While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This project has been classified as a Category B project as the environmental and social risks (E&S) and its potential impacts are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

The key E&S issues include: adequate assessment and management of identified risks and impacts including establishment and implementation of an associated EHSS system compliant with IFC’s Performance Standards (PSs); obtaining required permits and licenses; stakeholder engagement, occupational health and safety during construction and operations; emission control; solid and liquid waste management; management of hazardous materials; community security, health and safety.

Although all land plots are purchased on a willing seller willing buyer basis and/or allocated by the applicable municipality, PS5 Land Acquisition and Involuntary Resettlement is considered applicable as there will be government managed land acquisition for the energy transmission lines that will supply energy to the Bilecik project.

None of the project activities are located within the vicinity of a sensitive environmental area, thus PS6: Biodiversity Conservation and Sustainability is not considered applicable. There are no indigenous people in the host country, thus PS7: Indigenous Peoples is not applicable. Based on Environmental Impact Assessment’s (EIA’s) for the various activities there is no known historical and/or cultural heritage within the Project boundaries, therefore PS8: Cultural Heritage is not considered applicable.

Key E&S issues and relevant mitigation measures are described in detail in the paragraphs below. In addition, the client will implement an Environmental and Social Action Plan (ESAP) to achieve compliance with IFC’s PSs.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System and Policy / Identification of Risks and Impacts and Management Program: HKA’s existing EHSS system has been established according to the requirements of the Turkish environmental and social (E&S) legislation and includes impact assessment and risk analysis for the existing and future plant operations. HKA has an internal target to develop and implement an integrated management system in line with the ISO 9001 Quality Management System Standard, ISO 14001 Environmental Management System Standard and OHSAS 18001 Occupational Health and Safety (OHS) Standard for all of its operations and/or activities within 2015. As per the ESAP, HKA will agree with IFC on a time-based plan for each plant for development and implementation of a documented EHSS management system at a corporate level and adapted to each facility, in line with IFC’s PSs, including (but not limited to); (i) a policy; (ii) management programs to mitigate risks and impacts; (iii) organizational capacity and competency; (iv) emergency preparedness and response; (v) stakeholder engagement; and (vi) monitoring and review.



The EHSS management system referenced above will be applicable for all future operations and activities and HKA will keep IFC informed of any potential new activities.



In line with Turkish E&S legislation, EIAs were completed for the Pamukova, Bilecik (including landfill area) and Soke projects and these included an assessment of the following; waste projections, leachate, landfill gas generation (for Bilecik), working conditions during the operational and construction phases, waste management including excavation waste, emissions (i.e., that related to and operations including vehicles, waste water management, ambient noise, odor, resource consumption, geology, climatic conditions in the project location, agricultural profile surrounding the project location, biodiversity including sensitive and/or protected areas nearby, aesthetics and fire risks during construction and operational phases. EIA exemption certificates which state that no further EIA study is to be conducted has been obtained from the local authorities for the Pamukova, Bilecik and Soke projects. For the Odemis project, an EIA will be prepared and submitted to the authorities and as per the ESAP the Company will provide a copy to IFC of the Ministry of Environment’s decision on the EIA for Odemis.



In line with Turkish Occupational Health and Safety (OHS) legislation, risk assessments that related to explosions, excavations, health hazards during the operational phase, ergonomics, exposure to diseases, traffic accidents, working with rotating equipment, hand traps, falls, slips, etc. were conducted for the Pamukova project’s operational phase, and for Bilecik and Soke project construction phases. These assessments were conducted by a team of employees from relevant departments and OHS experts. As per the ESAP, HKA will agree with IFC on a
time-based plan for each plant to conduct and provide a copy to IFC of the risk assessments including mitigation measures that related to; i) Pamukova’s construction phase; (ii), Bilecik and Soke’s construction and operational phases; and (iii) Odemis’s construction and operations in line with both Turkish OHS legislation and IFC’s PS requirements.



At the time of the appraisal, HKA has made submission in respect of several permits and/or licenses including construction permits, environmental permits, energy production permits and fertilizer production licenses. In addition, on the basis that the compost and / or fertilizer will be used in a food manufacturing process, a Hazard Analysis and Critical Control Points (HACCP) system i.e., a certifiable system for food safety has been implemented at the existing Pamukova facility and is to be implemented for new projects. As per the ESAP HKA will agree with IFC on the reporting template to update IFC on a quarterly basis as to progress of the permit and/or license applications.



Organizational Capacity and Competency: HKA has a corporate level human resources department responsible for recruitment, development of the orientation program, development of ongoing training plans and performance evaluation. The facilities will have local human resource departments which will prepare weekly/monthly employee reports, creating employee records on the system, filing all employee documents and assisting with payroll and organizing trainings. There is an “A” certified OHS expert at the corporate level who is responsible for conducting risk analyses, developing and monitoring mitigations plans, reporting on OHS performance to management on a monthly basis, and to supervise HKA’s employees and operations. The OHS expert also conducts OHS trainings to staff as a part of the on boarding program and periodical training plan. HKA’s management confirmed that each facility will have a dedicated OHS expert. There are 11 environmental engineers in the existing Pamukova facility, responsible from routine and/or daily plant operations, and to supervise HKA’s staff on E&S issues. In future, there will be approximately 15 environmental engineers in Pamukova, 12 in Bilecik, 10 in Soke and 10 in Odemis during the operational phase.



Emergency Preparedness and Response: Pamukova has a documented emergency preparedness and response plan that includes a focus on earthquakes, firefighting, first aid, explosion, traffic accidents, floats, evacuation, chemical spills, external communication during the emergencies, and search and rescue. Fire exercises and evacuations drills are conducted twice a year whereas float and injury exercises are performed annually at Pamukova. The emergency response team consists of more than 50 employees in Pamukova. A similar system was developed for Soke and HKA will adapt these plans to the Bilecik and Odemis projects. Smoke detectors and foam/gas type sprinklers were installed in the existing
Pamukova facility throughout the plant. The fire system includes 2 pumps (1 diesel, 1 electrical) and water reservoir for firefighting and there are alarms and stationary monitoring devices for smoke and gas detection in the plant; no emergency incidents including fires have occurred in the last 3 years at the existing Pamukova facility. HKA has incorporated Turkish life and fire safety legislation requirements into its design for the new facilities.



In order to avoid conditions that can lead to spontaneous combustion; compost in the windrows will be kept around a maximum 3-4 meters high and the temperature will be monitored online in order to increase the composting efficiency as well as for turning the compost to control the temperature to ensure it is less than 600C.



Monitoring and Review: HKA has a system in place to monitor and review key performance indicators (KPIs), including ambient and workplace noise levels, vibration, workplace dust, received waste amounts, mixed waste rate, fuel consumption of the facility and/or collection vehicles and incident rates. The environmental performance is reviewed twice a year during management review meetings; whereas OHS performance is reviewed during monthly OHS committee meetings where senior management is present. Corrective / preventive actions are planned if needed.



Stakeholder Engagement / External Communication and Grievance Mechanism and Ongoing Reporting to Affected People: Although there is no structured stakeholder engagement plan for Bilecik, Soke and Odemis, as a part of a carbon credit study to be certified against The Gold Standard, (an internationally accepted standard for creating high-quality emission reductions projects in the Clean Development Mechanism (CDM) Joint Implementation (JI) and Voluntary Carbon Market, developed in 2003 by a group of non-governmental organizations including the World Wide Fund for Nature (WWF), SouthSouthNorth, and Helio International) a Local Stakeholder Consultation Report was prepared for the existing Pamukova facility. HKA is planning to develop a similar stakeholder engagement plan and reports for Bilecik, Soke and Odemis. Although there is a documented system related to customer demands and complaints, there is no formalized external grievance mechanism to cover all interested parties. Since 2013, the existing system recorded a total of approximately 300 requests and complaints from Pamukova, Soke and Odemis combined. Requests and complaints mainly related to requests for additional waste bins and transportation of full bins, and all have since been responded to and closed out. As per the ESAP, HKA will agree with IFC on a time-based plan for each plant to develop and implement an agreed Stakeholder Engagement Plan that is aligned with IFC’s requirements. This will include a documented external grievance mechanism where interested parties, other than the customers, can raise and register their concerns.

Working Conditions and Management of Worker Relationship: At the time of the appraisal, HKA employed 243 employees for the existing facility in Pamukova of whom 25% are females. When all the projects are operational, the number of employees will be around 1,100 in total (including the waste collection vehicle drivers) where 305 will be employed in Pamukova, 285 in Bilecik, 30 in Pazaryeri (Bilecik Fertilizer), 220 in Soke, 220 in Odemis and 40 in Odemis (or Ortaklar). The turnover rate was around 5% per year for the last three years. There will be no temporary workers and / or seasonal changes in the work force.



HKA has a documented HR policy and procedures including recruitment, performance evaluation, career development, training and company rules. There are policies and procedures against all kinds of harassment and discrimination on the basis of personal beliefs or other characteristics unrelated to a person’s ability to perform his/her duty. Vacation allowances are documented in procedures, and in the terms of employment. HKA’s management stated that there is no prohibition or discouragement of freedom of association in line with Turkish Labor law; though currently there are no unionized employees and no collective bargaining agreement.



There is a documented formal internal grievance system in place, including use of suggestion/complaint boxes distributed throughout the Pamukova facility which allow for anonymous reporting. The system received almost 50 suggestions/complaints in 2013 and 2014. All suggestions and complaints, as well as progress on the mitigations plans developed to address them, are periodically reviewed by senior management; either during the monthly Occupational Health and Safety meeting and/or at the time of bi annual staff performance reports. A similar system will be used in Bilecik, Soke and Odemis and annual employee satisfaction surveys will be conducted starting from 2015.



Retrenchment is not anticipated as the business is growing.



Protecting the Work Force: In line with the national laws, HKA does not employ child or forced labor.



Occupational Health and Safety: HKA has an OHS system in place in line with Turkish legal requirements, and these include periodic risk analysis, OHS training, documented job descriptions, periodical inspections of the equipment and work place monitoring.



HKA has an incident reporting and investigation system in place that covers both actual incidents as well as near misses. In 2013, at the existing Pamukova facility, the lost time injury frequency rate (LTIFR, number of injuries per million work hours) was 60, an increase when compared to 31 in 2012 and 40 in 2011. Although there is no benchmark data for the industry, these LTIFRs are higher than the benchmarks for similar sectors (reference: http://www.bls.gov) waste management and remediation services (9.5), waste collection (12.0) and waste treatment and disposal (7.0). The majority of the incidents are hand inju
ries including cuts during segregation / sorting though there have been two incidents resulting in permanent disabilities in the last year.



At the time of the appraisal personal protective equipment (PPE), including safety shoes, goggles, masks and work clothes hard hats, ear plugs, gloves etc., were provided to employees. There are various warning signs displayed throughout the plant including that related to the use of PPE, no smoking and machinery risks. However, goggles were not used by many of the sorting employees.



Periodical workplace OHS measurements including that related to illumination levels, organic gases, dust, noise, and vibration are conducted in Pamukova annually as a part of the existing EHSS system. Mitigation measures are planned if needed. The measurements were in line with Turkish legislation and the WBG’s General EHS Guideline limits. Similar monitoring will be implemented in the new project sites.



Each plant will have its own company doctors who will report to the human resources department. Pre-employment and periodical health tests include respiratory system control, chemicals in blood and urea and audiometry checks. However, there is no specific bio aerosol monitoring at the workplace, as well as workers exposure to bio aerosol particles in the workplace air (bio aerosols are particles in the air consisting wholly or partially of microorganisms which may result in reduced pulmonary function and increased respiratory disease).



Sorting and composting halls as well as the waste unloading building will be equipped with ventilation and eye/body showers will be installed.



There is on boarding EHSS training programs and periodic EHSS training are mandatory for all employees. In Pamukova, EHSS training included topics such as waste collection, waste segregation, organic wastes, first aid, forklift safety, and loader safety.



As per the ESAP, HKA will enhance its existing EHSS system, which will be updated in line with OHSAS 18001 to include; (i) improvements related to the existing incident investigation system to incorporate a more effective root cause analysis system so as to reduce the number of incidents; (ii) development of a program to ensure that required PPE including goggles is used by all employees; (iii) development of a training matrix, in line with the risk analyses and impact assessments to ensure that all employees receive training according to the risk associated with their job descriptions including topics as PPE use, mitigations measures for the risks; (iv) development and implementation of a periodic program for monitoring workplace bio aerosol levels; (v) a review of the adequacy of PPE use versus incidents and risks, and improve the quality of the PPEs, including gloves, if needed; (vi) a program to ensure that the EHSS management system will be applicable to all existing and future activities; and (viii) a documented workplace monitoring program in line with the WBG’s General EHS Guid
eline and WBG’s EHS Guideline for Waste Management Facilities, and relevant Turkish legislative requirements.



Workers Engaged by Third Party: HKA will employ subcontractors for security, catering services and transportation of the employees during operations. For the construction phase, contractors will be hired for the mechanical, electrical and civil works. Contractors will be required to have defined OHS organizational responsibilities, including an OHS expert and HKA’s technical department will be responsible for preparation of the Project specifications, contractor selection and monitoring of the contractor OHS performance. Almost 200 contractors will be employed during construction phase of each facility.



Subcontractors are required, as per contract requirements, to follow Turkish E&S and OHS legislative requirements, including conducting risk assessments, nominating OHS experts and provide EHSS training to employees. Subcontractors are also required as per contract requirements, to follow HKA’s safe working instruction for contractors, which include work permits for specific types of work, incident reporting, emergency response, PPE requirements, machinery and equipment inspections, safe working instructions for working at heights, working with pressurized equipment and that related to hot works. The EHSS performances of contractors, including the lost time injury frequency rate or severity rate (number of lost days per million hours) are not recorded. During the construction period, accommodation will be provided for construction employees at the Bilecik project. As transportation to the other project locations will be relatively easy, there will be no accommodation at other project locations. As per the ESAP, HKA will enhance its EHSS system to; (i) define responsibility within the Company for monitoring contractors’ EHSS performance and reporting to senior management and to relevant departments; (ii) develop a matrix to evaluate contractors EHSS performance, including lost time injury frequency rates (LTIFR number of injuries per million work hours) or severity rates (number of lost days per million hours) and; (iii) review and update contractors contracts for construction to incorporate IFC’s PS2 requirements including accommodation and access to a grievance mechanism.

Resource Efficiency: Electricity will be provided from the national grid for all facilities. It is expected that Pamukova will consume 5.8 million kWh per year, Bilecik 3.7 million kWh per year and the Soke and Odemis facilities around 2.9 million kWh million. Heat required for the anaerobic digesters will be provided from the gensets. The fertilizer plants are expected to consume 15 million kWh/year for the drying process. Biogas generation is expected to be 4.3 million Nm3/year in Pamukova, 5.7 million Nm3/year in Bilecik, 3.8 million Nm3/year in Soke and 3.3 million Nm3/year in Odemis. With the new expansion, the Pamukova facility will have an electricity generation capacity of 9.3 million kWh per year. Bilecik will produce 11.1 million kWh per year, Soke 7.4 million kWh per year and Odemis 6.9 million kWh per year. For the transportation vehicles, it is expected that fuel consumption will be 672,000 liters per year in Pamukova, 530,000 liters per year in Bilecik and will be 314,000 liters per year at Soke and Odemis respectively. The Bilecik fertilizer and Odemis fertilizer plant’s vehicle fuel consumptions is estimated to be 110,000 liters per year of each.



For energy usage the existing Pamukova facility is using that generated via biogas at the facility. For the new facilities, biogas will be also used to generate energy for the facilities and the excess heat will be used for composting and facility heating. For the fertilizer plants at Pazaryeri, and probably in Odemis (or Ortaklar), which will be located some distance from biogas production, natural gas will be used for energy requirements. For the construction period and for the startup operations and during the failures such as breakdowns of the gas engines; energy will be supplied by use of stand by generators and boilers which will consume fuel oil.



All heat from the gensets will be used for heating and for the fertilizer drying processes in Pamukova whereas in Bilecik, Soke and Odemis it will be used for the heating of the facilities. For the hygenization, hot air will be discharged to the last row of the windrows. In Odemis, excess heat is planned to be used for residential heating. At Bilecik the autoclave unit which will be used for hygenization and stabilization of medical wastes, it is planned to use excess heat from the gensets.



Vehicle fuel consumption will be monitored per shift and the routes will be optimized to minimize distance travelled and thus fuel use and emissions.



Water Consumption: Water for domestic usage will be provided by the municipal network. Process water will be provided from an underground well in addition to the municipal network at Pamukova, from the municipal network at Bilecik and from underground wells at Soke and Odemis.



Sorting and segregation plants will have separate storm water collection systems and HKA will be required to perform effluent analysis and provide the results to IFC.



Emissions: Process emissions are generated
from (i) gensets (engines) which will consume biogas to produce electricity and heat where wet scrubbers will be used for biogas treatment; (ii) bio filters and activated carbon filters which are in place at the existing Pamukova plant for air treatment from the waste sorting areas, for the chicken manure building and for the composting hall for odor management, and will similarly be applied for the new projects; and (iii) mainly dust emissions from packaging operations of the compost and/or fertilizer operations where compost and/or fertilizer will be transported by use of conveyors and dust will be collected by a system of filters. The collection and filtration system in the fertilizer and composting operations is expected to improve the ventilation and workplace air quality. In order to mitigate the risk of dust explosion, HKA has an ongoing plan for the replacement and modification of transportation and dosing systems.



At the existing Pamukova plant for the gensets which are 0.6 MW and 0.8 MW respectively, process emissions were measured as 8.4 to 8.6 mg/m3 for particulate material (PM), 67-71 mg/m3 for carbon monoxide (CO), 500-513 mg/m3 for NOx and 0-1.9 mg/m3 for sulphur dioxide (SO2), which are in line with Turkish E&S legislation limits. The WBG’s General Environmental Health and Safety (EHS) Guideline and/or EHS Guidelines for Waste Management Facilities do not set a limit for gas engines, turbines and/or boilers smaller than 3 MW.



For the bio filter and activated carbon, emissions were measured as 5.5 – 6.1 mg/m3 for PM, 2.8 – 5.4 mg/m3 for total organic carbon (TOC), 0.27 – 0.29 mg/m3 for hydrogen sulphate (H2S) and 0.01 – 0.09 mg/m3 for ammonia, which are in line with Turkish E&S legislative requirements.



The standby boiler emissions at Pamukova were measured as 4.9 – 8.1 mg/m3 for PM, 0-19.2 mg/m3 for CO, 34.9 – 185.5 mg/m3 for NOx, and 0 – 247.4 for mg/m3 SO2 which are in line with Turkish E&S legislation and the WBG’s General EHS Guideline requirements.



Green House Gases (GHG): Carbon dioxide (CO2) equivalent emission is estimated to be around 5,000 tpa for Pamukova, 9,000 tpa for Bilecik, 3,600 tpa for Soke and 6,900 tpa for Odemis.



Effluents: At the existing Pamukova facility, process water and domestic wastewater is collected separately. Domestic waste water is transferred by trucks to the municipality’s wastewater treatment plant which is almost 40 km away, in line with an existing protocol. The facility has a package type domestic wastewater treatment plant (SBR type-activated sludge) which is not yet operational as it is awaiting the permit from the local authority; once the permit is received this system will be used to treat domestic waste water .



As per the ESAP, HKA will agree with IFC on a reporting template to update IFC on a quarterly basis on the progress of the permit and/or license applications, including reporting of the status of the discharge permit. Approximately 30 % of the process wa
ter is being recycled to the turbo dissolver (pulper-organic waste preparation unit) and discharged back to the anaerobic digester, 5% - 10 % is used in composting facility when needed, as some compost recipes require more humidity) with the remaining wastewater being transferred by trucks to the municipality’s wastewater treatment plant.



For the new projects, all process related liquid effluents will be collected separately. Approximately 30% will be discharged back to the anaerobic digesters. As this may lead to heavy metals build up in the digester and in the compost, HKA will monitor the metal content in the anaerobic digesters and report to IFC on this (metals monitoring is also required by the Turkish authorities). HKA is also testing reverse osmosis and membrane bioreactor treatment capacities for its process waste water to develop alternative solutions for the use of process water. Domestic waste water will be discharged to the municipal networks in Soke and Odemis. At Bilecik, there will be septic tanks for domestic waste water, where it will be collected and transferred by trucks to the municipality’s wastewater treatment plant.



There will be a leachate collection pond at the Bilecik landfill where the leachate will be pumped back to the landfill for the first three years. After three years, it will be transported and treated by the new municipal waste water treatment plant if the acceptance criteria are met, or a leachate treatment plant will be constructed on site to treat the leachate before it is discharged to the municipality’s treatment plant for the final treatment. As per ESAP, in the event of the Bilecik landfill leachate not meeting the acceptance criteria of the new municipal waste water treatment, HKA will construct a leachate treatment plant on site to treat the leachate before it is discharged to the municipality’s treatment plant for the final treatment. For all of its facilities, HKA will report the amount and quality of the waste water that will be discharged and / or transported to municipality’s network and/or municipality’s waste water treatment plant through AMR.



Collection vehicles will be washed at the end of each shift and waste water will be collected separately. Silt and oil separators will be installed on the discharge points where vehicles are washed. The collected waste water will be discharged as domestic waste water, with the silt disposed of at landfills, and oil disposed and/or recycled by hazardous waste management companies.



During the construction phase in Odemis, Soke and Bilecik, domestic waste water will be collected separately in a septic tank and will be transported to the respective municipality’s waste water collection network.



Impermeable materials will be used for plant roads, waste processing and vehicle washing areas and curbs to prevent ingress. For the sorting and segregation facilities, this will include a leachate barrier system, including a HDPE liner to form a sec
ure barrier for the groundwater and soil. Collected leachate will be pumped to anaerobic digesters.



The Bilecik landfill leachate drainage system design includes a single main collection pipe. As per the ESAP, HKA will review the Bilecik landfill design and provide IFC a copy of the updated design documents to ensure that the leachate drainage system includes (i) technical structures such as manholes for monitoring, cleaning, flushing and repair and (ii) installation of multiple main pipes to ensure stable leachate drainage preventing the risk of leachate accumulation in the waste cells.



Waste: Industrial process wastes and/or hazardous wastes will not be accepted at HKA facilities. Concessions are for the municipal solid wastes which will include organics, recyclables and inert waste which will be segregated at source by use of colored plastic bags and / or collection bins / containers. However, the facilities will have segregation and sorting processes in order to segregate the wastes if necessary as well as to segregate recyclables into 24 sub-groups for effective recycling. At source separation and sorting / segregation is critical in order to prevent contamination as the produced compost / fertilizer is being used in agricultural fields for food production. Incoming waste streams will be visually inspected and weighed. In order to monitor the at source waste segregation system’s performance, HKA will monitor and record the quantity of wastes that are not adequately sorted and the neighborhoods where it is collected. Based on these necessary actions such improved awareness can be implemented in the respective areas.



Organic wastes will be used for biogas generation and sludge will be used for composting and fertilizer production. Agricultural wastes, food industry wastes, chicken and cattle manure as well as horse bedding which will be provided from the manufacturing plants, farmers and/or stables, will be feed to the anaerobic digesters in order to increase the dry matter content.



Inert wastes which include mainly dust and ash will be sent to the municipal landfill areas. In Bilecik, construction and operation of the municipal landfill is a part of the concession, and the landfill area will be constructed near the segregation and composting facility.



Recyclables will be sold to third party licensed contractors.



Medical wastes will be collected by HKA only in Bilecik. Medical wastes identified in the waste streams at the facilities in Pamukova, Soke and Odemis will be segregated and sent to appropriate waste disposal facilities in these areas. In Bilecik, collection of medical waste is a part of the concession and will be treated via the autoclave to be installed.



Hazardous wastes, including batteries, fluorescent lamps and chemical containers will be separated from the waste stream in the facilities, and will be recycled and / or disposed by third party licensed contractors.



In Pamukova, relatively large quantiti
es of horse bedding waste provided from stables are stored in an open area. At the time of the appraisal, the stored amount was almost equivalent to 6 months of Pamukova’s horse bedding consumption. As per the ESAP, HKA shall develop a plan to use this material within an agreed time frame with IFC and the authorities.



HKA will implement a construction phase environmental management plan for all new projects. As per the ESAP, HKA will agree with IFC on a time-based environmental management plan for each plant that will include construction area safety measures to protect communities, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. As part of the implementation, HKA will develop and implement procedures for traffic safety to ensure safe movement of construction vehicles within the site, and in and out of sites.



Landfill Gas: The EIA for the Bilecik landfill included installation of gas collection points to remove the gas from the waste cells and emit this to atmosphere. As organic wastes will be separated before it is disposed at the landfill, gas generation is not expected to be in high amounts and/or it is not expected that the gas will contain organics. As per the ESAP, after the landfill commences operations, if the methane content of the gas is 20% or higher, HKA will install a gas collection system to ensure that the gas is collected and combusted; combustion of gas with 20 % and less methane content is not feasible.



Noise: According to the EIA’s for the respective operations the noise level at the closest residential building is calculated to be around 36 dB(A) at Pamukova 35 dB(A) at Bilecik and 27 dB(A) at Soke. Noise estimations calculations were not completed for the Odemis project at the time of the appraisal as the EIA studies is not completed yet. HKA will monitor and report to IFC the ambient noise levels for all of its facilities and implement corrective actions to ensure such noise aligns with the national legislation and the requirements of the WBG EHS Guidelines if applicable.



Hazardous chemicals: Hazardous chemicals include sulphuric acid which is used for biogas and odor treatment, maintenance chemicals and fuel oil for generators and fire pump. For the fertilizer process, hazardous chemicals including N, P and K will be in use. Material safety data sheets were presented for all chemicals at the existing Pamukova facility. As per the ESAP, HKA will agree with IFC on a time-based plan for each plant to review the facilities’ design and to provide IFC the updated design documents to confirm appropriate storage for all hazardous materials including fuels.



Odor: In Pamukova, an activated carbon filtration system is used for treatment of waste air from the waste sorting areas. For the chicken manure building and for the
composting hall, sulphuric acid scrubbers and bio-filters are in use. Similar systems are incorporated in the design of Bilecik, Soke and Odemis. A buffer area surrounded by trees and fences will be provided between processing areas and potential receptors. This includes a buffer zone of 170 m to the facility and the closest residential building is located more than 1.5 km.



Odor was measured as 271-443 odor units per m3 in Pamukova which is in line with Turkish E&S legislation requirements. Inspections by local authorities indicate that HKA has necessary measures for odor management. In the event of complaints from communities, HKA will undertake additional odor measurement in line with Turkish E&S legislation requirements and will report the results to IFC.

Community Health and Safety: At Pamukova, the closest residential area is Bozoren village which is almost 2,5 km from the facility. At Bilecik which will include development of a landfill, there are 3 nearby villages, Kizildamlar, Baskoy and Yenikoy within approximately 1,5 – 5.0 km of the facility. At Soke and Odemis the facilities will be located some 2.5 – 3 km from the closest residential building. All the facilities, transport stations and landfill site will be fenced and there will be online cameras to monitor against unauthorized access. The Odemis and Pazaryeri fertilizer plants’ locations are likely to be in organized industry zones while the Bilecik, Söke and Odemis waste management facilities and Bilecik landfill area have been provided by the respective municipalities.



Biogas will be stored in double membrane biogas containers with a capacity of 330 m3 in Pamukova, 1,190 m3 in Bilecik, 500 m3 in Soke and 500 m3 in Odemis. Access to the containers will be prevented by locked fences and gas detectors in addition to automatic fire suppressions system to be installed.



Waste will be collected by 19 vehicles in Pamukova, 40 in Bilecik, 18 in Soke and 17 in Odemis. All collection vehicles have closed containers to minimize odor and designed to have a sump container to collect drainage during transportation.



In order to mitigate the potential odor problem, street bins will be closed type containers. Routes and collection frequency will be planned to minimize the odor problem. To limit scavengers’ access to the bins, municipal authorities have requested households to place their wastes in the bins only at certain times. In addition, as mentioned above, HKA has a grievance mechanism for its customers where odor, collection frequency, etc. complains can be raised and registered. There will be 2 transport stations in Pamukova, and 3 in Bilecik, No transport station will be constructed in Soke and Odemis.



In Pamukova, rat, reptile and mosquito controls are applied by use of a third party company. A similar pest control system will also be implemented in Bilecik, Soke and Odemis.



At Bilecik landfill, there is an underground well approximately 2 km away from the site boundary on the downstream of the landfill area. The nearby village is provided with its domestic water from the municipal network; however, the well water can be used for irrigation and / or for livestock water supply. As per the ESAP, HKA will engage with a consultant acceptable to IFC to conduct a ground and surface water assessment to determine the potential impact of the landfill on such water resources and implement mitigation measures as proposed. The latter will also include a ground and surface water monitoring program to be implemented to monitor potential impacts on the landfill on such resources. The Company will provide IFC with a copy of the assessment, implement the proposed mitigation measures and report to IFC on the ground and surface water monitoring
results.



HKA has emergency plans including external communication, thus will be able to inform the local authorities and nearby villages if needed.



All project locations are within known earthquake zones. As per the ESAP, HKA will engage with a seismic safety expert acceptable to IFC to verify that the facilities’ design criteria are in line with internationally accepted seismic codes. Thereafter and if required, HKA will agree with IFC on a time-based plan to upgrade the respective facilities design to ensure such complies with the internationally accepted seimic code defined.



The produced compost and/or fertilizer needs to be free of heavy metals and / pathogens and vectors as it will be used in agricultural fields for food production. HKA will implement a segregation and production system in line with the HACCP requirements in order to ensure that batteries, chemical containers, fluorescent lamps are removed from the waste stream and stored in temporary storage areas. Pathogens / vectors are treated appropriately by maintaining 700C and above for 1 hour during the windrow process as per the Turkish legislation called “ Hayvansal Yan Ürün Kullanan Biyogaz ve Kompost Tesislerinin Çalışma Usul İle Esaslarına İlişkin Talimat”.



Security personnel: Unarmed security personnel are employed through private security contractors. Security personnel are trained in the use of force for defensive purposes.

In order to operate an integrated waste management system efficiently, incoming wastes need to be collected separately at the source. HKA has developed and implemented a waste segregation system at source at Pamukova and is planning to implement the same system in other project location. The system included use of three different colored containers where green containers were used for organic wastes, blue containers were used for recyclables and gray containers were used for inert wastes that cannot be recycled or converted into valuable end products. Awareness training was provided to users on a regular basis, and when needed. Training activities included:
Households: The initial step of training consisted of three separate mail drops to households. The first one relates to introducing the waste collection project / new facility. The second mail relates to the mandatory requirement for waste segregation as required by local regulations. The final mail relate to the environmental and economic benefits of separate waste collection. Visuals of the facility and its operations are included in the mail. Following the mail drops, HKA’s training teams engage in face to face communication with the households. All households are visited at least once and informed on the details of collecting waste separately. Each household is supplied with waste bins and plastic bags that simplify waste collection and separation. Households are regularly provided with new plastic bags with routine door to door visits that also enable continuous training. Success of the training is monitored by monitoring the extent to which waste is separated in any one neighborhood; where separation is not considered effective, additional training is provided. Meanwhile, the municipality also provides information on separate waste collection via public announcements made from public loudspeakers and at the end of sermons preached at mosques;
Schools: In collaboration with the Ministry of Education, environmental clubs are established at the schools within the district. Training seminars are arranged for school administrators and teachers through these environmental clubs. In addition, schools are visited to provide training on the importance of separate waste collection. The schools are provided with custom built waste collection containers to achieve high levels of waste separation.
Private and Public Sector: Private and public institutions are visited and the separation systems are established by training of all required personnel and the provision of necessary waste collection equipment.
In Pamukova 5,400 households, 15 schools, 500 private and 24 public institutions were visited and face to face trainings were provided to almost 20,000 people in 2013.

The Environmental and Social Review Summary will be shared on HKA’s website, at the gate of existing Pamukova facility, the head quarter in Istanbul and project’s construction sites as well as site gates when they are operational.

For more information please contact:

Contact person: Evren Kutlu
Company name: Heksagon Kati Atık AŞ
Physical address, and postal (if different): İşKuleleri Kule:2 Kat:6, 4 Levent, Beşiktaş, Istanbul, Turkey
Email mailto:evren.kutlu@hexagonkatiatik.com
Phone: +90 212 385 2400
Facsimile: +90 212 278 2578

Broad Community Support is not applicable for this project

HKA(34552) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
HKA will agree with IFC on a time-based plan for each plant for development and implementation of a documented EHSS management system at a corporate level and adapted to each facility, in line with IFC’s PSs, including (but not limited to); (i) a policy; (ii) management programs to mitigate risks and impacts; (iii) organizational capacity and competency; (iv) emergency preparedness and response; (v) stakeholder engagement; and (vi) monitoring and review. HKA will enhance its existing EHSS system, which will be updated in line with OHSAS 18001 to include (but not limited to); (i) improvements related to the existing incident investigation system to incorporate a more effective root cause analysis system so as to reduce the number of incidents; (ii) development of a program to ensure that required PPE including goggles is used by all employees; (iii) development of a training matrix, in line with the risk analyses and impact assessments to ensure that all employees receive training according to the risk associated with their job descriptions including topics as PPE use, mitigations measures for the risks; (iv) development and implementation of a periodic program for monitoring workplace bio aerosol levels; (v) a review of the adequacy of PPE use versus incidents and risks, and improve the quality of the PPEs, including gloves, if needed; (vi) a program to ensure that the EHSS management system will be applicable to all existing and future activities; and (viii) a documented workplace monitoring program in line with the WBG’s General EHS Guideline and WBG’s EHS Guideline for Waste Management Facilities, and relevant Turkish legislative requirements.	31-Dec-2014	Completed	Completed	1/16/2015
HKA will provide a copy to IFC of the Ministry of Environment’s decision on the EIA for Odemis confirming approval thereof.	30-Mar-2019	In progress	Due date revised as agreed with IFC Client
HKA will agree with IFC on a time-based plan for each plant to conduct and provide a copy to IFC of the risk assessments including mitigation measures that related to; i) Pamukova’s construction phase; (ii), Bilecik and Soke’s construction and operational phases; and (iii) Odemis’s construction and operations in line with both Turkish OHS legislation and IFC’s PS requirements.	31-Dec-2014	Completed	Completed	1/16/2015
HKA will agree with IFC on a reporting template to update IFC on a quarterly basis on the progress of the permit and/or license applications, including reporting of the status of the discharge permit	31-Dec-2014	Completed	Completed	8/29/2016
HKA will agree with IFC on a time-based plan for each plant to develop and implement an agreed Stakeholder Engagement Plan that is aligned with IFC’s requirements. This will include a documented external grievance mechanism where interested parties, other than the customers, can raise and register their concerns.	30-Mar-2019	In progress	Due date revised as agreed with IFC Client
To improve contractor management system, HKA will enhance its EHSS system to; (i) define responsibility within the Company for monitoring contractors’ EHSS performance and reporting to senior management and to relevant departments; (ii) develop a matrix to evaluate contractors EHSS performance, including lost time injury frequency rates (LTIFR number of injuries per million work hours) or severity rates (number of lost days per million hours) and; (iii) review and update contractors contracts for construction to incorporate IFC’s PS2 requirements including accommodation and access to a grievance mechanism.	31-Dec-2014	Completed	Completed	1/16/2015
In the event of the Bilecik landfill leachate not meeting the acceptance criteria of the new municipal waste water treatment, HKA will construct a leachate treatment plant on site to treat the leachate before it is discharged to the municipality’s treatment plant for the final treatment.	01-Jan-2020	In progress	Due date revised as agreed with IFC Client
HKA will review the Bilecik landfill design and provide IFC a copy of the updated design documents to ensure that the leachate drainage system includes (i) technical structures such as manholes for monitoring, cleaning, flushing and repair and (ii) installation of multiple main pipes to ensure stable leachate drainage preventing the risk of leachate accumulation in the waste cells.	31-Dec-2014	Completed	Completed	8/29/2016
After the landfill commences operations, if the methane content of the gas is 20% or higher, HKA will install a gas collection system to ensure that the gas is collected and combusted.	01-Jan-2019	In progress	Due date revised as agreed with IFC Client
HKA shall develop a plan to use the horse bedding waste that is stored in the existing Pamukova facility within an agreed time frame with IFC and the authorities.	31-Dec-2014	Completed	Completed	2/27/2015
HKA will agree with IFC on a time-based environmental management plan for each plant that will include construction area safety measures to protect communities, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. As part of the implementation, HKA will develop and implement procedures for traffic safety to ensure safe movement of construction vehicles within the site, and in and out of sites.	31-Dec-2014	Completed	Completed	1/16/2016
HKA will agree with IFC on a time-based plan for each plant to review the facilities’ design and to provide IFC the updated design documents to confirm appropriate storage for all hazardous materials including fuels.	31-Dec-2014	Completed	Completed	3/9/2015
HKA will engage with a consultant acceptable to IFC to conduct a ground and surface water assessment to determine the potential impact of the landfill on such water resources and implement mitigation measures as proposed. The latter will also include a ground and surface water monitoring program to be implemented to monitor potential impacts on the landfill on such resources.	31-Dec-2014	Completed	Completed	6/4/2015
HKA will provide IFC with a copy of the assessment, implement the proposed mitigation measures and report to IFC on the ground and surface water monitoring results.	30-Jun-2015	Completed	Completed	6/4/2015
As per the ESAP, HKA will engage with a seismic safety expert acceptable to IFC to verify that the facilities’ design criteria are in line with internationally accepted seismic codes. Thereafter and if required, HKA will agree with IFC on a time-based plan to upgrade the respective facilities design to ensure such complies with the internationally accepted seimic code defined.	15-Jul-2018	In progress	Due date revised as agreed with IFC Client	6/1/2015
For the Bilecik landfill project's transmission line, HKA will engage a third party independent expert, acceptable to IFC, to undertake a documented review of the valuation / compesation process to ensure alignment of such with PS:5 as it applies to Government led resettlement. Where gaps are identified, the Company will agree with IFC on a time based action plan to address these.	30-Sep-2018	In progress	Due date revised as agreed with IFC Client