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

The project is to develop a new large scale natural gas fired combined cycle power plant, with an installed capacity up to about 928 MW (net), in an unused meadow land about 50 km east of Ankara and an associated 119km 380 kV transmission line. Due to the potential significant adverse E&S impacts and risks, this project is a category A project according to IFC’s Policy on Environmental and Social Sustainability.

Key E&S issues include NOx emission control and ambient air quality impacts, water intake from Kizilirmak River through caisson wells and effluent discharge, noise control measures, selection of cooling system, E&S impacts of the associated high-voltage transmission line, labor and working conditions management during construction phase, energy efficiency and greenhouse gas emissions, and land acquisition and compensation.

PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not considered to be applicable to this proposed investment because the power plant site is in a modified habitat with limited project’s impacts on biodiversity values and the transmission line route will not affect any ecologically sensitive areas. PS7 (Indigenous Peoples) is not considered applicable because the project will not affect any indigenous peoples. PS8 (Cultural Heritage) is not considered applicable because the ESIA reports show that there are no items of cultural heritage affected by the project.

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.

Policy:

The sponsor of the project, ACWA Power, has overarching E&S policies such as ACWA Power Commitments Statement addressing corporate responsibility, governance and environmental sustainability; ACWA Power Health, Safety and Environmental Policy Statement committing to implement a risk-based HSE management system that conforms to international practices and standards.



Assessment and Management System:

ACWA Power has well-established environmental and social assessment and management systems. It has its own HSE (Health, Safety and Environment) team who undertake periodic inspections and audits to monitor HSE management activities and performance at its projects. All projects by ACWA Power are subject to environmental and social impact assessment which complies with both local and World Bank Group standards. ACWA Power uses HSE performance indicators to monitor performance and reports the outcomes in their corporate annual reports. ACWA Guc, the company developing the project, is supported by ACWA Power to establish and maintain the Environmental and Social Management System in line with IFC Performance Standards.



Identification of Risks and Impacts:

The company retained MGS Project Consultancy Engineering Trade Company (“MGS”) to conduct an environmental and social impact assessment (ESIA) for the project (both the up to 928 MW power plant and the 119 km 380 kV associated transmission line). ACWA Power and its external HSE consultant (5Capitals) provided guidance to ensure that the ESIA conformed to ACWA Power’s requirements to follow international standards. The company submitted the ESIA reports to the Turkish Ministry of Environment and Urban Planning and received the positive EIA document (which is equivalent to the approval of the EIA) on April 9, 2014 for the power plant, whereas TEIAS submitted the reports to Turkish Ministry of Environment and Urban Planning and received the positive EIA Certificate on February 20, 2014 for the associated transmission line.



The company reviewed three alternative sites and selected the power plant site to minimize E&S impacts. The site selected is located in modified habitat but with no ongoing agricultural activities. The transmission line route was selected to avoid any ecologically sensitive areas or existing houses within the required right-of-way (25 m each side). The company selected the wet closed cooling system to minimize water intake and discharge impacts on Kizirlirmak River.



A connecting gas pipeline from the existing national gas pipeline will be selected from two alternative options (either about 3 km gas pipeline, or about 4 km gas pipeline). Neither option is expected to have significant E&S impacts.



The ESIA for the power plant included a cumulative air quality impact assessment for the three CCGT projects in the project’s area of influence: (i) ACWA Guc’s power plant project, (ii) the 830 MW ESER power plant project (which was planned to be developed by ACWA Pow
er and their local partner, reviewed as IFC’s previous project #32503 of which ESRS was disclosed in 2012, but is not proceeding anymore), and another 1,200 MW CCGT project called Kirikkale (or GAP) NGCCP (which was proposed, but the license was cancelled). The company instructed MGS to conduct this cumulative air quality assessment as a precautionary approach. Water intake and discharge cumulative impacts were not assessed considering that the ACWA Guc will be the only CCGT project taking water from the Kizilirmak River in the relevant area of influence.



Management Programs:

Based on the baseline analysis and impacts assessment of the ESIA, the company designed the project to avoid or minimize impacts and risks. The mitigation measures and monitoring program for the power plant were presented in Table 91 (Construction Phase) and Table 92 (Operational Phase) of the ESIA. The key construction phase mitigation measures include (i) immediate stopping of the excavation works in case any cultural and archaeological asset is encountered to enable the relevant institution to evaluate, (ii) storage of top vegetative soil excavated without mixing with other types soil so that it can be reused for landscape works, (iii) storage of excess excavation materials without damaging the surrounding environment, and (iv) obtaining necessary permissions from Kirikkale Forest authority before starting construction activities. The key operational phase mitigation measures include (i) continuously monitor NOx emissions to confirm compliance and (ii) treating wastewater in the wastewater treatment facility before discharging to Kizilirmak River. In addition to the Tables 91 and 92, the ESIA also includes E&S Management and Monitoring Plan listing action items to comply with EBRD Performance Requirements addressing management program, HR policies, pollution prevention, community health, protection of biodiversity, stakeholder engagement.



Within the scope of the ESIA prepared for the transmission line, the company designed a monitoring plan (Table 69) and mitigation plan (Table 70) to avoid or minimize the risks during the construction and commissioning phases.



Organizational Capacity and Competency:

ACWA Guc plans to employ about 50 people during the construction phase and 30 people during the operational phase (a full breakdown of anticipated project labor requirements is provided below under PS 2). In both phases, the company will be headed by an Executive Managing Officer (EMO) and dedicated HSE Specialist and Environmental Specialist will report to the EMO on HSE issues, implementation of the ESMS and E&S Management and Monitoring Plan in close coordination with the Project Director and QA/QC Manager. ACWA Guc’s HSE and Environmental Specialists will coordinate implementation of the E&S Management Monitoring Plan with the EPC Contractor (during the construction phase) and the O&M Contractor (during the operational phase). Detailed EHS requirements, inclu
ding the IFC/World Bank Group EHS Guidelines are to be specified as part of the EPC Contract. The EPC contractor is likely to employ 1000 people during construction. The O&M Contractor will be NOMQAC, a subsidiary of ACWA Power. NOMAC’s management system has been certified to ISO 9001, ISO 14001, and OHSAS 18001. As an O&M Operator of the Project, NOMAC estimates to employ around 60 people, including two dedicated HSE personnel. NOMAC has a strong health and safety program (defining functions to run HSE actions, hazardous substance management, and waste management) and safety training program.



Emergency Preparedness and Response:

As part of the ESIA, the company prepared an Emergency Response Plan (Section VIII.1.2 of the ESIA) describing key components such as responsibilities of response teams, rescue teams, first aid teams, company guard teams, and measures to be taken for different emergency situations such as earthquake, fire, flood and inundations, and natural gas leakage. Details of “Emergency Response Plan” for each emergency case will be prepared in coordination with the EPC Contractor, prior to the start of construction, and with the O&M Contractor, prior to the start operations.



Monitoring and Review:

ACWA Guc will establish procedures to monitor the effectiveness of the mitigation measures proposed in the ESIA (Table 91 for the construction phase and Table 92 for the operational phase) in coordination with the EPC and O&M contractors. ACWA Guc’s HSE and Environmental Specialists will receive the HSE monitoring data from those contractors and report to both external regulators as required and to the management of ACWA Guc. HSE performance will also be audited by ACWA Power, in accordance with their internal EHS auditing systems. In accordance with the Stakeholders Engagement Plan, ACWA Guc will make the HSE monitoring reports available to stakeholders by placing these at ACWA Kirikkale power plant site and ACWA Guc’s website (construction & operational phases).

ACWA Power currently has about 150 employees. In addition, NOMAC, its O&M service provider, has approximately 800 employees. At any given time, several thousand construction workers from EPCs and their subcontractors are typically working at ACWA Power project sites that are under construction in various countries. At the time of the appraisal of ACWA Guc project, no site activities had started and the company did not have an office at site. At the peak of the construction phase, it is expected that 1,000 workers will be on site while the average is expected to be 500 during this period. Around 120 jobs are expected to be provided during the associated transmission line project construction. Workers will be recruited locally as much as possible including local subcontractors. The workforce requirement during the operation phase is anticipated to be approximately 60 in total.



Human Resources Policies and Procedures:

ACWA Power has a Human Resources policy which specifies conditions and procedures of labor related issues such as code of conduct, recruitment, annual, educational, medical and special leaves, compensation and benefits, official working hours, termination and whistleblower protection. Besides this umbrella policy, ACWA Power follows national law regulations in each of the countries where they operate. In this respect, as per the ESAP Action No.1, the company will develop an HR Policy in line with requirements of PS2 and will ensure that all the workers are aware of the content. The HR policy will include provisions regarding age, wages, working hours, disabled employees, non-employee workers, health and safety, workers camps as well as grievance mechanism. Furthermore, elimination of child and forced labor, elimination of discrimination as well as employees right to freedom of association will be addressed in the policy.



Grievance Mechanism:

Besides the whistleblower policy of ACWA Power, the company will establish a formal grievance mechanism for direct and contracted employees and ensure that staff is aware of the mechanism and it is easily accessible to them. The company will develop a clear process, including required steps, timelines, procedures, and appropriate level of management for handling grievances. Once developed the grievance procedure will be fully disclosed to all employees.



Health and Safety:

As per the ESAP Action No. 2, the company will develop an Occupational Health and Safety (OHS) Management Plan to ensure that all applicable health and safety legislation and IFC standards on PS2 are met during the construction and operation phases of the project. The OHS Management Plan for the construction phase will include an occupational health and safety, communication and training program and will apply across all contractors. The plan will include provision of organization charts, safety regulations, responsibilities, accident and incident response and reporting, use of personal protective equipment (PPE), f
ire prevention measures, fall protection and emergency preparedness. There will also be necessary equipment and staff for first aid and emergency transfer during construction and operation phases. Furthermore, the contractor responsible for support services will ensure that the sub-contractors will adhere with OHS policies of the company and report incidents and accidents as well as non-compliances to the contractor.



Workers Accommodation:

Although the large majority of the workforce will be sourced locally, there may be need for on-site worker accommodation during construction of both the plant and the transmission line. In this respect, as per ESAP Action No. 3, ACWA Guc will prepare policy and standards to ensure that camp sites are facilitated with services and utilities in line with IFC’s Guidance on Worker’s Accommodation. Those will include but not limited to the size and maximum occupancy of rooms and bathrooms, air conditioning, furniture, hot water, drinking water, wastewater collection and transportation, life and fire safety provisions, kitchen and food in line with WHO recommendations, first aid services, and leisure and communications facilities.



Workers Engaged by Third Parties:

The project company will work with EPC contractors during the construction phase and with O&M contractor during the operational phase. The company will require its contractors to observe the health and safety policy and procedures of the project as well as local health and safety legislation. The contractors will also be requested to report accidents, incidents, and safety non-compliances. The project company will require that the contractors manage their employees in line with the established HR Policy. All the above-mentioned issues will be binding conditions in the contracts made with the contractors.

Resource Efficiency: The project will use combined cycle gas turbine technology with 59 % energy efficiency (i.e. “net” efficiency after deducting auxiliary electricity consumption, and on Lower Heating Value basis). The project will be one of the most energy efficient thermal power plants in Turkey. The company reviewed three alternative cooling systems for the project: once-through cooling, wet closed cooling, and dry closed cooling. The once-through cooling system was not selected due to the potential impacts on water intake from, and thermal discharge back to, Kizilirmak River. A dry closed system would minimize water intake from the river, but have less energy efficiency due to auxiliary electricity consumption needed for the cooling system. Considering the water availability from Kizilimak River, the wet closed cooling system was selected, enabling the project to achieve higher energy efficiency over dry closed cooling system while minimizing water intake impact.



Greenhouse Gases: The Company estimates that the project will produce 7,557 GWh of electricity per year, with carbon dioxide (CO2) emissions of about 2.58 million ton per year at CO2 emissions performance of 0.341 kgCO2/kWh. This performance is better than the Turkish grid average performance (0.476 kgCO2/kWh, 2009-2011 average, according to the latest 2013 International Energy Agency statistics) and comparable to good global industry practice benchmarks.



Water Consumption: The ESIA shows that the project will require 1,275 m3/h (or 0.354 m3/s) of water during the operation of the power plant, mainly to provide make-up water to the wet closed cooling system. Five or six caisson wells less than10m deep will be installed along the riverbed of Kizilirmak River. The ESIA shows that average monthly flow rate of the Kizilirmak River near the point of caisson wells location is in the range of 24 m3/s (April) to 80 m3/s (July), and the project’s intake from the caisson wells (in total 0.354 m3/s) is very low compared to the available river flow (about 0.4% to 1.4% ratio of water intake compared with the river flow). About 38% (485 m3/h or 0.13 m3/s) of the water taken (1,275 m3/h or 0.354 m3/s) from the caisson wells will be discharged back to the river after treatment (pH treatment, oil water separation). The company will work with DSI (State Hydraulic Works) in charge of the river flow management to ensure that the project’s impacts on river flow will remain minimal. NOMAC, the O&M Contractor, will implement water saving measures to maximize the operational efficiency of the plant.



Pollution Prevention (Air Emission and Noise): NOx emissions of the project will be limited to 50 mg/Nm3 at 15% excess O2, in compliance with Turkish standard, IFC/World Bank Group EHS Guideline limit, and EU standard, which are also 50 - 51 mg/Nm3. The stack height will be a minimum of 75 m. The existing air quality of the area is clean. The ESIA concluded that based on the air dispersion modelin
g results, the project’s incremental impacts on ground level NO2 concentration for both annual average and hourly maximum will not contribute more than 25% of the applicable ambient air quality standards. The ESIA also conducted the cumulative air quality impact assessment for ACWA Guc project (924.7 MW) and two other CCGT projects (830 MW and 1,200 MW). As mentioned in PS1 section, these two projects are not expected to be developed anymore. The conclusion of the ESIA with regard to 25% contribution remained the same considering the cumulative impacts of the three projects. The company will conduct ambient air quality monitoring program to confirm that the project’s impacts are small. The plant site is located far from residential areas, and the ESIA shows that the IFC/World Bank Group EHS Guideline limits of ambient noise will be met.



Pollution Prevention (Liquid Effluents): All process waste water resulting from cooling system blow-down losses and heat recovery system generator blow down losses will be neutralized, balanced and discharged. Domestic waste from the facilities will be treated biological treatment system. Wastewater after treatment will comply with the Turkish liquid effluent standards and IFC/World Bank Group effluent guideline limits (pH, TSS, Oil and grease, total residual chlorine, heavy metals, and temperature increase).



Wastes: The ESIA estimated that the excavation for the project construction will produce about 522,285 m3 of material. About 350,000 m3 of excavated soil will be used for land filling works, and the remaining will be used for land leveling activities. If excess material needs to be disposed, the company will ensure that it is not disposed in any creek bed, surface water resource, agricultural land or forestry areas located around the project site, and will work closely with Kiliclar Municipality to identify an acceptable storage site. Both the EPC Contractor and O&M Contractor will implement hazardous waste management to minimize and control of release of hazardous materials (e.g. used oils, chemicals for water treatment, water quality analysis, wastewater treatment).

Considering the sufficient distance (about 3.7km) between the project site and the nearest village (Kiliclar village), and considering the characteristics of inherent hazards of the project, the risk of non-routine hazardous materials release (i.e. noxious gas or effluent leaks) on communities is small. A detailed waste management plan, including hazardous materials management and safety, will be prepared in coordination with the EPC Contractor for the construction phase, and with the O&M Contractor for the operational phase. On the electro-magnetic field (EMF) impacts from the transmission line, the ESIA concluded the EMF levels from the line will be below the international EMS guideline limits for the general public.



The ESIA notes that a temporary construction camp may be established during the construction phase of the project. The company included this possibility in the ESIA so that the EPC Contractor can consider this as an option. However, due to the labor force availability in the region and the accessibility to the project site from the neighboring communities and municipalities, it is not likely that a construction camp will be established. In case a camp does need to be established, the company will require the EPC Contractor to implement measures to avoid any negative impacts on surrounding communities.



Ecosystem Services:

The project will take water from the riverbed of the Kizilirmak River. Other users of water from the Kizilirmak River are for hydropower generation and irrigation. Considering that (i) the amount of water intake from the river is relatively small compared with monthly arrange river flows of the year, and (ii) about 38% of the water taken will be treated and discharged back to the river, the project’s impacts on primary ecosystem services of the river is not expected to be significant. Nevertheless, the company will monitor the impacts of the project’s water intake on the downstream ecosystem services of the river as part of its ongoing monitoring program.



Security Personnel:

Security arrangements to be performed during the construction and operational phases have not been established yet but this service is planned to be provided by a private company during both phases. ACWA Guc, as per the ESAP Action No. 4, will prepare policy and procedures for the security arrangements for the EPC and O&M contractors to ensure that the security arrangement will follow the requirements of IFC Performance Standard 4 including provision of a grievance mechanism.

Before initiation of the ESIA process, the company visited the local authorities in the region (Kirikalle Governorship, Kirikkale Parliament Members, Yahsihan Municipality, Kiliclar Municipality and Irmak Municipality) to inform them of the project. As part of national environmental impact assessment regulation the sponsor conducted a public participation meeting for the stakeholders of power plant on May 23, 2013 in Kiliclar sub-district. In addition, the TEIAS conducted two additional public participation meetings for the stakeholders of energy transmission lines in Cubuk and Yahsihan districts on August 12 and 13, 2013 respectively. Announcements for the public participation meetings were published in national and relevant local newspapers.

Major concerns identified by the communities were about whether their agricultural lands would be damaged because of the project and whether employment opportunities would be provided to local residents. The company responded that the surrounding agricultural lands will not be affected by the project, and the personnel who would be employed both during construction and operational phases would be in general from local communities.

A Stakeholder Engagement Plan was prepared by the sponsor in order to address people’s concerns in a timely manner. The Stakeholder Engagement Plan describes the details of stakeholders, engagement methodologies and a grievance mechanism and the list of addresses where ESIA documents are available during project development, construction and operations. The SEP also explains where the monitoring reports will be available during the construction and operational phases. The grievance mechanism created is not only for the public disclosure period of ESIA documents, but also for receiving complaints and/or inquiries from stakeholders during the construction and operations phases. According to the SEP, the company will develop informative brochures describing the grievance procedure and distribute them to the local communities via village headmen.

The EISA documents are available at:
Kirikkale Provincial directorate of Environmental and Urbanization
Address: Kaletepe Mahallesi Samsun Bulvari Ulutas Apartmani No: 151, Kirikkale

ACWA Power, Central Building in Istanbul
Address: Tesvikiye cad. Tesvikiye Palas. No:23-2 Nisantasi 34365, Istanbul

MGS Project
Address: Sehit Cevdet Ozdemir Mah. Ovecler 4. Cad, 1351. (Eski 203.) Sk. No:1/7, 06460 Cankaya, Ankara

ACWA Power’s corporate website:
http://www.acwapower.com/corporate-social-responsibility/environment.html

ACWA Guc’s contact for further information:
Company: ACWA Guc Elektrik Isletme ve Yonetim Sanayi ve Ticaret Anonim Sirketi.
Representative: Soner Yildiz
Address: Tesvikiye Cad. Tesvikiye Palas No: 23-2 Nisantasi 34365. Istanbul Turkey
Telephone: +90 212-259-3396
E-mail: mailto:syildiz@acwapower.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
No. 2: ACWA Guc will develop an OHS Management Plan to ensure that all applicable health and safety legislation and IFC standards on PS2 are met during the construction and operation phases of the project.	11/01/2014
No. 4: ACWA Guc will prepare policy and procedures for the security arrangements for the EPC and O&M contractors to ensure that the security arrangement will follow the requirements of IFC Performance Standard 4 including provision of a grievance mechanism	11/01/2014
No. 5: ACWA Guc will document a summary of findings and land acquisition requirements determined in the land acquisition and expropriation plan to be prepared for 119 km transmission line and submit to IFC.	11/01/2014
No. 6: ACWA Guc will assess the land acquisition and right of way establishment processes followed by related authorities for main plant facility, caisson wells, natural gas pipeline and access road in order to confirm that land acquisition done for the related project components and/or associated facilities are in compliance with PS5.	11/01/2014
No. 3: ACWA Guc will prepare policy and standards to ensure that camp sites are facilitated with services and utilities in line with IFC’s Guidance on Worker’s Accommodation.	11/01/2014
No. 1: ACWA Guc will develop an HR Policy in line with requirements of IFC Performance Standard 2 and will ensure that all the workers are aware of the content. The HR policy will include provisions regarding age, wages, working hours, disabled employees, non-employee workers, health and safety, workers camps as well as grievance mechanism.	11/01/2014