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TERMS OF REFERENCE

Development of Cumulative Impact Assessment of Geothermal Resources Being Developed in Turkey to Tackle the Challenges of the Future

1. SELECTED DEFINITIONS AND ABBREVIATIONS

EBRD or the Bank European Bank for Reconstruction and Development

EC European Commission

EU European Union

IPA Instrument for Pre-Accession Assistance

MoEU Ministry of Environment and Urbanization

TA or TC Technical Assistance or Technical Cooperation

CIA Cumulative Impact Assessment Study

SEA Strategic Environment Impact Assessment

PR Bank Performance Requirements

EIA Environmental Impact Assessment

2. SUMMARY

The aim of this assignment is to provide analytical support to the Government of Turkey in developing a holistic strategic plan allowing the use of geothermal resources in a sustainable manner. Sustainable management basically involves setting up and maintaining a specific long-term production scheme. It also involves the basic ingredients of successful geothermal resource management, i.e. reinjection, monitoring and modelling.

Maximizing exploitation of domestic primary energy resources and securing reliable and affordable energy to a growing economy in an environmentally sustainable manner has been, and remains, the core energy policy priority of the Government of Turkey. In this context, the Government has set a target of developing 1,500 MW of geothermal by 2023. The Menderes and Gediz Grabens, in the Aegean region, are currently the hot spots of geothermal development in Turkey. Support to the exploration and development in these areas is considered indispensable to maintain the growth momentum of the emerging geothermal sector in Turkey. Nevertheless, sustainable geothermal development by integrating water, land, ecosystem and social management objectives is required, and there is recent increasing public opposition to some large proposed geothermal projects in the country, especially in Menderes Graben. Therefore, the time is appropriate to develop integrated policy and plans to guide the geothermal sector, a key pillar of national planning and economic development. In particular, policy and plans are required to guide the rapid expansion of medium/large geothermal projects in a coordinated whole-of-basin manner to achieve sustainable use that balances geothermal generation with the protection of resources, river ecosystems and air quality whilst putting in place clear benefit sharing mechanisms with local communities.

This Technical Cooperation (TC) assignment will:

understand and analyse the current state of geothermal development – related government policy and plans, existing projects, and the likely business-as-usual (BAU) geothermal development pathway;

review current projects developed under development and planned based on review of permits and information from Trade associations (such as the Geothermal Association) and government agencies;

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review the production history including numbers and location of wells used for production and reinjection, especially in relation to observed reservoir changes;

identify future geothermal resource usage scenarios; review the types of environmental and social impacts associated with the Projects and review

information on compliance and non-compliance issues associated with the sector; provide adequate environmental and social baseline information to inform consultation/dialogue

with decision makers and other stakeholders and assist with the development of government policy and plans;

involve decision makers and key stakeholders in establishing development priorities and influencing them to agree on a common set of priorities to achieve sustainable geothermal development;

screen pipeline geothermal project proposals based on Menderes Graben to provide environmental and social risk profiles by rating sub-basins on significant existing environmental and social values that may be compromised by the increased number of geothermal power plants;

describe the environmental and social impacts of geothermal projects to date and into the future; frame a preferred sustainable geothermal development pathway that optimizes environmental, social

and economic outcomes in line with decision makers’ and stakeholders’ priorities; and review the global best practices in social and community engagement globally and draw lessons

learnt from specific examples in tackling different issues and develop a strategy to transpose those into Turkey-specific issues;

develop a best practice guide for developing operating and monitoring geothermal plants in Turkey; advice to promote the long-term sustainability of geothermal resources while maximising the long-

term power output where recommendations will be based on lessons learnt and best global practices adapted to the Turkish context;

recommend appropriate policy and plans (and supporting studies) that make trade-offs to achieve sustainable geothermal development, ecosystem protection and local natural resource use, accounting for institutional and policy constraints to mainstreaming environmental and social considerations into geothermal planning and development.

The TC will be funded through the EU Instrument for Pre- Accession Assistance 2013 (the “IPA 2013”), as part of the Bank’s PLUTO Framework aiming to support early stage geothermal development in Turkey. The TC is to be carried out in compliance with EBRD Policies, notably the Environmental and Social Policy and the relevant PRs ) and the Public Information Policy as well as Turkish and EU environmental law. The assignment should take account of the requirements and guidance provided in the respective EU SEA (Strategic Environmental Assessment) Directive (Directive 2001/42/EC) as well as the Kiev signed UNECE SEACIA Protocol1; and should also meet international best practice in Strategic Environmental and Social Impact Assessment (SESIA) development. However, the EU Directive will serve as guidance only.

3. BACKGROUND

Exploration activities conducted by the MTA were a critical driver behind geothermal development in Turkey. The MTA, established in 1935, was responsible for the exploration and mapping of geothermal resources in the country until 2007 and was traditionally the main institution advancing the development of geothermal utilization. Out of 190 geothermal sites discovered, the MTA prioritized 25 sites, which were considered suitable for electricity production. Those 25 sites were subsequently explored further, mostly by the MTA performing additional surface exploration and exploration drilling. Most of the geothermal development in recent years has taken place in areas that had initially been explored by the MTA. The total technical and economical electricity production potential has been estimated as 2,000 MW and theoretical electricity production potential as 4,500 MW. The installed capacity of geothermal power plants in Turkey has grown rapidly in recent years: from some 15 MW in 2006 to 1144 MW as of end of June, 2018. This growth has been restricted to western Turkey; the vast majority of the capacity development has taken place

1 http://www.unece.org/env/eia/sea_protocol.htm2

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in the Menderes and the Gediz Grabens; although significant potential has also been identified in central and eastern Anatolia.

Geothermal energy is generally accepted as being an environmental friendly energy source, particularly when compared to fossil fuel energy sources. Geothermal developments in the last 50 years, however, have shown that it is not completely free of adverse impacts on the environment. These impacts are becoming of increasing concern, and to an extent which may now be limiting developments. History shows that disregarding such problems can be counterproductive to development of an industry because it may lead to a loss of confidence in that industry by the public, regulatory, and financial sectors. The extent and nature of environmental impacts of geothermal development are determined by the nature and the characteristic of geothermal fluid described in Table 1.

Table 1. Characteristics of the geothermal resource and the effects on the development and environment

Resource Characteristic Effects

Temperature Determines the type of technology used; consequently, affects the air emissions emitted to the atmosphere.

Chemical Composition Determines the nature of air emissions and the nature of fluids that may be discharged.

Depth Determines size of the drilling rigs required to extract the resource. Larger drill rigs are used to reach deeper reservoirs; the larger rigs require greater surface disturbance for larger drilling pads.

Reservoir rock formation Determines the duration of drilling. Difficult subsurface conditions can extend the drilling time and the associated effects of drilling.

Therefore, comprehensive and efficient environmental management is an essential part of any successful geothermal utilization scheme. As Menderes and Gediz Grabens are rapidly developing in terms of geothermal power production capacity, the immediate take of such actions will provide substantial benefit to tackle the future problems related with adverse impacts of geothermal power development.

Geothermal Energy is associations with the following impacts

Reservoirs investigations and development of field o Investigation of resource o Risk of surface and groundwater contamination through use of drilling techniques and

discharge of any waste watero Land use

Project Developmento Drillingo Constructiono Development of associations infrastructure

Project operationso Emission of H2S, CO2 etco Noise o Risk of groundwater and surface water contamination with brine

More details on Geothermal is provided in the Annex II. 3

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4. DESCRIPTION OF THE ASSIGNMENT

4.1 Objectives

The Objective of the assignment is to provide guidance to Competent Authorises, developers as well as investors (including Lenders) on environmental and social impacts associated with geothermal development and constraints to consider when developing Projects. The assignments will include:

Describe, identify and assess the likely significant effects on the environment of implementing the geothermal power plants, as well as the most important environmental and natural resource-related constraints bearing on the implementation of any related activity.

Provide decision-makers of the MoEU and other stakeholders in Turkey with relevant information (quantitative and qualitative) to assess the adequacy of environmental and social considerations when supporting the implementation of the strategic plan/policy with regards to geothermal sector. This should include a guide and check list. This information should help ensure that environmental and social concerns are appropriately integrated in the decision-making processes at the stages of programming, planning and implementation.

Assess the global best practices how the major environmental sustainability challenges in the geothermal sector are managed and provide recommendations at strategic level on how potential negative effects can be minimized and how positive effects can be optimized. Particular focus will be given to the NCGs and the brine management in order to address these key environmental concerns associated to the geothermal sector.

Provide practical guidance to Ministry, local authorities, developers and lenders on how to develop project and what mitigation measures to consider. Include clear guidance on project development and subsequent monitoring. This will include a brochure that can be downloaded as PDF or provided in hard copy in English and Turkish.

4.2 Requested Services

Cumulative Impact Assessment (CIA) is composed of two parts: a scoping study in Phase I and a CIA study in Phase II. The scoping study will define the issues that need to be addressed in the CIA study, considering the specific context in which the sector is being developed and is likely to be implemented. Precise activities and calendar for the CIA study will be determined on the basis of the conclusions of the scoping study.

In Phase I, the scoping study will provide:

a description of the sector concerned;

a brief description of the environmental requirements of Turkey, EU and other relevant countries (Iceland, US, New Zealand, etc…) with high geothermal potential;

a brief description of the institutional and legislative framework of the energy sector in Turkey;

a brief presentation of the relevant environmental policy and objectives in the country;

an identification of the key stakeholders and relevant authorities for the CIA and their concerns, as this is critical to ensure buy-in and ownership;

an identification of the key sector environmental and environmentally-linked social impacts of its implementation;

a description of the scope of the environmental and social baseline to be prepared during the CIA study and the main sources from which the baseline will be compiled;

an identification of the impact identification and evaluation methodologies to be used in the CIA study;

a description of the stakeholder engagement mechanisms proposed for the CIA study including the development of a website and public meeting to be organized;

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an indication of the time frames (person-days), costs and resources needed to carry out the CIA study;

a proposal of the methodology for the CIA (see Annex).

In Phase, the CIA study will deliver the following results:

an environmental and social assessment of the Menderes Graben, taking into account the potential environmental and social impacts of geothermal power plant implementations and their consistency with the Turkey’s and EU's environmental and social policies and objectives.

presenting clear recommendations on policies and plans to achieve agreed sustainable geothermal development over the medium to long term, and providing justification for the recommendations. Gaps in the existing decision-making process and policies and plans in terms of creating the stated sustainable development will be identified. Recommended actions shall be presented in an action plan that is likely to include further consultation, identified knowledge gaps, baseline surveys and detailed assessments needed to finalize policy, plans, programs, implementation arrangements and a monitoring framework.

development of a best practice guide for developing and operating geothermal pants inclusive of permitting and monitoring requirements.

stakeholder engagement inclusive if presentation on impacts in the Menderes Graben areas, Izmir, Manisa, Denizli, Ankara and Istanbul.

recommendations to the MoEU which may include possible adjustments of environmental and socio-economic performance indicators, accompanying measures to deal with identified challenges, as well as priority issues for policy dialogue and coordination with MoEU and other stakeholders.

4.3 Required Outputs

4.3.1. Phase I: Scoping Study

Overview of the sector and its institutional and legislative framework

The policy-making and/or planning process relating to the sector under assessment should be presented, including alternative options that may be under discussion. If deemed necessary and with adequate justification, additional options should be suggested for consideration in the CIA study. Where a sector policy already exists, its main features should be described.

The links between the policy-making/planning process and the CIA must be described, i.e. which outputs of the policy-making/planning process should feed into the CIA process and vice-versa. The specific policy-making/planning decisions and processes that should be influenced by the CIA must be identified.

Description of key stakeholders and their concerns

The involvement and active participation of stakeholders in the CIA process is a key success factor. Key stakeholders should be identified: key groups and institutions, environmental agencies, non-governmental organisations, representatives of the public and others, including those groups potentially affected by the likely environmental impacts of implementing the sector. Stakeholder consultation meetings should be organized at scoping stage and final stage.

The Consultants must review records of any national public consultation processes that may have taken place as part of the sector development. Based on this review and on additional consultations, they should identify key stakeholders’ concerns and values with respect to the sector and propose a stakeholder engagement strategy. The stakeholder engagement strategy to be employed has to be agreed with the EBRD and MoEU before being implemented, in order to avoid unnecessary conflicts or raising of expectations. This strategy should provide stakeholders with an opportunity to influence decisions. If some of the identified stakeholders are not used to being engaged, particularly at the strategic level, and if there are no precedents, it would be important to include an education component in the stakeholder engagement process.

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Appropriate disclosure material will be provided to stakeholder include draft of the guide to enable this to be consulted on and amended based on comments received from stakeholders.

The Consultants must keep records of all consultation held and comments received. The outcome of these consultations will have important implications for the direction and focus of the CIA study. Consequently, a structured analysis of the available material will be needed to determine the key conclusions and areas of concern.

The Consultant will summarize the results of the consultation and issues being raised and provide this to the MoEU and EBRD as a stand alone summary.

Description of key environmental and social aspects to be addressed in the CIA

On the basis of the policy, institutional and legislative framework analysis, as well as the participation of stakeholders, the key environmental and social aspects that should be addressed in the CIA study should be identified – that is, the key sector environment and social interactions that need to be given special consideration and emphasis.

Description of the scope of the environmental and social baseline to be prepared in the CIA study

The Consultants must provide indications on the scope of the environmental and social baseline needed for the CIA study, ensuring that it will be adequate to examine in more detail the key environmental and social aspects identified above. This will include a proposal of the geographical units that will need to be addressed, if relevant.

In an overall sense, the baseline should contribute effectively to assess positive and/or negative environmental and social impacts; as well as determining the magnitude and sensitivity of those impacts at a level of confidence that can be used in policy and management decisions.

Recommendations on specific impact identification and evaluation methodologies to be used in the CIA study

The Consultants should provide an indication of the impact identification and evaluation methodologies that will be used in the CIA study, with regards to both the sector’s expected impacts on the environment and the impacts that environmental conditions and natural resource availability.

Methodologies proposed should be drawn from best international practice and should be rigorous enough to ensure an adequate assessment and a sector-targeted analysis of issues at a strategic level.

Indication of the time frames needed to carry out the CIA study

The Consultants must assess the time that needs to be allowed for the completion of the CIA study, based on the initial indicative assessment. A description and estimation of the resources required (in terms of budget, person-days) must be provided, including a breakdown of costs.

The Team Leader, in coordination with the rest of the team, may review and adapt the initial timing and expertise to complete the CIA study, and develop a schedule of resources needed, including

person-days of technical input for each of the experts;

operational support costs, including participatory processes and special technical inputs (workshops, group participation training);

any special mapping or data collection costs; and

the Consultant team’s operating cost (out-of-town transport, accommodation, etc).

4.3.2. Phase II: CIA Study

The scope of the CIA study will be agreed with the EBRD and MoEU on the basis of the results of the scoping study. The CIA study will include an environmental and social baseline study, an identification of environmental and social constraints and opportunities, an identification and assessment of the potential

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environmental and social impacts, an analysis of performance indicators, an assessment of the institutional capacities to address environmental and social challenges, and conclusions and recommendations.

Environmental and social baseline study

A description and appraisal must be made of the current state of the environment, focusing on those key environmental and social components identified by the scoping study. The trends for, and pressures on, the various environmental and social components must be identified and a projection must be made of the state of the environment on the short-, medium- and long term under the assumption of no implementation of the sector, taking into account the expected effects of climate change (to the extent they can be predicted with some reliability). External factors must be taken into account, including the influence of other sectoral policies. If the ‘no implementation’ scenario is unrealistic, the most probable ‘business-as-usual’ scenario should be selected. The geographical (or mapping) units to be addressed should be described, if relevant.

Identification and evaluation of environment and social-related risks, constraints and opportunities

The environmental and social factors that can affect (positively or negatively) the relevance, effectiveness, efficiency and sustainability of the sector, including climate- and natural resource-related aspects, should be identified, described and assessed. These factors may include natural resource availability as well as the current and projected effects of climate change. This part of the study should also consider whether the sector provides an adequate response to these constraints and opportunities.

An analysis must be made of addressing environmental and social issues that affect sector performance in a negative manner, and making optimal use of opportunities offered by the environment to enhance sector performance. A matrix approach is suggested to illustrate the findings, indicating the environmental factors and resources; the positive and negative impacts and degrees of significance.

Identification and evaluation of impacts

The potential environmental and social impacts and risks from implementing the sector must be identified and described, taking into account the views and concerns of stakeholders. Their significance should be determined according to their characteristics (e.g. duration, probability, magnitude, mitigability, reversibility) and the sensitivity of the environment. The potential cumulative impacts of the envisaged sector activities should be identified, since they may differ from the sum of individual project impacts. Those impacts which are significant should be assessed in detail taking into account:

the views and concerns of stakeholders;

the consistency with international commitments (Multilateral Environmental Agreements);

compliance with environmental regulations and standards;

consistency with environmental objectives and policies;

and

their implications for sustainable development.

It is suggested that matrices, flow charts, etc. are used to illustrate the findings, showing which components of the sector have an effect on which environmental aspects, and the significance of such impacts, as well as to show the consistency with environmental objectives and international commitments.

Assessment of the capacities to address environmental and climate-related challenges

The capacity of implementing institutions in carrying out identified environmental and climate-related interventions, both in terms of adaptation and mitigation, should be assessed.

The Consultants will address the adequacy of institutional structure and capacities of the regulatory framework and human resources of the Energy sector and national environmental institutions to address the key environmental concerns associated to the geothermal sector. As noted earlier, this assessment should focus at the policy/sector level and take adequate cognizance of realistic present and future capacities.

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Stakeholder engagement

Stakeholders should be engaged throughout the CIA study according to the stakeholder engagement strategy agreed at the scoping stage. Stakeholder engagement could include a mix of different mechanisms, such as questionnaires, focused semi-structure interviews and workshops with key stakeholders in accordance with EBRD Performance Requirement 10.

Conclusions and recommendations

This chapter will summarise the key environmental and social issues for the sector involved, including policy and institutional constraints, challenges and main recommendations. Recommendations should be made on how to optimise positive impacts and make the best out of environment- and natural resource-related opportunities, as well as on how to mitigate negative effects, adapt to environmental and social constraints and manage risks. It should suggest the selection of an alternative (if more than one alternative is envisaged), potential changes in the sector design (e.g. adoption of measures to increase adaptive capacity with regard to climate variability and the expected effects of climate change), implementation and monitoring modalities, or cooperation actions.

The Consultants will pay specific attention to providing realistic, targeted and workable operational recommendations. General statements should be avoided.

The limitations of the CIA and its assumptions should be presented. The recommendations should consider the views presented by the stakeholders and explain how these were integrated. In the case of concerns that were not integrated in the final recommendations, the reasons thereof should be given.

In addition a stand alone guide for developing and operating Geothermal plants.

5. EXPERTISE REQUIRED

The following is the minimum experience and expertise required for this assignment:

A senior environmental expert/team leader with at least 15 years international experience in leading and supporting environmental projects, including expertise and experience with cumulative impact assessment in Turkey, EU and non-EU countries, environmental impact assessment, in particular with assessing impacts of Power Sector projects.

Social and environmental scientists/analysts with local and international experience in characterizing baseline conditions and assessing impacts of programs and policies on people and the environment in Turkey.

Stakeholder Engagement expert with experience in designing and implementing programs to identify and involve local and public stakeholders in decision-making for environmental and power sector cumulative impact assessment projects.

Social assessment expert(s), with local and international experience of working with rural communities and good understating of IFI (such as EBRD, World Bank, IFC etc.) social requirements.

Geologists with at least 15years of local and international experience in geothermal power engineering.

GIS specialist with at least 5 years of local and international experience in GIS/CAD mapping. Local experts with at least 10 years of experience in environmental assessment, public consultations

and environmental legislation. Strong understanding of environmental and social challenges in Turkey especially with regards to geothermal sector. These may include any or all of the experts above.

6. IMPLEMENTATION ARRANGEMENTS

Starting Period

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It is expected that the assignment shall commence as soon as possible after the signature of the specific contract, preferably in early November,2018.

Location of assignment

Menderes Graben, in Turkey. Working days in the field will be determined by Consultants during scoping stage.

Work Plan

The work plan should include but not necessarily be limited to the following activities:

Phase I: Scoping study

Fact finding / data collection

Review of prior public consultations, identification of key stakeholders

Engagement of stakeholders

Analysis/preparation of recommendations and scoping report.

Phase II: CIA study

Fact finding / data collection – extensive quantitative data

Technical Field trips

Development of best practice guides

Engagement of stakeholders

Identification and detailed analysis of the potential environmental and social impacts and constraints

Preparation of recommendations to mitigate negative environmental and social effects, adapt to constraints, optimise positive effects, exploit opportunities, and generally manage and control environmental and climate-related risks

Preparation of recommendations and draft CIA report

Preparation of the final CIA report.

On the basis of this draft proposal and the time schedule outlined in these Terms of Reference (ToR), the Consultants must provide their detailed work plan.

Time Schedule

The Consultant shall commence work no later than 5 days after conclusion of the Contract (kick-off date). The Assignment is to be completed within 8 months. Key time milestones are as follows:Phase I:

End of week from the kick-off meeting provide an inception report. This will in essence act as a gap analysis and definition of the project and will include key elements of the scoping study;

Formal scoping study and Stakeholder Engagement Plan by week 6, to enable agreement of both by month 2 and allow for public consultation in month 3;

Phase II: End of month 4: submission of a draft CIA Report to the Bank, who will provide comments,

following which the Consultant will have 2 weeks to provide an amended version; submission of the draft report on the project due diligence, benefits and obstacles;

End of month 5: draft CIA Report ready for 45 days public consultation; public consultation commences; submission of the final report on the project due diligence, benefits and obstacles;

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End of month 7: end of public consultation; Consultant will amend the draft CIA Report following the public consultations as required by the Bank and MoEU comments 2 weeks after the end of the public consultation period);

End of month 8: submission of the agreed final CIA Report and the Report on Public Consultation.Liaison with Stakeholders

The Consultant will liaise closely with the Bank and the MoEU, among others, and points of contact/responsibility as nominated by the Bank and MoEU.The Consultant is requested to attend a minimum of five meetings with the Bank/Ministry at the Bank’s Resident Office in Istanbul or at an in-country venue nominated by MoEU:

at the beginning of the CIA process – kick off meeting; on submission of the draft inception report and scoping study (see Section 7 below); Prior to beginning the scoping meetings; on completion of the final report (for a formal presentation to the Bank); Prior to beginning the public consultation process.

Facilities, Equipment, StaffAs part of this Assignment, and within the budget assigned, the Consultant will:

provide all equipment required for the project (e.g. laptops, PCs, photocopiers, etc.) that will remain its property at the end of the assignment;

arrange any office facilities, etc. which may be required for its own use; arrange any facilities required for public meetings (as part of public information/disclosure); this

should be based on one meeting in the study area; arrange for translation facilities at the Consultant's expense as provided in the agreed budget.

The consultant will cover his own expense during the public consultation process and stakeholder engagement meetings; including covering all costs of facilities, refreshments, adverts, handouts, Turkish-English simultaneous translation etc.

TravelThe Consultant is responsible for all necessary travel arrangements to and within Turkey.

7. DELIVERABLES AND REPORTING REQUIREMENTS

7.1 Reports to be DeliveredDeliverable No. 1: Inception ReportThe Consultant will provide an Inception Report not later than 4 weeks after commencement of the Assignment to MoEU and the Bank. This report should include (but not necessarily be limited to) the following:

identify relevant regulations, guidelines, industry standards, etc.; identify relevant existing information; identify information gaps which are likely to have a significant impact on the assignment and the

quality and usefulness of the final report; provide all details or any necessary material amendments to the work plan initially proposed; identify key stakeholders (e.g. local, national and international institutions and CSOs); provide an outline SEP;

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describe how the Consultant intends to manage interactions with the Bank, Geothermal Associations and the Ministry of Environment and Urbanization.

Deliverable No. 2: Scoping Study The Scoping Study is to be presented in the format given in Appendix 1, although this is to be used as a guide as the inception report needs to be tailored to meet the requirements of the Project.Following the issue of an inception report and meeting to be held in Izmir, Denizli, Manisa, Ankara and Istanbul, the Consultant will prepare in week 6 a draft Stakeholder Engagement Plan and scoping study; copies are to be presented to the Bank for comments in English and Turkish. Following the approval of the scoping study (assumed in week 7-8), scoping meetings will be undertaken in week 10 in line with a program outlined in the SEP. The invitation to the scoping meetings will be issued at least 2 full weeks before they are due to take place, in national and local papers, and other media as required. Consultant will cover all costs of the meeting and preparation for the meetings (including venues, refreshments etc). The consultant will cover his direct costsDeliverable No. 3: CIA ReportDraft CIA ReportThe CIA Report should, in structure, content, detail and presentation, take account of the requirements of the EU CIA Directive and best international practice such as the CIA Protocol as well as the Turkish requirements associated with the implementation of the CIA Protocol. The report will include Annexes relating to each region under consideration as well as Stand along guidance documents for developing projects and subsequent monitoring. The Consultant is encouraged to discuss the report structure and presentation with the Bank and MoEU at an early stage.The Consultant will provide the Bank and MoEU with an CIA Report w in draft form not later than 4 months after commencement of the assignment. The Bank and MoEU will provide comments. The Consultant will then (if required) have 2 weeks to amend the draft as necessary.Final CIA ReportFollowing acceptance of the amended draft by the Bank and MoEU, the reports will be made available for public comment. Following completion of the public consultation in accordance with Bank procedures (60 days), and taking account of any comment from the public, the Consultant will prepare the final CIA Report within 2 months of completion of the 60 days period (final comments from the Bank and MoEU to be provided to the Consultant not later than one month after completion of the 60-day consultation period). Deliverable No. 4: Report on Public ConsultationThe Consultant will provide the Bank and MoEU with a concise report summarising:

liaison with interested parties during the development of the CIA (e.g. at scoping stage) with the development of a scoping report and SEP; and

the formal 60 days public consultation process of the CIA document with meetings held in Aydın region.

Deliverables No. 5: Monthly Progress ReportsThe Consultant will present brief monthly progress reports to MoEU (copy to the Bank) providing a summary of progress made (against the initial work plan) and will flag up any problem which could materially affect the CIA implementation. The inception report will count as the first progress report.General Reporting Requirements, Reporting Language and Number of CopiesThe Consultant shall send copies of all reports/deliverables to the EBRD too.The Inception Report, the Monthly Progress Reports and all correspondence with the Bank and MoEU will be in English and Turkish. The Final EA Report, the Report on Public Consultation and all materials prepared for public information and disclosure will be in English and in Turkish.All reports are to be submitted in hard copy (5 copies to each to MoEU and the Bank) and in electronic format.

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ANNEX 1 – Standard report formatsStandard format for the CIA scoping report

Maximum length of the main report (without appendices): 25 pages.The following text appears on the inside front cover of the report:This report is financed by EBRD and is presented by the [name of consultant] for the … It does not necessarily reflect the opinion of the … or the EBRD1. Executive summary2. Description of the Sector and areas3. Overview of institutional and legislation documents4. Description of key stakeholders and their concerns5. Description of key environmental and social aspects to be addressed in the CIA study6. Description of the scope of the environmental and social baseline to be prepared in the CIA study7. Recommendations on specific impact identification and evaluation methodologies to be used in the CIA study8. Proposal of time frames and resources needed for the CIA study9. Technical appendices

I. Stakeholder engagement methodologyII. List of stakeholders engaged or consultedIII. Records of stakeholder participation.IV. List of documents consulted

Standard format reportThe following text appears on the inside front cover of the report:This report is financed by EBRD and is presented by the [name of consultant] for the … It does not necessarily reflect the opinion of the … or the EBRD and ….1. Executive summary2. Scope3. Background

3.1 Upgrade Program justification and purpose3.2 Alternatives3.3 Environmental and Social policy, legislative and planning framework

4. Approach and methodology4.1 General approach4.2 Geographical or environmental and mapping4.3 Assumptions, uncertainties and constraints

5. Environmental and social baseline study6. Impact identification and evaluation7. Analysis of alternatives8. Mitigation or optimising measures9. Indicators and institutional capacities10. Conclusions and recommendations

10.1. General conclusions10.2. Recommendations for developing Projects10.3. Recommendations for enhancement

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11. Technical appendices Maps and other illustrative information not incorporated into the main report Other technical information and data, as required List of stakeholders consulted/engaged Records of stakeholders’ participation Questions and answers book

12. Other appendices Study methodology/work plan (2–4 pages) Consultants’ itinerary (1–2 pages) List of documentation consulted (1–2 pages) Curricula vitae of the consultants (1 page per person) Terms of Reference for the CIA

In additional separate chapters, or annexes will be provided for specific geothermal regions.

ANNEX II- BACKGROUND INFORMATION13

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1. MAJOR ENVIRONMENTAL IMPACTS of GEOTHERMAL POWER PLANTS

Major adverse impacts generally relate to longer term impacts that are larger in scale and more difficult to manage, and largely related to project site selection. Many construction phase impacts are usually not classed as major impacts as they occur over the short to medium term and are manageable using conventional measures.

Air Borne Emissions

Geothermal gases are dissolved in the liquid phase at the reservoir level, but where steam is present the gases partition preferentially into the steam phase. Common geothermal gases are CO2, H2S, H2, N2, CH4, NH3 and Ar, but other gases are also present in trace amounts. A common compositional range of geothermal gases is shown in Table 1.

Table 1. Typical Composition of Geothermal Gas (weight %dry gas)

CO2 H2S H2 CH4 NH3 N2 AR

Median 95.4 3.0 0.012 0.15 0.29 0.84 0.02

Maximum 99.8 21.2 2.2 1.7 1.8 3.0 0.04

Minimum 75.7 0.1 0.001 0.0045 0.005 0.17 0.04

Table 1 illustrates how CO2 is generally the dominant geothermal gas, typically constituting more than 95 percent of the total gas. Carbonate-hosted high temperature geothermal systems are not common but they do occur (notably in the Tuscany region of Italy and western Turkey) and are characterized by significantly higher CO2 fluid concentrations than other geothermal reservoirs. Other significant gases are H2S and N2, the weight of which, in rare cases, can constitute several percentage points of the total geothermal gas. Other gases are generally found in low concentrations in the order of a few percent to a fraction of a percent.

In the context of geothermal power production, the geothermal gases are commonly referred to as non-condensable gases (NCGs) as they do not condense at the same physical conditions as water vapor but remain in the gas phase. NCGs have a negative effect on the efficiency of the energy conversion process and need to be removed from the system (either from the condenser or the heat exchanger).

Carbonate rocks are common sedimentary rocks, composed mainly of calcite or aragonite (CaCO3 ) or dolomite (CaMg(CO3 ) 2 ). Carbonate rocks are biogenic sedimentary rocks formed in relatively shallow waters from skeletal fragments of marine organisms. Marble forms by recrystallization of carbonate rocks at high temperatures and pressures, and is referred to as metamorphic carbonate rock. When carbonate rocks are exposed to relatively high temperatures at relatively low pressure, such as near shallow magma intrusions or in the roots of high temperature geothermal systems, the carbonate minerals react with silicates to form calcium or magnesium silicates and CO2 gas. One example of such a thermal decomposition reaction is:

CaCO3 + SiO2 = CaSiO3 + CO2

calcite + quartz = wollastonite + carbon dioxide

Thermal breakdown of carbonate rocks in the roots of geothermal systems can result in the formation of CO2 gas that migrates up to the geothermal reservoir. Similarly, equilibrium between calcite, quartz, and wollastonite in high temperature geothermal reservoirs can result in high concentrations of dissolved CO2 in the geothermal fluid.

Carbonate-hosted high temperature geothermal systems are not common but they do occur (notably in the Tuscany region of Italy and western Turkey) and are characterized by significantly higher CO2 fluid concentrations than other geothermal reservoirs. The high gas emissions from the geothermal power plants in Buyuk Menderes and Gediz grabens are a result of unusual geological settings. Most of the high temperature geothermal fields in the country are located in the Aegean region in Western Anatolia. This area is characterized by extensional tectonics, resulting in graben formations and crustal thinning. High regional

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heat flow, resulting from crustal thinning appears to be the main source of heat for these geothermal systems. This region is also characterized by an abundance of carbonate sedimentary and metamorphic rocks, such as limestone and marble. The high concentrations of CO2 in the geothermal fluids in the region seem to result from thermal breakdown of carbonate minerals in the reservoir rocks.

The range of emissions from the Buyuk Menderes graben power plants is from 900 to 1,300 g/kWh. The second most developed region for geothermal power production in Turkey is the Gediz graben, located north of the Buyuk Menderes graben, and preliminary information indicate that CO2 emissions will be similar to those from the Buyuk Menderes graben. It should be noted that not all the CO2 brought to surface by geothermal production in Turkey is released directly into the atmosphere. In at least four of the Turkish geothermal power plants, the CO2 from the geothermal fluid is captured and sold off as dry ice and liquid CO2.

Other significant gases are H2S and N2, the weight of which, in rare cases, can constitute several percentage points of the total geothermal gas. H2S is characterised by a “rotten egg odour” detectable by humans at very low concentrations of about 0.3 ppm. At such concentrations, it is primarily a nuisance, but as the concentration increases, it may irritate and injure the eye (10 ppm), the membranes of the upper respiratory tracts (50-100 ppm), and lead to loss of smell (150 ppm). At a concentration of about 700 ppm, it is fatal. Because H2S is heavier than air, it can accumulate in topographic depressions where there is still air, such as well cellars and the basements of buildings near the gas exhausters. The disappearance of the characteristic smell at concentrations greater than 150 ppm is especially dangerous because it leads to people failing to recognise potentially fatal concentrations. Exposure standards range from 10 to 50 ppm (10 min.). In sparsely populated areas, H2S emissions may not prove a problem, and at many sites, there are already natural emissions from fumaroles, hot springs, mud pots, etc.

Geothermal gases in steam may also contain ammonia (NH3), traces of mercury (Hg), boron vapors (B), hydrocarbons such as methane (CH4) and radon (Rn). Boron, NH3, and to a lesser extent mercury, are leached from the atmosphere by rain, leading to soil and vegetation contamination. Boron, in particular, can have serious impact on vegetation contamination. These contaminants can also affect surface waters and impact aquatic life.

Legislation of NCGs in Turkey and other countries

Since geothermal power generation is widely considered a non-CO2 emitting renewable energy source, there are currently no regulations in Turkey that constrain CO2 emissions from geothermal power plants and developers are not required to monitor or report their gas emissions either. However, facilities to capture geothermal CO2 are already installed at four power plants in the Menderes graben, with the gas being sold to the food and beverage industries. Air emissions can occur during well drilling and flow testing activities. The open contact condenser / cooling tower systems is another source of air emissions during operation of the power plant. Well-field and plant-site vent mufflers can also be potential sources of hydrogen sulfide emissions, primarily during upset operating conditions when venting is required.

The Air Quality Control Regulation and the Industrial Air Pollution Control Regulation set out emission limits for industrial facilities in Turkey. The Industrial Air Pollution Control Regulation also provides that facilities, which are not subject to the emission permit, must minimise the adverse impacts of their activities on the environment by using high-tech methods in accordance with the legislation. Annex-2, Table 2.1 sets out the mass flow rate limits for the airborne emissions under this legislation.

Tablo 2. Mass Flowrate (kg/hr)

Emissions From Stack Other Places

Dust 10 1

Lead 0.5 0.05

Cadmium 0.01 0.001

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Thallium 0.01 0.001

Chlorine 20 2

Hyrogen Chloride 20 2

Hydrogen Floride 2 0.2

Hyrogen Sulphide 4 0.4

CO 500 50

SO2 60 6

[NOx (in terms of NO2)] 40 4

Total Organic Compounds 30 3

Also under the same regulation, the ambient air quality limits for air pollutants are listed in Table 2.2 in Annex 2. H2S limits listed in this table are presented below:

Tablo 3. Ambient Air Quality Parameters within the close vicinity of the Plant

Parameter Duration Unit

Year

2014 2015 2016 2017 2018 2019-2023

2024

And after

H2SHourly

µg/m3

100 100 100 100 100 100 100

Short term limit value 20 20 20 20 20 20 20

New regulation set by the government of Iceland in 2014 on H2S concentration in air puts high demands on the geothermal industry in Iceland to lower H2S emission from their power plants. The regulation is significantly stricter than the World Health Organization (WHO) Air Quality Guidelines (World Health Organization 2000). Below table presents the new limit values came in force after 2014.  

For comparison purposes, Table 4 provides other guidelines enforced in the United States and New Zealand.

Table 4. Different Environmental Guidelines for H2S air concentration emissions

Country/Agency Limit Averaging Period16

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New Zealand 7 µg/m3 1 hour

USEPA California 43 µg/m3 1 hour

Bay area 2.5 kg/hr -

Iceland 50 µg/m3 1 hour

WHO guidelines for Europe 150 µg/m3 1 hour

Turkey 100 µg/m3 1 hour

The sample calculations of H2S levels based on the available data from couple plants in Turkey:

Kızıldere III Plant:

Capacity: 80 MWe

Flowrate: 2,800 ton/hr

NCG content the resource: 1,32%

Total NCGs to be emitted: 37 ton/hr

Mole percentages of NCGs:

CO2 N2 CH4 H2S H2 O2 Ar C2H4

0.9927500

0.0037590

0.0028600

0.0004490

0.0000580

0.0000420

0.0000300

0.0000260

The mass weight of 1 mole of gas: 43,85 g/mol

H2S emissons= 37 ton/hr x 8,760 ton/hr x 0,000449 x 34 g/mole / 43,85 g/mole= 113 ton/yr

H2S (volumetric fraction): <0.1 ppm (assumption)

H2S: 0.1x 1.5 mg/m3= 0.15 mg/m3= 150 µg/m3

Technologies to reduce airborne emission levels

There are several technologies that have been developed to capture and treat NCGs from geothermal power plants. Most of these have been developed to remove H2 S from the geothermal gas released to the atmosphere but there are also a few examples of geothermal CO2 capture. Geothermal CO2 is captured at some of the geothermal power plants in Turkey, including Kızıldere, Dora I and II, and Gümüşköy. The gas captured at these power plants is commercialized for dry ice production and for production of carbonated beverages. Geothermal CO2 can also be used to enhance photosynthesis in green houses, production of paint and fertilizer, fuel synthesis, and for enhanced oil recovery. It is possible to reinject some or all the NCG from geothermal plants. This is not widely practiced but two notable example are available. Near complete NCG reinjection is practiced at the Puna plant in Hawaii. Similarly, since 2014, Reykjavik Energy has reinjected about a quarter of the geothermal H2S and about 10 percent of the CO2 from the Hellisheidi Power Plant in Southwest Iceland by using Carbfix and Sulfix methods.

The CarbFix-SulFix project involves re-injecting a gas mixture of approximately 70% CO2 and 30% H2S, dissolved in water from the Hellisheidi power plant, into basaltic formations, with the purpose of storing the gases in mineral in the bedrock. Rather than re-injecting CO2 directly into geological formations, the CarbFix-SulFix project dissolves the gas stream into formation fluids and well water during injection. This solubility-trapping approach is expected to promote carbonation of the host rock and long-term storage of the re-injected gas stream.

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The initial pilot tests included reinjection tests of a pure CO2 gas stream sourced from commercial sources as well as reinjection of the gas mixture from the power plant (for what were often labelled separate CarbFix and SulFix projects). During the pilot tests around 170 tonnes of pure CO2 was injected into a target zone between 400-800 metres (with formation temperature at 30-80°C). Approximately 100 tonnes of gas mixture was injected into a target zone in excess of 800 metres (with a formation temperature greater than 200°C). The initial pilot tests demonstrated solubility storage of the pure gases in a few minutes, and that more than 80% of the injected CO2 into basaltic rocks was mineralised with 12 months of the injection date (at formation temperature of 20-50°C). The ‘larger-scale injection’ CarbFix-SulFix project commenced injection in early June 2014, with injection of the (dissolved) gas mixture at a depth of approximately 800 metres. Approximately 2,400 tonnes of CO2 and 1,300 tonnes of H2S had been injected by the end of 2014. Four monitoring wells were used to collect water and gas samples.

The cost and economic feasibility of CO2 capture from geothermal NCG depends on several factors. These include the NCG composition, the pressure of the NCG at the outlet from the power plant, and the desired purity and pressure of the end product as well as the size of the demand relative to the volume produced. The cost of capturing and processing CO2 estimated from a hypothetical geothermal power plant are presented below. Assumptions made for this study:

The cost of capturing and processing NCG is estimated for a fluid with relatively high CO2 content (98.4% by volume), moderate concentrations of N2, CH4, H2S and NH3 (0.5, 0.7, 0.2 and 0.1% by volume, respectively) and trace concentrations of H2 and Ar (0.05 and 0.005% by volume, respectively). The assessment considered only commercially available and tested technologies.

The total NGC supply was taken to be 50 t/hr. To put this gas supply into perspective, 50 t/hr corresponds to emissions from a 50 MW power plant with an emission factor of 1,000 g/kWh or a 100 MW power plant with an emission factor of 500 g/kWh.

Furthermore, it is assumed that that the NCG was delivered to the treatment plant saturated with water vapor at 70°C and 4 bar-g. This corresponds to conditions at a two-phase binary plant, which is the most suitable technology when the gas content of the geothermal fluid is high.

The methods that can be used to mitigate CO2 emissions from geothermal power plants:

1. Low pressure gas for use in greenhouses

This case involves the removal of NH3, H2S and H2O. Bulk removal of NH3 (to 40 ppmV) is assumed to be achieved by ammonia dissolution in the condensate water. Liquid Redox Sulfur Recovery (LRSR) technology can reduce the H2S concentration to less than 1 ppmV and H2O can be removed from the gas by condensation by cooling the gas. A 5-km pipeline is included in the cost estimate for the greenhouse application.

2. Supercritical CO2 compressed to 125 bar for Enhanced Oil Recovery

For this purpose, it is necessary to reduce the concentration of NH3 to less than 0.1 ppmV in order to prevent the formation of solids during the compression of the gas. This can be achieved by dissolution of NH3 in condensate water during chilling, followed by acid scrubbing. The same LRSR process for H2S removal is anticipated as for the greenhouse application. H2O is removed from the gas through a combination of compression and chilling.

3. Liquefied beverage-grade CO2 (with and without removal of Hg, COS, and C2H6)

It should be noted that the cost estimate for the liquefied beverage-grade CO2 also applies to food-grade, dry-ice grade, and industrial-grade CO2. The basic case involves the removal of H2S, NH3 , H2O, N2, Ar, H2, and CH4. Furthermore, the additional cost of removing the trace gases Hg, COS, and C2H6, which may or may not need to be removed to meet the standard for beverage-grade CO2, is also considered. The cost of four 500-ton storage tanks for CO2, is included in the capital cost estimate for the beverage-grade CO2. In addition, the cost of removing Hg, COS, and C2H6 is estimated for each gas species.

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4. Reinjection of NCG along with brine and condensate

The cost of reinjecting the NCG back into the geothermal reservoir along with a mixture of brine and condensate from the power plant is estimated. It is estimated that the 50 t/hr of gas would be dissolved in 2,500 t/hr of geothermal liquid at 70°C and 55 bar pressure should be sufficient to dissolve the gas in the liquid at this temperature. This corresponds to about 560 m depth in a well full of water at 70°C or well above the typical depth of geothermal reservoirs (1,000 to 1,500 m). In order to prevent the formation of solids, it is necessary to remove the NH3 from the gas stream before it is compressed. The gas is then compressed to 55 bar and pumped into a reinjection well along with brine and condensate.

The economics of each method is presented below:

Table 6. Economic Summary of Different Methodologies

Method

Capital Cost,

K USD

Operating Cost,

K USD per year

Treating Cost for CO2 product, USD per tonne CO2

Low pressure gas for greenhouse

13,122 667 5.0

High pressure fluid for EOR 25,304 3,765 15.4

Beverage-grade liquid 37,793 4,764 21.1

Reinjection of NCGs 14,700 2,817 10.3

Liquid or Solid Effluents

Liquid Effluents

Geothermal energy projects may result in the release of hot water into the environment during construction or operation. Water quality in the area may be affected by the release of more acidic/alkaline effluent from the power plant, or effluent containing chlorides and sulphides or other dissolved chemicals, such as metals. Most high temperature geothermal water may contain high concentrations of at least one of the following toxic chemicals: aluminium (Al), boron (B), arsenic (As), cadmium (Cd), lead (Pb), mercury (Hg), and sometimes fluoride (F). This has significant implications for human health. There are a number of known cases of heavy metal water pollution from geothermal power plants, for example since the Wairakei power plant was built in the late 1950s, the amount of arsenic in the Waikato River has more than doubled. Arsenic levels in the river now exceed drinking water standards. Therefore, the appropriate control of these effluents is crucial and should be strictly monitored for surface water quality.

Liquid effluents of geothermal development projects can be classified as i) drilling fluids; ii) spent geothermal fluids; iii) reject water from injection wells; iv) well cleaning water (for clogging); and v) domestic wastewater.

i. Drilling Fluids: Freshwater is commonly used as a drilling fluid (circulation water) during drilling in the production zone of the reservoir. The purpose of the drilling fluid is to cool and lubricate the drilling equipment and carry rock cuttings out of the well. In some cases synthetic drilling polymers are injected to form high-viscosity polymer slugs to facilitate clean-out. Commonly used drilling polymers include xanthan gum and starch and cellulose derivatives. Geothermal water extracted during well testing period is also considered as a drilling fluid. In some cases, geothermal water may be saline and contain elevated concentrations of components such as Arsenic and Boron.

ii. Spent Geothermal Fluids: These effluents consist of water from steam separators and condensate derived from spent steam condensation following power generation.

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iii. Reject Water from Injection Well: These effluents are produced during reinjection of geothermal water. This is a small amount, which is rejected by the geothermal source due to pressure.

iv. Cleaning Water: During the operation of wells, periodical cleaning is sometimes done using chemicals including strong acids, most commonly hydrochloric acid. The acids dissolve and remove mineral deposits from the wells and the surroundings. Before wells are subjected to acid treatment, it needs to be ensured that the well casings are leak proof to prevent any leakage of the acids to shallow groundwater aquifers. The acids are partially neutralized by dissolving the deposited minerals and then diluted through post-injection of fresh water or geothermal brine and finally by mixing with geothermal fluids in the reservoir before discharge.

v. Domestic Wastewater: These effluents are produced as a result of daily activities of workers during surface exploration, drilling and operation of a geothermal project.

Temporary impacts on surface water may also occur as a result of the release of geothermal fluids during well testing, if they are not contained. Geothermal fluids are hot and often highly mineralized and, if released to surface water, could cause thermal changes and changes in water quality. Accidental spills of geothermal fluids could occur due to well blowouts during drilling, leaks in piping or wellheads, or overflow from sump pits. Additionally, surface or groundwater use can be necessary during exploration, well drilling and facility operation. Furthermore, depending on the operation of facility, water can be used in cooling system. Surface and groundwater quality may also be adversely affected due to direct discharge of wastewater. Treatment or connection to municipal network should thus be made where necessary.

The well casing is the first barrier against pollution of groundwaters. Damaged casings may allow brines to mingle with fresh water aquifers. Therefore, particular care is taken to install and cement multiple casings at shallow depths to provide extra barriers. Cement-bond logs (integrity tests) are performed to assure the driller that there are no blind spots behind the casing that could rupture under thermal stress caused by repeated opening and closing of the well.

In case the discharge of the test waters is obligatory, the waters shall be stored in the impermeable area to be prepared at the drilling site at the suitable sizes and the shall be cooled down to 35 oC’ and discharged to the closest surface water during the times of than the watering period (April 1st - September 30th) with the maximum flow of 10 l/sec observing the criteria mentioned in the Table 9.5 of "Water Pollution Control Regulation" as given below:

PARAMETER UNIT

2- hour

Composite Sample

24- hour Composite Sample

Chemical Oxygen Demand (COD) (mg/L) 60 30

Oil and Grease (mg/L) 20 10

Total Cyanide (CN‾) (mg/L) -  0.5

Temperature (°C) - 35

pH  - 6-9 6-9

Drilling Mud

Water based drilling mud is sometimes used as a drilling fluid in geothermal drilling, particularly when drilling through the cap rock of the reservoir. Drilling mud typically consists of water mixed with bentonite (a natural clay). Additives are used to control the viscosity and density of the mud. These additives include xanthan gum and starch and cellulose derivatives for viscosity control and solid barium sulphate for density

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control. The drilling mud is recycled during drilling and the rock cuttings are separated from the mud in on shaker boards. Drilling muds are processed with activated carbon, and reused. If the rock cuttings consist of environmentally benign rock types, they can be disposed of in landfills. This is a practical and economical way to dispose of solid waste materials that can be used in most cases. However, cuttings may be classified as hazardous depending on the concentration and potential for leaching of silica compounds, chlorides, arsenic, mercury, vanadium, nickel, and other heavy metals. In such cases, cuttings need to be disposed of appropriately. Oil based drilling mud is very rarely used in geothermal drilling. Cuttings from oil-based drilling mud are of much greater environmental concern due to the content of oil-related contaminants. In the unlikely case oil based drilling mud would be used for geothermal drilling it may be necessary to apply special on-site or off-site treatment before disposal.

2. MAJOR SOCIAL IMPACTS of GEOTHERMAL POWER PLANTS

Community Health and Safety

Major community health and safety issues in geothermal projects include:

exposure to geothermal gases; facility safety; impacts on water resources

A qualified health impact assessment expert is needed to thoroughly examine the health impacts that are likely to occur as a result of a geothermal project implementation and operation. It is also important to do a baseline survey of local health and diCIAse incidences in Menderes Graben region to avoid speculation during and after implementation.

Occupational Health and Safety

Major health and safety issues in geothermal projects comprise the potential for exposure to:

geothermal gases; confined spaces; heat; noise.

In addition, the use of acids for well cleaning should be conducted by taking all precautionary measures and by using protective equipment. Storage of these substances at the site should be done according to hazardous waste control regulation.

Expropriation

From social point of view, development of geothermal resources may involve occupation of large areas depending on the scale of project (i.e. number of wells, length of pipelines, and size of power plant and separator stations). Hence, a land acquisition process is implemented. Where the project area is not government property, expropriation is required, which may be among the major impacts associated with geothermal development, similar to the case in other energy generation investments.

Cultural heritage

Geothermal development activities may cause impact on physical cultural heritage known to be of local, regional or national significance based on proposed national or provincial lists identified during public consultation with local affected groups.

Public Concerns and Acceptance

Menderes Graben is one of the consequence basins having agricultural potential, aspect of water and soil resources in Turkey. The adverse impacts (if any) on crop production rates of geothermal power plants in the region should be investigated in detail as this issue becomes a raising concern of the local community. Furthermore, likely effects on livelihoods, livestock and tourism should also be evaluated in detail.

Other Social Impacts21

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There may be population influx to project area and creation of new job opportunities and increase in local economic livelihoods. Positive aspects of geothermal development projects may be enhanced by providing such services to nearby communities. These include providing heating to the nearest settlements and/or industries or farms. This may be advantageous in terms of project costs if it results in removal of condenser from project formulation.

3. ENVIRONMENTAL MONITORING OF GEOTHERMAL POWER PLANTS

Turkey

Monitoring and control are essential components of best practice and they are significant for the quality of environmental impact assessment process. The Ministry of Environment and Urbanization monitors and controls projects which “EIA Positive” or “EIA is Not Required” decision has been made. In addition to this, the investor is under the obligation to deliver monitoring reports on initiation, construction, operation and post-operation phases. If the investor fails to comply with these obligations, the Ministry may give extra time for the developer to fulfil the requirements. In cases where the invester continues to fail to comply with the requirements, the project stops.

Facilities must also obtain the following permits before the start of operation:

Environmental permit. An environmental permit must be obtained from the Ministry of Environment (Environmental Permits and Licenses Regulation). This permit covers air, wastewater and noise emissions. Under the Permit and License Regulations, it is required to obtain a single consolidated permit, which is valid for a period of five years, instead of obtaining separate environment permits (e.g., emission permit and water discharge permit). The Regulation sets forth a temporary certificate, a "temporary activities certificate" and two types of permits, an (i) "environmental permit" (çevre izni) and an (ii) "environmental permit and license" (çevre izni ve lisansı). The environmental permit covers air emissions, environmental noise, deep sea discharge and hazardous waste discharge, whereas the environment license addresses the technical sufficiency of the applicant facility. Geothermal drilling activities are subject to environmental permitting procedure under Annex 1 of this regulation; however, geothermal power plant operations are not considered under this regulation.

Workplace operating licence. A workplace operating licence must be received from the relevant municipality (Regulation Concerning the Workplace Opening and Operating Licence).

Wastewater connection certificate. If a facility discharges wastewater into the sewage system, a wastewater connection certificate must be obtained from the relevant municipality under the relevant municipal regulation. An environmental permit does not cover wastewater emission into the sewage system.

Hazardous waste storage permit. This permit must be obtained from the Ministry of Environment in order to store a monthly amount of over 1000 kg of dangerous waste temporarily at a facility site. This waste must be collected from the facility site every six months by an entity licensed for dangerous waste management activities.

Additionally, according to the Regulation Regarding Environmental Audit particularly polluting activities and industries are obliged to establish an Environmental Audit Units or to employ an Environmental Officer or to obtain Environmental Audit Service within the given term in such Regulation (18 up to 24 months based on the categorization of such particularly pollution activity or industry by this Regulation). Similarly, geothermal drilling activities are subject to environmental permitting procedure under Annex 1 of this regulation; however, geothermal power plant operations are not considered under this category.

2. 1. Environmental Monitoring in Other Countries

Iceland

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In Iceland, the National Planning Agency is only responsible for administering an environmental impact assessment when it comes to research or utilisation of geothermal energy. The Agency has no responsibility as a monitoring authority; as soon as the environmental assessment has been conducted the monitoring becomes the responsibility of the authority that issues a licence for a project. For example, after a municipal council has issued a development or a building licence for construction subject to an environmental impact assessment, that council is thereafter responsible for monitoring that construction. The councils can only issue development licences if an environmental impact assessment has been carried out or if the National Planning Agency has decided that the project is not subject to such an assessment. The council then reaches a decision based upon the verdict of the National Planning Agency, and in the development licence the council can apply the recommendations set forth in the Agency’s decision on the need for an environmental impact assessment. The municipalities have executive power, according to the Planning Act. It is the municipal council’s responsibility to continue to monitor projects, both those subject to a development licence and those subject to a building licence; the council is to make sure that the project is carried out according to the description in the licence and relevant legislation.

It is also the Environment Agency’s and Nature Conservation Committees’ responsibility to present their verdict before a development or building licence is issued. The Environment Agency supervises the proper enforcement of the Pollution Control Act by supervising and coordinating health inspection and monitoring and ensures that it is carried out in an efficient manner and does not overlap. An environmental monitoring plan is always included in the EIA of a geothermal project, which has to be implemented once the project is in operation. The parameters included are discussed and proposed by the developers and approved by the Environment Agency. Monitoring and reporting is the responsibility of the developers and the monitoring reports have to be submitted to the local environment agencies and the municipal governments.

New Zealand

New Zealand is a country that has pioneered the sustainable use of its geothermal resources, and the main key for achieving this goal is the management of environmental effects through appropriate regulation. The principal environmental legislation in New Zealand is the Resources Management Act (RMA). The RMA was designed to bring all resources under one set of environmental regulations. The Act was implemented in 1991 along with the 1991 Crown Minerals Act. These two laws consolidated and amended scores of acts to provide for a streamlined review and the protection of natural resources. The RMA focuses on the effects of projects, rather than on the type of project, in order to ensure that all activities are treated equally. The environmental management of geothermal resources is administered by Regional Councils under the Resource Management Act (1991). Monitoring is organized through a District Plan Monitoring to fulfil the RMA, Section 35: “to gather information, monitor, and keep records of the state of the whole or any part of the environment of its region to effectively carry out its function”.

Local authorities have an obligation to monitor the exercise of resource consents which have an effect on their region or district and to take appropriate action where this is necessary. The conditions of a resource consent may also require the consent holder to monitor the environmental effects of the activity to assist in ensuring compliance with the consent conditions and to determine effects of the consented operation. This may include collecting samples and making measurements, carrying out analysis, surveys, investigations or inspections and providing information to the consent authority at specified times. The results of such monitoring should be publicly available and obtainable from the consent authority. Geothermal resources are scattered in many regions of New Zealand, but it is thought that 80% of the high-temperature resources are in the Waikato region, administered by the Waikato Regional Council, also known as Environment Waikato. An environmental monitoring programme, established under conditions associated with the original resource consent, has included subsidence, gas emissions (H2S, Hg), groundwater, streams, vegetation, fauna and surface thermal features in the Rotokawa, Mokai, and Wairakei geothermal fields.

Each year in the Waikato region, the consents for geothermal developments are examined to see whether monitoring and reporting conditions have been complied with. The site is visited by council staff, who also look for unauthorised activities and potential hazards. Compliance monitoring reports are then sent to the

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developer setting out the consent conditions which have not been complied with (if any), and any issues of concern to council staff. A common problem in New Zealand is that regulatory authorities rarely have scientific or engineering staff with the appropriate qualifications and experience to assess the monitoring data. To overcome this problem, the monitoring results are initially examined by a Review Panel. Each developed field has a separate Panel. The panels are composed of 3 geothermal experts who are independent of the developer, and often comprise retired geothermal professionals and university staff. The panels meet twice yearly for the first two years of development, then annually after that, to examine the results of the monitoring programme which are prepared by the developer and given to panel members prior to panel meetings. The formal meetings last about one day, and the costs are paid by the developer. The Panel then prepares a report to the regulatory authority, which may then recommend changes to the direction in which the development proceeds and any further monitoring that might be needed. Data and interpretation provided by the developer to the panel, and the panel reports are considered to be public information and can be requested by any member of the public, except that the developer may request that certain information which might be of commercial value be kept confidential.

USA

Development of every type in the U.S. is governed by many environmental laws at the federal, state and local level. The key laws that pertain to the environmental aspects of geothermal development are:

National Environmental Policy Act (NEPA);

Geothermal Resources Operational Orders (GROs);

Specific resources protection laws.

The National Environmental Policy Act (NEPA) is one of the primary U.S. laws for the protection of the environment. The California Environmental Quality Act (CEQA) is an example of state legislation based on NEPA. CEQA requires that each local agency of the city, county or state develop and implement an environmental monitoring programme for all public and private projects for which an environmental impact assessment report or a negative declaration is prepared.

An example of a monitoring programme to meet the CEQA requirements include: (1) the utilization of existing inspection officials wherever possible; (2) the merging of mitigation measures, conditions of approval, and verification procedures into a single document stream managed by the city; (3) making the project proponent responsible for preparation of the compliance schedule; (4) verification of compliance by independent, professionally qualified personnel; (5) submission of periodic compliance reports by the project proponent; (6) an annual environmental monitoring report by the city.

The city monitoring programme is under the general direction of the city’s monitoring manager and under the general supervision of the city’s planning director. The project proponent is responsible for compliance with the mitigation measures and for meeting the requirements of a compliance schedule. The project proponent periodically submits compliance reports. The specific reporting frequency is established in the compliance schedule, and is approved by the appropriate verification inspection entity. The monitoring manager, city inspectors and delegated authorities conduct periodic, unannounced spot checks to verify project compliance. The verification reports are compiled by the monitoring manager. Any person or agency may file a complaint alleging noncompliance with the conditions of approval. Such a complaint must be in writing and provide specific information on the alleged violation. The monitoring manager receives all such complaints, and, with the help of the appropriate city inspector, determines the validity of the complaints and reports the result to the planning director. At the end of the year, the monitoring manager prepares an annual environmental monitoring report which includes a summary of all verification reports, analysis of deficiencies and actions to correct them, a summary and analysis of any disputes, and recommendations for future mitigation measures and other corrective actions needed.

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