manager and General Manager of Geothermal Investments. The key responsibilities for the implementation and supervision for the implementation of the ESMMP are given below in Table 10-1: Final Report March 2018 Project No: 17/010 134 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 10-1. Roles and Responsibilities Role Responsibility General Manager of Geothermal  Provide leadership and direction to achieve Environmental /OHS Investments and Social goals, targets and objectives.  Responsible for the implementation of approval process Project Manager  Provide authority and resources for effective implementation of Project policies and Environmental and Social Management System,  Responsible for the implementation of the requirements regarding Project Environmental / OHS and Social Management System  Responsible for the implementation of review process Environmental Manager  Act as management representative on Environmental and Social issues and report to the Project Manager,  Prepare, implement, and monitor the Project Environmental and Social Management Plans,  Follow the Project related national and international legislation,  Assure and monitor the implementation of ESMMP requirements, analyse the E&S performances and report to the Project Manager,  Investigate the causes of the environmental and social incidents, OHS Manager  Act as management representative on OHS issues and report to the Project Manager,  Prepare, implement, and monitor the Project OHS Management Plans,  Follow the the Project related national and international legislation,  Assure and monitor the implementation of ESMMP requirements, analyse the OHS performances and report to the Project Manager,  Investigate the causes of the OHS incidents, Company management plans have been prepared and provided as annex to the ESIA report. The Management Plans will be revised to be specific to the Project along with the implementation of the ESIA requirements. The list of the management plans are as follows:  Construction Emergency Response Plan  Operation Emergency Response Plan  Occupational Health and Safety Plan  Traffic Management Plan  Waste Management Plan  Effluent Management Plan  Hazardous Chemical Management Plan The Project Company will also assign an External Environmental Consultantto monitor the performance of the implementation of the ESMMP during the Project. The Consultant will report the monitoring results and proposed mitigation measures for the findings periodically. The roles and responsibilities for the implementation and monitoring of ESMMP during construction and operation phases of the Project are summarized below in Table 10-1. Final Report March 2018 Project No: 17/010 135 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Table 10-1 Roles and Responsibilities Activity Responsible Party Monitoring Period Monitoring Environmental Analysis/Measurement Implementation of Manager of the Reports, Grievance Periodically ESMMP Project Records, Internal Audit Company/Contractor Records Performance External Company Annual Monitoring Report Monitoring of ESMMP Final Report March 2018 Project No: 17/010 136 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 11. E&S Mitigation and Monitoring Plan 11.1 Construction Stage E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency Water Pollution Control Regulation Geothermal fluid will be reinjected Visual inspection to ensure the Regulation on back to the system into reinjection effectiveness of the mitigation Monitoring of Surface wells measures water and Groundwater Project Company and Geothermal fluid Geothermal fluid collection ponds Groundwater quality monitoring Groundwater contamination Contractors covered with impermeable layer will at downstream of geothermal Regulation on be established for emergency fluid storage ponds will be Monitoring of situations. conducted quarterly (Quarterly) Groundwater Against Pollution and Deterioration Water Pollution Control Regulation Visual inspection to ensure the Regulation on effectiveness of the mitigation Monitoring of Surface Appropriate well casing will be measures water and Chemicals from Groundwater provided (closed casings during Project Company and Groundwater quality monitoring Groundwater drilling contamination drilling and concrete cover around Contractors casings) at downstream of reinjection Regulation on wells will be conducted quarterly Monitoring of (Quarterly) Groundwater Against Pollution and Deterioration Drilling mud will be collected in mud Visual inspection to ensure the Water Pollution Control ponds provided with impermeable effectiveness of the mitigation Regulation Soil and groundwater Project Company and Drilling mud layer. measures Circular on the contamination Contractors The mud will be analyzed and Analysis report of drilling mud Disposal of Drilling disposed according to the analysis Mud and Wastes Final Report March 2018 Project No: 17/010 137 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment results. Generated from the Physical Treatment of Chromium Minery, Waste Management Regulation Regulation on Monitoring of Surface water and Groundwater Regulation on Monitoring of Groundwater Against Pollution and Deterioration Regulation on Landfill of Wastes Air quality measurements for Temporary odor due to monitoring of H2S Project Company and Industrial Air Pollution H2S emissions H2S release from test Use of gas separators concentrations at sensitive Contractors Control Regulation waters receptors. (Quarterly) Waste Management Wastewater generated by the Regulation workers will be collected in leak Regulation on the Wastewater Soil and groundwater Project Company and proof septic tank and will be Wastewater disposal records Construction of Septic management contamination Contractors disposed by Salihli Municipality Tanks at Places Where regularly. Sewer Construction is Not Possible Improper dumping of solid waste to the environment which can cause soil and groundwater contamination Visual inspection to ensure the Solid waste Soil and groundwater will be prevented. effectiveness of the mitigation Project Company and Waste Management management contamination Wastes will be collected and stored measures Contractors Regulation separately according to their types. Waste disposal records Domestic solid waste will be collected in leak proof garbage Final Report March 2018 Project No: 17/010 138 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment containers. Waste will be collected and disposed by Salihli Municipality. Vegetative top soil stripped during site preparation will be stored separately to be used for landscaping purposes Excavated soil will be stored and re-used for backfilling during construction activities. Waste Management Plan will be implemented for the collection, storage and disposal of wastes Hazardous material will be stored in leak proof containers on impermeable ground. Visual inspection to ensure the Regulation on Soil Spill kits will be available at the site effectiveness of the mitigation Handling of Pollution Control and Soil and groundwater for immediate response. measures Project Company and hazardous Point Source Polluted contamination MSDS for chemicals will be Soil quality analysis for heavy Contractors Areas material available for the workers. metal and hydrocarbons if any Hazardous Chemicals Management contamination risk is observed Plan will be developed and implemented. Water Pollution Control Regulation, Automated monitoring system Regulation on will be established at two Monitoring of Surface locations to monitor temperature water and Sustainability of and EC in groundwater. Project Company and Groundwater use Groundwater shallow aquifers - (continuously) Contractors Regulation on Water level measurements Monitoring of (Monthly) Groundwater Against Pollution and Deterioration Impact on flora Loss of vegetation and Topsoil will be stripped and stored Visual inspections to ensure the Project Company and Waste Management Final Report March 2018 Project No: 17/010 139 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment and fauna top soil in designated storage areas for effectiveness of the mitigation Contractors Regulation further site restoration works. measures (Daily) Water Pollution Control Storage areas will be prevented Regulation,, from the accumulation of storm IFC PS6 water, provided with drainage. Weed growth in stockpiles of topsoil will be prevented and the stockpiles will be seeded if required. Existing access roads will be used for Project purposes and off-road driving will be prohibited. Project activities will be limited in the construction area and construction sites will be surrounded with fences to prevent wild animals intrusion to the site. Hunting or collection of animals will be strictly prohibited within the Project area. Awareness among all construction workers will be provided during the lifetime of the Project for especially the fauna species with limited mobility. If these species, are observed, they will be translocated to undisturbed but similar areas. An OHS Management Plan will be developed and implemented for the Project. Poisoning from H2S All workers will be provided with and odour nuisance. Visual inspections to ensure the OHS training prior to start working Project Company and Law on Occupational OHS Workers health and effectiveness of the mitigation Workers will be provided with Contractors Health and Safety safety risks during the measures (Daily) appropriate PPE. construction works H2S detectors will be placed at well heads to monitor H2S levels Emergency Response Plan will be Final Report March 2018 Project No: 17/010 140 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment improved including evacuation procedure regarding H2S release Maintenance of construction equipment will be conducted regularly, exhaust mufflers will be applied to the equipment in order to minimize noise emissions and also speed limits will be implemented for the vehicles. Construction works will not be performed at nighttime. Construction site and wells will be surrounded by fences. Regulation on Warning signs will be in place Assessment and Nuisance from noise Environmental noise Management of around the Project area, the wells Project Company and Community HS and dust, H2S measurement at sensitive Environmental Noise and pipeline in order to inform the Contractors exposure locals for Project site associated receptors. (Upon grievance) Industrial Air Pollution risks. Control Regulation H2S levels will be monitored IFC PS4 through H2S detectors at well heads. Community will be informed immediately in case of high levels. An emergency preparedness and response plan to be enacted in the event of abnormal operation. Information boards about public safety hazards and emergency contact information will be available in the Project site. In case of land take negotiations with the land owners and mutual agreement on price will be primary Meeting records with Loss of agricultural Project Company and Expropriation Law, Land use approach of the Project Company. stakeholders land Contractors IFC PS5 In case of a Resettlement Action Grievance records Plan/Abbreviated Resettlement Action Plan (RAP/ARAP) for land Final Report March 2018 Project No: 17/010 141 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment acquisition will be prepared and implemented. Stakeholder Engagement Plan will be updated. Priority to local employment will be given to the extend possible. Impact on local Grievance Records Awareness of workers on expected Project Company and Labor Influx infrastructure and Stakeholder Engagement IFC PS2, PS4 behavior on their relations with the Contractors social conflicts Activities locals through a developed Code of Conduct Site specific traffic management will be developed and implemented. If damage on the roads occurs due to Project activities, required maintenance and repair will be Visual inspections to ensure the Risks to locals and Transportation / performed. effectiveness of the mitigation Project Company and especially to children IFC PS1, PS4 Traffic Local communities will be informed measures Contractors Damaging Roads on the traffic schedule. Grievance Mechanism Warning and safety signs will be in place on the access roads and exit and entrance of the construction site. Construction works will be monitored for archaeological remains. Work will cease in case Possible damage to any archaeological remains are Ancient City of Sardis met. Law on Preservation of Reporting by archaeologists Cultural Heritage Project Company Cultural and Natural Possible Cultural Heritage Management Plan (Upon any chance finds) Assets archaeological finds will be implemented for Project activities. Chance Find Procedure will be in place for Project acitvities. Positive impact on Number of local workers Employment - Project Company - local employment employed Final Report March 2018 Project No: 17/010 142 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Records of local material and Positive impact on service providers Local economy - Project Company - local economy Records of local procurement Final Report March 2018 Project No: 17/010 143 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 11.2 Operation Stage E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency Water Pollution Control Regulation Geothermal fluid will be reinjected Visual inspection to ensure the back to the system into reinjection effectiveness of the mitigation Regulation on wells measures Monitoring of Surface Groundwater water and Groundwater Geothermal fluid Geothermal fluid collection ponds Groundwater quality monitoring Project Company contamination Regulation on covered with impermeable layer will at downstream of geothermal be established for emergency fluid storage ponds will be Monitoring of situations. conducted quarterly (Quarterly) Groundwater Against Pollution and Deterioration Water Pollution Control Regulation Visual inspection to ensure the effectiveness of the mitigation Regulation on Appropriate well casing will be measures Monitoring of Surface Chemicals from Groundwater provided (closed casings during water and Groundwater Groundwater quality monitoring Project Company drilling contamination drilling and concrete cover around Regulation on casings) at downstream of reinjection wells will be conducted quarterly Monitoring of (Quarterly) Groundwater Against Pollution and Deterioration Water Pollution Control Regulation Drilling mud will be collected in mud Circular on the ponds provided with impermeable Visual inspection to ensure the Disposal of Drilling Soil and groundwater layer. effectiveness of the mitigation Mud and Wastes Drilling mud measures Project Company contamination The mud will be analyzed and Generated from the disposed according to the analysis Analysis report of drilling mud Physical Treatment of results. Chromium Minery, Waste Management Regulation Final Report March 2018 Project No: 17/010 144 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency Regulation on Monitoring of Surface water and Groundwater Regulation on Monitoring of Groundwater Against Pollution and Deterioration Regulation on Landfill of Wastes Air quality measurements for Temporary odor due to monitoring of H2S concentrations Industrial Air Pollution H2S emissions H2S release from test Use of gas separators Project Company at sensitive receptors. Control Regulation waters (Quarterly) Waste Management Wastewater generated by the Regulation workers will be collected in leak Regulation on the Wastewater Soil and groundwater proof septic tank and will be Wastewater disposal records Project Company Construction of Septic management contamination disposed by Salihli Municipality Tanks at Places Where regularly. Sewer Construction is Not Possible Improper dumping of solid waste to the environment which can cause soil and groundwater contamination will be prevented. Wastes will be collected and stored Visual inspection to ensure the Soil and groundwater Solid waste separately according to their types. effectiveness of the mitigation Waste Management contamination Project Company management Domestic solid waste will be measures Regulation collected in leak proof garbage Waste disposal records containers. Waste will be collected and disposed by Salihli Municipality. Vegetative top soil stripped during Final Report March 2018 Project No: 17/010 145 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency site preparation will be stored separately to be used for landscaping purposes Excavated soil will be stored and re- used for backfilling during construction activities. Waste Management Plan will be implemented for the collection, storage and disposal of wastes Hazardous material will be stored in leak proof containers on impermeable ground. Visual inspection to ensure the effectiveness of the mitigation Regulation on Soil Spill kits will be available at the site measures Handling of Pollution Control and Soil and groundwater for immediate response. hazardous Soil quality analysis for heavy Project Company Point Source Polluted contamination MSDS for chemicals will be Areas material metal and hydrocarbons if any available for the workers. contamination risk is observed Hazardous Chemicals Management Plan will be developed and implemented. Water Pollution Control Regulation, Automated monitoring system will be established at two Regulation on locations to monitor temperature Monitoring of Surface Sustainability of and EC in groundwater. water and Groundwater Groundwater use Project Company shallow aquifers - (continuously) Regulation on Water level measurements Monitoring of (Monthly) Groundwater Against Pollution and Deterioration Poisoning from H2S H2S detectors will be placed at well Visual inspection to ensure the and odour nuisance. Law on Occupational OHS heads effectiveness of the mitigation Project Company Workers health and Health and Safety OHS Management Plan will be measures safety risks during the Final Report March 2018 Project No: 17/010 146 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency construction works developed and implemented (Daily) Emergency Response Plan will be improved including evacuation procedure regarding H2S release Appropriate PPEs will be provided for workers Appropriate Training will be provided for the workers Maintenance of construction equipment will be conducted regularly, exhaust mufflers will be applied to the equipment in order to minimize noise emissions and also speed limits will be implemented for the vehicles. Construction works will not be performed at nighttime. Construction site and wells will be Continuous monitoring of Odor Regulation on surrounded by fences in order to from H2S. Nuisance from noise Assessment and and dust, H2S prevent unauthorized entrance. Noise measurements before Management of exposure Warning signs will be in place start of the operation and upon Environmental Noise Community HS Project Company around the Project area, the wells complaint. Accident risk at the Industrial Air Pollution project site and pipeline in order to inform the Environmental noise Control Regulation locals for Project site associated measurement at sensitive IFC PS4 risks. receptors. (Upon grievance) H2S levels will be monitored through H2S detectors at well heads. Community will be informed immediately in case of high levels. An emergency preparedness and response plan to be enacted in the event of abnormal operation. Information boards about public safety hazards and emergency Final Report March 2018 Project No: 17/010 147 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment E&S Potential Impacts and Monitoring Indicators and Mitigation Measures Responsible Entity Legal Framework Issues Risks Frequency contact information will be available in the Project site. Gas release from CO2 emissions - Biannual assessment Project Company - steam separation In case of land take negotiations with the land owners and mutual agreement on price will be primary approach of the Project Company. In case expropriation occurs for the Meeting records with Loss of agricultural Project, a Resettlement Action Expropriation Law, Land use stakeholders Project Company land Plan/Abbreviated Resettlement IFC PS5 Action Plan (RAP/ARAP) for land Grievance records acquisition will be prepared and implemented. Stakeholder Engagement Plan will be updated. Priority to local employment will be given to the extent possible. Impact on local Grievance Records Labor Influx infrastructure and Awareness of workers on expected Project Company IFC PS2, PS4 Stakeholder Engagement social conflicts behavior on their relations with the Activities locals through a developed Code of Conduct National Positive impact on - Annual energy production Project Company - economy national economy Positive impact on local Number of local workers Employment - Project Company - employment employed Records of local material and Positive impact on local service providers Local economy - Project Company - economy Records of local procurement Final Report March 2018 Project No: 17/010 148 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Final Report March 2018 Project No: 17/010 149 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment 12. REFERENCES Baran, I. 2005, Amphibia and Reptiles of Turkey. Tübitak Popular Science Books, Ankara. Başoğlu, M., Baran.., 1998. Turkey Reptiles Section 1 Turtles and Lizards EÜ Science Faculty Books Series No: 76 Başoğlu, M., Baran.., 1998. Turkey Reptiles Section 2 Snakes EÜ Science Faculty Books Series No: 81 BERN Convention 2002; Convention on the Conservation of European Wildlife and Natural Habitats. CITES 2004; Convention on International Trade in Endangered Species of Wild Fauna and Flora. Davis, P. H, 1965-1988. Flora of Turkey and East Aegean Islands. Vol. 1-10, University Press, Edinburgh. Demirsoy, 1997, Amphibians of Turkey , METEKSAN Publications, 69 h, Ankara, Demirsoy, 1998, Mammals of Turkey , METEKSAN Publications, 292 s, Ankara, Demirsoy, 2001, Birds of Turkey , METEKSAN Publications, 520 s, Ankara, Demirsoy, 2006, Reptiles of Turkey , METEKSAN Publications, 205 h, Ankara, Demirsoy, A. (1999). General and Turkey Zoogeography "Animal Geography". Ankara: Meteksan A.Ş. Publications. Ekim, Tuna and Friends, Endemic Endangered and Endangered Plant Species of Turkey. Kaplan U, Serpen U (2010) Developing geothermal power plants for geothermal fields in Western Turkey. In: World geothermal congress proceedings Kiziroğlu, İ., 2008, Red Data Book for Birds of Turkey, Ankara. Manisa Provincial Culture and Tourism Directorate . Manisa'dan Yetişenler. http://www.manisakulturturizm.gov.tr/TR,151849/manisadan-yetisenler.html Manisa Provincial Health Directorate. (2017). http://www.manisa.saglik.gov.tr/TR,21793/saglik-kurumlari.html Özeti. N., Yılmaz.., 1994. Turkey Amphibiousies EÜ Science Faculty Books Series No: 151 Secmen, O, 1995. Seeded Plant Systems, Ege University, Science Faculty Books Series No: 116, İzmir The Strategic Plan of Turkey for 2015-2019 published by the Ministry of Energy and Natural Resources Thrá nn Fridriksson, A. M. (2016, April). Greenhouse Gases from Geothermal Power Production. Energy Sector Management Assistance Program, The World Bank. Final Report March 2018 Project No: 17/010 150 / 151 SANKO Geothermal Power Plant Project Environmental and Social Impact Assessment Turkish Statistical Institute . (2016). https://biruni.tuik.gov.tr/gosterge/?locale=tr U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy. Geothermal Electricity Generation. 2017 https://energy.gov/eere/geothermal/electricity-generation Union of Concerned Scientists. Environmental Impacts of Geothermal Energy. 2017 http://www.ucsusa.org/clean_energy/our-energy-choices/renewable-energy/environmental- impacts-geothermal-energy.html#.WjPxQMaB3oz Final Report March 2018 Project No: 17/010 151 / 151 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan SANKO GEOTHERMAL POWER PLANT PROJECT STAKEHOLDER ENGAGEMENT PLAN (SEP) MARCH 2018 ANKARA Final March 2018 Project No: 17/010 i/v SANKO Geothermal Power Plant Project Stakeholder Engagement Plan SANKO GEOTHERMAL POWER PLANT PROJECT STAKEHOLDER ENGAGEMENT PLAN Revision Version Date Prepared By Checked By Approved By December 13, 2017 October 23, 2017 Elçin Kaya Günal Özenirler Turgay Eser Final Draft Sociologist Environmental Engineer Environmental Engineer A1 Elçin Kaya Günal Özenirler Turgay Eser Final Draft Sociologist Environmental Engineer Environmental Engineer B1 Elçin Kaya Günal Özenirler Turgay Eser January 15, Sociologist Environmental Engineer Environmental Engineer 2017 Final C1 Elçin Kaya Günal Özenirler Turgay Eser March 07, Sociologist Environmental Engineer Environmental Engineer 2018 Final C2 REVISION CODES: A: DRAFT, B: FINAL DRAFT, C: FINAL PROJECT NO: 17/010 MARCH 2018 CLIENT: CONSULTANT: 15 Temmuz Mah. Gülbahar Cad. Tepe Prime İş Ve Yaşam Merkezi No: 43 K: 6-7 34212 Mustafa Kemal Mahallesi Dumlupınar Güneşli / İstanbul/ Türkiye Bulvarı No: 266 B Blok Kat: 2 Daire: 37 :+90 444 87 65 Çankaya - Ankara / Türkiye : +90 (212) 410 46 66 : +90 (312) 295 62 48 : +90 (312) 295 62 00 Final March 2018 Project No: 17/010 ii/v SANKO Geothermal Power Plant Project Stakeholder Engagement Plan TABLE OF CONTENTS Page 1 INTRODUCTION ........................................................................................................... 1 2 PROJECT LOCATION and AREA OF INFLUENCE .................................................... 2 3 REGULATORY REQUIREMENTS ................................................................................ 6 3.1 Turkish Legislation ................................................................................................ 6 3.2 World Bank Standards .......................................................................................... 6 3.3 Gaps Between Turkish Legislation and International Guidelines ........................... 7 4 ROLES AND RESPONSIBILITIES ............................................................................... 8 5 PROJECT STAKEHOLDERS ......................................................................................11 5.1 Stakeholder Identification and Categorization ......................................................11 6 STAKEHOLDER ENGAGEMENT TOOLS...................................................................13 7 PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES ........................................15 7.1 Engagement for the Turkish EIA ..........................................................................15 7.2 Social Baseline and Impact Assessment Activities ...............................................16 7.3 Outputs of Social Field Study ...............................................................................19 7.3.1 Focus Group Discussions .................................................................................19 7.3.2 Key Informant Interviews ..................................................................................21 7.3.3 Community Level Surveys ................................................................................23 7.3.4 Household Surveys (Land Acquisition) .............................................................25 8 SOCIAL RESPONSIBILITY PROJECTS .....................................................................26 9 FUTURE STAKEHOLDER ENGAGEMENT ................................................................27 9.1 Phase-2: ESIA Disclosure ....................................................................................27 9.2 Phase-3: Implementation .....................................................................................27 10 THE GRIEVANCE MECHANISM .................................................................................30 10.1 Grievance Procedure Channels of Communication ..............................................32 ANNEX - 1 Complaint Register Form ..........................................................................33 ANNEX - 2 Grievance Closeout Form ..........................................................................34 Final March 2018 Project No: 17/010 iii/v SANKO Geothermal Power Plant Project Stakeholder Engagement Plan LIST OF TABLES Page Table 2-1. Settlements and their Distance to the Project Site .............................................. 3 Table 4-1. Key Roles and Responsibilities .........................................................................10 Table 5-1. Stakeholder Groups ..........................................................................................12 Table 6-1 Stakeholder Engagement Approach ...................................................................14 Table 7-1. Summary of Field Studies .................................................................................17 Table 7-2. Summary of Key Issues of FGDs ......................................................................19 Table 7-3 Summary of Key Informant Interviews ................................................................21 Table 7-4 Summary of Community Level Surveys ..............................................................24 LIST OF FIGURES Figure 2-1. Project Location ................................................................................................ 2 Figure 2-2. Geographical Location of the Project and Associated Facilities ......................... 5 Figure 4-1 Organization Chart ............................................................................................. 9 Figure 7-1. General View from Public Participation Meeting ...............................................15 Figure 7-2. Photos of Community Survey ...........................................................................18 LIST OF BOXES Box 3-1. Specific Objectives of National EIA Regulation of Turkey (25.11.2014, Article-9) .. 6 Box 3-2 Specific Objectives of WB Regarding Stakeholder Engagement (30.07.2014) ....... 7 Final March 2018 Project No: 17/010 iv/v SANKO Geothermal Power Plant Project Stakeholder Engagement Plan ABBREVIATIONS AoI Area of Influence DC Distribution Centre EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment ESS Environmetal and Social Standarts FGD Focus Group Discussion NGO Non-Governmental Organization PPM Public Participation Meeting PRO Public Relations Officer SEP Stakeholder Engagement Plan SIA Social Impact Assessment WB Informed Consultation and Participation Final March 2018 Project No: 17/010 v/v SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 1 INTRODUCTION This document is the Stakeholder Engagement Plan (SEP) for ‘Sanko Geothermal Power Plant Project’ (herein after ‘the Project’). It has been prepared by 2U1K Engineering and Consultancy Inc. on behalf of “Sanko Enerji” (the Project Company). Sanko Enerji, an energy branch of Sanko Holding Group plans to develop Sanko Geothermal Power Project in Manisa , Salihli District, Yılmaz Neighborhood. The Project is planned to be realized in three phases; in the first phase, 15 MWe energy is planned to be generated. In the second phase, additional 15 MWe and, finally with additional 20 MWe a total of 50 MWe will be achieved. The Project seeks for potential financing for the first phase of the Project with 15 MW capacity from Türkiye Kalkınma Bankası (TKB), the financial intermediary. This SEP document is prepared for the Project with 15 MW capacity. This SEP has been prepared in line with the WB’s Environmental and Social Standards (ESS). In accordance with the ESS-10-Information Disclosure and Stakeholder Engagement the purpose of the SEP is to guide the Project Company to:  build and maintain a constructive relationship with the stakeholders, in particular project-affected communities,  promote improved environmental and social performance through effective engagement with the stakeholders,  promote and provide means for adequate engagement with project-affected communities throughout the project cycle on issues that could potentially affect them and to ensure that meaningful environmental and social information is disclosed to them and to other stakeholders,  ensure that all stakeholders have ways to access project information and raise issues,  ensure that project-affected communities have accessible means to raise issues and grievances, and the Project Company respond to and manage such issues and grievances appropriately. This SEP includes; (i) the identification of stakeholders for the Project, (ii) analysis of relationships of the stakeholders with the Project, (iii) details of consultation methodologies, (iv) activities carried out to-date and those planned for the future of the Project, (v) details of the process for managing stakeholders’ concerns and grievances, and explains how the stakeholder engagement process will be recorded, monitored, evaluated and reported. The Project Company is committed to implementing this SEP document throughout all stages of Project. The SEP is a living document and it will be regularly monitored, reviewed and updated by Sanko Enerji. Final March 2018 Project No: 17/010 1 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 2 PROJECT LOCATION and AREA OF INFLUENCE The Project site is located within the boundaries of Salihli District of Manisa Province. The project area is located in the "Agricultural Field" according to the 1/100.000 scale Environment Plan. Agricultural activities are already being carried in the surrounding area. Project Location Source: National EIA Report, 2016 Figure 2-1. Project Location The Project Site is subject to "Soil Conservation and Land Use Law" and a public interest decision required by the Ministry of Energy and Ministry of Food Agriculture and Livestock. A public interest decision was obtained for the Project in compliance with the Law. Final March 2018 Project No: 17/010 2 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan According to outputs of environmental and social researches carried out within the scope of the Project, the social settings determined by considering the existing and planned facilities and possible social impacts. The AoI for social impacts is determined by considering the impacts sourced from land acquisition, workers’ accommodation, noise during construction and operation phase, labour influx, changes on dust and air quality. The settlement in which experienced land allocation due to Project activities and / or the closest settlement to the Project Site that may experience primarily environmental impacts of the Project will be considered as the first impact zone. In other words, the first impact zone may experience direct impacts of the Project. Therefore, Yılmaz neighbourhood, being the closest settlement in which may experience direct environmental and social impacts and experienced almost all land acquisition for the first phase of the Project, is considered within the first impact zone. Sanko used voluntary purchase method for land take of the area required for the Project. Land take process and payment for the purchased lands have been completed and there will be no more land acquisition for the Project. Further information on Project’s land allocation can be found in Section 8.2 of this Report. Last, it is important to note that, there has been no physical displacement caused due to Project activities. Second impact zone may cover majority of the indirect Project impacts such as job opportunities, providing of goods and service. Therefore, the second impact zone will cover the settlements as Gaffar Okan, Hasalan and Caferbey. Also, changes on dust and air quality may be experienced in the second zone as well since the most distant settlement, Caferbey, is 2 km away from the Project Site. The social setting of the Project in terms of local settlements, population, distance to Project site and likely impacts and risks is set out in the below Table 2-1. Table 2-1. Settlements and their Distance to the Project Site Neighbourhood The Closest Project units Likely Impacts  Local Economy  Environmental Impacts  Transportation route  Community Health and Safety Yılmaz  Land Acquisition  Wells  Transportation/Traffic.  Local Economy,  Transmission line (the transmission  Environmental Impacts Caferbey  Community Health and Safety line in under the authority of TEDAŞ)  Transportation/Traffic  Local Economy,  Land Acquisition Hasalan  Wells, Water pipeline, Camp site  Environmental Impacts  Community Health and Safety  Transportation/Traffic Gaffar Okkan  Power plant, Distribution Centre  Local Economy, Final March 2018 Project No: 17/010 3 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Neighbourhood The Closest Project units Likely Impacts  Environmental Impacts  Community Health and Safety  Transportation/Traffic Following Figure 2-2 presents the geographical location of the Project and associated facilities and the proximity of the settlements to the Project units. Final March 2018 Project No: 17/010 4 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Figure 2-2. Geographical Location of the Project and Associated Facilities Final March 2018 Project No: 17/010 5 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 3 REGULATORY REQUIREMENTS This section outlines the regulatory framework for the Project’s stakeholder engagement activities, according to national and international requirements. 3.1 Turkish Legislation The “Regulation on Environmental Impact Assessment (dated November 25, 2014; No: 29186 and amended on February 9, 2016; No: 29619)” defines the administrative and technical procedures and principles to be followed throughout the EIA process. The Project is subject to a preparation of a national EIA process therefore an EIA report has been prepared in accordance with the Environmental Impact Assessment General Form given in Annex III of the Environmental Impact Assessment Regulation (EIA Regulation) in order to demonstrate the characteristics, location, potential environmental impacts of the project and the measures to minimize these potential impacts and to introduce the project in general dimensions. It was approved by the Ministry of Environment and Urbanization on January 2017. According to EIA Regulation a Public Participation Meeting (PPM) required for the Project in line with the 9th Article of the EIA Regulation. Specific Objectives of PPM according to regulation is presented in Box 3-1. Box 3-1. Specific Objectives of National EIA Regulation of Turkey (25.11.2014, Article-9) 1) In order to inform the investing public, to get their opinions and suggestions regarding the project; Public Participation Meeting will be accomplished on the date given by Ministry and Ministry qualification given institution / organization and project owners as well as the participants of the project affected community will be expected to attend in a central location determined by the Governor. a) The competency issued institutions / organizations by the Ministry will publish the meeting date, time and place through widely published newspaper at least ten (10) calendar days before the determined date for the PPM. b) Public Participation meeting will be held under the Director of Environment or through Urbanization or authorized chairman. The meeting will inform the public regarding the project, receive views, questions and suggestions. The Director may seek written opinions from the participants. Minutes of meeting will be sent to Ministry, with one copy kept for the Governorship records. 2) Governorship will announce the schedule and contact information regarding for the public opinion and suggestions. Comments received from the public will be submitted to Commission as per the schedule. 3) Members of Commission may review the Project implementation area before the scoping process, also may attend to public participation meeting on the date announced. 4) The competency issued institutions / organizations by the Ministry could provide studies as brochures, surveys and seminars or through internet in order to inform the public before the Public Participation Meeting. A Public Participation Meeting was held in Yılmaz Neighbourhood on 27.09.2016. Details of the meeting is presented in Section 7. 3.2 World Bank Standards Since the WB is a potential lender for the Project, the project must align with good international practice, including the ESS-10 (Information Disclosure and Stakeholder Engagement) of WB 2014. The specific objectives of ESS-10 are outlined in Box 3-2. Final March 2018 Project No: 17/010 6 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Box 3-2 Specific Objectives of WB Regarding Stakeholder Engagement (30.07.2014) For all projects, Project Company will consult with stakeholders to identify issues and concerns in order to inform the environmental and social assessment and the design and implementation of the project. Disclosure of relevant project information helps stakeholders understand the risks, impacts and opportunities of the project. If communities may be affected by environmental or social impacts from the project, the Borrower will provide them with access to the following information: (a) The purpose, nature and scale of the project; (b) The duration of proposed project activities; (c) Any risks to and potential impacts on communities and proposed mitigation plans; (d) The envisaged stakeholder engagement process, if any, and opportunities and ways in which stakeholders can participate; (e) The time and venue of any envisaged public consultation meetings, and the process by which meetings are notified, summarized, and reported; and (f) The process and means by which grievances are raised and managed. The information will be disclosed in local language(s) and in a manner that is accessible and culturally appropriate, taking into account any specific needs of groups that may be differentially or disproportionately affected by the project because of their status or groups of the population with specific information needs (such as, literacy, gender, differences in language or accessibility of technical information). 3.3 Gaps Between Turkish Legislation and International Guidelines The most prominent topic, which requires further elaboration in Turkish Environmental Legislation, is “Social Impact Assessment (SIA)”. Additional studies and implementations are required in this topic for internationally financed projects to achieve alignment with international standards. For example, Turkish EIA Regulation does not stipulate implementation of detailed socio-economic surveys and disclosure of information at Project Site and the establishment of a Grievance Mechanism. However, these are required by international standards. Such differences will be taken into consideration in respective sections in the ESIA Report. Final March 2018 Project No: 17/010 7 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 4 ROLES AND RESPONSIBILITIES The Project Company will make sure that all affected parties, particularly affected settlements, the local community organizations, Non-Governmental Organizations (NGOs), and local governmental agencies are informed about the Project and will be involved in the process of identifying the important issues of the Project. Roles and responsibilities have been defined in order to ensure effective stakeholder engagement during the life of the project. The organizational structure of the Project is presented in Figure 4-1 and principal roles and responsibilities for the implementation of this plan are outlined in Table 4-1 below. Final March 2018 Project No: 17/010 8 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan General Manager of Geothermal Investments Finance Procurement Project Manager Incentive Implementation Consultant Resource Development and Mechanical Works and Electrical Works Project Construction Works Project Administrative Affairs Administrative Permits Operation and Site Manager OHS Manager Environmental Manager Project Manager Manager Manager Manager Project Manager HS Inspector Figure 4-1 Organization Chart Final March 2018 Project No: 17/010 9 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Table 4-1. Key Roles and Responsibilities Roles Responsibilities Ensures that this SEP is implemented General Manager Provides necessary resources for effective implementation of this Plan Ensures that this SEP is implemented Project Manager Provides necessary resources for effective implementation of this Plan Coordinates with parties for effective implementation of this Plan Implements and improves this SEP Determines necessary resources for effective implementation of this SEP and submits to his line managers Administrative Affairs Evaluates the compliance of Project activities with national and international Department legislation requirements , Grievance Officer Searches the causes of the social incidents that cause; injuries, delays or stoppage in the work and disputes among Project and communities Monitors all grievances and ensure that all complaints are resolved and closed, Coordinates with parties for proper implementation of this SEP Implements this Plan Organizes cooperation activities with employees Reports grievances, which are received or observed verbally, to Project Manager, OHS Department Fills out a Complaint & Consultation Register Form Investigates and proposes appropriate methodology for resolving the grievance, Conducts follow ups for the results of complaints and reports on weekly, monthly and annual basis to the Management, Final March 2018 Project No: 17/010 10 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 5 PROJECT STAKEHOLDERS For the purposes of this SEP, a stakeholder is defined as any individual, organization or group which is potentially affected by the Project or which has an interest in the Project and its impacts. The objective of stakeholder identification is to establish which stakeholders may be directly or indirectly affected – either positively or negatively - (“affected parties”), or have an interest in the Project (“other interested parties”). It is important that particular effort is made to identify any disadvantaged and vulnerable stakeholders who may be differentially or disproportionately affected by the Project or who may have difficulty participating in the engagement and development processes. Stakeholder identification is also an on-going process and will require regular review and update. 5.1 Stakeholder Identification and Categorization The SEP defines a stakeholder as ‘any individual or group who may be directly or indirectly affected by the Project, as well as those who may have an interest in or influence over the project’. The process also aims to identify which stakeholder may have a positive or negative impact or influence on the project. Stakeholder identification has been an on-going process and different issues are likely to concern different stakeholders. Therefore, stakeholders have been grouped based on their connections to the project. Having an understanding of the connections of a stakeholder group to the project helps identify the key objectives of engagement. Table 5-1 presents the stakeholders who identified as relevant for the main ESIA phase. Final March 2018 Project No: 17/010 11 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Table 5-1. Stakeholder Groups Stakeholder Type Stakeholder Groups Affected Interested Party Party Local Communities  Muhtars and residents of following Neighbourhoods; o Yılmaz o Caferbey o Hasalan o Gaffar Okkan  Project workers; √ √  Following vulnerable groups in the AoI; o Seasonal agricultural workers; o Females; o Low income groups; o Illitrate people; o Handicapped people; Government  Ministry of Energy  Ministry of Labor and Social Security  District Governorate of Salihli  Provincial Governorate of Manisa √ √  Salihli Agriculture Directorate  Provincial Directorate of Agriculture of Manisa  Manisa Provincial Directorate of Environment and Urbanization Municipality  Municipality of Salihli √ √  Metropolitan Municipality of Manisa Media  Local Media √ Project Employees √ √ NGOs and Professional Organizations  Salihli Agricuture Credit Cooperative √ √  Tariş Grape Cooperative Academics  University of Manisa √ Private Sectors  Lider Greenhouse Company √ √  Bostan Greenhouse Company  Other Geothermal Projects in Manisa Final March 2018 Project No: 17/010 12 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 6 STAKEHOLDER ENGAGEMENT TOOLS A range of tools has been and will be used for stakeholder engagement within the scope of this Project. Stakeholder engagement will continue using these already established communication mechanisms, with new mechanisms employed as required to ensure efficient and effective engagement throughout the life of the Project. Project has and will continue to use the following methods for engaging with stakeholders:  Informal / Formal face to face meetings – likely to be the primary form of on-going consultation during the construction and operation phase.  Project Brochure/Updates - Project Brochure initially used as part of the SIA scoping process. This will be updated to provide up to date construction progress info and will be used as on-going communication tool.  Project Company website – publically available site for project announcements, documents, reports, etc.  Grievance mechanism – aimed particularly at directly affected stakeholders. Mechanism has been and will continue to be widely disclosed to affected public.  Media advertisements – invitations to participate in meetings, information disclosure, etc. Table 6-1 below outlines the stakeholders and engagement approach to be applied for the Construction and Operation phases. Final March 2018 Project No: 17/010 13 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Table 6-1 Stakeholder Engagement Approach Lead and Method and No Stakeholder Topics Frequency Supporting Materials Responsibility 1 Local Update of Project Monthly Informal / Formal Operational Communities activities and face-to-face Manager progress meetings Administrative Unit Employment Written Project process brochures/ Posters Land Acquisition updates Corporate website Grievance mechanism 2 Local Update of Project Quarterly Meetings / Visits Operational Government activities and Written Project Manager progress brochures/updates Administrative Unit Municipality Local procurement Corporate website and employment data. Grievance mechanism Local Media 3 Project Update of Project Yearly Internal Workshops OHS Team Employees activities progress Corporate website Operational and planning Manager Written Project brochures/updates 4 Local NGOs Update of Project Monthly Formal face-to-face Operational activities and meetings Manager progress Written Project Administrative Unit Social development brochures/ Posters projects updates Corporate website Grievance mechanism 5 Academics Update of Project Quarterly Meetings / Visits Operational activities and Written Project Manager progress brochures/updates Administrative Unit Corporate website 6 Private Update of Project Yearly Corporate website Operational Sectors activities progress Written Project Manager and planning brochures/updates Administrative Unit Media advertisements Final March 2018 Project No: 17/010 14 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 7 PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES 7.1 Engagement for the Turkish EIA In order to inform the local communities, a PPM was organized in accordance with the Environmental Impact Assessment Regulation. The PPM was held on 27.09.2016 in Salihli district, Yılmaz neighbourhood (See Figure 7-1). The meeting was announced in the national and local newspapers. The announcement was also posted on the billboard of the neighbourhood. Provincial Directorate of Environment and Urbanization (PDoEU), Project Company representatives, EIA national EIA Consultant and locals participated to the meeting. During the meeting Project Company representatives responded questions raised by the locals and the representative of PDoEU. The objectives of the PPM were to:  present a clear and succinct description of the Project and its activities via presentation,  to safely disseminate information on the Project and to give clarifications on misconceptions,  establish communication systems and build positive relationships with stakeholders that would eventually help to utilize engagements in the future phases of the Project. The participants were informed on the scope and aim of the Project as well as the possible environmental impacts that may arise within the scope of the Project, the measures planned to prevent these impacts were shared. Figure 7-1. General View from Public Participation Meeting Final March 2018 Project No: 17/010 15 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan The questions raised by the participants and response of the Project Company representatives are provided below: Q: Will the locals be exposed to any negative impacts due to reinjection process? R: Required analysis for the potential impacts will be conducted within the EIA studies in order to prove that the Project activities will not exceed over suggested environmental standards. This will also be monitored throughout the Project life span. The main purpose of this investment is to use natural resources to provide electricity for our country with the minimum negative impacts as possible. The geothermal fluid will be reinjected according to national legislations and standards in order to prevent any potential impacts to the community or the environment. A grievance mechanism accessible by everybody will be established for the Project. Q: Will there be more well drillings in the future? R: There may be further drilling activities for the future phases of the Project. •Q: There was an explosion in Alaşehir about three years ago, is there a similar incident likely for the Project? R: Sanko will take all the necessary measures into consideration in order to establish a safe and secure Project Site and activities. These measures will be adopted by all Project parties throughout the Project phases. The participant list, meeting announcement and minutes of meeting are provided in Annex- 3. 7.2 Social Baseline and Impact Assessment Activities The aim of the socio-economic baseline study is to describe the socio-economic conditions and trends in the areas potentially affected by the Project to understand potential effects and to develop appropriate mitigation measures. The socio-economic baseline defines the socio-economic issues of importance of provincial and local communities and establishes a baseline of socio-economic data that can be used for monitoring changes in the affected communities after the Project. Socio-economic data was collected using a combination of research methods. The baseline section was conducted by collecting, reviewing, and analysing a range of secondary data, including data originating from the Turkish Statistical Agency (TURKSTAT), Salihli Municipality, local and provincial Governorates’ Database. In order to provide baseline information on the neighbourhood level, national statistics are supported with information obtained from primary data collected through interviews with Mukhtars which were carried out between the July 4 and 6, 2017. Stakeholder engagement activities as part of social surveys are presented below. Final March 2018 Project No: 17/010 16 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Table 7-1. Summary of Field Studies Research Method Number of Surveys Community level survey 4 Land Acquisition 2 Focus Group Discussions (FGD) 3 meeting consisting of 20 Key informant interviews 5 TOTAL 31 Community Level Survey and FGD in Yılmaz (04.07.2017) Community Level Survey and FGD in Hasalan (05.07.2017) Final March 2018 Project No: 17/010 17 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Community Level Survey and FGD in Caferbey (05.07.2017) Figure 7-2. Photos of Community Survey Final March 2018 Project No: 17/010 18 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 7.3 Outputs of Social Field Study 7.3.1 Focus Group Discussions FGD provides to engage specific sections of the community that might require special attention in consultation, e.g. female, young population, vulnerable people. FGD is an effective way to collect together people from similar experiences to discuss a specific interest related with the Project. Table 7-2 presents the key issues and recommendations raised by the stakeholders. Table 7-2. Summary of Key Issues of FGDs FGD Topics Yılmaz Caferbey Hasalan Project  Participants of FGD do not know  The Project Company held  Residents know about the geothermal Information detailed information about the research and drilling investment but they do not have detailed planned investment. activities in the settlement. information.  Some of the villagers participated to Residents know about the the public participation meeting. geothermal investment but  However, since the population of they do not have detailed the settlement is around 6000 information. people, it was not possible to provide high level of participation. Questions  What kind of benefits can we get  What will happen if the  Are you planning to use reinjection? Raised by the from the Project? Company find a geothermal  What will be the impacts of the operation villagers  Will the Project create any seismic source in my land? Will period? risk? they take my land too by  How many wells are planned for the Project?  Will we (as the locals) able to use expropriation?  How many power plants are planned for the geothermal water for greenhouse, Project? after the energy production ?  What is the border of the Project area and  Will this Project create any odor Project license area? problem?  In what ways, our agriculture activity will be affected by the Project? Final March 2018 Project No: 17/010 19 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan FGD Topics Yılmaz Caferbey Hasalan Suggested A printed material such as brochure should A consultation should be held with If the Project Company do not want any objection Information be distributed to neighbourhoods. Since the the neighbourhood. regarding to the Project, they need to explain the Tools majority of the residents are engaged with Project in detail to the each affected settlement. A brochure should be distributed. the agriculture and they stated that the All estimated impacts should be explained to the participation to the meeting is difficult for neighbourhoods. them. A Public Relation Officer may visit the settlements An informative banner can be used in the once a month. neighbourhood. Perceived The relationship with the Project workers is During the research and drilling The Project will be beneficial in terms of local Positive positive and the local residents are happy to activities, unemployed youth economy and it may create job opportunities for the Impacts having such investment in the area since population had chance to work for youth population. they create positive impact on the local the Company for a short term. economy. Perceived Odour is a problem during the testing Land acquisition is a negative High tonnage vehicles damaged the roads of the Negative process. impact of the Project. Project neighbourhood. Impacts Company does not provide a good compensation to the affected people. Final March 2018 Project No: 17/010 20 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 7.3.2 Key Informant Interviews Key informant interviews are a common data collection technique during the stakeholder engagement process since the key informants are well informed on their community and its inhabitants as a result of their professional background, leadership responsibilities or personal experience, key informants have specific knowledge or expertise about some aspects of the emergency, the area, the community, a specific sector or a sensitive issue. Typically, a key informant represents a non-governmental institution and academy. The Table 7-3 summarizes the information level and comments of local interviewees. Table 7-3 Summary of Key Informant Interviews Name of the Project Information Perceived Positive Impacts and Suggestions Perceived Negative Impacts Institution Tariş Grape Since president of the Cooperative has Geothermal water can be used in agriculture and Due to the increase of geothermal projects in the region, Cooperative previous experiences about Alaşehir tourism sector. Afyon can be taken as an impaired fertility of vegetation types has started in our region, district, negative impacts are example for tourism. as a result of increased boron level of irrigation waters. expectedAccording to Cooperative, It's not expensive to provide credible and With the increase of geothermal projects, the potential for practical activities do not comply with transparent investments however, the agriculture ends and several companies can not cover to the technical information and the companies are not implementing transparent provide income for the all district. liability of the EIA reports is not high. process during the investment process. Farmers are getting water up to 200 meters. If agriculture is The major concern about the Project is If the company will collaborate with the Chamber totally connected to this water and if safe release is not related with the reinjection proses. of Agriculture, District Directorate of Agriculture handled during the re-injection agricultural activities can be They would like to learn impacts of the and the related agriculture cooperatives, these risky. reinjection process on underground institutions can work together to convince the water. Agricultural lands were taken for these Projects and the public. farmers should also get benefit from the energy projects. The project company needs to explain the impacts of the Project. Ineffective in agriculture in Alasehir, is evident and grape prices are decreased in Alaşehir. We do not trust EIA reports; these reports do not reflect reality. Final March 2018 Project No: 17/010 21 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Name of the Project Information Perceived Positive Impacts and Suggestions Perceived Negative Impacts Institution The agricultural sector is the largest stock exchange of employment, and if people who engage in farming are left out of the sector, they cannot be employed in other sectors because they are uneducated. Farming activities should be protected. Agriculture Not adequate Projects related to greenhouses can be realized Water samples were taken from the drills in Alasehir and it Chamber of collaboration with the Metropolitan Municipality. was observed that there was an increase in boron level in the Salihli The recycled waters of existing wells can be water due to the use of geothermal resources. used in greenhouses. The population of Turkey is increasing and on the other hand, Organize greenhouse area can be established. the agricultural land is decreasing. Energy production should be done in places where is not suitable for agriculture. 25% of the total land in the town of Salihli is composed of grape lands. The destruction of agricultural areas and the negative characteristics of the ascension project at the boron level. Due to the fact that existing artesian wells are being used intensively, the level of boron in the water raised. District Not adequate _ We expect geothermal Companies to support District Directorate Municipalities about geothermal heating system. Greenhouse of Agriculture areas can also be established by the support of energy companies. The power plant cannot provide employment for sufficient amount of people. The public have negative opinions regarding geothermal projects. There are some doubts in the peoples though in that manner. There are too many complaints by the farmers Final March 2018 Project No: 17/010 22 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Name of the Project Information Perceived Positive Impacts and Suggestions Perceived Negative Impacts Institution mainly due to temporary project activities. Salihli Adequate The municipality has a heating Project in the If the Project Company will not use reinjection in the future, Municipality close vicinity of the Sanko’s Project Site and the there may be environmental problems. municipality and the Project Company has a The government do not have sufficient personnel on good relation. They are on the process of inspecting contaminated fluids that may spill to the nature negotiation about the collaboration on the usage during the drilling and operating period. of the reinjection water. It will be used for the heating of Salihli District. There are negative examples of similar projects in the region, so the prejudice of the people can also occur with regard to The municipality has a heating infrastructure, Sanko. however, the capacity of the existing wells of the Municipality is not sufficient. The Project Company is planning to support this Project as a social responsibility. The number of subscribers using geothermal heating in the district is 7,500. Salihli Not adequate There is no information about the planned Agriculture Project. Costs of greenhouses around Yilmaz Credit and Hasan neighbourhoods are very high. The Cooperative municipality has problems about the current geothermal heating project. The Project Company should support the municipality. 7.3.3 Community Level Surveys The aim of this survey is to determine socio-economic status of each settlement inclusive of population, migration and reasons of migration, ethnic composition, age distributions, social facilities (schools, mosques, etc.) in the settlement, education level, local conflicts and problems, livelihoods and main income generation activities, economic production in the settlement, land use, services and infrastructure, vulnerable groups and perceptions of project impacts. The settlements in the AoI that was consulted within the scope of community level surveys are Yılmaz, Caferbey, Hasalan and Gaffar Okkan Neigbourhoods. The Community Level Surveys were conducted with the mukhtars and detailed information about the settlements is presented in the ESIA Report. Final March 2018 Project No: 17/010 23 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Table 7-4 Summary of Community Level Surveys Name of the Project Information Perceived Perceived Negative Impacts Neighbourhood Positive Impacts and Suggestions Yılmaz Although PPM was held in Yılmaz neighbourhood under .- - the local EIA process, the local community do not have a sufficient information about the Project. Caferbey The locals overheard the meeting that was held in _ _ Yilmaz neighbourhood however, they did not participate. The mukhtar do not have an opinion about the Project. -Hasalan During the exploration activities of the Project, the The Project Company has been compensated for villagers were informed. damages of the exploration activities on the agricultural lands. The villagers have complained about the damage occurred in to the village road due to transportation of high tonnage vehicles. The locals would like to communicate with the assigned Project person to express their opinions and suggestions throughout the Project activities. Gaffar Okkan According to mukhtar, the residents of the neighbourhood did not receive official information related with the Project but they overheard through the rumours. Final March 2018 Project No: 17/010 24 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 7.3.4 Household Surveys (Land Acquisition) The land to be used for the Project activities are agricultural lands, owned by private owners and were acquired by voluntary purchase method. During the social field study, two households surveys were conducted with the locals who sold and rented their land to the Project Company. According to both of the locals statement, they have received their payment from the Project Company. Furthermore, it was stated that expropriation was not preferred for land acquisition since the values might be lower than negotiated prices, therefore they preferred to go on an agreement with the Project Company on land value rather than expropriation. It was observed during the interviews that there was a common concern on loosing profit in a case of expropriation. During the focus group discussions and one on one interviews, it was observed that there is a general misconception towards the project companies of the geothermal power plants. There is a common perception of loosing profit either by selling the lands to the Project Companies. This also leads to concern on expropriation of their lands as well. Majority of the locals do not specific information regarding the purpose of the geothermal projects or interacted with the projects officials. Lack of communication expanded the misconception towards the geothermal projects in the region. Further information of the land allocation process and suggested mitigation measures can be found in Section 8.2. of the ESIA Report. Final March 2018 Project No: 17/010 25 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 8 SOCIAL RESPONSIBILITY PROJECTS Corporate Social Responsibility Projects (CSP) are one of the most important tool especially during the corporate level stakeholder engagement activities. CSPs provides accountability, transparency, sustainability of the Company and the Project and at the same time it supports affected local communities and the local governmental bodies. The Project Company aims to provide local and regional support as social responsibility projects. The Project Company has undertaken below activities until now:  2 robotic arms education and software sets have been donated to schools in Manisa in the scope of a pilot education programme namely “KODLAMANİSA” conducted by Manisa Governorate.  Maintenance of the police station which is in charge of protecting the Ancient Sardes city. Salihli Municipality gives heating services to 7500 house through geothermal heating center however can be insufficient. The Project Company will provide geothermal fluid for heating system of Salihli Municipality this winter season. In order to clear of the general misconception towards the geothermal power plant projects in the Region, the Project Company will put an effort to establish direct interactions with the locals and provide further social responsibility projects to benefit the locals in the AoI. With the implementation of SEP, PRO of the Project Company will seek to receive any suggested or requested potential responsibility projects by the local authorities, communities, NGOs and all other interested stakeholders in which may benefit the affected communities living standards. In order to do so, periodic engagement approaches and methods are stated in Table 6-1 of this Report. Final March 2018 Project No: 17/010 26 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 9 FUTURE STAKEHOLDER ENGAGEMENT This section describes the stakeholder engagement planned for the Project during Impact Assessment (IA) disclosure, and then during construction and operation. 9.1 Phase-2: ESIA Disclosure Disclosure of the Draft ESIA Report will provide detailed information about the Project activities, assessment of the impacts and the planned mitigation measures and monitoring activities. After submitting the Draft ESIA Report to the lenders, it will be advertised and made available for public review. According to ESS-10 “The Borrower will tailor its consultation process to any specific language preferences of the project-affected communities, their decision-making process, and the needs of disadvantaged or vulnerable groups. The Borrower will inform those who have participated in the public consultation process in a timely manner of the final decision on the project, associated environmental and social mitigation measures and any benefits of the project for the local communities, along with reasons and considerations on which the decision is based, and the grievance or complaint mechanism or process available.” Display venues would be expected to include:  The Salihli Municipality;  Yılmaz, Caferbey, Hasalan and Gaffar Okkan Neighbourhoods,  Local government and  The Project office. A community meeting will be held to disclose the ESIA. Electronic copies of the Draft ESIA Report will be available on CDs/memory sticks and a Non-Technical Summary of the Draft ESIA Report with its appendices will be distributed to select stakeholders registered on the database. Copies of the Draft ESIA Report will also be made available for download from the Project website. Directly affected stakeholders will be informed about the disclosure process by phone and a letter will be sent to key stakeholders. The purpose of this letter will be to inform stakeholders about the disclosure. The project team will answer questions from the public and stakeholders. The Public Relations officer of the Project will be responsible for receiving and collecting all comments. All received comments will be included into the ESIA finalization process and the Final Report will be posted on the Project website. 9.2 Phase-3: Implementation Stakeholder engagement will continue throughout design finalization, construction and operation. Key stakeholders will be kept informed about the progress of the Project, have the opportunity to provide feedback on the effectiveness of mitigation and enhancement Final March 2018 Project No: 17/010 27 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan measures and to raise any concerns or grievances. Information to be shared before construction commences will include (but is not limited to) the following:  the impacts that have been identified as a result of the Project,  the impacts and mitigation or enhancement measures that are being implemented,  the implementation schedule,  roles and responsibilities,  monitoring and management measures, and  information on the grievance mechanism for the Project. Implementation phase engagement will focus on new stakeholders, including children and potential and existing employees, as well as those engaged at earlier phases; it will focus on developing relationships thorough on-going stakeholder engagement and will be designed to build on positive stakeholder relationships established during the ESIA process, carrying these forward through Project construction and operation. To ensure effective stakeholder engagement, the SEP will be reviewed annually by the Public Relations Officer (PRO) throughout construction and operation of the Project, with it being adapted as appropriate. Project’s PRO will be responsible for engagement with stakeholders as an on-going process throughout the life of the Project. This department will be dedicated to conveying information about the Project, finalizing, and implementing the ESIA mitigation measures. Grievances can be an indication of growing stakeholder concerns (real and perceived) and can escalate if not identified and resolved. Identifying and responding to grievances supports the development of positive relationships between projects, communities and other stakeholders. Project Company has formally established a Complaint / Suggestion and Request Procedure for all phases of the Project. This will provide a formal and on- going avenue for stakeholders to engage with the Project. This grievance mechanism will be accessible to all sections of the affected community, at no cost and will not impede access to other judicial or administrative remedies. Affected communities will be repeatedly informed about the grievance process over the course of community engagement activities. Stakeholders will be able to share their opinions and grievances via a range of options such as web sites, letters and face to face meetings during all future phases of the Project. Feedback will also be provided to demonstrate how their comments and suggestions have been incorporated into the Project decision-making process in the second public participation meeting and this process will be continue in all phases of the Project. A separate grievance mechanism will be established for Project workers. Grievance procedures will be coordinated through the PRO, who is the primary interface between the community and the Project Company. Confidentiality procedures will be put in place to protect the complainant, as appropriate. The grievance mechanism will be advertised and announced to affected stakeholders so that they are aware of the process, know they have the right to submit a grievance and understand how the mechanism will work and how their grievance will be addressed. In Final March 2018 Project No: 17/010 28 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan most cases, a grievance or complaint will be submitted by a stakeholder or local resident by phone, in writing or by speaking with one of the company’s grievances officer. Further information on the Project Company’s grievance mechanism is presented in Chapter 10 of this Report. A robust grievance mechanism for workers in both construction and operation stages will be developed by the Project Company before commencement of either activity. Once finalized, this process will be managed separately from the public grievance mechanism, but employees will retain their right to access the public grievance mechanism for non- employment-related issues. Final March 2018 Project No: 17/010 29 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 10 THE GRIEVANCE MECHANISM The Project Company established a system to capture, manage, monitor and report on complaints, disputes and grievances. Prior to the official system, any type of requests were received verbally by the General Manager Assistant and Business Manager of the Project, whom were always located in the Project Site. Through the formal procedure, Turgut Sümer is assigned as a Public Relations Officer (PRO) to collect and address all type of grievances regarding the Project. He will be available to be contacted via telephone or Project Affected Parties can contact personally by visiting the Project Site directly. Further contact information of the assigned PRO are presented below:  Name: Turgut Sümer  Tel: +90 (532) 285 4751 (Primary Phone) 0 236 712 2827 / 0 236 712 1727  E-mail: tsumer@sankoenerji.com.tr The details of the Project Company’s Complaint, Suggestion and Request Procedure presented below. Complaint / Suggestion / Request Procedure 1. A "Public Relations Officer" (PRO) assigned to serve as a bridge between the Project and Project Affected Parties (community, NGOs, national and local organizations and authorities, project related parties, etc.). Throughout the drilling, construction and operation phases of the Project, the PRO will establish a positive relationship based on open communication and common respect. All complaints, requests, suggestions will be directed to the PRO. 2. Contact information of the PRO will be posted at the main entrance of the Project Site and the security cabin of the drilling locations in a manner that is visible to the public. Security Officers will be informed about this mechanism and locals will be contacted by the PRO. 3. The Complaints will be handled and reviewed within 7 days. 4. As the claim handled, the PRO shall notify the claimant and propose corrective action. 5. Complaints, except those regarding the infrastructure, will be finalized within 30 days. 6. Complaints related to the infrastructure should be concluded as soon as possible so that the people of the region will not experience difficulties in their daily lives. 7. The complaint-request-suggestion form (See Annex 1) will be filled in for each complaint, request, suggestion. 8. The form will have 4 copies in 4 different colors. a. The white copy (the original version) will be for the claimant, b. The yellow copy will be given to the Business Manager (in case of construction; to the Site Manager, for drilling activities to Company Mane and for operation phase to the Business Manager), c. The green copy will be given to the relevant department responsible for resolving the complaint, Final March 2018 Project No: 17/010 30 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan d. The pink copy will be kept by Public Relations Officer for archiving. 9. Once the corrective action is completed, a Complaint-Request-Suggestion Closure Form (See Annex 2) will be filled. 10. The Closure Form shall include the claim number, date, subject, relevant corrective measures, date of the closure and sections for signatures. Final March 2018 Project No: 17/010 31 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan 10.1 Grievance Procedure Channels of Communication Numerous channels will be used for stakeholders to submit any complaints and requests: Telephone – All incoming calls will be registered and information summarized daily and sent to the relevant department for processing and action in accordance with the grievance procedure outlined above. Electronic channels – Stakeholders have the opportunity to send comments, remarks, requests and complaints via the official website of the Project Company. Post – Mail can be used by stakeholders for submission of their queries/requests/complaints/comments for consideration by the PRO. All incoming letters will be documented and stored as well as the responses sent to the originating party in accordance with the grievance procedure outlined above.  Name: Turgut Sümer  Address: Sıraağaçlar Mevkiisi, Yılmaz Mahallesi Salihli / Manisa Any queries/requests/complaints/comments can be brought to the attention of the Project Company verbally or written (e-mail) or by filling in a Grievance Form which will be available in the project site office (See Annex 1). Final March 2018 Project No: 17/010 32 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan ANNEX - 1 Complaint Register Form SANKO ENERJİ SANAYİ TİCRET A.Ş./ SALİHLİ JES ŞUBESİ SANKO JES PROJESİ SANKO ŞİKAYET-İSTEK-ÖNERİ FORMU / COMPLAINT-REQUEST-PROPOSAL FORM Halkla İrtibat Görevlisinin Adı: Kopyaların Dağılımı: Name of CLO: Copies to go to: Tarih: Beyaz (Orijinal) – Şikayetçi Date: White (Original) – Complainant Şikayet-İstek-Öneri Numarası: Sarı (Kopya) – İşletme Müdürü, Complaint-Request-Proposal No: Şantiye Şefi, Company Man Yellow (Copy) – Site Manager, Site Telefon / Phone Chief, Company Man Yeşil (Kopya) – İlgili Departman Bireysel Başvuru / Individual Application Şikayet-İstek-Öneri Geliş Yönü: Green (Copy) – Relevant Dept. Delivery of Complaint-Request- Pembe (Kopya) – Halkla İrtibat Halk Toplantısı / Community Meeting Proposal: Görevlisi Pink (Copy) – Community Diğer / Other Liaison Officer BÖLÜM A – TALEP SAHİBİ HAKKINDA BİLGİ / PART A - INFO ABOUT CLAIMER İsim-Soyad / Name- Surname: Kimlik No / ID Number Adres / Address: Telefon / Telephone: E-Posta / E-Mail İmza / Signature BÖLÜM B – ŞİKAYET-İSTEK-ÖNERİ DETAYLARI / PART B – DETAILS OF COMPLAINT-REQUEST- PROPOSAL Arazi, Hane, Kullanım Alanları, Gelir Kaynaklarına Zarar / Damage to Lands, Household and Livelihood Alt Yapı ve Kamu Malına Zarar / Damage to Infrastructure or Community Assets Proje Çalışanlarının Rahatsızlık Veren Davranışları / Misconduct of Preject Staff Kaza / Accidents Çevresel ve Sosyal / Environmental and Social Arazi Edinimi ve Kamulaştırma / Land Take and Expropriation İş Gücü ve İşe Alım / Labor and Employement Diğer / Other Şikayet-İstek-Öneriyi Açıklayın / Define The Complaint-Request-Proposal: Şikayet-Öneri için Yapılması Gerekenler/Action Required to Solve the Grievance: Şikayet-Öneri için Sorumlu Birim/Responsible Party to Take the Action: Şikayet-Öneri Durumu/ Grievance Status ☐Open ☐Closed ☐Pending Final March 2018 Project No: 17/010 33 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan ANNEX - 2 Grievance Closeout Form SANKO ENERJİ SANAYİ TİCRET A.Ş./SALİHLİ JES ŞUBESİ SANKO SANKO JES PROJESİ ŞİKAYET-İSTEK-ÖNERİ KAPATMA FORMU / COMPLAINT-REQUEST-PROPOSAL CLOSE UP Halkla İrtibat Görevlisinin Adı: Name of CLO: Şikayet-İstek-Öneri Numarası: Complaint- Request-Proposal No Şikayet-İstek-Öneri Tarihi: Date of the Claim: Şikayet-İstek-Öneri Kapanma Tarihi: Date of the Close-up: Şikayet-İstek-Öneriyi Açıklayın: Define The Complaint-Request-Proposal: Gerçekleştirilen Düzeltici Faaliyet: Completed Corrective Action Halkla İrtibat Görevlisinin İmzası: Signature of CLO: Talep Sahibinin İmzası: Signature of Claimer Final March 2018 Project No: 17/010 34 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan ANNEX - 3 Public Participation Announcement Final March 2018 Project No: 17/010 35 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 36 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 37 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 38 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 39 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 40 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 41 / 42 SANKO Geothermal Power Plant Project Stakeholder Engagement Plan Final March 2018 Project No: 17/010 42 / 42 SANKO GEOTHERMAL POWER PLANT PROJECT CULTURAL HERITAGE MANAGEMENT PLAN MARCH 2018 ANKARA SANKO Geothermal Power Plant Project Cultural Heritage Management Plan TABLE OF CONTENTS Page 1 INTRODUCTION ........................................................................................................... 1 2 SCOPE ......................................................................................................................... 2 3 OBJECTIVES ............................................................................................................... 3 4 PROJECT LOCATION .................................................................................................. 4 5 REGULATORY REQUIREMENTS ...............................................................................12 5.1 Turkish Legislation ...............................................................................................12 5.2 World Bank Standards (OP4.11 Physical Cultural Resources) .............................15 5.3 International Conventions ....................................................................................15 6 ROLES AND RESPONSIBILITIES ..............................................................................16 6.1 Requirements and Responsibilities Throughout the Project Phases.....................18 7 IMPLEMENTATION and MONITORING OF CHMP .....................................................20 7.1 Monitoring of CHMP .............................................................................................20 8 AUDIT AND REPORTING ...........................................................................................21 9 CHANCE FIND PROCEDURE .....................................................................................22 9.1 Purpose ...............................................................................................................22 9.2 Scope ..................................................................................................................22 9.3 Responsibilities ....................................................................................................22 9.4 Definitions ............................................................................................................22 9.5 Procedure ............................................................................................................23 Final March 2018 Project No: 17/010 i/ii SANKO Geothermal Power Plant Project Cultural Heritage Management Plan LIST OF TABLES Page Table 5-1. Applicable Project Standards ............................................................................12 Table 6-1. Responsible Parties of the CHMP .....................................................................16 Table 6-2. Key Roles and Responsibilities .........................................................................16 LIST OF FIGURES Page Figure 4-1 Geographical Location of the Project and Associated Facilities .......................... 5 Figure 4-2 Ancient City of Sardis, the Project Area and Operation License Area ................. 7 Figure 4-3 Projected Wells and the Ancient City of Sardis................................................... 9 Figure 4-4 Visibility Map of the Project from the Ancient City of Sardis...............................11 LIST OF BOXES Box 5-1 Classification of Archaeological Sites in Turkey ....................................................13 Final March 2018 Project No: 17/010 ii/ii SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 1 INTRODUCTION This document is the Cultural Heritage Management Plan (CHMP) for ‘Sanko Geothermal Power Plant Project’ (herein after ‘the Project’). It is prepared by 2U1K Engineering and Consultancy Inc. on behalf of “Sanko Enerji Sanayi ve Ticaret A.Ş. (Sanko Enerji” -the Project Company). Sanko Enerji, an energy branch of Sanko Holding Group plannedto develop Sanko Geothermal Power Project with capacity of 15 MW in Manisa, Salihli District, Yılmaz Neighborhood. The Project seeks for potential financing for the first phase of the Project with 15 MW capacity from Türkiye Kalkınma Bankası (TKB), the financial intermediary. This document is prepared for the Project with 15 MW capacity. Sanko Enerji projects the potential expansion of the Project to achieve a total capacity of 50 MW. Therefore, additional wells are planned to be established within the license area of the Project. This CHMP has been prepared in line with the World Bank’s (WBs) OP/BP 4.11 Physical Cultural Resources in order to preserve the archaeological and cultural heritage within the scope of the Project and minimize the possible project impacts. The impact mitigation on the potential and existing archaeological and cultural heritage sites within the project impact area is possible by developing a management plan. Therefore, the construction and drilling activities within the scope of the Project should be conducted in compliance with this management plan. Final March 2018 Project No: 17/010 1 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 2 SCOPE This CHMP applies to all Project activities that have potential to cause an impact on the cultural heritage. This includes especially the site preparation and drilling works of the Project. Noise from testing of wells and odor from the operation of the power plant may have nuisance for the people visiting the sites. Final March 2018 Project No: 17/010 2 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 3 OBJECTIVES The objectives of the CHMP are to:  Define the Project Area and the cultural heritage which the Project may have impacts on;  Define the Regulatory Requirements for the protection of the cultural heritage;  Define roles and responsibilities;  Define implementation and monitoring requirements of the CHMP;  Define auditing and reporting requirements;  Define chance find procedure. Final March 2018 Project No: 17/010 3 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 4 PROJECT LOCATION The Project area is located in Yılmaz Neighbourhood of Salihli District of Manisa Province. Project Company has secured Geothermal Resource Operation License for an area of 2,267.97 hectares with license no.143 and the Production area of the Project covers an area of 84,841 m2. The Licenced Area intersects with the "Agricultural Field" according to the 1/100.000 scale Environment Plan. Yılmaz Neighbourhood at northeast is the closest settlement at a distance of 600 m to the Project area. The Project site is surrounded with agricultural lands at east, west and north and İzmir-Uşak highway (E-96) and Manisa- Salihli-Turgutlu Railway at the south. The Project area and the license are presented in Figure 4-1 and Figure 4-2. Final March 2018 Project No: 17/010 4 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Figure 4-1 Geographical Location of the Project and Associated Facilities Final March 2018 Project No: 17/010 5 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan The closest archaeological site to the Project area is the Ancient City of Sardis which was classified as 1st and 3rd Degree Archaeological Site according to the Ministry of Culture and Tourism, İzmir 2nd Regional Committee of Protection of Cultural Heritage. According to the official letter of Ministry of Culture and Tourism, İzmir 2 nd Regional Committee of Protection of Cultural Heritage no 08.12.2016-7394 no physical or construction activity can be conducted without the Committee consent (Annex-1). According to the United Nations Educational, Scientific and Cultural Organization (UNESCO), the Ancient City of Sardis was designated as 1st and 3rd Degree Archeological Site in 1978. The preservation of ancient remains at Sardis, in Bin Tepe varies widely depending largely on natural topography, later rebuilding, and earlier explorations, licit and illicit. Some areas of Sardis are eroded or were overbuilt in later eras, while other parts of the city are deeply buried and very well preserved; many of the tumuli in Bin Tepe were opened over a century ago and continue to be looted. Furthermore, agriculture, construction, and looting are ongoing problems at Sardis as they are in many ancient sites. The site is under the control of the Manisa Archaeological and Ethnographic Museum, and is controlled by the local gendarmerie and by site guards stationed at the Artemis Temple and the Bath-Gymnasium complex. There are privately owned lands where agricultural activities are taking place. Part of the modern town of Sart is located in the first and third degree protected area of the ancient site, where further building is prohibited (UNESCO, 2013). The license area of the Project intersects the Ancient City of Sardis however, the archaeological site is at about a distance of 4 km to the Power Plant and the wells while the distance to the boundaries of the site is about 2.5 km from the Project units as can be seen in Figure 4-2 below. Final March 2018 Project No: 17/010 6 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Figure 4-2 Ancient City of Sardis, the Project Area and Operation License Area Final March 2018 Project No: 17/010 7 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan The Project has gone through Environmental Impact Assessment (EIA) process according to the EIA Regulation and secured “EIA positive” decision on February 14, 2017 from the Ministry of Environment. As required by EIA process an official opinion on archaeological sites and cultural heritage protection areas was obtained from İzmir Cultural Assets Regional Committee on the Project area during the national EIA process (Annex-2). According to the official letter there are no registered archaeological or protected sites or cultural heritage assets according to the requirements of Law on “Conservation of Cultural and Natural Assets” (Law No. 2863, amended with the Law No. 5226) within the Project area. Sanko Enerji projects the potential expansion of the Project to achieve a total capacity of 50 MW. Therefore, additional wells are planned to be established within the license area of the Project. The locations of the potential wells for the future purposes of the Project are presented in Figure 4-3 . Final March 2018 Project No: 17/010 8 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Figure 4-3 Projected Wells and the Ancient City of Sardis Final March 2018 Project No: 17/010 9 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan As can be seen in Figure 4-3 above, the projected wells are not located in the boundaries of the Ancient City of Sardis. The distance of the closest well is around 900 to 1,000 meters to the borders of the 1.Degree Archaeological site. The location and type of wells have been described in the EIA Report of the Project but on the other hand, during the course of the Project development, both the location and type could be changed based on the outcomes of drilling activities. In case, new wells are required in the upcoming phases of the Project, all required permits will be obtained from pertinent official authorities such as General Directorate of State Hydraulic Works (DSİ), Directorate of Cultural Heritage Protection Committee and Provincial Directorate of Food, Agriculture and Livestock. In any case, no activity will be performed within the area of the Ancient City of Sardis. Impacts of the Project on landscape have been evaluated in the scope of the ESIA studies and a visibility analysis of the Project components from the Ancient City of Sardis was conducted. The area around the Project has flat topography with no specific visual features except for the except for the Ancient City of Sardis whose boundary is at about 2.5 km distance from the Power Plant. Temporary drilling rigs will be visible to the nearby settlements and be contrasting in the landscape. The highest structure within the scope of the Project will be the drilling rigs of 45 meter followed by the plant however will be erected for a limited period of time. Visibility analysis for the landscape impacts on the Ancient City of Sardis was conducted and a visibility map was prepared which is provided below in Figure 4-4. The structural features of the Ancient City are located within a limited area surrounded with orchards. There are also other structures such as dwellings, orchards and road between the existing and planned Project units (the power plant, wells and aboveground pipelines) and the Ancient City which will decrease the visibility of the units. The distance is also relatively long for creating a major negative landscape impact. Final March 2018 Project No: 17/010 10 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Figure 4-4 Visibility Map of the Project from the Ancient City of Sardis Final March 2018 Project No: 17/010 11 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 5 REGULATORY REQUIREMENTS The Project will comply with the national laws / regulations and applicable lender standards, with the more stringent standards representing the Project Standards. Applicable Project Standards are summarized in Table 5-1 below. Table 5-1. Applicable Project Standards Standard Scope Law on Preservation of Cultural and Identification, designation, mitigation and management of cultural Natural Assets heritage World Bank OP4.11 Physical Cultural Risk assessment, mitigation and management related to cultural Resources heritage The Convention Concerning the Protection of the World Cultural and Protection, conservation and presentation of cultural and natural Natural Heritage (The World Heritage heritage Convention) 5.1 Turkish Legislation In Turkey, the movable and immovable cultural and natural assets are put under protection in compliance with the “Law on Preservation of Cultural and Natural Assets”, 2863, which was published in the Official Gazette numbered 18113 and dated 23 July 1983. The objective of the Law is to set the definitions regarding the movable and immovable cultural and natural assets that shall be protected; to arrange the procedures and activities to be performed and to establish the formation and duties of the organization that will enforce the required principles and implement decisions on this subject. Article 3 of the Law provides the following definitions:  Cultural properties are all over-ground, underground or submarine movable and immovable properties related with science, culture, religion and fine arts belonging to prehistoric and historic periods.  Natural properties are the over-ground, underground or submarine properties that belong to geological, prehistoric and historical periods and that shall be protected because of their rarity, features and values. Article 4 of Law regulates the Obligation to inform. In case of chance find of movable and immovable cultural and natural properties there is an obligation to inform the nearest Museum Directorate, Mukhtar, or civil administrative bodies, not later than 3 days after the find. The Mukhtar should inform the nearest civil administrative body within 24 hours of the notification. The civil administrative office will inform the Ministry of Culture and Tourism and nearest Museum Directorate within 10 days of an official application. The General Directorate for Cultural Heritage and Museums of Ministry of Culture and Tourism and the relevant Regional Cultural Heritage Preservation Council is responsible for the registration of the find. Final March 2018 Project No: 17/010 12 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Article 5 states that cultural and natural properties shall be treated as state assets. Article 6 defines immovable cultural and natural heritage properties and provides a detailed list of them. Article 7 states that the relevant Regional Cultural Heritage Preservation Council Directorate is responsible for registration of cultural heritage properties. Article 8 of the Law regulates the taking of decisions for protection areas of cultural heritage properties. This article states that RCHPCs have the power of taking decisions for the protection areas of cultural heritage properties and they decide about the possibility of construction and facilities inside their protection areas. Article 9 of the Law states that construction and physical intervention to the immovable cultural heritage properties is forbidden without the permission and decisions of the Regional Cultural Heritage Preservation Council. Restoration, construction, drilling, partial or total destruction, and excavation are considered as physical interventions. In addition to the Law no: 2863 on Preservation of Cultural and Natural Assets, there are some regulations and principle decisions governing the management of cultural and natural assets. According to the Principle Decision no: 658, taken on November 5th 1999, “Archaeological Sites, Conditions of Protection and Usage”, the archaeological sites are classified into three main categories, which can be found in Box 3-1. Box 5-1 Classification of Archaeological Sites in Turkey Areas requiring highest level of protection, with the exception of scientific excavations aiming protection. Neither construction nor development are allowed in these sites. All kinds of construction, excavation, and modification activities are prohibited within the FIRST DEGREE ARCHAEOLOGICAL SITE boundaries of these sites. However, for exceptional cases such as the necessity for infrastructure construction, Regional Preservation Boards may permit such activities based on the approval of the relevant museum directorate and the head of the scientific excavation team Final March 2018 Project No: 17/010 13 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Sites which require medium level of protection. They should be preserved based on the conditions of protection and utilisation set by the Regional Preservation Boards. Additional construction is prohibited. Similar to the 1st Degree Sites, for SECOND DEGREE ARCHAEOLOGICAL SITES: exceptional cases such as necessity for infrastructure construction among others, Regional Preservation Boards may permit such activities based on the approval of the relevant museum directorate and the head of the scientific excavation team. Lowest level of protection area. Construction is permitted based on the decisions of Regional Preservation Boards. Before applying for a construction permit, test pit excavations should be conducted and the outcomes of these excavations should be reviewed by the relevant museum and, if present, the head of the scientific excavation team. Reviews should be submitted to Regional THIRD DEGREE ARCHAEOLOGICAL SITES Preservation Boards. The Boards may ask for extension of the scope of test pits before taking any decision. Furthermore, Implementation Guidelines for Field Surveys, Test Pits and Excavation Works on Cultural and Natural Assets (Ministry approval number 94949537-160.99-51264, dated 13.03.2013) define the procedures for salvage excavations, archaeological test pits and other studies. Final March 2018 Project No: 17/010 14 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 5.2 World Bank Standards (OP4.11 Physical Cultural Resources) The World Bank’s general policy regarding cultural properties is to assist in their preservation, and to seek to avoid their elimination. The specific aspects of the Policy are given below.  The Bank will assist in the protection and enhancement of cultural properties encountered in Bank financed projects, rather than leaving that protection to chance. In some cases, the project is best relocated in order that sites and structures can be preserved, studied, and restored intact in situ. In other cases, structures can be relocated, preserved, studied, and restored on alternate sites. Often, scientific study, selective salvage, and museum preservation before destruction is all that is necessary. Most such projects should include the training and strengthening of institutions entrusted with safeguarding a nation’s cultural patrimony. Such activities should be directly included in the scope of the project, rather than being postponed for some possible future action, and the costs are to be internalized in computing overall project costs.  This policy pertains to any project in which the Bank is involved, irrespective of whether the Bank is itself financing the part of the project that may affect cultural property. In addition, it states that the impacts on physical cultural resources resulting from project activities including mitigating measures may not contravene either the borrower’s national legislation or its obligations under relevant international environmental treaties and agreements. According to Paragraph 9 of the Policy; “The objective of this policy is to assist borrowing countries to avoid or mitigate adverse impacts on physical cultural resources from development project the Bank finances. In addition, it states that the impacts on physical cultural resources resulting from project activities including mitigating measures may not contravene either the borrower’s national legislation or its obligations under relevant international environmental treaties and agreements.” 5.3 International Conventions Project relevant guidelines include those of the United Nations Educational, Scientific, and Cultural Organization (UNESCO). Turkey ratified "The Convention Concerning the Protection of the World Cultural and Natural Heritage" (The World Heritage Convention). The signatories to this Convention have agreed "to ensure that effective and active measures are taken for the protection, conservation and presentation of the cultural and natural heritage" on their territories. Final March 2018 Project No: 17/010 15 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 6 ROLES AND RESPONSIBILITIES This Plan identifies the requirements, and processes and procedures for CHMP compliance. The Project has the ultimate responsibility for CHMP compliance but responsibilities regarding the protection program are divided between The Project Company staff and Contractors. The introduction of responsible parties to ensure the implementation of the commitments of this Plan is briefly described in the Table below. Table 6-1. Responsible Parties of the CHMP Ministry of Culture  Responsible for culture and tourism affairs in Turkey. and Tourism  Responsible to provide experts for the sites within 24 hours after being Directorate of Manisa informed. Archaeology  Responsible for the excavation of chance find areas. Museum Directorate Museum will follow the directions and decisions of Ankara Regional Preservation Board of Cultural Assets of Ankara. Ankara Regional  The head of decision making any intervention, which would be made on the Preservation Board site after the chance find of Cultural Assets  Responsible with the monitoring of the implementation of the Cultural Heritage Management Plan and the Chance Find Procedure  In case of need to identify a Chance Find, mobilize an archaeology tea andequipment.(stop or resume of the ground disturbing activities will be unde Project Company r the sole responsibility of the cultural heritage responsible staff)  Supervise the cultural heritage responsible staff for the monitoring of cultural heritage and archaeological protection activities  Record and monitor all chance finds through a formal system. Furthermore, the responsibilities for the implementation of this plan are outlined in Table 4- 2 below. Table 6-2. Key Roles and Responsibilities Roles Responsibilities Ensures that this CHMP is implemented General Manager Provides necessary resources for effective implementation of this Plan Ensures that this CHMP is implemented Project Manager Provides necessary resources for effective implementation of this Plan Coordinates with parties for effective implementation of this Plan Ensures that all employees are aware of, and appropriately trained on, Cultural Administrative Affairs Heritage Management Plans, and include cultural heritage into “Code of Manager Conduct” induction training. Construction Works Implements and improves this CHMP Project Manager Ensures that all contractors and subcontractors are aware of, and appropriately trained on Cultural Heritage Management Plans. Records the spatial coordinates of all known cultural heritage sites, and chance Final March 2018 Project No: 17/010 16 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan Roles Responsibilities Operation and Site finds, throughout the Projects lifecycle. Manager OHS Department Community Relations Coordination with organisations and other stakeholders. Officer Comply with cultural heritage management procedures. Contractors Comply with cultural heritage management requirements set out in contractor contracts. Be familiar with cultural heritage management procedures through induction Project Workers training and other training provided. Final March 2018 Project No: 17/010 17 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 6.1 Requirements and Responsibilities Throughout the Project Phases Construction / Drilling Activities Requirements Responsibility  Training on the Ancient City of Sardis and its conservation requirements as well as Chance Find Procedure to all workers including contractors’ and sub-contractors’ should be provided by the Project Company in cooperation with the Ministry of Culture and Tourism and Provincial Museum Directorate. The trainings should be performed along with the start of implementation of ESIA requirements and by external experts if required.  Monitor and audit contractor compliance with cultural heritage protocols  A Chance Finds reporting approach must be implemented and maintained (for all possible Chance Finds, cultural heritage or not)  Any archaeological or heritage site discoveries during works must be reported to the related authorities, Project Company and treated as an incident. Work at the area must cease immediately, the area demarcated and investigate and carry out salvage operations Project Subcontractor  If the Chance Find is an isolate or not cultural heritage, the community superintendents must approve the removal of site protection measures and activity can resume only with consultation and Local / National Authorities approval of the local authorities.  If the heritage specialist and/or archaeologist confirm the Chance Find is an cultural heritage site he/she will inform the Environmental Manager and Supervisor; and initiate discussions with the latter about treatment  If a Chance Find is a verified cultural heritage site, prepare a final Chance Finds report once required treatment has been completed  While required treatment is ongoing, coordinate with Contractor and relevant Project staff keeping them informed as to status and schedule of investigations, and informing both when the construction may resume  Components of the Cultural Heritage Management Plan for the Project will be communicated in an accessible format to local communities, local and national governments and regulatory agencies Operation Phase Requirements Responsibility  Ongoing monitoring and evaluation, through monthly Cultural Heritage monitoring reports, will be Project Company prepared during the operation phase Final March 2018 Project No: 17/010 18 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan  Ongoing implementation of Chance Find approach Local / National Authorities  Ongoing monitoring and auditing of internal and consultant implementation of CHMP Closure Phase Requirements Responsibility  Review all Cultural Heritage monitoring reports and document any potential areas of concern Project Company  Ensure that there are no outstanding grievances that could be of risk to Rio Tinto and subsidiaries at the Local / National Authorities Project site  Determine if post-project monitoring is required Final March 2018 Project No: 17/010 19 / 23 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 7 IMPLEMENTATION and MONITORING OF CHMP This Plan will be reviewed on three months basis during the construction / drilling activities. During the operation phase, revisions (if any) will be made to reflect the changing circumstances or operational needs of the Project. Any revisions to this Management Plan will be distributed accordingly in order to ensure that all Project staff has access to the latest version of this Plan. 7.1 Monitoring of CHMP Monitoring procedures of this Plan are listed below, respectively as;  The Project contractors shall report during drilling/construction works to the related department of the Project Company on the implementation of cultural heritage management requirements during the construction and operation phase of the project, including: o The protection of sites by careful siting of access routes or facilities; o Induction training including cultural heritage awareness given to staff and planned; o Cultural heritage-related complaints and actions taken; o Cases of damage to, or disruption of, cultural heritage properties and actions taken.  The related department of the Project Company will conduct routine inspections of site activities in consultation with the Construction Manager and Operation Manager to assess the potential for chance finds at work sites and any other cultural heritage issues that may arise.  The Project Company will conduct an inspection of any cultural heritage field activities and documentation that are implemented as a result of a chance find or other event that results in archaeological field work. Final March 2018 Project No: 17/010 20 / 24 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 8 AUDIT AND REPORTING1 Internal Auditing Daily inspections will be carried out by operational area superintendents / supervisors covering a broad range of operational aspects, including cultural heritage. Any incidents identified during these inspections will be reported formally. External Auditing Conformance with this plan will be subject to periodic assessment by the Project Lenders. 1 Records of internal and external audits, inspections and incidents will be managed by the Project Company. Final March 2018 Project No: 17/010 21 / 24 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 9 CHANCE FIND PROCEDURE 9.1 Purpose The purpose of this Procedure is to ensure that the impact of construction activities on archaeology and cultural heritage issues in Construction Site of the Project is controlled and minimized. Additionally, this procedure describes how chance archaeological finds should be managed. 9.2 Scope This procedure is applicable within the Project Site and close environs at all stages of the associated facilities, throughout the Project activities. 9.3 Responsibilities Operation and Site Manager will be responsible for conducting this procedure and to ensure the applicability of the methods outlined in this procedure. An archaeological consultant will be responsible to conduct an audit in compliance with the World Bank OP 4.11 Physical Cultural Resources. The consultant will constitute the archaeological watching brief and will be responsible for communicating the chance finds as per the procedure outlined in this procedure. Operation and Site Manager and Archeological Consultant will work together in planning and designing training programs to be delivered to the construction and operation personnel for identification of features suspected to be of cultural value in a quarterly basis. 9.4 Definitions Archaeological discoveries of minor significance: This type of archaeological discovery would be of fairly small size, such as an isolated feature or find-spot. Examples: Statues, Tablets, Seals, Coins, Mosaics, Metal Objects, Human Skeletons, Stone tools, etc. Archaeological discoveries of medium significance: This type of archaeological discovery would be of small to medium size, such as a small group of features or a single burial. Examples: Small size mound, Rock cut tombs, Rock carvings, Fossils. Archaeological discoveries of major significance: This type of archaeological discovery would have fairly major significance such as a settlement site or group of burials. Examples: Mounds, Tumuli, Cave paintings, Castle remains, Acropolis, Necropolis spheres, Open air settlements. Final March 2018 Project No: 17/010 22 / 24 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan 9.5 Procedure In the event of a chance find discovery, the following actions will be executed: 1 All the work will cease at the location of the chance find. 2 Temporary buffer zone will be established around the chance find location. 3 Operation and Site Manager will inform the Archaeological Consultant to make detailed site assessment. 4 Operation and Site Manager will inform Museums Directorate and Museums Directorate representatives to mobilize to site within 24 hours of notification. 5 Museums Directorate will assess findings and determine the significance of the find and will inform Operation and Site Manager and Archaeological Consultant on the scope of the resulting investigation. 6 Operation and Site Manager and Archaeological Consultant be informed of actual time delay. 7 Construction machinery to be removed from the area of the archaeological find and the archaeological area to be cordoned off by warning tapes, fences and notice boards. 8 Operation and Site Manager will fill out a Chance Find form. Final March 2018 Project No: 17/010 23 / 24 SANKO Geothermal Power Plant Project Cultural Heritage Management Plan ARCHAEOLOGICAL CHANCE FIND FORM Location Chance Find No Date Condition Period Description Material Object geometry Photo Name of Encounter Signature Final March 2018 Project No: 17/010 24 / 24 Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 1 / 20 Revision Follow-up Page Prepared by Approved by Environmental Manager Project Manager OHS Manager Revision Date Revision No Revised Page Reason for Revision 15.05.2017 0 - Newly published. Ay, Yıl Rev.0 Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 2 / 20 TABLE OF CONTENTS 1. INTRODUCTION ........................................................................................................... 1 1.1. Purpose and Scope .............................................................................................. 1 1.2. References........................................................................................................... 1 1.3. Basic Principle...................................................................................................... 1 1.4. Review Conditions for Construction Site Emergency Plan .................................... 1 1.5. Definitions ............................................................................................................ 2 2. RESPONSIBILITIES ..................................................................................................... 3 2.1. General ................................................................................................................ 3 2.2. Duty, Authority and Responsibilities of Emergency Response Team.................... 3 3. EMERGENCY RESPONSE .......................................................................................... 7 3.1. Informing the Emergency ..................................................................................... 7 3.2. Access to Scene .................................................................................................. 8 3.3. Evacuation and Assembly Points ......................................................................... 8 3.4. Fire Extinguishing................................................................................................. 9 3.5. Securing-Rescue................................................................................................ 10 3.6. Medical Attention................................................................................................ 10 3.7. Serious Injuries and Loss of Life ........................................................................ 12 3.8. Landslide - Subsidence of Excavation ................................................................ 13 3.9. Rescue from Height ........................................................................................... 13 3.10. Mass Food Poisoning ......................................................................................... 14 3.11. Earthquake......................................................................................................... 14 3.12. Chemical Leakage ............................................................................................. 15 3.13. Events (Terror / Protest / Strike, etc.) ................................................................. 16 3.14. Weather Conditions ............................................................................................ 17 3.15. Floods ................................................................................................................ 17 3.16. Emergency Recording and Reporting ................................................................. 18 3.17. Return to Work after Emergency ........................................................................ 18 Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 3 / 20 4. ASSESSMENT OF EFFICIENCY OF CONSTRUCTION SITE EMERGENCY PLAN AND ITS SUSTAINABILITY ....................................................................................... 18 4.1. Drills ................................................................................................................... 18 4.2. Trainings ............................................................................................................ 19 4.3. Accident-Incident Reporting and Inspection ....................................................... 19 4.4. Emergency Tools and Equipment....................................................................... 19 5. APPENDICES ............................................................................................................. 20 Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 1 / 20 1. INTRODUCTION 1.1. Purpose and Scope This plan is the key document that provides information on the emergencies that can be experienced throughout the Sanko GEPP Project, puts forth the requirements and measures for an effective response and defines the roles and responsibilities during emergency response. This plan covers the entire construction site of Sanko GEPP Project of Sanko Energy Industry and Trade Inc. located at Yılmaz Quarter of Sıraağaç Location at Parcel No. 1182 in Salihli-Manisa. 1.2. References  Regulation on Protection of Buildings against Fire  Regulation on Health and Safety Measures to be taken at Workplace Buildings and Built-on  OHSAS 18001:2008 Article 4.4.7  Regulation on Audit and Control of Food Safety and Quality 1.3. Basic Principle In Sanko GEPP Project, the principle to provide a safe working environment, to determine the risks that could jeopardize the project and the personnel beforehand and to take all measures and be prepared for any possible emergency is adopted. The basic principle is to plan and carry out the preventive actions through risk assessments with the intention to resolve the problem at source before any emergency happens, to be incessantly prepared and cautious by drills, trainings and communication means in a manner that an emergency can be experienced at any time. 1.4. Review Conditions for Construction Site Emergency Plan The existing plan is revised when permanent modifications are required to be made in one or more items that constitute the Construction Site Emergency Plan. The plan is revised under following conditions;  Noticing deficients during drills,  Amendments in legal regulations, Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 2 / 20  Encountering serious accidents or incidents,  Renewal of risk assessments,  Changes in used technique, method, material or equipment,  Excluding the above stated reasons, in cases where revision is required in the existing system due to unpredictable reasons. Even none of above is experienced; Construction Site Emergency Plan is reviewed and updated every 6 months. 1.5. Definitions Emergency: States caused by incidents considered as disaster, inattention, negligence, malice and all incidents executed with various reasons. (Regulation on Protection of Buildings against Fire) Emergency Response Teams: Teams to be assigned during emergencies. Emergency Plan: Plan that set forth how and by whom the response, securing, search and rescue and first aid will be performed during incidents requiring emergency and that should be prepared before emergencies. (Regulation on Protection of Buildings against Fire) Fittings: Building elements in buildings such as sanitation system, electricity wiring, etc. Adsorbent: Solid substance that withholds the liquid or chemicals by absorbing. Closest Health Facility: Unless specified otherwise by Occupational Physician and/or Emergency Manager in case of emergency, the closest health facility will be considered as the State Hospital. Excavation: Excavating the soil, digging. Material Safety Data Sheet: A document that contains detailed information on the characteristics of the chemical substances and also information on safety measures to be taken as per the characteristics of the chemical at the workplace and on the protection of environment and human health against the adverse impacts of the chemical. Risk: Loss, injury or other unhealthy consequence to be arisen owing to the danger. Danger: Potential to give damage or harm that can happen at or outside the workplace and that can affect the personnel or the workplace. (Occupational Health and Safety Law) Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 3 / 20 Risk Assessment: Studies required to be performed to determine the dangers at or outside the workplace, to grade these dangers through the analysis of the factors that can cause these dangers to turn into risks and risks resulting from the dangers and also to agree on the control measures. Sabotage-Arson: Setting the property on fire intentionally. Hot Works: Works that can cause sparks or flames at a degree of temperature that can ignite the combustible and inflammable substances. For example; Grinding, welding and cutting, usage of equipment that can cause open flame, spark at the areas where there is combustible gas and vapour. Assembly Point: An area where evacuees should assemble in case of emergency, where the personnel will be counted and the instructions will be given. 2. RESPONSIBILITIES 2.1. General All project personnel are liable for the application of this plan and working in compliance to the plan. Emergency Response team member should be selected among the personnel, who are familiar with the occupational health safety and emergency issues, obey the rules strictly and assigned by their superiors. 2.2. Duty, Authority and Responsibilities of Emergency Response Team Construction Site Manager (Emergency Manager)  Responsible for the enactment of the plan.  Provides the supply of the resources requisite for emergency responses.  Decides whether the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) will be called.  Leads the Emergency Response Team until the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) arrives at the scene and takes the situation in hand.  Decides whether the site is to be evacuated or the personnel can continue working depending on the information coming from the scene.  Gathers information on the number of injuries and the scale of the damage and harm on the equipment and assets.  Ensures that the required information is conveyed to Subcontractor Managers. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 4 / 20  Provides communication with the Project Owner and Consultant. Project OHSE Expert (Emergency Deputy Manager)  Brings Construction Site Manager (Emergency Manager) up-to-date for him to fulfil his obligations.  Undertakes the management when Emergency Manager is absent.  Provides the safety of the region affected by the emergency.  Carries out research on the emergency after the emergency response is completed and provides suggestions for the required corrective-preventive measures.  Organizes requisite trainings for the personnel.  Follows the short and safe access routes to the workplace for the possible emergencies. Section Chief / Site Engineer / Architect / Technician  Makes arrangements for safe evacuation of the scene of emergency.  Provides the security of his area of responsibility.  Informs the responsible personnel of the Subcontractor at the collective working area.  Provides emergency access for all restricted and limited working areas during emergencies.  Provides the execution of the determined corrective-prevention measures after the emergency response.  Provides that the personnel receive the required training.  Ensures that the inferior personnel gather at the assembly point.  Counts the personnel at the assembly point and determines the absent personnel, if any, by contacting the Administrative Affairs Department.  Takes the requisite measures at his area of responsibility.  Helps the Emergency Response Team physically with heavy machinery and motor vehicles when necessary.  Provides the blackout of power at the impacted area.  Controls the operability of the emergency lighting and fire alarm system. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 5 / 20  Provides the maintenance of the malfunctions in the electricity by authorized person. Emergency Response Team (Fire Extinguishing, Search-Rescue-Evacuation and First Aid Team)  The fire extinguishing team will intervene as per the instruction of the team leader if the fire is not severe.  Helps the Project OHSE Expert - to the possible extent - while keeping the vicinity of the emergency area safe until the local emergency organizations arrives at the scene.  Supports the securing-rescue studies of the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) for the personnel and the valuable assets that are in danger.  Coordinates the personnel at the assembly point. If required, provides their evacuation to a safe place.  Provides the securing of the personnel and valuable assets after the emergency is taken under control.  Provides first aid to the injured person to the possible extent until the first aid team, doctor, medical personnel or ambulance arrives.  Provides the transfer of the stretchers and sanitary transport kit, which are placed at central points at the site, to the scene during emergency.  Provides the transfer of the injured person to the ambulance after their transport by stretchers or sanitary transport kit. Administrative Affairs  Contacts the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) as per the information provided by the Emergency Manager.  Organizes the access of the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) to the scene.  Ensures that the personnel at the offices arrive at the assembly point, counts the personnel and ascertains that no one stayed at the emergency area.  Decides if there are any missing personnel according to the number of personnel coming from the site.  Ensures that the office buildings are completely evacuated during emergency. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 6 / 20  Communicates with the relatives of the affected personnel. Security Supervisor  Controls the entry-exit gates of the construction site and only allows the entrance of the local emergency vehicles to the construction site.  Helps the access of the local emergency organizations to the scene.  Helps the organization of the traffic during emergency.  Disallow the entrance to the scene except for the Emergency Response Team. Occupational Physician and Other Medical Personnel  Helps the Emergency Response Team in lifesaving and first aid to the injured person.  Gives urgent medical attention to the injured personnel until health organizations arrive.  Contacts the ambulance or hospital when required and informs Emergency Manager.  Carries out the requisite controls at dining halls, kitchen and food storehouse in mass food poisonings. Subcontractor Managers  Provides the safety of his personnel.  Ensures that all his personnel arrive at the assembly point, counts the personnel and ascertains that no one stayed at the emergency area.  Provides the security of his area of responsibility.  Provides emergency access to his working areas of responsibility.  Takes the corrective-preventive measures after emergency response.  Provides that his personnel receive the required training. Subcontractor HSE Experts  Responsible for the conduction of the works in compliance to this plan.  Receives the required training on Emergency Plan. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 7 / 20  Coordinates his own personnel in the scope of emergency response. Site Workers  Arrives at the assembly point and follows the given instructions.  Keep the access roads to the working areas open for emergencies. 3. EMERGENCY RESPONSE For the construction site, occupational accident, landslide, subsidence of excavation, fire, explosion, earthquake, storm, flood, mass food poisoning and incidents concerning the public peace (burglary, sabotage, arson, etc.) and all incidents that would cause panic, disorder and tension at the construction site and among personnel, although not predicted herein, are the incidents when the emergency response will be of concern. 3.1. Informing the Emergency In case of emergency, witness to the incident should immediately inform the related department by telephone or verbally. If telephone is to be used, the telephone number of the Emergency Manager listed in the Emergency Communication Numbers hanged at the entry-exit gates of the site shall be dialled. In cases when the informing is to be made verbally, the person will run and notify his superior or an authorized person. The witness should be calm when informing the emergency and the following information should be given explicitly:  Location,  Type of incident,  If an injury is of concern,  Name of informant. Together with informing the emergency, Emergency manager will investigate the emergency, set an order of priority according to the situation, inform the fire brigade, ambulance and public order team and the Project Owner and the Main Contractor. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 8 / 20 3.2. Access to Scene No equipment or goods will be left at the vehicle entry-exit roads, on the stairs, pedestrian walkways and the roads will be open at all times so that the Emergency Response Team (Fire Extinguishing, Securing-Rescue and First Aid) can access the scene shortly and safely in case of emergencies. For the possible blackouts during the emergency, generators with adequate capacity will be reserved. Moreover, emergency access will be provided for all restricted and limited areas where work is going on. No one except for the Emergency Response Teams will be allowed at the scene. 3.3. Evacuation and Assembly Points In case if evacuation is required during emergency, the decision to evacuate will be informed to the site supervisors (site engineer/architect, technician and foreman) by telephone. After notification, the supervisors will be responsible for announcement of the emergency to the workers that they are in charge of and will direct them to the assembly point. The works of all teams and equipments will be stopped at the impacted area during emergency. An assembly point will be designated at the construction site at open space and outside the buildings and easily visible signs will hanged at the assembly point. The personnel will be informed during the work initiation training and in case of any change of assembly point. The assembly points of Sanko GEPP Project are located at the rear side of the Construction Site Offices and in front of the offices at SAN2 region. In case if a danger is of concern at both assembly points or at the routes towards these points, a safe spot will be selected for waiting. In case of an emergency, section chief, site engineers / architects / technicians and foremen will count the personnel and ascertain that no one stayed at the emergency area. The evacuation of the Office region is the responsibility of Administrative Affairs Department. No equipment or goods will be left at the entry-exit roads, passages, on the stairs and pedestrian walkways and the roads will be open at all times so that the personnel can evacuate the area shortly and safely in case of emergencies. Emergency lighting will be placed at the access routes. The site layout plan and pedestrian/vehicle roads will be demonstrated on the central doors. Attention will be paid for the evacuation of the disabled personnel by his/her department. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 9 / 20 3.4. Fire Extinguishing The fire extinguishing team will respond, extinguish or take the fire under control using the information of the fire extinguishing training taken previously. When the local fire brigade arrives, the team will help the extinguishing works under the command of the local authority when required. When the fire extinguishing team becomes aware of the fire, the extinguishing works will be commenced if the fire is recently started and if it can be extinguished with the fire extinguishers (or after putting into use, by water extinguisher and hydrant systems) and in cases if the fire is larger, requisite measures will be taken for the fire not to spread and fire brigade will be waited. In the meanwhile, the team members will not endanger themselves or team-mates under no circumstances. The entire team will be under the command of the local fire brigade team and provide their support when needed. When the fire is put out, the team will support the works to be carried out for loss assessment and for detection of the reason of the fire. Salihli Fire Brigade that is the closest to the construction site will be contacted and it will be provided that the fire brigade will visit the construction site on a regular basis and be informed about the current state of the project, the roads and the buildings. Salihli Fire Brigade Directorate Address: ATATÜRK MH. AKHİSAR YOLU NO: 4 PK: 45300 SALİHLİ MANİSA Telephone: 0236 714 11 48 Map View: Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 10 / 20 3.5. Securing-Rescue Securing-Rescue team will support the local emergency organizations (fire brigade, civil defence, health facilities, etc.) in case of emergencies such as fire, landslide, subsidence of excavation, flood, earthquake, etc. during the rescue and protection efforts for the personnel and valuable assets that are in danger. The team will be selected beforehand and will be informed on the matter. The duties of the securing-rescue team are to ensure the evacuation is carried out without panic in case of emergency, to count the personnel after evacuation to detect the place and location of the person to be rescued and to convey the injuries to the first aid team and the goods to the employer after the incident. 3.6. Medical Attention The first contacted department in emergencies requiring medical attention is the Health Department. Medical personnel will arrive to the scene with immediate medical response bag and stretcher. The first aid treatment of the injured person in case of emergencies will be applied by the certified first aid team with requisite training until the medical team of the construction site arrives at the scene. The medical personnel of the construction site will perform the required immediate medical treatments of the injured person and maintain their health condition until the closest health facility arrives at the scene. In serious injuries, the ambulance service will be notified by phoning 112 and it will be ensured that the injured person will be taken to the closest health facility immediately. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 11 / 20 Map View: Özel Medigüneş Hospital Address: Zafer Mah., 629. Sk. No: 27, 45300 Salihli/Manisa, Turkey Telephone: +90 236 712 07 12 Özel Salihli Can Hospital Address: Avar Caddesi No: 123 Salihli / MANİSA Telephone: 0 (236) 715 40 00 pbx Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 12 / 20 Özel Salihli Hospital Address: Cumhuriyet Mahallesi, Menderes Cad. No: 48, 45300 Salihli/Manisa, Turkey Telephone: +90 236 713 14 00 Salihli State Hospital Address: Sağlık Mahallesi, Şühada Cad., 45310 Merkez/Salihli/Manisa, Turkey Telephone: +90 236 713 15 00 3.7. Serious Injuries and Loss of Life In case of serious injuries, the immediate response will be performed by the trained and certified personnel, who are competent in first aid. Firstly, the scene will be Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 13 / 20 investigated to secure the entry and the situation will be assessed. Later on, first aid will be applied to the sick or injured person. Unconscious and injured person that fell from heights will not be moved. In case of loss of life, the scene will be surrounded with safety tape and the access to the scene and the impacted area will not be allowed. Afterwards, the police will be informed. Short, brief and accurate information will be given to the police to help during interrogation and inspections. No predictions will be made. Technical and administrative details will only be explained by Emergency Manager. 3.8. Landslide - Subsidence of Excavation In case if the personnel would be trapped under excavated material during the construction activities, local fire brigade, civil defence directorates and medical facilities will be immediately contacted. Against the possibility of continuation of the subsidence of the excavation, it is forbidden to the personnel of the construction site to enter the excavation for rescue. The heavy machinery and equipment on site will not be used for rescue to prevent additional injuries or mortalities. The securing-rescue team will be under the command of the local emergency organizations when they arrive at the scene and provide support when needed. 3.9. Rescue from Height Rescue from height can be required if the personnel would be trapped in the elevator, working platforms, at high working areas, scaffolds or in case of fallings. If the personnel could be reached with a safe ladder or similar equipment, he/she can be rescued; otherwise, rescue operation will not be performed. Furthermore, if risk is not of concern for the injured person or the person in shock (excluding the cases when hanging at the safety belt or got stuck on the platform being collapsed), the emergency response will be performed only by the external rescue teams for the prevention of further injuries of the casualty and rescuers. For similar cases when the construction site means are inadequate, fire brigade will be contacted for the rescue operation. The place and height where the personnel are trapped will be explicitly uttered when informing the rescue team so that the team will provide the proper rescue teams and equipment. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 14 / 20 3.10. Mass Food Poisoning Mass food poisoning can be experienced at institutional catering places such as the personnel dining halls and the commissary stores at the social facilities. The symptoms of the poisoning can emerge in the following 2-4 hours after food consumption or in 8-12 hours. In case of food poisoning, Administrative Affairs, Occupational Physician and Kitchen/Dining Hall Chief will carry out the requisite controls at dining halls, kitchen and food storehouse:  How many people are poisoned? To which case it resembles clinically? Which are the suspected food and for what?  What are the menus covering all four meals given to the personnel before the food poisoning?  Which foods can lead to poisoning?  When was the purchase date of the suspicious food and when were they used for cooking?  Where and at which temperature was the food stored before consumption?  At which temperature and how long was the food waited?  If the suspicious food is a meat product, was it defrosted in proper conditions?  Are there any leftovers from the suspicious food?  If any food product was thrown away or considered suspicious recently? After the initial inspection, the samples from the past four meals will be sent to the laboratory for analysis and the results of the analysis will be presented to the Emergency Manager. After the poisoning is taken under control, an incident assessment report will be prepared and the measures required to be taken for the incident not to happen again will be determined. 3.11. Earthquake Instant earthquakes that can happen without any warning can give serious damage to the buildings that are still being constructed or the completed ones, heavy machinery and the structures at the construction site, public services and the communication and they can lead to landslides and fires. Requisite measures should be taken at the construction site to minimize the earthquake related risks: Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 15 / 20  The lockers and similar furniture that can fall over at the construction site facilities (offices, dining halls, storehouses, WCs, etc.) should be fixed to each other and to the wall or floor. Lower furniture should be preferred instead of furniture reaching the ceiling.  The lighting armature, air conditioners, ceiling and others that are hanged to the ceiling and the walls temporarily should be fixed in a way that they can sustain their weight.  Heavy goods should not be placed at high places at the construction site facilities (offices, dining halls, storehouses, WCs, etc.). Anti-slip ground covers should be placed to prevent the slip and falling of the goods and materials if it is unavoidable to place.  The objects that can fall or leak should not be placed to the corners of the floor slabs, shafts and spaces at the work area. Huge and heavy equipment should be fixed to the floor or wall.  Earthquake related risks should be considered during installation of critical systems (electricity, pressure pipes and tanks, fire and cooling water systems, hydraulic lines, etc.) and the communication network that can cause emergencies indirectly. The response operation will be started after the earthquake and Emergency Manager will decide on whether an evacuation is required or not. If evacuation is required, the alarm will be raised or all personnel will be notified by a megaphone and the personnel will gather at the points that are designated earlier. After the counting that will be performed on department basis and the evacuation of the personnel, the damage at the construction site will be determined and maintenance works will be performed within the bounds of possibility. Before the commissioning of the activities at the construction site, the equipment such as scaffolds, working platforms, cranes, etc. and all facilities including the entire working area will be inspected. After the inspection, the decision of the Emergency Manager will be awaited. 3.12. Chemical Leakage The following tools and equipment will be kept available to respond the leakage of the oil, grease, liquid chemical, etc. at the construction site:  Personal protective equipment such as gloves, respirator, work shoes and protective clothing against chemicals, Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 16 / 20  Barriers or sand bags to prevent the spread of the leakage,  Fine saw dust, sand, absorbing pillows or other absorbing material to remove the leaking chemical,  Pump to remove vast amount of leaking substance inside ditches or pits. The methods of response to the chemical leakage vary depending on the structure and amount of the leaking substance. Therefore, the type (solvents, gasoline and similar combustible/flammable, abrasive, toxic, explosive chemicals that are stored collectively) and amount of chemicals at the construction site will be determined. Material Safety Data Sheet (Safety Data Sheet - SDS) and labels will be used when determining the dangers/risks of each chemical. In case of leakage, the impacted area will be isolated and no one except for the response team using the proper personnel protective equipment will be allowed to enter. Depending on the leaking substance, the control of the spillage will be carried out by cutting-off the valves, lowering of the pressure of the tanks, transfer of the product, patching or plugging the source of leakage or absorbing the leaking substance, usage of absorbing materials for removal. In case of chemical leakage, the Emergency Manager will decide on the need for providing emergency response from the external organizations (fire brigade, provincial directorates of Ministry of Forest and Water Management and the Ministry of environment and Urbanization, etc.) depending on the character, volume of the leaking substance, to where the substance leaked (for example, floor, soil or drains) and the magnitude of the impact. 3.13. Events (Terror / Protest / Strike, etc.) Anarchy events such as bomb threats, sabotage-arson, burglary and strike happen without forewarning and seriously threaten the safety of the workers. In case of any security threat such as an anarchic problem or attack, the local police/gendarme will be immediately notified. Handling of the violent personnel will not be undertaken by anybody including the security guards until the police/gendarme arrives. The following steps will be followed in case of any treat phones to the construction site:  The person answering the telephone should remain calm and get as much information as possible.  The collected information should be written down. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 17 / 20  After a threat and annoying telephone, the person who answers the phone will immediately notify the Emergency Manager. This conversation should not be shared with anyone unless instructed by the Emergency Manager.  Emergency Manager should contact the police/gendarme. 3.14. Weather Conditions Emergencies that can affect the construction site depending on the weather conditions are hurricane or typhoon, tornado or severe storms. The auditory, printed and mass media should be followed for the warnings against hurricane, typhoon or tornado risks at the region of the construction site and local weather station (meteorological) should be kept in touch. All personnel should be notified in line with the warning. In case of evacuation decision, the construction site personnel should leave the working areas and go to a safe area. Emergency Manager will determine the safe areas of the construction site, preferably under original ground level. These areas will be small rooms or corridors at the ground floor away from the gates and windows and the rooms with brick or concrete walls and ground. Conference rooms, cafeterias or large rooms with flat wide ceilings and light modular offices and modular houses are not considered as safe. After emergency, damage will be determined and requisite repairs will be performed. Before start working, the equipment such as scaffolds, working platforms, cranes, etc. and all facilities will be inspected. 3.15. Floods The floods that are among the common natural disasters can be experienced after the sudden melt down of snow, torrents and severe storms. Although the flood risk is low given that the construction site is at a distance from the water sources, rivers or dams and located at high ground, the auditory, printed and mass media should be followed for the warnings against flood at the region of the construction site. The water drainage system will be considered while establishing the construction site and structural alterations, the expensive systems and equipment will not be placed at lower elevations. The personnel working at or under the original ground level during flood will go to higher floors or higher grounds using the emergency evacuation roads. After receding of the water level, damage assessment of the corporate assets will be carried out. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 18 / 20 The excavations that are exposed to the flood are rather unstable. Therefore, the ground conditions will be inspected before working at an excavation and the work will start afterwards. 3.16. Emergency Recording and Reporting The operations related with the emergency will be verbally reported to the Emergency Manager and Project OHSE Expert. After the emergency is gotten under control and obviated in the consequence of the operations, Project OHSE Manager and Emergency Manager will arrive at the scene and detect and put the following in written record:  Place of emergency,  Date, hour and duration of emergency,  Description of the emergency,  Impact of the emergency (damage on personnel and tangible asset),  Measures to be taken and operations to be performed to continue the work,  Responsibles of the measures and operations. 3.17. Return to Work after Emergency Project OHSE Expert will inspect in-situ whether the determined operations are performed and measures are taken before return to and start of work. After the verification by the Project OHSE Expert that the defined operations and measures are completely fulfilled, return to work will be allowed by the decision of Project Manager and Coordination Chief. After the start of work, Project OHSE Expert will keep a close watch on the related activity area according to the significance and severity of the detected emergency and verify the effectiveness and adequacy of the defined preventive measures. 4. ASSESSMENT OF EFFICIENCY OF CONSTRUCTION SITE EMERGENCY PLAN AND ITS SUSTAINABILITY 4.1. Drills Drills will be conducted every 6 months to rate the efficiency of the Construction Site Emergency Plan. The duties and responsibilities will be reminded to the persons Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 19 / 20 before the drills. The drills will be conducted without notice and the response times will be monitored and recorded. If the Construction Site Emergency Plan could be followed effectively during the drill, the plan will be revised. After the drill,  Trainings will be organized to resolve the faults in the behaviours of the persons,  Inconveniences, if any, will be corrected via requisite instructions,  Plan will be revised considering the suggestions of the Project OHSE Expert if any deficiency is of concern. 4.2. Trainings After organizing the emergency response team, they will be trained about the content of the Construction Site Emergency Plan and the responsibilities will be explained to the team members in case of emergencies. The team will get refresher trainings every six months in all cases. Training label will be given to the emergency response team after the training for them to place on their helmets. 4.3. Accident-Incident Reporting and Inspection All encountered emergencies will be recorded and reported. After any accident or incident is experienced and gotten under control, accident- incident inspection process will be started. The reasons for every reported incident will be investigated and the corrective and preventive actions will be started to eliminate the detected reasons. The statistics and risk assessments from the accident-incident reporting will be used to develop a proactive approach. 4.4. Emergency Tools and Equipment Fire  The controls of the fire extinguishing equipment (fire extinguishers, hydrant system, pickaxe, shovel, hook, etc.) will be performed monthly and the results of the control will be recorded.  Fire extinguishers will be placed at every location where hot works are being performed and also fire panels will be placed at the central locations of the construction site. The tools on the fire panel will not be used for other purposes. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 15.05.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 20 / 20  Fire extinguishers will be found at the heavy machineries and they will be checked monthly. First Aid  The control of the firs aid kits and the stretchers at the OHSE site offices will be carried out regularly by OHSE personnel, they will be easily accessible and signs showing their locations will be placed. 5. APPENDICES Appendix.1 List of Emergency Team Appendix.2 Information on Emergency Communication Appendix.3 Emergency Layout Plan Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03.EK1 SANKO GEPP First Publication Date 10.06.2017 CONSTRUCTION SITE Revision No 0 EMERGENCY RESPONSE Revision Date TEAM Page No 1/2 Company: Date: Search-Rescue and First Aid Team  The fire extinguishing team will intervene as per the instruction of the team leader if the fire is not severe.  Helps the Project OHSE Expert - to the possible extent - while keeping the vicinity of the emergency area safe until the local emergency organizations arrives at the scene.  Supports the securing-rescue studies of the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) for the personnel and the valuable assets that are in danger.  Coordinates the personnel at the assembly point. If required, provides their evacuation to a safe place.  Provides the securing of the personnel and valuable assets after the emergency is taken under control.  Provides first aid to the injured person to the possible extent until the first aid team, doctor, medical personnel or ambulance arrives.  Provides the transfer of the stretchers and sanitary transport kit, which are placed at central points at the site, to the scene during emergency.  Provides the transfer of the injured person to the ambulance after their transport by stretchers or sanitary transport kit. Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03.EK1 SANKO GEPP First Publication Date 10.06.2017 CONSTRUCTION SITE Revision No 0 EMERGENCY RESPONSE Revision Date TEAM Page No 2/2 1. Emergency Manager Name-Surname Duty Telephone Signature 2. Fire Extinguishing Team Name-Surname Duty Telephone Signature 3. Search-Rescue-Evacuation Team Name-Surname Duty Telephone Signature 4. First Aid Team Name-Surname Duty Telephone Signature Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. SANKO Document Code SE.P01.PL03.EK2 GEPP First Publication Date 10.06.2017 CONSTRUCTION SITE Revision No 0 EMERGENCY Revision Date COMMUNICATION Page No 1/1 ACCIDENT - INCIDENT COMMUNICATION AUTHORIZED PERSONNEL AT CONSTRUCTION SITE MEDICAL ASSISTANT Ali Gökçe 0 543 468 45 74 SITE MANAGER İbrahim Taş 0 533 911 66 37 ADMINISTRATIVE AFFAIRS Turgut Sümer 0 532 285 47 51 DIRECTOR KAYA OSGB HSE EXPERT Onur Can Kaya 0 543 685 18 23 IMMEDIATE AID AMBULANCE 112 FIRE BRIGADE 110 POLICE 155 Information to be given in emergency calls DETAILS OF CALL □ IDENTITY OF CALLER? □ PLACE OF INCIDENT? □ TIME OF INCIDENT? □ HOW MANY PEOPLE ARE AFFECTED? □ WHAT HAPPENED TO CASUALTY? □ CONDITION OF CASUALTY? Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 1 / 23 Revision Follow-up Page Prepared by Approved by Environmental Manager Project Manager OHS Manager Revision Date Revision No Revised Page Reason for Revision 06.12.2017 0 - Newly published. Ay, Yıl Rev.0 Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 2 / 23 TABLE OF CONTENTS 1. INTRODUCTION ........................................................................................................... 4 1.1. Purpose and Scope .............................................................................................. 4 1.2. References........................................................................................................... 4 1.3. Basic Principle...................................................................................................... 4 1.4. Review Conditions for Operation Emergency Plan ............................................... 4 1.5. Definitions ............................................................................................................ 5 2. RESPONSIBILITIES ..................................................................................................... 6 2.1. General ................................................................................................................ 6 2.2. Duty, Authority and Responsibilities of Emergency Response Team .................... 6 3. EMERGENCY RESPONSE .......................................................................................... 9 3.1. Informing the Emergency ................................................................................... 10 3.2. Access to Scene ................................................................................................ 10 3.3. Evacuation and Assembly Points ....................................................................... 10 3.4. Fire Extinguishing............................................................................................... 11 3.5. Securing-Rescue................................................................................................ 12 3.6. Medical Attention................................................................................................ 13 3.7. Serious Injuries and Loss of Life ........................................................................ 15 3.8. Landslide - Subsidence of Excavation ................................................................ 15 3.9. Rescue from Height ........................................................................................... 16 3.10. Mass Food Poisoning ......................................................................................... 16 3.11. Earthquake......................................................................................................... 17 3.12. Chemical Leakage ............................................................................................. 18 3.12.1. Pentane Leakage .......................................................................................... 19 3.13. Events (Terror / Protest / Strike, etc.) ................................................................. 19 3.14. Weather Conditions ............................................................................................ 19 3.15. Floods ................................................................................................................ 20 3.16. Emergency Recording and Reporting ................................................................. 20 3.17. Return to Work after Emergency ........................................................................ 21 Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 3 / 23 4. ASSESSMENT OF EFFICIENCY OF OPERATION EMERGENCY PLAN AND ITS SUSTAINABILITY....................................................................................................... 21 4.1. Drills ................................................................................................................... 21 4.2. Trainings ............................................................................................................ 22 4.3. Accident-Incident Reporting and Inspection ....................................................... 22 4.4. Emergency Tools and Equipment....................................................................... 22 5. APPENDICES ............................................................................................................. 23 Warning: This plan is prepared by KAYA OSGB for Sanko Energy Geothermal Power Plant Enterprise. It is forbidden to duplicate, to use the plan outside the power plant without permission. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 4 / 23 1. INTRODUCTION 1.1. Purpose and Scope This plan is the key document that provides information on the emergencies that can be experienced at the Sanko Energy Geothermal Energy Power Plant Enterprise, puts forth the requirements and measures for an effective response and defines the roles and responsibilities during emergency response. This plan covers the entire operation site of Geothermal Energy Power Plant of Sanko Energy Industry and Trade Inc. located at Yılmaz Quarter of Sıraağaç Location at Parcel No. 1182 in Salihli-Manisa. 1.2. References  Regulation on Protection of Buildings against Fire  Regulation on Health and Safety Measures to be taken at Workplace Buildings and Built-on  OHSAS 18001:2008 Article 4.4.7  Regulation on Audit and Control of Food Safety and Quality 1.3. Basic Principle In Sanko Energy GEPP Enterprise, the principle to provide a safe working environment, to determine the risks that could jeopardize the operation and the personnel beforehand and to take all measures and be prepared for any possible emergency is adopted. The basic principle is to plan and carry out the preventive actions through risk assessments with the intention to resolve the problem at source before any emergency happens, to be incessantly prepared and cautious by drills, trainings and communication means in a manner that an emergency can be experienced at any time. 1.4. Review Conditions for Operation Emergency Plan The existing plan is revised when permanent modifications are required to be made in one or more items that constitute the Operation Emergency Plan. The plan is revised under following conditions;  Noticing deficients during drills, Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 5 / 23  Amendments in legal regulations,  Encountering serious accidents or incidents,  Renewal of risk assessments,  Changes in used technique, method, material or equipment,  Excluding the above stated reasons, in cases where revision is required in the existing system due to unpredictable reasons. Even none of above is experienced; Operation Emergency Plan is reviewed and updated annually. 1.5. Definitions Emergency: States caused by incidents considered as disaster, inattention, negligence, malice and all incidents executed with various reasons. (Regulation on Protection of Buildings against Fire) Emergency Response Teams: Teams to be assigned during emergencies. Emergency Plan: Plan that set forth how and by whom the response, securing, search and rescue and first aid will be performed during incidents requiring emergency and that should be prepared before emergencies. (Regulation on Protection of Buildings against Fire) Fittings: Building elements in buildings such as sanitation system, electricity wiring, etc. Adsorbent: Solid substance that withholds the liquid or chemicals by absorbing. Closest Health Facility: Unless specified otherwise by Occupational Physician and/or Emergency Manager in case of emergency, the closest health facility will be considered as the State Hospital. Excavation: Excavating the soil, digging. Material Safety Data Sheet: A document that contains detailed information on the characteristics of the chemical substances and also information on safety measures to be taken as per the characteristics of the chemical at the workplace and on the protection of environment and human health against the adverse impacts of the chemical. Risk: Loss, injury or other unhealthy consequence to be arisen owing to the danger. Danger: Potential to give damage or harm that can happen at or outside the workplace and that can affect the personnel or the workplace. (Occupational Health and Safety Law) Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 6 / 23 Risk Assessment: Studies required to be performed to determine the dangers at or outside the workplace, to grade these dangers through the analysis of the factors that can cause these dangers to turn into risks and risks resulting from the dangers and also to agree on the control measures. Sabotage-Arson: Setting the property on fire intentionally. Hot Works: Works that can cause sparks or flames at a degree of temperature that can ignite the combustible and inflammable substances. For example; Grinding, welding and cutting, usage of equipment that can cause open flame, spark at the areas where there is combustible gas and vapour. Assembly Point: An area where evacuees should assemble in case of emergency, where the personnel will be counted and the instructions will be given. 2. RESPONSIBILITIES 2.1. General All enterprise personnel are liable for the application of this plan and working in compliance to the plan. Emergency Response team member should be selected among the personnel, who are familiar with the occupational health safety and emergency issues, obey the rules strictly and assigned by their superiors. 2.2. Duty, Authority and Responsibilities of Emergency Response Team Operation Manager (Emergency Manager)  Responsible for the enactment of the plan.  Provides the supply of the resources requisite for emergency responses.  Decides whether the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) will be called.  Leads the Emergency Response Team until the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) arrives at the scene and takes the situation in hand.  Decides whether the site is to be evacuated or the personnel can continue working depending on the information coming from the scene.  Gathers information on the number of injuries and the scale of the damage and harm on the equipment and assets.  Ensures that the required information is conveyed to operation engineers. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 7 / 23  Provides communication with Sanko Energy and management of Sanko Holding if required. Operation OHS Expert (Emergency Deputy Manager)  Brings Operation Manager (Emergency Manager) up-to-date for him to fulfil his obligations.  Undertakes the management when Emergency Manager is absent.  Provides the safety of the region affected by the emergency.  Carries out research on the emergency after the emergency response is completed and provides suggestions for the required corrective-preventive measures.  Organizes requisite trainings for the personnel.  Provides evaluation and suggestions for short and safe access routes to the safe areas from the workplaces for the possible emergencies. Operation Engineer  Makes arrangements for safe evacuation of the scene of emergency.  Provides the security of his area of responsibility.  Informs the engineers at the collective working area.  Provides emergency access for all restricted and limited working areas during emergencies.  Provides the execution of the determined corrective-prevention measures after the emergency response.  Provides that the personnel receive the required training.  Ensures that the workers under his/her responsibility gather at the assembly point.  Counts the personnel at the assembly point and determines the absent personnel, if any, by contacting the Administrative Affairs personnel.  Takes the requisite measures at his area of responsibility.  Helps the Emergency Response Team physically with heavy machinery and motor vehicles when necessary.  Provides the blackout of power at the impacted area. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 8 / 23  Controls the operability of the emergency lighting and fire alarm system.  Provides the maintenance of the malfunctions in the electricity by authorized person. Emergency Response Team (Fire Extinguishing, Search-Rescue-Evacuation and First Aid Team)  The fire extinguishing team will intervene as per the instruction of the team leader if the fire is not severe.  Helps the Operation OHS Expert - to the possible extent - while keeping the vicinity of the emergency area safe until the local emergency organizations arrives at the scene.  Supports the securing-rescue studies of the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) for the personnel and the valuable assets that are in danger.  Coordinates the personnel at the assembly point. If required, provides their evacuation to a safe place.  Provides the securing of the personnel and valuable assets after the emergency is taken under control.  Provides first aid to the injured person to the possible extent until the first aid team, doctor, medical personnel or ambulance arrives.  Provides the transfer of the stretchers and sanitary transport kit, which are placed at central points at the site, to the scene during emergency.  Provides the transfer of the injured person to the ambulance after their transport by stretchers or sanitary transport kit. Administrative Affairs  Contacts the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) as per the information provided by the Emergency Manager.  Organizes the access of the local emergency organizations (fire brigade, ambulance, police, civil defence, etc.) to the scene.  Ensures that the personnel at the offices arrive at the assembly point, counts the personnel and ascertains that no one stayed at the emergency area.  Decides if there are any missing personnel according to the number of personnel coming from the site. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 9 / 23  Ensures that the office buildings are completely evacuated during emergency.  Communicates with the relatives of the affected personnel. Security Personnel  Controls the entry-exit gates of the operation site and only allows the entrance of the local emergency vehicles to the operation site.  Helps the access of the local emergency organizations to the scene.  Helps the organization of the traffic during emergency.  Disallow the entrance to the scene except for the Emergency Response Team. Occupational Physician and Other Medical Personnel  Helps the Emergency Response Team in lifesaving and first aid to the injured person.  Gives urgent medical attention to the injured personnel until health organizations arrive.  Contacts the ambulance or hospital when required and informs Emergency Manager.  Carries out the requisite controls at dining halls, kitchen and food storehouse in mass food poisonings. Site Workers  Arrives at the assembly point and follows the given instructions.  Keep the access roads to the working areas open for emergencies. 3. EMERGENCY RESPONSE For the operation site, occupational accident, landslide, subsidence of excavation, fire, explosion, earthquake, storm, flood, mass food poisoning and incidents concerning the public peace (burglary, sabotage, arson, etc.) and all incidents that would cause panic, disorder and tension at the operation site and among personnel, although not predicted herein, are the incidents when the emergency response will be of concern. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 10 / 23 3.1. Informing the Emergency In case of emergency, witness to the incident should immediately inform the related department by telephone, wireless or verbally. If telephone is to be used, the telephone number of the Emergency Manager listed in the Emergency Communication Numbers hanged at the entry-exit gates of the site shall be dialled. In cases when the informing is to be made verbally, the person will run and notify his superior or an authorized person. The witness should be calm when informing the emergency and the following information should be given explicitly:  Location,  Type of incident,  If an injury is of concern,  Name of informant. Together with informing the emergency, Emergency manager will investigate the emergency, set an order of priority according to the situation, and inform the fire brigade, ambulance and public order team and operation engineers. 3.2. Access to Scene No equipment or goods will be left at the vehicle entry-exit roads, on the stairs, pedestrian walkways and the roads will be open at all times so that the Emergency Response Team (Fire Extinguishing, Securing-Rescue and First Aid) can access the scene shortly and safely in case of emergencies. For the possible blackouts during the emergency, generators with adequate capacity will be reserved. Moreover, emergency access will be provided for all restricted and limited areas where work is going on. No one except for the Emergency Response Teams will be allowed at the scene. 3.3. Evacuation and Assembly Points In case if evacuation is required during emergency, the decision to evacuate will be informed to the site supervisors (site engineer/architect, technician and foreman) by telephone. After notification, the supervisors will be responsible for announcement of the emergency to the workers that they are in charge of and will direct them to the assembly point. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 11 / 23 The works of all teams and equipments will be stopped at the impacted area during emergency. An assembly point will be designated at the operation site at open space and outside the buildings and easily visible signs will hanged at the assembly point. The personnel will be informed during the work initiation training and in case of any change of assembly point. The assembly point of Sanko Energy GEPP Enterprise is located in front of the infirmary at the rear side of Operation ADM building. In case if a danger is of concern at both assembly points or at the routes towards these points, a safe spot will be selected for waiting. In case of an emergency, operation engineers of the department and headworkers will count the personnel and ascertain that no one stayed at the emergency area. The evacuation of the Office region is the responsibility of Administrative Affairs Department. No equipment or goods will be left at the entry-exit roads, passages, on the stairs and pedestrian walkways and the roads will be open at all times so that the personnel can evacuate the area shortly and safely in case of emergencies. Emergency lighting will be placed at the access routes. The site layout plan and pedestrian/vehicle roads will be demonstrated on the central doors. Attention will be paid for the evacuation of the disabled personnel by his/her department. 3.4. Fire Extinguishing The fire extinguishing team will respond, extinguish or take the fire under control using the information of the fire extinguishing training taken previously. When the local fire brigade arrives, the team will help the extinguishing works under the command of the local authority when required. When the fire extinguishing team becomes aware of the fire, the extinguishing works will be commenced if the fire is recently started and if it can be extinguished with the fire extinguishers (or after putting into use, by water extinguisher and hydrant systems) and in cases if the fire is larger, requisite measures will be taken for the fire not to spread and fire brigade will be waited. In the meanwhile, the team members will not endanger themselves or team-mates under no circumstances. The entire team will be under the command of the local fire brigade team and provide their support when needed. When the fire is put out, the team will support the works to be carried out for loss assessment and for detection of the reason of the fire. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 12 / 23 Salihli Fire Brigade that is the closest to the operation site will be contacted and it will be provided that the fire brigade will visit the operation site on a regular basis and be informed about the current state of the operation, the roads and the buildings. Salihli Fire Brigade Directorate Address: ATATÜRK MH. AKHİSAR YOLU NO: 4 PK: 45300 SALİHLİ MANİSA Telephone: 0236 714 11 48 Map View: 3.5. Securing-Rescue Securing-Rescue team will support the local emergency organizations (fire brigade, civil defence, health facilities, etc.) in case of emergencies such as fire, landslide, subsidence of excavation, flood, earthquake, etc. during the rescue and protection efforts for the personnel and valuable assets that are in danger. The team will be selected beforehand and will be informed on the matter. The duties of the securing-rescue team are to ensure the evacuation is carried out without panic in case of emergency, to count the personnel after evacuation to detect the place and location of the person to be rescued and to convey the injuries to the first aid team and the goods to the employer after the incident. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 13 / 23 3.6. Medical Attention The first contacted department in emergencies such as sickness-injury is the first aid team. First aid team will arrive to the scene with first aid kit and stretcher. The first aid treatment of the injured person in case of emergencies will be applied by the certified first aid team with requisite training. The first aid personnel will perform the required immediate medical treatments of the injured person and maintain their health condition until the closest health facility arrives at the scene. In serious injuries, the ambulance service will be notified by phoning 112 and it will be ensured that the injured person will be taken to the closest health facility immediately. Map View: Özel Medigüneş Hospital Address: Zafer Mah., 629. Sk. No: 27, 45300 Salihli/Manisa, Turkey Telephone: +90 236 712 07 12 Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 14 / 23 Özel Salihli Can Hospital Address: Avar Caddesi No: 123 Salihli / MANİSA Telephone: 0 (236) 715 40 00 pbx Özel Salihli Hospital Address: Cumhuriyet Mahallesi, Menderes Cad. No: 48, 45300 Salihli/Manisa, Turkey Telephone: +90 236 713 14 00 Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 15 / 23 Salihli State Hospital Address: Sağlık Mahallesi, Şühada Cad., 45310 Merkez/Salihli/Manisa, Turkey Telephone: +90 236 713 15 00 3.7. Serious Injuries and Loss of Life In case of serious injuries, the immediate response will be performed by the trained and certified personnel, who are competent in first aid. Firstly, the scene will be investigated to secure the entry and the situation will be assessed. Later on, first aid will be applied to the sick or injured person. Unconscious and injured person that fell from heights will not be moved. In case of loss of life, the scene will be surrounded with safety tape and the access to the scene and the impacted area will not be allowed. Afterwards, the police will be informed. Short, brief and accurate information will be given to the police to help during interrogation and inspections. No predictions will be made. Technical and administrative details will only be explained by Emergency Manager. 3.8. Landslide - Subsidence of Excavation In case if the personnel would be trapped under excavated material during the construction activities, local fire brigade, civil defence directorates and medical facilities will be immediately contacted. Against the possibility of continuation of the subsidence of the excavation, it is forbidden to the operation personnel to enter the excavation for rescue. The heavy Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 16 / 23 machinery and equipment at the operation site will not be used for rescue to prevent additional injuries or mortalities. The securing-rescue team will be under the command of the local emergency organizations when they arrive at the scene and provide support when needed. 3.9. Rescue from Height Rescue from height can be required if the personnel would be trapped at the working platforms, at high working areas, scaffolds or in case of fallings. If the personnel could be reached with a safe ladder or similar equipment, he/she can be rescued; otherwise, professional teams will be called for the rescue operation. Furthermore, if risk is not of concern for the injured person or the person in shock (excluding the cases when hanging at the safety belt or got stuck on the platform being collapsed), the emergency response will be performed only by the external rescue teams for the prevention of further injuries of the casualty and rescuers. For similar cases when the operation site means are inadequate, fire brigade will be contacted for the rescue operation. The place and height where the personnel are trapped will be explicitly uttered when informing the rescue team so that the team will provide the proper rescue teams and equipment. 3.10. Mass Food Poisoning Mass food poisoning can be experienced at institutional catering places such as the personnel dining halls and the commissary stores at the social facilities. The symptoms of the poisoning can emerge in the following 2-4 hours after food consumption or in 8-12 hours. In case of food poisoning, Administrative Affairs, Occupational Physician and Kitchen/Dining Hall personnel will carry out the requisite controls at dining halls, kitchen and food storehouse:  How many people are poisoned? To which case it resembles clinically? Which are the suspected food and for what?  What are the menus covering all four meals given to the personnel before the food poisoning?  Which foods can lead to poisoning?  When was the purchase date of the suspicious food and when were they used for cooking? Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 17 / 23  Where and at which temperature was the food stored before consumption?  At which temperature and how long was the food waited?  If the suspicious food is a meat product, was it defrosted in proper conditions?  Are there any leftovers from the suspicious food?  If any food product was thrown away or considered suspicious recently? After the initial inspection, the samples from the past four meals will be sent to the laboratory for analysis and the results of the analysis will be presented to the Emergency Manager. After the poisoning is taken under control, an incident assessment report will be prepared and the measures required to be taken for the incident not to happen again will be determined. 3.11. Earthquake Instant earthquakes that can happen without any warning can give serious damage to the buildings that are still being constructed or the completed ones, heavy machinery and the structures at the operation site, public services and the communication and they can lead to landslides and fires. Requisite measures should be taken at the operation site to minimize the earthquake related risks:  The lockers and similar furniture that can fall over at the operation facilities (offices, dining halls, storehouses, WCs, etc.) should be fixed to each other and to the wall or floor. Lower furniture should be preferred instead of furniture reaching the ceiling.  The lighting armature, air conditioners, ceiling and others that are hanged to the ceiling and the walls temporarily should be fixed in a way that they can sustain their weight.  Heavy goods should not be placed at high places at the operation facilities (offices, dining halls, storehouses, WCs, etc.). Anti-slip ground covers should be placed to prevent the slip and falling of the goods and materials if it is unavoidable to place.  The objects that can fall or leak should not be placed to the corners of the floor slabs, shafts and spaces at the work area. Huge and heavy equipment should be fixed to the floor or wall.  Earthquake related risks should be considered during installation of critical systems (electricity, pressure pipes and tanks, fire and cooling water systems, Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 18 / 23 hydraulic lines, etc.) and the communication network that can cause emergencies indirectly. The response operation will be started after the earthquake and Emergency Manager will decide on whether an evacuation is required or not. If evacuation is required, the alarm will be raised or all personnel will be notified by a megaphone and the personnel will gather at the points that are designated earlier. After the counting that will be performed on department basis and the evacuation of the personnel, the damage at the operation will be determined and maintenance works will be performed within the bounds of possibility. Before the commissioning of the activities at the operation site, the equipment such as scaffolds, working platforms, cranes, etc. and all facilities including the entire working area will be inspected. After the inspection, the decision of the Emergency Manager will be awaited. 3.12. Chemical Leakage The following tools and equipment will be kept available to respond the leakage of the oil, grease, liquid chemical, etc. at the operation site:  Personal protective equipment such as gloves, respirator, work shoes and protective clothing against chemicals,  Barriers or sand bags to prevent the spread of the leakage,  Fine saw dust, sand, absorbing pillows or other absorbing material to remove the leaking chemical,  Pump to remove vast amount of leaking substance inside ditches or pits. The methods of response to the chemical leakage vary depending on the structure and amount of the leaking substance. Therefore, the type (solvents, gasoline and similar combustible/flammable, abrasive, toxic, explosive chemicals that are stored collectively) and amount of chemicals at the construction site will be determined. Material Safety Data Sheet (Safety Data Sheet - SDS) and labels will be used when determining the dangers/risks of each chemical. In case of leakage, the impacted area will be isolated and no one except for the response team using the proper personnel protective equipment will be allowed to enter. Depending on the leaking substance, the control of the spillage will be carried out by cutting-off the valves, lowering of the pressure of the tanks, transfer of the product, repair or plugging the source of leakage or absorbing the leaking substance, usage of absorbing materials for removal. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 19 / 23 In case of chemical leakage, the Emergency Manager will decide on the need for providing emergency response from the external organizations (fire brigade, provincial directorates of Ministry of Forest and Water Management and the Ministry of environment and Urbanization, etc.) depending on the character, volume of the leaking substance, to where the substance leaked (for example, floor, soil or drains) and the magnitude of the impact. 3.12.1. Pentane Leakage The leakage will be cut at its source. The spread of the leakage will be prevented. Its vapour /aerosols will not be inhaled. Ignition sources will be removed. Its entry to the sewage system will be prevented. Water spray will be used to decrease the explosive vapour. The chemical will be removed by liquid absorbing substance (for example, Chemizorb) and will be sent for disposal. The impacted area will be cleaned. If the leakage is indoors, supply-air mask will be used. Support will be sought from local fire brigade. 3.13. Events (Terror / Protest / Strike, etc.) Anarchy events such as bomb threats, sabotage-arson, burglary and strike happen without forewarning and seriously threaten the safety of the workers. In case of any security threat such as an anarchic problem or attack, the local police/gendarme will be immediately notified. Handling of the violent personnel will not be undertaken by anybody including the security guards until the police/gendarme arrives. The following steps will be followed in case of any treat phones to the enterprise:  The person answering the telephone should remain calm and get as much information as possible.  The collected information should be written down.  After a threat and annoying telephone, the person who answers the phone will immediately notify the Emergency Manager. This conversation should not be shared with anyone unless instructed by the Emergency Manager.  Emergency Manager should contact the police/gendarme. 3.14. Weather Conditions Emergencies that can affect the operation depending on the weather conditions are hurricane or typhoon, tornado or severe storms. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 20 / 23 The auditory, printed and mass media should be followed for the warnings against hurricane, typhoon or tornado risks at the region of the enterprise and local weather station (meteorological) should be kept in touch. All personnel should be notified in line with the warning. In case of evacuation decision, the operation personnel should leave the working areas and go to a safe area. Emergency Manager will determine the safe areas of the operation, preferably under original ground level. These areas will be small rooms or corridors at the ground floor away from the gates and windows and the rooms with brick or concrete walls and ground. Conference rooms, cafeterias or large rooms with flat wide ceilings and light modular offices and modular houses are not considered as safe. After emergency, damage will be determined and requisite repairs will be performed. 3.15. Floods The floods that are among the common natural disasters can be experienced after the sudden melt down of snow, torrents and severe storms. Although the flood risk is low given that the operation site is at a distance from the water sources, rivers or dams and located at high ground, the auditory, printed and mass media should be followed for the warnings against flood at the region of the enterprise. The water drainage system will be considered while establishing the operation and structural alterations, the expensive systems and equipment will not be placed at lower elevations. The personnel working at or under the original ground level during flood will go to higher floors or higher grounds using the emergency evacuation roads. After receding of the water level, damage assessment of the corporate assets will be carried out. The excavations that are exposed to the flood are rather unstable. Therefore, the ground conditions will be inspected before working at an excavation and the work will start afterwards. 3.16. Emergency Recording and Reporting The operations related with the emergency will be verbally reported to the Emergency Manager and Operation OHS Expert. After the emergency is gotten under control and obviated in the consequence of the operations, Operation OHS Expert and Emergency Manager will arrive at the scene and detect and put the following in written record:  Place of emergency, Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 21 / 23  Date, hour and duration of emergency,  Description of the emergency,  Impact of the emergency (damage on personnel and tangible asset),  Measures to be taken and operations to be performed to continue the work,  Responsible of the measures and operations. 3.17. Return to Work after Emergency Operation OHS Expert will inspect in-situ whether the determined operations are performed and measures are taken before return to and start of work. After the verification by the Operation OHS Expert that the defined operations and measures are completely fulfilled, return to work will be allowed by the decision of Operation Manager. After the start of work, Operation OHS Expert will keep a close watch on the related activity area according to the significance and severity of the detected emergency and verify the effectiveness and adequacy of the defined preventive measures. 4. ASSESSMENT OF EFFICIENCY OF OPERATION EMERGENCY PLAN AND ITS SUSTAINABILITY 4.1. Drills Drills will be conducted every 6 months to rate the efficiency of the Operation Emergency Plan. The duties and responsibilities will be reminded to the persons before the drills. The drills will be conducted without notice and the response times will be monitored and recorded. If the Operation Emergency Plan could be followed effectively during the drill, the plan will be revised. After the drill,  Trainings will be organized to resolve the faults in the behaviours of the persons,  Inconveniences, if any, will be corrected via requisite instructions,  Plan will be revised considering the suggestions of the Operation OHS Expert if any deficiency is of concern. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 22 / 23 4.2. Trainings After organizing the emergency response team, they will be trained about the content of the Operation Emergency Plan and the responsibilities will be explained to the team members in case of emergencies. The team will get refresher trainings every six months in all cases. Training label will be given to the emergency response team after the training for them to place on their helmets. 4.3. Accident-Incident Reporting and Inspection All encountered emergencies will be recorded and reported. After any accident or incident is experienced and gotten under control, accident- incident inspection process will be started. The reasons for every reported incident will be investigated and the corrective and preventive actions will be started to eliminate the detected reasons. The statistics and risk assessments from the accident-incident reporting will be used to develop a proactive approach. 4.4. Emergency Tools and Equipment Fire  The controls of the fire extinguishing equipment (fire extinguishers, hydrant system, etc.) will be performed monthly and the results of the control will be recorded.  Fire extinguishers will be placed at every location where hot works are being performed and also fire panels will be placed at the central locations of the operation site. The tools on the fire panel will not be used for other purposes.  Fire extinguishers will be found at the heavy machineries and they will be checked monthly. First Aid  The control of the firs aid kits at the offices and on site and the stretchers at the infirmary will be carried out regularly by OHS personnel and support members, they will be easily accessible and signs showing their locations will be placed. Document Code SE.P01.PL03 SANKO GEPP First Publication Date 06.12.2017 Revision No 0 EMERGENCY PLAN Revision Date Page No 23 / 23 5. APPENDICES Appendix.1 List of Emergency Team Appendix.2 Information on Emergency Communication Appendix.3 Emergency Layout Plan Date: 19.12.2017 Date: 19.12.2017 Date: 19.12.2017 Date: 19.12.2017 SANKO ENERGY GEPP SANKO ENERGY GEPP SANKO ENERGY GEPP SANKO ENERGY GEPP Rev: 0 Rev: 0 Rev: 0 Rev: 0 Visitor Security Card Visitor Security Card Visitor Security Card Visitor Security Card No: No: No: No: Dear Visitor, welcome to Sanko Energy Geothermal Energy • The visitors should use the following personnel protective • In case of any accident to which you are involved or Power Plant … equipment at all times at the process area of the power witnessed or in case if you witness any situation or plant. behaviour that is against the Occupational Health and The approach of SANKO Energy to Occupational Health and Safety during your visit at the power plant, please do Safety follows the philosophy ‘’Best Method is the Safe inform the Operation Occupational Safety Expert. Method”. • Pay regard to all warning signs at the operation site and Our target is zero occupational-work accident. We believe follow the rules. that all accidents are preventable.  Helmet: EN 397  Protective Glasses: EN 166  Earphones: EN 352  Isolated Work Shoes: EN 345 High Voltage Head Bump Danger  High visibility vest • Moreover, additional personnel protective equipment can be asked to be used depending on the section visited at the process area of the power plant or on the ongoing activity. Pressure Vessels No Trespassing Established Capacity 15 MW • Special permit and equipment are required to enter the Annual energy Generation 110 Million kWh switchyard, turbine floors, tunnels and OG Panel Rooms at Start Date of Project April 2017 Construction the operation area. Date of Commissioning October 2017 • Be cautious against the moved, transported, stored goods during your visit. Do not pass under, beside the goods or • The visitors cannot enter the process site before possible damage zones of falling. Rotating Parts Danger of Falling participating the operation orientation training. • Do not stand at the route and working zone of the moving • It is forbidden to work for the persons coming to the lifting, hauling, loading, unloading vehicles (forklift, truck, power plant for visit. etc.) at the operation site. Name/Surname: • It is forbidden for the persons under the influence of • Follow the safety instructions taken against the use and alcohol and drugs to enter the operation site. Company: storage of the chemical substances at the operation site. Explosive Environment No Smoking • It is forbidden to enter the operation site with a gun. The Avoid intentional or unintentional contact with the Visit Date: visitors in possession of a gun should leave their gun chemicals. Immediately get in touch with the authorized security department. personnel in case of any contact with any substance. • Do not smoke at the operation site except for the points Signature: Proceed in line with the Material Safety Data Sheets. designated for smoking. • The visitor shall be accompanied with a person from the occupational safety expert and responsible team from the • A siren will sound in case of emergency • The speed limit at the operation site is 20 km/h. Follow the visited department throughout the entire time at the and all visitors shall gather at the traffic rules at the operation site. power plant. Please proceed in line with the information Assembly Point and shall proceed given by the companion. according to the instructions of the responsible at that point. The assembly point at the power plant is IN FRONT OF INFIRMARY OF ADM BUILDING. SANKO GEOTHERMAL POWER PROJECT OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN Revision Version Date Prepared by Checked by Approved by Muhsin Dervişoğulları Yener Esen Project Manager Environmental Manager OHS Manager January 10, 2018 Draft A.0 Revision Codes: A: Draft, B: Final Draft, C: Final January 2018 SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 2 / 29 ABBREVIATIONS PROJECT Sanko Geothermal Power Plant Project PROJECT OWNER Sanko Energy Industry and Trade Co. AoI Area of Influence CO2 Carbon Dioxide GPP Geothermal Power Plant EA Environmental Assessment EHS Environment, Health and Safety EIA Environmental Impact Assessment EMF Electromagnetic Field EPRP Emergency Preparedness and Response Plan EU European Union H2S Hydrogen Sulphide H&S Health and Safety IFC International Finance Corporation ISO International Standards Organization MEWP Mobile Elevated Work Platform MoEU Ministry of Environment and Urbanization NGO Non-Governmental Organization NCG Non-Condensable Gas OHS Occupational Health and Safety OSHAS 18001 Occupational Safety, Health Assurance System PPE Personal Protective Equipment PS Performance Standards PTW Permit to Work QMS Quality Management System TSA Task Safety Awareness SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 3 / 29 1 DESCRIPTION OF PROJECT This document is the Occupational Health and safety Plan (OHSP) for ‘Sanko Geothermal Power Plant Project’ (herein after ‘the Project’). It is prepared by “Sanko Energy” -the Project Company). Sanko Energy, an energy branch of Sanko Holding Group planned to develop Sanko Geothermal Power Project with capacity of 15 MW in Manisa, Salihli District, Yılmaz Neighbourhood. Sanko Energy projects the potential expansion of the Project to achieve a total capacity of 50 MW. Therefore, additional wells are planned to be established within the license area of the Project. 2 PURPOSE AND SCOPE The purpose of this H&S Plan is to provide instruction and guidance to the, Project Management Team (both Operation and Site based personnel), Project Personnel and Sanko’s Contractors. This H&S plan outlines the organization and arrangements for managing H&S on the Project for the operation and construction phase incorporating activities within the İstanbul, Ankara Offices and Sanko GPP Site. The implementation of the various elements contained in the plan requires prioritization and schedule of events produced that defines the H&S deliverables. The purpose of this document is to demonstrate the provisions in respect of the following matters:  the identification of hazards by employers and the elimination or control of risks at employers’ places of work,  particular risk control measures (including provisions regarding lighting, noise, atmosphere, electricity, confined spaces and manual handling),  the manufacture and supply of hazardous substances for use at places of work and the use of hazardous substances at places of work,  the regulation of hazardous processes at places of work (including such processes as spray painting, abrasive blasting, welding etc.),  the regulation of construction work (including excavation work, demolition work etc.),  the regulation of operation work,  the notification of accidents and other matters. The scope of this document is to:  Transfer ownership and approval of the program at the appropriate level and to ensure that the Project Management is fully aware of the contents of this plan and the deliverables established against it, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 4 / 29  Inform all Project and other interested parties of the steps and intentions the Project intend to implement to achieve the objectives of the Health & Safety program and of its contractual obligations,  To inform Contractors of the contents of this H&S Plan and to gain their support in achieving its objectives. The objective of the H&S Plan and program are:  To create a cultural and step change environment of well informed and motivated people who will actively participate and share the belief that “Delivery of Safe Construction and Operation, is our only Objective”,  Provide a continuous H&S training regime for: o Project Personnel, o Contractors Management and Supervision,  Develop Sanko’s Contractors Workforce H&S Training Programme,  Develop and maintain an H&S Audit and Inspection Programme,  Provide a Risk Management Programme. 2.1 PROJECT COMMITMENT STATEMENT The project objective is to guarantee the success of the Project by unrelenting promotion of a Preventative HS&E Culture between the Project Team, Operators and Contractors. Project key management staff such that Cost and Time constraints will be demoted as secondary considerations in order to realize commitment to ensure:  NO harm to any Person,  NO damage to Property or the Environment. 2.2 PROJECT HEALTH, SAFETY & ENVIRONMENTAL POLICY AND PRINCIPLES Policy Statement In order to ensure work safety and protect health of Sanko’s employees, who are Sanko’s most valuable internal resource, and to minimize adverse effects on environment while offering high-quality projects meeting the expectations of Sanko’s customers, we will carry out Sanko’s operations by:  Acting in compliance with all the applicable laws and regulations,  Implementing training programs needed to enable the employees to familiarize themselves with the systems in those fields, and to improve their sense of responsibility and consciousness and to ensure continuous improvement,  Achieve the target of "Accident, Injury Free" by eliminating the risks at their sources with the involvement of all employees,  Ensuring that practicable precautions that would safeguard environment and prevent environmental pollution are taken during all phases of the process of designing or developing projects in cooperation with other firms and contractors. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 5 / 29 Principles The following principles will govern all Project practices: Accountability: Management will take a leadership role in identifying and eliminating Health, Safety and Environmental risks and promoting safer ways of working; whoever, it is the responsibility of every Project employee to work together to carry out Health and Safety (H&S) policy and principles. Health and Safety: Sanko will provide and promote a safe and healthy environment for It’s employees and contractors. H&S Integration into Business: Project will integrate, health, safety and environmental policy, principles, regulatory requirements and internal standards into It’s business processes and services. H&S aspects will be integrated into all investment decisions. Communication: Project will openly communicate health, safety and environmental objectives and performance to employees and to the public. Sanko will establish H&S goals and objectives designed to achieve industry leadership within the Project. Education and Training: Project will provide effective education and training, which is critical to successful H&S performance. Pollution Prevention: Project believes that sustainable growth, including cost-effective pollution prevention, and the efficient and responsible use of natural resources, is essential to the long-term success of It’s business. Sanko will continuously strive to reduce energy consumption. Commitment: Project will comply with H&S laws, regulations and internal standards. Sanko will establish and implement programs and procedures in order to conduct operations safely and in an environmentally responsible manner. Sanko will participate in the development of H&S laws, regulations, and Project policies and will support Project efforts that represent a reasonable balance of risk and benefit. Organization: Project will provide the resources to maintain an organization, which fosters continuous improvement in H&S performance. Participation: Recognizing that Sanko’s employees are it’s most important recherché, Project will strive to enlist their knowledge, dedication, and skill in formulating and achieving H&S goals and objectives. Sanko will work with It’s employees to foster effective mechanisms for employee participation. 2.3 GETTING HSE RIGHTS Leadership and Accountability People at all levels in the Sanko organisation are responsible for leading and engaging the workforce in meeting their health, safety, technical integrity and environmental goals and objectives. Leaders will be held accountable for accomplishing this by demonstrating correct SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 6 / 29 H&S behaviours, by clearly defining H&S roles and responsibilities, by providing needed resources, and by measuring, reviewing and continuously improving It’s H&S performance. Risk Assessment and Management Management of risk is a continuous process and the cornerstone of all the HS&E elements. Sanko will regularly identify the hazards and assess the risks associated with It’s activities. Sanko will take appropriate action to manage the risks and hence prevent or reduce the impact of potential accidents or incidents. People, Training and Behaviors People’s behaviour is critical to Sanko’s success; therefore, Sanko’s workforce will be carefully selected and trained, and their skills and competencies regularly assessed. Working with Contractors and Others Contractors, suppliers and others are key to Sanko’s business performance and Sanko will assess their capabilities and competencies to perform work on Sanko’s behalf. Sanko will work together with them to ensure It’s HS&E Expectations are aligned. Sanko will monitor Contractors’ and Partners’ performance and ensure its procurement processes contain the mechanism to deliver It’s Expectations. Facilities Design and Construction New facilities and modifications to existing facilities will be designed, procured, constructed and commissioned to enable safe, secure, healthy and environmentally sound performance throughout their operational life, by using recognized standards, procedures and management systems. Operations and Maintenance Facilities will be operated and maintained within the current design envelope to ensure safe, secure, healthy and environmentally sound performance. Management of Change All temporary and permanent changes to organization, personnel, systems, procedures, equipment, products, materials or substances will be evaluated and managed to ensure that health, safety and environmental risks arising from these changes remain at an acceptable level. Sanko will comply with changes to laws and regulations and take account of new scientific evidence relating to HS&E effects. Information and Documentation Sanko will maintain accurate information on It’s operations and products. It will be held securely yet readily available. Community and Stakeholder Awareness SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 7 / 29 Sanko value the importance of community awareness and will actively engage in dialogue with various stakeholders to maintain public confidence in the integrity of It’s operations and products and It’s Commitment to HS&E Performance. Crisis and Emergency Management Emergency response plan will be maintained to cover all of Sanko’s facilities and locations. This plan will identify equipment, training and personnel necessary to protect the workforce, public, environment and Sanko’s reputation in the event of an incident. Incidents Analysis and Prevention Incidents will be reported, investigated and analyzed to prevent recurrence and improve Sanko’s performance. Sanko’s investigations will focus on root causes and/or system failures. Corrective actions and preventive measures will be utilized to reduce future injuries and losses. Assessment, Assurance and Improvement Sanko will periodically assess the implementation of and compliance with these Expectations to assure stakeholders and Sanko that management processes are in place and working effectively. This will involve both internal self-assessments and appropriate external assessments. Sanko will use this information to improve its performance and processes. Note: Addressing the full set of HS&E Expectations is mandatory for every activity across the entire Sanko organization. Managers are accountable for putting in place appropriate documented systems and processes for each Expectation, for ensuring continuous improvement towards Sanko’s HS&E goals and targets, and for confirming that these are effective via the H&S Assurance process. In order for the Project to meet these expectations a number of systems and activities will need to be implemented. The means by which the Project will achieve the above principles and elements are set out in this Project H&S Plan. The Project H&S Plan is the key Project H&S guidance document, evolved as a result of the interpretation of agreed legislative and “Best Practice” requirements. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 8 / 29 3 KEY ROLES & RESPONSIBILITIES 3.1 OPERATIONAL MANAGER Reports to the Project Management, and will have the following responsibilities:  Active participation in the implementation of the safety program (e.g., audits, safety committees, training etc.),  Participate as a member of the Accident Investigation Team for medium and high severity and high potential incidents.  Will ensure that line management and supervisors participate, contribute actively and exercise leadership in their respective individual and collective project HSE meetings,  Carry out audit reviews of the areas under his control with the HSE Team,  On commencement of the permit to work system (where applicable) will act as area authority for the work,  Will co-ordinate with the HSE Team and facilitate the site HSE meetings on two weeks basis, 3.2 COMPANY MAN Reports to the Project Management, and will have the following responsibilities:  Active participation in the implementation of the safety program (e.g., audits, safety committees, training etc.),  Participate as a member of the Accident Investigation Team for medium and high severity and high potential incidents.  Will ensure that line management and supervisors participate, contribute actively and exercise leadership in their respective individual and collective project HSE meetings,  Carry out audit reviews of the areas under his control with the HSE Team,  On commencement of the permit to work system (where applicable) will act as area authority for the work,  Will co-ordinate with the HSE Team and facilitate the site HSE meetings on two weeks basis,  Ensure that all contractors at the site are aware and trained in the HSE requirements of the Project,  Actively participate in Camp and Office inspections,  Provide liaison between Project and the contractors. 3.3 HEALTH, SAFETY COORDINATOR The HS Coordinator reports to the Project Management, and has responsibility for the following:  Reporting of status of the Project to the Project Management,  Integrating a HS team,  Audit the HS Teams and their roles at the work site,  Involvement in the approval of design changes after the start of construction, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 9 / 29  Ensure that required training is being performed,  Provide liaison between Project and Project Management about HS,  Be fully conversant with the leadership, objectives and expectations of the Project,  Will ‘drive’ the ‘Step Change’ and behavioural development, necessary to achieve a ‘World Class’ safety performance. 3.4 HS LEAD ENGINEER, INSPECTOR The assigned HS Lead Engineer reports to HS Coordinator. He has the following responsibilities:  Provide HS Administrative support for the HS Coordinator,  Deputies for HS Coordinator in his absence,  Assist in the tracking of action items,  Develop core HS Strategies, Procedures, Instructions etc.  Prepare the Project HS Plans and Procedures,  Effectively manage the safety personnel under his control and provide appropriate direction and training as required optimizing their effectiveness on site,  Implement a training program that addresses the requirements of Prime Rules established for the Project along with site specific skill training,  Review the results of inspections of the site to identify safety issues and deficiencies,  Co-ordinate the investigation of any incident,  Identify any trends relevant to incident investigations that become apparent and to ensure that remedial actions have been agreed and corrective action performed and recorded,  To liaise with the Site Engineers to ensure that he is involved and kept informed of all site activities,  Create and implement any procedures that are required,  Monitor the performance of the HS programme and initiatives introduced throughout the Project,  Monitor the performance of HS Representatives of Contractors on site. 3.5 DOCTOR The assigned Doctor reports to the H&S Lead Engineer and has responsibility for the following:  Perform / Update assessments of health risks,  Identify any trends relevant to incident investigations that become apparent and to ensure that remedial actions have been agreed and corrective action performed and recorded,  Effectively manage the health personnel under his control and provide appropriate direction and training as required optimizing their effectiveness on site,  Review the results of inspections of the site to identify health or medical issues and deficiencies, and to advise the Site Manager and HS Lead Engineer of findings, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 10 / 29  Supervise all health related issues in relevance with contractors,  Monitor and track all personnel Health and Medical issues during the define stages for Sanko associated with the Project. 3.6 PROJECT ENGINEERS Reporting to the Opertional Manager or Company Man according to the postion, they will have the following responsibilities:  Will set a personal example and assist in the proactive promotion of safety as a personal objective,  Overall co-ordination of the disciplines and areas under their control with a view to eliminating any interface problems,  Review all method statements and risk assessments as produced for the safe execution of the work,  Attend Progress Meetings (on two weeks basis) and ensure that health and safety is being addressed for work in progress and for work being planned,  Participation in the investigation of any incidents that result in serious property damage or high potential Near Misses occurring in areas under their control,  Actively participate in all H&S awareness training and safety initiatives,  Review workforce acknowledgement of work or workfaces they believe as being ‘at risk’ or ‘unsafe’,  Be fully conversant with Project Prime Rules of Safety,  Note: the above responsibilities will also be fully adopted by all contractors personnel at site. 3.7 EMPLOYEES (SANKO & CONTRACTOR PERSONNEL) Employees will be responsible for:  Learning, understanding and complying with all HS procedures, rules and practice which are applicable to their conduct at all times whether at or away from the workplace,  Employees are responsible for their personal safety and the safety of their co- workers, through both their acts or their omissions,  Be constantly aware of their work situation and report hazardous situations to their supervisors, stopping work and informing their immediate supervision if there is the potential for any harm,  Comply with all health and safety requirements, practices and other initiatives at all times,  Use and maintain the appropriate supplied Personal Protective Equipment, reporting all deficiencies and replacing as necessary,  Reporting substandard procedures or conditions to their immediate supervisor, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 11 / 29  Understand that any employee who jeopardizes their safety and health and /or the safety and health of others will be subject to disciplinary action (including immediate termination of employment),  Working in a safe manner at all times.  Stopping their immediate or impinging work where they consider the work being performed is ‘at risk’ or ‘unsafe’. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 12 / 29 4 PROJECT H&S MANAGEMENT SYSTEM The Project H&S Plan is an integral part of the H&S Management System that is based on the OHSAS 18001- Occupational Health and Safety Management System. The essence of the drilling, construction and operation phase is the setting of objectives based on project policy which contain these aspects. H&S significant aspects and applicable regulatory requirements will be matched by a corresponding objective. 4.1 GENERAL REQUIREMENTS The H&S Team in conjunction with the Project have developed, implemented and maintained an H&S Management System. Within the H&S Management System, supporting procedures and instructions have been developed, many of which apply to this Project. These supporting procedures and instructions will be adhered and referred to, during the drilling, construction and operation phases and its associated activities. The H&S Management system has been designed to ensure the successful delivery of Sanko’s H&S commitment, expectations and legal compliance. Personnel at all levels in the organization are responsible for achieving the Project H&S objectives; this requires clear communication between Project personnel, contractors and others. Through this structured H&S Management system, specific roles and responsibilities associated with Sanko’s objectives have been identified. Reviews will be undertaken periodically of objectives requirements that may lead to revision of the system, its components and associated personnel responsibilities. The responsibilities and job descriptions of project personnel having been defined will be communicated to those personnel to ensure they are fully aware of these requirements. Management have and will further ensure that competent personnel fill key positions in the project organization to aid development and implementation of positive H&S behaviour to achieve success with regard to the expectations and objectives at all levels. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 13 / 29 5 PROJECT H&S STANDARDS H&S expectations will be incorporated into business planning and decision-making processes such that they become a transparent and effective management measurement tool of the Project’s success. The Project H&S team will identify the regulatory requirements that apply to the H&S aspects of the Project. The requirements include relevant provisions of:  Legislation (both Turkish and International requirements),  Codes,  Standards and guidelines. Regulatory requirements include (as they apply to the project):  The requirements of the National laws of Turkey,  National and local guidelines supporting the Laws of Turkey,  Specific requirements of the regulators of Turkey,  International protocols ratified by Turkey,  The requirements of project financiers and insurers, Project Management will ensure that those responsible for H&S implementation and management have access to the relevant necessary information. The applicable legislation etc. will be recorded in a Regulatory Requirements Register. This will show, for each regulatory requirement:  Type of regulation, e.g. statute, guideline, code of practice,  Applicability: International; National; Regional; Local,  Title, number and edition/ issue of regulation,  Project activities or programmes to which it is applicable,  Forward reference to corresponding Objectives. The Register will be compiled with applicable reference to:  Project design basis documentation,  Turkish National H&S (Labor and Other relevant Laws / guidelines), Project objectives will be set to ensure compliance with the applicable laws, regulations, government agreements, permits, project policies and procedures. The objectives will be based on the edition or issue of the regulation that is current at the time the relevant activity is carried out, they will only refer to a future regulation if the regulation is in its final form and there is a clear timetable for its implementation, during the planned life cycle of the project. 5.1 EXPECTATIONS & OBJECTIVES General SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 14 / 29 The Project Management and HSE Teams, in accordance with the following drivers, set project H&S Expectations and Objectives:  High level requirements,  Regulatory requirements,  Identified significant H&S aspects. Objectives for each of the above requirements will be developed. Where the necessities of different requirements are similar, one will take precedence to avoid duplication. Setting H&S Objectives At each phase of the Project, the HS Lead Engineer will conduct an Objectives review with appropriate disciplines. The outcome of the review will be a set of confirmed H&S objectives. 5.2 KEY PROJECT INITIATIVES Project will provide the following:  This specific H&S Plan,  Clearly defined roles and responsibilities for H&S personnel,  Training of Project Personnel,  Safety Inspection / Audit,  Risk Assessment Plan,  Emergency Response Plan, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 15 / 29 6 CONTRACTOR SELECTION Sanko has developed a contractor selection process to ensure that H&S was addressed as part of the selection process, particularly reflecting their ability to do the work, and on their competence to conduct the work safely. To aid the selection and future processes, the contractors has been required to conform issues stated in this document. Minimum requirements include adopting and following Sanko H&S Plan and cover:  Organization Charts showing Accountabilities and lines of Reporting,  Nomination of a Competent H&S Representative and his support team,  Contractual obligations to perform the work safety and in accord with the site regulations. Contractors will ensure that their Project H&S requirements are fully communicated to, and appreciated by, their team as part of their selection process. Furthermore they will ensure that:  Contractors, the self-employed and designers to be appointed are competent,  Suppliers of materials to Sanko will provide adequate health and safety information to support their products,  Machinery and other plant supplied for use will be properly selected, used and maintained. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 16 / 29 7 COMMUNICATIONS 7.1 PROGRESS MEETINGS H&S will be the first an agenda item of site progress meetings (on two weeks basis). Safety issues covered will not only include immediate areas of concern but will also address near future work and the methods of / ‘work packs’ for carrying out such work safely. PTW requirements for the following month will also be discussed to ensure timely completion in readiness for the next month’s activities. Agenda items for health and safety will include:  H&S Expectations Objectives,  Key Performance Indicators,  H&S roles and responsibilities,  H&S Contractual requirements – Docs, reporting etc.  H&S plans for contractors,  Joint task risk assessments covering the scope of work,  Vehicle safety systems,  Crisis and emergency management (emergency response plan and bridging document),  Communications protocol (equipment and process),  Incident reporting, Investigation, analysis and prevention systems,  Security arrangements and procedures. 7.2 SAFETY & SAFETY RELATED NOTICE BOARDS Sanko HS Lead Engineer on site will arrange for H&S Notice Boards to be erected in a prominent position at the power plant site, site office(s) and accommodation. The Notice boards will be used for the communication of safety awareness bulletins, current safety issues etc. 7.3 SAFETY TALKS The function of safety talk is to communicate relevant issues in a simplified manner, emphasizing awareness of H&S or other pertinent values. When conducted in the correct manner using clear communication and two-way understanding enables “on the spot” transfer of sound preventative information and knowledge learning. Safety talks, either respective to the task, the work environment or some other H&S awareness topic will be communicated to the workforce, before starting any work – Note: this applies to all personnel below the level of Operational Manager and Company Man. Safety talks will be conducted by Supervisors / Foremen / Functional Managers of all personnel. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 17 / 29 Sanko H&S Lead Engineer at site will develop with the Supervision; Safety talks, specific to the tasks and environment in which they are conducted. 7.4 POST TASK BRIEFING At the work face, it is often the case that improvements can be identified, to the way in which the previously conducted work was accomplished. Supervision will take adequate time to address these issues following the ‘clean up’ housekeeping task and before or following leaving the workface. Any improvements identified will be discussed with the management team to ensure compliance with the aspect of ‘management of change’ before changes are made. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 18 / 29 8 HAZARD AND RISK INFORMATION 8.1 DRILLING HEALTH & SAFETY HAZARDS & RISK Throughout the Drilling phase of the project, specific Risk assessments will be held to identify risks associated with the Well Design and the Management of Change, key personnel from the project team will attend and provide input relating to hazards and risks associated with the project. To support this function personnel attending will be encouraged to assess potential severity, probability and likelihood of occurrence. Hazards will always be prevalent in virtually all drilling activities. These hazards and the associated risks will be assessed in terms of their severity, probability and consequence, to ensure that Sanko identify appropriate controls for the work. 8.2 CONSTRUCTION HEALTH & SAFETY HAZARDS & RISK Throughout the Construction phase of the project, specific Risk assessments will be held to identify risks associated with the Construction Design and the Management of Change, key personnel from the project team will attend and provide input relating to hazards and risks associated with the project. To support this function personnel attending will be encouraged to assess potential severity, probability and likelihood of occurrence. Hazards will always be prevalent in virtually all construction activities (that is one of the major factors that contribute to the industries high Incidence rate). These hazards and the associated risks will be assessed in terms of their severity, probability and consequence, to ensure that Sanko identify appropriate controls for the work. 8.3 OPERATIONAL HEALTH & SAFETY HAZARDS & RISK Throughout the Operation phase of the project, specific Risk assessments will be held to identify risks associated with the Management of Change, key personnel from the project team will attend and provide input relating to hazards and risks associated with the project. To support this function personnel attending will be encouraged to assess potential severity, probability and likelihood of occurrence. Hazards will always be prevalent in virtually all operational. These hazards and the associated risks will be assessed in terms of their severity, probability and consequence, to ensure that Sanko identify appropriate controls for the work. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 19 / 29 9 H&S MANAGEMENT FUNCTIONS 9.1 H&S AUDITING & REVIEW Safety reviews will be performed as follows: Audits The audit schedule and process will be developed to assess H&S compliance of procedures and policies in place, their implementation in the field and to provide an assurance that they are being effectively communicated, understood and implemented by the workforce. These audits will be structured to measure the implementation of the policies and procedures in place in terms of their effectiveness and implementation and will create a profile, which highlights the areas that need attention/improvement, thus establishing a baseline for continuous improvement objectives. H&S Audit & Review Programme will comprise the following:  Internal – Power Plant and Site Audits,  Management - Power Plant and Site Audits,  Management Review,  Site Inspections. Inspections A schedule of inspections will be conducted to review drilling, construction and operation site status and conditions. These inspections could be carried out by Project Management, HS Coordinator, HS Lead Engineer, HS Inspector, field supervision / foremen. Progress meetings will be conducted at site on two weeks basis. At the meetings, the inspection results will be discussed and where applicable follow-up actions and responsibilities will be assigned. Reporting and Record Keeping The results of inspections conducted by the HS Responsible of the Contractors will be reported to HS Lead Engineer on weekly basis. The signed reports will be kept on Sanko project office on site. The weekly reports from contractors will be compiled by HS Lead Engineer and reported to HS Coordinator on weekly basis. HS inspection, findings and results related with the Project activities will be reported to Project Management by HS Coordinator on two weeks basis. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 20 / 29 10 CRISIS MANAGEMENT & EMERGENCY RESPONSE 10.1 POLICY STATEMENT It is the policy of the Project to protect its assets, accurate records and employees from threats that could damage its business. Managers are held accountable for the continuation of Project business in line with both legal and Project requirements. 10.2 RECOVERY OBJECTIVES  To ensure that the Project can continue to carry out the key support and administrative functions following a disaster or any serious incident,  To ensure that any interruption at any Project site or office does not result in a significant loss to its overall performance. 10.3 DISASTER SCENARIOS Potential events that could impact Project related activities or assets range from major physical incidents such as fire, to failure of significant computer or communications systems. These are shown below:  Fire,  Explosion (accident or terrorist),  Earthquake  Flood (natural and accident),  Weather impact,  Criminal, sabotage or arson attack,  Interruption to utilities supplies (gas, water, electricity),  Interruption to telecommunications system,  Access roads closed. A Risk Assessment approach was taken to consider the "Worse-Case Scenario" as a total loss of Project site. In response to an unplanned disaster at this location the prime concerns are to:  Protect personnel, assets and information,  Ensure that the Project continues to with no effect on schedule,  Ensure that stakeholders and staff do not lose confidence in the Project and its ability to continue. There are three time frames defined:  Critical functions to be restored within 24 hours,  Important functions to be restored within 1-3 days,  Other activities to be restored within 10 days. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 21 / 29 Recovery activities beyond 10 days will require extensive mobilization of resources and be subject to a detailed project plan. 10.4 RESPONSIBILITIES Project Emergency Management Team will handle initial Emergency Response using local procedures. The team also manage and co-ordinate recovery for 10 days following a disaster. 10.5 TESTING & REVIEW Each plan is to be tested annually to the policy guidelines issued by the Health & Safety Team. Plans are to be reviewed every six months by the Project Management Team. 10.6 EMERGENCY RESPONSE An Emergency Response Plan has been developed that encompass all reasonably foreseeable events that pose serious injury to the workforce. The Emergency Plan allows for the fact that emergency events can occur and develop rapidly, requiring personnel to act without waiting for further guidance. The following has been considered in the development of the procedure:  Equipment requirements to assist in an emergency situation,  Training requirements,  Personnel needs – resources,  Public interface,  Environmental impact,  Social impact. This Plan will either reflect in its entirety the Project Plan by being comprehensive in its coverage of possible emergencies and their scale, or will take the form of a bridging document, showing how Sanko intends to link into and follow the Projects requirements. 10.7 TRAINING All emergency duty personnel will be adequately trained to fill the emergency response role. All Sanko and Contractors Emergency Response Procedures will be tested at specified intervals. All drills and exercises will be recorded. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 22 / 29 11 PROJECT - PRIME RULES 11.1 INTRODUCTION The Project Prime Rules of Safety are a collection of guidance notes and requirements, addressing both major hazard & risk activity concerns that in the past have contributed to high incidence rates in the industry, coupled with effective controls that must be implemented to safely conclude them. The Prime Rules of Safety are shown below:  Permit to Work,  Vehicle Safety,  Confined Space Entry,  Working at Height,  Working with electricity,  Working with chemicals,  Lifting Operations,  Energy Isolations,  Ground Disturbance,  Management of Change. In those identified high hazard and risk areas above, the Project will complimented by the provision of both legislative and ‘best practice’ requirements such as those below to assure successful H&S management of the Project:  Risk Assessments,  Suitable and sufficient Training,  Suitable and sufficient PPE – Personal Protective Equipment,  Appropriate Emergency Response Plans. 11.2 H&S DELIVERABLES To achieve Sanko’s prime Objective contained in the statement “Safe Design, Construction and Operation is our Paramount Objective”, various performance indicators and the measurement of them, will be identified for monitoring, improvement and recording purposes during the Drilling, Construction and Operation phase. The following aspects will be addressed and suitable performance indicators for each implemented:  Applicable Legislation,  Equipment & Resources,  Measurements (monitoring requirements),  Variations (Best practices against National and International legislation),  Contractors Impact,  Risk Assessments, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 23 / 29  Permit to Work,  Vehicle Safety,  Confined Space Entry,  Working at Height,  Working with electricity,  Working with chemicals,  Lifting Operations,  Energy Isolations,  Ground Disturbance,  Management of Change,  Education & Training,  Safety Talks,  Hazard Communication,  Manual Handling,  PPE (Personal Protective Equipment),  Fall Prevention,  Housekeeping,  Scaffolding,  Barricades,  Floor & Wall Openings,  Excavation & Trenching,  Portable Ladders,  Lifting / Rigging,  MEWP’s,  Compressed Gas Cylinders,  Temporary Electric’s,  Road Transport,  Plant & Equipment,  Night Work,  Work In / Over Water,  Hot Work / Welding. 11.3 H&S OBJECTIVES The following H&S Objectives have been implemented within the Project, these will be further communicated in an ongoing process to Sanko’s Contractors as previously stated in the document. The objectives are clearly stated as:  Zero Accidents – Accident performance will be monitored throughout the related phases of the project,  H&S Orientation – NO personnel will be allowed to work on any site unless they have attended the Project H&S Education and Training programme, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 24 / 29  H&S Site Induction - All new site personnel will attend within first week of assignment, and before they are allowed to work on site, to ensure they are aware of the specific hazards in the work area,  Prime Rules of Safety – All personnel to attend specific training on Sanko’s Prime Rules prior to mobilization to site,  Audits / Inspections / Risk Workshops – Will be performed in accordance to the Audit and Risk Assessment Plans,  Behavioural Based Safety - ‘Safe’ and ‘At Risk’ behavioural observations will be measured by the number of observations completed per month following contract award and introduction of the programme.  Step Change Initiatives - Initiatives will be introduced to the project whereby all personnel can actively engage in the safety process and ultimately change behaviours and focus on Zero Accidents. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 25 / 29 12 MEDICAL FACILITIES 13.1 INTRODUCTION Sanko will identify all health risks associated with all workplaces, at all times, within his scope of work. The Medical representatives on site will, through defined means, adequately communicate these risks to the site management and workforce in an expedient and proactive manner. 13.2 FIRST AID REQUIREMENTS First Aid is seen by the medical community as the primary intervention towards stabilization of injured or ailing patients, to this end, for the site requirements, Sanko will provide basic first aid training for all personnel. 13.3 H&S INCIDENT REPORTING The policy of the Project is that all incidents no matter how insignificant they might appear, will be investigated, reported and recorded. The level of the investigation will be dependent on the severity or the perceived potential severity of the Incident. Note: A Near Miss will be treated as if ‘it actually happened’, based on the potential severity of its perceived outcome. The immediate managers will be informed immediately in the event of any incident and / or Near Miss. Employees will be educated in the Incident reporting process. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 26 / 29 13 H&S INCENTIVES A Safety Incentive programme will be considered and driven by the management, whereby positive H&S behaviours at all levels will be recognized by the Stakeholders, Project team and contractors during the drilling and construction stage of the project. SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 27 / 29 14 DISCIPLINARY PROCEDURES Similarly, a system of disciplinary measures will be established. The first unsuitable behaviour of any personnel will be warned. After the first warning, Sanko will adopt a ‘Yellow / Red card system’, similar to that used in ‘Football games’, a second Yellow card and personnel will be dismissed. Note: No one will be allowed to work on the Project who endangers individual lives – this if substantiated will lead to ‘Instant dismissal from the Project’. A written disciplinary procedure for violations of Project H&S Procedures is in place and the Project and its participants at all levels will be included. The purpose of this procedure is to place accountability within the project organization and to avoid any disputes that may occur through any seemingly unfair decisions. The disciplinary procedure will:  Observe In-Country legal and H&S Regulations,  Be in accordance with the Project H&S Plan and Procedures,  Be fair and equitable to all employees. The following safety guidelines apply to the development of a disciplinary procedure:  Define the range of offences (e.g., safety procedural violations, on site traffic violations),  Detail the actions against the different categories of offences (e.g., verbal warnings, written warnings, suspension and dismissal). SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 28 / 29 15 H&S TRAINING Preliminary details of the training are shown below. 16.1 H&S TRAINING PROGRAMME Covering Managerial and Supervisory legal responsibilities related to the health and safety of the employees require that the following is known and understood as part of their competencies:  know the health and safety legislation,  know the hazards in their workplace,  ensure that workers follow safety procedures required by the Project and,  ensure that their workers comply with regulations. In addition, they are expected to:  promote awareness of health and safety,  establish and enforce healthy and safe work practices,  resolve work refusals,  investigate accidents, and,  report certain injuries and accidents to the Regional Directorate of the Ministry of Labour,  Report all incidents to the Project. 16.2 H&S ORIENTATION / INDUCTION All Personnel working at all phase of the project will be required to attend an H&S Orientation / Induction briefing before commencing work. This H&S Orientation / Induction will be developed by the Project H&S Lead Engineer and be implemented by all Contractors at all sites, taking place in a suitably equipped training facility within the workplace, all attendees will be assessed to ascertain their level of understanding of the Induction content and will sign an attendance log following satisfactory completion of the induction programme. The programme will be repeated at a minimum of 6 monthly intervals or following major changes to legislative or on-site condition / working arrangements, whichever is the sooner. This H&S Orientation / Induction training will be given to Project employees and Contractors personnel prior to commencement of their employment on site, and will be monitored by the project H&S Lead Engineer to ensure that the appropriate standards are being adhered to. Subjects to be covered in the H&S Orientation / Induction will include:  Overview of the project and scope of work,  The organization on site,  Legislative requirements, SANKO ENERGY INDUSTRY AND TRADE CO. Date: 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT OCCUPATIONAL HEALTH AND SAFETY PLAN Page 29 / 29  The HS&E Policy and Objectives of the safety program - Zero Accident Performance, Prime Rules,  Safety Leadership –Sanko’s role in changing behaviours and developing employee involvement and process improvement,  Behaviour Based Safety – Employee involvement in safety and process improvement,  The role of the individual in the Safety Talk,  Project’s expectations of employees,  Drilling activities,  Driving and operating / maintenance and refuelling of equipment on site,  Driving requirements, Safe Driving requirements (e.g. seat belts, speed restrictions),  PPE, including clothing, minimum requirements and maintenance,  Reporting of incidents, personal injury and near-misses,  Medical facilities & Personal Health,  Fire prevention and suppression,  Housekeeping,  Open communications policy,  Hot work, Welding, Burning and Grinding,  Hazardous materials,  Portable tools,  Overhead Power Cables,  Drug and Alcohol awareness,  Office & Site Environment,  Lifestyle Safety. Special emphasis will be given on the proactive role expected by all personnel working on the project and their ability to stop work. The open communications policy will ensure that people are not put into hazardous situations. 16.3 VISITORS All visitors to Project site will also undergo a limited H&S Orientation / Induction. Sanko will develop this H&S Orientation / Induction which will be approved by the Project Team. Notes: No visitor(s) will be allowed onto the site unless accompanied at all times. There will be no dispensation for this rule, should a visitor attend site on a regular basis he/she will attend the site’s full H&S Orientation / Induction. As all sites will have specific differences, visitors will attend each site’s limited or full H&S Orientation / Induction programme. SANKO GEOTHERMAL POWER PROJECT TRAFFIC MANAGEMENT PLAN Revision Version Date Prepared by Checked by Approved by Muhsin Dervişoğulları General Manager of Geothermal Project Manager Environmental Manager Investments January 10, 2018 Draft A.0 Revision Codes: A: Draft, B: Final Draft, C: Final January 2018 Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 2/9 TRAFFIC MANAGEMENT PLAN 1. S C O P E AN D O B J E C T I V E Traffic Management Plan (TMP) defines the traffic related potential impacts and the mitigation measures to be taken during drilling, construction and operation phases. Sanko Energy and Contractors will:  identify those responsible for carrying out and managing the procedures;  reference the procedures and activities the Contractor will develop and implement;  identify work to be undertaken on the roads prior to construction activities to upgrade or stabilise the roads;  identify the routes that will be used with the estimated numbers of traffic movements, speeds and times of travel;  justify where a route has to pass through residential areas and the measures that will be used to ensure the safety of the community and minimise the nuisance impact of traffic movements;  identify the programme of road restoration measures that are likely to be required post construction;  address how the Sanko and Contractors can reduce the exposure of vehicle drivers, their passengers and other road users from the hazards of road-related accidents. Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 3/9 TRAFFIC MANAGEMENT PLAN 2. TURKISH S T AN D AR D S R E L AT E D TO T R AF F I C AN D T R AN S P O R T AT I O N Sanko Energy and the Contractors should comply with the following Turkish Standards relating to traffic and transport:  Turkish Regulation on Vehicle Production, Repair, Assembly (Official Gazette 26/10/2016 and No: 29869).  Turkish Regulation on Exhoust Gas Emissions of Veicles. (Official Gazette 11/03/2017 and No: 30004).  Turkish Regulation on Highway Notice (Official Gazette 19/06/1985 and No: 18789).  Turkish Regulation on Highway Traffic (Official Gazette 18/07/1997 and No: 23053).  Highway Traffic Law (Official Gazette 18/10/1983 and No: 18195). 2.1. POTENTIAL IMPACTS The main potential impacts associated with all phases of the Project include:  temporary increases in traffic flows on the road network leading to potential for delays and congestion;  conflicts between motorised and non-motorised forms of transport;  short-term closures and diversions of existing transport routes (eg roads, paths) resulting in disruption to transport users;  visual intrusion, increased roadside litter and traffic-related noise and emissions;  impacts on natural resources where traffic needs to travel ‘off-road’;  the loss of vegetative cover brought about by the construction of new roads;  water and soil pollution from spills or accumulated contaminants on road surfaces and potential modifications to natural drainage patterns brought about by the construction of new roads;  traffic accidents, which may result in death, injury or environmental damage. 2.2. TRAFFIC MANAGEMENT MEASURES AND PROCEDURES The key issues addressed by the TMP in terms of mitigation measures include:  access to construction areas and power plant;  routing of construction traffic;  temporary traffic control and management;  parking facilities; Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 4/9 TRAFFIC MANAGEMENT PLAN  keeping highways clean of mud and dust;  reducing the probability of traffic accidents. The requirements include the following mitigation measures: 2.2.1. ACCESS ROADS There is no need for new access roads. If it is required; in order to mitigate the potential traffic related impacts the following measures will be implemented:  Transportation will be carried out through the routes agreed with relevant authorities.  If the Contractor requires additional routes, a specific proposal will be submitted to Sanko for consideration and approval.  Temporary roads will be removed when no longer needed and will be reinstated. All damage to existing roads will also be reinstated.  The Contractor will liase with the appropriate regulatory authorities to gain approval to use, and regularly inspect, the road infrastructure.  Culverts will be installed as necessary where access roads cross water courses.  Crushed rock will be applied where necessary to act as an erosion control measure at temporary access roads, turning areas and other locations where sediment causes problems. Where crushed rock is applied over wet clay it may sink in to the soil and may require the Contractor to install an appropriate filter blanket at the soil-stone interface.  Temporary access roads will be kept free from deposits to prevent silt, oil or other materials from entering drains or watercourses. Small dams in roadside ditches may therefore be required to assist in silt retention, particularly on steep slopes.  Access routes to be used by construction traffic will be properly signposted. This shall be sufficient to prevent vehicles from leaving the designated routes and ensure that the appropriate speed limits are enforced particularly through residential areas.  Access and site roads will be maintained in good condition.  Suitable measures will be implemented to avoid damage to public roads and any damage will be repaired to an equal or better standard in a timely manner.  The Contractor will remove all temporary roads or road enlargements, except where local communities or landowners request that a new road be left in place. Sanko will advise the Contractor regarding the views of regulators, environmental considerations and the concerns of stakeholders for those roads that are to be left in place. 2.3. TRAFFIC CONTROL AND MANAGEMENT Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 5/9 TRAFFIC MANAGEMENT PLAN  In terms of traffic control, vehicles will be prohibited from reversing unattended into the drilling areas, power plant area and construction sites. Vehicles and plant shall enter and exit these areas in a forward direction, as far as possible. In addition, the Contractor will ensure that all heavy goods vehicles are equipped with audible reversing alarms.  Clear signs, flagmen and signals will be set up where necessary. Where temporary traffic signals are required, the details and locations of the signs shall be discussed with the relevant authorities. The signs will be fixed safely and securely to ensure that they do not become detached or dislocated, and will be visible and comprehensible by all.  Sanko and its contractors will also carry out maintenance checks to clean and re- secure signs if necessary.  Appropriate supervision will be provided to control the flow of traffic when machinery needs to cross roads.  Liaison with the police and other authorities will occur prior to the movement of any abnormal loads. In particular, liaison with the General Directorate of State Highways will occur prior to transportation on motorways.  Access to commercial and residential properties shall be maintained and speed limits will be established and enforced over all construction traffic routes.  Where roads used by children to reach schools are used, vehicle traffic will be minimised during hours that children are travelling to and from school.  Ambulances and fire services will be consulted regarding road diversions. Road diversions will not increase the response time of these services to local communities.  Access to residential and commercial properties will be maintained.  If road closures are required, diversions will be planned and communicated to the authorities (including emergency services and public transport providers) and affected communities in advance and will be properly sign-posted.  Fuel use will be minimised during the transportation of construction materials and personnel.  A 20 km/h speed limit shall be enforced on the construction sites. The speed limit shall be 50 km/h in the cities and villages. The speed limit on the motorways and highways shall be 90km/h. Appendix 1 provides “Checklist for Traffic Management Inspection and Audit Control” to be used by Environmental Inspectors. 2.3.1. MAINTAINING HIGHWAYS Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 6/9 TRAFFIC MANAGEMENT PLAN Sanko and its Contractors are expected to keep highways free from mud and dust and to ensure that no vehicle or other items of equipment leaving the construction base or working width, deposit soil, debris or rock on public highways or public right of ways. Measures will be implemented to ensure that the transport of mud and dust from the site onto public highways and roads is limited. Such measures shall be developed in consultation with Sanko representative and may include:  The use of hard core surfaces on access roads;  The provision of an easily cleaned hardstanding area within the construction base for vehicles entering, parking and leaving;  Fully sheeting all works vehicles carrying potentially dusty material or likely to deposit loose materials on the public highway during transit;  The Contractor shall clean and maintain temporary and permanent roads, and shall remove mud and debris from public roads. 2.3.2. VEHICLES STANDARDS AND MAINTENANCE With regard to vehicles standards and maintenance, Sanko will ensure that:  All vehicles shall be maintained so that their noise and emissions do not cause nuisance to workers or local people.  New vehicles: vehicles/equipment purchased ‘as new’ after contract award shall comply with the appropriate emission standards in force on the purchase date.  Older vehicles: vehicles/equipment not purchased ‘as new’ after contract award shall be maintained so that noise and emissions levels are no greater than when the vehicle/ equipment was new. APPENDIX 1 TRAFFIC MANAGEMENT INSPECTION AND AUDIT CHECKLIST Date 10.01.18 SANKO ENERGY INDUSTRY AND TRADE CO. SANKO GEOTHERMAL POWER PLANT PROJECT Page 8/9 TRAFFIC MANAGEMENT PLAN To be completed as follows 0 1 2 Subject of the Inspection Checklist Needs Compliant Needs immediate or not attention attention applicable Are the existing roads being used to avoid the need to 1 construct new roads? 2 Are access roads crossing watercourses? If so; a. Has a culvert / flumed crossing been installed? b. Have measures been implemented to mitigate against the impact of increased sediment flows? Are the temporary roads kept free from deposits? (Are 3 there soil piles, debris, etc.?) Is there any damage to public roads and public highways 4 resultant from construction related traffic? Have all temporary roads been reinstated, except for 5 those that required to be retained upon the request of the local community? Are the heavy goods vehicles equipped with audible 6 reversing alarms? Are there warning signs, flagmen, etc. at specific 7 locations (blind spots, bend, slope, residential areas)? 8 Are legal permits available for the traffic route changes? 9 Are the parking facilities signposted? Are vehicle parking, cleaning & maintenance areas kept 10 clean (i.e., free from spills, leaks, etc.)? Are there designated emergency parking areas with 11 proper signages? 12 Do vehicles have "First Aid" and "Fire Extinguisher"? Did the employees have appropriate training to their 13 position? 14 Do the project personnel obey the project speed limits? Do the drivers of long vehicles and Heavy goods vehicles 15 have assistant drivers to guide them on critical roads? SANKO GEOTHERMAL POWER PROJECT WASTE MANAGEMENT PLAN Revision Version Date Prepared by Checked by Approved by Muhsin Dervişoğulları General Manager of Geothermal Project Manager Environmental Manager Investments January 10, 2018 Draft A.0 Revision Codes: A: Draft, B: Final Draft, C: Final January 2018 SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 2 / 28 WASTE MANAGEMENT PLAN 1. S C O P E AN D O B J E C T I V E The Waste Management Plan (WMP) defines any potential wastes likely to occur during drilling, construction and operation of Sanko Geothermal Power Plant Project and incorporates appropriate waste management methods for their collection, storage, treatment and / or disposal. WMP covers any wastes occurring as a result of drilling, construction and operation and relevant activities thereof. The wastes covered by WMP are generated by the following activities:  Drilling activities,  Construction and commissioning of all the facilities,  Both provisional and permanent housing (used during construction) ,  Secondary works such as provision of equipment, road construction, etc.,  Operation activities. WMP defines the method of management of wastes during drilling, construction and operation of the project including:  how to minimize potential impacts on human health and environment,  how to achieve compliance with the Turkish regulations and the environmental targets of Sanko,  how to maintain this possibilities and means for reducing operating costs and any potential obligations that may arise out of waste transport operations. This plan also guarantees that the waste streams and solid waste materials on the sites will be managed in a proper manner. 1.1. STRUCTURE OF THE WASTE MANAGEMENT PLAN WMP covers the following headings in addition to this part, which is of an introductory nature containing the definitions of the terms and a glossary thereof:  Applicable policies and standards,  Approved waste management facilities,  Waste disposal sites,  Waste sources and streams during drilling, construction and operation of Sanko geothermal Power Plant Project,  Waste management measures and procedures. 1.2. DEFINITIONS SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 3 / 28 WASTE MANAGEMENT PLAN Waste Management Structures built to process wastes or store them temporarily or permanently. Facility Waste management Segregation, collection, temporary storage, re-cycling, transport, handling, disposal and post disposal control and similar operations of wastes at source based on the respective characteristics and similar activities. Wastes Any substances or objects defined by the Turkish laws related with solid wates, hazardous wastes, medical wastes etc. or any other substances or objects defined in connection with such wastes. Any substances or objects disposed of by Sanko or the contractor or agreed by the contractor for disposal or required to be disposed of by the Contractor. Contagious / infectious As defined by “the Regulation on the Control of Medical Wastes” (dated 25.01.2017); wastes for instance, wastes containing bacteria or viruses most probably or contaminated by faeces. Domestic wastes As defined by “the Regulation on the Control of Medical Wastes”; for instance, office (medical) wastes and packaging wastes generated by emergency / first aid rooms and clinics. Inert wastes Any substances which are not substantially changed, dissolved or incinerated physically, chemically or biologically, which do not have any physical and chemical reactions or any biological degradation or Which do not affect any articles contacted by them to such an extent harming environment or human life, having minor levels of total leakage capability or eco- toxicity and no risks of contaminating surface and ground water in particular (construction and demolition wastes). Excavated soil, Any wastes as defined by Article 4 of the Regulation on the Control of Excavated construction and Soil, Construction and Demolition Wastes. demolition wastes Pathogenical wastes As defined by “the Regulation on the Control of Medical Wastes” . Pathological wastes As defined by “the Regulation on the Control of Medical Wastes” (for instance: limbs, parts of body, animal carcasses, etc.) Project Sanko Geothermal Power Plant Project. Hazardous wastes Any substances or objects defined by the Turkish laws (Regulation on the Control of Hazardous Wastes dated March 14, 2005, and Regulation on Waste Management dated 23.03.2017) Solid wastes Any wastes as defined by the Regulation on the Waste Management Medical wastes As defined by the Regulation on the Control of Medical Wastes, for instance: clothes, cotton bars, syringe injections and the like SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 4 / 28 WASTE MANAGEMENT PLAN Generators (wastes) Any natural persons or legal entities as defined by the Turkish laws (Regulation on the Waste Management dated March 23, 2017) SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 5 / 28 WASTE MANAGEMENT PLAN 2. AP P L I C AB L E P O L I C I E S AN D S T AN D A R D S 2.1. ENVIRONMENTAL POLICIES OF SANKO A number of policies have been identified by Sanko to provide guidance over any operations carried out. The Declaration of Policy provided below covers the policy underlying the environmental operations:  Sanko Geothermal Power Plant Project is a scheme attaching priority to the preservation of environment.  Sanko is responsible for elimination or proper minimization of all the potential adverse affects of the project on environment during implementation of good environmental administrative methods. Accordingly, all the works will be carried out in compliance with applicable environmental laws and regulations as well as with international engineering approaches and standards in general such that environment is preserved and its quality enhanced. In order to attain this goal, Sanko will:  conduct top management reviews and inspections on an annual basis as a minimum for the purpose of achieving conformity to any established policies, procedures and applicable environmental laws and regulations,  maintain a commitment to waste minimization and pollution prevention, and shall incorporate such principles in any definitions of project conditions and performance of project operations,  define, evaluate and manage any environmental risks, exerting its best efforts to determine and review objectives and targets for operation thereof and minimize the risks of occurrence of any adverse environmental effects,  be committed to building relationships with authorities, the scientific community and the public to promote the development and communication of innovative, cost effective solutions to environmental problems;  ensure a commitment to the continuous improvement of the Environmental Management System wherever possible and sustainable. All Project personnel shall be individually and collectively responsible for adherence to, and effective application of the policies and principles contained in this environmental policy statement. 2.2. WASTE MANAGEMENT POLICIES AND PRINCIPLES The following waste management principles will be implemented under the project to achieve compliance with the policies of Sanko outlined above: SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 6 / 28 WASTE MANAGEMENT PLAN  Waste management hierarchy  Principle of proximity  Statutory liabilities  Employment of most advanced feasible technologies, which do not cause any excessive costs  The principle of “polluter pays” Both principles are discussed under the sub-headings below. 2.2.1. WASTE MANAGEMENT HIERARCHY Figure 2.1 indicates the waste management operations classified according to the order of preferences as the Waste Management Hierarchy. This hierarchical structure basically emphasizes that prevention of wastes at source and minimization of volumes of wastes generated and any hazards thereof are the practices which must be preferred with priority. In addition, it also notes that re-use, recovery and re-cycling must be preferred after treatment of wastes and that therefore, disposal must be the final option. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 7 / 28 WASTE MANAGEMENT PLAN Figure 2.1 Waste Management Hierarchy 2.2.2. PRINCIPLE OF PROXIMITY In simple terms, the principle of proximity explains that wastes will be managed in the locations nearest to sources (by considering waste management policies and principles). In particular, it notes that countries and regions preferably must be self sufficient in terms of waste management conditions. 2.2.3. STATUTORY LIABILITIES The principle of statutory liabilities notes that it is a statutory obligation for generators of wastes to guarantee proper management of wastes (whether they are hazardous wastes or not) even after they are transported to a third party. As a matter of fact, this principle stresses the importance of evaluation by waste generators of waste management capabilities of third parties collecting wastes in selection and observation of their operations. 2.2.4. EMPLOYMENT OF FEASIBLE MOST ADVANCED TECHNOLOGIES, WHICH ARE NOT EXCESSIVELY COSTLY The principle of employing feasible most advanced technologies, which are not excessively costly, means that wastes will be managed by optimum technologies presently available, which would not require excessive spending; in other words, costs of transition to another technology offering better performance than a given technology would not be compared to overall waste management benefits that would be obtained as a result. 2.2.5. PRINCIPLE OF “POLLUTER PAYS” It basically refers to a requirement on the part of any parties causing pollution to pay costs for reduction of such pollution. 2.3. WASTE MANAGEMENT LEGISLATION The elements of the Turkish legislation referred to below closely relate to management of wastes which would occur during the project drilling, construction and operation and this legislation must be complied with strictly. Official Gazette Official Legislation Implications for the Project Stages Date Gazette Issue  Disposal of wastes generated by construction staff during construction Waste Management 02.04.2015 29314 stage and by operation staff during the Regulation 23.03.2017 30016 operation stage  Hazardous wastes generated at construction and operation stages SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 8 / 28 WASTE MANAGEMENT PLAN Official Gazette Official Legislation Implications for the Project Stages Date Gazette Issue 31.12.2004 25687  Discharge of wastewater generated Water Pollution by site staff at construction stage and by Control Regulation 10.01.2016 29589 operation staff during the operation stage Regulation on 26.03.2010 27533  Drilling mud generated during the Landfill of Wastes 11.03.2015 29292 construction stage Waste Oil Control 30.07.2008 26952  Waste oils generated at construction Regulation 05.11.2013 28812 and operation stages Waste Vegetable  Waste vegetable oils generated at Oil Control 06.06.2015 29378 construction and operation stages Regulation Packaging Waste  Packaging wastes generated at 24.08.2011 28035 Control Regulation construction and operation stages Medical Waste 22.07.2005 25883  Medical wastes generated at Control Regulation 21.03.2014 28948 construction and operation stages Regulation on the 25.11.2006 26357  End-of-life tires generated at Control of End-of- 11.03.2015 29292 construction and operation stages life Tires Regulation on the 31.08.2004 25569  Waste batteries and accumulators Control of Waste generated at the construction and Batteries and 23.12.2014 29214 operation stages Accumulators Regulation on the Construction of  Septic tanks for the collection of Septic Tanks at 19.03.1971 13783 domestic wastewater generated at Places Where construction and operation stages Sewer Construction is Not Feasible Regulation on the Noise Emission in 30.12.2006 26392  Noise levels caused by noise the Environment sources within the Project site at the from Equipment for 06.06.2017 30088 construction and operation stages Outdoor Use Industrial Air 03.07.2009 27277  Dust emissions at the construction Pollution Control stage and CO2 emissions at the operation Regulation 20.12.2014 29211 stage Regulation on Assessment and 06.06.2008 26898  Emissions originating from the Management of Air 05.05.2009 27219 Facility during the operation stage Quality Regulation on the  Odorous emissions generated Control of Odorous 19.07.2013 28712 during the operation stage Emissions Regulation on Assessment and  Noise emissions at construction and Management of 04.06.2010 27601 operation stages Environmental Noise SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 9 / 28 WASTE MANAGEMENT PLAN Official Gazette Official Legislation Implications for the Project Stages Date Gazette Issue Regulation on Soil Pollution Control 08.06.2010 27605  Risks of soil contamination at and Point Source 11.07.2013 28704 construction and operation stages Polluted Areas Regulation on the Control of 18.03.2004 25406  Transportation and disposal of Excavation Soil, excavation waste and construction debris Construction and 26.03.2010 27533 at the construction stage Debris Wastes Law on Occupational Health 20.06.2012  Health and safety measures to be and Safety (6331) 01.07.2017 28339 taken during construction and operation (as amended with stages the Law numbered 7033) Regulation on Buildings to be 06.03.2007 26454  Construction works within the scope Constructed within 03.05.2007 26511 of the Project the Seismic Zones 2.3.1. REGULATION ON THE CONTROL OF SOLID WASTES The Regulation on the Waste Management (WM) refers to employment of low waste technologies although it prescribes use of waste management for prevention any hazards to humans, environment and buildings. WM also incorporates the hierarchy of preferences for re- use, recovery and re-cycling after treatment of wastes as well as disposal of wastes. Certain particular conditions will be considered:  any clinical wastes must be separated from those solid wastes of a garbage type and they must be disposed of separately.  Consumers must not dispose of any batteries or unused medicine / pharmaceutical products jointly with garbage type solid wastes.  Producers must be held responsible for management of liquid containers and thermo- plastic packages when they become wastes.  Garbage type wastes (for instance: domestic wastes, food wastes) must be stored and transported such that any dust and odor emission by them is prevented to avoid any hazards on human health and environment.  It is prohibited regularly to store and dispose of any liquids, fluid sludge, explosives, clinical wastes, animal carcasses, radioactive substances and any other materials or SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 10 / 28 WASTE MANAGEMENT PLAN agents / substances which may lead to emissions of dust and odor or any other hazardous substances.  Any excavated soil must be stored in those locations approved by authorities only.  Permissions for waste management facilities must be obtained from relevant local authorities or municipalities.  Both construction and operation permissions and operation licenses must be obtained for any incineration systems. 2.3.2. REGULATION ON THE CONTROL OF HAZARDOUS WASTES The Regulation on the Control of Hazardous Wastes (HWR) meets Articles No 8, 11 and 12 of the Environmental Law of 14/3/2005 and Article No 3 of the Convention of Basel, to which Turkey is a Party. HWR incorporates regulation related procedures concerning hazardous wastes and statutory liabilities for them as well as the principle of polluter pays. HWR establishes responsibilities related to approval for site selection, receipt of permissions, guaranteeing inspections and satisfaction of the obligations under the Convention of Basel, to which Turkey is a Party. Powers and duties are also assigned to local authorities and municipalities. Concerning waste generators, it imposes a requirement for definition of wastes and maintenance of records thereof, in addition to the general requirements for minimization of waste volumes and provision of safe temporary depots. There is a requirement to comply with applicable international standards governing waste control. It is required that as a first step, a preliminary license must be held during design and development of treatment and disposal facilities and subsequently, a license is further needed during operation. It is obligatory that operators of waste management facilities must be in possession of relevant qualifications and competence so that they can prepare Waste Management Operation Plans (WMOP’s) for operation of their respective facilities as well as for each department of such facilities. HWR clearly demonstrates that documentation of handling and transport of hazardous wastes is vital. It notes in connection with incineration of hazardous wastes specified by Annex 6 to HWR that all the requirements under Article 33 of the Regulation on the Control of Medical Wastes (RCMW) (which was published in the Official Gazette Issue No 25883 of 22.7.2005 updated by Official Gazette issue no 28945 of 21.03.2014) are duly met. HWR clearly defines basic standards for any facility designs, construction operations, closure and subsequent maintenance. Part Eight of HWR meets the standard conditions governing “cross border transport of wastes” under the Convention of Basel. 2.3.3. REGULATION ON THE CONTROL OF MEDICAL WASTES The Regulation on the Control of Medical Wastes (RCMW) (dated July 22, 2005) demonstrates the requirements provided below: SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 11 / 28 WASTE MANAGEMENT PLAN  Part 3: medical wastes are separately collected, stored, transported and disposed of from domestic wastes  Pathogenous wastes are collected in special plastic red bags, the specifications of which are indicated by Article 13, together with other infected wastes after they are sterilized.  Disposal of radioactive wastes is carried out subject to the provisions of the by-law concerning the Law on the Turkish Atomic Energy Agency.  Licenses are issued for waste depots as per Article 18. Any wastes generated by sources of a medical nature (such as: infirmaries on the construction sites and clinics) will be managed as per RCMW. Such kinds of wastes will be sorted, packaged and disposed of as required by this regulation. Medical wastes and infected wastes will be separately stored from domestic wastes. 2.3.4. ENVIRONMENTAL INSPECTION REGULATION This regulation lays down the procedures for environmental inspections to be conducted by the Ministry of Environment and Forestry during the stages of building a facility, which involves construction and operation and various other aspects.  In the event that it is established during inspection conducted that the prohibitions prescribed by the Environmental Legislation are not adhered to or that the obligations concerning control of solid wastes are not met, - A time limit of 30 days is granted for performance of corrective action in case wastes of various types are directly or indirectly discharged into recipient media, stored, transported, removed or subjected to other similar operations in violation of the standards and methods established by the relevant applications. - A time limit of 10 days is granted for introduction of measures for treatment, removal and other similar activities involving any kinds of wastes in a manner not harming environment. - A time limit of 10 days is granted where information is not regularly and continuously documented on the characteristics and volumes of fuels consumed and wastes resulting thereof and not notified to the Ministry of Environment and Civilization accordingly. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 12 / 28 WASTE MANAGEMENT PLAN 3. AP P R O V E D W AS T E M AN AG E M E N T F A C I L I T I E S Presence of approved waste management facilities and assurance that such facilities actually possess the capabilities which can accommodate wastes projected to be generated constitute an inseparable part of waste management. Wastes must be disposed of in countries where they are generated. In addition, cross border transportation of wastes without prior management approval as required by the international agreements is out of the question. This part outlines disposal of solid wastes and excavated soil, clarifying the procedures for approval of facilities for waste disposal. 3.1. PROCEDURE FOR APPROVAL OF FACILIITIES The site must be taken under evaluation a decision be adopted as regards if the facility is compliant with the Regulation on the Waste Management (which is dated March 23, 2017) so that a given facility may receive “approval”. The obligation regarding waste management in Turkey is exercised by the governors’ offices and municipalities. Apart from information on the types and volumes of materials to be excavated, excavation plans and documentation in support of calculations must be submitted to the relevant municipalities or governors’ offices. Domestic wastes Domestic wastes will be disposed of by licensed solid waste facilities operated by municipalities. Agreements will be made with municipalities prior to the issue of permissions for disposal of wastes. Accordingly, wastes will be taken to licensed waste disposal sites owned by municipalities. Excavated soil The procedures related to receipt of approval for facilities to receive excavated soil involve a different procedure. An application form must be submitted to the relevant municipality or governor’s office for the purpose of determining a site for disposal of excavated soil. Upon approval of the application form, a protocol is signed. Following this, excavated soil is taken to the designated areas covered by the protocol and disposed of there. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 13 / 28 WASTE MANAGEMENT PLAN 4. W AS T E S O U R C E S AN D S T R E AM S D U R I N G P R O J E C T C O N S T R U C T I O N The defined wastes are categorized under the following main groups of wastes and the planned management options are indicated. WASTE STREAM SOURCES TYPE* MANAGEMENT OPTION Aluminum boxes Largely empty drink boxes S Compression and re-cycling Wet batteries Used up batteries in machinery and vehicles H Re-cycling Dry batteries Used up batteries in portable articles such as H Re-cycling personal radios and flashlights Blasted debris Regions where geological structure requires S Disposal in designated scrap disposal blasting sites (locations will be provided); or re-use in appropriate locations as a second option. Cables / copper Surplus supplies after construction of facilities H Re-cycling and temporary job sites and also at the stage of closure of operation Containers (having large Empty steel barrels S Re-cycling sizes) Containers (other) Empty steel and plastic containers of various S Re-cycling sizes Contaminated soil Disposal resulting due to spills or by accident H Particular treatment - treatment by facilities holding appropriate licenses Barrel cleaning wastes Cleaning steel barrels from wastes so that H Particular treatment - treatment by they can be used for other applications facilities holding appropriate licenses Electrical / electronic S Landfill components Electrical equipment (for H/S Landfill instance: switchyards) Filters air / oil Used filters of machinery and components H Incineration Filters (water) S Incineration Food Pieces and other organic wastes O Landfill Diesel, gasoline and H Re-cycling petroleum wastes H Diesel H Diesel generator engine oil H Various oils (including H hydraulic) Vehicle and equipment engine oil Glass Largely empty bottles as a result of domestic S Re-cycling wastes Grease Wastes of lubrication products and some S/H Incineration SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 14 / 28 WASTE MANAGEMENT PLAN domestic greases Insulation Surplus supplies for installation of insulation H Landfill materials Bulbs Used incandescent and fluorescent bulbs H Re-cycling (Special treatment is required if fluorescent bulbs are in large quantities) Medical Sharp objects such as needles and cotton M Incineration bars Packaging materials Plastics, paper, hardboard and the like S Re-cycling Paper and hardboard Office and domestic wastes S Re-cycling / Incineration Plastic bottles Water containers, of which some are industrial S Re-cycling but which are largely disposed, and other domestic materials KKM and clothes Disposed personnel protective clothes, H/S Incineration overalls, boots, rags, etc. Waste water Waste water originating from construction sites L Collection in multispan impermeable and temporary facilities cess pit tanks and subsequent transport to Manisa Municipality Wastewater Treatment Plant by vacuum tankers Site drainage water Storm water collection L Pumping it into the trench on the side position by using straining / settlement techniques in line with Ministry of Environment and Cicilization (MOEC) requirements Concrete mixing waste water Concrete breaking L Collection in the sedimentation pools and subsequent disposal Excavation wastes Surplus excavated soil and supplied fill I Re-use / storage materials Steel Surplus volumes of materials from S Re-use / storage of useful construction of facilities and temporary job components for forthcoming works sites as well as the stage of closure of and re-cycling for the remainder. operation Stones / fences / gates / Temporary stone pathes; temporary fences, I/S Re-use in the field if it is possible. passages gates, passages, etc. Surplus soil and rock Fill and corrective activities S Re-use if possible / provision to a licensed waste disposal facility Rubber Worn vehicle tires T Re-cycling * I= İnert; H = Hazardous; S = Solid; L = Liquid; O=Organic; M=Medical Waste management will be carried out in line with the table provided above: Solid wastes: Recovery / Re-cycling: SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 15 / 28 WASTE MANAGEMENT PLAN Substances to be subjected to priority recycling (for instance: paper, hardboard, plastics, glass, metals) will be separated from domestic solid wastes for recovery / recycling to an appropriate extent. Landfill : Landfill of domestic solid wastes, which cannot be recycled, may be achieved in present Landfill facilities (owned by third parties). Disposal sites for the project will be designated by the Municipalities of Salihli and delivery will be made to the disposal sites to be designated by the municipalities as defined by Part 5.6 and Part 5.7, with the contractor being responsible for transportation. No wastes will be disposed of or buried on the site. Wastes will never be allowed to be disposed of on the construction camp site, on the public roads or neighboring areas or inside the rivers in any manner contrary to laws. Wastes, plants and garbage will not be allowed to be incinerated on the site. Hazardous and non-hazardous solid wastes expected to be generated during the drilling, construction and operation stage are domestic solid waste from construction staff, excavation debris, packaging wastes, recyclable solid waste end-of-life tires, waste batteries and accumulators and drilling mud. Non-hazardous Solid Waste Domestic solid waste is generated by the project personnel as a result of various consumptions of the field staff. Considering that the number of field staff will be 84 and taking the daily waste generation per capita value as 1.25 kg/person-day, as indicated by Turkish Statistical Institute’s 2014 data for Manisa province, the total domestic solid waste generation by the field staff will be 105 kg/day. Recyclable wastes such as glass, paper and plastics will be segregated from other wastes and stored temporarily on site for eventual recycling process. Non-hazardous solid waste other than recyclables will be stored in containers and will be disposed by Salihli Municipality. All solid non-hazardous wastes will be disposed according to the Waste Management Regulation. Excavated soil will be re-used for backfilling, landscaping and site leveling purposes. Hence, no excavated soil will be transported and stored outside the Project area. Temporary storage of the excavated material will be performed providing the generation of drainage pathways to underlying aquifers. The height of the stockpiles will not exceed 5 m and the stockpiles will be dampened especially during dry and windy weather in order to prevent dust emissions. If excess material occurs it will be disposed in a landfill approved by Manisa Municipality. Hazardous Waste SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 16 / 28 WASTE MANAGEMENT PLAN During the all phases of the Project hazardous waste will mainly be contaminated packaging wastes, contaminated protective material and waste oil. In case, it is inevitable to perform maintenance of the construction vehicles on site, minor amounts of waste oil will be generated at the site. Oil change of the vehicles will be conducted by machine experts or service staff on leak-proof surface within the construction site, therefore a possible soil contamination will be prevented Generated waste oil will be collected in safe leak-proof containers, stored in an area with a concrete surface and a proper secondary containment to prevent potential spills and leakages reaching to the soil and groundwater. Waste oil will be disposed in accordance with the Waste Oil Control Regulation. Hazardous waste generated due to Project activities will be waste drilling muds in case they are determined as hazardous according to the analysis. Domestic Solid Waste Domestic solid waste in the operation stage is generated as a result of various consumptions of the operation personnel. According to the EIA Report domestic solid waste generation for 27 personnel will be 33.75 kg/day. Domestic solid waste will be collected and stored in the Project area and disposed by Salihili Municipality according to the requirements of Waste Management Regulation. Furthermore, recyclable waste (i.e. glass, plastics, glass) will be collected separately at source as indicated in Article 5 of the Waste Management Regulation. Packaging Waste Packaging waste generated during the operation stage are composed of recyclable materials such as metal, paper, plastics and glass. Packaging waste will be collected in separate containers in order to be reintegrated into the economy without exposed to any chemical or biological process. In addition, compliance with the Packaging Waste Control Regulation will be ensured for their management during the operation stage. Liquid wastes: Waste water which will develop as a result of the project implementation will originate from the basic operations indicated below:  Domestic wastes from the temporary site (well drilling and camp site)  Water from drilling activities  Waste water from workshops, offices and laboratories  Domestic wastes from operation building  Construction site drainage system water During the construction stage, water demand will consist of potable water and water to be used for dust emission prevention. Potable water will be supplied as demijohns. Domestic SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 17 / 28 WASTE MANAGEMENT PLAN water for the workers and water for dust suppression will be provided by the two wells established by the former owner of the land within the Project area. Sanko Enerji has applied to DSİ for the transfer of the ownership of the wells. A total of 100 personnel is planned to be working in the scope of the construction phase for various works and periods, however number of personnel working at the same time will not exceed 84. Total number of persons engaged: 84 Water required: 0.203 m3/person/day (Turkish Statistical Institute, 2014) Total water requirement: 0.203 m3/person/day x 84 persons = 17.52 m3/day It is assumed that approximately 52.5 m3 water per day will be used for construction activities for preventing dust emission. Regarding the drilling works; 48 personnel is expected to be operating daily. Total water requirement: 0.203 m3/person/day x 48 persons = 9.744 m3/day Water is also required during drilling works. Exact amount of required water cannot be determined due to various factors such as drilling fluid and geological units, however based on the previous drilling studies 630 m3 water is estimated to be used during drilling according to the EIA report. The drilling fluid will be stored in mud storage tanks after solid material is removed and the fluid is re-used afterwards. Therefore water consumption of 14 m3/day will occur in order to supplement the required water during drilling activities. Water required for drilling works are supplied from available wells or surface water sources at the drilling locations after DSI consent and if there are no wells available, water will be transferred by tankers. Wastewater Generation: Only domestic wastewater will be generated during construction stage activities. Considering domestic waste requirement is 17.52 m3/day for 84 personnel, waste water generated is estimated to be below 17.52 m3/day. Domestic wastewater generated at the construction stage will be collected in a septic tank in compliance with the Regulation on the Construction of Septic Tanks at Places Where Sewer Construction is Not Possible. If the number of employees exceeds 84, waste water treatment plant will be established for the Project according to the requirements of the Regulation on Water Pollution Control. Below parameters are expected for the domestic waste water generated during construction phase of the Project according to the EIA report: Expected Domestic Wastewater Parameters Parameter Concentration (mg/lt) pH 6-9 SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 18 / 28 WASTE MANAGEMENT PLAN Parameter Concentration (mg/lt) Suspended Solids 200 BOD 200 COD 500 Total Nitrogen 40 Total Phosphorous 10 . Test Waters: Test drillings are conducted in order to prove the commercial viability of potential resources. Drilling works are the same for both the production wells and reinjection wells. Type of the wells is decided according to the efficiency assessment of the wells based on properties such as temperature, flow rate and pressure. During the drilling works, liquid drilling mud which is the mixture of different type of chemicals with water will be employed in order to carry rock cuttings to the surface and also lubricate and cool the drill bit. Impacts of drilling mud is provided in the following section. . Rotary drilling is used for the wells within the scope of the Project. Casings of three different diameters were employed during drilling of wells which have diameters of 20’’, 13 3/8’’ and 9 5/8’’. At the end 7’’ production pipes are employed to convey the geothermal fluid to the surface. Cement is applied around the casings and in this way in order to order to contain the geothermal fluid is contained and uncontrolled generation of geothermal fluid or vapour is prevented. The casings at shallow depth prevent loose near-surface material collapsing into the well and casings with intermediate diameter will support successive wellheads.. Casings and concrete wall around casings prevent groundwater and geothermal fluids intervene with each other. No discharge to aquifer will occur due to Project activities. It is planned to extract 420 tonnes/hour geothermal fluid for 15 MW capacity from wells with a depth of 2500-3000 m. Geothermal fluid extracted from the production wells will be reinjected to the original reservoir through reinjection wells. It is planned to construct an impermeable collection pond to be used in case of any failure during reinjection, operation of the power plant or during maintenance of the wells. The capacity of the collection pond is planned to be 1400 m3 with the estimation of use of 1400-1500 tonnes/hour geothermal fluid at maximum for a potential capacity increase of the power plant to 50 MW. The capacity of the pond is calculated based on the estimation that the system will stop maximum for 1 hour duration. If the volume of the collection pond is exceeded due to malfunction, extraction of geothermal fluid will be stopped. Geothermal fluid collected in the pond will be reinjected back to the system by reinjection pump. Geothermal fluid discharge to any kind of environment will be prevented during the whole Project lifetime. Drilling Mud: SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 19 / 28 WASTE MANAGEMENT PLAN Drilling mud will be generated as a result of drillings. Drilling mud will be elevated to the ground collecting solid particles. Drilling mud will be sieved for foreign substances and then passed through solid-liquid separator (decanter). Liquid part is pumped back to the mud tankers to be reused. Solid substances on the other hand, are sent back to waste mud pond. The solid material passing through the decanter has some amount of water content therefore collected as liquid waste in the drilling mud pond. Liquid drilling mud is settled in the pond providing solid substances to deposit. For the Project 100 lt of drilling mud is expected to be generated for 1 m drilling. Average depth of the drilling wells is estimated to be 2,500 m therefore the amount of drilling mud at each drilling location is calculated as follows: Amount of drilling mud: 100 lt/m x 2500 m=250,000 lt= 250 m3 Mud ponds with dimensions 60 m x 6.5 m x 3 m with side slope are established for storage of mud at each drilling location. Each pond is covered with impermeable material such as geomembrane and has 1,170 m3 capacity which is above the calculated value above. Mud collected in the pond is settled providing the deposition of solid substances. Waste mud is analyzed for categorization according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery (dated 2012/15) and the Regulation on Landfill of Wastes (Official Gazette dated 26.03.2010, no: 27533). If the waste is deemed hazardous waste, it will be disposed according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery. If the waste mud is determined as inert and/or non-hazardous waste then the mud ponds will be filled with excavation debris and covered with the vegetative soil which was stripped and stored separately during land preparation. After the drilling mud is deposited, remaining water on the mud is evaporated or discharged by vacuum truck if drilling mud is determined as non-hazardous or inert. If the mud is classified as hazardous then the water on the mud is collected into IBC tank and disposed according to the requirements the Regulation on Waste Management. Inert construction wastes: Excavated materials will be used in service road fills and landscaping works. Medical wastes: There will be an infirmary established at the Power Plant for the personnel. Besides health institutions close to the Project area will be applied if required. Salihli State Hospital is at a distance of 4.5 km to the Project area. According to the EIA Report 10 kg/year medical waste is estimated to be generated. Medical waste which will be generated as a result of on-site first aid applications for injuries; they will SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 20 / 28 WASTE MANAGEMENT PLAN be collected, transferred, stored and disposed of in compliance with the Medical Waste Control Regulation. Hazardous wastes: Hazardous wastes to be generated during operation phase of the Project is expected to be contaminated materials due to maintenance activities, contaminated packaging material wastes, waste electronics, fluorescent and waste toner and cartridge. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 21 / 28 WASTE MANAGEMENT PLAN End-of-life Tires Maintenance of the vehicles to be used during the operation stage will be performed at authorized technical stations therefore end-of-life tires are not expected to occur at the Project area. In case there are in the area tires will be sent to licensed companies for disposal in accordance with the Regulation on the Control of End-of-life Tires. Waste Batteries and Accumulators Waste batteries generated during the operation stage will be separately collected in the waste battery containers found at the Project site and periodically will be sent to a Waste Battery Recycling Plant. Compliance will be ensured with the Regulation on the Control of Waste Batteries and Accumulators. There will be no accumulator replacement within the Project area. Empty accumulators generated in compulsory cases will be sent to firms to be replaced with full ones as stated in the Regulation on the Control of Waste Batteries and Accumulators. Waste Oils Waste oil is expected to be generated due to transformer oil used in the switchyard and substation. Maintenance of the transformers will be provided by authorized service companies and disposal of the waste oil will be conducted according to Waste Oil Control Regulation. Waste oil is generated as a result of maintenance of vehicles and equipment. In case of waste oil generation during an oil change, it will be stored and disposed off in accordance with the Waste Oil Control Regulation. Vehicle maintenance will be conducted periodically on a daily, weekly and monthly basis, and oil leakage will be avoided by using drip pans. Waste vegetable oil is not expected to be generated since food service will be outsourced during operation phase of the Project. In case of waste vegetable oil generation compliance with the Waste Vegetable Oil Control Regulation will be provided. Hazardous material will be stored in leak proof containers on impermeable ground. Spill kits will be available at the site for immediate response. MSDS for chemicals will be available for the workers. Explosive wastes: Wastes of explosives purchased for use during the project will be stored in their original containers but they will specifically be labeled as wastes. They will be managed and disposed as recommended by manufacturers in line with the Turkish legislation. Any explosive wastes SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 22 / 28 WASTE MANAGEMENT PLAN located within the boundaries of the project site will be specifically identified for disposal by competent authorities. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 23 / 28 WASTE MANAGEMENT PLAN 5. W AS T E M AN AG E M E N T M E A S U R E S A N D P R O C E D U R E S 5.1. DUTIES AND RESPONSIBILITIES The project construction contractor(s) will be deemed “owner(s)” of any wastes (including domestic and sanitary wastes) generated by drilling and construction activities and they will thus be held accountable for proper management of such wastes. Sanko and its contractors will take any measures to prevent generation of wastes and minimize both volumes and hazards of such wastes generated. It will be ensured that the contractor guarantees proper identification of any wastes generated and storage until collection / transportation activities, which are not agreed on for re-use, recovery, re-cycling, treatment and / or disposal thereof. Although Sanko and the contractor may employ third parties for collection, recovery, re- cycling, treatment and / or disposal of wastes, it is responsible for monitoring the activities of such third parties thus employed to ensure selection of licensed / authorized contractors, proper management of wastes and treatment and disposal operations thereof. In case Sanko and the contractor will provide and operate any waste management facilities, it must then guarantee that such facilities comply with applicable Turkish legislation, having proper licenses and / or authorization and further that they are manufactured and operated as per the foregoing legislation. Sanko will also conduct compliance inspections periodically. 5.2. WASTE MANAGEMENT TRAINING Sanko and the contractor must ensure that all of its employees are aware of all the relevant elements of WMP and that they are adequately trained so that they can perform their duties and functions as part of waste management. Personnel files will have pertinent records on the training status of all the employees. 5.3. WASTE GENERATION Any reasonable measures must be taken in order to prevent waste generation and minimize both volumes and hazards of such wastes. Any wastes generated will be identified, classified and documented as per applicable Turkish legislation. 5.4. SAMPLING AND CLASSIFICATION OF WASTES Sanko and the contractor shall identify any wastes generated by conducting sampling, checking, tests and analyses so that wastes are classified as per Turkish legislation and the following points may be determined:  whether wastes are hazardous, solid or “inert”  The method of waste management SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 24 / 28 WASTE MANAGEMENT PLAN 5.5. COLLECTION AND STORAGE OF WASTES Wastes will be collected and temporarily stored at the Waste Collection Points (WCP) in line with a procedure providing safety and awareness about environment. Suitable waste containers will be made available at the waste generation points in order to facilitate safe and environmentally sensitive temporary storage. All the containers will clearly be marked according to their contents. Waste collection frequencies will be minimum twice a day and more in windy weather, depending on weather conditions. At the end of each working day, the person in charge of each team will be sure before leaving the area of activities for which he / she is responsible that the area is left clean and that wastes generated have been transported to the Waste Collection Areas in line with this plan. 5.5.1. WASTE COLLECTION AND TEMPORARY STORAGE POINTS WCP’s will have separate storage containers for major recyclable materials (plastics, glasses, ferrous and non ferrous metals) and for other wastes such as oils, chemicals and batteries requiring sorting. Care will be paid to ensure that chemicals are held in separate containers to prevent any chemical reaction. 5.5.2. WASTE TRANSPORTATION Wastes will be transported from waste generation locations / temporary depots by enclosed special vehicles in a manner not polluting the environment in respect of appearance, odor, dust, leakage and other similar factors. Collection operations will be scheduled as frequent as required to prevent excessive accumulation of wastes. Properly licensed companies will be hired for transport of hazardous wastes. 5.6. MONITORING WASTE MANAGEMENT ACTIVITIES Movements of wastes from the Waste Collection Points (WCP’s) will be monitored and documented by Sanko and the contractor, with the following information taken under record:  Identification of WCP’s  Dates of collection  Times of collection  Type(s) of waste  Definitions of wastes to an extent containing information on their physical / chemical properties and relative rates as required  Volume(s)  Particular waste management procedures  Vehicle control  Load safety control SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 25 / 28 WASTE MANAGEMENT PLAN  Name and signature of WCP chief  Identification of destination for the disposal plant  Date of delivery  Time of delivery  Checking differences between the type(s) and volume(s) of wastes  Name and signature of vehicle driver Records will also be maintained on the transport of waste water from the impermeable cess pit tanks located on the site to Manisa Municipality Treatment Plant. 5.7. INSPECTION AND AUDIT Any Waste Collection Points (WCP) for waste management as well as any designated Landfill areas and any other relevant facilities will periodically be inspected and audited in terms of compliance with the established operating procedures, regulation requirements and project policies. Appendix 1 provides “Checklist for Waste Management Inspection and Audit Control” to be used by Environmental Inspectors. Inspection forms will be developed for this purpose. Inspection records will be maintained and they will be kept ready for inspection of Sanko by the regulatory authorities in Turkey. APPENDIX 1 Check-List for Waste Management Inspection and Audit SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 26 / 28 WASTE MANAGEMENT PLAN SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 27 / 28 WASTE MANAGEMENT PLAN To be completed as follows 0 1 2 Subject of the Inspection Checklist Needs Compliant or Needs immediate not attention attention applicable 1 Are hazardous and non-hazardous wastes segregated? 2 Does the waste inventory indicate the source of waste? Does the waste inventory have records on the dates, times 3 and shipment reference numbers of waste transfers? Does the waste inventory have records on the types of 4 wastes? Does the waste inventory have records on the volumes of 5 wastes disposed? Does the waste inventory have records on the destination of 6 wastes and the name and telephone number of transport company hired? Does the waste inventory have records on the methods of 7 disposal for respective types of wastes? Does the waste inventory have records on the copies of the 8 National Waste Transport Forms? 9 Are all the wastes stored on the designated storage sites? Are there any signs of leakage / dripping out of waste 10 containers? Do the waste containers have any signs of corrosion or 11 damage? Are the waste depots are fenced off (by fences, barriers, 12 etc.) ? Are wastes stored in a safe manner such that they may not 13 be disturbed by animals? Are all the containers compatible for the wastes they 14 contain? 15 Are the covers of the waste containers closed? 16 Are solid and liquid wastes stored separately? SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 28 / 28 WASTE MANAGEMENT PLAN Are the waste containers labeled according to the wastes 17 they contain? 18 Are there any worn labels? Are there National Waste Transport Forms for all the wastes 19 going to disposal plants? Are the National Waste Transport Form signed by the 20 persons in charge? Is the contractor registered with the Ministry of Environment and Forestry as a Generator of Hazardous 21 Wastes and is it aware of its obligation to prepare and submit waste declarations to the ministry every year? Are there any dedicated areas for washing transmixers? Is 22 washing water discharged into surface water? Are there any sedimentation pools near the concrete mixing 23 plants? Are the sign posts in place around the concrete washing zones? Are the employees interviewed by you trained on waste 24 management? Are the employees interviewed by you aware of their 25 responsibilities regarding waste management? Has the contractor sub-let transport of waste to the disposal 26 plants? If yes, a. Does the sub-contractor hold a valid waste transfer license? Has the contractor ever visited the waste disposal plant? 27 Has it ever inspected such a plant? 28 Are all the records maintained and filed? SANKO GEOTHERMAL POWER PROJECT EFFLUENT MANAGEMENT PLAN Revision Version Date Prepared by Checked by Approved by Muhsin Dervişoğulları General Manager of Geothermal Project Manager Environmental Manager Investments January 10, 2018 Draft A.0 Revision Codes: A: Draft, B: Final Draft, C: Final January 2018 SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 2/8 EFFLUENT MANAGEMENT PLAN 1. S C O P E AN D O B J E C T I V E The Effluent Management Plan (EMP) defines any potential discharge or leakage likely to occur during drilling, construction and operation of Sanko Geothermal Power Plant Project and incorporates appropriate effluent management methods for collection, storage, discharge. The effluents covered by EMP are generated by the following activities:  Drilling activities,  Well testing,  Both provisional and permanent housing (used during construction),  Operation activities. EMP defines the method of management of effluents during drilling, construction and operation of the project including:  how to minimize potential impacts on human health and environment,  how to achieve compliance with the Turkish regulations and the environmental targets of Sanko,  how to maintain this possibilities and means for reducing operating costs and any potential obligations. This plan also guarantees that the effluents will be managed in a proper manner. 1.1. STRUCTURE OF THE EFFLUENT MANAGEMENT PLAN EMP covers the following headings in addition to this part, which is of an introductory nature containing the definitions of the terms and a glossary thereof:  Applicable policies and standards,  Approved effluent management facilities,  Geothermal water collection ponds,  Mud pits,  Effluent management measures and procedures. 1.2. DEFINITIONS Effluent Management Structures built to process effluents or store and reinjection them temporarily or Facility permanently. Effluent management Collection, temporary storage, re-injection of effluents produced during drilling, well testing and power plant operation activities. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 3/8 EFFLUENT MANAGEMENT PLAN Effluents Any hot water produced during well testing and power plant operation activities. Project Sanko Geothermal Power Plant Project. Hazardous wastes Any substances or objects defined by the Turkish laws (Regulation on the Control of Hazardous Wastes dated March 14, 2005, and Regulation on Waste Management dated 23.03.2017) SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 4/8 EFFLUENT MANAGEMENT PLAN 2. AP P L I C AB L E P O L I C I E S AN D S T AN D A R D S 2.1. ENVIRONMENTAL POLICIES OF SANKO A number of policies have been identified by Sanko to provide guidance over any operations carried out. The Declaration of Policy provided below covers the policy underlying the environmental operations:  Sanko Geothermal Power Plant Project is a scheme attaching priority to the preservation of environment.  Sanko is responsible for elimination or proper minimization of all the potential adverse effects of the project on environment during implementation of good environmental administrative methods. Accordingly, all the works will be carried out in compliance with applicable environmental laws and regulations as well as with international engineering approaches and standards in general such that environment is preserved and its quality enhanced. In order to attain this goal, Sanko will:  conduct top management reviews and inspections on an annual basis as a minimum for the purpose of achieving conformity to any established policies, procedures and applicable environmental laws and regulations,  maintain a commitment to pollution prevention, and shall incorporate such principles in any definitions of project conditions and performance of project operations,  define, evaluate and manage any environmental risks, exerting its best efforts to determine and review objectives and targets for operation thereof and minimize the risks of occurrence of any adverse environmental effects,  be committed to building relationships with authorities, the scientific community and the public to promote the development and communication of innovative, cost effective solutions to environmental problems;  ensure a commitment to the continuous improvement of the Environmental Management System wherever possible and sustainable. All Project personnel shall be individually and collectively responsible for adherence to, and effective application of the policies and principles contained in this environmental policy statement. 2.2. EFFLUENT MANAGEMENT LEGISLATION The elements of the Turkish legislation referred to below closely relate to management of effluents which would occur during the project drilling, well testing and operation and this legislation must be complied with strictly. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 5/8 EFFLUENT MANAGEMENT PLAN Official Gazette Official Legislation Implications for the Project Stages Date Gazette Issue 02.04.2015 29314  Discharge of effluents generated Waste Management during drilling and operation of power Regulation 23.03.2017 30016 plant 31.12.2004 25687  Discharge of effluents generated Water Pollution during drilling and operation of power Control Regulation 10.01.2016 29589 plant Regulation on the Construction of  Septic tanks for the collection of Septic Tanks at 19.03.1971 13783 domestic wastewater generated at Places Where construction and operation stages Sewer Construction is Not Feasible Regulation on the  Odorous emissions generated Control of Odorous 19.07.2013 28712 during the operation stage Emissions Regulation on Soil Pollution Control 08.06.2010 27605  Risks of soil contamination at and Point Source 11.07.2013 28704 construction and operation stages Polluted Areas Regulation on the Control of 18.03.2004 25406  Transportation and disposal of Excavation Soil, excavation waste and construction debris Construction and 26.03.2010 27533 at the construction stage Debris Wastes Law on Occupational Health 20.06.2012  Health and safety measures to be and Safety (6331) 01.07.2017 28339 taken during construction and operation (as amended with stages the Law numbered 7033) Regulation on Monitoring of 11.02.2014 28910  Control of effluents Surface water and Groundwater Regulation on Monitoring of  Control of effluents to protect Groundwater 07.04.2012 28257 groundwater Against Pollution and Deterioration SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 6/8 EFFLUENT MANAGEMENT PLAN 3. EFFLUENT SOURCES AN D S T R E AM S DURING PROJECT AC T I V I T I E S AN D M AN AG E M E N T O F E F F L U E N T S Geothermal Water After and During the Drilling Operation: Exploration Wells are conducted in order to prove the commercial viability of potential resources. These Exploration Drillings are the same for both the production wells and reinjection wells. Type of the wells is decided according to the efficiency assessment of the wells based on properties such as temperature, flow rate and pressure. During the drilling operation, liquid drilling mud which is the mixture of different type of chemicals with water will be employed in order to carry rock cuttings to the surface and also lubricate and cool the drill bit. Impacts of drilling mud is provided in the following section. Rotary drilling is used for the wells within the scope of the Project. Casings of three different diameters were employed during drilling of wells which have diameters of 20’’, 13 3/8’’ and 9 5/8’’. At the end 7’’ slotted production liners are employed to convey the geothermal fluid to the surface. Cement is applied around the casings and in this way in order to contain the geothermal fluid is contained and uncontrolled generation of geothermal fluid or vapour is prevented. The casings at shallow depth prevent loose near-surface material collapsing into the well and casings with intermediate diameter will support successive wellheads. Casings and concrete wall around casings prevent groundwater and geothermal fluids intervene with each other. No discharge to aquifer will occur due to Project activities. It is planned to extract 420 tonnes/hour geothermal fluid for 15 MW capacity from wells with a depth of 2500-3000 meter depth. Geothermal fluid extracted from the production wells will be reinjected to the original reservoir through reinjection wells. If the distance to the re-injection wells is provided in the new drilled wells, it is injected to the re-injection well during the test. If the distance of this line is not suitable, new pond is constructed and covered with geo membrane (material is EPDM) near the well site until the test capacity in an appropriate region is reached and the test process is carried out. Then this accumulated water/brine is evaporated. It is planned to construct an impermeable collection pond to be used in case of any failure during reinjection, operation of the power plant or during maintenance of the wells. The capacity of the collection pond is planned to be 1400 m3 with the estimation of use of 1400- 1500 tonnes/hour geothermal fluid at maximum for a potential capacity increase of the power plant to 50 MW. The capacity of the pond is calculated based on the estimation that the system will stop maximum for 1 hour duration. If the volume of the collection pond is exceeded due to malfunction, extraction of geothermal fluid will be stopped. Geothermal fluid collected in the pond will be reinjected back to the system by reinjection pump. Geothermal fluid discharge to any kind of environment will be prevented during the whole Project lifetime. Drilling Mud: SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 7/8 EFFLUENT MANAGEMENT PLAN Drilling mud will be generated as a result of drillings. Drilling mud will be elevated to the ground collecting solid particles. Drilling mud will be sieved for foreign substances and then passed through solid-liquid separator (decanter). Liquid part is pumped back to the mud tankers to be reused. Solid substances on the other hand, are sent back to waste mud pit. The solid material passing through the decanter has some amount of water content therefore collected as liquid waste in the drilling mud pit. Liquid drilling mud is settled in the pit providing solid substances to deposit. For the Project 100 lt of drilling mud is expected to be generated for 1 m drilling. Average depth of the drilling wells is estimated to be 2,500 m therefore the amount of drilling mud at each drilling location is calculated as follows: Amount of drilling mud: 100 lt/m x 2500 m=250,000 lt= 250 m3 Mud pits with dimensions 60 m x 6.5 m x 3 m with side slope are established for storage of mud at each drilling location. Each pit is covered with impermeable material such as geomembrane and has 1,170 m3 capacity which is above the calculated value above. Mud collected in the mud pit is settled providing the deposition of solid substances. Waste mud is analyzed for categorization according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery (dated 2012/15) and the Regulation on Landfill of Wastes (Official Gazette dated 26.03.2010, no: 27533). If the waste is deemed hazardous waste, it will be disposed according to the requirements of the Circular on the Disposal of Drilling Mud and Wastes Generated from the Physical Treatment of Chromium Minery. If the waste mud is determined as inert and/or non-hazardous waste then the mud pits will be filled with excavation debris and covered with the vegetative soil which was stripped and stored separately during land preparation. After the drilling mud is deposited, remaining water on the mud is evaporated or discharged by vacuum truck if drilling mud is determined as non-hazardous or inert. If the mud is classified as hazardous then the water on the mud is collected into IBC tank and disposed according to the requirements the Regulation on Waste Management. Geothermal Water After Geothermal Power Plant Started-Up : Spent geothermal fluids generated during operation will be re-injected to the reservoir rock formation, resulting in minor effluent volumes involving reject waters. Potential contaminants in geothermal effluents will vary according to the mineralogy of the host geological formation, temperature of the geothermal water, and site-specific facility processes (IFC EHS Guidelines for Geothermal Power Generation). Potential for contamination of groundwater will be minimized by installation of leak-proof well casings in the injection wells to a depth to the geological formation hosting the geothermal reservoir. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 8/8 EFFLUENT MANAGEMENT PLAN After the power plant has been started up; in the short term breakdown of the plant, all of the fluid (1500 m3 pond capacity is enough to carry the available fluid capacity for 3-4 hours) is given to the emergency fluid pond in order to keep the production lines heat. If the trouble longer than capacity, power plant is shut down. After that this pond is injected to re-injection wells. In the event of emergency discharge of geothermal water to surface waters, geothermal water will be discharged into a retained in a thermal pond, where the temperature of water will drop to allowable limits set by the Water Pollution Control Regulation. The storage pond will be lined and of sufficient size to allow for storage and required cooling to be carried out for the potential duration of the reinjection failure. The impact of any potential failure of the reinjection system within the Project area can be effectively managed through good design, regular monitoring and development of appropriate emergency responses. Given that a critical failure of the pipeline is extremely unlikely and with a well-prepared management and monitoring plan in place, the residual impacts can be assessed as low. Groundwater quality monitoring will be conducted at downstream of geothermal fluid storage ponds and reinjection wells quarterly. Upon DSI approval two locations will be established within the license area and temperature and EC will be monitored in groundwater through installed automated monitoring systems. SANKO GEOTHERMAL POWER PROJECT HAZARDOUS CHEMICALS MANAGEMENT PLAN Revision Version Date Prepared by Checked by Approved by Muhsin Dervişoğulları General Manager of Geothermal Project Manager Environmental Manager Investments January 10, 2018 Draft A.0 Revision Codes: A: Draft, B: Final Draft, C: Final January 2018 SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 2 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 1. INTRODUCTION 1.1. PURPOSE The purpose of Hazardous Chemicals Management Plan (HCMP) is to outline aspects associated with the management of chemicals at Sanko Geothermal Power Plant Project area. This includes purchasing, safe use, storage, management, transportation and disposal of chemicals. The chemicals covered by HCMP are used by the following activities:  Drilling activities,  Operation activities. 1.2. AIM The aim of this document is to outline Sanko Geothermal Power Plant Project’s process and expectations for managing chemicals and their associated risks to ensure:  That arrangements are in place to minimize the risk of adverse health effects and protect the safety of staff and contractors,  The mitigation of adverse environmental impacts; and  Compliance with Turkish and World Bank Regulations. 1.3. SCOPE This document applies to all Project activities by staff and contractors who are required to use chemicals and/or controlled substances within the scope of their duties. The Chemical Management System is intended for the use of chemicals such as, but not limited to, hazardous substances/chemicals, dangerous goods and otherwise controlled substances. This document should be used in conjunction with other ESIA and sub-plans prepared for Sanko Geothermal Power Plant Project. This document has been developed in line with Turkish and World Bank Regulations. This management plan outlines appropriate hazardous chemicals methodologies for:  Storage;  Handling;  Transport; and  Disposal. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 3 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN Through the management of these aspects potential health and safety effects will be minimized and environmental risks will be reduced. This plan also guarantees that the chemicals will be managed in a proper manner. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 4 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 2. E N V I R O N M E N T AL AS P E C T S The storage and use of hazardous chemicals within the Project footprint presents a number of potential environmental risks including discharge to the environment, impacts on human health, fire and explosion. Adverse effects resulting from poor management practices associated with hazardous substances can include:  The contamination of surface and groundwater, soils and air;  Damage to the environment and ecosystems that can be short term or long term in nature; and  Damage to human health and wellbeing (short term and long term). SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 5 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 3. H AZ AR D O U S C H E M I C AL S M AN AG E M E N T L E G I S L AT I O N The elements of the Turkish legislation referred to below closely relate to management of chemicals which would occur during the project drilling, well testing and operation and this legislation must be complied with strictly. Official Gazette Official Legislation Implications for the Project Stages Date Gazette Issue 02.04.2015 29314  Storage and Dispose of chemicals Waste Management generated during drilling and operation of Regulation 23.03.2017 30016 power plant Hazardous  Storage and Dispose of chemicals Chemicals 18.01.2008 26760 generated during drilling and operation of Regulation power plant 31.12.2004 25687  Storage and Dispose of chemicals Water Pollution generated during drilling and operation of Control Regulation 10.01.2016 29589 power plant Regulation on the  Odorous emissions generated Control of Odorous 19.07.2013 28712 during the operation stage Emissions Regulation on Soil Pollution Control 08.06.2010 27605  Risks of soil contamination at and Point Source 11.07.2013 28704 construction and operation stages Polluted Areas Law on Occupational Health 01.07.2017  Health and safety measures to be and Safety (6331) 28339 taken during construction and operation (as amended with stages the Law numbered 7033) Regulation on Monitoring of 11.02.2014 28910  Control of disposal Surface water and Groundwater Regulation on Monitoring of  Control of chemicals to protect Groundwater 07.04.2012 28257 groundwater Against Pollution and Deterioration SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 6 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 4. AP P L I C AB L E P O L I C I E S AN D S T AN D A R D S 4.1. ENVIRONMENTAL POLICIES OF SANKO A number of policies have been identified by Sanko to provide guidance over any operations carried out. The Declaration of Policy provided below covers the policy underlying the environmental operations:  Sanko Geothermal Power Plant Project is a scheme attaching priority to the preservation of environment.  Sanko is responsible for elimination or proper minimization of all the potential adverse effects of the project on environment during implementation of good environmental administrative methods. The storage, use and management of hazardous chemicals within the Project footprint are subject to the following environmental standards:  Regulations issued by Turkish Official Gazette related to; • Storage, Use and Disposal, • Appropriate design to prevent / reduce the potential for any accidental spillage or leak of hazardous substances, • Containers are appropriately labelled to identify potential hazards.  Transportation of hazardous substances must be performed in accordance with the Related Regulation, • Ensure the Emergency Response Plan is in place to provide the framework to manage any incidents involving hazardous substances.  Training systems implemented to provide appropriate training on the handling, storage and use of hazardous substances. The use, storage, transportation and disposal of hazardous chemicals are managed under the control of Sanko. The Act for hazardous chemicals of Sanko deals with the safe management of all hazardous substances. Hazardous substances are substances that are explosive, flammable, oxidizing, toxic, corrosive, or harmful to the environment. Accordingly, all the works will be carried out in compliance with applicable environmental laws and regulations as well as with international engineering approaches and standards in general such that environment is preserved and its quality enhanced. In order to attain this goal, Sanko will:  conduct top management reviews and inspections on an annual basis as a minimum for the purpose of achieving conformity to any established policies, procedures and applicable environmental laws and regulations, SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 7 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN  maintain a commitment to pollution prevention, and shall incorporate such principles in any definitions of project conditions and performance of project operations,  define, evaluate and manage any environmental risks, exerting its best efforts to determine and review objectives and targets for operation thereof and minimize the risks of occurrence of any adverse environmental effects,  be committed to building relationships with authorities, the scientific community and the public to promote the development and communication of innovative, cost effective solutions to environmental problems;  Ensure a commitment to the continuous improvement of the Environmental Management System wherever possible and sustainable. All Project personnel shall be individually and collectively responsible for adherence to, and effective application of the policies and principles contained in this environmental policy statement. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 8 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 5. M AN AG E M E N T H I E R AR C H Y O F H AZ A R D O U S C H E M I C AL S The management of hazardous chemicals at Project is undertaken in general accordance with the hierarchy of control. The hierarchy of control for hazardous substances is as follows:  Elimination and removal Eliminating either the substance or the activity which gives rise to the risk is the most effective  Form of risk reduction.  Substitution Substituting high risk products or activities with alternative lower risk products or activities will reduce overall risk exposure.  Isolation, enclosure or sealing Hazards may be isolated by distance or barriers or a combination of both.  Engineering controls Engineering controls involve making engineering changes to a process or piece of equipment used to store or handle hazardous substances.  Safe work practices (administrative controls) Administration controls consist of properly designed and implemented work practices and procedures.  Personal protective equipment (least preferred) PPE is considered the last line of defense against hazardous substances. Material Safety Data Sheets (MSDS) normally contain recommendations on the selection and use of PPE for the particular materials being used. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 9 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 6. C H E M I C AL S U S E D F O R P R O J E C T Chemicals used for the Project during Drilling, construction and operation phases are listed below. Table includes Producers, name and Globally Harmonized System (GHS) codes of chemicals. PRODUCER NAME OF CHEMICALS GHS CODE Sulfuric acid for 1000 ml, c(H₂SO₄) = 0.005 mol/l (0.01 Merck N) Titrisol® Hach Lange Iron Reagent Powder Pillows, 0.02-3.00 mg/L Fe GHS-05, GHS-07, GHS-08 Tekkim Phenolphthalein indicator GHS-08 Tekkim Potassium Chromate Extra Pure GHS-08, GHS-07, GHS-09 Tekkim Metil Oranj GHS-06 Hach Lange Buffer solution Hardness 1 pH 10.1 ± 0,1 GHS-07 Hach Lange Acid Reagent GHS-05, GHS-07 Hach Lange ManVer 2 Hardness Indicator GHS-08, GHS-07 Hach Lange Molybdate Reagent - Hach Lange Citric Acid GHS-07 Norateks GHS-05 kimya 6M NaOH (Sodium Hydroxide) Hydrochloric acid c(HCl) = 1 mol/l (1 N) Titripur® Reag. Merck GHS-05 Ph Eur,Reag. USP Merck c(NaOH) = 1 mol/l (1 N) Titripur® GHS-05 Merck 0,01N Titriplex III Solution Silica Gel Hach Lange Sulfate, SülfaVer Reagent GHS-07 Hach Lange Ammonium cuvette test 2.0-47.0 mg/L NH4-N GHS-05, GHS-07, GHS-09 Merck %65 HNO3 GHS-03, GHS-05 Hach Lange Sulphide cuvette test 0.1-2.0 mg/L S2- GHS-05 Hach Lange 1,600N Sulfuric Acid GHS-05 Hach Lange 3,636N Sodium Hydroxide GHS-05 Silver nitrate solution for 1000 ml, c(AgNO₃) = 0.1 Merck GHS-05, GHS-09 mol/l (0.1 N) Titrisol® Hach Lange Phenolphthalein indicator GHS-08 Hach Lange Bromkrezol Yeşili-Mtil kırmızı Indicator Hach Lange 0,3636N Sodium Hydroxide GHS-05 Hach Lange 0,1600N Sulfuric Acid GHS-05 %96 Pure Ethyl Alcohol GHS-02 WTW Ph-Meter ph:7.00 calibration solution WTW Ph-Meter ph:10.00 calibration solution WTW Ph-Meter ph:4.01 calibration solution WTW Conduct meter calibration solution 0,01 mol/l KCl WTW ph probe electrolyte solution 3mol/l KCl çözeltisi Merck ph probe electrolyte solution 3mol/l KCl çözeltisi SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 10 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 7. L AB E L L I N G , M O N I T O R I N G AN D I N C I D E N T N O T I F I C AT I O N 7.1. LABELLING Hazardous substances will be labelled including the following information:  Product identified and chemical ingredients;  Name, address and business telephone number (manufacturer or importer);  Hazard pictograms;  Hazard statement;  Hazard, first aid and emergency procedures; and  Expiry date (if applicable). 7.2. HAZARD PICTOGRAMS The hazard pictograms in relation to the hazardous substances shows potential impact to physical, heath and/or the environment. Hazard pictogram will be located on all hazardous substance containers. A summary of hazardous pictograms and associated dangerous goods class labels are provided in Table below. HAZARD PICTOGRAMS SYMBOL AND GHS CODE HAZARD Exploding Bomb (GHS-01)  Explosives  Self-Reactives  Organic Peroxides Flame (GHS-02)  Flammables  Pyrophorics  Self-Heating  Emits Flammable Gas  Self-Reactives  Organic Peroxides Flame Over Circle (GHS-03)  Oxidizers SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 11 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN  Gases Under Pressure Gas Cylinder (GHS-04) Corrosion (GHS-05)  Skin Corrosion/Burns  Eye Damage  Corrosive to Metals Skull and Crossbones (GHS-  Acute Toxicity (fatal or toxic) 06)  Irritant (skin and eye)  Skin Sensitizer  Acute Toxicity (harmful) Exclamation mark (GHS-07)  Narcotic Effects  Respiratory Tract Irritant  Hazardous to Ozone Layer (Non-Mandatory) Health Hazard (GHS-08)  Carcinogen  Mutagenicity  Reproductive Toxicity  Respiratory Sensitizer  Target Organ Toxicity  Aspiration Toxicity  Aquatic Toxicity Environment (Non-Mandatory) (GHS-09) SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 12 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 8. MONITORING 8.1. HAZARDOUS SUBSTANCES INVENTORY Data Collected The inventory includes the following information:  Site and location;  Name, position and date;  Commercial Name;  Chemical Composition;  Volume (L / kg / m3);  State (solid, liquid or gas);  Safe fill volume (L / kg / m3);  Maximum capacity (L / kg / m3);  Container type; and  Hazardous substance / dangerous goods classification. Frequency Hazardous substance inventories will be updated frequently and when new substances not previously listed within the inventory are brought onto site. 8.2. MATERIAL SAFETY DATA SHEETS REGISTER In addition to hazardous substance inventories, all product Material Safety Data Sheets (MSDSs) will be maintained at both storage locations and the Site Office. The MSDS register will be updated as new hazardous substances are brought to site. 8.3. LEAKAGE OR LOSS IDENTIFIED Should a chemical leak, spill or other cause of discrepancy be detected the following will be undertaken:  If required, take action as soon as practicable to prevent any further release of product or used chemicals into the environment;  Identify and mitigate any fire, explosion or vapor hazards;  Take all reasonable steps to prevent migration of product that has leaked or spilled;  Take all reasonable steps to recover or remove product that has leaked or spilled so that the site does not pose any threat to the environment or human health and safety; and  Remove or, where practical to do so, repair any leaking components of the storage container. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 13 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN 9. H AZ AR D O U S C H E M I C AL S M AN AG E M E N T Hazardous chemicals management will be undertaken in accordance with this plan. Management of hazardous substances risk is structured below as follows:  Key Activities, Risks and Impacts: A summary of the key activities being undertaken during the management period. The potential environmental impacts and residual risk levels are identified for each environmental aspect.  Objective: The guiding environmental management objective(s) and activities that apply to the element.  Mitigation Measures: The procedures to be employed to ensure that the relevant objectives are met.  Responsibility: Nominates the responsible position for implementing actions and monitoring.  Trigger, Action, Response: The actions to be implemented in the case of noncompliance. This includes strategies of remediation and the person(s) responsible for the actions. 9.1. KEY ACTIVITIES, RISKS AND IMPACTS The key activities and potential environmental impacts have been identified for hazardous substances are listed in Table below. Potential Residual Risk Level Activity Environmental Impact Consequence Likelyhood Risk Contaminant to Uncontrolled release, spill or ground resulting in passive discharge of contamination of Minor Unlikely Low chemicals, including through soils and inappropriate storage and groundwater handling. resource. Personnel impacted by fire or explosion. This includes equipment and substance fire and explosions. This may occur during construction or Personnel fatality Catastrophic Rare Medium operations. Personnel or injury. exposed to hazardous materials via all means e.g. ingestion, inhalation or skin contact. Unauthorised site access / Personnel or security breach during third party fatality Major Rare Medium construction and operation. or injury. SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 14 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN The hazardous substances management objectives have been established and are detailed in Table below. OBJECTIVE TARGET INDICATOR Protection of the surrounding No long term impact and/or environmental Number of incidents reported environment from hazardous harm occurring from the release of leading to potential long term substances. hazardous substances. impact and/or environmental harm. Hazardous Substances to be stored Number of hazardous substance appropriately and in accordance with non compliance breaches of legislative standards. legislative standards. 9.2. MITIGATION MEASURES Mitigation measures have been developed to minimize potential impacts associated with hazardous chemicals. The mitigation measures, timing and responsibilities are provided in Table below. MITIGATION MEASURE TIMING RESPONSIBILITY SITE INDUCTION Site induction includes the following components for hazardous Site Induction All personnel chemicals:  Summary of hazardous substance at the project and associated locations;  Summary of hazardous pictograms and dangerous goods code class labels and what they mean;  Requirements for handling and utilizing fuel infrastructure;  No hot works or naked flames allowed within 20 m of flammable substances; and  Procedure for reporting and/or managing a spill. GENERAL Management of hazardous substances in accordance with Drilling, Construction Operation Manager / Turkish and Operation Company Man Standards. Hazardous chemicals to be stored in Chemical Storage Shed Drilling, Construction Operation Manager / with internal bunding to collect spills and ventilation to prevent and Operation Company Man the buildup of fumes. Waste oil and oil filters are to be stored in appropriately Construction All personnel labelled Intermediate Bulk Containers (IBC). All IBCs labelled and Operation and hazard it poses listed on container. The IBC are to be removed from site by a suitably licenced contractor and delivered to a licenced depot. Storage of IBCs will not exceed capacity of secondary Drilling, Construction All personnel containment volume. and Operation Fuel (diesel) storage tanks will meet environmental guidelines Drilling, Construction Operation Manager / for the safe storage. and Operation Company Man Fire extinguishers fitted in site vehicles. Drilling, Construction Operation Manager / and Operation Company Man In general, hazardous substances are to be stored a minimum Drilling, Construction Operation Manager / of 10 m from surface water and 50 m from groundwater wells. and Operation Company Man Storage of flammable and combustible materials will be in Drilling, Construction Operation Manager / accordance with the Hazardous Chemicals Management Plan. and Operation Company Man SANKO ENERGY INDUSTRY AND TRADE CO. Date 10.01.18 SANKO GEOTHERMAL POWER PLANT PROJECT Page 15 / 15 HAZARDOUS CHEMICAL MANAGEMENT PLAN Open flame or other ignition sources are prohibited within 20 m of bulk flammable storage areas, fuel dispensing vehicles or refueling operations and activities in hazardous atmospheres. SPILL MANAGEMENT Spill kits are located at all hazardous substance storage Drilling, Construction Operation Manager / locations. and Operation Company Man Monthly inspections of hazardous substance storage locations Monthly Environmental to ensure facilities meet HSE requirements and spill kits are manager present/contain sufficient materials for potential spillages. In the event of a spill follow the spill management procedure At all times All personnel within the Emergency Response Plan. INSPECTION AND MONITORING The inspection is to update the hazardous substances Monthly /As All personnel inventory. In addition, any new hazardous substances will be required included when they are brought to site. Safety Data Sheets (SDSs) register will be maintained at As required Area Supervisors storage locations and the Site Office. The register will be supplemented when new hazardous substances are brought to site. Spill kits to be inspected on a monthly basis to ensure kits Monthly Safety Officer contain adequate equipment. Environmental Manager Area Supervisors If any leaks, spills or other cause of loss is identified the As required All personnel following will be undertaken:  Take action as soon as practicable to prevent any further release of product or used oil into the environment;  Identify and mitigate any fire, explosion or vapor hazards;  Take all reasonable steps to prevent migration of product or used oil that has leaked or spilled;  Take all reasonable steps to recover or remove product or used oil that has leaked or spilled so that the site does not pose any threat to the environment or human health and safety; and  Remove or, where practical to do so, repair any leaking components. Annual Hazardous Chemical Management Plan performance Annually Environmental review. Manager / Adviser