Resource efficiency: The Ic Anadolu CCGT project under construction has been designed to achieve guaranteed efficiency of ~58% which is high relative to industry norms. The only project under Gama Enerji’s assets that use a notable volume of process water is the Ic Anadolu plant which will use an air cooled condenser system that has minimal water consumption. Total plant consumption will be 35.5 m3/hr for plant processes (heat recovery stream generator blowdown and demineralization system, turbine washing) and 0.4 m3/day for employee use.

Construction Risks and Management: Pollution risks occur during project construction and operation. Construction activities typically for large scale civil works, involving site clearance, excavation and earthmoving, blasting and tunneling, quarrying, concrete batching, concreting and structure/building erection. Pollution risks associated with these activities included noise, dust, erosion and sedimentation, water quality decline, waste disposal and spoil disposal. As a component of each recent EIA, an EMP has been included setting out the construction and operation phase management measures to be implemented, responsibility for implementation and monitoring requirements. Typical pollution control measures included in the EMPs are: site clearance restrictions; topsoil saving and reuse; erosion and sediment controls; spoil disposal controls; site revegetation; dust suppression; noise controls; and waste collection, handling and disposal measures.

EMP measures are compliant with environmental permitting requirements, forming a component of Turkish EIAs. Construction contractors are contractually required to implement EMP measures. The company oversees contractor compliance, performed by the company’s HSE Manager assigned to the project. All operational projects apart from the Gokres-II and Disi have been operating for two or more years, with the inspected projects exhibiting no residual construction-related impacts. When the company acquires established assets, E&S risk assessment and inherited issues are assessed by the consulting firm conducting overall project due diligence, although the company does not have a formalized E&S due diligence process. The company will prepare a corporate-wide procedure for undertaking E&S due diligence review of each established asset that is been assessed for acquisition, as per ESAP item 1.

Operation Risks and Management: The main pollution risks of operating assets relate to air quality issues from CCGT combustion emissions, noise from wind turbines and CCGT plant, and wastewater from CCGT plant.

Air quality – Ic Anadolu CCGT plant emissions were assessed in the EIA in accordance with the Turkish Regulation on Assessment and Management of Air Quality (RAMAQ), with emissions designed to comply with Turkish limits for stationary sources as set out in the Large Combustion Plants Regulation (No. 27605, 2010) (LPCR) and the IFC/WB EHS Guidelines on Thermal Power Plants (2007). The use of natural gas in high technology turbines will produce negligible SO2, CO and PM emission concentrations, well within Turkish and IFC/WB limits. NOx emission concentrations will reach a maximum of 50 mg/Nm3 (dry basis at 15% excess oxygen) when the plant is operating at maximum load, equal to the Turkish limit (50 mg/Nm3) and marginally below the IFC/WB guideline limit (51 mg/Nm3).

The American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) was used to model emission dispersion, incorporating the results of recent passive sampling of NOx concentrations in the airshed. A stack height of 74.5 m has been designed to ensure that “emissions from the stack do not result in excessive concentrations of any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash, eddies and wakes … (U.S. EPA, 1985)”. Cumulative airshed air quality will primarily be affected by the company’s 840 MW plant and the existing Orta Anadolu (Tüpras) Refinery located 500 m away in the same broad valley. The annual cumulative concentration (project plus background levels) is calculated as 7.96 µg/m3, lower than the IAPCR limit of 60 µg/m3 for 2013 and 40 µg/m3 for 2024, and the IFC/WB guideline value of 40 µg/m3.

The EIA concluded that the cumulative effect of Iç Anadolu CCGT and the proposed 928 MW (net) Kirikkale CCGT (18.5 km to the north, separated by high hills) on air quality will be negligible as the prevailing wind directions are similar, the sites are separated by high hills and therefore maximum NOx concentrations from each project projected to occur at different locations. The project’s incremental impact on 24-hr and annual ground level NO2 concentrations is well below the IFC/WB guideline limit of 25% of the Turkish air quality standard. The company will conduct an ambient air quality monitoring program to confirm that the project’s impact.

Noise – The company’s three operational wind power projects were designed to meet Turkish and IFC/WB EHS Guideline noise limits (maximum daytime level of 55 Leq (dBA) and night time level of 45 Leq (dBA) at residences, and maximum increase of 3 dB). Background noise levels were measured at the nearest sensitive receptor (NSR) to a project turbine (Sares – 1,597 m, Karadag – 486 m and Gokres-II – 670 m) and an industry-recognized noise propagation model was used to estimate noise levels at the NSR. Noise modeling indicated that Turkish noise level limits stipulated in the Regulation on Assessment and Management of Environmental Noise (RAMEN) will be met at the nearest NSR to each project for wind speeds of between 3-10 m/s. The IFC/WB Guideline limit of a maximum increase above background level of 3 dB is achieved at each project, whereas the absolute daytime and nighttime limits will be met at each project except Gokres-II where nighttime levels will exceed 45 dBA (reaching up to 48.2 dBA) due to high background levels (up to 47.7 dBA), although it should be noted that the increase created by the project will only be 0.5-0.9 dBA above background levels.

Operational noise from the Ic Anadolu CCGT project will be steady, emitted continuously throughout the year. Noise levels at the nearest NSR (a house used seasonally) are predicted to meet Turkish RAMEN limits at all times but will exceed IFC/WB Guideline limits. The daytime and night time cumulative noise levels at this NSR are estimated to reach 55.4 dBA and 55.3 dBA respectively, marginally exceeding the IFC/WB Guideline daytime limit of 55 dBA and substantially exceeding the night time level of 45 dBA. No noise predictions were provided for the company offices located 300 m west of the plant. The company will monitor actual noise levels at the nearest NSR to assess if noise levels are excessive and if so shall implement appropriate corrective action/s, as per ESAP item 6.

The main source of noise from the HEPs comes from the turbine halls, but standards there appear to be adequate setback between these structures and the nearest NSR at each project. Wastewater - Industrial and domestic wastewater from the Ic Anadolu CCGT plant will be treated in an on-site wastewater treatment system to comply with Turkish Water Pollution Control Regulation (WPCR) standards for liquid effluent and IFC/WB effluent guideline limits (for pH, TSS, oil and grease, total residual chlorine, heavy metals, and temperature increase). Chemically contaminated wastewater will be neutralised, pH adjusted and aerated. RO concentrate reject, UF/CEB wash and backflash wastes, MB backwash and regeneration wastes, and filters backwashes will be treated in a chemical treatment system to reduce TSS and TDS concentrations. Sewage will be treated in a separate system. Treated water will be discharged to the Hacilar Municipality sewerage network (or an on-site septic tank and transferred by vacuum trucks for Municipal treatment if the sewage network has not been completed). Sludge will also be treated. The company will provide details on wastewater treatment system performance prior to installation, as per ESAP item 7.

Wastes - Given the different characteristics of the various assets under the company’s management, each project has waste management measures suited to the types and volumes of wastes generated.  Non-hazardous solid wastes from projects are usually disposed of in municipal landfills by contracted waste management companies, with a copy of waste transportation document is sent to the Provincial Department of Environment. Hazardous wastes are collected by licensed contractors and disposed of in accordance with Government requirements. For example, Ic Anadolu waste management will consist of waste characterization and segregation at source according to composition, source, types of wastes produced, and generation rates in accordance with the Regulation on General Principles of Waste Management. Domestic and industrial solid waste (e.g. non-contaminated filters, used moisture retaining substances, workshop wastes and empty drums) will be transported and disposed of in accordance with regulations and Municipal requirements. Recyclable wastes like paper, cardboard, metal and glass will be collected, separately and recycled in accordance with Turkish regulations and IFC/WB guidelines.

Excess landfill from Ic Anadolu CCGT has been used by the road authority (Karayollari Genel Müdürlügü) for road construction. Sediment is removed from the Cakirlar HEP trap weirs and disposed of in accordance with permit conditions, including being used for earth road surfacing. Sediment will be removed from Lamas HEPs for the first time in 2014, with disposal to be determined. The company does not have a procedure for debris removal and disposal at Birecik HEP.

River Water Quality - HEPs have the potential to affect the quality of retained water in reservoirs, with the effect largely dependent upon the length of time that water is detained. Cakirlar HEP has no storage so there is no impact on water quality. Lamas and Cakirlar HEPs are run-of-river projects with minimal live storage therefore the effect on water quality is negligible, although there is no data available on this. 

Greenhouse Gas Emissions: The company’s current portfolio of operational generation projects totals 794.65 MW of renewable energy (hydro and wind power). By the end of 2016, after the handover of Birecik HEP to the Government, the company is expected to have 377.65 MW of renewable assets generating 1,257 GWh per annum, and 840 MW of fossil fuel assets generating 6,600 GWh per annum. In addition, the Disi project consumes approximately 800 GWh per annum of energy for water pumping. The majority of the company’s GHG emissions will be produced by the efficient Ic Anadolu CCGT project that will use good global industry practice and be lower than the average performance on the Turkish grid. Total emissions from the assets will be in excess of 25,000 T CO2e per annum therefore annual total company emissions will be reported to IFC annually.
 
The company certified and sold 49,292 T carbon credits from Lamas HEP for 2009-2010 vintages in February 2012 under the Clean Development Mechanism (CDM), and plans to certify credits from other projects. Greenhouse gas emissions from the decomposition of vegetation and soil carbon in reservoirs and weir ponds is assumed to be minimal because only one HEP has a large reservoir (Birecik - 55 km2), which was established 13 years ago and had sparse vegetation cover due to the semi-arid climate.