independent environmental & social consultant

FINAL REPORT OF THE:

INDEPENDENT ENVIRONMENTAL & SOCIAL CONSULTANT

ENVIRONMENTAL AND SOCIAL DUE DILIGENCE OF THE TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT FINAL JUNE 2017

INDEPENDENT ENVIRONMENTAL & SOCIAL CONSULTANT

ENVIRONMENTAL AND SOCIAL DUE DILIGENCE

TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT

Prepared for: European Bank for Reconstruction and Development

Prepared by: Sustainability Pty Ltd

Suite 3, 118 Flora Terrace

North Beach, Western Australia, 6020

www.sustainability.net.au

+61 (0)8 9246 6666

Team Members: John Miragliotta Project Director

Marc Barendrecht Environmental Specialist

Amy Sexton Social/Cultural Heritage Specialist

Catherine Grant Social Advisor

Saniye Onur Local Environmental Specialist

http://www.sustainability.net.au/

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental Due Diligence June 2017

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ........................................................................................ I

EXECUTIVE SUMMARY ....................................................................................................... III

PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES ............................................................ III

PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS ........................................... V

PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY ................................................................ VII

PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY .................................................................. VIII

PERFORMANCE REQUIREMENT 5: LAND ACQUISITION, INVOLUNTARY RESETTLEMENT AND ECONOMIC DISPLACEMENT ................................................................................................ IX

PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL RESOURCES ................... XII

PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE .................................................................. XIV

PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND STAKEHOLDER ENGAGEMENT ............................................................................................................................ XIV

REPORT ORGANISATION .................................................................................................. XVI

1. INTRODUCTION ........................................................................................................... 1

1.1 SCOPE OF WORK ........................................................................................................................... 1 1.1.1 Reviews and Assessments .................................................................................................. 2 1.1.2 Site Reconnaissance ........................................................................................................... 3 1.1.3 Reporting .......................................................................................................................... 3

1.2 LENDER POLICIES ......................................................................................................................... 6 1.2.1 EBRD Performance Requirements ........................................................................................ 6

1.3 SOURCES OF INFORMATION ......................................................................................................... 6

2. SUMMARY OF PROJECT CHARACTERTISTICS .............................................................. 7 2.1.1 Current Progress ................................................................................................................ 8

3. INSTITUTIONAL AND LEGAL FRAMEWORK ............................................................... 10

4. ENVIRONMENT, SOCIAL, HEALTH & SAFETY REVIEW AND AUDIT ........................... 12

5. COMPLIANCE AGAINST EBRD PERFORMANCE REQUIREMENTS ............................... 13

5.1 PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES ............................................................. 13 5.1.1 Environmental and Social Assessment ................................................................................ 13 5.1.2 Environmental and Social Management System .................................................................. 18 5.1.3 Environmental and Social Policy ........................................................................................ 19 5.1.4 Environmental and Social Management Plans ..................................................................... 19 5.1.5 Organisational Capacity and Commitment .......................................................................... 21 5.1.6 Supply Chain Management ............................................................................................... 22 5.1.7 Project Monitoring and Reporting ...................................................................................... 22

5.2 PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS .............................. 28 5.2.1 Human Resource Policies and Working Relationships ........................................................... 28 5.2.2 Child and Forced Labour ................................................................................................... 30 5.2.3 Non-Discrimination and Equal Opportunity ......................................................................... 30 5.2.4 Workers Organisations ..................................................................................................... 30 5.2.5 Working Conditions .......................................................................................................... 30 5.2.6 Retrenchment.................................................................................................................. 32 5.2.7 Grievance Mechanism....................................................................................................... 32 5.2.8 Non-Employee Workers .................................................................................................... 33 5.2.9 Supply Chain ................................................................................................................... 33


5.2.10 Security Personnel ........................................................................................................... 33

5.3 PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND CONTROL ...................................................................................................... 40 5.3.1 Resource Efficiency .......................................................................................................... 40 5.3.2 Pollution Prevention and Control ....................................................................................... 40 5.3.3 Greenhouse Gases ........................................................................................................... 42 5.3.4 Water ............................................................................................................................. 43 5.3.5 Waste ............................................................................................................................. 43 5.3.6 Hazardous Substances ..................................................................................................... 43

5.4 PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY ........................................................... 47 5.4.1 Occupational Health and Safety ......................................................................................... 47 5.4.2 Community Health and Safety ........................................................................................... 49 5.4.3 Infrastructure, Building and Equipment Design and Safety ................................................... 49 5.4.4 Hazardous Materials Safety ............................................................................................... 50 5.4.5 Traffic and Road Safety .................................................................................................... 50 5.4.6 Natural Hazards ............................................................................................................... 50 5.4.7 Exposure to Disease ......................................................................................................... 50 5.4.8 Emergency Preparedness and Response ............................................................................ 51

5.5 PERFORMANCE REQUIREMENTS 5: LAND ACQUISITION, INVOLUNTARY RESETTLEMENT, AND ECONOMIC DISPLACEMENT .................................................................... 56 5.5.1 Physical and Economic Displacement ................................................................................. 56 5.5.2 Consultation .................................................................................................................... 57 5.5.3 Compensation ................................................................................................................. 59 5.5.4 Grievance Mechanism....................................................................................................... 61 5.5.5 RAP/LRP Documentation .................................................................................................. 62 5.5.6 RAP/LRP Implementation.................................................................................................. 62 5.5.7 Monitoring ...................................................................................................................... 63

5.6 PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL RESOURCES ................................................................................................................................. 68 5.6.1 Assessment of Biodiversity and Living Natural Resources ..................................................... 69 5.6.2 Conservation of Biodiversity .............................................................................................. 77

5.7 PERFORMANCE REQUIREMENT 7: INDIGENOUS PEOPLE.......................................................... 87

5.8 PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE .......................................................... 88 5.8.1 Assessment and Management of Impacts on Cultural Heritage ............................................. 88 5.8.2 Consultation .................................................................................................................... 89

5.9 PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND STAKEHOLDER ENGAGEMENT ..................................................................................................... 91 5.9.1 Stakeholder Engagement Plan ........................................................................................... 91 5.9.2 Operational Grievance Mechanism ..................................................................................... 92 5.9.3 Information Disclosure ..................................................................................................... 92

6. COMPLIANCE AGAINST TURKISH ENVIRONMENTAL, HEALTH, SAFETY,

AND SOCIAL LAWS, REGULATIONS, AND PERMITS ................................................... 95

6.1 HOST GOVERNMENT AGREEMENTS ............................................................................................ 95

6.2 EIA PROCESS IN TURKEY ............................................................................................................ 95

7. COMPLIANCE AGAINST OTHER APPLICABLE STANDARDS / LAWS / CONVENTIONS ........................................................................................................... 98

7.1 EU DIRECTIVES ........................................................................................................................... 98

7.2 INTERNATIONAL LAWS / CONVENTIONS .................................................................................. 98

7.3 IFC EHS GUIDELINES .................................................................................................................. 98

7.4 TANAP PROJECT HSES STANDARDS ........................................................................................... 98

8. HIGH LEVEL COMPLIANCE ASSESSMENT OF ASSOCIATED

INFRASTRUCTURE...................................................................................................... 99


APPENDIX A: DOCUMENT LIST ........................................................................................................... 113

APPENDIX B: IFC EHS GUIDELINES COMPLIANCE ASSESSMENT TABLE........................................... 162

APPENDIX C: ENVIRONMENTAL AND SOCIAL ACTION PLAN ............................................................ 183

TABLES

Table 5-1 PR 1 Findings Summary .................................................................................................... 24 Table 5-2 PR 2 Findings Summary .................................................................................................... 36 Table 5-3 PR 3 Findings Summary .................................................................................................... 44 Table 5-4 PR 4 Findings Summary .................................................................................................... 52 Table 5-5 PR 5 Findings Summary .................................................................................................... 65 Table 5-6 PR 6 Findings Summary .................................................................................................... 80 Table 5-7 PR 8 Findings Summary .................................................................................................... 90 Table 5-8 PR 10 Findings Summary .................................................................................................. 93 Table 8-1 High Level Compliance Evaluation – Associated Infrastructure ............................................ 100

FIGURES

Figure 1.1 TANAP Pipeline Overview ................................................................................................... 4 Figure 1.2 TANAP Pipeline Route Within Turkey ................................................................................... 5 Figure 5.1 Pipeline Route Assessment Process ................................................................................... 16 Figure 5.2 ESIA Consultation approach .............................................................................................. 17 Figure 6.1 Turkish EIA Process ......................................................................................................... 97

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page i

ACRONYMS AND ABBREVIATIONS

ADB Asian Development Bank

AGI Above-Ground Installation

BAP Biodiversity Action Plan

BAT Best Available Technology

bcma billion cubic meters per annum

BOP Blow Out Preventer

BTC Baku-Tbilisi-Ceyhan

CAP Corrective Action Plan

CC Construction Contractor

CST Compressor Station

ERP Emergency Response Plan

CFC Chlorofluorocarbon

CHMP Cultural Heritage Management Plan

CHSS Community, Health, Safety, and Security

EBRD European Bank for Reconstruction and Development

EHS Environment, Health and Safety

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EPs Equator Principles

ERMP Employee Relations Management Plan

ES Environmental and Social

ESAP Environmental and Social Action Plan

ESHS Environmental, Social, and Health and Safety

ESIA Environmental and Social Impact Assessment

ESMP Environmental and Social Management Plan

ESMS Environmental and Social Management System

ESR Environmental and Social Review

EU European Union

FFD Full Field Development

FGR Flare Gas Recovery

FID Final Investment Decision

GHG Greenhouse Gas

GIP Good International Practice

HCFC Hydrochlorofluorocarbon

H&S Health and Safety

HR Human Resource

HSES Health, Safety, Environmental and Social

HSE Health, Safety and Environmental

HUC Hook-Up and Commissioning

IBA Important Bird Area

IESC Independent Environmental and Social Consultant

IFC International Finance Corporation

ILO International Labour Organisation

IP Indigenous Peoples

ISD Inherently Safer Design

JV Joint Venture

KBA Key Bird Area

KPI Key Performance Indicator

LARP Land Acquisition and Resettlement Procedures

LTMOBM Low Toxicity Mineral Oil Based Muds

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page ii

MEG monoethylene glycol

MoEU Ministry of Environment and Urbanisation

MP Management Plan

MSDS Material Safety Data Sheet

NCR Non-Conformance Report

NGO Non-Governmental Organisation

NO2 Nitrogen Dioxide

Nitrous Oxide Nitrous Oxide

OHS Occupational, Health and Safety

OMS Operating Management System

OSID Online Stakeholder Interaction Database

OSPAR The Convention for the Protection of the Marine Environment of the North-East Atlantic

OSRP Oil Spill Response Plan

PAHs Polycyclic Aromatic Hydrocarbons

PAP Project-Affected Person

PPE Personal Protective Equipment

PS Performance Standard

PR Performance Requirement

RfP Request for Proposal

RAP Resettlement Action Plan

SCP Southern Caucasus Pipeline

SD Shah Deniz

SEP Stakeholder Engagement Plan

SMP Social Management Plan

SOP Standard Operating Procedure

SPS Safeguard Policy Statement

Sustainability Sustainability Pty Ltd

TAP Trans Adriatic Pipeline

TANAP Trans Anatolian Pipeline

TSP Total Suspended Particle

USEPA United States Environmental Protection Agency

VOC Volatile organic compounds

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page iii

EXECUTIVE SUMMARY

This report contains the Environmental and Social Due Diligence (ESDD) for the TANAP Project in

Turkey. Sustainability Pty Ltd (Sustainability) was engaged by the European Bank for Reconstruction

and Development (EBRD) as the Independent Environmental and Social Consultant (IESC) to conduct

the ESDD. The ESDD was developed based on an extensive document review and incorporated a site

visit to Lots 1 and 3 of the TANAP pipeline route.

The Project is substantially commenced, with construction works having started on all 4 Lots of the

pipeline route. Construction contracts for the offshore pipeline have been awarded but works have

not yet commenced. Relevant dates for the remainder of the construction period include:

• Commencement of offshore construction – July 2017;

• Mechanical Completion of Phase 0 pipeline – December 2017;

• Supply of gas to Eskişehir (offtake station) Phase 0 complete – June 2018;

• Material Completion of Phase 1 pipeline works – December 2018;

• Gas supply to Europe – June 2019.

The IESC observed strong adherence to the EBRD Environmental and Social Policy requirements as

communicated through the respective Environmental and Social Performance Requirements (PRs) of

the EBRD. TANAP personnel involved in the ESDD process were open, transparent, and willing to

provide all requested documentation and assistance to the IESC before, during and after the site visit

in order to facilitate the finalisation of this ESDD. The structure of the ESDD Report is outlined at the

end of this Executive Summary.

With respect to compliance with the PRs, the IESC has observed no Material Non-Compliances, and a

number of Partial Compliances, which are explained further in this Executive Summary and again in

more detail in the body report. The partial compliance items identified are considered readily

addressed through the development and implementation of the Environmental and Social Action Plan

presented in Appendix C of this ESDD Report.

Applicable Performance Requirements are PR1, PR2, PR3, PR4, PR5, PR6, PR8 and PR10.

PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES

The TANAP project is under development in Turkey consistent with the Project’s Host Government

Agreement (HGA), which provide guidance on the expected Environmental and Social (E&S)

standards and requirements, preparation of an ESIA, and the project’s social investment program.

The Project carried out an ESIA as the means of scoping and assessing its environmental and social

impacts, commensurate with the environmental and social impacts presented by the Project. The

ESIA was publicly disclosed on the TANAP website (22 June 2015). Turkey’s Ministry of Environment

and Urbanisation (MoEU) approved the ESIA in June 2014.

E&S aspects and impacts have been considered during Project scoping and planning, with due

consideration of the mitigation hierarchy and Good International Practice (GIP). Route selection was a

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page iv

key focus for ensuring that E&S impacts were minimised while providing for technical feasibility in

installation. E&S criteria were used to narrow the Preferred Route Corridor from 2km to 500m. Within

this 500-metre corridor the centreline for the corridor was delineated and the Right of Way (RoW)

disturbance area of 36 metres was located. The ESIA was conducted on the full 500-metre pipeline

corridor on Route H. Significantly, there is no physical displacement of households along the entire

corridor route. Route selection changes were implemented throughout the construction phase to

avoid significant cultural heritage sites and designated wildlife areas, among others, managed

through a Management of Change (MoC) process.

Stakeholder engagement and consultation has been carried out throughout scoping, preconstruction,

and construction phases, and the key issues raised through consultation are considered within the

final ESIA and ESMPs. Consultation provided for the input of local, regional, national and international

stakeholders, and separate inputs of local authorities and vulnerable groups, including women and

children locally. TANAP has in place a web-based online stakeholder interaction database (OSID) to

track, record and manage all stakeholder engagement activities including grievance management.

At the commencement of the Project, TANAP employed a three-tiered contractor structure to

implement the Project, with an Engineering, Procurement, Construction and Management (EPCM)

contractor managing the selected Construction Contractors (CCs) in the field. TANAP has recently

modified this structure to an integrated two-tier organisation (with TANAP and CCs), removing the

EPCM contractor from the organisational structure. The IESC noted during the audit that the ESMS

was out of date with respect to roles and responsibilities and subsequent system documentation. In

many instances, the same individuals are working in the same roles (i.e. former EPCM staff are now

directly employed by TANAP) so while day to day activities appear to remain well-managed and

understood by staff, ESMS documentation reviewed during the audit did not reflect the current

organisational structure and so may not effectively manage potential risks (e.g. arising from incidents,

staff changes). The IESC team considers this issue to be compliant with this PR, given that the issue

is known, changes substantially commenced, and is considered to be part of normal ESMS review and

improvement during the life of the Project. Furthermore, subsequent evidence provided to the IESC

indicates that the revision of TANAP documents is complete, and that CC reviews are ongoing and will

be provided to the IESC as they are approved.

The ESIA assessed potential E&S impacts of the project on communities and the related ESMPs were

prepared to manage any outstanding residual risks. Internal and third party monitoring is undertaken

of delivery of ESIA and ESMP commitments. This includes third party monitoring by Turkish

consultants, Çınar Engineering Consulting Co. (Çinar), of:

• Construction Impacts Management Plan (ESIA Appendix 5.1);

• Community Safety Management Plan (Appendix 5.2);

• Community Relations Plan (Appendix 5.3);

• Employment and Training Plan (Appendix 5.4);

• Procurement and Supply Management Plan (Appendix 5.5);

• Aggregate Management Plan (Appendix 5.6);

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page v

• Traffic Management Plan (Appendix 5.7);

• Cultural Heritage Management Plan (Appendix 5.8);

• Erosion, Reinstatement and Landscaping Plan (Appendix 5.9);

• Pollution Prevention Plan (Appendix 5.10);

• Waste Management Plan (Appendix 5.11);

• Emergency Response Plan (Appendix 5.12).

Some gaps were observed in the review of the ESIA related to the assessment of offshore

construction impacts. The review found that the ESIA did not adequately assess the impacts related

to the potential for vessel to vessel interactions and vessel interactions with marine fauna. Vessel to

vessel interactions are considered a high risk given the stated level of high shipping traffic and vessel

use in the offshore project area. Subsequent evidence provided is sufficient to demonstrate

compliance to the IESC. Specifically, as there was limited information available regarding offshore

construction methodology during the ESIA development, a comprehensive HAZID was conducted

post-ESIA development, which assesses construction related risks, including vessel to vessel

interactions. Prior to commencement of offshore construction activities, the existing HAZID will be

updated and a set of Task Risk Assessments will be developed by the Contractor to identify and

mitigate potential Project-related risks for offshore activities. Disclosure of Offshore ESMS

documentation is also planned to occur to ensure requirements of EBRD PRs are met.

As one of the major goods or services purchased by the Project, the lengths of pipe for the

construction of the pipeline presented a significant potential supply chain management risk, with

suppliers located within Turkey and internationally, in China. Evidence from TANAP describes the

desktop environmental assessment of Pipe producers that was undertaken during the pre-qualification

process including an OHS inspection by the EPCM. Documentation demonstrates TANAP’s efforts in

broadly ensuring E&S requirements can be managed appropriately in its supply chain through the

suppliers’ requirements for implementing an ESMS commensurate to the complexity, nature and scale

of the Project.

PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS

No material non-compliances were identified as part of the review against labour and working

conditions criteria. Some partial compliances were observed in other areas within this PR.

During discussions related to employee grievances, overtime work and fatigue management were

raised on several separate occasions to the IESC. Interviews revealed confusion at a site level as to

the TANAP policy on overtime. TANAP does not encourage overtime work for its employees, however,

due to the nature of the project, overtime work may occur within the legal limits. During interviews

on site with Lot 1 Contractor Fernas, personnel reported that overtime was allowed under Fernas

company policy. . TANAP is working to address overtime issues through a “Working Hours Action

Plan” that substantively addresses overtime issues, including stakeholder complaints of overtime, CC

compliance with TANAP overtime policies, and enforcing legal compliance with the Turkish Labour

Code. The Action Plan aims to reach compliance with the Labour Code by December 31, 2017. The

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page vi

IESC notes that the Action Plan emphasis is directed to legal compliance around overtime. While

there is a commitment to ensure that overtime hours are worked safely and without duress, it was

not clear how fatigue management measures are linked with effective overtime management. It is

also noted that contractors are financially incentivised for being on time/advance of deadlines, which

may contribute to the issue of overtime and fatigue. To this end, additional information was provided

to the IESC by TANAP in the form of the H&S Incentive Procedure (TNP-PCD-HSM-GEN-025) which

aims to promote awareness of H&S and incentivise workers regarding their H&S performance in order

to ensure that there is a balance between schedule / milestone incentives. During meetings with the

IESC on 12 May 2017, TANAP also noted that the link between financial incentives and effective

fatigue management is an area of current concern, and provided the example of hydrotesting,

whereby additional resources were engaged rather than the use of longer hours (Lot 1 had two

hydrotest crews, and it now has three crews and a fourth is being mobilised).

TANAP, through its contracting arrangements, ensure no child or forced labour is in use in the Project

through employment procedures. Nationally, Turkey has ratified the core ILO conventions including

on non-discrimination and TANAP’s role includes ensuring compliance with core labour standards on

behalf of the Project. Worker organisations are in place in parts of the Project, and all employees are

free to join labour unions.

Interviews with short term labour suggests that not all CCs are making clear what the working

conditions (including retrenchment/termination) are, and in absence of a TU, the individuals

interviewed stated that any issues have been raised through the Muhtar to the relevant CC for

resolution through the Grievance Mechanism. While the TANAP Project Site Audit Procedure provided

as evidence includes requirement for provision of document of resignation or notice of termination,

there appears to be confusion at a ground level regarding termination and retrenchment. This may be

exacerbated in the case of short-term contracts that are open-ended, or, renewed without formal

extension of the completion date. While notice periods for dismissal of staff are in accordance with

Turkish Labour Law requirements, in practice notice periods for dismissal may be occurring

inconsistently, particularly in relation to casual / short-term work. For example, TANAP reported that

the third-party audits have not found inconsistencies with national legislative requirements, however

in interviews with locally engaged staff at Ardiçli village, it was stated that following the completion of

a one year contract at the CC, a short-term contract was commenced with a subcontractor with no

contract in place and little notice for ‘termination’ of the worker. Internal audits are conducted of CCs

indicating compliance checks against labour issues including overtime and communications on

contracts with workers. These audits are documented in the TANAP Project Site Control Procedure,

the scope of which is to audit working conditions and rights of workers including working hours,

leave, payroll, Social Security, and terminations/new hires by carrying out a physical audit at least in

one camp monthly.

Some working conditions and amenities observed at Lot 1 did not appear appropriate to the nature of

the work being conducted and the climatic conditions at the time. TANAP presented to the IESC

information regarding non-conformance reporting (NCRs) and management. NCR requirements

address the process in place to develop and assess criticality of NCRs, and steps for root cause

analysis, corrective action implementation and NCR closure. This observation was noted in relation to

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page vii

works conducted at Lot 1 and it is recognised that working conditions observed at Lot 3 were much

improved.

In relation to security, the IESC considers that reasonable efforts have been made to align with this

PR, including adequate due diligence of security providers and presence of Standard Operating

Procedures guiding activities. Training on use of force and appropriate conduct towards communities

by security personnel is considered efficient to demonstrate compliance (e.g. Security Risk

Assessment, training records, Security Management Plan).

PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY

Observed performance against this PR was found to be strong, and in full compliance with the PRs.

The ESIA and ESMPs provide the overarching Project principles for the application of resource

efficiency and pollution prevention principles. These Principles are defined as: identify and understand

impacts; consult with others; design and avoid adverse impacts and minimise use of natural

resources. The ESMPs includes environmental control strategies designed to reduce waste and

conserve natural resources through engineering and procurement environmental design controls and

construction and installation controls.

PR 3 requires that the ESIA process identifies opportunities and alternatives for resource efficiency in

accordance with GIP. The Compressor Stations (CSTs) are a major emitter of GHG during operation

of the pipeline, as identified in the ESIA. A Best Available Technology (BAT) assessment has been

conducted and provides sufficient detail so as to verify that EBRD guidance requirements have been

met in relation to how the adoption of resource efficiency and waste reduction considerations helped

to define the technology chosen in the CSTs. The BAT included detail on the realisation of the energy

savings that are possible because of the adoption of BAT for the CSTs and demonstrated that energy

efficiency measures have been identified.

Regarding onshore hydrotest water, this will preferentially be taken from surface water bodies. After

use, it is intended that water be treated until it meets the required Project Standards and discharged

back to the closest receiving environment (surface water). Where possible, addition of chemical

corrosion inhibitors will be avoided, although in some cases they may be required. The hydrotesting

process is managed through an Environmental Hydrotest Monitoring Plan, developed under TANAP

guidance for each CC over the four Lots. Each water abstraction and discharge point along the entire

route was assessed for water quality and ecological restrictions and appropriate management

measures proposed (i.e. exclusion of fish spawning periods for extraction activities).

The ESIA has assessed impacts related to GHG emissions, although it does not appear to contain

consideration of technically and financially achievable options to minimise emissions of GHG in the

assessment process. Upon IESC request, supplementary evidence was provided, in the form of the

BAT emissions inventory and relevant evaluation data, that demonstrates that resource efficiency

measures have been considered during design (e.g. ability to limit venting of gas, alternative forms of

power supply during operations or waste heat recovery systems).

As per the requirements of both Turkish and EU legislation, TANAP utilises licenced contractors to

transport and dispose of hazardous waste. The EBRD PRs recommend that clients ascertain whether

licenced disposal sites are being operated to acceptable standards. TANAP has conducted site

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page viii

verification audits of a sample of disposal facilities along the pipeline route to ensure that their waste

is being disposed of appropriately by the contractor.

PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY

The IESC team has not recorded any material non-compliances within PR 4, while there are several

partial compliance areas.

A review of the Project incident database identified that there were many incidents that involved near

misses and first aid / lost time injuries related to pipeline lifting activities. One of the recorded

fatalities was also a lifting incident. The detailed incident report related to the lifting fatality stated

that root causes of the incident were insufficient training and a lack of suitable procedures for the

tasks. Interviews with employees on the Lot indicated that it was normal practice for personnel to be

in the designated ‘danger zone’ during lifts, amongst other system failings. The fact that it was

considered normal working practice to be within the ‘danger zone’ during lifts also indicates that there

may have been a lack of appropriate supervision and conduct of workplace inspections of lifting

activities by TANAP in the field. It is also unclear if corrective actions (i.e. retraining all lifting

personnel) were rolled out to all CCs on other Lots or were contained to just the Lot on which the

incident occurred.

The IESC team has some concern that lifting activities in particular are leading to a relatively high

occurrence of reported incidents / near misses. Given that lifting of pipe is one of the most common

activities on the Project which has the potential for serious injury or fatalities, a certain level of

control and supervision of the tasks by TANAP would be expected, particularly given that lifts on the

Project are not controlled under the permit to work system TANAP reports that Lessons Learnt

documents of incidents are being shared with all lots and stations, and actions are being followed up

by LOT and Station Leads (Delivery Manager, Lot HS Lead, etc). Relevant procedures and official

letters provided and discussed with TANAP in meetings held on 12 May 2017 indicate that appropriate

remedial actions are being implemented by TANAP in relation to lifting activities.

Other areas of concern relate to CC performance in managing community safety on site (e.g. fencing,

signage, accessibility of open trenches, engagement with affected communities); and the Project’s

use of epidemiological studies to inform management of communicable diseases and implementation

of community health programs. TANAP reports that trench registers are being kept for the entire

route, including the barricading status of open trenches, and are being closely followed up by the

Construction and HS Teams. Additionally, the Community Relations Team is undertaking Community

Safety Awareness meetings including access to open trenches, ROW, risks related with unauthorised

site access, and construction and traffic safety with communities throughout the pipeline route.

In alignment with a key construction phase project risk, there was evidence of strong management of

potential road safety impacts to both workers and communities. These included travel management

tools, vehicle controls and monitoring, and community and worker training, and specific training with

women and children to minimise public health risks due to vehicle traffic. TANAP is commended for

investing significantly and providing strong management of potential road safety impacts to both

workers and communities. These included travel management tools, vehicle controls and monitoring,

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page ix

and community and worker training, and specific training with women and children to minimise public

health risks due to vehicle traffic.

Construction Contractor MPs and procedures are aligned with those prepared by TANAP, and

documentation reflects a mitigation hierarchy approach. Awareness-raising within the workforce of

interactions with the community, interactions with emergency responders, and awareness for the

community of potential project hazards are all included in worker training.

Community Safety MPs provide for communicable disease training to the workforce and engagement

with local health authorities to agree appropriate mitigation actions, who have also been investigated

and engaged should any incidences of communicable diseases eventuate. Local engagement and

employment practices have been key in mitigating any potential effects of population influx, including

community exposure to disease.

Emergency Response Plans (ERPs) have additionally been developed and approved by TANAP,

including provision for engagement and training with external emergency responders by the Project,

led by TANAP’s Security and Emergency Response departments. These plans are supplemented by

mapping of available health services along the pipeline, and address potential for community conflicts

that may occur as a result of the Project. Regular walk-overs and fly-overs of the pipeline are in place

for the construction phase of the Project to monitor potential pipeline intrusion, while building

intrusion systems are being implemented during construction for all AGIs.

ERPs related to operation of the pipeline are currently in development and are stated to be ready six

months prior to operation. Offshore construction ERPs including an Oil Spill Emergency Response

Plan required to manage response to vessel interactions have been drafted and TANAP plan to

complete these prior to construction in the offshore package commencing in late June 2017. TANAP

are required to have these developed and disclose these plans prior to commencement of offshore

works.

PERFORMANCE REQUIREMENT 5: LAND ACQUISITION, INVOLUNTARY RESETTLEMENT AND ECONOMIC DISPLACEMENT

No material non-compliances were identified as the part of the review against land acquisition,

involuntary resettlement and economic displacement criteria. The RAPs present the overall impacts,

policy and legislative framework, land acquisition process, consultations and disclosure details and

implementation arrangements, indicative implementation schedules and budgets and significant

further work has been undertaken by TANAP and Lenders to develop additional commitments to meet

international requirements in land acquisition and resettlement.

The suite of key documents relating to TANAP land acquisition, involuntary resettlement and

economic displacement activities are the 2014 Resettlement Action Plan (RAP), the RAP for Above

Ground Installations (AGIs RAP) and a RAP for the Pipeline (Pipeline RAP), and the Guide to Land

Acquisition and Compensation (GLAC), developed for stakeholders.

Following an Implementation Audit and World Bank due diligence investigations, a new suite of

studies, commitments, processes, and documents was developed and implemented by TANAP to fulfil

international standards in land acquisition and livelihood restoration. The areas covered by the

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page x

additional corrective actions identified by TANAP address: Compensation and Entitlements; Livelihood

Restoration; Vulnerable Groups; Grievance Redress Mechanism; Community Engagement and

Disclosure Policy; Monitoring Process; and Local Employment.

Full compliance was observed in relation to avoidance or minimisation of displacement. Route

realignment has been carried out during the construction phase to manage deviations from the ESIA

approved alignment, in accordance with Project procedures. The pipeline requires temporary (3-year)

acquisition of 6,340ha, while 263ha of land was acquired permanently for AGIs, across 578 land

parcels and 936 Project Affected Persons (PAPs).

Partial non-compliances were observed in relation to consultation, assessment and census,

compensation for displaced persons, the Project grievance mechanism, RAP/LRP documentation and

implementation, and monitoring.

BOTAS, the entity responsible for land acquisition, TANAP and CCs’ also undertake consultation with

stakeholders, requiring identification and consultation with approximately 97,000 landowners, land

shareholders and land users. Consultation and engagement has included: Information meetings prior

to negotiations/census data gathering; 2 rounds of negotiation meetings; crop determination

studies/meetings; preconstruction information meetings; and land entry meetings. Land exit meetings

will also be undertaken following reinstatement (approximately 3 years after land entry).

Consultation processes provide for engagement with vulnerable groups including women. TANAP has

committed to undertaking additional engagement and disclosure actions to strengthen the Project’s

responsiveness to stakeholders’ issues.

The cut-off date from the original RAP could not be met, as construction commenced in advance of

this date and identification of PAPs and assets inventory had not been completed, however BOTAS

has developed a practicable approach to evaluate and compensate every additional claim and justified

complaint that falls before or after the relevant cut-off date because the international standards on

applying a cut-off date could not be met.

As at August 2016, approximately 5,450 formal land users have been identified (i.e. users occupying

privately owned or treasury owned land, both documented and non-documented, to be compensated

through BOTAS) and 324 informal users (i.e. users occupying publicly owned land such as pastures or

forest lands, unauthorized or tolerated users, to be compensated through the RAP Fund, administered

by TANAP). BOTAS cannot acquire land from or compensate these categories that fall outside the

Turkish legal RAP requirements, hence the need to establish a mechanism from the Project that

provides for compensation to international standards, including transaction costs, transitional

payments, support to vulnerable households, and compensation for unviable land parcels. A RAP

Fund Management Procedure focusing on RAP Fund strategy and implementation principles has been

drafted and is currently being delivered to Project-affected settlements and PAPs, along with the new

GLAC (Guide to Land Acquisition). The RAP Fund Evaluation Committee has additionally been

established.

Permanent land acquisition is required for approximately 260ha for the AGIs, while approximately

6,600ha is required for a temporary period of 3 years (easement land for the construction corridor, or

unrestricted access for the ROW). This land is to be returned to owners after construction, with some

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xi

restrictions on agriculture / buildings in easement areas. TANAP is commissioning a retrospective

study (due for completion in July 2017) to identify and compensate PAPs who have not been yet been

compensated under the new Entitlements Matrix framework (ref: Summary of Corrective Actions).

Further, TANAP has committed to providing for full replacement cost for all assets and will ensure

that lost income is fully restored through the compensation process.

The procedure for demonstrating avoidance of expropriation appears to be a gap. While TANAP’s LA

process allows for negotiation with landowners, 67% of agreements are not amicable and trigger the

expropriation process, which does not meet with GIP and suggests the process of determining and

compensating landowners is rushed, in addition to absentee owners or other factors, resulting in

significant expropriation by international standards. While acknowledging that the pipeline component

of the project is linear, temporary and land acquisition has been completed, it should be clear to

TANAP that the expropriation process has not caused undue hardship to those losing access to their

resources. Through the Corrective Action Register, TANAP have committed to ensure that all eligible

PAPs are informed on entitlements in order to come forward for losses that have not yet been

compensated. TANAP will compensate all additional claims that are valid, consistent with the

conditions and criteria set in TANAP’s information brochures and GLAC document.

A grievance mechanism and Online Stakeholder Information Database, OSID, are in place for the

Project. As part of TANAP’s has commitment to strengthen this mechanism, an Appeals Committee

has been established (in January 2017), with notification at the community level from February 2017.

TANAP has also committed to strengthening disclosure of summary grievance information to

stakeholders.

TANAP has committed to development of a range of new RAP documents, documented in the

Summary of Corrective Actions in the Pipeline RAP. These include the Livelihood Restoration Plan

(LRP), RAP Fund guidance and documentation. The RAP Fund intends to fill the gap between

payments that can be provided for by BOTAS (as the national responsible agency) and international

requirements managed and implemented by TANAP. Some payments are reported to have already

been made from the RAP Fund, and for transparency these should be reconciled following approval of

guidance on implementation of the Fund. RAP Fund Management Procedure has been drafted and

disclosure with PAPs commenced. TANAP has contracted independent experts for RAP External

Monitoring and will produce their 1st Semi-Annual External Monitoring Report in June 2017.

The Pipeline RAP additionally identifies measures to strengthen ongoing implementation of the RAP.

This includes a study to investigate potential impacts to fisherfolk in the Sea of Marmara and

thereafter develop an appropriate Livelihood Restoration Plan. The study has been carried out, (i.e.

with adequate time to investigate, plan and respond, in advance of any impacts occurring). Similarly,

the AGI RAP provides for the development of an LRP to PAPs who have experienced a permanent loss

of livelihoods. Mitigation measures are yet to be developed and will differ from those who experience

temporary loss, which should be clearly managed and communicated to stakeholders.

The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators,

implementation schedule, and budget. These RAPs would be subject to IESC/independent monitoring

and review throughout implementation in accordance with GIP. A RAP Monitoring Plan has been

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xii

completed, and both internal and external monitoring has commenced so as to inform the impact

evaluation at the conclusion of the LA and livelihood restoration program.

PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL RESOURCES

The biodiversity assessments and studies have been completed in consideration of the IFC 2012

Performance Standards and with specific reference to Performance Standard 6 (PS): Biodiversity

Conservation and Sustainable Natural Resource Management of Living Natural Resources. TANAP has

developed a Biodiversity Action Plan (BAP) with specific reference to the IFC 2012 PS6 and the

Turkish National Biodiversity Strategy and Action Plan3.

The TANAP route selection described in the ESIA Chapter 5 describes the process for defining the

TANAP route and included consideration of a range of factors included the presence of protected

areas, sensitive habitats, scrublands, meadows, pastures and wetlands. A number of route

alternatives were identified to avoid key biodiversity conservation areas including the Posof Ardahan

Wildlife Development Area, Kakgol-Sahara National Park, Sarikamis Allahaukber Mountains National

Park, and the Akdagmadeni Forest (Important natural area).

Baseline studies were completed between 2013 and 2014 and include comprehensive desktop studies

supplemented with targeted site surveys focused on the areas where impacts to priority biodiversity

values are likely to occur.

The TANAP Biodiversity Action Plan (BAP) was developed with the specific objective to identify the

species and habitats in consideration of national and international significance and to consequently

determine the applicable area specific actions required to protect and conserve biodiversity within the

36m pipeline Right of Way (RoW). The BAP has identified the presence of critical habitats,

intersections of the ROW with protected or conservation areas and the presence of ecologically

sensitive species within the ROW.

The BAP includes a discussion of EUNIS habitat types encountered along the TANAP route including

30 different terrestrial habitat types classified as Level III and 6 level III freshwater habitats. Habitat

types classified as significant under the Turkish ‘National Biodiversity Strategy and Action Plan” were

also identified as priority habitats including steppe, coastal sand-dunes, and mountainous forest

ecosystems.

The re-assessment of critical habitat in the BAP identified 67 terrestrial and 27 freshwater critical

habitats. The terrestrial critical habitats cover only 0.39% of the 500m LSA corridor assessed in the

ESIA and 5.6% of the ROW (36m). This represents a significant decrease in terrestrial critical habitat

affected by the Project from that identified in the initial ESIA studies following the BAP re-assessment.

However, this reassessment of critical habitat area is based on the presence or absence of critical

habitat triggering species or values within the project’s direct impact area and removes critical habitat

areas where the triggering species or values were found to be undisturbed by direct impacts of the

ROW. The IESC finds that the TANAP critical habitat assessment is not in full compliance with the IFC

PS6 GN and is therefore in partial compliance with the requirements of PR6 to ensure net biodiversity

gain of critical habitat and no net loss of priority biodiversity features.

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xiii

The BAP states that the impact assessment undertaken in the ESIA confirms a low degree of impact

expected on natural and critical habitat, and states that significant permanent and long term impacts

are not expected and the defined mitigation measures are sufficient for the recovery of habitats. The

BAP also refers to the ESIA in confirming no long term or permanent significant impact to Species of

Conservation Concern. However, the BAP does recognise the threat of permanent impacts on SCCs

from alien invasive species, including the pathways for introduction of weed species, within the

pipeline ROW and reiterates the importance of the Alien Invasive Species Guidance Document.

Furthermore, the TANAP’s “Erosion, Reinstatement, and Landscaping Plan” and the “Specification for

Reinstatement” includes the range of actions for reinstatement and bio restoration of the project sites

to achieve pre-development biodiversity criteria. The performance of the bio restoration efforts in

achieving the stated biodiversity objectives is proposed to be monitored and reported through the

“Bio-Restoration Monitoring Plan (October, 2016).

Section 3.2.1 of the most recent version of the BAP does include discussion on the application of the

mitigation hierarchy for critical habitats. The BAP describes how mitigation measures are applied for

each critical habitat that occurs along the Project and identifies where additional conservation actions

are required to ensure no net loss of priority species. Annex 9 of the BAP includes a range of

measures designed to ensure a net gain in critical habitat that is impacted by the Project. However,

these net gain actions are not described in a way that demonstrate how a net gain would be

achieved. There is no quantification of the no net loss/ net gain objectives of the BAP to demonstrate

full compliance with PR6. Neither the ESIA nor the BAP provide sufficient detail of the project related

direct, indirect, and residual impacts on populations; species and ecosystems identified in the baseline

studies. There is insufficient assessment of the project impacts on critical habitat other than the direct

impacts within the ROW and the potential for introduced pest species (weeds). The impact

assessment on biodiversity values provides insufficient discussion on why aspects such as habitat

fragmentation, fauna avoidance and impacts from increased third party access are not considered.

The project has not demonstrated full compliance with PS6 GN15 in its assessment of impacts to

critical habitat and has provided insufficient evidence that bio restoration works on the ROW will be

adequate to achieve the biodiversity outcomes required to demonstrate compliance with PR6. The

IESC has found that TANAP has relied heavily on the assumptions that mitigation of temporary

disturbance through bio-restoration and alien species control will be effective in ensuring no residual

impacts to priority biodiversity values and critical habitat. There is little discussion in the ESIA that

supports the assumption that bio-remediation will ensure no permanent or long term impacts to

priority biodiversity values and critical habitat. The limitations of bio-reclamation are stated in various

sections of the ESIA that refer to challenges in achieving propagation or translocation of some

species, and the inability to replace tree species over the ROW to ensure the integrity of the pipeline

is maintained.

The effectiveness of the mitigation measures, including bio-restoration and alien species controls,

should be discussed in further detail and, where possible, refer to examples where these mitigation

measure have been effective in ensuring no loss of priority biodiversity values or critical habitat.

However, if relevant and geographic specific examples of successful bio-restoration are not available,

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xiv

then the assumption that there will be no residual impact to priority features and critical habitat

cannot be supported.

In consideration of the limitations found with the TANAP critical habitat assessment and management

approach, and recognising the current status of Project construction. The IESC recommends that

TANAP develop and implement an Offset Management Strategy document that supplements the BAP.

PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE

TANAP is in full compliance with the requirements of PR 8.

A total of 161 sites were identified in the ESIA process, and mitigation actions defined. Eleven sites

were identified as unavoidable at preconstruction phase. A Cultural Heritage Management Plan

(CHMP) is in place, including a Chance Find Procedure, which is reflected in each of the CCs’ MPs.

The CCs’ Archaeologist, who liaises with the TANAP Cultural Heritage Officer and the Museum

Directorate, monitors ground clearance work. Third party monitoring of implementation of the CHMP

is also undertaken by Çinar.

During the construction phase to date, five route changes have been implemented at the eleven

unavoidable sites, following engagement and mitigation actions implemented under the direction of

the with the relevant authorities (Museum Directorate of the Ministry of Culture and Tourism).

Ongoing and close engagement has been undertaken with the Museum Directorate of the Ministry of

Culture and Tourism, as the responsible agency for advice and direction on archaeological finds and

appears to have been effective in managing and mitigating potential impacts to tangible heritage in

line with the mitigation hierarchy approach. However, consultation with affected communities and

other stakeholders has been largely limited. Invitations to specialist interest groups at the ESIA

consultation phase has been recorded. IESC notes that consultation with affected communities is

carried out for intangible cultural heritage and registered tangible cultural heritage elements.

However, the chance finds are managed differently due to security reasons (the risk of illegal

excavations).

PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND STAKEHOLDER ENGAGEMENT

No material non-compliances were observed in reviewing the information disclosure and stakeholder

engagement criteria. Partial compliance was observed in relation to operational grievance

mechanism, and information disclosure.

Policies and standards are in place for the Project regarding stakeholder engagement,

communications and social impact management and requirements. The total number of consultation

meetings during the construction phase (as at November 2016) was 1,234, including meetings with

women, safety awareness for children, and with local authorities, across all Lots and stations.

Comments raised during project disclosure were reflected and analysed and incorporated into Project

SMPs, completing the feedback loop in line with GIP.

The Project SEP was published (18 August 2013) on the TANAP website in Turkish and English,

appropriate to the nature, scale and risks posed by the Project and reflecting engagement actions

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xv

specific to different stakeholder groups (e.g. vulnerable groups). This SEP has been recently updated

and finalized (30 January 2017) and includes additional guidance on stakeholder engagement

implementation for CCs during the construction phase, and provides for updated roles and

responsibilities.

ESIA documents were disclosed on the TANAP website, with key documents in English and Turkish.

The current SEP specifies periodic review of the document in line with PR 10 requirements for

ongoing provision of information to stakeholders appropriate to the nature of the Project and its

adverse impacts. PR 10 requires at least annual reporting to stakeholders for Category A projects;

commitment on this aspect is included in the SEP. The modality of disclosure of Project documents

was described by TANAP. For RAP documentation, the disclosure process was addressed adequately

through provision of written summary information in the local language, available to public disclosure

meetings, which subsequently informed the final RAPs prior to their disclosure. Additional

engagement planning and disclosure material is required of TANAP on the next phase of RAP activity

(i.e. in identifying and appropriately compensating new PAPs) and in the development and disclosure

of the BAP.

The grievance mechanism is operational and is aligned with the CCs. All grievances are logged in an

online grievance recording and tracking system. A total of 790 complaints have been received from

1/1/14 to 17/11/16 with 85% closed over an average of 15-day response time (30 days is the time

limit in the procedure for closure of complaints). The most common grievances since project

commencement relate to damage to property/land; land acquisition and compensation process;

damage to irrigation infrastructure; damage to roads; and outstanding subcontractor payments (as

per: Complaints issues – Top 20, 17.Nov. 2016). An Appeals Committee has been established to

provide third party review of unresolved grievances between TANAP and the Complainant.

Documentation on this committee has been developed and is to be provided to the IESC. Legal

redress is possible regardless of establishment of the Appeals Committee with complainants able to

take matters to court independently. This has not occurred in the Project to date; a third-party

valuation had been sought to resolve land valuation, and a policy of resolution by mutual agreement

is in place by the project.

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page xvi

REPORT ORGANISATION

Subsequent sections of this Environmental and Social Review to Support Financing report are

organised as follows:

• Section 1 – Introduction;

• Section 2 – Summary Project Description;

• Section 3 – Institutional and Legal Framework;

• Section 4 – Environment, Social, Health and Safety Review and Audit Overview;

• Section 5 – Compliance with EBRD PRs;

• Section 6 – Compliance with Turkish Legislation

• Section 7 – Compliance with Other Applicable Laws / Conventions / Treaties

• Section 8 – High-level assessment of export gas pipelines projects against Lender Group

requirements for associated facilities.

• ESDD Appendices

The basic findings of the review are presented in the form of observations, comments, and

recommendations according to each standard assessed against. Direct comparison between each

requirement and reviewed Project documentation is provided in a table format at the end of each

section where relevant comments and suggested action, if necessary, to achieve compliance are also

included. The findings presented in the summary table sections form the basis of the Environmental

and Social Action Plan contained in Appendix C of this report. Descriptions of the Project have been

provided only to a degree necessary to provide context for the observations and recommendations

provided in the text.

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017 Page 1

1. INTRODUCTION

This report contains the Environmental and Social Due Diligence (ESDD) for the TANAP Project in

Turkey. Sustainability Pty Ltd (Sustainability) was engaged by the European Bank for Reconstruction

and Development (EBRD) as the Independent Environmental and Social Consultant (IESC) to conduct

the ESDD.

The TANAP Project involves a 1,850km pipeline to facilitate the transport of natural gas produced

from the Shah Deniz Phase II development in Azerbaijan to Turkey and Europe (Figure 1.1). The

TANAP Project will connect the South Caucasus Pipeline Expansion Project (SCPx) in Georgia to the

Trans Adriatic Pipeline (TAP) Project, which commenced construction in March 2015 and extends

through Greece and Albania and across the Adriatic Sea to southern Italy.

The TANAP is being developed by a group of shareholders who currently comprise of Southern Gas

Corridor Closed Stock Joint Company (58%), BOTAS (30%) and BP (12%) and are herein referred to

collectively as the “Sponsors”. The TANAP Project, in conjunction with the South Caucasus Pipeline

(SCP) and the Trans-Adriatic Pipeline (TAP) form the elements of the Southern Gas Corridor.

TANAP will run from the Turkish border with Georgia, beginning in the Turkish village of Türkgözü in

the Posof district of Ardahan, will run through 20 provinces ending at the Greek border in the İpsala

district of Edirne (Figure 1.2). Two off-take stations are located within Turkey for national natural gas

transmission, one located in Eskişehir and the other in Thrace. With 19km running under the Sea of

Marmara, the main pipeline within Turkey reaches a total of 1,850km, along with off-take stations

and above-ground installations, with their numbers and properties detailed below:

• 7 compressor stations,

• 4 measuring stations,

• 11 pigging stations,

• 49 block valve stations and

• 2 off-take stations to supply Turkey’s national natural gas network.

In addition to the aboveground installations, temporary camps to accommodate workers, pipe storage

areas and access roads necessary during the construction phase will also be built.

TANAP is a Category A project, requiring comprehensive Environmental and Social Impact

Assessment (ESIA) in accordance with the EBRD Environmental and Social (ES) Policy. Based on the

above, the EBRD engaged Sustainability to review the existing ESIA documentation and conduct the

ESDD (to the extent possible based on available information) of the Project. The focus of the ESDD is

on the TANAP Project, however a cursory review (to identify main risks or gaps and discussion about

the significance of any identified gaps) of associated facilities, including the SCPx, TAP, and SD2

documentation is also within the scope of this ESDD.

1.1 SCOPE OF WORK

The role of the IESC comprised four major elements. These included:


• Summarizing the relevant characteristics of the Project including its associated facilities and

area of influence related to environmental and social aspects based upon a review of existing

information and appropriate site reconnaissance. Relevant characteristics include: the Project

description; institutional and legal framework; environmental and social conditions;

environmental and social impacts (direct, indirect and induced) and risks; analysis of

reasonable alternatives; environmental and social mitigation, compensation, and remedial

measures; monitoring system in place including indicators; and consultation and engagement

of affected population;

• Evaluating the adequacy of, and likely costs associated with, the proposed Project

environmental, social, and health and safety assessments, management and action plans and

procedures and present conclusions and recommendations associated with identified issues;

• Confirming to EBRD the compliance of the proposed development plan for the Project with

the applicable environmental, health, safety and social requirements, including statutory

requirements and project requirements under the Applicable Standards, and;

• Coordinating and assist the EBRD in the due diligence process in respect of environmental

and social matters in connection with the financing of the Project, answering questions and

attending meetings and conference calls as required.

Sustainability, as the IESC, provided independent review, assessment and comment on the TANAP

Project’s compliance with EBRD standards for the purposes of Project financing. This included

advising the EBRD on the adequacy of the Project’s assessments, management and mitigation

controls and monitoring measures against EBRD standards.

On account of TANAP forming a sub-component of a larger gas chain, which encompasses the TAP,

SCPx and the Shah Deniz Phase II Development, Sustainability also undertook a high level

environmental due diligence review of these associated facilities, based on publicly-available ESIAs

and management plans. Sustainability also drew upon its current experience as the IESC for Lenders

on the Shah Deniz II Development and the previous high-level assessments completed for the TAP

and SCPx Projects.

Key tasks undertaken in the documentation of this ESDD Report included:

1.1.1 Reviews and Assessments

Review of key HSES documentation, which included, but was not limited to:

• The ESIAs produced for the Project including the information prepared for the trans-boundary

notification and consultation;

• The Environmental and Social Management Plans (ESMPs) and relevant additional specific

plans including the Stakeholder Engagement Plan (SEP);

• Environmental and Social Management System (ESMS);

• Other relevant HSES materials including baseline studies, surveys, and additional

assessments, and;


• Relevant Land Acquisition and Compensation (LAC) and Resettlement Action Plan (RAP)

documentation and Grievance Mechanism.

1.1.2 Site Reconnaissance

The IESC conducted a single site visit from the 23 – 27th November 2016, with EBRD team members

also attending. Tasks associated with the site visit included:

• Inspection of Project site locations that are agreed with the Sponsors and Lenders including

pipeline construction, compression and metering stations;

• Inspection of the associated facilities (as defined under EBRD’s Performance Requirement 1)

as appropriate, and;

• Interviews with Project HSES and other personnel and key stakeholders as relevant to the

scope of work.

The Site Visit Report is included as Appendix D.

1.1.3 Reporting

The primary objective of the Reporting task is to produce an Environmental and Social Due Diligence

(ESDD) Report (this Report).

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental and Social Due Diligence June 2017

Page 4

Figure 1.1 TANAP Pipeline Overview


Page 5

Figure 1.2 TANAP Pipeline Route Within Turkey


1.2 LENDER POLICIES

1.2.1 EBRD Performance Requirements

EBRD-financed projects are expected to be designed and operated in compliance with good

international practices relating to sustainable development. To assist clients and their projects achieve

this, the EBRD has defined ten performance requirements covering the key areas of environmental

and social issues and impacts. In order to obtain financial support from the EBRD clients should meet

a set of 10 PRs, as follows:

• PR 1: Environmental and Social Appraisal and Management;

• PR 2: Labour and Working Conditions;

• PR 3: Pollution Prevention and Abatement;

• PR 4: Community Health, Safety and Security;

• PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement;

• PR 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;

• PR 7: Indigenous Peoples;

• PR 8: Cultural Heritage;

• PR 9: Financial Intermediaries; and

• PR 10: Information Disclosure and Stakeholder Engagement.

The PRs should be read in conjunction with the EBRD’s ES Policy. The EBRD is bound by its founding

agreement to adhere to sound banking principles and “promote in the full range of its activities

environmentally sound and sustainable development.” The ways in which the EBRD promotes such

development are described in the EBRD’s Environmental Policy document. One specific step taken by

the EBRD to address this mandate and the General Principles and Objectives set out in the Policy is to

ensure that all its investment and technical cooperation projects undergo environmental and

socioeconomic appraisal along with the financial, economic, legal and technical due diligence, and to

ensure that appropriate monitoring is undertaken following approval of projects by the Board of

Directors.

1.3 SOURCES OF INFORMATION

The review and audit was based on 1) publicly available ESIA documentation, and 2) Information

provided by TANAP, which is not available in the public domain. The main sources of information

used to prepare this Report included, among others: the ESIA and appendices; ESMPs and

supplementary slide packs prepared by TANAP and a range of implementation evidence requested by

the IESC as a result of the site visit. A full list of all documents used to prepare this Report is

provided in Appendix A.


2. SUMMARY OF PROJECT CHARACTERTISTICS

The TANAP Project is part of the Southern Gas Corridor, which aims to transport natural gas from

Shah Deniz 2 Gas Field and other fields in the South Caspian Sea to Turkey and Europe in Azerbaijan.

The Southern Gas Corridor comprises the South Caucasus Pipeline (SCP), TANAP and the

TransAdriatic Pipeline (TAP). The TANAP corridor starts from the Georgia/Turkey border at

Türkgözü/Posof/Ardahan where it connects to SCP and ends at the Turkey/Greece border in

İpsala/Edirne, where it feeds into the TAP Pipeline. There is an off-take station at Eskişehir, Turkey,

and another one at Thrace, Turkey to connect to the Turkish natural gas distribution network.

The TANAP Project is a 56-inch and 48-inch pipeline system of 1,850km, and will transport natural

gas to the required specifications and quantity in stages starting with 16 bcma as initial phase leading

up to a high flow case of 31 bcma which is the last phase. 6 bcma will be delivered to BOTAŞ (Boru

Hatları ile Petrol Taşıma A.Ş.) to be used within the Republic of Turkey via off-take stations by Gas

Transport Agreement (GTA). The construction of the Project is expected to last for 4 years, and a

phased approach will be pursued where the target for completion of the construction and starting

operation is by the middle of 2018. The initial capacity of 16 bcma (First Stage) is expected to expand

to 24 bcma by 2023 (Second Stage) and to 31 bcma by 2026 (Third Stage), upon construction of the

required additional compressor stations. TANAP is planned to begin from the Georgia/Turkey border

and go through the provincial borders of Ardahan, Kars, Erzurum, Erzincan, Bayburt, Gümüşhane,

Giresun, Sivas, Yozgat, Kırşehir, Kırıkkale, Ankara, Eskişehir, Bilecik, Kütahya, Bursa, Balıkesir,

Çanakkale, Tekirdağ and Edirne. At the beginning of the Environmental and Social Impact Assessment

(ESIA) process the pipeline was planned to be divided into two branches after crossing Marmara Sea

and the second branch would pass Tekirdağ and enter Bulgaria through Kırklareli. However, due to

the change in the marketing strategy of Azerbaijan, natural gas to Europe by the Bulgarian section

was cancelled. The TANAP system will be fully automated with main and back-up control centres to

meet the requirements of gas transmissions and associated environmental and safety considerations.

The main pipeline facilities include the required number of compression facilities, block valve stations,

distribution and custody transfer metering facilities. The pipeline crosses terrain with challenging

geotechnical features, including landslides and other geo-hazards, in addition to crossing regions with

different levels of urbanization and economic activity. TANAP includes:

• Onshore pipeline:

o A main natural gas pipeline from the Turkey/Georgia border to the Turkey/Greece

border.

o Diameter: 56 inches to the Eskişehir Compressor Station and 48 inches from

Eskişehir.

o Compressor Station to the Turkey/Greece border.

o Total pipe length: 1850 km.

o Onshore length: 1832 km.

o Nominal capacity: 31 bcma in high-flow case.

o Design Pressure: 95.5 barg.


o Main design according to ASME B31.8, 2012.

• Offshore pipeline section:

o Looping at Marmara Sea crossing.

o Diameter: 2 x 36 inches.

o Length: 18 km, approximately.

• Compressor Stations:

o 7 compressor stations at intermediate points for fulfilling pressure requirements. A

separate compressor train is foreseen for the gas supply to BOTAS in CST-5A

(identified as CST-5AL).

• Metering Stations:

o 1 custody receiving border metering station at the entry point.

o 1 delivery border metering station at the exit point.

o 2 fiscal metering stations at Eskişehir and Thrace Offtakes.

• Pig Launcher and Receiver facilities:

o at each compressor station (including phase compressors).

o at each metering station.

o at both sides of the shore approaches of the Dardanelles Strait Crossing.

• Block Valve Stations:

o 49 in accordance with ASME B31.8, 2012 requirements.

• Off-take Points:

o 2 in Turkey, with metering stations.

• Supervisory Control and Data Acquisition (SCADA) automation, control and

Telecommunication equipment:

o Main Control Centre in Ankara, Turkey.

o Back-up Control Centre located with Compressor Station CST-5A in Eskişehir, Turkey.

2.1.1 Current Progress

The Project is substantially commenced, with construction works having commenced on all 4 Lots.

Construction contracts for the offshore pipeline have been awarded but have not yet commenced. A

summary of construction progress at the time of the field visit, in November 2016, across all Lots is

outlined below. It is acknowledged that these figures are impacted by the inclusion of Lot 4 progress,

as works at Lot 4 had only recently commenced at that time. The completion figures for Lots 1 -3 are

significantly higher:

• 65% of pipeline welds completed;


• 45% of pipeline lowered into construction trench;

• 38% of backfilling completed.

Relevant dates for the remainder of the construction period include:

• Final pipeline manufacture and delivery – Completed March 2017;

• Commencement of offshore construction – July 2017;

• Mechanical Completion of Phase 0 pipeline – December2017;

• Supply of gas to Eskişehir (offtake station) Phase 0 complete – June 2018;

• Material Completion of Phase 1 pipeline works – December 2018;

• Gas supply to Europe – June 2019.


3. INSTITUTIONAL AND LEGAL FRAMEWORK

The key legal regime for the construction and operation of the TANAP Project is set out in the

applicable Host Government Agreements between Turkey and Azerbaijan (see Section 6). The Host

Government Agreement requires Project Environmental and Social Standards complying with National

Laws and also taking due account of international standards and practices generally prevailing in the

Natural Gas pipeline industry, including relevant Performance Standards of the International Finance

Corporation.

Turkey is signatory to numerous international and regional conventions that oblige the government to

prevent pollution and protect specified habitats, flora and fauna. Those of relevance to the TANAP

Project include:

Convention on the International Transportation of Hazardous Wastes, Basel, ratified by Turkey on 1994

Convention on the Persistent Organic Pollutants, Stockholm, ratified by Turkey on 2010

United Nations Climate Change Framework Convention, Bonn, ratified by Turkey on 2004

Convention on Protection of Ozone Layer, Vienna, ratified by Turkey on 1991

Convention on Long-Range Transboundary Air Pollution, ratified by Turkey on 1983

Convention on Biological Diversity. Turkey ratified this convention in 1992

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (Turkey is a member country).

International Convention for the Prevention of Pollution from Ships (MARPOL), ratified by Turkey on 1990

Convention on Migratory Species of Wild Animals (CMS) (Turkey is a not yet member country).

Ramsar Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar) (Turkey is a contracting body)

Convention concerning the Protection of World Cultural and Natural Heritage (WHC) (Turkey ratified this convention)

Convention for the Conservation of European Wildlife and Natural Habitats (BERN) (1984) (ratified by Turkey)

Convention on Wetlands of International Importance, Especially as Waterfowl Habitat (RAMSAR) (1994) (ratified by Turkey)

European Landscape Convention (2001) (ratified by Turkey)

Convention to Combat Desertification (CCD) (1998) (ratified by Turkey)

Convention on substances depleting Ozone Layer, Montreal, ratified by Turkey on 1991

Kyoto Protocol, ratified by Turkey on 2009

Convention on the Transboundary Effects of Industrial Accidents, 2000

While not currently a member of the EU, much of Turkeys legislation has been drafted based on EU

legal provisions as a pre-cursor to membership talks that are currently ongoing. The key legislation

governing environment requirements in Turkey is the Environment Law (1983). The purpose of this

legislation is to protect the environment based on the principles of sustainable environment and

sustainable development.

Adopting the principle “Polluter Pays”, the Law encompasses principles about punishment and closure

of the facilities polluting the environment and the liabilities for informing the related authorities about

any changes to be made on the production process of the facilities. It sets the framework for other

environmental (and social) legislation within Turkey, including (as relevant to the Project):

• Law on Protection of Soil and Land Use (2005);

• Law on Pasture Land (1998);

• Conservation of Cultural and Natural Assets Law (1983);


• Forestry Law (1956);

• Groundwater Law (1960);

• Health and Safety Law (2012);

• Labour Law (2003);

• Shore Law (1990);

• Law on Protection of Animals (2004);

• Law on the Transit Transport of Petroleum with Pipelines (2000);

• Regulation on Control of Water Pollution (2004);

• Regulation on Control of Hazardous Wastes (2005);

• Regulation on EIA (2008);

• Regulation on Management of Surface Water Quality (2012); and

• Regulation on Permits and Licenses to be Secured According to the Environment Law (2009);


4. ENVIRONMENT, SOCIAL, HEALTH & SAFETY REVIEW AND AUDIT

The Compliance Summary Table at the end of each PR in Section 5 provides a systematic review of

project compliance with the EBRD Environmental and Social Policy, as defined through the applicable

Performance Requirements (PRs). The review is intended to provide a baseline against which to

judge future performance of projects through the annual environmental and social reporting process.

Between 2 and 10 indicators are identified for each of the applicable PRs: 1, 2, 3, 4, 5, 6, 7, 8 and 10.

Within each sub-section, an introductory paragraph is included to provide the most relevant

observations and to facilitate the understanding of the compliance table that follows. Therefore, the

narrative paragraphs preceding the compliance tables for each Performance Requirement are aimed

to provide the “rationale” for the identified gaps, and explanation of the IESC prescriptions.

Justification for any derogation from a PR is summarised and supporting documents referenced. For

each indicator within a PR, the following three steps are completed:

• Decide whether the indicator is applicable. For Category A and B projects the starting point is

that all indicators are applicable unless the project has no significant aspects relevant to the

indicator (i.e. no risks), in which case the indicator should be scored "NA" and a brief

summary of the reason given.

• Decide whether an opinion is possible. If not (for example if the indicator will apply, but it is

too early in the project) score as "NOP" and a brief summary of why is provided. Where lack

of opinion represents a material omission to the review, reference to where this is addressed

in the report is made and recommendations are summarised.

• Indicators are scored as follows and a brief justification provided.

EC Exceeding Compliance: The project has gone beyond the expectations of EBRD’s PR requirements. EBRD should be able to use projects rated EC as a role model for positive Environmental and Social effects.

FC Fully Compliant: The project is fully in compliance with EBRD’s requirements, and EU and local environmental, health and safety policies and guidelines.

PC Partial Compliance: The project is not in full compliance with EBRD’s requirements, but has systems, processes or mitigation measure in place which are working towards addressing the deficiencies.

MNC Material Non-compliance: The project is not in material compliance with EBRD’s requirements, and the systems, processes and mitigation measures in place are not working towards addressing the deficiencies.

NOP No Opinion Possible: Based on the data provided to date, the IESC team has not been able to form a definitive position on the

subject being discussed.

• Comments/Issues: Provide a brief commentary on the relevance of this requirement for the

project and an explanation of the chosen score.

• Actions Required: Where applicable, briefly describe any actions required by the client to

achieve full compliance with each requirement.

Trans Anatolian Natural Gas Pipeline Project Rev 5 Environmental Due Diligence June 2017 Page 13

5. COMPLIANCE AGAINST EBRD PERFORMANCE REQUIREMENTS

5.1 PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES

The EBRD outlines their requirements for assessment and management of environmental issues in

PR1. PR1 establishes the importance of integrated assessment to identify the environmental and

social impacts and issues associated with projects and the client’s management of environmental and

social performance throughout the life of the Project.

In addition to the ESIA documentation, a range of additional documentation has been requested and

provided and has been considered in this ESDD. This was undertaken to have a clear understanding

of the ESMS supporting the ESIA documents and, as mentioned above, this report is based only on

that information which has been received from TANAP or that which is in the public domain.

5.1.1 Environmental and Social Assessment

ESIA

The overarching agreement guiding development of the TANAP project with the Government of

Turkey is the Host Government Agreement (HGA, 26.06.2012). The HGA specifies the requirement

for the TANAP Project to identify E&S Standards, in line with Turkish national requirements and with

due account of prevailing international industry practices and the IFC Performance Standards (Article

17.1). The HGA further requires that TANAP prepare an ESIA in accordance with E&S Standards, for

approval by the Turkish Government, and that the ESIA include an environmental and social

investment program (Article 17.2).

The environmental and social impacts of the Project have been assessed through a systematic

process applied for all Project components as identified through the ESIA scoping process. The

primary assessment document is the TANAP ESIA which was publicly disclosed on the TANAP website

on the 22nd June 2015. The ESIA was approved by the Turkish Ministry of Environment and

Urbanisation (MoEU) in June 2014.

The ESIA involved a comprehensive assessment of the Project commensurate with and proportional

to the environmental impacts the Project presents. Prior to the detailed ESIA, a Project scoping

phase was undertaken of which the primary focus was to identify the preferred route of the pipeline

to minimise environmental and social impacts while maintaining a technically feasible installation

process. This process is outlined in detail in Chapter 5 of the ESIA and summarised in Figure 5.1

below. A predetermined set of criteria was used to determine the preferred route and these criteria

included environmental and social considerations. Preliminary assessment of the route was initially a

desktop exercise which determined a Preferred Route Corridor (PRC) of 2 kilometres in width. Once

the corridor was determined, a preferred centreline was chosen using a combination of desktop and

field data to reduce the PRC to a width of 500 metres. Within this 500-metre corridor the centreline

for the corridor was delineated and the Right of Way (RoW) disturbance area of 36 metres was

located. The ESIA was conducted on the full 500-metre pipeline corridor.


Parameters considered during the determination of the 500-metre corridor included the following:

• General Topographical Properties;

• Soil Properties;

• Land Usage Status;

• General Geological-Geomorphologic Properties;

• Stratigraphy;

• Engineering Properties of the Rock Units;

• Surface Fault Hazards and Seismicity;

• Areas with Potential Geological Risks (Erosion, Landslide, Elevated Ground Water Layers and

Aquifers, Karstic Zones);

• Hydrological Properties;

• Ecological Properties (Protected Areas (National Parks, etc.), Sensitive Habitats, Forests,

Scrublands, Meadows-Pastures and Wetlands);

• Archaeological Sites;

• Tangible and Intangible Cultural Heritage;

• Socio-Economic Properties (Demographics, Economic Properties); and

• Existing and/or planned state authority infrastructure(s).

Potential social impacts were assessed on the effects of the following parameters:

• Effects on traffic and mobility;

• Effects on infrastructures and utility services;

• Opportunities for local economy;

• Changes to local employment conditions;

• Effects on livelihood from farming activities;

• Effects on livelihood from livestock activities;

• Effects on local healthcare services and facilities;

• Effects on human health and safety;

• Effects on local education services and facilities;

• Increase of tensions and conflicts;

• Disturbance and nuisance to daily activities;

• Influence on local population;

• Effects on intangible cultural heritage; and


• Effects on cultural sites and archaeology.

This planning process led to a series of documented route revisions prior to the ESIA PRC and RoW

centreline being approved at Revision H. Within this process, at total of 156 different route changes

were documented. Clear evidence of avoidance of key environmental features such as national parks

and designated wildlife areas, forested areas and identified biodiversity features was observed during

the review of Project documentation.

Further route changes post Revision H have been necessary as field construction activities have

discovered previously unidentified limitations to the proposed RoW. These route changes are

managed through the TANAP Environmental Management of Change (MoC) procedure. Completed

MoC examples that incorporated a range of environmental and social checks were reviewed by the

IESC team during the site inspection.

The IESC team could see clear evidence that environmental and social aspects and impacts were

considered in detail during Project scoping and planning stages and that the mitigation hierarchy and

Good International Practice (GIP) was implemented in the route selection process.


Figure 5.1 Pipeline Route Assessment Process


Stakeholder engagement and consultation was undertaken during the scoping phase and results of

the consultation process incorporated into the final ESIA process. Public Participation Meetings (PPM),

Social Baseline data collection and disclosure activities were carried out along the entire pipeline route

as preliminary engagement, in accordance with the activities described in Figure 5 2 below and in line

with GIP and in line with the nature and scale of the Project.

Figure 5.2 ESIA Consultation approach

At the local level, social baseline data collection and engagement was carried out with a range of

stakeholders including local governors, local NGOs, media and communities, using primary research

methods and public disclosure meetings. Regionally, NGO & Interest Group Meetings were held in

Ankara & İstanbul, while International NGO & Interest Group meetings were held in Ankara.

A web-based online stakeholder interaction database (OSID) using software called Darzin has been

established to track, record and manage all stakeholder engagement activities including grievance

management, which has been active through pre-construction and construction and will continue into

the operations phase.

ESIA Methodology

A clear impact assessment methodology was undertaken in the conduct of the ESIA, outlined in

Chapter 2 of the ESIA Report. The ESIA was managed by international consultants Golder Associates

Ltd (Golder) to ensure compliance with both Turkish and international requirements. Local

consultants Çinar conducted the baseline studies under guidance from Golder. The impact

assessment methodology is stated to follow guidance of the European Environmental Agency (EEA)

and utilises a Drivers-Pressures-State-Impact-Response (DPSIR) framework. The ESIA was

conducted in compliance with the Turkish Regulation on Environmental Impact Assessment (2008)

and in consideration of EU Directive 2011/92/EU.


The scoping process allowed for the identification of Valued Environmental and Social Components

(VECs) that were defined as the distinct components of the physical, biological and social

environment in the Project Area of Influence (AOI) that are subject to National or International

policies, conventions, agreements, legislative or administrative acts aimed at their protection /

enhancement.

Some gaps were observed in the review of the ESIA related to the assessment of offshore

construction impacts. The review found that the ESIA did not adequately assess the impacts related

to the potential for vessel to vessel interactions and vessel interactions with marine fauna. Vessel to

vessel interactions are considered a high risk given the stated level of high shipping traffic and vessel

use in the offshore project area. Subsequent evidence provided is sufficient to demonstrate

compliance to the IESC. Specifically, as there was limited information available regarding offshore

construction methodology during the ESIA development, a comprehensive HAZID was conducted post

ESIA development, which assesses construction related risks, including vessel to vessel interactions.

Prior to commencement of offshore construction activities, the existing HAZID will be updated and a

set of Task Risk Assessments will be developed by the Contractor to identify and mitigate potential

Project-related risks for offshore activities. The primary objective of the Task Risk Assessments is to

ensure that any Project risks are appropriately mitigated and reduced to as low as reasonably

practicable. The Contractor is currently developing Emergency Management Plans for TANAP

approval. It was also reported to the IESC that all works will be completed under close

communication with local Marine Authorities and that communications have already commenced in

this regard.

Cumulative and Transboundary Assessment

The ESIA assesses the potential for cumulative and transboundary impacts in Chapter 10 of the

document. This assessment considers the interaction between existing and planned Projects within

Turkey and the cumulative impacts of these on the physical, biological and social aspects of the

Project. Minor transboundary impacts are possible on some of the major waterways crossed by the

Pipeline route that flow into neighbouring countries. The IESC team considers the assessment of

these potential impacts has been appropriately undertaken and of a suitable scale to the Project

characteristics.

5.1.2 Environmental and Social Management System

TANAP has developed and implemented a detailed Environmental and Social Management System

(ESMS) with which to manage the Project’s environmental and social aspects. TANAP has

documented the ESMS in line with ISO 14001 requirements. The ESMS was observed to be

appropriate to the size and scale of the Project, documenting E&S policy, management plans,

procedures and guidance. The TANAP ESMS was communicated to the Project subcontractors to

ensure that their respective ESMS’ reflected the requirements of the TANAP ESMS. These

requirements were communicated through TANAP’s Environmental and Social Management Plan

(ESMP) (TNP-PLN-ENV-GEN-001) and through Environmental and Social Requirements for Contractors

(ILF-SPC-ENV-GEN001). Samples of Construction Contractors (CCs) ESMS documentation was

reviewed during the site visit where it was confirmed that it meets the requirements of TANAPs

environmental and social objectives outlined in these documents.


In line with the ESMS, weekly environmental coordination meetings are conducted and weekly reports

are issued; coordination meetings between TANAP E&S and construction team members are also held

regularly, and monthly construction meetings are held at construction sites. There are different types

of reporting (daily, weekly, monthly, quarterly) depending on the elements of the ESMS being

implemented. TANAP conducts regular audits and inspections of CCs in line with their ESMS

requirements. A range of documentation relating to implementation of the ESMS was reviewed as

part of the ESDD and the IESC team considers that the ESMS is working in a streamlined and

coordinated manner.

At the commencement of the Project, TANAP employed a three-tiered contractor structure to

implement the Project, with an Engineering, Procurement, Construction and Management (EPCM)

contractor managing the selected CCs in the field. TANAP formally made an organisational change

from 15 September 2016 to an integrated two-tier organisation (with TANAP and CCs), removing the

EPCM contractor from the organisational structure. The IESC noted during the audit that the ESMS is

out of date with respect to roles and responsibilities and subsequent system documentation. In many

instances, the same individuals are working in the same roles (i.e. former EPCM staff are now directly

employed by TANAP) so while day to day activities appear to remain well-managed and understood

by staff, ESMS documentation reviewed during the audit does not reflect the current organisational

structure and so may not effectively manage potential risks (e.g. arising from incidents, staff

changes). As a work in progress, the IESC team considers this issue to be compliant with this PR,

given that the issue is known, changes substantially commenced, and is considered to be part of

normal ESMS review and improvement during the life of the Project. Subsequent evidence1 provided

to the IESC by TANAP indicates that the revision of TANAP documents is complete, and that CC

reviews are ongoing and will be provided to the IESC as they are approved.

The ESMS structure (and ESMPs) for the offshore pipeline construction has been developed in draft

form, and is currently being finalised. Disclosure thereof is planned to occur upon finalisation. The

IESC reviewed the draft documents at meetings held in Ankara on 12 May 2017 and the

documentation appears suitable to meet the requirements of the EBRD PRs.

5.1.3 Environmental and Social Policy

TANAP and their CCs have documented Health & Safety, Environmental and Social Policies that have

been approved and signed off by the Board of Directors.

5.1.4 Environmental and Social Management Plans

Within the ESMS a series of ESMPs have been documented to manage the Project’s environmental

and social aspects during design, construction and operation. The following ESMPs were created to

manage the impacts identified during the ESIA process:

• Construction Impacts Management Plan;

• Community Safety Management Plan;

• Community Relations Plan;

1 Including updated management plans, and TANAP presentations in Ankara meetings on 12/05/2017


• Employment and Training Plan;

• Procurement and Supply Management Plan;

• Aggregates Management Plan;

• Traffic Management Plan;

• Cultural Heritage Management Plan;

• Erosion, Reinstatement and Landscaping Plan;

• Pollution Prevention Plan;

• Waste Management Plan; and

• Emergency Response Plan.

The framework for this suite of management plans is described in the TANAP Environmental and

Social Management Plan (TNP-PLN-ENV-GEN-001). In conjunction with these above management

plans, management and mitigation measures are also further described in the:

• Environmental Action Plan (TNP-PLN-ENV-GEN-002);

• Social Action Plan (TNP-PLN-SOC-GEN-002);

• Environmental Monitoring Plan (TNP-PLN-ENV-GEN-003);

• Social Monitoring Plan (TNP-PLN-SOC-GEN-001); and

• Biodiversity Action Plan.

The ESIA provided the basis for a number of Social SMPs, including:

• Community Relations Management Plan, addressing: Consultation Meetings, Construction

impacts activities and grievance management;

• Local Employment & Workers Management Plan: local recruitment process, worker

disciplinary actions, and employee grievances;

• Local Procurement Management Plan: supplier of local goods and services, and control of

payments to local companies & workers;

• Community Safety Management Plan: Construction impacts of the local affected communities;

mitigation measures of high risk areas; and training and awareness meetings with

communities; and

• Traffic Management Plan: E&S evaluation of traffic impacts with associated mitigation

measures.

Further, with a material change in the approach by the Project to management of resettlement and

land acquisition, additional RAPs were developed and publicly disclosed:

• RAP for AGIs: approach to management of resettlement (including permanent land

acquisition) for the above ground installations (TNP-PLN-SOC-GEN-008-P3-0); and


• RAP for the Pipeline: approach to management of resettlement (and temporary land

acquisition) along the pipeline corridor (TNP-PLN-SOC-GEN-006-P3-0).

A range of other documentation in the form of procedures, work method statements and forms and

templates also form part of the ESMPs, which have been developed in line with ISO 14001 and the

Plan-Do-Check-Act approach.

These requirements have been communicated and enforced amongst the CCs. TANAP requires all

CCs to develop their own versions of these ESMPs, which are subsequently reviewed by TANAP for

suitability and approved for use.

As discussed in Section 5.1.2, the offshore construction ESMPs have now been developed in draft and

were able to be reviewed during meetings held with TANAP on 12 May 2017. The IESC believes the

documentation reviewed is suitable for purpose and meets the EBRD PRs.

Effective contractor management is provided for in the ESMPs, including a process for the

management of non-compliance of CCs, sighted by the IESC. However, the implementation of

contractor management mechanisms appears to differ between CCs. Regular internal and third party

monitoring is provided for through the ESMS, and records that this activity is carried out were sighted

by the IESC. However, the differing levels of capacity between CCs suggest that additional support

and performance management is required by TANAP to ensure implementation is carried out as

documented. This may be in the form of additional TANAP support staff available to those CCs who

are not as experienced or are demonstrating underperformance on site, while also providing

increased performance management focused on those specific Lots (See also PRs 2 and 4.). Non-

conformance reporting / quality management procedures have been developed, which include

performance monitoring and improvement requirements for contractors. Contractors are required to

specify KPIs and their monitoring frequency, along with specified internal and external quality audits.

Following performance reviews, any corrective action plans are developed and implemented for

regular reporting to TANAP, and escalation as appropriate based on the criticality of any non-

conformances (e.g. stop work for immediate risks, or periodic reporting to TANAP as required). As at

26.2.17, TANAP reports of 543 non-conformances raised during the Project to date to vendors and

contractors, that 90% are closed and 6% overdue. The NCRs have been raised on environmental

issues 91 times, health and safety 127 times, social and community liaison 12 times and security 16

times. In the year to date, 52 NCRs have been raised with 35% overdue.

The IESC team considers that the level of detail and breadth of coverage within the ESMPs is suitable

to manage the environmental and social impacts presented by the Project’s activities.

5.1.5 Organisational Capacity and Commitment

TANAP has a defined organisation structure, which is suitable to implement a Project of this size and

magnitude. Sufficient environmental and social personnel have been employed to implement the

ESMS and manage environmental and social issues that are present on the Project.

TANAP’s E&S team organisation is comprised of an HSSE manager, under which reports individual

Environmental and Social Impact Managers, environmental and social impact specialists (responsible

by Lots, Stations and Offshore), environmental and social impact specialist assistants and a RAP


specialist. Site-based organisation is comprised of Lot Site Managers, to whom report environmental

and social impact specialist leads by Lot, thereunder environmental and social impact specialists by

spread. It is noted that former EPCM staff are broadly now engaged directly by TANAP.

Training of staff includes core competencies required by workers, covered in induction training and on

the Code of Conduct to ensure appropriate worker conduct is well understood and implemented,

sighted by the audit team [refer to document list Appendix A].

Modification to the organisational roles and responsibility as part of the changes to the ESMS, as

discussed in Section 5.1.2, is complete for TANAP documentation and nearly complete for CCs.

5.1.6 Supply Chain Management

Suppliers of major goods and services to the Project were chosen through a tender process, which

included HSES pre-qualification requirements and a request for certificates of ISO 18001 and ISO

14001 certification, or a description of how HSEC aspects are managed if certification has not been

achieved. This includes the sample of the contract for 56” selected pipeline suppliers for Lots 1, 2 and

3, which clearly specifies management systems requirements and project standards. The contract

defines the requirements of contractors to develop, staff, implement and improve their own ESMS in

alignment with TANAP’s ESMS and policies; national and international statutory and regulatory

requirements; ISO 14001 Standards; and all requirements, mitigations and commitments stipulated in

the Project ESIA and ESMPs.

As one of the major goods or services purchased by the Project, the lengths of pipe for the

construction of the pipeline present a significant potential supply chain management risk, with

suppliers located within Turkey and internationally in China. Evidence from TANAP describes the

desktop environmental assessment of Pipe producers that was undertaken during the pre-qualification

process including an OHS inspection by the EPCM. While aspects of E&S issues were included in this

inspection, a separate E&S inspection was not conducted. Documentation demonstrates TANAP’s

efforts in broadly ensuring E&S requirements can be managed appropriately in its supply chain

through the suppliers’ requirements for implementing an ESMS commensurate to the complexity,

nature and scale of the Project. However, an E&S inspection or strengthening of prequalification

questionnaires on social issues could reasonably have been undertaken (by TANAP or by the EPCM)

to ensure that management at suppliers’ sites was sufficient. This would have included an assessment

of aspects relating to the prevention of child / forced labour in line with the requirements of PR2.

Assessment of this aspect is not considered sufficient and is described further in the section on PR2

below.

The EBRD PRs recommend that clients ascertain whether licenced disposal sites are being operated to

acceptable standards. Evidence has been supplied to validate that TANAP has conducted site

verification audits of licenced waste disposal facilities along the pipeline route to ensure that Project

generated waste is being disposed of appropriately by the contractor.

5.1.7 Project Monitoring and Reporting

TANAP has documented and is implementing the following monitoring activities as part of their ESMS:

• Environmental Action Plan;


• Environmental Monitoring Plan;

• Social Action Plan;

• Social Monitoring Plan;

• Commitments Register;

• Resettlement Action Plan; and

• Biodiversity Action Plan.

The Environmental Monitoring Plan (TNP-PLN-ENV-GEN-003-P3-2) has been prepared by TANAP and

is currently being implemented on the Project. This Plan defines the Environmental Monitoring

requirements for the Project, which is established based on the FEED phase Environmental and Social

Monitoring Procedure and defined in the ESIA. It ensures the appropriate management of

environmental impacts in all phases of construction, operation and de-commissioning of the Project.

Environmental & Social monitoring plans are applied to the detailed planning, reporting and follow up

of environmental and social performance measurement and monitoring throughout the Project.

TANAP establishes measurable environmental and social performance indicators (KPIs) to track

Project progress in achieving the objectives and targets and to evaluate and improve environmental

and social performance.

The Environmental Action Plan (TNP-PLN-ENV-GEN-002_P3-2) outlines how TANAP intends to ensure

that the environmental aspects of the Projects construction, operation and decommissioning are

managed in line with Project requirements. It is noted that this document currently only refers to the

requirements of the IFC Performance Standards (2012) when committing to international standards.

Evidence of implementation of the commitments made in the Project monitoring document suite was

observed during the site visit and through revision of documents in the ESDD process.

Compliance with Turkish legal requirements is overseen by the MoEU and mainly relies on quarterly

third-party monitoring reports by Çinar, distributed electronically to relevant parties, and with a hard

copy sent to the Ministry and local authorities. It is noted that Çinar is the same company who

gathered the in-country baseline data, developed the local ESIA and the BAP and there may be a

perceived conflict of interest issue with regard to using the same company for the ESIA development

and independent monitoring over the ESIA implementation. Evidence, in the form of detailed

organisation charts have been provided by TANAP to demonstrate that the levels of independence

between separate teams is sufficient and eliminates the potential for conflict of interest queries by

interested third parties.

The IESC were unable to verify the financial provision for implementation of BAP monitoring

requirements to determine if these are sufficient for monitoring of biorestoration effectiveness in

critical habitat and to ensure sufficient consideration of ongoing maintenance of biorestoration works.

The details of these cost estimates are yet to be developed by TANAP for its operational budget. The

IESC team recommends that a detailed cost breakdown is provided in order to justify that the

financial allocation is sufficient for the length of the pipeline corridor and ensure sufficient

contingency budget allocations for any newly identified biodiversity remedial and offset activities.


Table 5-1 PR 1 Findings Summary

PR Ref.

Performance Requirement Score Comments/ Issues Actions Required

1 Assessment and Management of Environmental and Social Impacts and Issues

1.1 Environmental and Social

Assessment

FC The environmental and social impacts have been assessed through a

systematic process applied for all Project components as identified through the ESIA scoping and through engagement with key Government stakeholders in Turkey. The ESIAs have been developed to meet national standards, TANAP policy and guidance provided by international institutions such as the IFC, EBRD and EU. Some gaps were observed in the review of the ESIA related to the assessment of offshore construction impacts. The review found that the EISA did not adequately assess the impacts related to the potential for vessel to vessel interactions and vessel interactions with marine fauna. Vessel to vessel interactions are considered a high risk

given the stated level of high shipping traffic and vessel use in the offshore project area. Additional evidence provided by TANAP is sufficient to demonstrate compliance., including a HAZID which assesses this risk, and which will be updated prior to the commencement of construction activities. A set of Task Risk Assessments will also be developed, and the Contractor is currently developing comprehensive Emergency Management Plans.

1.2 Environmental and Social Management Systems

FC At the commencement of the Project, TANAP employed a three-tiered contractor structure to implement the Project, with an Engineering, Procurement, Construction and Management (EPCM) contractor managing the selected CCs in the field. TANAP has recently modified

this structure to an integrated two-tier organisation (with TANAP and CCs), removing the EPCM contractor from the organisational structure. At the time of the audit, the ESMS was out of date with respect to roles and responsibilities and subsequent system documentation. In many instances, the same individuals are working in the same roles (i.e. former EPCM staff are now directly employed by TANAP) so while day to day activities currently appear to remain well-managed and understood by staff, ESMS documentation


PR Ref.


reviewed during the audit does not reflect the current organisational structure and so may not effectively manage potential risks (e.g. arising from incidents, staff changes). As a work in progress, the IESC team considers this issue to be compliant with this, given that the issue is known, changes substantially commenced, and is considered

to be part of normal ESMS review and improvement during the life of the Project. Additional evidence provided to the IESC by TANAP indicates that the revision of TANAP documents is complete, and that CC reviews are ongoing and will be provided to the IESC as they are approved. The shift to an integrated team was instituted in August 2016, and the process of E&S integration is approximately 70% complete. The Integrated Management System (IMS) team appear to have adequate support, human and financial resources to implement the ESMS, with competent professionals supported by external experts as required.

1.3 Environmental and Social Policy2 FC TANAP has a documented Environmental and Social Policy. TANAP subcontractors also have documented Environmental and Social policies.

1.4 Environmental and Social Management Plan

PC TANAP has developed and implemented a detailed suite of Environmental and Social Management Plans (ESMPs) for the Project. As discussed in 1.2, ESMS documentation, revision of TANAP documentation is complete, while CC documentation is nearly complete (currently under review by TANAP). Adequate for purpose offshore ESMPs have been developed, although are still subject to disclosure in order to meet PR requirements.

Disclose Offshore ESMS documentation to ensure requirements of EBRD PRs have been met.

1.5 Organisational Capacity and Commitment

FC TANAP has a defined organisation structure, which is suitable to implement a Project of this size and magnitude. Sufficient environmental and social personnel have been employed to implement the ESMS and manage environmental and social issues

2 Where the project represents a substantial extension to the client activities, confirm that Policy and supporting management systems and plans are appropriate for the new activities.


PR Ref.


that are present on the Project. Refer to discussion in PR Ref 1.2 regarding discussion on organisational structure.

1.6 Supply Chain Management FC The major project activity of potential E&S supply chain risk is of

pipeline procurement; pipeline procurement was carried out following pre-qualification of potential suppliers from mills in Turkey and China. OHS inspection of pipeline mills was reported to have been carried out by the EPCM prior to selection of the mills. Seven pipe mills in total were supplying to the Project, supplying to TANAP as well as other Projects. Pre-qualification processes broadly addressed E&S requirements at the mills and contracts with major suppliers specify ESMS requirements and Project E&S standards. See also PR2. As a key tool for ensuring supplier compliance with E&S requirements, CCs are required to develop and implement Non-Conformance reporting (NCRs) /Quality management plans to define KPIs and quality reporting requirements. NCRs include criticality assessment and root cause analysis, auditing/improvement processes to reduce repetition of non-conformances, and requirements for reporting to TANAP.

1.7 Project Monitoring and Reporting3 PC TANAP has documented and is implementing the following monitoring activities as part of their ESMS: Environmental Action Plan; Environmental Monitoring Plan; Social Action Plan; Social Monitoring Plan; Resettlement Action Plan; and Biodiversity Action Plan. Regular monitoring and reporting of HSES requirements against

TANAP provide a more detailed cost breakdown to justify that the financial allocation for BAP Biorestoration monitoring is sufficient for the length of the pipeline corridor and ensure sufficient contingency budget allocations for any newly identified biodiversity remedial and offset activities.

3 At appraisal stage there will be limited information. Compliance assessment should address specific plans for monitoring and reporting (against for example ESAP requirements) and also consider whether there is evidence of weak monitoring/reporting by client on other relevant projects - which may reduce confidence in future performance.


PR Ref.


stated Key Performance Indicators (KPIs) was observed. Çinar is observed to be the same company who gathered the in-country baseline data, developed the local ESIA and the BAP. Evidence provided is sufficient to demonstrate that there is no conflict

of interest associated with the same company also performing independent third-party monitoring of Project implementation. Financial provisions for implementation of BAP monitoring requirements may not be sufficient to adequately characterise biorestoration effectiveness.


5.2 PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS

No material non-compliances were identified as the part of the review against labour and working

conditions criteria. Full compliance was observed in relation to child and forced labour, non-

discrimination and equal opportunity, and worker organisations. Some partial compliances were

observed in other areas within PR 2, outlined below.

5.2.1 Human Resource Policies and Working Relationships

The Host Govt Agreement requires that the labour standards applicable to the TANAP Project are

pursuant to National Laws, and no less beneficial than the provisions of the State’s relevant legislation

generally applicable to its citizens. It also requires that the Project Standards “take due account of

international standards and practices generally prevailing in the natural gas pipeline industry,

including relevant Performance Standards of the International Finance Corporation” (Article 17.1).

Turkey has ratified the core ILO Conventions on freedom of association, non-discrimination, child

labour and forced labour. The ESIA included assessment of labour issues in ESIA chapter 8.3.

The ESMP for this area is included in the Employment and Training MPs for TANAP and each of the

CCs (See ESIA Appendix 5.4 – pg 3-4 is on contracting and training requirements); addresses hiring,

training, compensation, benefits, work hours and grievance mechanism.

Project contractors’ HR policies included in their Employment and Training Management Plans are

reviewed and approved by TANAP. Third party monitoring is undertaken of implementation of these

MPs by Çinar. Additional third-party monitoring is conducted by Practical Solutions Group Dan Hiz.

Ltd. Sti on procedures in relation to TANAP contractor and sub-contractor working hours, leave, and

pay (TANAP Project Site Control Procedure, 01/03/2016). This reporting is provided to TANAP (stated

by TANAP during audit). The authorities are conducting their own labour law related inspections at

all workplaces in compliance with the legislation.

HR policies are consistent with national laws and implementation thereof is being monitored by a

Turkish labour law firm to ensure compliance (Practical Solutions Group). This is ensured by site

visits, audits, and interviews on site monthly. Requirements apply to all people working on the Project

regardless whether national or expatriate. Documentation on roles and responsibilities between the

Project and CCs requires updating to reflect the change in structure away from having an EPC in

place (see also Section 5.1.2).

The Report of “Manpower Analysis Study in Settlements on TANAP Natural Gas Pipeline Route” (HZR-

REP-SOCGEN-001) provided workforce analysis, and evaluation of the manpower capacity of the

provinces in which TANAP is active, to inform management of employment and training for the

Project. KPIs are in place for local employment (including unskilled, semi-skilled and skilled staff at

the national, province, district, village levels) in line with GIP, documented in Employment and

Training MPs for each CC (e.g. FRN-PLN-SOC-PL1-001).

All workers are reported to be advised of their rights and working conditions at the time of

engagement by human resources (including induction, code of conduct, probation period, grievance

mechanism). Additionally, this is provided for in CCs sample employment contracts (ref: Fernas


sample contract). Induction records were sighted and are consistent with lender requirements.

However, it was reported to the audit team during the site visit by some local community contract

workers that contract terms were not clearly understood. This suggests that induction requirements

may not be applied consistently across all CCs.

Correspondence sighted (TANAP-TKF-WRP-0651) indicates that CCs are free to associate and union

agreements are in place where threshold limits are met (i.e. greater than 50% worker membership

with a single TU organisation); there are TUs in place at Lots 2 and 3 (refs: TANAP-SYA-LET-WRP-

0533 and TANAP-TKF-LET-WRP-0651).

It was noted during discussions on-site and in the head office related to employee grievances (see

5.2.7), that overtime work and fatigue management were raised on several separate occasions.

Interviews revealed there is confusion at a site level as to the TANAP policy on overtime. The IESC

understands that TANAP does not encourage overtime working for its employees, however, due to

nature of the project, overtime working may occur within the legal limits. During interviews on site

with Lot 1 Contractor Fernas, personnel reported that overtime was allowed under Fernas company

policy. According to the World Bank TANAP Disclosure Package, TANAP is working to address

overtime issues through a “Working Hours Action Plan” that substantively addresses overtime issues,

including stakeholder complaints of overtime, CC compliance with TANAP overtime policies, and

enforcing legal compliance with the Turkish Labour Code. The Action Plan aims to reach compliance

with the Labour Code by December 31, 2017. The IESC notes that the Action Plan emphasis is

directed to legal compliance around overtime. While there is a commitment to ensure that overtime

hours are worked safely and without duress, it is not clear how fatigue management measures are

linked with effective overtime management. It is also noted that contractors are financially

incentivised for being on time/advance of deadlines, which may contribute to the issue of overtime

and fatigue (see 1.3 Contractor Management and Non-Conformances regarding holding back

payments). The IESC acknowledges TANAP’s recent focus on the above issues of overtime and

fatigue management. To this end, additional information was provided to the IESC in the form of the

H&S Incentive Procedure (TNP-PCD-HSM-GEN-025), which aims to promote awareness of H&S and

incentivise workers regarding their H&S performance in order to ensure that there is a balance

between schedule / milestone incentives. During meetings on 12 May 2017, TANAP also noted that

the link between financial incentives and effective fatigue management is an area of current concern,

and provided the example of hydrotesting, whereby additional resources were engaged rather than

the use of longer hours (Lot 1 had 2 hydrotest crews, and it now has 3 crews and a 4th is being

mobilised).

The provision of employee assistance programs as GIP was discussed during the field audit (e.g.

support following presence of workers at serious accidents/fatalities while working on the Project).

TANAP stated that employees are covered under the Turkish (public) Social Insurance System, which

includes indemnity for work related incidents, valid for all workers (both CCs and TANAP employees).

TANAP has initiated a private insurance coverage (MARSH) for its employees in the event of work

related accidents, however this does not extend to CCs employees (TANAP has not set up separate

(private) insurance to cover CC workers in the event of work related accidents they may be involved

in).


5.2.2 Child and Forced Labour

TANAP procures a wide range of goods and services, and the IESC found that no audits/inspections

of the TANAP supply chain with a focus on working conditions and child/forced labour has been

conducted to determine compliance with this PR (see related to discussion in Ref 1.6). The pipe

manufacturer pre-qualification questionnaire sighted does not contain provisions to assess the risk of

child and forced labour. However, the Health, Safety, Social and Environmental Requirements for

Suppliers and Vendors require supplier compliance with Turkish laws and regulations including the

Regulation on the Procedures and Principles of the Employment of Children's and Young Workers.

5.2.3 Non-Discrimination and Equal Opportunity

Nationally, Turkey has ratified the core ILO conventions including on non-discrimination and TANAP’s

role includes ensuring compliance with core labour standards on behalf of the Project. There was no

evidence of non-conformances of these requirements while on site.

The TANAP Employment and Training Management Plan makes an explicit commitment to non-

discrimination and equal opportunity (see ESIA Appendix 5.4 pg 1).

5.2.4 Workers Organisations

Worker organisations are in place in parts of the Project, and all employees are free to join labour

unions. Membership tends to reflect blue collar/white collar representation in each CC/TANAP

workforce. Turkish legislative requirements are that 51% of the workforce must have membership of

one Trade Union (TU) to enable an agreement to be established with the Company. The CCs in Lots 2

and 3 have an agreement with one national TU (“Yolic”/ “Is-Yol”). It was stated that all the workers

and some of the subcontractors are members of this union. Subsequent correspondence sighted

(TANAP-SYA-LET-WRP-0533) confirms that most of the workers of the contractor (as of February

2016, 600 of 700) are members of the TU, and the others do not belong to another organisation.

Further, the collective bargaining agreement came into force on 01/01/2016 and it valid until

31/12/2017 (applicable to workers in Sivas and Erzincan camp sites). Per the same correspondence,

the collective bargaining agreement specifies weekly working hours, and overtime payments in line

with the Labour Law. It was reported that negotiations are ongoing for Lots 1 and 4.

In the absence of trade union membership, there is a functional grievance mechanism in place for

employees (see 5.2.7).

5.2.5 Working Conditions


conditions (including retrenchment/termination) are (see 5.2.6) and in absence of a TU, the

individuals interviewed stated that any issues have been raised through the Muhtar to the relevant CC

for resolution through the Grievance Mechanism. TANAP CLOs are also in place and receive

comments from local workers, in addition to receiving and resolving comments/grievances via

Muhtars. While the TANAP Project Site Audit Procedure provided as evidence includes requirement for

provision of document of resignation or notice of termination, there appears to be confusion at a

ground level regarding termination and retrenchment. This may be exacerbated in the case of short-

term contracts that are open-ended, or, renewed without formal extension of the completion date.


While notice periods for dismissal of staff are in accordance with Turkish Labour Law requirements4,

which should reflect ILO Convention 158 Termination of Employment Convention, 1982 (which Turkey

has ratified), in practice notice periods for dismissal may be occurring inconsistently, particularly in

relation to casual / short-term work. For example, TANAP reported that the third-party audits have

not found inconsistencies with national legislative requirements, however in interviews with locally

engaged staff at Ardiçli village, it was stated that following the completion of a one year contract at

the CC, a short-term contract was commenced with a subcontractor with no contract in place and

little notice for ‘termination’ of the worker. Internal audits are conducted of CCs (e.g. evidence from

EPCM audit of CC (WRP-REP-ENV-PL1-001; WRP-REP-ENV-PL2-003) indicating compliance checks

against labour issues including overtime and communications on contracts with workers. These

audits are documented in the TANAP Project Site Control Procedure, the scope of which is to audit

working conditions and rights of workers including working hours, leave, payroll, Social Security,

terminations/new hires and so on by carrying out a physical audit at least in one camp monthly.

The TANAP Health and Safety team is engaged in the design and inspection of CC accommodation.

This includes for example, that TANAP review the Lot 4 camp design to ensure requirements are met,

and for those now in place, regular inspections of accommodation. The Construction Camp

Management Plans describes weekly inspections by Camp Management personnel to ensure hygiene,

maintenance, and safety requirements are maintained. Stations contractors are supplying their own

camps however it was not possible to view one during the field audit. The Health and Safety team

audit food, accommodation, and medical facilities. A visual inspection of the camp at Lot 2 indicated

appropriate accommodation requirements are met.


the work being conducted and the climatic conditions at the time (see also PR4 on OHS). A lack of

in-field amenities including toilets, shelters and heating were observed in a range of separate

locations in the field at Lot 1. Temperature in the field during the site visit was approximately -5 to -

10C. Remains of a campfire on bare ground were observed in the Erzurum Wetland (Critical Habitat

area). TANAP presented to the IESC information regarding non-conformance reporting (NCRs) and

management. NCR requirements address the process in place to develop and assess criticality of

4 Article 29 of the Turkish Labour Law Turkish requires 30 days notice to implement collective dismissal for economic, technical or similar reasons, affecting a specific number of workers of an organization. In relation to individual termination and retrenchment, international Law, specifically ILO Convention 158 Termination of Employment Convention, 1982 on the issue of notice periods for dismissal of staff states that “a worker whose employment is to be terminated shall be entitled to a reasonable period of notice or compensation in lieu thereof, unless he is guilty of serious misconduct, that is, misconduct of such a nature that it would be unreasonable to require the employer to continue his employment during the notice period”. The Turkish Labour Law allows termination without notice for reasons that are less stringent than the ILO provision for “serious misconduct”. According to the Turkish Labour Law, the employer can immediately terminate an employment contract for a just cause whether for a definite or indefinite period, before its expiry or without the prescribed notice periods. The law provides a list of reasons for breaking the contract for just cause which are divided in three groups for the employee and four groups for the employer (Art. 24 and 25), namely, reasons of health; immoral or dishonourable conduct or other similar behaviour and force majeure. There is also a fourth group for the employer which is the employee being under arrest or under custody. The employer is entitled to break the employment contract, whether for a definite or indefinite period, before its expiry or without the prescribed notice periods in the above cases.


NCRs, and steps for root cause analysis, corrective action implementation and NCR closure; this is

addressed further in PR 1.

Construction camp facilities provide adequate accommodation for workers, documented in Camp MPs

(e.g. TKN-PLN-HSM-GEN-003-P4-0).

5.2.6 Retrenchment

Local workers are being recruited by CCs for finite periods of time for work in each pipeline section

before retrenchment. It was reported and documented that workers are informed in advance of their

appointment about the duration, scope, and worker conditions (including demobilisation processes) at

their appointment. There is a large, skilled workforce in Turkey, therefore the Project is trying to

maximise local employment opportunities as the work in each area progresses. Opportunities for

local employment exist now during the current construction phase of work and retrenchment is

carried out rather than engage and move local unskilled labour outside their village/district; this is

also an approach to minimise any potential influx issues between villages/districts. It was reported

that retrenchment activities including notification and final payments, are carried out in accordance

with Turkish legal requirements.

Specific retrenchment programs are carried out by CCs, including provision of references to good

performers and providing employment again on other construction contracts (e.g. as reported by

Fernas) and TANAP reports that CCs prepare Retrenchment Plans (not sighted).


conditions (including retrenchment) are; in absence of a TU, the individuals interviewed stated that

any issues have been raised through the Muhtar to the relevant CC for resolution through the

Grievance mechanism (see 2.5 for further discussion).

5.2.7 Grievance Mechanism

All TANAP workers (worker and non-employee workers) have access to SpeakOut, TANAP’s whistle-

blower mechanism. Training on SpeakOut is provided during induction for all workers, and

signage/access is provided in camps and offices. During induction, workers are informed that any

complaint they have should go through the CRO of CC, or direct to TANAP. If the complainant wishes

to remain anonymous, then it is possible to call through a dedicated hotline or use a non-identifying

form for lodging the complaint; most complaints are not anonymous. TANAP reports that status

update and trend analysis of worker complaints will be announced on Community Relations

noticeboards available in camp sites, to be updated monthly.

CC Tekfen additionally has access for all its staff to the grievance mechanism ‘Sound off’ (ref: TANAP-

TKF-LET-WRP-0651). Coordination between CC and TANAP grievance mechanisms is documented in

the CC’s SMP with implementation monitoring by TANAP through internal and external auditing. CCs

are required to establish their own grievance mechanism, which are in effect for both community and

worker grievances. The Community Relations and Human Resources Departments coordinate

grievance handling in accordance with the grievance mechanism, Turkish law, and Project

requirements. All grievances are recorded in OSID (Online Stakeholder Interaction Database,

regarding grievances raised and corrective actions.


The TANAP Grievance Mechanism (TNP-PCD-SOC-GEN-001) was updated on 31/1/17, and is

considered by the IESC to be compliant with the Performance Requirements.

Demobilisation process and late payment of salaries are the main topics of grievances raised by

workers overall, while Fernas also reported issues of unfair dismissal, and of poor food quality at

camp, which was resolved and rectified through the internal monthly monitoring system.

5.2.8 Non-Employee Workers

Engagement of non-employee workers carried out by CCs is undertaken in accordance with the

contractor management processes and procedures that are in place. TANAP has developed guidance

for CCs (through the former EPCM) for their development of ESMPs including Worker Management

MPs, that required approval by TANAP prior to their implementation to ensure minimum requirements

are met across all CCs. Skilled/unskilled work opportunities are locally advertised including (generally

reported) notification of working conditions and contract duration. Contract workers are informed that

the construction phase is temporary (20,000 people engaged); there is no obligation in contractor

employment agreements to provide ongoing employment. At the first consultation meeting in

settlements along the pipeline corridor, announcements are made of employment opportunities, the

type of labour required and duration, in accordance with the Local Employment MP.

Minimum working conditions for contractors are also third party monitored and are subject to

regulatory inspections.

5.2.9 Supply Chain

TANAP procures a wide range of goods and services required to complete the Project. Related to the

discussion in Ref 1.6, TANAP has not conducted any audits/inspections of their supply chain with a

focus on working conditions and child/forced labour to determine if they are compliant with this PR.

Pipe manufacturer pre-qualification questionnaire sighted does not contain provisions to assess the

risk of child and forced labour. However, the Health, Safety, Social and Environmental Requirements

for Suppliers and Vendors (ILF·SPC-HSE-GEN-001, Rev P2-0, 07.03 .2014) requires supplier

compliance with Turkish laws and regulations including the Regulation on the Procedures and

Principles of the Employment of Children's and Young Workers (#25425, 06.04.2004).

5.2.10 Security Personnel

The Host Govt Agreement provides that:

• the TANAP Project Entity shall provide the security of manned Facilities, including material

storage yards and permanent installations, in accordance with National Laws; and

• the Parties will develop a security plan to co-ordinate these activities.

TANAP specifies its security requirements to contractors through the Security Management Appendix

of the CC contract (consistent across all CCs), and directs communications through each CC’s Security

Manager. Each CC has a security subcontractor. Governors of each area determined whether security

guards are armed or unarmed, and this was reported to be detailed in a Security Risk Assessment for

the use of arms (sample Security Risk Assessments and security due diligence materials were

provided for IESC review).


Private security legislation additionally guides implementation of local legal requirements with respect

to security personnel, roles, and responsibilities. In Turkey, the law regulating the private security

industry is Law No. 5188 on Private Security Services, enacted in 2004, which regulates the private

security industry and allows for armed private security services. Licensing for private security

companies and guards is mandatory, and the Ministry of the Interior is the national authority in

charge of controls and inspections for the industry. Legal provisions include the identifying

requirements of guards (i.e. distinguishing uniforms, identification cards), and competencies and

powers of guards. Use of force is provided for, in accordance with Article 981 of Turkish Civil Law and

Article 7 of Law No. 5188 on Private Security Services, and a special licence is required for private

security companies owning weapons. Private security companies cannot provide services and

activities that are/would normally be reserved to police forces or other public security authorities in

Turkey. Turkish national-level private security legislation is considered ‘strict’ in relation to that of

other nations in the EU. 5

A suite of security related documents has been developed by TANAP. An evaluation plan, crisis

management, and training plan have been developed to guide security-related events and activities

and sample training records of Contractors have been provided for review. A protocol between the

Gendarmerie (law enforcement authority in rural areas) and TANAP for the construction phase is

under review. A project specific Security Management Plan has been developed for implementation

by Fernas. This Plan specifies that Government Private Security Commissions in each of the following

determined that security contractors will carry or use a weapon; in: Erzrum, Kars, Ardahan, Erzincan,

Sivas, Gumushane, and Giresun. Some of these districts include Kurdish populations. The Plan

requires that the Security Subcontractor Company provide a statement that they are willing to comply

with the “Voluntary Principles on Security and Human Rights (VPSHR)”, and photographic evidence of

the training sessions have been provided. The plan also specifies plan roles and responsibilities;

reasonable use of (lethal) force/rules of engagement; provisions for weapons storage, handling and

use; licencing; staff qualifications and training; and reporting. Coordination between the Security

Coordinator, Law Enforcement, and Regional police/Gendarme Commanders is also articulated,

specifying mechanisms in crisis events / natural disasters.

TANAP Security Department has responsibility for security analysis, inspection, training functions, as

well as the Security Management System during the operations phase, to be run from the Main

Control Centre (for the whole of the project, near Ankara).

Camp security managers are responsible for communications with HS Manager and Camp manager on

Camp Emergency Response matters, including drills, and with other stakeholders such as TANAP,

Local Authorities and local Communities (e.g. Camp management system SYA-PLN-HSE-GEN-012 and

see also PR4 item 4.9 regarding community conflicts/demonstrations).

IESC considers that reasonable efforts have been made to align with this PR, including adequate due

diligence of security providers and presence of Standard Operating Procedures guiding activities.

Training on use of force and appropriate conduct towards communities by security personnel is

5 Private Security services in Europe: CoESS Facts and Figures 2013 (Confederation of European Security Services)


considered efficient to demonstrate compliance (e.g. Security Risk Assessment, training records,

Security Management Plan).



PR Ref.


2 Labour and Working Conditions

2.1 Human Resource Policies and

Working Relationships

PC It was noted during discussions on-site and in the head office related

to employee grievances, that overtime work and fatigue management were raised on several separate occasions. Interviews revealed there is confusion at a site level as to the TANAP policy on overtime. The IESC understands that TANAP does not encourage overtime working for its employees, however, due to nature of the project, overtime working may occur within the legal limits. During interviews on site with Lot 1 Contractor Fernas, personnel reported that overtime was allowed under Fernas company policy. According to the World Bank TANAP Disclosure Package, TANAP is working to address overtime issues through a “Working Hours Action Plan” that substantively addresses overtime issues, including stakeholder complaints of

overtime, CC compliance with TANAP overtime policies, and enforcing legal compliance with the Turkish Labour Code. The Action Plan aims to reach compliance with the Labour Code by December 31, 2017. The IESC notes that the Action Plan emphasis is directed to legal compliance around overtime. While there is a commitment to ensure that overtime hours are worked safely and without duress, it is not clear how fatigue management measures are linked with effective overtime management. It is also noted that contractors are financially incentivised for being on time/advance of deadlines, which may contribute to the issue of overtime and fatigue. The IESC acknowledges TANAPs recent focus on the issues of overtime and fatigue management. To this end, additional information was provided to the IESC in the form of the H&S Incentive Procedure (TNP-PCD-HSM-GEN-025), which aims to promote awareness of H&S and incentivise workers regarding their H&S performance in order to ensure that there is a balance between schedule / milestone incentives. During meetings on 12 May 2017, TANAP also noted that the link between financial incentives and effective fatigue

Develop strengthened documentation and key

actions for agreement with TANAP and EBRD on overtime, to be incorporated into the ESMS, as follows: Develop and conduct a program of engagement

with CC workers through appropriate mechanisms (e.g. HR Managers) to clarify overtime policy at the site level and strengthen worker understanding of policy;

Continue to implement procedures, plans and employment contracts consistent with working hour policies. TANAP to share audit reports from Practical Solutions with EBRD.

Fatigue Management: Develop a Fatigue Management Plan for TANAP

and its CCs; Agree the Plan and its timeframe for

implementation with the EBRD; Implement the Plan as agreed.


PR Ref.


management is an area of current concern, and provided the example of hydrotesting, whereby additional resources were engaged rather than the use of longer hours (Lot 1 had 2 hydrotest crews, and it now has 3 crews and a 4th is being mobilised).

2.2 Child and Forced Labour FC TANAP and, through its contracting arrangements, the CCs, ensure no

child or forced labour is in use in the Project through employment procedures. This includes confirmation of age through provision of identification (proof of age) at recruitment, and the requirement to report to the relevant Government agency of compliance with national legislation that precludes employment of anyone under 18 years of age. All employees (TANAP and CCs) provide social security, demonstrating no staff are engaged forcibly.

2.3 Non-Discrimination and Equal Opportunity

FC Nationally, Turkey has ratified the core ILO conventions including on non-discrimination and TANAP’s role includes ensuring compliance with core labour standards on behalf of the Project. There was no evidence of non-conformances of these requirements while on site.

2.4 Workers Organizations FC Worker organisations are in place in parts of the Project, and all employees are free to join labour unions

2.5 Wages, benefits, and conditions of work and accommodation

PC Interviews with short term labour suggests that not all CCs are making clear what the working conditions (including retrenchment/termination) are. TANAP requires provision of a document of resignation or notice of termination, in practice notice periods for dismissal may be occurring inconsistently, particularly in relation to casual / short-term work. It is noted that the CCs are required to prepare Retrenchment Plans.

Termination and retrenchment provisions: Share with EBRD the Retrenchment Plans of

each of the CCs Share the first two quarterly monitoring reports

of the Retrenchment Plans, undertaken by TANAP of the CCs.

2.6 Retrenchment6 PC With respect to notice periods, interviews with short term labour suggests that not all CCs are making working conditions (including retrenchment / termination procedures) clear. TANAP requires

provision of a document of resignation or notice of termination, in practice notice periods for dismissal may be occurring inconsistently, particularly in relation to casual / short-term work.

Refer to PR Ref 2.5

6 Will not be applicable to many projects at appraisal stage. However evidence, within the last 3 years of client approach to retrenchment which is not compatible with the Policy should be taken into consideration.


2.7 Grievance Mechanism FC An operational grievance mechanism is in place with appropriate documentation, which appears to be being used effectively. Informal mechanisms for raising grievances were also noted (e.g. though Muhtars at village level for local workers), although it appears that some of these informally raised grievances may not be registered for tracking, monitoring and reporting within in the central recording and tracking system (OSID). OSID has oversight and overall management by TANAP, of all TANAP and CCs complaints, provided these have been appropriately uploaded into the system.

2.8 Non-Employee Workers FC Engagement of non-employee workers carried out by CCs is undertaken in accordance with the contractor management processes and procedures that are in place. Skilled/unskilled work opportunities are locally advertised including (generally reported) notification of working conditions and contract duration. Contract workers are informed that the construction phase is temporary (20,000 people engaged); there is no obligation in contractor employment agreements to provide ongoing employment. At the first consultation meeting in settlements along the pipeline corridor, announcements are made of employment opportunities, the type of labour required and duration, in accordance with the Local Employment MP. Working conditions of the employees of the contractors are also third party monitored.

2.9 Supply Chain FC TANAP procures a wide range of goods and services required to complete the Project. TANAP has not conducted any audits/inspections of their supply chain with a focus on working conditions and child/forced labour to determine if they are compliant with this PR. Pipe manufacturer pre-qualification questionnaire sighted does not contain provisions to assess the risk of child and forced labour. However, the Health, Safety, Social and Environmental Requirements for Suppliers and Vendors (ILF·SPC-HSE-GEN-001, Rev P2-0, 07.03 .2014) requires supplier compliance with Turkish laws and regulations including the Regulation on the Procedures and Principles of the Employment of Children's and Young Workers (#25425, 06.04.2004).


2.10 Security Personnel Requirements FC The IESC considers that reasonable efforts have been made to align with PR 2.10 Security Personnel Requirements, including the adequate due diligence of security providers, their training on the use of force and appropriate conduct towards communities by security personnel occurs.


5.3 PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND CONTROL

This section provides comments on the baseline characterisation and the impact analysis with respect

to pollution prevention and abatement measures expected for all Project-related facilities during both

construction and operations. The analysis focuses on the adequacy of mitigation measures and

pertinent ESMPs reviewed. In this section, the attention is focused on the topics included in PR 3,

Resource Efficiency and Pollution Prevention and Control.

5.3.1 Resource Efficiency

The ESIA and ESMPs provides the overarching Project principles for the application of resource

efficiency and pollution prevention principles. These Principles are defined as: identify and understand

impacts; consult with others; design and avoid adverse impacts and minimise use of natural

resources. The ESMPs includes environmental control strategies designed to reduce waste and

conserve natural resources through engineering and procurement environmental design controls and

construction and installation controls.

PR 3 requires that the ESIA process identifies opportunities and alternatives for resource efficiency in

accordance with GIP. Regarding the Compressor Stations (CSTs), it is not clear in the ESIA and

supporting documentation available for review how this has occurred. The CSTs are a major emitter

of GHG during operation of the pipeline, as identified in the ESIA. A BAT assessment has been

conducted and provides sufficient detail to verify that EBRD guidance requirements have been met in

relation to how the adoption of resource efficiency and waste reduction considerations helped to

define the technology chosen in the CSTs. The BAT included detail on the realisation of the energy

savings possible because of the adoption of BAT for the CSTs and demonstrated that energy

efficiency measures have been identified.

5.3.2 Pollution Prevention and Control

A Pollution Prevention MP has been developed by TANAP and its construction contractors to minimise

and manage pollution on the environment. Avoidance and minimisation of emissions is demonstrated

in the ESIA and through the incorporation of appropriate controls.

This MP sets out the ESIA compliance requirements and relevant responsibilities associated with

pollution prevention and spill prevention and response. It provides a list of the relevant ESIA

commitments and who has responsibility for the task(s) required for compliance with the

commitment, in line with the tasks and responsibilities assigned within the TANAP Environmental and

Social Compliance Registers. Contractor responsibilities are clearly defined and include the

requirement to develop a specific Pollution Prevention MP. Examples of CC Pollution Prevention MPs

were reviewed for suitability during the ESDD process. CC MPs are also publicly disclosed on the

TANAP website.

5.3.2.1 Air Quality

Project emissions were analysed and assessed through the conduct of an atmospheric dispersion

modelling exercise. TANAP utilised AERMOD, a USEPA approved modelling software, to conduct

emission modelling for particulates and gaseous emissions caused by Project activities. Emissions


from the modelling exercise were compared against the requirements of the Turkish Regulation on Air

Quality Assessment and Management (2008) as well as the WHO Ambient Air Quality Guidelines and

EU Directive 2008/50/EC/.

Construction

Generation of particulate matter was the primary impact identified during construction activities and

these are managed in the Pollution Prevention MP. Particulate emissions at sensitive receptors

(human and ecological) were assessed with appropriate methodology. Mitigation measures included

consideration of technically and financially feasible options to reduce construction emissions.

Operation

The primary emission source during operations are the CSTs located along the pipeline route (4

CSTs). These are designed to increase the gas pressure to adjust the gas flow to the desired

throughput. Each compressor station will be operated by gas turbines and the gas supply will be

provided from the gas flow in the pipeline. As such these facilities will have associated gaseous

emissions which required assessment. The ESIA states (in Chapter 2) that best practice technology

has been considered in reducing emissions from the CSTs. Modelled Ground Level Concentrations

(GLCs) of gaseous emissions surrounding the CSTs indicate that they are below applicable Project

Standards.

The maximum rated output of the CSTs is 157MW (for three out of four of the CSTs). EU Directive

2010/75 requires that facilities with power rating greater than 100MW shall have their emissions

monitored continuously. This should be confirmed once the infrastructure design has been defined

further.

Management and monitoring plans for air emissions during operation phases (both routine and non-

routine) of the Project have not yet been developed; although the design requirements for equipment

are specified and include minimum emission performance standards. The emissions to air from the

CST’s has been predicted using air dispersion models.

5.3.2.2 Water Quality

The Project generates two main streams of waste water from its construction activities; these being

effluent water generated from Project camps/facilities and hydrotest waste water.

The ESIA states that waste water from domestic requirements will be captured and treated in water

treatment facilities prior to being discharged to the environment. Prior to discharge, testing would be

undertaken to ensure compliance with Project Standards.

Onshore hydrotest water will preferentially be taken from surface water bodies. After use, it is

intended that water be treated until it meets the required Project Standards and discharged back to

the closest receiving environment (surface water). Where possible, addition of chemical corrosion

inhibitors will be avoided, although in some cases they may be required. The hydrotesting process is

managed through an Environmental Hydrotest Monitoring Plan, developed under TANAP guidance for

each CC over the four Lots. Each water abstraction and discharge point along the entire route was

assessed for water quality and ecological restrictions and appropriate management measures

proposed (i.e. exclusion of fish spawning periods for extraction activities).


Water intake for hydro testing is taken based on permits granted by DSI, the General Directorate for

State Hydraulic Works. Water intake is metered at the source and instant flow rate monitors are

used. To reduce the intake of water, used hydrotesting water is pumped from one section to another.

Used hydro testing water goes through sedimentation and filtration before the discharge; and

laboratory tests are conducted to ensure water meets Project Standards prior to discharge.

Hydrostatic testing of offshore equipment and marine section of the pipeline involves pressure testing

with water (typically filtered seawater, unless equipment specifications do not allow it) to verify

equipment and pipeline integrity. Chemical additives (corrosion inhibitors, oxygen scavengers, and

dyes) may be added to the water to prevent internal corrosion or to identify leaks. A range of

measures have been proposed to minimise pollution to the marine environment from hydrotesting,

although these have yet to be formalised within the ESMPs and require review against EBRD PRs

when completed.

Water supplied to the construction camps is extracted from groundwater bores at the site under

permit from the DSI. Sanitary wastewater from the camps is treated at on-site wastewater treatment

plant and discharged to an approved location after it meets applicable Project Standards. As for the

wastewater from construction sites, it is understood that such water is collected in septic tanks and

then transported to the camps for treatment.

During operation, the collection of process waste water in the Above Ground Facilities is possible. It

will be collected in impermeable storage containers and either pumped to waste water treatment

plants if nearby or transferred by truck to an appropriate facility.

5.3.2.3 Soil

Soils were studied with specific reference to their ability to produce acidic conditions (due to sulphide

oxidation) upon excavation. Specifications for this soil testing were documented in a Subsurface

Investigation Works procedure, primarily designed to determine soil conditions and their potential for

corrosion of steel and concrete. If hostile soil conditions were encountered, then changes to the

pipeline route were considered or specific management and mitigation measures introduced.

5.3.3 Greenhouse Gases

The ESIA has assessed impacts related to GHG emissions, although it does not appear to contain

consideration of technically and financially achievable options to minimise emissions of GHG in the

assessment process. Upon IESC request, supplementary evidence was provided, in the form of the

BAT emissions inventory and relevant evaluation data, that demonstrates that resource efficiency

measures have been considered during design (e.g. ability to limit venting of gas, alternative forms of

power supply during operations or waste heat recovery systems).

An assessment of GHG emissions has been conducted in Section 8.1.1 of the ESIA. Emissions were

calculated using the guidance outlined in INGAA, 2005. Greenhouse gas emission estimation

guidelines for natural gas transmission and storage – Volume 1 – GHG emission estimation

methodologies and procedures.

Section 10.5 of the ESIA estimates total annual GHG emissions as follows (CO2-equivalent):

• GHGs emissions during construction phase: 78,883 tonnes per year;


• GHGs emissions from operation: 1,956,049 tonnes per year; and

• GHGs emissions during decommissioning: 7,888 tonnes per year.

The EBRD requires that operations that produce more than 25,000 tonnes CO2-equivalent annually

quantify and report these emissions to the EBRD annually, in accordance with the EBRD Methodology

for Assessment of Greenhouse Gas Emissions.

5.3.4 Water

Combined with the discussion in 5.3.2, abstraction of water for hydrotest activities is assessed in the

ESIA; with more detail on each abstraction point given in the BAP and within the CCs respective

Hydrotest Management Plans. Examples reviewed demonstrated that both ecological and social

aspects were considered when assessing the abstraction and discharge points for each hydrotest

location, as required by PR 3.

5.3.5 Waste

The ESIA includes a detailed assessment of waste streams generated by the Project during

construction, operation and decommissioning. Management and mitigation measures are documented

in a Waste Management Plan and Pollution Prevention Plan developed by TANAP and each CC has

developed their own equivalent plans for implementation on the Project. The Plan’s includes key

responsibilities and accountability; waste forecasting requirements; segregation; application of the

waste management hierarchy; organisational structure; training; monitoring and reporting.

Waste disposal is regulated under Turkish legislation, with which TANAP complies. Waste contractors

are utilised to transfer waste to the nearest municipality landfill and disposed of. Recyclable material

will be segregated and disposed of at appropriate facilities licenced by the applicable Ministry.

Hazardous wastes are disposed of by a licenced waste disposal contractor with applicable permits

under Turkish legislation. Chain of custody records are held by TANAP confirming waste has been

disposed of at an appropriate facility.

As discussed in Section 5.1.6, EBRD PRs recommend that clients ascertain whether licenced disposal

sites are being operated to acceptable standards. Evidence has been supplied to validate that TANAP

has conducted site verification audits of licenced waste disposal facilities along the pipeline route to

ensure that Project generated waste is being disposed of appropriately by the contractor.

5.3.6 Hazardous Substances

The Project does not use or generate substantial hazardous waste volumes. The Project utilises a

formal chemical management system (ChemAlert) to manage and inform their use and selection of

chemicals that may be required during Project activities. This system preferentially selects chemicals

with the least ecological impact.

As per the requirements of both Turkish and EU legislation, TANAP utilises licenced contractors to

transport and dispose of hazardous waste. The EBRD PRs recommend that clients ascertain whether

licenced disposal sites are being operated to acceptable standards. TANAP has conducted site

verification audits of a sample of disposal facilities along the pipeline route to ensure that their waste

is being disposed of appropriately by the contractor.



PR Ref.


3 Resource Efficiency and Pollution Prevention

3.1 Resource Efficiency FC The principles of resource efficiency appear to have been suitability

identified during the ESIA process. Supplementary evidence provided to the IESC is sufficient to demonstrate appropriate consideration of energy efficient measures during project planning.

3.2 Pollution Prevention and Control - Air emissions

FC A Pollution Prevention Management Plan has been developed by TANAP and its construction contractors to minimise and manage pollution on the environment. The ESIA states (in Chapter 2) that best practice technology has been considered in reducing emissions from the Compressor Stations

(CSTs). The maximum rated output of the CSTs is 157MW (for three of the CSTs). EU Directive 2010/75 requires that facilities with power rating greater than 100MW shall have their emissions monitored continuously. It is not clear in the ESIA whether this will occur at the CSTs as part of the commitment to best practice technology. Emission limits are listed in Chapter 4 (Table 4.4-3) and discussed in Chapter 8.1.14 of the ESIA. Modelled emissions for CST’s have been provided and the maximum emission criteria for each unit is specified

in the design documentation.

3.3 Pollution Prevention and Control - Waste waters

FC A Pollution Prevention Management Plan has been developed by TANAP and its construction contractors to minimise and manage pollution on the environment. The Project generates two main streams of waste water from its construction activities; these being effluent water generated from Project camps/facilities and hydrotest waste water.


PR Ref.


The ESIA states that waste water from domestic requirements will be captured and treated in water treatment facilities prior to being discharged to the environment. Prior to discharge, testing would be undertaken to ensure compliance with Project Standards.

Onshore hydrotest water will preferentially be taken from surface water bodies. After use, it is intended that water be treated until it meets the required Project Standards and discharged back to the closest receiving environment (surface water). Where possible, addition of chemical corrosion inhibitors will be avoided, although in some cases they may be required. Hydrostatic testing of offshore equipment and marine section of the pipeline involves pressure testing with water (typically filtered seawater, unless equipment specifications do not allow it) to verify equipment and pipeline integrity. Chemical additives (corrosion

inhibitors, oxygen scavengers, and dyes) may be added to the water to prevent internal corrosion or to identify leaks. A range of measures have been proposed to minimise pollution to the marine environment from hydrotesting. During operation, the collection of process waste water in the Above Ground Facilities is possible. It will be collected in impermeable storage containers and either pumped to waste water treatment plants if nearby or transferred by truck to an appropriate facility.

3.4 Greenhouse Gases7 FC The ESIA has assessed impacts related to GHG emissions, although it does not appear to contain consideration of technically and financially

achievable options to minimise emissions of GHG in the assessment process. Upon IESC request, supplementary evidence was provided in the form of the BAT emissions inventory and relevant evaluation data

Commit to annual reporting of GHG emissions to the EBRD in line with their accepted methodology.

7 Particular attention should be given to client demonstration of consideration of alternatives. Projects expected annually to produce more than 25,000 tonnes of Co2 equivalent should provide an emission inventory and plans for annual reporting.


PR Ref.


that demonstrates resource efficiency measures have been considered during design (e.g. ability to limit venting of gas, alternative forms of power supply during operations or waste heat recovery systems). While this may have formed part of Project planning and assessment, it has not been expressly stated in the ESIA documentation.

An assessment of GHG emissions has been conducted in Section 8.1.1 of the ESIA. Emissions were calculated using the guidance outlined in INGAA, 2005. Greenhouse gas emission estimation guidelines for natural gas transmission and storage – Volume 1 – GHG emission estimation methodologies and procedures. The EBRD requires that operations that produce more than 25,000 tonnes CO2-equivalent annually (which TANAP does) quantify and report these emissions to the EBRD annually, in accordance with the EBRD Methodology for Assessment of Greenhouse Gas Emissions.

3.5 Water FC Discussion is evident in the ESIA on the need to minimise and re-use water where possible.

3.6 Wastes FC Detailed consideration of waste streams and their impact has been provided in the ESIA.

3.7 Hazardous Substances and Materials FC As per the requirements of both Turkish and EU legislation, TANAP utilises licenced contractors to transport and dispose of hazardous waste. The EBRD PRs recommend that clients ascertain whether licenced disposal sites are being operated to acceptable standards. TANAP has conducted site verification audits of a sample of disposal facilities along the pipeline route to ensure that their waste is being disposed of appropriately by the contractor.


5.4 PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY

This PR recognises the importance of avoiding or mitigating adverse health and safety impacts and

issues associated with Project activities on workers, communities and consumers.

5.4.1 Occupational Health and Safety

TANAP implements a detailed Health and Safety Management System (HSMS) to manage the

Project’s Health and Safety (H&S) risks. The principles of the HSMS are documented in the TANAP

H&S Commitment (Policy) signed by the executive management team of TANAP.

Risk assessments form the basis of the management controls within the HSMS and apply the

mitigation hierarchy in their implementation. A dedicated organisational structure has been defined

to implement the TANAP HSMS.

H&S expectations for CCs were communicated during the tender process through the Health, Safety,

Social and Environmental Requirements for Suppliers and Vendors. CCs implement their own internal

HSMS which aligns with the TANAP HSMS.

High risk hazards are controlled through a Permit to Work (PTW) process, implemented by each Lot

CC and under supervision from TANAP personnel. Activities that require implementation of a PTW

include:

• Cold Work;

• Hot Work;

• Excavation;

• Confined Space;

• Lock Out / Tag Out; and

• Gas Measurement.

Lifting of pipeline on each Lot is managed under procedural guidance in the form of Safe Work

Method Statements (SWMS), as it was determined that due to the large amount of pipeline lifts on

the Project that control through a PTW system would be time consuming without providing additional

benefits to the task.


the work being conducted and the climatic conditions at the time (see also PR 2 on working

conditions). A lack of in-field amenities including toilets, shelters and heating were observed in a

range of separate locations in the field at Lot 1. Temperature in the field during the site visit was

approximately -5 to -10C. Remains of a campfire on bare ground were observed in the Erzurum

Wetland (Critical Habitat area). The IESC considers that the observed working conditions may pose

an occupational health and safety risk to construction workers on this Lot. TANAP has a NCR system

in place to manage CC performance. However, it is not clear when / if it has been used for OHS

breaches relating to environmental conditions experience in each Lot. The TANAP Assurance Review

process provides a detailed review of contractor management of HSE issues including site worker

facilities, fatigue management for drivers, high risk work procedures, work permit system


implementation, worker training requirements and competency. The outcomes and corrective

actions of the assurance review process are tracked by TANAP.

5.4.1.1 Project H&S Incidents

TANAP monitors workplace H&S incidents and near misses. This process is outlined in the Incident

Management, Reporting and Action Tracking Procedure (TNP-SCD-HSM-GEN-006). Clear evidence

was available during the site visit that incidents are investigated in an appropriate manner and

measures to prevent reoccurrence implemented. TANAP monitors worker health through a Health

and Hygiene Monitoring process, also implemented by the CCs.

As of March 2017, the Project had recorded 1 fatality in the year to date and 6 fatalities for the period

of the Project. There have been 5 Lost Time Incidents in the year to date and 27 for the Project to

date. For road accidents attributable to the Project, there have been 2 recordable accidents in the

year to date and 14 over the life of Project. TANAP has recorded a Lost Time Injury frequency rate of

0.66 which is below its target of 0.82. The Project’s Total Recordable Injury Frequency Rate (TRIFR)

is 1.45 which is also below the Project target frequency rate of 2.

For each major safety incident, the IESC team reviewed the detailed incident reports to determine

whether the appropriate response measures had been investigated and implemented. Each incident

appeared to have been investigated in detail, with numerous corrective actions implemented.

Fatalities that occurred were on Lots managed by different CCs and involving a range of scenarios

(i.e. no pattern of occurrence) however a review of incident root cause analysis indicated that some

recurring trends were observed. These included insufficient training, infrequent audits and

evaluations and inadequate risk assessment of tasks. For personnel involved in or witnessing these

incidents, it is not clear if additional support in terms of counselling services has been offered to these

employees.

A review of the Project incident database identified that there were many incidents that involved near

misses and first aid / lost time injuries related to pipeline lifting activities. One of the recorded

fatalities was also a lifting incident. The detailed incident report related to the lifting fatality stated

that root causes of the incident were insufficient training and a lack of suitable procedures for the

tasks. Interviews with employees on the Lot indicated that it was normal practice for personnel to be

in the designated ‘danger zone’ during lifts, amongst other system failings. The fact that it was

considered normal working practice to be within the ‘danger zone’ during lifts also indicates that there

may have been a lack of appropriate supervision and conduct of workplace inspections of lifting

activities by TANAP in the field.

The IESC team has some concern that lifting activities in particular are leading to a relatively high

occurrence of reported incidents / near misses. Given that lifting of pipe is one of the most common

activities on the Project which has the potential for serious injury or fatalities, a certain level of

control and supervision of the tasks by TANAP would be expected, particularly given that lifts on the

Project are not controlled under the PTW system. TANAP reports that Lessons Learnt documents of

incidents are being shared with all lots and stations, and actions are being followed up by LOT and

Station Leads (Delivery Manager, Lot HS Lead, etc). Relevant procedures and official letters provided

and discussed with TANAP in meetings held on 12 May 2017 indicate that appropriate remedial

actions are being implemented by TANAP in relation to lifting activities.


5.4.2 Community Health and Safety

Assessment of potential community health and safety impacts of the project on communities was

articulated in the ESIA (Chapter 8.3), along with the related Community Safety, Emergency Response

and Traffic Management Plans. TANAP, and third-party monitoring contractor, CINAR, undertake

periodic monitoring of delivery of ESIA commitments and MPs. Construction Contractor MPs and

procedures are aligned with those prepared by TANAP, and the documentation reflects a mitigation

hierarchy approach. Training for MP implementation includes awareness-raising within the workforce

of interactions with the community, interactions with emergency responders, and awareness for the

community of potential project hazards.

Site-based practices vary across CCs, with evidence of differing standards of security of Project site

access and protection of communities from potential hazards (e.g. fencing, signage, accessibility of

open trenches, engagement with affected communities). TANAP reports that trench registers are

being kept for the entire route, including the barricading status of open trenches, and are being

closely followed up by the Construction and HS Teams. Additionally, the Community Relations Team

is undertaking Community Safety Awareness meetings including access to open trenches, ROW, risks

related with unauthorised site access, and construction and traffic safety with communities

throughout the pipeline route.

However, in alignment with a key construction phase project risk, there was evidence of strong

management of potential road safety impacts to both workers and communities. These included

travel management tools, vehicle controls and monitoring, and community and worker training, and

specific training with women and children to minimise public health risks due to vehicle traffic.

Emergency Response Plans have additionally been developed and approved by TANAP, including

provision for engagement and training with external emergency responders by the Project, led by

TANAP’s Security and Emergency Response departments. These plans are supplemented by mapping

of available health services along the pipeline, and address potential for community conflicts that may

occur as a result of the Project. Regular walk-overs and fly-overs of the pipeline are in place for the

construction phase of the Project to monitor potential pipeline intrusion, while building intrusion

systems are being implemented during construction for all AGIs.

Transportation of explosives for blasting of some pipeline trenches in rocky terrain areas is done

under the supervision of Gendarmerie. Blasting is done by a series of controlled explosions, and any

excess explosives are collected by the Gendarmerie. No explosives are stored on-site.

5.4.3 Infrastructure, Building and Equipment Design and Safety

TANAP has considered GIP in the design and safe operation of its infrastructure required for operation

of the pipeline. Block valves will be operated from the CSTs manned by TANAP staff. Intelligent

pigging will be conducted regularly to monitor the mechanical integrity of the pipeline. The Project

will also install and operate a SCADA (Supervisory Control and Data Acquisition) System. The pipeline

will also have leak detection systems installed along its length, with data reviewed on the SCADA

system.

Process safety and equipment safety procedural guidance has yet to be developed and will be done

prior to operations commencing.


5.4.4 Hazardous Materials Safety

The process and tools used to manage and monitor implementation of the environmental and social

compliance requirements relevant to construction Project are described within the ESMS. The ESMS

requires the development and implementation of a Pollution Prevention MP as part of the ESMPs,

which includes the management of hazardous materials and selection of chemicals required during

the Project construction to ensure compliance with ESIA commitments.

The ESMPs provide construction phase management controls to prevent impacts from Project related

activities resulting in harmful exposures or degradation of environmental values that are important in

maintaining community health. The construction phase plans include interface with stakeholder

engagement plans and recognise the need to communicate with local communities regarding

environmental performance and to respond to external stakeholder concerns. The Pollution

Prevention MP describes the control measures to be implemented by all Project delivery teams to

prevent contamination of soil and water, minimise spills risks and prevent impacts to livestock.

5.4.5 Traffic and Road Safety

Given the scale of the Project and the reliance on vehicles to access the pipeline route, vehicle and

road safety was identified as one of the biggest health and safety risks during Project construction

activities.

A specific Road Safety Management Unit was created to work within the overall HSMS. Detailed

ESMS documentation has been developed related to road safety, vehicle use and journey

management. Each driving route was risk assessed using a road risk analysis. Mitigation measures

on vehicles including GPS tracking and vehicle cameras were observed in all Project vehicles. Use of

mobile phones is prohibited when driving.

From a community perspective, evidence from community meetings concurs with Lender

requirements and GIP. This includes provision of training in project-affected communities on road and

traffic safety, commencing from the construction phase. Evidence has been sighted of training

programs with women and children, facilitated by CCs and TANAP social staff.

5.4.6 Natural Hazards

Detailed assessment and design studies were conducted for seismic risks along the pipeline route

during the ESIA. Where the pipeline crosses known active fault zones or is in high seismic risk areas,

specific designs are utilised to allow for potential shifts in the land surface to minimise stress on the

pipe and avoid tension in the case of surface displacement. Specialist international experts were

employed to design the seismic crossings. Specialised design drawings were observed during the site

inspection for these crossings. Section 8.1.3 of the ESIA also considers impacts associated with slope

instability in the design of the pipeline route.

5.4.7 Exposure to Disease

Community Safety MPs provide for communicable disease training to the workforce and engagement

with local health authorities to agree appropriate mitigation actions. Further, TANAP is conducting

Occupational Health Audits of CCs and sharing the actions officially with them. It is not clear if this

engagement on epidemiological studies has occurred to inform the CCs’ MPs, however in practice,


third party contractors are available to assist in the event of any incidences of communicable diseases

as a last response with respect to the mitigation hierarchy.

Potential effects of population influx including community exposure to disease has been minimised by

local employment practices. A local hiring plan with associated KPIs, and communications with local

communities on potential hiring opportunities, have minimised population influx. Further, documented

engagement results demonstrate variation in the demand for unskilled jobs across different Lots,

which can also influence potential for influx.

5.4.8 Emergency Preparedness and Response

Appropriate Emergency Response Plans (ERPs) have been developed by TANAP and the CCs for

construction activities. Evidence of drills against the requirements of the plans was provided. TANAP

identifies that contractors operating the construction Lots are primarily responsible for emergency

response management. This includes development and testing of site specific emergency response

plans; maintaining adequate response resources and communicating with communities.

ERPs related to operation of the pipeline are currently in development and are stated to be ready six

months prior to operation. Offshore construction ERPs including an Oil Spill Emergency Response

Plan required to manage response to vessel interactions have been drafted and TANAP plan to

complete these prior to construction in the offshore package commencing in late June 2017. TANAP

are required to have these developed and disclose these plans prior to commencement of offshore

works.



PR Ref.


4 Health and Safety

4.1 Occupational Health and Safety FC The Project has recorded 6 fatalities since its commencement, with 4 of these occurring in 2016. Detailed incident analysis of each event was undertaken. A range of corrective and preventative actions were implemented as a result of these detailed incident investigations. Particular attention was given to lifting activities on the Project and whether appropriate controls and supervision of lifting is occurring to ensure incidents are minimised. The IESC team was provided with additional information following the site audit that demonstrated that the actions resulting from major incident investigations were being adequately applied and that the incident rates due to construction activities had been reduced for the period from January to March 2017.

4.2 Community Health and Safety FC Potential impacts to Community health and safety was assessed in the ESIA chapter 8.3 (Social impact assessment – onshore) and the relevant SMPs subsequently developed: Community Safety Management Plan (Appendix 5.2)

Traffic Management Plan (Appendix 5.7). TANAP conducts periodic monitoring of implementation by CCs’ of the MPs and third party independent monitoring is additionally undertaken by CINAR. Contractors are required to develop their own procedures (pursuant to Contracts and consistent with the ESIA commitments and TANAP ESMPs), which have been submitted to TANAP and approved. MPs are consistent with the mitigation hierarchy approach and include awareness of communities to potential hazards (particularly at the construction phase), as well as preparedness of Project staff in managing potential risks. Management measures for key risks are documented in CC MPs, including: Appropriate engagement with external emergency responders (CCs’ Emergency

Response Plans) Communicable disease mitigation measures (CCs’ Community Safety MPs) Reduction of potential community-traffic interactions (CCs’ Community Safety MPs

and Traffic MPs). While TANAP provides support through its Construction, HS and CR Teams, variation between site management practices was evident between different CCs,


with varying standards of security of site access between different Lots visited. Variations included: fencing, signage, accessibility of open pits/other potential hazards, and engagement with local affected communities. Evidence was provided in community meetings that TANAP/CCs have held community safety meetings, including with women and children on trench access and road safety. The community raised concerns about road safety in ESIA consultation meetings, but no accidents involving communities were reported in community meetings attended by the audit team. The project has dedicated significant resources to minimising potential road/traffic related incidents and accidents, including travel management tools, vehicle tracking and monitoring equipment. See also s.4.6 below.

4.3 Infrastructure, Building, and Equipment Design and Safety

FC TANAP has demonstrated that safety considerations relating to Project infrastructure have been assessed appropriately.

4.4 Hazardous Materials Safety FC TANAP has considered safe use and transport of hazardous materials appropriately.

4.5 Product and Services Safety N/A Not applicable to this Project

4.6 Traffic and Road Safety FC Given the scale of the Project and the reliance on vehicles to access the pipeline route, vehicle and road safety was identified as one of the biggest health and safety risks.

Detailed ESMS documentation has been developed related to vehicle use and journey management. Mitigation measures on vehicles including GPS tracking and vehicle cameras were observed in all Project vehicles. Use of mobile phones is prohibited when driving. From a community perspective, evidence from community meetings concurs with Lender requirements and GIP. This includes provision of training in project-affected communities on road and traffic safety, commencing from the construction phase. Evidence has been sighted of training programs with women and children, facilitated by CC and TANAP social staff.

4.7 Natural Hazards FC Detailed assessment and design studies were conducted for seismic risks along the

pipeline route. Where the pipeline crosses known fault zones or is in high seismic risk areas, specific designs are utilised to allow for potential shifts in the land surface. Specialist international experts were employed to design the seismic crossings. Design drawings were observed during the site inspection. Section 8.1.3 of the ESIA also considers impacts associated with slope instability in the design of the pipeline route.


4.8 Exposure to Disease PC CCs’ Community Safety MPs make commitments to provide periodic communicable disease training to workers and training on worker interactions with community members. The Community Safety MP requires that the CCs will prepare studies on incidence of communicable diseases in affected Provinces, based on epidemiological information available, to ensure that all precautions are taken to prevent the transmission of such diseases due to the presence of workers. Engagement is required by CCs with local health authorities to agree appropriate mitigation strategies as required. This is reflected in CCs’ MPs (e.g. SYA-PLN-SOC-GEN-001, Table 4.2); it is not clear if such engagement/studies have been undertaken by all CCs. TANAP reports that it is conducting Occupational Health Audits throughout the route. One of the audit items was to understand the status of providing training for communicable diseases among the employees. The findings are being shared via official Audit Reports with related EPC/PCCs. Also, related community safety training regarding communicable disease is to be undertaken from April to June 2017 in camp affected settlements in liaison with local Health Authorities. TANAP stated during the audit that 3rd party contractors are on call for any incidences of communicable diseases, together with the Project Occupational Health doctors, whose program of work is also periodically audited. Communicable disease management is provided for occupational response, in the Medical Emergency Response Plan (see PLK-PLN-HSM-PL4-011, 13.12.2016), however this Plan does not extend to community health response to Project-induced communicable disease. Any potential effects of population influx, with the consequent potential impact of exposure to communicable diseases, were stated as being mitigated predominantly through local employment practices. A study on manpower resources requirements and availability was undertaken, in consultation with relevant stakeholders (local authorities, chambers of commerce and others) (ref: HZR-REP-SOCGEN-001, 11.12.2015). This study indicated province-specific manpower context and informed

CCs’ local hiring plans, with associated roles, responsibilities and KPIs, developed by each CC (e.g. FRN-PLN-SOC-PL1-001). Potential employment opportunities for local labour are promoted at the village level near the current construction sites, based on local hiring plans. Resulting levels of influx are low, as local potential hiring opportunities are well understood and communicated to communities according to the site-specific manpower resources.

Develop a program on the prevention and management of communicable diseases in Project-affected communities: Develop the program Terms of

Reference for EBRD approval; Implement the program as agreed,

including regular monitoring and reporting;

Share with EBRD for the Banks’ comment the plans for worker training on communicable diseases.

4.9 Emergency Preparedness and Response

PC Environmental Emergency Response Plans have been developed by construction contractors based on the requirements of the Guidelines for Contractors

Develop offshore construction ERPs and disclose information in line with


specification developed by TANAP. The Security and Emergency Response departments of TANAP have undertaken training with relevant emergency response agencies and CCs on site, initiated by TANAP. Major incidents are to be prevented and contained by security systems including pipeline intrusion inspection system, which can be operated on any station or route (this will be moved to the Main Control Centre functions during the operations phase), as documented in the Security Management Plan. Fence and Building Intrusion Detection systems are in place on all AGIs, and regular walkovers and flyovers are in place of the pipeline for the construction phase. The Environmental Emergency Response Plan, which includes oils spill response, has been drafted for the offshore construction package and is expected to be finalised prior to the commencement of the offshore construction – late June 2017.

PR 10, allowing for EBRD review of documentation prior to disclosure.

Develop operational ERPs 6 months prior to operations commencing.


5.5 PERFORMANCE REQUIREMENTS 5: LAND ACQUISITION, INVOLUNTARY RESETTLEMENT, AND ECONOMIC DISPLACEMENT

The TANAP project passes through 20 provinces and 585 settlements across Turkey, with

construction of a pipeline with a 36m wide Right of Way (ROW), above ground installations (AGIs),

access roads, powerlines, some permanent operational facilities and temporary facilities during the

construction phase.

The project will cause no physical displacement, but will require permanent and temporary land

acquisition, on both public and private land. Livelihoods impacts will predominantly be from short-

term construction impacts but will cause loss of agricultural land and crops, and common natural

resources.

A number of documents regarding resettlement have been prepared for the TANAP Project. This

commenced with the Resettlement Action Plan (RAP), which was prepared at the time of the ESIA

(Golder, 2015, GLD-PLN-LAC-GEN-003-P3-1). Following this, an Implementation Audit (carried out by

ERM in 2016) and WB due diligence investigation have been undertaken on the TANAP land

acquisition, involuntary resettlement and economic displacement activities to identify gaps in

inventory studies and against World Bank E&S safeguards policies. These resulted in the development

of the RAP for Above Ground Installations (AGIs RAP) and a RAP for the Pipeline (Pipeline RAP).

These documents present a new suite of studies, commitments, processes and documents for

development and implementation by TANAP in fulfilling international standards in land acquisition and

livelihood restoration, including filling gaps in having not completed a full socio-economic survey and

census8, or livelihood restoration mechanism. The areas covered by the additional corrective actions

identified by TANAP address: Compensation and Entitlements; Livelihood Restoration; Vulnerable

Groups; Grievance Redress Mechanism; Community Engagement and Disclosure Policy; Monitoring

Process; and Local Employment9. TANAP has made an additional 16 commitments to be taken for the

remaining implementation period including preparation of a monitoring program to ensure delivery of

the commitments against international standards.

No material non-compliances were identified as the part of the review against land acquisition,

involuntary resettlement and economic displacement criteria. The RAPs present the overall impacts,

policy and legislative framework, land acquisition process, consultations and disclosure details and

implementation arrangements, indicative implementation schedules and budgets and significant

further work has been undertaken by TANAP and Lenders to develop additional commitments to meet

international requirements in LAR.

5.5.1 Physical and Economic Displacement

TANAP has avoided physical displacement through remote preferred route corridor investigation,

application of more selective selection criteria as more detailed planning progressed in assessing and

selecting the preferred corridor, and subsequent evaluation of alternative route corridors. The Route

8 A full census was not carried out for the pipeline. Instead, a representative socioeconomic survey was conducted with 876 Project affected households, in-depth interviews with 132 village headmen and focus group discussions with 16 different women’s groups. 9 The corrective actions are summarized in Table 24: Summary of Corrective Actions of the Pipeline RAP (pp. 48)


has been frozen at Route H (i.e. ESMPs were developed according to this alignment). Additional

baseline studies have been undertaken to avoid key features (e.g. archaeological sites, homes, critical

habitat) with successive alignment changes, such that the current alignment is Route J. An E&S

checklist is used to determine whether desktop or field studies are required.

Four different land types are required: 49-year unrestricted and exclusive rights (16m pipeline

corridor); temporary (3year) easement rights (20m pipeline corridor); permanent ownership rights

(AGIs, access roads, poles); and 5-year contractual (rental agreement) rights for temporary facilities

such as camps. BOTAS as the land rights entity (LRE) is carrying out management and execution of

all land acquisition, in accordance to national requirements, project standards and international

policies, monitored by TANAP. The pipeline requires acquisition of 6,340ha (2,307ha of public land

and 4,032ha of private land), while 263ha of land was acquired permanently for AGIs, across 578

land parcels (79% privately owned) and impacting 936 Project Affected Persons (PAPs). AGIs for the

TANAP project include 7 compressor stations, 4 Metering stations, 11 Pig Launcher and receiver

facilities, 49 Block Valve Stations (BVS), and 2 Off-Take points.

Route realignment has been carried out during the construction phase in accordance with the re-

routing procedure to manage deviations that are required from the ESIA approved alignment. Site

surveys are undertaken by an assessment with TANAP, the CC and survey team for TANAP final

approval prior to route change implementation, including consultation with relevant stakeholders. The

process is described for community engagement in the Guide to Land Acquisition and Compensation

(currently being updated). A third-party consultant, consisting of three senior experts and one junior

expert has been engaged to conduct monitoring of PR 5 related issues (CINAR is the third-party

monitoring consultant for all other areas, excluding PR5 related issues).

TANAP has committed to follow international and national policies on LA, and in the event of a

conflict in interpretation, the international standards (World Bank OP4.12) will prevail.

5.5.2 Consultation

Consultation is required with the land owners, tenants, users, squatters, encroachers and those who

will/are experiencing loss of grazing, forest and community lands and severance/fragmentation of

lands. BOTAS is the government entity responsible for carrying out land acquisition and expropriation

on behalf of the TANAP project, including identifying, engaging with some 97,000 landowners, with

TANAP. Good working relationships were evident during the audit between BOTAS and TANAP.

Consultations commenced during Project planning phase activities, with 80 meetings with Project

affected settlements in September 2014 including distribution of the Guide to Land Access and

Resettlement (GLAC). Subsequent consultation has been undertaken by BOTAS, TANAP and CCs,

from 2014 to the present, including: Information meetings prior to negotiations/gathering sample

census data; 2 rounds of negotiation meetings; crop determination studies/meetings; preconstruction

information meetings; and land entry meetings. Advance notice/information is provided to PAPs prior

to discussions/negotiations and legal advisors present during negotiation meetings to advise on

procedural matters. Land entry meetings are held only after compensation has been paid to the

relevant landowner(s) or into an escrow account. CCs’ Community Liaison Officers (CLOs) maintain

continuous relations with PAPs and TANAP field staff maintain continuous relations with other


stakeholders according to the RAP, and TANAP field staff providing monitoring and support in RAP

consultation and engagement to CLOs. Consultation processes provide for greater participation of

women and vulnerable groups through targeted meetings, in addition to wider village-level meetings.

Engagement as well as grievances is tracked through OSID, with data collected for TANAP and all

CCs. The Corrective Actions presented by TANAP in the Pipeline RAP additionally provides for

identification of and support to vulnerable groups.

TANAP acknowledges in the RAP for the Pipeline that the cut-off date identified in the initial RAP was

not applied in practice, as the construction commenced in advance of the original schedule and the

identification of PAPs and their assets inventory had not been completed, as is required by

international standards. However, in line with the concept of multiple cut-off dates across the

different provinces, BOTAS is applying the following approach in line with the Pipeline RAP

specifications:

• For land and other assets; the cut-off date was determined as “the day before negotiations”

(noting that BOTAS branch office representatives announced information regarding the cut

off dates and distributed the GLAC during the village consultations prior to negotiations); and

• For standing crops; the cut-off date was determined as “the day of the determination of

users” after Article 27 was put into force.

While the original approach was not in compliance with GIP, BOTAS has committed to evaluating and

compensating every additional claim and justified complaint (i.e. in line with eligibility requirements)

including those that fall after the cut-off date, which is considered a practicable approach to this

requirement (ref: Pipeline RAP s.2.34).

TANAP also acknowledges that a full socioeconomic census was not conducted (Ref: Pipeline RAP s.

2.102), rather, a sample survey was undertaken that did not allow for a full census or identification of

vulnerable households. TANAP has committed to carrying out a retrospective study to inform all

eligible PAPs and compensate these PAPs who have not yet been compensated under the new

Entitlements Matrix, to be undertaken with the development and disclosure of the public brochure

describing the RAP Fund and its management. Further, in absence of one to date, TANAP commits to

developing a Livelihood Restoration Plan to address livelihoods impacts of the Project. This should

address PAPs, and as per s.5.5.3 below, also specifically respond to whether undue hardship has

been caused through the expropriation process. Note this will allow for an additional layer of analysis

to the commitment to investigate and provide support for vulnerable groups, as identified in the

Corrective Actions summary (Table 24, RAP for Pipeline).

Consultation identified community concerns related to the themes:

• Limited access to agricultural land thus direct impact on agricultural production and livelihood

reduction

• Limited access to grazing land thus impacting livestock activities

• Damages to crops during construction

• Health risks due to leakages


• Damage to land quality, poor reinstatement of previous projects,

• Perception of pipeline existence affecting the value of land; and

• Damages to existing infrastructure.

Consultation and information disclosure has been undertaken providing details of project activities,

timelines and responsibilities of various parties in land acquisition (LA), including distribution of the

Guide to Land Acquisition and Compensation (GLAC). The IESC notes that the corrective actions

identified in the RAP include additional engagement and disclosure actions to strengthen the Project’s

response and management of these identified issues. The RAP Fund Management Procedure has

been drafted and defines the process for implementing the RAP Fund to entitled PAPs (i.e. the

mechanism for ensuring those eligible under the revised Entitlements Matrix are identified and

compensated accordingly). Further, a new brochure is being prepared for those who are entitled to

RAP Fund compensation in line with the revised Entitlements Matrix for a widespread disclosure of

RAP Fund components and entitlements to facilitate information disclosure to PAPs in detail about

eligibility, entitlements and processes. This brochure is being delivered to eligible households and

affected communities, commencing April 2017. In parallel, internal training on international Lender

requirements has been scheduled or undertaken with all LOTS to ensure consultation and

engagement with PAPs is in line with the requirements. Lastly a stakeholder engagement plan specific

to the disclosure and engagement process on the revised entitlements matrix is yet to be complete.

This engagement plan should ensure that TANAP is proactively identifying potentially eligible

households. For disclosure of and engagement on RAP Implementation, TANAP advise that an Annex-

2 to the existing SEP is the preferred method, rather than developing a new plan of engagement

specific to RAP Implementation. This is intended to minimise confusion by making the documentation

as simple and user-friendly as possible.

5.5.3 Compensation

TANAP has described the LA process (including, broadly, identifying the corridor,

landowner/landowner shareholders, negotiation and agreement with landowners or expropriation

process). LA compensation is: (a) cash compensation for private land acquisition; (b) other assistance

through implementation of livelihood restoration plans (c) RAP Fund assistance for PAPs (informal

users or settlers not covered by Turkish legal requirements); (d) entry costs and leases for the

forestry lands. As at August 2016, approximately 5,450 formal land users have been identified (to be

compensated through BOTAS) and 324 informal users to be compensated through the RAP Fund,

administered by TANAP, as BOTAS cannot acquire land from or compensate these categories that fall

outside the Turkish legal framework. PAPs in categories eligible to receive compensation from the

RAP Fund are defined in the Entitlement Matrix in the AGIs and Pipeline RAPs. A RAP Fund

Management Procedure focusing on RAP Fund strategy and implementation principles has been

drafted and is currently being delivered to Project-affected settlements and PAPs, along with the new

GLAC (Guide to Land Acquisition). The RAP Fund Evaluation Committee has additionally been

established.

Permanent land acquisition is required for approximately 260ha for the AGIs, while approximately

6,600ha is required for a temporary period of 3 years (easement land for the construction corridor, or


unrestricted access for the ROW). This land is to be returned to owners after construction, with some

restrictions on agriculture / buildings in easement areas.

Eligibility criteria for AGIs are defined and include provision for support to vulnerable groups. TANAP

has committed to provide additional support from this fund for economic losses of producers that

earn income from agricultural activities carried out on private or public lands affected by permanent

acquisition of land for AGIs, and to compensate such losses by allowing producers to benefit from

activities to be determined within the scope of Livelihood Restoration Program. Field studies for the

preparation of LRP for AGIs, focusing on AGI-based vulnerable groups, were completed in April 2017

and the following Livelihood Restoration Program is to be drafted by the end of June 2017. Types of

support will depend on the settlement impacted, but may include priority for employment during

Project construction, agricultural support, support to livestock production, intensive farming support,

irrigation support, alternative income generation, trainings and capacity building.

Payments to be made were initially developed to meet Turkish national expropriation requirements,

however additional entitlements have been included to meet WB OP 4.12 requirements (transaction

costs, transitional payments, support to vulnerable households, and compensation for unviable land

parcels). In some areas, this is to be applied retrospectively (for example, 100% of ROW activity has

been completed in Lot 1). A retrospective study is being undertaken (due for completion in July 2017)

to identify and compensate PAPs who have not been compensated yet under this change in

Entitlements Matrix (ref: Summary of Corrective Actions). Further, TANAP will explicitly allow for full

replacement cost for all assets and will ensure that lost income is fully restored through the

compensation process.

The Guide to Land Acquisition and Compensation (GLAC) was developed in 2014 to inform

landowners about the process for land acquisition, including the grievance mechanism, rights, and the

Land entry protocols in place to ensure land parcels are not able to be accessed by CCs without

compensation payments having been received by land owners. In addition, TANAP has developed a

brochure as a supplementary document to GLAC-2014 to explain new entitlements and eligibility

requirements as per the new Entitlements Matrix (as referenced in the above), as well as new

grievance mechanism information such as the Appeals Committee process (i.e. as per Pipeline RAP).

This new brochure developed for disclosure focuses on the frequently asked questions related to land

acquisition, and additional RAP Fund items, together with the revised / improved Entitlements Matrix.

The procedure for demonstrating avoidance of expropriation appears to be a gap. While TANAP’s LA

process allows for negotiation with landowners, 67% of agreements are not amicable and trigger the

expropriation process, which does not meet with GIP and suggests the process of determining and

compensating landowners is rushed, in addition to absentee owners or other factors, resulting in

significant expropriation by international standards. While acknowledging that the pipeline

component of the project is linear, temporary and land acquisition has been completed, it should be

clear to TANAP that the expropriation process has not caused undue hardship to those losing access

to their resources, and thus the interviews and community-level meetings planned with disclosure of

the new RAP Fund brochure are key to ensuring proactive identification of potentially eligible PAPs.


5.5.4 Grievance Mechanism

The grievance mechanism in place for the land acquisition process is the same integrated system as

per the Stakeholder Engagement Plan (the Online Stakeholder Information Database, OSID).

Complaints and requests can be lodged online, by phone, in person or with CLOs/TANAP Social

Specialists and via Muhtars. Complaints can be lodged anonymously or complainants can identify

themselves.

All PAPs are provided with general information about the Project and specific information regarding

the LA activities, through meetings and engagement activities, as well as receiving disclosure

information such as the GLAC. The GLAC also describes the grievance process, including ways in

which grievances can be raised and the process and timelines for resolution. A quarter of all

complaints across all Lots received to date relate to damage to land (see also PR10).

Appeals Committees have been established for each Lot in January 2017 with notification at the

community level from February 2017. These will provide for third party consideration of grievances

that cannot be agreed between TANAP and the complainant. Appeals Committees were established in

January 2017 for each Lot and are being announced via posters at settlement level in addition to

public disclosure on the TANAP website and supported by documentation including the SEP,

Grievance Procedure and an Appeals Committee Application Form. Currently, no complaints have

been escalated to Appeals Committees. The SEP was updated to reflect their formation, and

disclosed via new brochure being prepared to announce RAP Fund and Appeals Committee as a part

of TANAP’s Grievance Mechanism as of April 2017. Further, incorporating additional grievance

categories into OSID will now to allow for deeper analysis and better responsiveness to issues raised

by PAPs.

CCs have a maintenance period of one year, which will include the period for testing success of

reinstatement of land. This is to be completed to the satisfaction of TANAP, and losses of income due

to the failure of reinstatement are anticipated in the payments to landowners. Landowners are

additionally able to raise a grievance following the Land Exit process. For example, if grievances

relate to satisfaction of reinstatement and this falls during the maintenance period, this will fall under

the jurisdiction of the CC to rectify, otherwise this will be responded to as per the grievance

mechanism. According to TANAP, post-maintenance period land reinstatement rectification for the 2

years after reinstatement is the responsibility of the associated construction contractors as per their

contracts. ; the guidance on the Fund’s operation is yet to be developed and is anticipated for

completion by June 2017. Depreciation of land value is factored in to the valuation of land parcels

during the negotiation process (payments are between 70-90% of easement value, depending on the

type of land, and productivity losses are calculated as 30% for year 1, 20% loss for year 2 and 10%

loss for year three, added to the land value.)

It can be anticipated that there may be issues regarding reinstatement success due to soil storage

practices (see PR 6) hence the need to ensure the guidance provides clarity that this reinstatement

will be provided for and grievances redress actions taken, whether financed through the RAP Fund or

elsewhere, and an assessment that the productivity loss factors are accurate and sufficient to cover

real losses experienced in practice. See also Section 5.5.6 and 5.5.7. It is noted that Reinstatement

has been included as a new category in OSID to enable tracking of this issue.


5.5.5 RAP/LRP Documentation

The Project RAP (GLD-PLN-LAC-GEN-003-P3-1) was developed with a focus primarily on meeting

Turkish legal requirements and international standards, without IFI involvement. Additional

documentation has been developed and publicly disclosed, including the RAP for the Pipeline (relating

to temporary land acquisition, TNP-PLN-SOC-GEN-006-P3-0), and the RAP for AGIs (relating to

permanent land acquisition, TNP-PLN-SOC-GEN-008-P3-0). A Guide to Land Acquisition and

Compensation (GLAC) has been developed and disclosed that outlines the process of LA for owners

and non-legal land users and other stakeholders. These documents have all been publicly disclosed

on TANAP’s website.

Gaps in meeting international requirements have been identified and plans are in place to address

these, as publicly disclosed commitments in the Summary of Corrective Actions (Addendum to the

Pipeline RAP) for development and implementation of a Livelihood Restoration Plan (LRP) for the AGIs

,, focusing on AGI-affected vulnerable groups, and an LRP for Offshore Fishermen. Some of the

livelihood restoration activities are to be supported through the RAP Fund (e.g. squatters, informal

land users and vulnerable households). The LRP documentation reflects onshore and offshore

impacts; the Draft Fisheries LRP was disclosed to fishermen at two impacted settlements (Kemer &

Aksaz villages) from April 2017 and the LRP has been finalised with the inputs from disclosure and

other Lenders. The field studies for the preparation of the LRP for AGIs, focusing on AGI-based

vulnerable groups, were completed in April 2017, with the LRP to be drafted by the end of June 2017.

There have been some crop payments made from the RAP Fund already, in absence of the RAP Fund

guidance (e.g. small costs in transporting landowners to meetings during the land acquisition

process); these payments will need to be reconciled and audited by a third party (the RAP External

Monitoring Team).

5.5.6 RAP/LRP Implementation

The Pipeline RAP identifies measures to strengthen remaining implementation (RAP s.4). These

include conduct of additional studies are required to be undertaken by TANAP to fill gaps between

existing RAP implementation and as a result of expansion to the Entitlements Matrix. This includes

determining which categories of PAPs are now eligible for compensation, and confirms which have

and have not already been compensated. The AGI and Pipeline RAPs identify that some of this work

will be undertaken retrospectively as land acquisition is already finalised or commenced (i.e. only in

Lot 4 will these new RAP measures be possible to initiate from commencement of implementation in

that Lot).

TANAP commissioned a study to identify possible livelihood impacts on fishery communities near

Marmara Sea in order to develop a mitigation approach and Livelihood Restoration Plan appropriate

to the impact of the Project on fisher livelihoods. The IESC notes that completion and commencement

of implementation of this Plan is on track to commence in advance of early works and exclusion of

fisherfolk from the fishing areas. TANAP and the Offshore CC are, at May 2016, preparing for

stakeholder engagement and LRP implementation.

The Specification for Reinstatement (WRP–SPC-EGG-PLG-001) guides CCs on development,

management and implementation of reinstatement plans to ensure the ROW is restored to a form


suitable for future use. This requires that method statements be prepared which consider the specific

environment in which reinstatement is to be undertaken, and that the CC undertakes monitoring, and

if necessary, repair, to achieve ecological and biological restoration as agreed with the landowner.

This includes for example; the land is to be made ready for re-planting with crops in arable areas and

there is a contract maintenance period during which biorestoration measures must be maintained by

the CC. The grievance management system is referenced, providing additional protections for PAPs.

Land acquisition for AGI has commenced for 349 of the 458 parcels impacted by the Project, and A

Socio-economic field study conducted during July-August 2016 with 182 PAPs impacted by

Compressor Stations and Metering Stations. Engagement identified the key findings that PAPs do not

clearly distinguish land acquisition between the pipeline compared to the AGIs, that most do not use

the grievance mechanism and that PAPs do not distinguish between TANAP, BOTAS or CCs on site,

rather, the Project is viewed as a single entity. IESC notes that TANAP is addressing these

shortcomings; AGI-specific disclosure to respond to all concerns raised by PAPs (including Project

information, grievance mechanism, compensation strategy, employment opportunities, subcontractors

and Project details regarding implementation) are currently being implemented. The AGIs land

census survey was completed with 1008 PAPs in 265 households, and according to PAP declaration,

almost half of the households lost less than 20 percent of their total land holdings due to permanent

land take resulted from MS and CS specific AGIs. The IESC notes that the LRP for PAPs whom have

been subjected to a loss of livelihood are to be compensated through the AGI LRP now under

development.

5.5.7 Monitoring

The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators,

implementation schedule, and budget. These RAPs will be subject to IESC/independent monitoring

and review throughout implementation in accordance with GIP and EBRD PR 5 requirements.

TANAP reports that the Final RAP Monitoring Plan has been prepared and approved by TANAP (and

the World Bank) and an independent expert contracted for RAP External Monitoring. This Team

commenced External Monitoring in April 2017 and their 1st Semi-Annual Report will be submitted in

June 2017. The 1st RAP Quarterly Internal Monitoring Report has been prepared, and is now also

available for input to the RAP External Monitoring Team review/assessment.

TANAP has committed that the monitoring process for the Project is to be immediately implemented,

and it is to be closely linked to the grievance mechanism to provide a feedback loop. Internal

monitoring processes, key indicators (input, output, process, outcome and impact, see RAP s8.8) are

to be monitored through regular internal progress reports. The IESC notes that specific indicators will

apply to BOTAS and TANAP. This RAP Monitoring plan has been reviewed by the IESC.

Internal and external monitoring activities will be further defined in line with RAP commitments, and

includes TANAP internal performance monitoring, external experts/consultants undertaking impact

monitoring, and TANAP and external consultants conducting the RAP Completion audit. Further,

TANAP has committed to undertaking an end term impact evaluation by an independent firm, one

year following substantial RAP implementation, to evaluate the outcomes of compensation and

assistance impact on project affected people to improve their living standards. This report is to be


commissioned to document whether RAP/LRP provisions have been met, with a corrective action

identified to close out any outstanding TANAP obligations for compensation, livelihood restoration and

development benefits. The IESC notes that internal monitoring should inform the date of the

completion of the impact evaluation as the specification of one year following implementation may

not be appropriate to be able to see impacts on longer term livelihoods programs on PAPs.



PR Ref.


5 Land Acquisition, Involuntary Resettlement, and Economic Displacement

5.1 Avoid or minimise displacement FC Full compliance was observed in relation to avoidance or minimisation

of displacement, with no physical resettlement required over the length of the pipeline or at AGIs. Route realignment has been carried out during the construction phase to manage deviations from the ESIA approved alignment, in accordance with Project procedures and the Guide to Land Acquisition and Compensation (GLAC), developed for stakeholders. The pipeline requires temporary (3-year) acquisition of 6,340ha, while 263ha of land was acquired permanently for AGIs, across 578 land parcels and 936 Project Affected Persons (PAPs).

5.2 Consultation PC Consultation with stakeholders is undertaken by TANAP as the Project owner, CCs’ through site-based community liaison officers, and BOTAS, as the entity responsible for land acquisition, requiring

identification and engagement with approximately 97,000 landowners. Consultation commenced during the Project planning phase, and has since additionally included engagement specifically on: Information meetings prior to negotiations/census data gathering; 2 rounds of negotiation meetings; crop determination studies/meetings; preconstruction information meetings; and land entry meetings. Land exit meetings will also be undertaken following reinstatement (approximately 3 years after land entry). Consultation processes provide for engagement with vulnerable groups including women, and overall, the IESC notes that the corrective actions identified in the RAP include additional engagement and disclosure actions to

strengthen the Project’s responsiveness to stakeholders’ issues. The Cut-off date from the original RAP could not be met, and BOTAS has developed a practicable approach to evaluate and compensate every additional claim and justified complaint even after the cut-off date. TANAP should ensure that this commitment is met through its monitoring and auditing processes.

RAP Fund Management: (a) Provide EBRD the stakeholder engagement

plan, Annex 2 on RAP Implementation),

including specific provisions for engagement with vulnerable households.

5.3 Compensation for displaced persons PC Permanent land acquisition is required for approximately 260ha for


PR Ref.


the AGIs, while approximately 6,600ha is required for a temporary period of 3 years (easement land for the construction corridor, or unrestricted access for the ROW). This land is to be returned to owners after construction, with some restrictions on agriculture / buildings in easement areas. TANAP is commissioning a retrospective

study (due for completion in July 2017) to identify and compensate PAPs who have not been yet been compensated under the new Entitlements Matrix framework (ref: Summary of Corrective Actions). Further, TANAP has committed to providing for full replacement cost for all assets and will ensure that lost income is fully restored through the compensation process.

5.4 Grievance mechanism PC There is a grievance mechanism in place. The same system for stakeholder engagement is also applied to grievance management (the Online Stakeholder Information Database, OSID). TANAP has made commitments to strengthen this mechanism including through establishment of an Appeals Committee and strengthened disclosure of summary grievance information to stakeholders.

Disclosure to communities of summary grievance data and measures taken by TANAP and CCs to address the common causes of grievances, in line with recommendations made in 10.2.

Provide a copy of Appeals Committee

documentation to EBRD including Terms of Reference and publicly disclosed information regarding the Committees

5.5 RAP/LRP documentation PC TANAP has committed to development of a range of new RAP documents, documented in the Summary of Corrective Actions in the Pipeline RAP. These include the Livelihood Restoration Plan (LRP), RAP Fund guidance and documentation. The RAP Fund intends to fill the gap between payments that can be provided for by BOTAS (as the national responsible agency) and international requirements managed and implemented by TANAP. Some payments are reported to have already been made from the RAP Fund, and for transparency these

should be reconciled following approval of guidance on implementation of the Fund. RAP Fund Management Procedure has been drafted and disclosure with PAPs commenced. LRPs are the AGI-affected resettlement (currently under development) and the Offshore Fisheries LRP (completed).

Livelihood Restoration Program (LRP): (a) Provide for EBRD comment the LRP for

AGI-affected settlement prior to the Plan’s disclosure;

(b) Provide a copy of the completed Offshore Fisheries LRP to EBRD.

5.6 RAP/LRP implementation PC The Pipeline RAP additionally identifies measures to strengthen See 5.5.


PR Ref.


ongoing implementation of the RAP. This includes a study to investigate potential impacts to fisherfolk in the Sea of Marmara and thereafter develop an appropriate Livelihood Restoration Plan. The study has been carried out, (i.e. with adequate time to investigate, plan and respond, in advance of any impacts occurring). Similarly, the

AGI RAP provides for the development of an LRP to PAPs who have experienced a permanent loss of livelihoods. Mitigation measures are yet to be developed and will differ from those who experience temporary loss, which should be clearly managed and communicated to stakeholders.

5.7 Monitoring PC The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators, implementation schedule, and budget. These RAPs would be subject to IESC/independent monitoring and review throughout implementation in accordance with GIP. Both internal and external monitoring have commenced, with the 1st Quarterly Internal Monitoring Report (March 31, 2017) reviewed by the IESC in May 2017. TANAP has contracted independent experts for RAP External Monitoring and will produce their 1st Semi-Annual External Monitoring Report in June 2017.A site visit and investigation by the RAP External Monitoring Team was completed as of May 5, 2017. This monitoring, will, in turn, inform the Impact Evaluation at the conclusion of the LA and livelihood restoration program.

RAP Monitoring: Provide to EBRD a copy of the Internal

Monitoring Report(which includes monitoring of the RAP Fund, and implementation of the Corrective Actions Register);

Provide to EBRD the results of external regular monitoring of the RAP, including payments

from the RAP Fund.


5.6 PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL RESOURCES

The TANAP Project presents significant challenges to ensuring that potential biodiversity impacts are

effectively managed. The construction of the 1787 km underground pipeline and an 18km subsea

crossing through the Sea of Marmara, including all aboveground support facilities, involves direct

disturbance within the pipeline Right of Way (RoW) corridor through numerous ecological regions and

habitat types including terrestrial, fresh water and marine habitats. Linear construction projects of

this nature require extensive broad range data gathering to effectively characterise the biodiversity

values likely to be affected. Biodiversity management measures applied during construction are

required to be site specific to reflect the range of landscapes and habitat types encountered. These

biodiversity protection measures are therefore non-standard and require intensive management to

ensure effective outcomes.

The IESC recognise that the application of impact assessment methodology and various standards for

characterising the significance of biodiversity values for large scale linear projects requires some

modification from that which would be applied for projects that have limited geographical extent.

The consideration of area of influence and the temporal extent of likely impacts is significant in

assessment of biodiversity issues for the TANAP project and the extent to which the Project can

achieve its stated objectives for protection of biodiversity.

The TANAP Project has developed extensive documentation for baseline studies, impact assessment

and biodiversity management and monitoring. The extent of documentation reflects the diversity of

ecological regions and habitat types and the need for biodiversity management measures to be fit for

purpose. The Biodiversity Action Plan (BAP) has been developed and was being implemented at the

time of the IESC site visit and the effectiveness of these measures was observed at a sample of work

sites, including those where critical habitat had been identified.

The biodiversity assessments and studies have been completed in consideration of the IFC 2012

Performance Standards and with specific reference to Performance Standard 6: Biodiversity

Conservation and Sustainable Natural Resource Management of Living Natural Resources. In addition,

key international guidelines and standards referenced in the ESIA relevant to biodiversity

management include:

• International Union for Conservation of Nature (IUCN) Red Book (RDB) for protected species;

• Action Plan for the conservation of marine vegetation in the Mediterranean Sea (1999);

• Strategic Action Programme for the conservation of Biological Diversity (SAPO BIO) on the

Mediterranean Region (2003);

• Priority habitats according to the SAP/BIO Protocol (Barcelona Convention) (1999);

• Biodiversity in Impact Assessment Background Document to Decision VIII/28 of the

Convention on Biological Diversity – CBD Technical Series No. 26;

• The Action Plan for the conservation of Mediterranean Marine Turtles (UNEP-MAP);

• European Directive 2009/147/EEC The Birds Directive; and


• 92/43/EEC Council Directive on the conservation of natural habitats and of wild fauna and

flora.

5.6.1 Assessment of Biodiversity and Living Natural Resources

Baseline Studies:

Baseline studies for the initial ESIA report were completed between February 2013 and March 2014.

The individual component studies did not extend throughout this period but were scheduled, for

various lengths of time, within this period. The studies were completed by Çinar Engineering who sub

contracted a range of specialist experts from various national academic and research institutions. The

baseline studies included desktop studies, aimed at collection and analysis of existing relevant

bibliographic data for all the valued environmental components (VEC’s), as identified through ESIA

scoping, and included field studies aimed at collection of field data for selected VECs, filling

knowledge gaps and verification of the desktop study results. Field surveys for the ESIA were

completed by Çinar using a defined survey methodology developed by Golder Associates who were

engaged by TANAP to assist in guiding the ESIA compliance with international standards including IFC

and EBRD requirements. A review of the baseline methodology found that the component field

studies had been undertaken using representative sampling that appears to be representative of the

project AoI. These field studies were undertaken selectively within the 500m wide Local Study Area

(LSA) for the ESIA followed by a more focussed field surveys within the 36-70m wide Right of Way

(RoW) to support the Biodiversity Action Plan (BAP). The IESC notes that the initial ESIA flora studies

were limited in duration to only one flowering season and that the flowering season in eastern and

western Turkey varies considerably. These deficiencies were somewhat addressed through the

further BAP studies undertaken between August and October 2014 that was focussed on identification

or priority species within the Pipeline Right of Way ROW (which ranges from 36 to 70 m in width).

A Baseline LSA was defined based on the likely AoI in which direct or indirect impacts to VECs could

occur. The LSA considers a 500m wide route corridor for the onshore pipeline and 100m wide for the

offshore component. A Regional Study Area (RSA) was also defined through the ESIA to allow impact

significance assessments, including identification of priority biodiversity features and critical habitat.

The RSA included terrestrial flora and fauna and habitats through Eco-regional data, and protected

areas within 5km of the TANAP route. There were 20 RSA provinces covered through the baseline

study that capture a vast array of ecoregions across the extent of Turkey. The RSA and LSA were

mainly assessed through desktop study while the AoI was assessed through field study.

The scale and linear nature of the Project presented some significant issues in collection of sufficient

baseline data required to undertake a comprehensive habitat assessment. The ESIA mapped the

EUNIS habitat types along the full pipeline route and identified 30 different Level 3 habitat types

along the route. The IESC notes that the ESIA did not establish a discrete management unit (DMU),

which is essential for the quantitative evaluation of the proportion of the global population occurring

within it. The ESIA concedes that the baseline data gathering was insufficient to delineate habitats

distribution around the LSA and the absence of population data from the baseline studies resulted in

the LSA being used as the spatial unit of analysis and critical habitat being only identified and mapped

at the LSA scale (500m from the Project footprint). The ESIA does recognise this deficiency and


states that “it would be appropriate to conduct in-depth critical habitat assessments for the Project if

data become available for identifying the appropriate DMU’s”. The critical habitat assessment in the

ESIA was unable to assess against the quantitative thresholds set in Criteria 1 to 3 as a DMU was not

determined and therefore the assessment does not follow Guidance Note 65 of IFC PS6. As a result of

this, the ESIA applied conservative critical habitat assessment to define:

• Confirmed critical habitat – where species under Criteria 1 to 3 were observed and therefore

the entire patch of EUNIS Level 3 Habitat relevant to that species within the LSA was

determined to be critical habitat.

• Potential Critical habitat – where species under Criteria 1 to 3 were identified to be potentially

present and /or the habitats might contain unique evolutionary processes and/or high

biodiversity values (Criteria 4 and 5).

The baseline survey biodiversity studies included:

• Marine Fauna Baseline Report - containing data gathered from field observations, materials

collected, literature screening and personal interviews for a 2km wide buffer zone within the

local study area along the section of pipeline through the Sea of Marmara;

• Marine Flora Baseline Report – including data gathered form field observations, collected

materials and literature reviews for the local study area associated with the subsea pipeline

corridor;

• Marine Biodiversity Baseline Report – includes the findings and analysis obtained from the

marine flora and fauna reports along with literature review to characterise the biodiversity of

the local and regional study areas;

• Marine Habitats and Ecosystems Baseline Report – focussed on a 500m wide subsea pipeline

corridor route for the local study area and a 100m wide regional study area to identify habitat

types and assess the potential for critical and priority habitats;

• Terrestrial Fauna Baseline Report – includes both desktop and field studies (May and July

2013) with field studies prioritised to confirm presence and distribution of fauna within

natural and critical habitat areas of the LSA and to identify priority species and habitats.

• Terrestrial Flora Baseline Report - Terrestrial flora field data was collected in May to July of

2013, being only one flowering season, to confirm the presence and distribution of terrestrial

flora species particularly within Natural and Critical habitat areas of the LSA (500 m corridor),

and determine the presence of endemic, restricted-range, critically endangered and

endangered flora species in the LSA.

• Terrestrial Protected Areas Baseline Report - identified protected areas present in the LSA

(500m corridor) and Regional Survey Area (RSA) (within 5km of the LSA) and identify where

impacts may be predicted.


• Terrestrial Biodiversity Baseline Report – collected field data and documented information on

the biodiversity characteristics of the RSA with respect to ecological values and characterised

the biodiversity values, including potential for critical habitats, within the LSA and relevant

nearby locations where impacts are predicted.

• Terrestrial Habitats and Ecosystems Baseline Report – included ground truthing of European

Nature Information System (EUNIS) level 3 habitat classification map and acquire data

regarding the status if habitats of conservation importance.

• Freshwater Fauna Baseline Report – included desktop and field studies, June-July 2013 and

September-November 2013) at 200 sampling stations to confirm the presence of fish species

within rivers subject to pipeline crossings and determine presence of endemic, restricted

range, critically endangered and endangered fish species for habitat assessments.

• Freshwater Flora Baseline Report – included desktop and field surveys conducted during key

flowering periods (May to June for the western sectors and July to August for the eastern

Turkey section), to determine distribution and presence of flora species in the LSA and to

determine priority species and allow the assessment of critical habitats.

• Freshwater Habitats and Ecosystems Baseline Report - was completed for freshwater habitats

within the LSA to confirm the distribution of habitats defined at a desktop level using the

EUNIS standardised habitat system, and also to acquire recent data regarding conservation

status and significance using National and international data and criteria.

• Ecosystem Assessment of TANAP corridor through Posof Wildlife Development Area – was

undertaken by a multi-disciplinary team of National scientific specialists in July 2013 to

undertake an ecological assessment of a range of protected areas within the WDA that are

likely to be affected by the TANAP LSA.

The baseline studies undertaken for the ESIA were sufficient to allow the scoping of critical habitat

(PR6 paragraph 6) but are not sufficiently detailed to allow for a critical habitat assessment in

accordance with PR6 paragraphs 7-9.

The European Nature Information System (EUNIS) habitat criteria appeared to provide a useful tool

for desktop studies and impact assessment of biodiversity values within the study areas (RSA, LOA

and AoI).

Community engagement undertaken for the ESIA included a range of surveys that include questions

regarding the presence of conservation significant species within the Project AoI and request for

information regarding community use of natural ecosystems including hunting, collection, bee

keeping and livestock grazing. This social data was used to supplement biodiversity baseline where

relevant.

Additional BAP Studies and Surveys

Further field and desktop biodiversity studies were undertaken by Cinar from August to October 2014

as part of the Biodiversity Action Plan (BAP) development. The BAP has been subject to a number of

revisions, the latest being the version Rev-P3-10 issued in May 2017. The BAP studies were required

to address data gaps identified in the ESIA studies, as described below, accommodate route changes


that had occurred and to revise the critical habitat assessment completed for the ESIA. The BAP

ecological surveys were targeted towards the presence of ecological sensitive species and habitats

along the RoW, between 36m and 70 m in width.

BAP ecological field surveys focused on potential impacts within and along and immediately adjacent

to the ROW (36-70m) and used the ESIA as a macro perspective of the ROW surroundings.

The BAP objective is to protect and conserve the biodiversity within the 36m ROW during the

construction, operation and decommissioning phases of the project. The BAP identifies species and

habitats of significance with the aim of developing area specific actions. The BAP objectives include

the identification and management of critical habitat in line with IFC Performance Standard 6 and the

requirements of the Turkish National Biodiversity Strategy and Action Plan.

The BAP re-evaluated the baseline surveys carried out in the ESIA studies. This re-evaluation

included:

• The findings of the ESIA baseline studies within the 500m LSA were re-assessed for the 36 m

ROW;

• Verification and re-evaluation of Species of Conservation Concern;

• Field studies for considered species and habitats were planned; and

• Intersections between the ROW and protected areas or high biodiversity areas were

reviewed.

The BAP, including the re-evaluation of critical habitat, was undertaken by Çinar by relevant subject

matter national specialists. The Critical Habitat assessment methodology was developed in

consultation with other Project lenders and recognised the lack of identified Discrete Management

Unit and the species level data limitations for the 500m wide corridor.

Impact Assessment

The ESIA baseline data was used to define the sensitivity of the various VEC’s to identify likely

impacts associated with the project and to define the pre- project condition that will be used as a

benchmark to detect changes during monitoring. VECs were assigned sensitivity levels based on a

range of factors including current quality of the component and susceptibility to environmental

changes. Those impact factors most relevant to biodiversity impacts were identified as:

• Reduction in topsoil quality/availability;

• Site restoration;

• Sediment suspension;

• Removal of natural vegetation; and

• Introduction of alien species.

The impact assessment methodology for biodiversity assigned impact factor intensity based on

assumed standard mitigations being applied in accordance with good industry practice, so impact

factors are measured only after mitigation. The impact assessment methodology was based on that


provided by Golder Associated which applies a GIS approach using a Driving Forces –Pressures-State-

Impacts-Response (DPSIR) framework.

Protection of terrestrial flora species in Turkey is a key issue as Turkey represents the richest flora in

the Palearctic (approximately 9700 species) and a very high rate of endemism (over 30%).

Priority Biodiversity Features

The TANAP BAP was developed with the specific objective to identify the species and habitats in

consideration of national and international significance and to consequently determine the applicable

area specific action to protect and conserve biodiversity within the 36 m RoW. The BAP has

identified the presence of natural habitats, intersections of the ROW with protected or conservation

areas and the presence of ecologically sensitive species within the ROW.

Flora studies included the sampling of 246 stations along the pipeline route. Species of conservation

significance were identified from assessments against the Red Book of Turkish Plants and IUCN 2001.

The studies identified 9 species considered critically endangered, 14 endangered, 35 vulnerable and

14 are near threatened. Moreover, 221 taxa were found to endemic and 62 of these are considered

restricted range. Of the 86 Species of Conservation Concern (SCC), 62 were found along the pipeline

ROW during field studies and one species was identified as new to science, bringing the total number

of SCC to 87.

The terrestrial fauna surveys identified five mammal SCC as a result of desktop and field studies

including 3 vulnerable and one near threatened. Bird studies identified 11 SCC including one critically

endangered, 4 endangered, 2 vulnerable and one near threatened species. There were 3 reptile SCC

identified including one critically engaged, on endangered and one near threatened. One vulnerable

amphibian species was identified. A total of 34 Arthropod species were identified as SCC including one

critically endangered, 7 endangered, 2 vulnerable and one near threatened.

The BAP includes a discussion of EUNIS habitat types encountered along the TANAP route including

30 different terrestrial habitat types classified as Level III and 6 level III freshwater habitats. Habitat

types classified as significant under the Turkish ‘National Biodiversity Strategy and Action Plan” were

also identified as priority habitats including steppe, coastal sand-dunes and mountainous forest

ecosystems.

Freshwater biological studies found no flora taxa that triggered SCC. The fish species were identified

from 189 river crossing sites sampled over two field campaigns in different seasons. These studies

identified 13 SCC fish species, 11 of which are highly endemic and two critically endangered. One

species of endangered aquatic invertebrate was identified as being potentially occurring at project

river crossings.

Protection status and endemism (for some species) have been determined by checking against BERN,

IUCN, CITES, Bird Directive, Habitat Directive, CHCD and RDBT. Protected and conservation areas in

the 10-km buffer around the Project have been determined.

Threatened flora and fauna species within the 500m corridor have been assessed. Freshwater critical

habitats (FCH) have been determined according to EUNIS Code with classification of confirmed versus

potential critical habitat.


BAP Critical Habitat Assessment

The BAP states that it has identified critical habitat under five criteria outlined in the IFC PS6 (2012)

and GN6 and quantitative assessment for Tier 1 and 2 of Critical Habitat Criteria 1-3. Critical Habitat

was first identified during the baseline phase of the ESIA study and has been re-evaluated and

further defined in the BAP using the following approach:

• Information about the current status of the critical habitats (i.e. at the species, ecosystem

and landscape scales) was collected;

• The relationship between critical habitat with relevant conservation significant species was

identified;

• Intersects of the ROW with protected areas or high biodiversity areas were reviewed;

• Species and habitats were evaluated and prioritised as “low, medium and high” significance

scale in consideration of a range of factors including conservation status, distribution,

endemism, species/habitats and local conditions.

For critical habitat triggering flora species identified in the ESIA Studies, those that occurred within

the 36 m ROW were identified and included in the critical species list; those that were not observed in

the ROW were removed. For terrestrial fauna species identified as potentially critical habitat triggers

in the ESIA, the re-evaluation considered the potential for those species to use the 36m wide ROW

for reproduction, feeding, nesting or other habitat use was assessed on the basis of field investigation

and where no habitat use was identified then those species were removed from the critical species

list.

This process represents some limitations to the critical habitat determination as it is focussed on the

TANAP impact on species that trigger critical habitat rather than the critical habitat itself. PS6 GN 64

requires that critical habitat should be determined based on the biodiversity attributes particular to

the habitat in question and the ecological processes required to maintain them. It is recognised that

TANAP has applied the critical habitat assessment methodology using the available collected data

from the RoW, and more broadly in certain areas. However, TANAP’s critical habitat assessment was

limited due to the lack of regional species population and habitat data over the whole corridor.

TANAP has considered the broad scale EUNIS habitat scale data in determining critical habitat and

has also consulted with Project stakeholders in the critical habitat assessment methodology.

Where seasonal or other limitations to field investigations meant that the presence or of species or

habitat could not be assessed within the ROW then the BAP applied the precautionary principle and

included these in the critical habitat assessment and made recommendations for further field studies

to verify the assessment. TANAP does require construction contractors to undertake pre-construction

biological surveys of the RoW and uses this data to further verify the assessments.

The BAP provides a tabular summary of the critical habitat assessment outcomes including the criteria

triggers, the outcomes of the quantitative assessment to determine the appropriate tier for Criteria 1-

3 and area of critical habitat within the ROW. However, the BAP does provide limited information on

how the species data has been screened against the quantitative thresholds as described in the GN6

paragraph 69. As described above, there is no discussion or detail of the discrete management units


for species and habitats that are identified as potentially critical. Quantitative assessments have been

applied by TANAP using the broad EUNIS habitat classifications.

The TANAP BAP includes a revision of the Critical Habitat determination made in the ESIA. The ESIA

assessment of critical habitat was limited to habitats within the LSA due to the limited area of

investigation and the lack of population data, as discussed above. This initial critical habitat

assessment identified that 10.8 % of the TANAP terrestrial LSA was confirmed as triggering critical

habitat and 81% of the LSA being identified as potential critical habitat. For rivers crossed through

the LSA, 41 rivers were confirmed as critical habitat and all the remaining rivers (1170 crossings)

were assessed as being potentially critical habitat. The ESIA identified further studies requiring to be

completed to further define critical habitat and these additional studies were completed during the

BAP surveys completed from August to October of 2014.

The re-assessment of critical habitat in the BAP identified 67 terrestrial and 27 freshwater critical

habitats. The terrestrial critical habitats cover only 0.39% of the 500m LSA corridor assessed in the

ESIA and 5.6% of the ROW (36m). This represents a significant decrease in terrestrial critical habitat

affected by the Project from that identified in the initial ESIA studies following the BAP re-assessment.

However, this reassessment of critical habitat area is based on the presence or absence of critical

habitat triggering species or values within the project’s direct impact area and removes critical habitat

areas where the triggering species or values were found to be undisturbed by direct impacts of the

ROW.

The IESC finds that the TANAP critical habitat assessment is not in full compliance with the IFC PS6

GN and is therefore in partial compliance with the requirements of PR6 to ensure net biodiversity gain

of critical habitat and no net loss of priority biodiversity features.

The BAP states that the impact assessment undertaken in the ESIA confirms a low degree of impact

expected on natural and critical habitat; states that significant permanent and long-term impacts are

not expected, and the defined mitigation measures are sufficient for the recovery of habitats. The

BAP also refers to the ESIA in confirming no long term or permanent significant impact to Species of

Conservation Concern. However, the BAP does recognise the threat of permanent impacts on SCCs

from alien invasive species, including the pathways for introduction of weed species, within the

pipeline ROW and reiterates the importance of the Alien Invasive Species Guidance Document.

Furthermore, the TANAP’s “Erosion, Reinstatement, and Landscaping Plan” and the “Specification for

Reinstatement” includes the range of actions for reinstatement and bio restoration of the project sites

to achieve pre-development biodiversity criteria. The performance of the bio restoration efforts in

achieving the stated biodiversity objectives is proposed to be monitored and reported through the

“Bio-Restoration Monitoring Plan (October, 2016).

The IESC review of the ESIA and BAP has found the impact assessment does recognises the potential

direct impacts to species of conservation concern including those that trigger critical habitat. For

example, high impacts are identified for two areas within the Ardahan and Kutahaya provinces for a

total of 4.8 hectares where SCC species are potentially present within the Project AoI. The mitigation

recommended in the ESIA for identified high impact includes measures to translocate individuals,

which is stated to be a “high risk option”. The mitigation measures also include seed collection from

SCC species for use in conservation projects and additional conservation measured where critically


endangered species are impacted. The conservation measures include measures to re-introduce

populations in suitable habitats within the species range and includes the option to translocate to

suitable sites outside the RoW.

Section 3.2.1 of the most recent version of the BAP does include discussion on the application of the

mitigation hierarchy for critical habitats. The BAP describes how mitigation measures are applied for

each critical habitat that occurs along the Project and identifies where additional conservation actions

are required to ensure no net loss of priority species. Annex 9 of the BAP includes a range of

measures designed to ensure a net gain in critical habitat that is impacted by the Project. The net

gain measures include:

• Species specific action plans;

• Support for scientific research;

• Reducing grazing pressure on habitats; and

• A range of public awareness raising activities.

However, these net gain actions are not described in a way that demonstrate how a net gain would

be achieved. There is no quantification of the no net loss/ net gain objectives of the BAP to

demonstrate full compliance with PR6.

Neither the ESIA nor the BAP provide sufficient detail of the project related direct, indirect and

residual impacts on populations; species and ecosystems identified in the baseline studies. There is

insufficient assessment of the project impacts on critical habitat other than the direct impacts within

the ROW. The impact assessment on biodiversity values provides insufficient discussion on why

aspects such as habitat fragmentation, fauna avoidance and impacts from increased third party

access are not considered.

The BAP discussion of impacts to habitat includes reference to two other pipeline routes that passed

through some sections of the areas studied. One of these pipeline route corridors had restoration

work completed some years past and the BAP concluded that “there is no damage” evident after the

restoration has been completed. The other had no restoration work completed and damage to

biodiversity remains evident after long years being passed. This does demonstrate that good practice

remediation measures are an important mitigation necessary for biodiversity management. However,

there is no specific study cited or detailed evidence that supports the assertion that restoration work

on the TANAP ROW will result in net biodiversity gains in critical habitat and no net loss of priority

biodiversity features.

The project has not demonstrated full compliance with PS6 GN15 in its assessment of impacts to

critical habitat and has provided insufficient evidence that bio restoration works on the ROW will be

adequate to achieve the biodiversity outcomes required to demonstrate compliance with PR6.

The IESC has found that TANAP has relied heavily on the assumptions that mitigation of temporary

disturbance through bio-restoration and alien species control will be effective in ensuring no residual

impacts to priority biodiversity values and critical habitat. There is little discussion in the ESIA that

supports the assumption that bio-remediation will ensure no permanent or long-term impacts to

priority biodiversity values and critical habitat. The limitations of bio-reclamation are stated in various


sections of the ESIA that refer to challenges in achieving propagation or translocate of some species,

and the inability to replace tree species over the ROW to ensure the integrity of the pipeline is

maintained (see Terrestrial Flora Baseline Report Section 2).

The effectiveness of the mitigation measures, including bio-restoration and alien species controls,

should be discussed in further detail and, where possible, refer to examples where these mitigation

measure have been effective in ensuring no loss of priority biodiversity values or critical habitat.

However, if relevant and geographic specific examples of successful bio-restoration are not available,

then the assumption that there will be no residual impact to priority features and critical habitat

cannot be supported.

In consideration of the limitations found with the TANAP critical habitat assessment and management

approach, and recognising the current status of Project construction. The IESC recommends that

TANAP develop and implement an Offset Management Strategy document that supplements the BAP.

The Offset Management Strategy should include:

• Quantification of the residual impacts to Priority Biodiversity Features and Critical Habitats, as

defined in the BAP;

• Identification of specific biodiversity measures in accordance with the mitigation hierarchy, to

achieve No Net Loss/ Net Gain outcomes of the species and habitats of conservation

importance;

• Quantifies No Net Loss/ Net Gains based on the successful implementation of the above

actions over a reasonable timeframe

Ecosystem Services

The ESIA assessed ecosystem services were assessed for TANAP in consideration of information

derived from both social and biological studies. Impacts and risks relating to ecosystem services were

measured through a range of component studies including:

• Employment and livelihoods;

• Land use and agriculture;

• Flora (terrestrial and freshwater);

• Fauna (terrestrial and freshwater)

The ESIA identified potential TANAP effects on ecosystem services and has considered these within

both environmental and social impact assessment and mitigation measures.

5.6.2 Conservation of Biodiversity

Application of the mitigation hierarchy

The TANAP route selection described in the ESIA Chapter 5 describes the process for defining the

TANAP route and included consideration of a range of factors included the presence of protected

areas, sensitive habitats, Scrublands, Meadows-pastures and wetlands. A number of route

alternatives were identified to avoid key biodiversity conservation areas including the Posof Ardahan

Wildlife Development Area, Kakgol-Sahara National Park, Sarikamis Allahaukber Mountains National


Park, and the Akdagmadeni Forest (Important natural area). The range of constraints presented by

the TANAP project over the complete route presents challenges to avoidance of all priority

biodiversity features. However, ESIA Figures 5.10 and 5.11 demonstrate that route selection has been

successful in minimising impacts to protected areas and priority features.

The final TANAP route impacts are assessed in Annex 2 of the BAP (Rev P3-6) which shows 18

protected areas being intersected by the TANAP RoW. The ESIA baseline studies included detailed

assessment of the protected areas (Chapter 7.3.1.7 and Appendices) and a detailed assessment of

TANAP impacts to each protected area is provided in Chapter 8.2.2. The BAP assessment found all

intersections to be of a low impact level. The disturbance of protected areas from the TANAP RoW is

generally under 1% of the protected land area except for Bataklikduzi, Corakik Lake and Tuzlu lake

wetlands where the RoW disturbance area represents 1.26 %, 2% and 2.96 % of the protected area

respectively. Specific plans have been developed for each impacted protected area in consultation

with the relevant authorities that demonstrate compliance with Article 6 of the EU Habitats Directive.

Implementation of the BAP

The IESC site visit reviewed the implementation of the specific management measures outlined in the

Erosion, Reinstatement and Landscaping Management Plan (MP) for management of topsoil in

identified critical habitat and found that these measures are not realistically achievable in the field.

This MP states that topsoil shall be replaced onto the disturbed area as soon as the pipeline has been

placed into the ground and the surface reinstated. During the site visit it was found that this

commitment is not achievable in the field due to the need to conduct ongoing hydro-testing and

pressure testing activities that may require that the land surface be disturbed again after

reinstatement. Considering this, topsoil stockpiles in these areas may remain in place for up to 18 –

24 months before they are used in rehabilitation. As such, additional measures to ensure the topsoil

and seedbank remains viable should be considered. The delay in restoration is also likely to result in

biodiversity impact durations being extended and would require a re-evaluation of the biodiversity

impact assessment.

The observation of the critical habitat area (Erzurum Wetland) of ROW from the site visit confirms the

IESC’s concerns regarding the reliance on successful bio-restoration to ensure no long term or

permanent impacts to critical habitat. If topsoil management measures prescribed in the site-specific

restoration plans are not being followed, then it would suggest that alternative mitigation measures

or offset measures may be required.

The site visit to the pipeline construction sites noted the lack of implementation of specific measures

to minimise impacts top biodiversity including:

• Disturbance outside of the ROW corridor from vehicle and equipment movements;

• Presence of open trenches for extended periods without measures to prevent animal being

trapped in the excavation or means for trapped animals to egress;

• Lack of covers on open pipelines to prevent animals being accidently trapped during the

construction phase.


The TANAP BAP implementation will require substantial level of effort and capability for both

implementation of the Erosion, Reinstatement and Landscape Management Plan by the relevant

construction contract teams and the monitoring efforts required for the Bio-Restoration Monitoring

Plan (October, 2016). The IESC has reviewed these plans and has some concern regarding the

resources available to fully implement both plans. For example, it is unclear how TANAP will ensure

the financial resources are available and planned for to ensure that failures in bio restoration

identified from monitoring are addressed up to 10 years following the completion of construction.



PR Ref.


6 Biodiversity and Living Natural Resources

6.7 Assessment of Biodiversity and Living

Natural Resources, Baseline Studies Assessment process will characterise the baseline conditions to a degree that is proportional and specific to the anticipated risk and significance of impacts. The baseline assessment will consider:

• loss of habitat, • degradation and fragmentation, • invasive alien species, • overexploitation,

• migratory corridors, • hydrological changes, • nutrient loading • pollution, • impacts relevant to climate

change and adaptation.

PC The BAP reassessment of critical habitat area is based on the

presence or absence of critical habitat triggering species or values within the project’s direct impact area and removes critical habitat areas where the triggering species or values were found to be undisturbed by direct impacts of the ROW. This method is inconsistent with PS6 GN64. The IESC finds that the TANAP critical habitat assessment is not in full compliance with the IFC PS6 GN and is therefore unable to demonstrate compliance with the requirements of PR6 to ensure net biodiversity gain of critical habitat and no net loss of priority biodiversity features.

The IESC recommends that TANAP quantify

the critical habitat/ priority biodiversity Features to be impacted directly/indirectly by the Project. The results of the quantification of critical habitat/ Priority Biodiversity Features should inform a Biodiversity Offset Strategy.

6.8 Identification of project related opportunities, risks and impacts on biodiversity. Characterise impacts based on likelihood, significance and severity and reflect concerns of communities and other

stakeholders. Consideration of direct, indirect and cumulative impacts

PC Impact assessment methodology is applied in accordance with accepted standards and is effective in identification of mitigation requirements. The ESIA baseline data was used to define the sensitivity of the various VEC’s to identify likely impacts associated with the

project and to define the pre- project condition that will be used as a benchmark to detect changes during monitoring. VECs were assigned sensitivity levels based on a range of factors including current quality of the component and susceptibility to environmental changes. Those impact factors most relevant to biodiversity impacts were identified as:

• Reduction in topsoil quality/availability • Site restoration

As per 6.7 above


PR Ref.


• Sediment suspension • Removal of natural vegetation • Introduction of alien species

The impact assessment methodology for biodiversity assigned impact factor intensity based on assumed standard mitigations

being applied in accordance with good industry practice, so impact factors are measured only after mitigation. Neither the ESIA nor the BAP provide sufficient detail of the project related direct, indirect and residual impacts on populations; species and ecosystems identified in the baseline studies. There is insufficient assessment of the project impacts on critical habitat other than the direct impacts within the ROW . The impact assessment on biodiversity values provides insufficient discussion on why aspects such as habitat fragmentation, fauna avoidance and impacts from increased third party access are not considered.

6.9 Assessment to consider the use of ecosystems by potentially affected communities and/or indigenous peoples. Avoid impacts to those ecosystems used. Where avoidance in not possible – minimise or implement appropriate mitigation measures to maintain overall functionality.

FC The ESIA assessed ecosystem services were assessed for TANAP in consideration of information derived from both social and biological studies. Impacts and risks relating to ecosystem services were measured through a range of component studies including:

• Employment and livelihoods; • Land use and agriculture; • Flora (terrestrial and freshwater); • Fauna (terrestrial and freshwater)

The ESIA identified potential TANAP effects on ecosystem services and has considered these within both environmental and social impact assessment and mitigation measures.

No action required

6.10 For projects that could potentially have such impacts on Indigenous Peoples and local communities, the client will provide opportunities for fair and equitable sharing of the benefits derived from the utilisation of living natural resources in accordance with:

N/A Utilisation of living natural resources is not an aspect of this Project


PR Ref.


(i) the requirements for addressing economic displacement issues in PR 5;

(ii) the specific requirements relating to managing potential issues and

impacts on Indigenous Peoples in PR 7; and

(iii) the stakeholder engagement requirements provided in PR 10.

6.11

Conservation of Biodiversity Project related impacts to biodiversity will be managed in accordance with the mitigation hierarchy and GIP. Adopt precautionary approach and apply adaptive management practices

PC A detailed Biodiversity Action Plan (BAP) has been developed by TANAP contractor Cinar for implementation on the Project. The most recent revision to this document occurred in October 2016 and included the addition of a Biorestoration Monitoring Plan as an Annex to the document. The BAP has not adequately identified and addressed critical habitat that is likely to be disturbed by the Project. The BAP does not discuss how the species data has been screened against the quantitative thresholds as described in the GN6 paragraph 69. It appears that TANAP has applied a scale of analysis to assess criticality of species and habitats of conservation significance using project disturbance boundaries, the ROW, and has not applied discrete management units in accordance with the requirement of GN6 paragraph 64 and 65. It is therefore very likely that critical habitat exists within the ROW that has not been identified as such due to the absence of critical habitat triggering species.

Specific management measures outlined in the Erosion, Reinstatement and Landscaping Management Plan (MP) for management of topsoil in identified critical habitat are not realistically achievable in the field, as evidenced during the field visit. The impact assessment on biodiversity values provides insufficient discussion on why aspects such as habitat fragmentation, fauna avoidance and impacts from increased

It is recommended that TANAP identifies the specific biodiversity management actions in accordance with the mitigation hierarchy, to achieve No Net Loss/ Net Gain outcomes of the species and habitats of conservation significance. The biodiversity management actions should inform a Biodiversity Offset Strategy.


PR Ref.


third party access are not considered. Residual impacts to biodiversity will occur of bio restoration works are not 100% effective. This has not been effectively considered.

6.12 6.13

Maintain the viability of priority biodiversity features: Threatened habitats; vulnerable species; significant biodiversity features; and, ecological structure and functions needed to maintain the viability of priority biodiversity features. Where significant, adverse and irreversible impacts to priority biodiversity features are identified, activities should not be implemented unless: there are no feasible alternatives; overall benefits outweigh project impacts; stakeholders are consulted; permits are granted under applicable laws; appropriate mitigation measures are put in place.

PC TANAP has stated that no significant long term or permanent impacts to priority biodiversity features due to effective mitigation using bio-restoration and alien species control. The IESC has found that TANAP has relied heavily on the assumptions that mitigation of temporary disturbance through bio-restoration and alien species control will be effective in ensuring no residual impacts to priority biodiversity values and critical habitat. The limitation of bio-restoration is stated in various sections of the ESIA that refer to challenges in achieving propagation or translocate of some species, and the inability to replace tree species over the ROW to ensure the integrity of the pipeline is maintained (see Terrestrial Flora Baseline Report Section 2). The latest version of the BAP (Rev P3-10) provides prescriptive detail of the post construction bio-restoration monitoring requirements to ensure that residual impacts are avoided or additional measures are implemented to offset these impacts . The BAP has been subject to a number of revisions, the latest being the version Rev-P3-10 issued in May 2017. The BAP studies were required to address data gaps identified in the ESIA studies, as described below, accommodate route changes that had occurred and to revise the critical habitat assessment completed for the ESIA. The BAP ecological surveys were

targeted towards the presence of ecological sensitive species and habitats along the RoW, between 36m and 70 m in width. The effectiveness of the mitigation measures, including bio-restoration and alien species controls, should be discussed in further detail and, where possible, refer to examples where these mitigation measure have been effective in ensuring no

See 6.7 and 6.11 actions


PR Ref.


loss of priority biodiversity values or critical habitat. However, if relevant and geographic specific examples of successful bio-restoration are not available, then the assumption that there will be no residual impact to priority features and critical habitat cannot be supported.

6.14, 6.15 6.16 6.17 6.18

Impacts to critical habitat to be identified, including (i) highly threated or unique ecosystems; (ii) habitats of significant importance to engaged or critically endangered species; (iii) habitats of significant importance to endemic or geographically restricted species; (iv) areas associated with key evolutionary processes; or (v) ecological functions that are vital to maintaining the viability of these biodiversity features. Where impacts to critical habitat have been identified the client will retain experienced external experts to conduct the assessment of the potential adverse impacts on this critical habitat. Critical habitat must not be impacted to the extent that ecological integrity is compromised. Activities in areas of critical habitat are not to be implemented unless:

No viable alternative; stakeholders consulted; project is permitted under applicable law; no measurable adverse impact on those biodiversity features that trigger critical habitat; project is designed to deliver net gains for impacted critical habitat; no anticipated net reduction in

PC See 6.12 and 6.13 above

Develop and implement a Biodiversity Offset Strategy document that: Quantifies residual impacts to Priority

Biodiversity Features and Critical Habitats, as defined in the BAP [Rev P3 – 10]

Identifies specific biodiversity management actions, in accordance with the mitigation hierarchy, to achieve No Net Loss / Net Gain outcomes of these species and habitats of conservation importance

Quantifies No Net Loss / Net Gains based on the successful implementation of the above actions over a reasonable timeframe


PR Ref.


population of any endangered or critically endangered species; long term biodiversity monitoring and evaluation programme to assess status of critical habitat is implemented.

Where critical habitat requirements can be met - mitigations strategy will be defined in a BMP or BAP Where offsets are proposed for priority biodiversity features of critical habitat, the Client must demonstrate through an assessment that the significant residual impacts on biodiversity will be adequately mitigated and retain external expertise with knowledge of offset design and

implementation.

6.19 6.20

Impacts to protected areas to be identified and mitigation hierarchy applied Where impacts to priority biodiversity features and /or critical habitat occur within protected areas, then these impacts will be avoided and the client will: Show that the development is legally permitted; act in a manner consistent with recognised management plans; consult

protected area managers; implement additional programmes to promote and enhance the conservation objectives of the project area.

FC The TANAP route selection described in the ESIA Chapter 5 describes the process for defining the TANAP route and included consideration of a range of factors included the presence of protected areas, sensitive habitats, Scrublands, Meadows-pastures, and wetlands. A number of route alternatives were identified to avoid key biodiversity conservation areas including the Posof Ardahan Wildlife Development Area, Kakgol-Sahara National Park, Sarikamis Allahaukber Mountains National Park, and the Akdagmadeni Forest (Important natural area). The range of constraints presented by the TANAP project over the

complete route presents challenges to avoidance of all priority biodiversity features. However, ESIA Figures 5.10 and 5.11 demonstrate that route selection has been successful in minimising impacts to protected areas and priority features.

6.21 Invasive Alien Species: avoid and proactively prevent accidental or deliberate introduction of alien species that could

FC The Alien Invasive Species Guidance Document provides a comprehensive process for mitigation of potential invasive species and this mitigation is critical in ensuring successful

No Action Required


PR Ref.


have significant adverse impacts in biodiversity

mitigation of identified biodiversity impacts including the successful implementation of the Bio-restoration plan.

6.22 - 6.37

Sustainable Management of Living Natural Resources – applicable for projects which involve the primary production of living

natural resources or where such resources are central to the project’s core function

N/A Not applicable to TANAP


5.7 PERFORMANCE REQUIREMENT 7: INDIGENOUS PEOPLE

This Performance Requirement is not applicable to the TANAP Project.


5.8 PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE

As defined by EBRD in PR 8, cultural heritage includes both tangible (physical) and intangible heritage

recognized at local, regional, national or international levels. The TANAP ESIA assessed cultural and

archaeological sites and intangible heritage along the pipeline route, including incorporation of

cultural heritage criteria in the route selection process.

5.8.1 Assessment and Management of Impacts on Cultural Heritage

The ESIA includes assessment of cultural and archaeological sites, and intangible cultural heritage.

Mitigation actions for the 161 sites identified included: Route change/Area change; Archaeological

Monitoring; Salvage excavation and test pits; or, No action.

Avoidance of cultural heritage (CH) sites has been achieved to date as far as practicable using the

corridor assessment process that included cultural heritage selection criteria.

A CHMP has been developed (TNP-PLN-ENV-GEN-006), which specifies actions required to identify

and mitigate potential impacts to intangible CH, through engagement and liaison by Contractors with

local authorities.

The CHMP further identifies identification of tangible heritage resources and definition of mitigation

measures at pre-construction phase, informed by baseline and survey results. At those sites identified

as unavoidable, engagement with statutory authorities was reported, as required in the CHMP. Of 161

sites identified during surveys, 55 were already registered with authorities, while 106 newly

discovered sites were revisited with the Ministry, and as a result, 20% of these sites were registered

as Protection Sites by the Ministry of Culture and Tourism.

Day to day management is the responsibility of the site-based Cultural Heritage Officer, formerly an

EPCM role now under TANAP (see also comments in PR1 on organisational implementation of ESMS).

Monitoring is required by the contractors’ archaeologist during ground disturbance, under a SOW that

complies with requirements of a Protocol between TANAP and the Ministry of Culture and Tourism. A

chance find process is in place (defined in Annex A of TNP-PCD-ENV-GEN-006, and replicated by each

of the CCs) to address avoidance of significant finds during construction and land preparation. Further

studies have been carried out on those sites that were unavoidable during routing studies, followed

by either permission to proceed by local authority, or, preferentially, to implement a route change.

Eleven sites were identified as unavoidable at pre-construction phase, of which five route changes

were implemented during construction. A contracted third party, operating under supervision of the

Ministry, carries out all test pits and salvage excavations.

Sites that were inspected by the audit team had completed cultural heritage site management.

Additional evidence (provided in meetings on 12 May 2017) requested by the IESC on chance finds

records, indicated that a total of 49 chance finds have occurred during construction, 46 of which have

been closed out, and actions for 3 remain open. Details of the corrective actions taken regarding

these chance finds have not been sighted by the IESC.


5.8.2 Consultation

The CHMP identifies the Museum Directorate of the Ministry of Culture and Tourism as the

responsible agency for advice and direction on archaeological finds, under direction and decisions

from the Regional Board Directorate of Protection of Cultural Heritage.

TANAP and CCs stated and provided written evidence strong engagement with regulatory bodies on

cultural heritage, including assessment with museum specialists being undertaken at critical sites to

make a determination on any excavation, salvage or other mitigation requirements. The CC’s

archaeologist SOW includes consultation with the relevant state authorities on behalf of TANAP and

site-based CHOs provide additional support.

Stakeholder engagement with individuals or groups with specialist interests by the Project has been

limited; at the ESIA consultation phase, specialist NGOs were invited but did not participate (ESIA

Appendix 3.2d). Consultation with affected communities is carried out for intangible cultural heritage

and registered tangible cultural heritage elements. However, chance finds are managed differently

due to security reasons (due to the risk of illegal excavations).

TANAP is encouraged to continue to engage with CH specialist stakeholders for the duration of

construction in particular, in line with GIP. Museum specialists are the parties responsible for

informing stakeholders and making determinations on behalf of the Ministry of Culture, while TANAP

follows the expert advice in ensuring implementation requirements are followed by the CC.



PR Ref.


8 Cultural Heritage

8.1 Assessment and Management of

Impacts on Cultural Heritage

FC A total of 161 sites were identified in this process, and mitigation actions

defined. Eleven sites were identified as unavoidable at preconstruction phase. A Cultural Heritage Management Plan (CHMP) is in place, owned by TANAP and requirements of which reflected in construction contractor MPs. This includes a Chance Find Procedure. The CCs’ Archaeologist, who liaises with the TANAP Cultural Heritage Officer and the Museum Directorate, undertakes monitoring of ground clearance work. Third party monitoring of implementation of the CHMP is also undertaken by CINAR. It is noted that the former EPCM Chance Find requirements are still in place, and are expected to be deleted from the TANAP ESMS by 31 January 2017 (see also Section 5.1 on PR1).

During the construction phase to date, five route changes have been implemented at the eleven unavoidable sites, following engagement and mitigation actions implemented under the direction of the with the relevant authorities (Museum Directorate of the Ministry of Culture and Tourism).

8.2 Consultation with affected communities and other stakeholders

FC Ongoing and close engagement has been undertaken with the Museum Directorate of the Ministry of Culture and Tourism, as the responsible agency for advice and direction on archaeological finds and appears to have been effective in managing and mitigating potential impacts to tangible heritage in line with the mitigation hierarchy approach. However, consultation with affected communities and other stakeholders has been

largely limited. Invitations to specialist interest groups at the ESIA consultation phase has been recorded. IESC notes that consultation with affected communities is carried out for intangible cultural heritage and registered tangible cultural heritage elements. However, the chance finds are managed differently due to security reasons (the risk of illegal excavations).

8.3 Project use of Cultural Heritage FC Not applicable


5.9 PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND STAKEHOLDER ENGAGEMENT

Policies and standards are in place for the Project regarding Stakeholder engagement,

communications and social impact management and requirements. The Project Stakeholder

engagement approach was firstly outlined in the ESIA (Chapter 6), outlining engagement function

and approach across project phases and the Project’s grievance mechanism. Stakeholder

engagement past activities, current program and monitoring activities were also detailed, in line with

GIP. The total number of consultation meetings during the construction phase (as at November

2016) were 1,234, including meetings with women, safety awareness for children, and with local

authorities, across all Lots and stations. Comments raised during project disclosure were reflected

and analysed and incorporated into Project SMPs including the Stakeholder Engagement Plan (SEP)

and Resettlement Action Plan (RAP).

5.9.1 Stakeholder Engagement Plan

Policies and standards are in place for the Project regarding Stakeholder engagement,

communications and social impact management and requirements.

The SEP (Aug 2013) was prepared to meet international standards and was finalised reflecting public

participation and disclosure requirements. The SEP is aligned with an online Stakeholder Information

System for tracking ongoing engagement and issues of stakeholder interest.

Engagement activities during ESIA development and disclosure in line with GIP (including village-level

meetings, gender-segregated meetings/focus groups) and included stakeholder analysis of engaged

organisations (e.g. ERM-REP-ENV-GEN-003 Rev.P2-0, 17 January 2014). Engagement was

appropriate to the nature and the scale of the Project, at the pre-construction phase covering:

• 7 province and 56 District PPMs with the participation of local governors, local NGOs, media

and community representatives;

• 513 Village Questionnaires and 2,253 Household Questionnaires;

• 307 Focus Group Meetings with youth, women and fishermen;

• 151 in-depth interviews with Local Authorities, Sub-governors & Mayors;

• 83 Disclosure village meetings held; and

• 572 villages invited the village disclosure meetings.

Ongoing stakeholder engagement is undertaken by CCs with support of TANAP social specialists. The

last Lots/areas for construction phase engagement are Lot 4 and AGIs. A new SEP was developed

(2016 TNP-PLN-SOC-GEN-001-Rev3-2, 30/01/2017)), which provides for updated roles and

responsibilities.

Social induction training is provided to all workers thereby supporting culturally appropriate

behaviours by all workers on the Project, in line with GIP.


The Social and Environmental Investment Program (SEIP) has been developed and approved by the

Board of Directors. The SEIP is TANAP’s CSR Program and intends to support wider project-affected

areas; it is not a fund for mitigating specific project impacts.

5.9.2 Operational Grievance Mechanism

The grievance mechanism is operational and is aligned with the CCs. All grievances are logged in an

online grievance recording and tracking system. CCs have access to and management of the same

system for Lots within their areas of responsibility only; TANAP has control of the system overall.

A total of 790 complaints have been received from 1/1/14 to 17/11/16 with 85% closed over an

average of 15d response time (30d is the time limit in the procedure for closure of complaints). The

most common grievances since project commencement relate to Damage to property/land; Land

acquisition and compensation process; damage to irrigation infrastructure; damage to roads; and

outstanding subcontractor payments (as per: Complaints issues – Top 20, 17.Nov. 2016). One quarter

of complaints related to damage to land.

An Appeals Committee has been established to provide third party review of unresolved grievances

between TANAP and the Complainant. Documentation on this committee has been developed and is

to be provided to the IESC.

Legal redress is possible regardless of establishment of the Appeals Committee with complainants

able to take matters to court independently. This has not occurred in the Project to date; a third-

party valuation had been sought to resolve land valuation, and a policy of resolution by mutual

agreement is in place by the project.

5.9.3 Information Disclosure

The ESIA documents were disclosed on the TANAP website in English and Turkish on 22 June 2015;

this included the ESIA, a Guide to Land Acquisition and Compensation, a RAP and a Stakeholder

Engagement Plan based on international good practices and standards, including the 2012 IFC

Performance Standards.

The current SEP specifies periodic review of the document in line with PR 10 requirements for

ongoing provision of information to stakeholders appropriate to the nature of the Project and its

adverse impacts. Material changes to the project included the revised approach to land acquisition

and resettlement, as documented in the AGIs and Pipeline RAPs. PR 10 requires at least annual

reporting to stakeholders for Category A projects; commitment on this aspect is included in the SEP.

The modality of disclosure of Project documents was described by TANAP. For RAP documentation,

the disclosure process was addressed adequately through provision of written summary information

in the local language, available to public disclosure meetings, which subsequently informed the final

RAPs prior to their disclosure. Additional engagement planning and disclosure material is required of

TANAP on the next phase of RAP activity (i.e. in identifying and appropriately compensating new

PAPs) and in the development and disclosure of the BAP



PR Ref.


10 Information Disclosure and Stakeholder Engagement

10.1 Stakeholder Engagement Plan FC A SEP was published (18 August 2013) on the TANAP website in

Turkish and English, specifying objectives, legal context and project standards, previous engagement, stakeholder identification and the SE program. Roles and responsibilities, Grievance management processes and monitoring, evaluation and reporting were all included, in line with GIP and appropriate to the nature, scale and risks posed by the Project. The SEP specified engagement approaches with different stakeholder groups (e.g. community leaders, vulnerable groups). This SEP has been recently updated on 30/01/2017 (TNP-PLN-SOC-GEN-001-Rev3-2) and includes additional guidance on SE

implementation for the construction phase (Annex 1_Stakeholder Engagement Implementation Guidelines for Construction) to assist CCs in achieving consistent, responsive and effective engagement with the Project.

10.2 Operational Grievance Mechanism PC The Project’s grievance mechanism is in place to receive and respond to stakeholders’ concerns and grievances about the Project. The total grievances received across all Lots as at November 2016 were 746, of which 88% were closed, and 87 (12%) were open. The main grievances received since project commencement relate to damage to property and land, and the land acquisition process. A quarter of all complaints registered related to damage to land.

TANAP has committed to providing grievance feedback and data to communities during regular consultation meetings. An additional standing agenda item is to be added to consultation meetings, for follow up as appropriate; this will be reflected in the next SEP revision. The grievance process provides for legal redress, and an Appeals

Disclosure and actions to address common grievances:

(a) Conduct disclosure to communities of summary grievance data and measures taken by TANAP and CCs to address the common causes of grievances;

(b) include a specific section regarding

resettlement related grievances to be disclosed in summary form to relevant resettlement-affected stakeholders, with measures taken by TANAP to address the common causes of these grievances.


PR Ref.


Committee has additionally been established to provide third party review of grievances between TANAP and complainants, to provide an additional level of independent review of any unresolved complaints or grievances.

10.3 Information Disclosure PC ESIA documents were disclosed on the TANAP website, with key

documents in English and Turkish. Supplementary reports prepared included the RAP for Above-Ground Installations (AGIs) and the RAP for the Pipeline, prepared and disclosed due to material changes in the Project (i.e. approach to resettlement). The IESC recognizes that disclosure has been achieved online, and the modality of disclosure according to communities in a form and format readily understood by stakeholders. The RAP for AGIs was finalised with inputs from priority settlements; the revised Entitlements Matrix was disclosed in October 2016 and during this phase, informative leaflets were delivered to meeting attendees, as well as to Muhtars (for non-attendees). Details of these meetings were then incorporated into the RAP for AGIs. The final Plan was finalized and disclosed by TANAP. A RAP specific engagement plan (planned to be included as Annex 2 to existing SEP) is required as disclosure of the RAP Fund brochure is critical in ensuring that all PAPs are identified as compensated as is required.

Provide evidence to EBRD of the modality of

public disclosure of existing key project ESMPs, including the BAP and RAP documents.


6. COMPLIANCE AGAINST TURKISH ENVIRONMENTAL, HEALTH, SAFETY, AND SOCIAL LAWS, REGULATIONS, AND PERMITS

A key objective of the TANAP ESIA is to ensure that applicable Turkish legal requirements and

expectations are addressed. Chapter 4 of the ESIA provides an overview of the agreements,

legislation, standards and guidelines, which are applicable to the TANAP Project including the

applicable national legislation, applicable requirements of international conventions ratified by the

national government, international petroleum industry standards and TANAP’s Health & Safety,

Environment and Social Policy. Chapter 3 of the ESIA describes the required EIA process within

Turkey which is also summarised below in Figure 6.1.

6.1 HOST GOVERNMENT AGREEMENTS

The following Host Government Agreements and Inter-Government Agreements have been signed by

TANAP in order to meet legal compliance with Turkish requirements and set the basis for the Projects

implementation.

“Memorandum of Understanding between the Government of the Republic of Turkey and the

Government of the Republic of Azerbaijan Concerning the Development of a Standalone Pipeline for

the Transportation of The Natural Gas Originating and Transiting from the Republic of Azerbaijan

across the Territory of the Republic of Turkey”, was signed on 24 December 2011 in Ankara, which

was approved by Law no 6342 dated 29 June 2012 and was published in the Official Gazette on 12

July 2012. Following approval by Council of Ministers, the Agreement was published in the Official

Gazette on 11 October 2012 and entered into force. Within the framework of this Memorandum of

Understanding, Trans Anatolian Gas Pipeline Company B.V was established.”

“The Host Agreement Between the Government of the Republic of Turkey and the Government of the

Republic of Azerbaijan Concerning the Trans-Anatolian Natural Gas Pipeline System", and its

attachment, "The Host Government Agreement (HGA) between the Government of the Republic of

Turkey and The Trans Anatolian Gas Pipeline Company B.V. Concerning Trans-Anatolian Natural Gas

Pipeline System", were signed on 26 June 2012 in Istanbul. These Agreements were approved by Law

no 6375 dated 02 January 2013, which was published in the Official Gazette on 17 January 2013.

Following approval by Council of Ministers, the Agreements were published in the Official Gazette on

19 March 2013 and entered into force.”

The Host Government Agreement requires Project Environmental and Social Standards complying

with National Laws and also taking due account of international standards and practices generally

prevailing in the Natural Gas pipeline industry, including relevant Performance Standards of the

International Finance Corporation.

6.2 EIA PROCESS IN TURKEY

The Turkish legal framework for environmental protection was developed in line with national and

international initiatives and standards, and some of them have been revised recently to be

harmonized with the EU Directives in the scope of pre-accession efforts of Turkey to the EU. The


main legal basis for TANAP under Turkish environmental legislation is the Environment Law no. 2872,

which was published in the Official Gazette no. 18132 dated 11.08.1983 and amended by Law no.

5491 dated 26.04.2006. The objective of the Environment Law is to protect the environment in

accordance with the sustainable development principles.

The basic principles of EIA process applied in Turkey are defined by the Regulation on Environmental

Impact Assessment. As per the Turkish Regulation on EIA, whether a project requires an EIA study or

not is determined in relation to the scope and capacity of the project. The TANAP Project was

determined to require an EIA under Turkish legislation and was implemented following this regulation

appropriately. Legal approval through the MoEU for the ESIA Report of the Project was received on

24 July 2014.

The IESC team observes that the Project appears to be operated in full compliance with Turkish

legislation based upon the site visit and a review of provided documentation.


Figure 6.1 Turkish EIA Process


7. COMPLIANCE AGAINST OTHER APPLICABLE STANDARDS / LAWS / CONVENTIONS

Chapter 4 of the ESIA discusses the legal, political and institutional framework under which the

Project is being implemented. This Chapter identifies the following major Standards / Laws /

Directives as being applicable to the Project:

• Equator Principles and IFC Standards and Guidelines;

• IFC Performance Standards (2012);

• IFC EHS Guidelines;

• World Health Organisation (WHO) Standards;

• Various International Conventions (refer to Section 3);

• EU EIA Directive - 85/337/EEC Council Directive on the assessment of the effects of certain

public and private projects on the environment (EIA Directive). The EIA Directive of 1985

has been amended three times, in 1997, in 2003 and in 2009 and is now codified by Directive

2011/92/EU of 13 December 2011.

• 2009/147/EEC The Birds Directive; and

• 92/43/EEC Council Directive on the conservation of natural habitats and of wild fauna and

flora (the Habitats Directive).

7.1 EU DIRECTIVES

Chapter 4 of the ESIA lists a raft of EU legislation as having been considered and applied during

Project scoping and ESIA development.

7.2 INTERNATIONAL LAWS / CONVENTIONS

Turkey is signatory to a range of applicable international treaties and conventions, as discussed in

Chapter 4 of the ESIA. The requirements of these laws and treaties were observed to be considered

during the ESIA process.

7.3 IFC EHS GUIDELINES

A high-level compliance assessment against the IFC EHS General Guidelines is included as Appendix B

to this ESDD. The IESC notes no particular issues of concern in this assessment.

7.4 TANAP PROJECT HSES STANDARDS

TANAP Project Standards have been defined in Chapter 4 of the ESIA, considering the requirements

of Turkish legislation, IFC Guidelines and EU Directives, applying the most stringent criteria from each

source as the adopted Project Standard.

The Project Standards are captured within TANAPs and the CCs respective ESMS and ESMPs and

compliance against them regularly monitored and assessed. Evidence of this was reviewed and

agreed to be of a satisfactory nature by the IESC team.


8. HIGH LEVEL COMPLIANCE ASSESSMENT OF ASSOCIATED INFRASTRUCTURE

The TANAP Project associated facilities include the SCPx; the SD2 Project and the TAP Project. Separate ESIA

reports were completed for these projects including three ESIA documents for the TAP Project: TAP Albania, TAP

Greece and TAP Italy. These associated facilities have been subject to a high-level review by the IC against

EBRD PRs. As the scope of the IC’s review of TANAP’s associated facilities called for a high-level assessment,

this section should be read within the following context and is subject to several limitations, as follows:

• Findings are based on a sample of the publicly available ESIA documentation for the

associated facilities. Whilst the IC has made all efforts to establish compliance, it is

recommended that further detailed assessment, specifically on-site verification, be conducted.

• Due to the limited scope of the high-level review, the findings produced are necessarily

general. The IC has not provided a definitive opinion on compliance, rather findings are

written as observations with the intent that further detailed review be undertaken to establish

compliance.

• The TAP ESIAs (Greece, Albania, and Italy) were all conducted by ERM, utilising a common

methodology and approach. The findings of the high-level review for the TAP ESIAs are

therefore highly consistent with each other with respect to compliance and gaps.

• Sustainability is contracted to conduct bi-annual ESDD review and monitoring of the SD2

Project, and therefore is able to present a high-level review of this associated facility with a

far greater level of detail and confidence than the other facilities assessed. Findings for SD2

are taken directly from the most recent ESDD conducted in July 2016.

The scope of the review includes the assessment of each project’s ESIA report, namely:

• South Caucasus Pipeline Expansion Project, Azerbaijan ESIA, June 2013.

• ESIA for the Shah Deniz 2 Project, November 2013.

• ESIA for Greece, Trans Adriatic Pipeline, June 2013.

• ESIA for Italy, Trans Adriatic Pipeline, September 2013.

• ESIA for Albania, Trans-Adriatic Pipeline, January 2013.

Findings are derived from a review of the following chapters of each ESIA report:

• Table of Contents;

• Executive summary; and

• Methodology.

The review found all the associated infrastructure ESIA reports to be completed in general alignment with the

requirements of the EBRD. The findings of the high-level desktop review of the associated facilities is provided

below.


Table 8-1 High Level Compliance Evaluation – Associated Infrastructure

Performance Requirement

SCPx SD2 TAP Albania TAP Greece

TAP Italy

PR 1. Assessment and Management of Environmental and Social Impacts and Issues

Environmental and Social Assessment,

Environmental and Social Management Systems, Environmental and Social Policy10, Environmental and Social Management Plan, Organisational Capacity and Commitment, Supply Chain Management, Project Monitoring and

Reporting11

An ESIA and ESMS have been prepared for the SCPx by a third party. ESIA

appears comprehensive, having been produced in line with the requirements of the SCP Host Government Agreement (aligned with International Standards). Several activities in the ESIA were deemed yet to be finalised, including: Waste Disposal; sourcing of aggregates and other construction materials; river crossing methodologies; temporary access roads to the ROW. Documentary evidence as to progress / resolution of these issues is required. There is a

comprehensive Guide to Land Acquisition and Compensation that is stated to form the basis for the Land Acquisition and Compensation Framework. The emphasis of the ESIA is on the construction and less so on the operational and decommissioning phase. An overarching Environmental and Social

The environmental and social impacts have been assessed through a systematic

process applied for all Project components as identified through the ESIA scoping and through engagement with key Government stakeholders in Azerbaijan. This is the latest assessment for the SD Project that was initially subject to ESIA for Stage 1 in 2002. Baseline environmental and social data are comprehensive, being developed from monitoring programmes refined over a

10-year period. The impact assessment methodology is sound and consistent with GIP. The IC notes that the Project has various management plans (MPs) in place for its existing SD operations, and that these plans include measurable targets and indicators and assign clear roles and responsibilities for time-bound implementation. The social impact

High level review indicates that all major components of an international

standard ESIA are present. ESIA was conducted by relevant local and international third parties, in consultation with local authorities and appropriate engagement with stakeholders. The ESMS framework is clearly presented in the ESIA, as is the framework for each ESMP (the proposed contents for each ESMP is summarised in Section 9).

HSE policy framework is summarised, including basic objectives and content. Physical policy is not provided in the ESIA. Process for identification of risks and impacts appears robust, and consistent with the principle of GIP. Environmental and social baseline appears sufficient in all areas. The

See TAP

Albania

See TAP

Albania

10 Where the project represents a substantial extension to the client activities, confirm that Policy and supporting management systems and plans are appropriate for the new activities. 11 At appraisal stage, there will be limited information. Compliance assessment should address specific plans for monitoring and reporting (against for example ESAP requirements) and also consider whether there is evidence of weak monitoring/reporting by client on other relevant projects - which may reduce confidence in future performance.




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Policy is provided, stipulating environmental and social objectives and principles that guide the Project. The Policy is broadly aligned with the key principles of the EBRD PRs.

Management programs have been developed for the construction of the Project (i.e. not for the operational phase of the Project). The management programs sufficiently describe mitigation and performance improvement measures and actions that address the identified environmental and social risks. It is stated that operational phase management plans will be based on those developed for the construction

phase and developed prior to operations commencing. Roles, responsibilities and authorities are stipulated for the implementation of the construction phase ESMS. Clear lines of responsibilities are defined, including management representatives. Roles and responsibilities are also defined for contractors. Chapter 13: Management and

Monitoring adequately describes monitoring and review of the effectiveness of the management program, including legal compliance and contractual obligations.

management planning for the Project relies on both SD2 construction/contractor management planning and BP’s Regional Community and External Affairs team who implement

on-going consultation with potentially affected communities in the vicinity of the Sangachal Terminal. .

risks and impacts identification process considers the emissions of greenhouse gases, relevant risks associated with a changing climate, and potential trans-boundary and

cumulative effects. Environmental and social risks and impacts are suitably identified within the Project area of influence. The ESMS framework is clearly presented in the ESIA, as is the framework for each ESMP (the proposed contents for each ESMP are summarised in Section 9). Review of completed ESMPs is required to assess adequacy.

Environmental and social organisational structure and management are defined in Section 9 ESMP. Roles and responsibilities are clearly outlined in Section 9 ESMP, including that of contractors with regard to environmental and social management. Environmental, social, and cultural

monitoring procedures are proposed in Section 9 ESMP, including for pre-construction, construction, and operational phase monitoring.

PR 2. Labour and Working Conditions

Human Resource ESIA addresses the requirements for No substantial deficiencies were identified ESIA sufficiently addresses the




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Policies and Working Relationships, Child and Forced Labour, Non-Discrimination and

Equal Opportunity, Workers Organizations, Wages, benefits, and conditions of work and accommodation, Retrenchment12, Grievance Mechanism, Non-Employee Workers, Supply Chain, Security Personnel Requirements

working conditions and management of worker relationships in the ESMMS Section 16: Local Recruitment and Training Plan which details the measures in place for recruitment and training

management in line with PS2. Further verification through review and sighting of Labour, Health and Safety Management Plans, Programs, and HR Policies documentation is required. ESIA addresses the requirements for workers engaged by third parties in the ESMMS Section 16: Local Requirement and Training Plan which details the measures in place for contractor's including hiring, training, etc., in line with PS2. This review is unable to verify

whether monitoring is taking place, although it is stipulated in Section 16.

as a part of this review against labour and working conditions criteria. The SD2 construction project had maintained an excellent safety record for the period from commencement of construction to

the site visit in May 2016. The Project had amassed a total of 20.5 million man-hours, including both BP direct hire and contractors, and has achieved a very low accident frequency rate when compared to relevant industry benchmarks. At the time of the site visit there were a total of 18,976 contracted workers. The employment numbers had peaked for the construction phase and de-manning had occurred at Project sites in response to

completed work packages. The changes to Project labour requirements have been implemented through a de-manning strategy aimed at minimising the impacts of reduced employment as the Project moves towards completion. A Labour Management Committee has been put in place to discuss and resolve key HR/IR issues relevant to contracts and BP personnel working on the SD2 construction, including grievances, and

meeting records of which indicate no significant labour relations issues. The IESC notes that there is a potential for an

requirements for working conditions and management of worker relationships in Section 9 ESMP, including outlined the proposed content of the Workers MP. An

overview is provided in the Workers MP on the measures in place for recruitment and training management in line with PR2 (including legal framework, worker health and safety, contractor management, worker grievance mechanism, and monitoring). Further verification through review and sighting of the completed Workers MP, and associated

procedures, as well as HR Policies documentation is required to conduct a full review of adequacy. Child labour, worker rights and forced labour are assessed in Section 8 Assessment of Impacts and Mitigation Measures. In addition, these issues are considered in the Human Rights Impact Assessment. Section 9 ESMP indicates that provisions for protecting

the work force will be put in place (including reference to specific documents such as tender

12 Will not be applicable to many projects at appraisal stage. However, evidence, within the last 3 years of client approach to retrenchment which is not compatible with the Policy should be taken into consideration.




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increase in grievances during the de-manning process, particularly given the depressed Azeri economy and fewer future employment opportunities for particular skillsets. This will be followed

up during the next site visit.

documentation, supplier contracts, HR policy, etc.). Further validation of these documents is required to assess adequacy of measures.

A framework H&S MP is provided in Section 9 ESMP that outlines aspects to be included in the Plan, including HSE Policy, H&S Organisation, H&S Standards, Accidents and Incidents, H&S Auditing. Further validation of the full Plan is required to assess adequacy. In addition, the Local Content Plan also provides additional proposed management measures for a

responsible supply chain in compliance with GIP. The Local Content Plan also provides additional proposed management measures for a responsible supply chain in compliance with good international industry practice.

PR 3. Resource Efficiency and Pollution Prevention and Control

Resource Efficiency, Pollution Prevention and Control - Air emissions, Greenhouse Gases13, Pollution Prevention and Control - Waste waters,

High level review indicates that resources efficiency is sufficiently addressed in the ESIA. The ESMMP Section 11 Resources MP provides detailed information on the management of aggregates, water,

Oil spills and spill prevention: A key construction phase risk is the potential for spills to the environment resulting in soil and water contamination and discharge to the marine environment. Two spills over 1 barrel in volume were recorded in

High level review indicates that resource efficiency is sufficiently addressed in the ESIA. Section 8 Assessment of Impacts and Mitigation Measures is comprehensive, including detailed assessment of onshore and

13 Particular attention should be given to client demonstration of consideration of alternatives. Projects expected annually to produce more than 25,000 tonnes of Co2 equivalent should provide an emission inventory and plans for annual reporting.




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Water, Wastes, Hazardous Substances and Materials

energy efficiency and timber to sufficiently address the requirements of PS2. Chapter 10 Environmental and Social Impacts and Mitigations (Planned Activities) also provides detailed energy

consumption, water and other resources and inputs, their impacts and mitigation measures. Alternatives are considered in Chapter 4: Project Development and Evaluation of Alternatives, with options assessed against environmental and social sensitivity indicators.

2015, which were investigated and corrective and preventative actions identified and implemented. The operator has invested in improvement to oil spill response preparedness including

oil spill response planning with the Ministry of Emergency Situations and has engaged the services of oil spill responders for offshore and nearshore construction works. Waste Management: The ATA topsides fabrication yard expansion included installation of a sewage treatment plant with a capacity of treating 300m3 per day. Monitoring data indicates compliance with discharge water quality criteria. However,

the SD2 temporary onshore construction workforce sewage treatment plant at ST was not operational at the time of the site visit due to delays in obtaining permits. Alternative wastewater removal to licensed treatment facilities was in place for the work site and accommodation camp. The process to enable full operation of the temporary wastewater treatment facility by the construction contractor is well understood and in

progress, and will be monitored by the IE at the next site visit. Wastes at the offshore fabrication yards ATA and BDJF are segregated on site prior to transport to a centralised waste accumulation centre. At the centre, a BP

offshore aspects. Section 9 ESMP provides a detailed overview of the proposed content for each MP, including plans for waste, water, hazardous material management,

watercourse crossings, pollution prevention, landscape management, erosion and sediments control, and aggregates, among others, to sufficiently address the requirements of PR3. Alternatives are considered in Section 2 Project Justification.




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managed waste contractor transfers wastes to various waste treatment, recycling and disposal facilities. Approximately 500 tonnes of waste per month is generated at the ATA Yard,

including hazardous wastes. Noise and Vibration: Noise monitoring has been undertaken at the four communities near the ST, and shows regular noise levels above the daytime criteria of 65dB (LAeq). Elevated noise levels have been attributed to a range of contributing sources and have been reported back to the communities by the construction contractor. There have been no instances where the action triggers established in construction environmental

management plans has been reached. BP advised the IESC that construction noise from SD2 activities has generally not been audible at monitoring locations during the surveys and that no noise complaints have been received in Q1/2016.

PR 4. Health and Safety

Occupational Health and Safety, Community Health and Safety, Infrastructure, Building, and Equipment Design and Safety, Hazardous Materials Safety, Product and Services

General OHS programs and procedures are not included in the ESIA and therefore a full assessment is unable to be undertaken to determine compliance. Chapter 8 Socio-Economic Baseline does not appear to include any assessment of security context of the Project. The ESIA states that the existing SCPx Emergency Response Plan (ERP) will be updated to integrate the SCPX and

Occupational Health and Safety: In general, the LESC observed a strong Project health and safety culture. H&S management remains a priority at the site, particularly the ST with very few incidents reported especially considering the number of man-hours worked, compared to industry benchmarks. The project has achieved a commendable rolling 12-month Recordable Injury

Socio-Economic Baseline appears to adequately assess the social context of the Project, including health and safety. Section 8 Assessment of Impacts and Mitigations Measures evaluates risks and impacts to occupational health and safety and affected communities during all phases of the Project.




TAP Italy

Safety, Traffic and Road Safety, Natural Hazards, Exposure to Disease, Emergency

Preparedness and Response

refers to updates that will be included in the SCPX ERP. The ERP for the SCPX is insufficiently described in the ESIA to assess its adequacy. Chapter 12 Hazard Analysis and Risk Assessment

(Unplanned Events) comprehensively describes and assesses unplanned events and risks to public safety and harm to the environment including mitigation measures.

Frequency Rate (RIF) of 0.04 and a total RIF of 0.05, since the commencement of construction. Key statistics show that there have been no fatalities on the Project to date; 3 high potential incidents,

7 injuries requiring a day away from work, 18 recordable injuries, 193 first aid incidents and 520 safety near misses recorded. The IC notes the effective health and safety management structures and framework established between the Project Operator and key contractors who have all had experience in working with BP in the Caspian region since the AGT Project construction. Community Health, Safety and Security The Operator has described the HSE

leadership, planning and management, legal and regulatory framework, as well as management of contractor health and safety, security, environmental and social responsibility, and self-verification in the Programme HSE Management Plan, demonstrating an established system is in place for addressing emergencies. As with other management plans, the specific documented plans have not been publicly disclosed, which is inconsistent with the

requirements of the Lender Group policies. However, records of community engagement reviewed by the IC included communications, via public meetings, provided to potentially impacted communities on the measures proposed in response to emergencies and specific

Section 9 ESMPs provides an outline of the proposed content for the Community Health MP (including Safety and Security).

Security Personnel are addressed as per the provisions of PR 4. Section 8 Impacts Assessment and Mitigation Measures is comprehensive and includes a detailed assessment (including an HRIA). The Community Health MP includes provisions for due diligence of security providers, and training in Voluntary Principles on Security and Human Rights, and performance monitoring of security providers.

Community Grievance Mechanism is provided. An Emergency Response Plan framework and proposed contents is outlined in Section 9 ESMP. Further review once the finalised plan is available is required to assess adequacy.




TAP Italy

mitigations taken to ensure community safety during construction and operations. Furthermore, the impact of population influx to local communities was scoped

out at the ESIA Phase due to past Project experience and proven labour management practices. However, with a reduced construction workforce labour demand and fewer forward employment opportunities available in the current Azeri market, the mechanism for tracking potential impacts of the de-mobilised workforce on communities remains unclear. To enable independent verification of the available project data the IC recommends

that the next site visit include engagement with key external stakeholders on their experience and preparedness for emergencies and potential for social impacts as a result of demobilised workforce.

PR 5. Land Acquisition, Involuntary Resettlement and Economic Displacement

Avoid or minimise displacement, Consultation, Compensation for

displaced persons, Grievance mechanism, RAP/LRP documentation, RAP/LRP implementation, Monitoring

Project design is detailed in Chapter 4 Project Development and Evaluation of Alternatives - including consideration of physical and economic displacement

associated with options. Compensation and benefits appear to be compliant with PR 5 principles. The Project has developed a comprehensive Guide to Land Acquisition and Compensation that forms the basis of the Land Acquisition and Compensation

The Project induced some temporary economic displacement of fishing households in the vicinity of the export gas pipeline and monoethylene glycol

(MEG) pipeline shore crossing during the construction period when a marine exclusion zone was in place. Impact assessment on enforcement of the marine exclusion zone recognised the potential impact to small-scale fishermen, resulting in a fishing livelihood baseline

Social baseline report includes a detailed section on Land Use and Ownership. It is stated that a detailed Resettlement Action Plan and

associated Livelihoods Restoration Framework and Plan will be established and a detailed summary of the contents and objectives are stipulated. In addition a Draft Entitlements Matrix is provided in the ESIA. Further assessment once the




TAP Italy

Framework. Further documentary evidence of the framework is required to assess adequacy. Community engagement on land issues appears to be adequately detailed in the

Public Consultation and Disclosure Plan, including description of community feedback and Project responses. Grievance mechanism appears established and publicised. Resettlement and livelihood restoration baseline appears to adequately define potential impacts on land users at specific locations, to determine eligibility for compensation and assistance. The ESMMP provides procedures for the monitoring and evaluation of the

implementation of the Land MP and the Land Acquisition and Compensation Framework (pending its development). Additionally, the Guide to Land Acquisition and Compensation provides comprehensive guidance in line with PR 5 on land acquisition and resettlement. The responsibilities of the Company and the Government in resettlement are clearly delineated, including that the State will take responsibility for land

acquisition within the framework of the joint (i.e. State and Company) Land Acquisition Teams. The Guide to Land Acquisition and Compensation clearly outlines the process to be followed by all parties for all types of acquisition.

survey being undertaken to gather additional information on small-scale fishing activities within Sangachal Bay and the nearshore environment. The baseline determined that livelihood

restoration is required to compensate the fishermen’s temporary loss of access to natural resources of the Bay. The Project has developed and implemented a Fishing Livelihoods Management Plan (FLMP) which describes the mechanisms to be used to engage with Project-affected fishing households, the validation of information underpinning the impact assessment and to define priorities in relation to mitigation measures. Further, the Plan specifies measures to address

the needs of vulnerable fishing households (75% of, or 45 impacted fishing households). The Project reached agreement with the identified impacted fishing households, including support workers. The IC has reviewed the details of compensation measures which have been made to affected households and further adjusted agreements based on additional fishermen being deemed eligible and

increased payments made to accommodate for a longer period of marine exclusion. Evidence of effective engagement with affected fisherman has been reviewed including minutes of meetings, participant registers and two household surveys of eligible fishermen.

Resettlement Action Plan is available for review is required to ascertain compliance with the PS. The SEP outlines grievance mechanism that is consistent with PS

1.




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The grievance process outlined in the FLMP remains active with ongoing consideration of some issues. The IC will continue to monitor the implementation of the FLMP during the next site visit with

a focus on the resolution of residual grievances. It is recommended that the FLMP remain in place pending the outcome of the next planned independent FLMP monitoring report. Further, the IC notes that although the FLMP was disclosed by Lenders, on the ADB website, the SD2 Operator has not publicly disclosed the FLMP on the Operator’s website in local language and that such disclosure is necessary to fully comply with Lender policies and

requirements. This disclosure of key documentation is essential to verification that potentially affected fishermen have full access to the livelihood restoration mechanism outlined in the FLMP including the engagement and grievance process.

PR 6. Biodiversity and Living Natural Resources

Assessment of Biodiversity and Living Natural Resources,

Conservation of Biodiversity, Sustainable Management of Living Natural Resources

Chapter 7 Environmental Baseline appears to contain adequate detail. Chapter 10 Environmental and Social

Impacts and Mitigations (Planned Activities) also appears to address in sufficient detail the provisions of PS6.

ST environmental monitoring includes the water quality and water levels of wetlands (or wadi) located to the east of

the SD2 expansion area, in the proximity of the beach pull site. Pre-existing soil and water contamination was identified as well as possible sources of contamination from nearby pipelines and neighbouring land use. Free phase oil on water has been observed in wetlands near the neighbouring power station, and

Biodiversity risk and impacts appear well documented for both offshore and onshore, including modified,

natural and critical habitats. A Biodiversity Action Plan overview including all elements proposed for the Plan is provided (including a biodiversity offsets program). Ecosystem services are not explicitly discussed in the ESIA.




TAP Italy

the SD2 Project now maintains a monitoring programme to identify the cause of contamination at the wetlands area and monitor the ecological use of these wetlands by birds and other fauna,

the results of which are reported annually to the Ministry for Environment.

PR 7. Indigenous People

Not applicable to associated facility projects.

PR 8. Cultural Heritage

Assessment and Management of Impacts on Cultural Heritage, Consultation with affected communities

and other stakeholders, Project use of Cultural Heritage

Cultural heritage is comprehensively identified and documented in Chapter 7 Environmental Baseline Study. A thorough risk and impact assessment is conducted in Chapter 10 Environmental

and Social Impacts and Mitigations (Planned Events), indicating the application of mitigation measures that favour avoidance. A Cultural Heritage Chance Finds Process is provided in the ESMMP. Baseline indicates that surveys and consultation was conducted, and additional consultation is delineated in the ESMMP for the purposes of identification and decision-making.

The SD2 construction at ST includes provision of ongoing monitoring of potential impacts to Cultural Heritage and a watching brief for works being undertaken outside of past detailed

heritage surveys in line with the Project’s cultural heritage plan commitments. Local experts have been undertaking the monitoring in consultation with the Ministry for Culture and Tourism as cultural heritage observers, and initial surveys were completed and submitted for approval to the Ministry of Environment. A range of isolated artefacts have been identified during the watching brief of construction at ST but

no finds have been deemed to be of significant heritage value. Vibration monitoring at the Sand Cave heritage site has been undertaken by the SD2 Project to protect the site from potential damage from Project related activities in the vicinity of the shore crossing and pipeline beach pull site. The

Cultural heritage baseline appears comprehensive. The risks and impacts to Intangible cultural heritage are also assessed in a comprehensive manner. A CHMP overview and proposed

contents is defined (including a chance finds procedure).




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action trigger was not reached during monitoring, but the Project did amend the piling technique to reduce vibration in response to the monitoring results, and no damage to the Sand Cave site was

observed throughout the works.

PR9. Financial Intermediaries

Not applicable.

PR10. Information Disclosure and Stakeholder Engagement

Stakeholder Engagement Plan, Operational Grievance Mechanism, Information Disclosure

A Community Liaison Plan is defined within the ESIA that includes community relations training, establishment and maintenance of good community relations, and a grievance procedure. In addition, there is a Public Consultation

and Disclosure Plan that presents and describes the stakeholder disclosure and consultation procedures as part of the ESIA process. In sum, the plans appear substantive. Concerning disclosure, the ESIA documentation was disseminated for public review and comment for a period of 60 days, including public meetings. The Community Liaison Plan and the Public Consultation and Disclosure Plan both adequately define procedures for external communications and the lodging and resolution of grievances. Periodic reporting is adequately documented in the ESIA (i.e. of the ESIA itself), including evidence of reporting notifications and materials. In addition, there is a commitment to periodic

The IC notes that the environmental and social management plans documented for the SD2 construction phase have not been publicly disclosed during the SD2 ESIA process and are not currently available to the general public which

indicates a deficiency in conformance to Lender Group requirements. It is recommended that the SD2 Operator publicly disclose documented environmental and social management plans where these plans contain the details and commitments to manage or mitigate potentially significant environmental and social impacts of the Project. In line with stakeholder engagement and grievance management requirements, responses to affected communities, summary feedback and adjustment to management plans as a result of consultations and grievances received are recommended to be communicated back to interested stakeholders and affected communities. Verification on

Extensive engagement (analysis, planning disclosure and consultation) is documented in the ESIA in the following sections - Section 7 Stakeholder Engagement, Annex 7 Stakeholder Engagement Data, and

Annex E ESIA Disclosure indicating that engagement was conducted in accordance with IFC principles. The documentation indicates that stakeholder analysis and engagement planning was conducted, that there was adequate disclosure of Project information, and that the principles of informed consultation and participation were adhered to. A grievance mechanism is documented Section 7 Stakeholder Engagement.




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reporting to affected communities as the Project develops in both the Community Liaison Plan and the Public Consultation and Disclosure Plan.

effectiveness of engagement and grievance management with key stakeholders such as community members and representatives, commercial fishers, and local government

representatives is sought by the IESC for the next site visit.


APPENDIX A: DOCUMENT LIST

File Name Document Name Author / Company Rev / Date / Period

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\1.Topographical Map and Crossing Points - CIN_MAP_GEN_001_01 to 001_85 and CIN_MAP_GEN_002_1 to 002_6

001: Topographic map and crossing points002: Topographic Map

TANAP CINAR

2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence

Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 08 Spread-3 Drill Exercise Plan

2017 year training activity schedule SICIM

YUKSEL

2017

New Data April 17 2017 \ EBRD Questionarie on Social due diligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 09 Spread-4 Drill Exercise Plan

2017 year training activity schedule SICIM YUKSEL

2017

Documents 21122016\6.5 Completed Quarterly Third Party Monitoring Reports by ЗINAR - CIN-PRQ-PRC-GEN-009_9th quarterly monitoring report

9th QUARTERLY PROGRESS REPORT (English Version)ENVIRONMENTAL AND SOCIAL MONITORING STUDIES

CINAR TANAP

2/12/2016

2015-16 Action Status Report Action Status Report (ASR) – Environmental Monitoring

A. Selim KILIC / Tanap 1/1/2015 – 31/12/2015

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - SYA-PLN-ENV-GEN-012_P3-0

AGGREGATE MANAGEMENT PLAN SICIM – YUKSEL – AKKORD JV

04/04/2015

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - FRN-PLN-ENV-PL1-015-P4-0

AGGREGATES MANAGEMENT PLAN FERNAS iNŞAAT A.S. 16/06/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-009- Aggregates Management Plan- P4-0

Aggregates Management Plan TANAP 13-03-17

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - PLK-PLN-ENV-PL4-008_P4-C

AGGREGATES MANAGEMENT PLAN – 48’’ ONSHORE PIPELINE CONSTRUCTION LOT 4

PUNJ LLOYD-LİMAK-KALYON JV

22/06/2016

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-7.3.1.6

Agriculture and Livestock TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ BCH-CAL-ENV-CSG-001-Rev-P2-2-AIR EMISSION INVENTORY

AIR EMISSION INVENTORY TANAP iLF BEACHTEL

04.03.2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ BCH-CAL-ENV-CSG-001-Rev-P2-2-AIR EMISSION INVENTORY

AIR EMISSION INVENTORY TANAP iLF Bechtel

04.03.2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - Air Qual PM10&2_5 BL Report

AIR QUALITY (PM10&PM2.5)Baseline Report TANAP 24/7/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Quality (SO2, NOX, O3) Baseline Report - CIN-REP-ENV-GEN-010-22 Rev-P2-F_EN

AIR QUALITY (SO2, NOX, O3) Baseline Report TANAP 2/6/2014


Documents 21122016\1.1 Host Gov. & Int Agreement - E&S specific Provisions - HGA [ENG]

Amendment to “the host government agreement between the government of the republic of turkey and trans Anatolian gas pipeline company b.v. concerning the trans Anatolian natural gas pipeline system”

26/5/2014


Amphibians TANAP

Documents 21122016\8.2 List & Analysis of Stakeholders & Records of

Consultation - 8.2 Analysis of Stake Holder Consultation

Analysis of stakeholders and records of

consultation with relevant regulation authorities and stakeholders

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \Waste Facility Inspection Report \ Annex 1_Inspection checklist

ANNEX 1 CHECKLIST-WASTE MANAGEMENT 17.03.2017

New Data May 4 2017 \ Annex 1_Stakeholder Engagement Implementation Guideline For Construction... (1)

ANNEX 1 STAKEHOLDER ENGAGEMENT IMPLEMENTATION GUIDELINE FOR CONSTRUCTION PHASE

TANAP 30/01/2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Annex 1 The Analysis Reports for Seawater

Annex 1 The Analysis Reports for Seawater CINAR 2/7/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Annex 1 The Analysis Reports for

Seawater

Annex 1 The Analysis Reports for Seawater CINAR 2/7/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Annex 1 The Analysis Reports for Sediment

Annex 1 The Analysis Reports for Sediment CINAR 18/6/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Annex 1The Analysis Reports for Sediment

Annex 1 The Analysis Reports for Sediment CINAR 18/6/2013

ESIA – RAP – ANNEXES - Chp 1 – Introduction - ANNEX 1.1 - Existing & Planned Pipeline Projects

ANNEX 1.1. EXISTING AND PLANNED PİPELİNE PROJECTS IN TURKEY

ESIA – RAP – ANNEXES - Chp 1 – Introduction - ANNEX 1.2 - Detailed Tables on Project Affected Settlements

ANNEX 1.2. DETAILED TABLES RELATED TO THE PROJECT AFFECTEDSETTLEMENTS

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\11_Marine Habitat and Ecosystems Baseline Report - Biocenosis Annex- 1 to 3

Annex 1: Distribution Map of biocenosis in the local study area

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Annex 2 Field Forms for Seawater

Annex 2 Field Forms for Seawater TANAP 31/5/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Annex 2 Field Forms for Seawater

Annex 2 Field Forms for Seawater TANAP 31/5/2013


Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Annex 2 Field Forms for Sediment

Annex 2 Field Forms for Sediment TANAP 30/5/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Annex 2 Field Forms for Sediment

Annex 2 Field Forms for Sediment TANAP 30/5/2013

ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX 4.1 - Survey Questions

ANNEX 4.1 – SURVEY QUESTIONSTANAP Pipeline Project Socio-Economic Survey of Affected Land Owners and Land Users

TANAP

ESIA – RAP – ANNEXES - Chp 6 – Impact - ANNEX 6.2 - Valuation Process According to Expropriation Law

ANNEX 4.1 – Valuation Process According to Expropriation Law

Union of Chambers of Turkish Architects and Engineers

2012

ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX 4.3 - Village Headmen In-Depth Interview Summary Tables

ANNEX 4.3 - Village Headmen In-Depth Interview Summary Tables

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Annex 4_Laboratory Competency Certificate

Annex 4_Laboratory Competency Certificate CINAR

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.10 - Land Acquisition of Jointly Owned Land

ANNEX 5.10 - Land Acquisition for Jointly Owned Land

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.11 - Land Acquisition for Deceased Owner

ANNEX 5.11 – Land Acquisition Process for Deceased Owner

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.12 - Additional Information on Land Consolidation

ANNEX 5.12 – Additional Information on Land Consolidation in Turkey

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.13 - Quality Control and Reporting

ANNEX 5.13 - Quality Control and Reporting

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.14 - Land Exit Process

ANNEX 5.14 - Land Exit Process

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.15 - Transfer of Land Rights

ANNEX 5.15 - Transfer of Land Rights from LRE (BOTAS) to TANAP

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.2 - Key Steps in Land Acquisitionrev revP3-1

ANNEX 5.2 - Key Steps in Land Acquisition

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.4 - Land

Acquisition of State Pasture and Forest Land revp3-1

ANNEX 5.4 - Acquisition Procedures of State

Authority Land, Pasture Land and Forest Land

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.5 - Land Acquisition Under Customary Rights revp3-1

ANNEX 5.5 – Land Acquisition under Customary Rights

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.6 - Land Delivery Process revp3-1

ANNEX 5.6 - Land Delivery (Possession of Site) Process

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.7 - Land Entry Processrevp3-1

ANNEX 5.7 - Land Entry Process


ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.8 - Pipeline Route Deviation

ANNEX 5.8 – Pipeline Route Deviation

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.9 - Court Process Based on Article 10 of Expropriation Law revp3-1

ANNEX 5.9 - Court Process Based on Article 10 of the Expropriation Law

ESIA – RAP – ANNEXES - Chp 6 – Impact - ANNEX 6.1 - Additional Tables and Figures

ANNEX 6.1. Additional Tables and Figures of Chapter 6

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 06 SitePlus Security Due Diligence Report

Annex 7 Business Partner risk approval form SICIM YUKSEL AKKORD

13/06/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 07 Yuksel Guvenlik Due Diligence Report

Annex 7 Business Partner risk approval form SICIM YUKSEL AKKORD

4/06/2015

Guide to Land Aquisition and Compensation ANNEX 7.1 – Guide to Land Acquisition and Compensation (GLAC)LAND ACQUISITION

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Contamination Baseline Study Report - Annex I_The Analysis Reports

Annex I The Analysis Reports for Soil CINAR 2/12/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Contamination Baseline Study Report - Annex II_Field Forms

Annex II_Field Forms for Soil TANAP 1/11/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Annex IV_Laboratory Competency Certificate

Annex IV Laboratory Competency Certificate

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Contamination Baseline Study Report - Annex IV_Laboratory Competency Certificate

Annex IV_Laboratory Competency Certificate

BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ Appeals Committee \ APPEALS COMMITTEE_WEB ANNOUNCEMENTS

ANNOUNCEMENT

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ANNUAL TRAINING PLAN AND TOPICS

ANNUAL TRAINING PLAN AND TOPICS

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.16 - Application of Article 27revp31

App 5.16 Application of Article 27

BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ Appeals Committee \ TNP-SOC-FRM-006 Appeals Committee_Application Form

APPEALS COMMITTEE APPLICATION FORM

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6 - Appendix %96 2.6.1. Photographs of Project Area

Appendix – 2.6.1. Photographs of Project Area TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - Appendix 4.5

APPENDIX - 4.5 IMPACT REGISTERS TANAP



APPENDIX - 4.6. LEGISLATION REGISTERS TANAP


APPENDIX - 4.7COMMITMENTS REGISTERS TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Risk Rating Matrix

APPENDIX (4) RISK ANALYSIS AND ASSESSMENT RESULTS

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps - APPENDIX 1.3_index

APPENDIX 1.3 MAPS AND PLANS TANAP

Ref Mat\Documents 21122016\1.1 Host Gov. & Int Agreement - E&S specific Provisions - TANAP HGA English Final 25062012

Appendix 1: Host government between the government of the republic of turkey and trans Anatolian gas pipeline company (attached to and forms an integral part of the Intergovernmental agreement)

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.1 APPENDIX 2.1. TECHNICAL STUDIES, FIELD STUDIES, REPORTS, ANALYSES, MAPS AND PHOTOGRAPHS

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.2 APPENDIX 2.2METEOROLOGICAL BULLETIN

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.3 APPENDIX 2.3. ANALYSES TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4 APPENDIX 2.4. REPORTS TANAP

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.5 APPENDIX 2.5. ECOLOGICAL FIELD SURVEYS OBSERVATION POINTS

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6 - APPENDIX 2.6_index

APPENDIX 2.6. PHOTOGRAPHY ARCHIVE AND LOADED DATA BANK CATALOGUE

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.7 Appendix 2.7. “ModellingReport on Emission ofCompressor Station” of ESIA REPORT

ALTOSENE 16/04/2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_APPENDIX 2.7

Appendix 2.7. “ModellingReport on Emission ofCompressor Station” of ESIA REPORT

TANAP CINAR

16.04.2014

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.8 Appendix 2.8 “Noise ModellingReport For CompressorStations ”of ESIA REPORT

OZMEALTOSENE 16/04/2014

Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2_index APPENDIX 2_index TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) - APPENDIX 3_index

APPENDIX 3 TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.1

APPENDIX 3.1. INFORMATION AND REGISTERS RELATED TO PUBLIC PARTICIPATION

TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.2_index

APPENDIX 3.2 STAKEHOLDER REGISTERS TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2d-Invitee List and Forms

APPENDIX 3.2d Invitee List for NGO Meeting and FormsINVITEES AND PARTICIPANTS

TANAP 12/11/2013


FROMNATIONAL AND INTERNATIONAL STAKEHOLDERS

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2e-List of NGOs which received Info Packs

APPENDIX 3.2e List of NGOs which received Info Packs

TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2f-Feedback forms

APPENDIX 3.2f Feedback Form TANAP


APPENDIX 3.3ANNOUNCEMENT RECORDS TANAP 12/02/2013


APPENDIX 3.4NOTIFICATION REGISTERS TANAP


APPENDIX 3.5COMPLAINT REGISTERS TANAP


APPENDIX 4.1. INFORMATION AND REGISTERS, AND AUTHORITY OPINIONS RELATED TO EIA PROCESS

TANAP


APPENDIX 4.2 SPECIAL FORMAT OF ESIA REPORT

TANAP


Appendix 5.1. Construction Impacts Management Plan

TANAP


APPENDIX 5.10. Pollution Prevention Plan TANAP


APPENDIX 5.11. Waste Management Plan TANAP


APPENDIX 5.12. Emergency Response Plan TANAP


APPENDIX 5.2. Community Safety Management Plan

TANAP


APPENDIX 5.3. Community Relations Plan TANAP

Documents 21122016\2.7 Local Hiring Plans - CIN-REP-ENV-GEN-010-45 Rev-P2-C_App. 5.4_EN

Appendix 5.4. “Employment and Training Plan” of ESIA REPORT

CINAR TANAP

2/6/2014


APPENDIX 5.4. Employment and Training Plan TANAP


APPENDIX 5.5. Procurement and Supply Management Plan

TANAP


APPENDIX 5.6. Aggregates Management Plan TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.7. Traffic Management Plan TANAP


Appendix 5.7


APPENDIX 5.8. Cultural Heritage Management Plan

TANAP


APPENDIX 5.9. Erosion, Reinstatement and Landscaping Plan

TANAP

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5_index

APPENDIX 5MANAGEMENT PLANS TANAP

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - Appendex A

Appendix A - OFF ROW AGGREGATE CONSUMPTION REGISTER

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES

APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES


Documents 21122016\1.9 Pipe Supply Contract and Prequalication Requirements - Extract from LЭne Pipe Supply Contract

Appendix A: Schedule of requirementsHealth, Safety, Social and Environmental Requirements for Suppliers and Vendors

Consulting Engineers TANAP

7/3/2014

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX A TRAINING REGISTER

APPENDIX ATRAINING REGISTER

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 -

CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX B FAUNA REGİSTER

APPENDIX B FAUNA REGİSTER

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE

APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX B.1 TERRESTRIAL



FLORA MONITORING TABLE

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE_clean/tc/pdf file


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE_tc/clean/pdf file


Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE_clean

APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE_clean


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE_clean/tc/pdf file


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE_tc/ clean / pdf file


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE

APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE


Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE


Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX B.3 FRESHWATER



FAUNA MONITORING TABLE

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - Appendex B

APPENDIX B-LIST OF QUARRIES ALONG THE LOT 4 PIPELINECORRIDOR (AS PROVIDED)

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX C SENSITIVE AREA REGİSTER

APPENDIX C SENSITIVE AREA REGİSTER

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY -ESTIMATION OF SAMPLE NUMBER AND SAMPLE LOCATION FOR SPECIES COMPOSITIONASSESSMENT

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGYESTIMATION OF SAMPLE NUMBER AND SAMPLE LOCATION FOR SPECIES COMPOSITIONASSESSMENT

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY

APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGYESTIMATION OF SAMPLE NUMBER AND SAMPLE LOCATION FOR SPECIES COMPOSITIONASSESSMENT

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.2 SITE RECORDS

APPENDIX C.2: SITE RECORDS

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.2 SITE RECORDS

APPENDIX C.2: SITE RECORDS

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.2 SITE RECORDS

APPENDIX C.2: SITE RECORDSSITE ASSESSMENT PROFORMA

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX C.2 SITE RECORDS


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX C.2 SITE RECORDS


Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.3 SITE ASSESSMENT CHECKLIST


8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.3 SITE ASSESSMENT CHECKLIST

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX C.3 SITE ASSESSMENT CHECKLIST

APPENDIX C.3 SITE ASSESSMENT CHECKLIST

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX C.3 SITE ASSESSMENT CHECKLIST


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.3 SITE ASSESSMENT CHECKLIST


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.3 SITE ASSESSMENT CHECKLIST


Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.4 ESTIMATING PERCENT COVER

APPENDIX C.4 ESTIMATING PERCENT COVER

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX C.4 ESTIMATING PERCENT COVER


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.4 ESTIMATING PERCENT COVER


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.4 ESTIMATING PERCENT COVER


Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX C.4 ESTIMATING PERCENT COVER

APPENDIX C.4 ESTIMATING PERCENT COVER – VISUAL GUIDE TO ESTIMATING PERCENTAGE COVER

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.5 CALCULATION OF NDVI VALUES

APPENDIX C.5 CALCULATION OF NDVI VALUES

Documents 21122016\6.1 Description of Timing and Baseline Survey

Methodologies\BAP\Annex-8\Appendices - APPENDIX C.5 CALCULATION OF NDVI VALUES


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX C.5 CALCULATION OF NDVI VALUES


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.5



CALCULATION OF NDVI VALUES

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.5 CALCULATION OF NDVI VALUES


Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – Appendices - APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS

APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-8\Appendices - APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS


New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS


New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS


ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX D WATERCOURSE CROSSİNG REGISTER

APPENDIX D WATERCOURSE CROSSİNG REGISTER

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX E REINSTATEMENT REGISTER

APPENDIX E REINSTATEMENT REGISTER

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX F TREE_SHRUB CUT & RELOCATED REG

APPENDIX F TREE/SHRUB CUT & RELOCATED REGISTER

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - APPENDIX G MAJOR RIVER CROSSINGS

APPENDIX G MAJOR RIVER CROSSINGS


Report-02.03.2017 \ PR1(1.6) \ Appendix M Environmental and Social

Appendix M: Environmental and Social

Management for 56” Onshore Pipeline Construction

22.04.2014

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX 4_index

APPENDIX-4 TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 03 TANAP-WRP-LET-SYA-0069

Approval of subcontracts WorleyParson 14/04/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Approval of subcontracts SICIMYUKSELAKKORD JV 24/03/2015


Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 02 TANAP-SYA-LET-WRP-0066


Aquatic Invertebrates TANAP


Aquatic Vegetation TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.5. Archaeological Baseline Studies - 5. Archaeological Baseline Studies

Archaeological Baseline Studies 25/5/2014

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\9.Archaeological Areas Map - CIN_MAP_ARC_001_01 to 001_63

Archaeological site map TANAP CINAR

2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report - Annex 1 Archaeological Status Table 29052014

Archaeological Status Table 29/5/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report - Annex 2 Archaeological Survey Forms29052014

Archaeological Survey Forms REGIO 29/5/2014


Areas Under The Provision of Government (Military Prohibited Zones, Areas Allocated to State Institutions and Organizations with Special Purposes, “Restricted Areas” by Cabinet Decree no. 7/16349, etc.)

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\13_Terrestrial Fauna Baseline Report - Ek 7 -Arthropoda Field Forms

Arthropoda Field Forms 1/05/2013

ESIA – ESMS Docs – ESIA – Chapter 9 ASSESSMENT OF AREAS TO BE GIVEN UP IN THE PROJECT

TANAP

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-7.3.5

Assessment of Offshore Biological Environment TANAP


Assessment of Offshore Socio-Economic Environment

TANAP

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.3 Assessment of On Shore Social Characteristics TANAP

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-

7.3.3

Assessment of Onshore Socio-Economic

Environment

TANAP

Documents 21122016\11.1 Copies of All Presentations - EBRD Attendance Sheet

Attendance sheet TANAP Worley Parsons

Documents 21122016\6.9 BAP Monitoring Plans for Contractors - 6.9 BAP Monitoring Plans for Contractors (Read Me)

BAP Monitoring Plans for Contractors (Read Me)

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\7.Baseline Map - CIN_MAP_BAS_001_01 to 001_41

Baseline Map (Surveying Map) TANAP CINAR

2014


Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Basis of Design Pipeline Crossings of Active Tectonic Faults - WRP-REP-PPL-GEN-017

Basis of Design: Pipeline Crossings of Active Tectonic Faults

TANAP WorleyParsons

14/10/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ BAT Assessment Report

BAT Assessment Report TANAP iLF BEACHTEL

10.03.2014

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-7.3.2.14A

Biodiversity TANAP

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP - CIN-REP-ENV-GEN-017-Rev-P3-6

BIODIVERSITY ACTION PLAN CINAR TANAP

12/10/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ CIN-REP-ENV-GEN-017-Rev-P3-9

BIODIVERSITY ACTION PLAN TANAP CINAR

31.01.2017

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ CIN-REP-ENV-GEN-017-Rev-P3-10

BIODIVERSITY ACTION PLAN TANAP CINAR

02/05/2017

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ CIN-REP-ENV-GEN-017-Rev-P3-10.pdf \ CIN-REP-ENV-GEN-017-Rev-P3-10

BIODIVERSITY ACTION PLAN CINAR TANAP

02/05/2017

Revised 12.10.2016 - Biodiverity action plan (BAP) - Modification Register_12102016

BIODIVERSITY ACTION PLAN (BAP) MODIFICATION REGISTER

CINAR

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Modification Register_clean


TANAP CINAR

20/04/2017

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \Modification Register_clean.docx \ Modification Register_clean


CINAR TANAP

20/04/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ BAP_final draft \ Modification Register


TANAP CINAR

20/04/2017

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Modification Register_31012017

BIODIVERSITY ACTION PLAN (BAP)MODIFICATION REGISTER

TANAP CINAR

31.01.2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ BAP_final draft \ CIN-REP-ENV-GEN-017-Rev-P3-11_tc

BIODIVERSITY ACTION PLAN (Review P3-11) TANAP CINAR

18/05/2017

ESIA – ESMS Docs – BAP - BAP_CIN-REP-ENV-GEN-017_P3-4 Biodiversity Action Plan (The Trans-Anatolian Natural Gas Pipeline Project)

CINAR 12/07/2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\12_Freshwater Fauna Baseline Report - Freshwater Fauna BL Rep

BIOLOGICAL / FRESHWATERFAUNA BASELINE REPORT 2

OZEC 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\14_Freshwater Flora Baseline Report - Freshwater Flora BL Report

BIOLOGICAL / FRESHWATERFLORA BASELINE REPORT

DUMH 13/2/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\18_Freshwater Habitat and Ecosystems Baseline Report - Freshwater Habitat and Ecosystems BLReport

BIOLOGICAL / FRESHWATERHABITATS AND ECOSYSTEMSBASELINE REPORT

DUMH 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\10_Marine Biological / Marine BiodiversityBaseline Report KATT 27/1/2014


Biodiversity Baseline Report - Marine Biodiversity BL Rep CINM

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Fauna BL Report - Marine Fauna BL Report

BIOLOGICAL / MARINE FAUNABASELINE REPORT

KATT CINM

23/1/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\8_Marine Flora Baseline Report - Marine Flora BL Rep

Biological / Marine FloraBaseline Report TASE CINM

27/1/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\11_Marine Habitat and Ecosystems Baseline Report - Marine Habitat&Ecosystem BL Rep

Biological / Marine Habitats andEcosystems Baseline Report

KATT CINM

28/1/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\9_Marine Protected Areas Baseline Report - Marine Protected Areas BL Rep

Biological / Marine ProtectedAreas Baseline Report

CINM 30/1/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\17_Terrestrial Biodiversity Baseline Report - 17_Terrestrial Biodiversity Baseline Report

BIOLOGICAL / TERRESTRIALBIODIVERSITY BASELINEREPORT

HASA 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\13_Terrestrial Fauna Baseline Report - Terrestrial Fauna BL Report

BIOLOGICAL / TERRESTRIALFAUNA BASELINE REPORT

HASA 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\15_Terrestrial Flora Baseline Report - Terrestrial Flora Baseline Report

BIOLOGICAL / TERRESTRIALFLORA BASELINE REPORT

DUMH 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\19_Terrestrial Habitat and Ecosystems Baseline Report - Terrestrial Habitat and Ecosystems BL Rep.

BIOLOGICAL / TERRESTRIALHABITATS AND ECOSYSTEMSBASELINE REPORT

DUMH 7/2/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\16_Terrestrial Protected Areas Baseline Report - 16_Terrestrial Protected Areas Baseline Report

BIOLOGICAL / TERRESTRIALPROTECTED AREAS BASELINEREPORT

HASA 2/6/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.3. Biological Baseline Studies - 3. Biological Baseline Studies

Biological Baseline Studies CINAR

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\6.Biological Sampling Stations Map - CIN_MAP_BIO_001_01 to 001_41

Biological Sampling Stations Map TANAP CINAR 2014

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-8_Biorestoration Monitoring Plan – CIN-PLN-ENV-GEN-014-Rev-P3-1

BIORESTORATION MONITORING PLAN CINAR 10/2016

Documents 21122016\6.1 Description of Timing and Baseline Survey

Methodologies\BAP\Annex-8 - CIN-PLN-ENV-GEN-014-Rev-P3-1

BIORESTORATION MONITORING PLAN TANAP

CINAR

12/10/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ CIN-PLN-ENV-GEN-014-Rev-P3-2

BIORESTORATION MONITORING PLAN TANAP CINAR

31.01.2017

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-8 \ CIN-PLN-ENV-GEN-014-Rev-P3-2

BIORESTORATION MONITORING PLAN CINAR TANAP

31/01/2017

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ BIORESTORATION MONITORING PLAN CINAR 1/2017


CIN-PLN-ENV-GEN-014-Rev-P3-2 TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\13_Terrestrial Fauna Baseline Report - Ek 5- Bird Field Forms

Bird Field Forms TANAP 21/2/2013


Birds TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\25_Geotechnical Survey Borelogs - BoreLog Rep5-TR

Boring Log TANAP SOCAR

4/10/2013


Boring log TANAP SOCAR SEBAT

17-26/9/2013



30/10 – 6/11/2013



27-30/9/2013


Boring Log TANAP SOCAR

4-7/10/2013


Boring log TANAP SOCAR

29/8 – 1/9/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\25_Geotechnical Survey Borelogs - BoreLog RepCS-TR


5-20/2/2014

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Buoyancy Calculation - WRP-CAL-PPL-PLG-006

Buoyancy Calculation TANAP WorleyParsons

23/9/2015

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 4 SVAN CALIBRATOR new

Calibration report Protos 30/10/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 4 SVAN CALIBRATOR

Calibration report Protos 6/6/2013

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Access Control ID Check \

Sample ID Badges

CAMP ID CARDS

Documents 21122016\3.6 Construction Camp Site Drainage Management Process - PLK-PLN-ENV-PL4-004_Camp management plan_Lot 4

CAMP MANAGEMENT PLAN (LOT 4) TANAP WorleyParsons

4/8/2016

Documents 21122016\3.6 Construction Camp Site Drainage Management Process - FRN-PLN-ENV-PL1-002_Camp management plan_Lot 1

Camp Management Plan (LOT1) TANAP WorleyParsons FERNAS

11/5/2015


Documents 21122016\3.6 Construction Camp Site Drainage Management Process - SYA-PLN-HSE-GEN-012_Camp management plan_Lot 2

Camp Management System (LOT2) SYA ‐ Sicim‐Yuksel‐Akkord JV

TANAP WorleyParsons

5/5/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-003-P4-2 (SEC. PLAN SPRD-5)

Camp Security Plan For Spread-5 TANAPTEKFEN 15.12.2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-004-P4-2 SEC. PLAN SPRD-6

Camp Security Plan For Spread-6 TANAP TEKFEN

15.12.2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 4 Yuksel Guvenlik Securty license

Certificate of operating permit for private security company

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ certificate

Certificate of participation as trainer

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - WRP-PCD-ENV-GEN-003

Chance Finds Procedure WorleyParsons 14/04/2015

ESIA – ESMS Docs – ESIA – Chapter 2 Chapter 2 PROJECT DESCRIPTION TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_CH-2

CHAPTER 2: TRANS ANATOLIAN NATURAL GAS PIPELINE (TANAP) PROJECT ESIA REPORT

TANAP


Chapter 7.3.1.1 Meteorological and Climatic Characteristics

TANAP

Documents 21122016\3.1 Hydrotest Management Plan – Procedure - TNP-REP-ENV-GEN-002_CH-8.1

CHAPTER 8.1 Assessment Of Impacts On Physical Components

TANAP

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.1 Chapter 8.1 Assessment Of Impacts On Physical Components

TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ TNP-REP-ENV-GEN-002_CH-8.1

CHAPTER 8.1 Assessment Of Impacts On Physical Components

TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_CH-8.1

CHAPTER 8.1: TRANS ANATOLIAN NATURAL GAS PIPELINE (TANAP) PROJECT ESIA REPORT

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 2 Field Forms_PM10

ÇINAR ENVIRONMENTAL MEASUREMENT AND ANALYSIS LABORATORY PM 10 SAMPLING FORM

CINAR 21/12/2010

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex III_CINAR Laboratory Competency Certificate

CINAR Laboratory Competency Certificate CINAR

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY COMMUNITY RELATIONS MANAGEMENT PLAN FERNAS 19/06/2015


RELATIONS PLANS OF CCs - FRN-PLN-SOC-PL1-005_P4-0

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY RELATIONS PLANS OF CCs - PLK-PLN-SOC-PL4-002_P4-2

COMMUNITY RELATIONS MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 14/06/2016

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY RELATIONS PLANS OF CCs - SYA-PLN-SOC-GEN-002_P4-0

Community Relations Management Plan SYA ‐ Sicim‐Yuksel‐Akkord JV

21/05/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.7) \ FRN-PLN-SOC-PL1-005

Community Relations Management Plan TANAP FERNAS

19.01.2017

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \

1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-002- Community Relations Plan- P4-0

Community Relations Plan TANAP 16-02-17

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY SAFETY MANAGEMENT PLANS OF CCs - FRN-PLN-SOC-PL1-004_P4-0

COMMUNITY SAFETY MANAGEMENT PLAN FERNAS 17/06/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY SAFETY MANAGEMENT PLANS OF CCs - PLK-PLN-SOC-PL4-005_P4-0

COMMUNITY SAFETY MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 15/06/2016

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY SAFETY MANAGEMENT PLANS OF CCs - SYA-PLN-SOC-GEN-001_P4-0

Community Safety management plan SYA ‐ Sicim‐Yuksel‐Akkord JV

07/05/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-001- Community Safety Management Plan- P4-0

Community Safety Management Plan TANAP 02-02-17

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ WRP-REP-MEC-GEN-001-P3-2. Technical bid evaluation report.emission values

COMPRESSOR STATION 1 - DESIGN CASE PERFORMANCE DETAIL

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\26_ENVID Report - 26_ENVID Report

Compressor Station Environmental Impact Identification (ENVID) REPORT

2013

ESIA – ESMS Docs – ESIA – Chapter 12 Conclusion TANAP

Documents 21122016\3.6 Construction Camp Site Drainage Management Process - TKF-PLN-ENV-PL3-012_Camp management plan_Lot 3

Construction Camp Management Plan (LOT 3) Tekfen TANAP

16/4/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-ENV-PL4-003_P4-1 - PLK-PLN-ENV-PL4-003_P4-1

CONSTRUCTION IMPACT MANAGEMENT PLAN PUNJ LLOYD – LİMAK JV 10/06/2016

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - FRN-PLN-ENV-PL1-003_P4-1

CONSTRUCTION IMPACT MANAGEMENT PLAN FERNAS 15/06/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-002- Construction Impact Management Plan- P4-0

Construction Impact Management Plan TANAP 07-03-17

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLAN SYA ‐ 28/05/2015


CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN-ENV-GEN-008_P4-0 - SYA-PLN-ENV-GEN-008_P4-0

Sicim‐Yuksel‐Akkord JV

Documents 21122016\6.7 Procedures Management Plan for Invasive Species - SYA-PLN-ENV-GEN-008_Construction impacts management plan(revised)

CONSTRUCTION IMPACTS MANAGEMENT PLAN TANAP Worley Parsons SICM YUKSEL AKKORD JV

11/11/2016

Documents 21122016\4.5 Country Industry Project Safety Zone Distances from AGI's - 4.5 Country Industry Project Safety Zone

Distances

Country Industry Project Safety Zone Distances

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-004 Crissis Management Plan

CRISIS MANAGEMENT PLAN TANAP FERNAS

21.02.2017

Documents 21122016\8.1 Criteria for Avoiding Salvage Excavation of Cultural Heritage - 8.1 Criteria for Avoiding Salvage Excavation of Cultural Heritage (Read me)

Criteria for Avoiding Salvage Excavation of Cultural Heritage (Read me)


Critical Habitats TANAP

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - LOT 1- FRN-PLN-ENV-PL1-016

Cultural Heritage Management Plan FERNAS 27/01/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - LOT 2- SYA-PLN-ENV-GEN-006

Cultural Heritage Management Plan SYA ‐ Sicim ‐ Yuksel‐Akkord JV

04/05/2015

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - LOT 3- TKF-PLN-ENV-PL3-018

Cultural Heritage Management Plan Tekfen 14/05/2015

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - LOT 4- PLK-PLN-ENV-PL4-009

CULTURAL HERITAGE MANAGEMENT PLAN PUNJ LLOYD – LİMAK JV 05/06/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - TNP-PLN-ENV-GEN-006

CULTURAL HERITAGE MANAGEMENT PLAN 19/07/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-007-Cultural Heritage Management Plan-P4-C

Cultural Heritage Management Plan TANAP 15-10-16

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex B - Annex B_ Chance Finds Procedure of EPCM and CHMP of CCs

CULTURAL HERITAGE MANAGEMENT PLAN - ANNEX B CHANCE FINDS PROCEDURE OF EPCM AND CHMP OF CCS

19/07/2016

Documents 21122016\8.3 Cultural Heritage Management Plan - 8.3 Cultural Heritage Management Plan (Read me)

Cultural Heritage Management Plan (Read me)

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex D

CULTURAL HERITAGE MANAGEMENT PLANANNEX D SCOPE OF WORK ARCHAEOLOGY CONSULTANT

19/07/2016


ESIA – ESMS Docs – ESIA – Chapter 10 Cumulative and Global Impact Assessment TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Fauna BL Report - Annex 5_Hard Bottom Macrobenthos Field Forms

Daily activities report form: Annex 5_Hard Bottom Macrobenthos Field forms

TANAP 2/9/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Fauna BL Report - Annex 3_Fish Field Forms

Daily activities report form: Fish field forms TANAP 2/9/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Fauna BL Report - Annex 4_Soft Bottom Macrobenthos Field Forms

Daily activities report form: Soft Bottom Macrobenthos Field forms

TANAP 2/9/2013


Determination of Baseline Pollutant Load in the Project Area and in Impact Area (in terms of Air, Water, Soil, Noise etc.)

TANAP

Documents 21122016\2.1 Fatique Man. Guidelines & Man. Plan - TNP-MAN-HSM-GEN-001-Rev-P2-0_EN

Diver Manual DRIVING STANDARDS AND APPLICATIONSFOR TANAP PROJECT

TANAP 21/8/2014

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ TNP-PCD-SOC-GEN-003-Draft RAP Fund Management Procedure

DRAFT-TANAP RAP FUND MANAGEMENT PROCEDURE

TANAP 23/05/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ Security Drills in Gonen - Karaorman 2017 \ Gonen Drill and Karaorman DrillL

Drill / Execution TANAP 03/02/2017

Documents 21122016\2.1 Fatique Man. Guidelines & Man. Plan - HED-PCD-HSM-GEN-001-Rev-P2-2_EN

Driver and vehicle Management procedure HED Academy TANAP

8/8/2016

New Data 15 May 2017 \ BAP_Presentation_EBRD_11_05_2017_R1 ECOLOGICAL STUDIES TANAP CINAR

11/05/2017

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLANS OF CCs - FRN-PLN-SOC-PL1-001_P4-0

EMPLOYMENT AND TRAINING PLAN FERNAS 17/06/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLANS OF CCs - PLK-PLN-SOC-PL4-003_P4-2

EMPLOYMENT AND TRAINING PLAN PUNJ LLOYD-LIMAK JV 14/06/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-003- Employment and Training Plan-P4-D

Employment and Training Plan TANAP 15-03-17

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.7) \ FRN-PLN-SOC-PL1-001

Employment and Training Plan TANAP FERNAS

19.01.2017

Documents 21122016\2.7 Local Hiring Plans - FRN-PLN-SOC-PL1-001-P4-0-C1

Employment and training plan (Lot 1) Worley Parsons TANAPFERNAS

17/6/2015

Documents 21122016\1.2 Process & Timeline for transfer of Org - ENV-SOC REMAINING DOCUMENT REVISION STATUS 16122016

Environment and social remaining document revision status

Documents 21122016\1.2 Process & Timeline for transfer of Org - ENV- Environment and social remaining document


SOC REMAINING DOCUMENT REVISION STATUS 16122016 revision status

Documents 21122016\11.1 Copies of All Presentations - EBRD-_ENV DEPT

Environment Department 29/11/2016 TANAP FERNAS

29/11/2016

ESIA – ESMS Docs – ESMP - TNP-PLN-ENV-GEN-001_P3-1 ENVIRONMENTAL & SOCIAL MANAGEMENT PLAN

TANAP 21/07/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-008- Environmental & Social Monitoring Plan- P4-0

Environmental & Social Monitoring Plan TANAP 27-02-17

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-008- Environmental & Social Training Plan -P4-D

Environmental & Social Training Plan Sapura Kencana

12-01-17

ESIA – ESMS Docs – ESMP – EAP - TNP-PLN-ENV-GEN-002_P3-2 Environmental Action Plan TANAP 20/07/2016

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan - TNP-PLN-ENV-GEN-002

Environmental Action Plan TANAP 24/11/2014

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes - Annex 2-ESMP of EPCM (WRP-PLN-ENV-GEN-002_P4-2)

Environmental Action Plan Annex 2-ESMP of EPCMEnvironmental and Social Management system

TANAP Worley Parsons

20/7/2016

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes\Annex 5-Sensitive Biodiversity Areas - TNP-PLN-ENV-GEN-002-P3-2_Annex 5_clean

ENVIRONMENTAL ACTION PLAN ANNEX 5 SENSITIVE BIODIVERSITY AREAS (MS. Word)

TANAP 20/7/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 1-National and Internatiol Standards

ENVIRONMENTAL ACTION PLANANNEX 1 NATIONAL AND INTERNATIONAL STANDARDS OF TANAP PROJECT

TANAP 20/07/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 2-ESMP of EPCM (WRP-PLN-ENV-GEN-002_P4-2)

ENVIRONMENTAL ACTION PLANANNEX 2 ESMP OF EPCM

WorleyParsons 11/01/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Annex 3-CC Sub-Management Plans

ENVIRONMENTAL ACTION PLANANNEX 3 CC SUB-MANAGEMENT PLANS

20/07/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 4- Environmental Management Guidelines for Contractors

ENVIRONMENTAL ACTION PLANANNEX 4 ENVIRONMENTAL MANAGEMENT GUIDELINES FOR CONTRACTORS

24/11/2014

ESIA – ESMS Docs – ESMP – EAP - Annex 5-Sensitive Biodiversity Areas

- TNP-PLN-ENV-GEN-002-P3-2_Annex 5

ENVIRONMENTAL ACTION PLANANNEX 5

SENSITIVE BIODIVERSITY AREAS

20/07/2016

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes\Annex 5-Sensitive Biodiversity Areas - TNP-PLN-ENV-GEN-002-P3-2_Annex 5

ENVIRONMENTAL ACTION PLANANNEX 5 SENSITIVE BIODIVERSITY AREAS (PDF)

TANAP 20/7/2016

ESIA – ESMS Docs – ESIA – Chapter 11 Environmental and Social Management TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-001- Environmental & Social

Environmental and Social Management Plan TANAP 31/01/2017


Management Plan- P4-2

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-007- Environmental Emergency Response Plan- P4-C

Environmental Emergency Response Plan TANAP 31-10-16

Documents 21122016\3.1 Hydrotest Management Plan – Procedure - SYA-PLN-ENV-PL2-001.Environmental Hydrotest Monitoring Plan

ENVIRONMENTAL HYDROTEST MONITORING PLAN

TANAP Worley Parsons SICIM – YUKSEL – AKKORD JV

18/11/2016

ESIA – ESMS Docs – ESMP - Env Mon Plan - TNP-PLN-ENV-GEN-003_P3-2

ENVIRONMENTAL MONITORING PLAN TANAP 01/07/2016

ESIA – ESMS Docs – ESMP - Env Mon Plan - Annex 2 - TNP-PLN-ENV-GEN-003-Rev-P3-1 Annex 2

ENVIRONMENTAL MONITORING PLANANNEX 2 ENVIRONMENTAL STANDARDS FOR MONITORING

TANAP 01/07/2016

Documents 21122016\6.6 Records of Seed Collection - TNP-REG-ENV-GEN-008_Environmental Monthly Summary Registers

Environmental monthly registers summary report – September 2016

TANAP 26/10/2016

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental Master Plan and Legends - CIN_MAP_EMP_001_01 to 001_67

Environmental Plans (ARDAHAN) TANAP CINAR

2014

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 1 EPCM Environment and Social Management System

WorleyParsons 11/01/2016

ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.3 Erosion, Reinstatement and Landscaping Plan for LOT-2

Erosion Control, Reinstatement & Landscaping Plan

SYA ‐ Sicim‐Yuksel‐Akkord JV

25/05/2015


EROSION, REINSTATEMENT AND LANDSCAPING PLAN

FERNAS 11/12/2015



PUNJ LLOYD – LİMAK Joint Venture

06/06/2016

Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-6_Contractor Documents - Annex-6.5 Erosion, Reinstatement and Landscaping Plan for LOT-4


PUNJ LLOYD – LİMAK - KALYON JV

01/07/2016

Documents 21122016\10.1 NGO & International NGO TANAP Meeting Minutes - ERM-REP-ENV-GEN-003-Rev-P2-0_NGO Meeting Report

ESIA of TANAP ProjectSTAKEHOLDER CONSULTATION MEETINGS REPORT

TANA PERM

17/1/2014

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ Off-shore ESIA summary

ESIA Report Summary Evaluations for Off-shore Section

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-007 Evacuation PLan

Evacuation Plan TANAP FERNAS

21.02.2017

RAP Executive Summary Executive Summary (Natural Gas Pipeline Project)

Revised 12.10.2016 - Executive Summary_BAP - CIN-REP-ENV-GEN-022- EXECUTIVE SUMMARY OF BAP (English Version) CINAR 10/2016


Rev-P3-C_en

Documents 21122016\4.4 Explosives Management Plan - 4.4 Explosives Management Plan (Read Me)

Explosives Management Plan

ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.3 - Expropriation Law (2942)

EXPROPRIATION LAW

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Fault Crossing Engineering Critical Assessment Report - WRP-REP-PPL-PLG-056

Fault Crossing Engineering Critical Assessment Report

TANAP WorleyParsons

27/6/2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\12_Freshwater Fauna Baseline Report - 1. Fieldwork Forms

Fauna (Fish and Macroinvertebrate) Survey Form

7/7/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\12_Freshwater Fauna Baseline Report - 2. Fieldwork Forms

Fauna (Fish and Macroinvertebrate) Survey Form

29/10/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - Annex II_Field Forms

Field Forms CINAR

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 2 Field Forms_PM2_5&PM10

Field Forms_PM2_5&PM10 TANAP

RAP for Pipeline Final Addendum to RAP for TANAP Pipeline Route (The Trans-Anatolian Natural Gas Pipeline Project)

TANAP 21/10/2016

Addendum to RAP for Pipeline FINAL ADDENDUM TORESETTLEMENT ACTION PLAN (RAP) FOR TANAP PIPELINE ROUTE - EXECUTIVE SUMMARY

RAP for AGIs Final RAP for AGIs – Final Resettlement Action Plan for Above Ground Installations (The Trans -Anatolian Natural Gas Pipeline)

24/10/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR10(10.3) \TNP-PLN-SOC-GEN-008-RAP for AGIs_smallsize

Final resettlement action plan (RAP) for above ground installations

TANAP 24/10/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\CIN-PLN-SOC-GEN-002_Offshore Fisheries LRP

FISHERIES LIVELIHOOD RESTORATION PLAN TANAP CINER

10/05/2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX

2.4\15_Terrestrial Flora Baseline Report - Annex IV_Flora Field Forms

Flora Field Forms 1/5/2013


Forest Areas TANAP

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\4.Forestry Map - CIN_MAP_FRS_001_01 to 001_85

Forest Map TANAP CINAR 2014

Revised 12.10.2016 - Biodiverity action plan (BAP) - Critical Habitats KMZ Files

Freshwater Critical Habitats



Freshwater Fishes TANAP


Freshwater Habitats and Ecosystems TANAP

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Geohazard Assessment Report - ILF-REP-ROU-PLG-005-Rev-P1-0

Geohazard Assessment Report TANAP 12/7/2013

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Geohazard Close Out Report 48 Section - WRP-REP-EGG-PLG-026

Geohazard Close Out Report 48 Section TANAP WorleyParsons

9/11/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Geohazard Close Out Report 56 Section - WRP-REP-EGG-PLG-025

Geohazard Close Out Report 56 Section TANAP WorleyParsons

9/9/2015

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\2.Geological Map and Geohazards - CIN_MAP_GEO_001_01 to 001_85

Geologic Map and Geohazards TANAP CINAR

2014


Geological Characteristics TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 1 - Decision of Erzincan Governerate

Governorship of Erzincan Decision of the provincial private security commission

Documents 21122016\1.6 Routing Report - Feasibility Study - TNP-GUI-ROU-PLG-001

Guideline for route confirmation, centreline design and baseline field study

TANAP SOCAR

15/08/2012

New Data 15 May 2017 \ TNP-PCD-HSM-GEN-025_Incentive programme H&S incentive programme procedure TANAP 21/04/2017

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\5.Habitat Map - CIN_MAP_HAB_001_01 to 001_85

Habitant Map TANAP CINAR

2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.5)&PR4(4.1) \ FRN-PCD-HSE-PL1-045 health and industrial hygiene procedure

HEALTH AND INDUSTRIAL HYGIENE PROCEDURES

TANAP WorleyParsons FERNAS

25.04.2015

ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.2 - HGA Host Government Agreement between the government of the republic of Turkey and Trans Anatolian Gas Pipeline Company B.V. Concerning

the Trans Anatolian Natural Gas Pipeline System

26/06/2012


Hydrogeological Characteristics TANAP


Hydrological Characteristics TANAP

Documents 21122016\3.1 Hydrotest Management Plan – Procedure - 3.1 Hydrotest MAnagement Plan (Read me)

Hydrotest MAnagement Plan (Read me)


ESIA – ESMS Docs – ESIA – Chapter 3 IMPACT ASSESSMENT APPROACH AND METHODOLOGY

TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report - Annex 5 Impact Asessment Forms29052014

Impact Assessment Forms 29/5/2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7-28.02.2017 ROW Securi

INFORMATION TABE AND MACHINERY & SECURITY PERSONS FOR ROW SPREAD 7

28/02/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 2-SP-8 28.02.2017 ROW

INFORMATION TABE AND MACHINERY & SECURITY PERSONS FOR ROW SPREAD 8

28/02/2017

Documents 21122016\5.1 Documented Evidence of RAP Communication Consultation Disclosure - 5.1 Tanap_AGI RAP Disclosure Leaflet-ENG_Oct2016

INFORMATIVE LEAFLET FOR COMPENSATION OF LOSS OF LAND AND ECONOMIC LOSSES DUE TO LAND ACQUISITION ACTIVITIES FOR ABOVE GROUND INSTALLATIONS

TANAP 10/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Access Control ID Check \ Instructions On Ways of Conduct At Main Gates

Instructions On Ways of Conduct At Main Gates

Documents 21122016\1.1 Host Gov. & Int Agreement - E&S specific Provisions - TANAP IGA English Final 25062012 (2)

Intergovernmental agreement between the government of the republic of turkey and the

government of the republic of Azerbaijan concerning “The trans Anatolian natural gas pipeline system”

ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.1 - IGA Intergovernmental Agreement between the government of the Republic of Turkey and The Government of the republic of Azerbaijan concerning the trans Anatolian Natural Gas Pipeline System

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-7.1&7.2

Introduction of Environmental Baseline Features TANAP

ESIA – ESMS Docs – ESIA – Chapter 1 Introduction of TRANS-ANATOLIAN NATURAL GAS PIPELINE (TANAP) PROJECT ESIA REPORT

TANAP

Documents 21122016\1.3 Contractor Man. Pro & Non-Conformance Sys - 1.3 Contractor Man Pro & Non-Conformance System

Item 1.3 Contractor Management Procedures and Non-Conformance system – details of how used and financial penalty structure

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A IV_Laboratory Competency Certificate

Laboratory Competency Certificate CINAR


Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - Annex IV_Laboratory Competency Certificate

Laboratory Competency Certificate

Documents 21122016\2.2 Turkish Labour Law (in English) - Turkish Labor Law

LABOUR LAW 22/3/2003

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-003- Land Acquisition Plan- P4-C

Land Acquisition Plan TANAP 14-11-16

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.1 - Land Acquisition Strategy

LAND ACQUISITION STRATEGY iLF 22/08/2013

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\3.Land Use Map - CIN_MAP_LND_001_01 to 001_85

Land Use Map TANAP CINAR

2014

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.3 - Land Valuation Management Procedure

LAND VALUATION MANAGEMENT PROCEDURE TANAP 21/08/2014

Documents 21122016\2.2 Turkish Labour Law (in English) - Turkish Law on Unions - see article 41

LAW ON TRADE UNIONS AND COLLECTIVE LABOUR AGREEMENTS

7/11/2012

ESIA – ESMS Docs – ESIA – Chapter 4 LEGAL, POLITICAL AND INSTITUTIONAL FRAMEWORK

TANAP

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 1- WRP-REP-EGG-PLG-020

Liquefaction Assessment Report - Priority 1 TANAP WorleyParsons

23/11/2015

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 2 - WRP-REP-EGG-PLG-021


19/11/2015

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 3 - WRP-REP-EGG-PLG-022


7/12/2015

Documents 21122016\3.6 Construction Camp Site Drainage Management Process - ILF-LST-CST-GEN-001-P2-1 List of Requirements for Main Camps and Storage Yards

List of Requirements for Main Camps and StorageYards

iLF TANAP

29/05/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\13_Terrestrial Fauna Baseline Report - Ek 4-Mammal Field Forms

Mammal Field Forms 1/5/2013

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH-

7.3.2.5

Mammals TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Fauna BL Report - Annex 2_Mammals and Turtles Questionnaire Survey Forms

Mammals and Turtles Questionnaire Survey Forms

5-6/9/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\21_Marine Archaeology Desktop Study Baseline Report - Marine Archaeology Desktop Study Baseline Report

Marine Archaeology DesktopStudy Baseline Report

MUSG DAGH

17/2/2014


Documents 21122016\1.12 Preconstruction Survey Methodology - TKF-MST-PPL-PL3-023

Method Statement and Risk Assessment for Pre-Construction Survey

TEKFEN TANAP

25/6/2015

Documents 21122016\1.12 Preconstruction Survey Methodology - FRN-MST-PPL-PL1-001

Method Statement for Pre construction Activities WorleyParsons TANAP FERNAS

26/10/2015

Documents 21122016\1.12 Preconstruction Survey Methodology - SYA-MST-ROW-PL2-001

Method Statement:Pipeline Pre construction survey, survey and stake out

SICIM YUKSEL AKKORD JV

TANAP Worley Parsons

11/5/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN-ENV-GEN-008_P4-0 - Appendix-2_Lot2

Mitigation Measures – Lot 2 TANAP

Documents 21122016\6.5 Completed Quarterly Third Party Monitoring Reports by ЗINAR - CIN-PRM-PRC-GEN-046_monthly report

MONTHLY PROGRESS REPORT FORENVIRONMENTAL AND SOCIAL MONITORING WORKS

CINAR TANAP 2/8/2016

Documents 21122016\6.5 Completed Quarterly Third Party Monitoring Reports by ЗINAR - CIN-PRM-PRC-GEN-051_monthly report

MONTHLY PROGRESS REPORT FORENVIRONMENTAL AND SOCIAL MONITORING WORKS

CINAR TANAP

9/12/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \

BAT_emission inventory and relevant evaluation data \ WRP-REP-EGG-MS2-100-Rev-P3-0_heating&cooling study

MS2 Heating and Cooling System Concept

Study – Final Report

TANAP

WorleyParsons

10/12/2014

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 Зadirkaya (KP410) - WRP-TNO-PPL-GEN-001

NARROW RIDGE ASSESSMENT - ÇADIRKAYA (KP410)

TANAP WorleyParsons

21/10/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 Meryem Dag (KP392) - WRP-TNO-PPL-GEN-002

NARROW RIDGE ASSESSMENT - Meryem Dag (KP392)

TANAP WorleyParsons

27/10/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 Posof (KP16) - WRP-TNO-PPL-GEN-005

NARROW RIDGE ASSESSMENT - POSOF (KP16) TANAP WorleyParsons

22/9/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ NCR Register 2017_Rev0_26.02.2

NCR Register 2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - 6_Noise & Vibration BL Report

Noise & Vibration BaselineReport TANAP 24/7/2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.5)\ WRP-QAC-FRM-001-00385-P3-2

Non conformance report – Berms with stones TANAP WorleyParsons 10/05/2016


New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ SPK \ SPK-PCD-QAC-DAR-002

Non-Conformance Management System Procedure

TANAP Sapura Kencana

7-12-2016

ESIA – ESMS Docs – ESIA – Non-Technical Summary - Non-Technical Summary

NON-TECHNICAL SUMMARY TANAP

New Data 15 May 2017 \ Content of Compulsory HS trainings Occupational Health and Safety basic Training KURAL

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.5 Offshore Biological Impact Assessment TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ WRP-REP-TSF-GEN-005_Offshore HAZID

OFFSHORE HAZID CLOSE OUT REPORT TANAP Worley Parsons

5/12/2016


Offshore Physical Characteristics TANAP

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.4 Offshore Physical Impact Assessment TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ SPK \ SPK-PLN-QAC-DAR-001

OFFSHORE PROJECT QUALITY PLAN (PQP) TANAP Sapura Kencana

10-10-2016

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.2.5-11

Onshore Biological Characteristics - Biological Features – Terrestrial Fauna

TANAP

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.2.1-4

Onshore Biological Characteristics - Biological Features - Terrestrial Flora

TANAP

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan - 1.7

Onshore Fuel & Chemical Spill Plan (Read me)

Onshore Fuel & Chemical Spill Plan TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ WRP-REP-TSF-GEN-030_Onshore HAZID

ONSHORE HAZID CLOSE OUT REPORT TANAP WorleyParsons

29/11/2016

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Onshore Pipeline River Crossing Methodology - WRP-MAN-EGG-PLG-001

Onshore Pipeline: Hydrological Assessment Methodology

TANAP WorleyParsons

27/10/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Onshore Pipeline Watercourse Crossing Philosophy - WRP-PHL-EGG-PLG-001

Onshore Pipeline: Watercourse Crossing Philosophy

TANAP WorleyParsons

26/3/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Onshore Route and Geohazard Assessment Report - BCH-REP-EGG-PLG-008-Rev-P2-0

Onshore Route and Geohazard Assessment Report

BECHTEL TANAP iLF

2/4/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report - Annex 4 Other Archaeological Sites List

Other Archaeological Sites List

Documents 21122016\5.4 Identification of Land Parcels size and location for future Compressor - 5.4 Identification of Land Parcels Size and Location for future Compressor Station

Parcel size and locations for existing and future compressor stations and pig launching and receiving pads.


Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies - revision status regarding requested items

PERFORMANCE REQUIREMENT 6

ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.5 - IFC Performance Standard 5

Performance Standard 5 Land Acquisition and Involuntary Resettlement

International Finance Corporation

01/01/2012

Documents 21122016\4.10 Permit to Work Descriptions - 4.10 Permit To Work

PERMIT TO WORK PROCEDURE (LOT2) SICM YUKSEL AKKORD JV TANAP

Worley Parsons

30/3/2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \Waste Facility Inspection Report \ Annex3_photos

Photos

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ Security Cabins placed (1) (2) and alo

Photos

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ Gendarmerie Training Dutluca Eskiюehir 2017 \ E__T_M G_RSEL (1)

Photos - Gendarmerie Training Dutluca Eskiюehir 2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ SPREAD 5 – DOGANKENT \ Doрankent 1, 2, 3

Photos - Doрankent 1, 2, 3

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ SPREAD 6 – POLATLI \ Polatlэ-1, 2, 3, 4

Photos - Polatlэ-1, 2, 3, 4

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ IMAG4304 and IMAG4308

Photos - Training Dutluca Eskiюehir 2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ Trainings in Gцnen-Karaorman 2016 \ IMG-20161122-WA0000, 02, 05, 08, 16,22, 24

Photos - Trainings in Gцnen-Karaorman 2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.3. Biological Baseline Studies\Freshwater Habitat and Ecosystems\First field survey

Photos of first field survey 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.2. Physical Baseline Studies - 2. Physical Baseline Studies

Physical Baseline Studies CINAR

Documents 21122016\1.12 Preconstruction Survey Methodology - WRP-SPC-PPL-PLG-001 Pipeline Construction Specification P4-4

Pipeline Construction Specification TANAPWorley Parsons 20/5/2016


Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Pipeline Stress Analysis Report - WRP-REP-PPL-PLG-003

Pipeline Stress Analysis Report TANAP WorleyParsons

26/11/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7-28.02.2017 Daily Secu

PLK -LOT 4-SPREAD 7 SİTE PLUS DAILY SECURITY REPORT (DSR)

Punj Lioyd Limak Kalyon

28/02/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 1 -SP -

8 28.02.2017 Dai

PLK -LOT 4-SPREAD 8 SİTE PLUS DAILY SECURITY REPORT (DSR)

Punj Lioyd Limak

Kalyon

27/02/2017

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-005- Pollution Prevention Plan-P4-D

Pollution Prevention Plan TANAP 15-03-17

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\23_Eco-system Evaluation Report - Eco-system Evaluation Report

POSOF WDA ECOSYSTEM ASSESSMENTREPORT 2014

Documents 21122016\1.12 Preconstruction Survey Methodology - Pre- Construction Survey Note

Preconstruction survey methodology

Documents 21122016\1.12 Preconstruction Survey Methodology - Pre- Construction Survey Note

Preconstruction survey methodology (PDF)

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Probabilistic Seismic Hazard Assessment Report – Pipeline - WRP-REP-EGG-GEN-026

Probabilistic Seismic Hazard Assessment Report - Pipeline

TANAP WorleyParsons

14/9/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Probabilistic Seismic Hazard Assessment Report – Stations - WRP-REP-EGG-GEN-028

Probabilistic Seismic Hazard Assessment Report - Stations

TANAP WorleyParsons

14/9/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ FRN \ FRN-PCD-QAC-PL1-004

PROCEDURE FOR CONTROL OF NON CONFORMANCEPREVENTATIVE AND CORRECTIVE ACTION

TANAP WorleyParsons FERNAS

08.07.15

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ PLK \ PLK-PCD-QAC-PL4-001

PROCEDURE FOR CONTROL OF NON-CONFORMANCES, CORRECTIVE AND PREVENTIVEACTIONS

TANAP Punj Lioyd Limark Kalyon

25.01.2017


Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ TKF \ TKF-PCD-QAC-PL3-010

Procedure for Corrective, Preventive Action

andControl of Non-Conformance

TANAP

WorleyParsons Tekfen

11/09/2015

Documents 21122016\5.6 Land Entry Exit Procedure Examples - 5.6 SAMPLE LAND ENTRY - EXIT PROCEDURE_

Procedure for Land Delivery, Entry and Exit TEKFEN TANAP

19/11/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ SYA \ SYA-PCD-QAC-GEN-001

PROCEDURE FOR MANAGEMENT OF NON CONFORMITYCORRECTIVE & PREVENTIVE ACTIONS

TANAP WorleyParsons SICIM

01/07/2015


YUKSEL AKKORD JV

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ TKN \ TKN-PCD-QAC-GEN-075

Procedure for Non-Conformance Management TANAP Tekfen

08.11.2016

Documents 21122016\3.8 Procedures for Physical & Final Reinstatement - 3.8 Procedures for Physical & Final reinstatement (Read me)

Procedures for Physical & Final reinstatement (Read me)

Documents 21122016\3.7 Procedures for Testing of Excess Excavation Dredging Spoil - 3.7 Procedures for Testing of Excess Excavation Dredging Spoil (Read me)

Procedures for Testing of Excess Excavation Dredging Spoil (Read me)

Documents 21122016\6.7 Procedures Management Plan for Invasive Species - 6.7 Procedures Management Plan for Invasive Species (Read me)

Procedures Management Plan for Invasive Species (Read me)

Documents 21122016\1.2 Process & Timeline for transfer of Org - 1.2 Process & Timeline for Transfer of Organisation (Read Me)

Process & Timeline for Transfer of Organisation

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - SYA-PLN-SOC-GEN-003_P4-0

Procurement & Supply Management Plan SYA ‐ Sicim‐Yuksel‐Akkord JV

21/05/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - TKF-PLN-ENV-PL3-017_P4-0

Procurement and Supply Management Tekfen 11/12/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - FRN-PLN-SOC-PL1-002_P4-0

PROCUREMENT AND SUPPLY MANAGEMENT PLAN

FERNAS 17/06/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-004-Procurement and Supply Management Plan- P4-C

Procurement and Supply Management Plan TANAP 21-11-16

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Project Basis of Design - WRP-REP-EGG-GEN-003

Project Basis of Design TANAP WorleyParsons

4/5/2016

ESIA – ESMS Docs – ESMP - Env Mon Plan - Annex 1 - TNP-REG-ENV-GEN-003-Rev-P3-1

Project Environment and Social Commitments Register

TANAP 23/06/2016

Revised 12.10.2016 -Commitment Register - TNP-REG-ENV-GEN-003-Rev-P3-3

Project Environmental and Social CommitmentsRegister

TANAP 12/10/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.7) \ TNP-PLN-ENV-GEN-003_Annex 1

Project Environmental and Social CommitmentsRegister

TANAP 29.08.2016

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ PROJECT EXECUTION PLAN TANAP 9/2012


1.1 \ CC- ESMS \ CIN-PLN-ENV-GEN-001-Rev-P1-0_PEP_ESIA.Org. chart CINAR

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.4 \ CIN-PLN-ENV-GEN-002_Rev-P3-3_PEP_TPMC.Org.chart

PROJECT EXECUTION PLAN (PEP)THIRD PARTY ENVIRONMENTAL AND SOCIAL MONITORING SERVICES

TANAP CINAR

24/02/2017

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.4 \ CIN-PLN-ENV-GEN-001-Rev-P1-0_PEP_ESIA.Org. chart

PROJECT EXECUTIONPLAN TANAP CINAR SOCAR

9/2012

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ ABB \ ABB-PCD-QAC-GEN-003

Project Nonconformity Management Procedure TANAP WorleyParsons ABB

22.06.16

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ SYA \ SYA-PLN-QAC-GEN-001

Project Quality Management Plan TANAP WorleyParsons SICIM YUKSEL AKKORD JV

20/04/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ FRN \ FRN-PLN-QAC-PL1-001

PROJECT QUALITY PLAN TANAP WorleyParsonsFERNAS

07.05.2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the

Contractors-TANAP NCR Register \ PLK \ PLK-PLN-QAC-PL4-001

PROJECT QUALITY PLAN TANAP Punj Lioyd

Limark Kalyon

20/06/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ TKN \ TKN-PLN-QAC-GEN-001

Project Quality Plan TANAP Tekfen

07.11.2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ ABB \ ABB-PLN-QAC-GEN-001

Project Quality Plan (PQP) TANAP WorleyParsons ABB

22/11/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Contractors-TANAP NCR Register \ TKF \ TKF-PLN-QAC-PL3-001

Project Specific Quality Plan (PSQP) TANAP WorleyParsons Tekfen

14.05.2016

New Data 15 May 2017 \ 17.05.11 TANAP_EBRD_Presentation_2017.05.09

Project Status and Progress on ESIA Implementation EBRD - TANAP – TPMC

TANAP 11/05/2017


Protected and Sensitive Habitats TANAP


Protected areas TANAP

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Protected Areas (In the scope of the list of TANAP


7.3.1.7 buffer regions in Annex V)

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\8.Protected Areas Map - CIN_MAP_PAR_001_01 to 001_08

Protected Areas and high biodiversity area Map TANAP CINAR

2014

Documents 21122016\1.9 Pipe Supply Contract and Prequalication Requirements - Annex 2 - Questionnaires

Questionnaires (Prequalification for Line Pipe)

Documents 21122016\5.7 RAP Fund Strategy - 5.7 RAP Fund Strategy (Read Me )

RAP Fund Strategy (Read Me )

ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX 4.2 - Socioeconomic Survey Methodology

RAP of TANAP Project - METHODOLOGY FOR SOCIOECONOMIC SURVEY

Golder Associates 19/02/2014

Documents 21122016\5.2 Initial Draft of the Livelihood Restoration Plan - 5.2 Initial Draft of the Livelihood Restoration Plan (Read me)

Read me - Initial Draft of the Livelihood Restoration Plan

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ Read me

Read me - Notepad

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR10(10.3) \ Read Me 10.3

Read Me 10.3 TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.7) \ Read Me 2.7

Read Me 2.7 Social Management Plans

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ Read me 3.2

Read me 3.2


Report-02.03.2017 \ PR6(6.11) \ Read Me 6.11

Read Me 6.11

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR1(1.6) \ Read Me PR1 (1.6)

Read Me PR1

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies - 6.1 Description of Timing and Baseline Survey Methodolgies (Read me)

Read me: Description of Timing and Baseline Survey Methodolgies

Documents 21122016\8.4 Documented Evidence of Identified Disturbed Graveyards - 8.4 Documented Evidence of Identified Disturbed Graveyards (Read me)

Read me: Documented Evidence of Identified Disturbed Graveyards

Documents 21122016\6.3 Meth. used for the App. Assessment of Biodiversity Impacts - 6.3 Meth. used for the App. Assessment of Biodiversity Impacts (Read me)

Read me: Meth. used for the App. Assessment of Biodiversity Impacts

Documents 21122016\6.8 Method Statement for Tree Cutting and Replanting - 6.8 Method Statement for Tree Cutting and Replanting (Read me)

Read me: Method Statement for Tree Cutting and Replanting

Documents 21122016\6.2 The Methodology for Assessment of the current status of the Habitats - 6.2 The Methodology for Assessment of the current status of the Habitats (Read me)

Read me: The Methodology for Assessment of the current status of the Habitats


ESIA – ESMS Docs – ESIA – Chapter 5 REASONS FOR THE ROUTE SELECTION AND EVALUATION OF ALTERNATIVES

TANAP

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLANS OF CCs - SYA-PLN-SOC-GEN-004_P4-0

RECRUITMENT AND WORKERS MANAGEMENT PLAN

SYA ‐ Sicim‐Yuksel‐Akkord JV

21/05/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Reinstatement and Erosion Control Requirements - WRP-REP-EGG-GEN-004-Rev-P3-0

REINSTATEMENT AND EROSION CONTROL REQUIREMENTS

TANAP WorleyParsons

25/9/2014

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Reinstatement and Erosion Control Requirements for the 48 Pipe - WRP-REP-EGG-GEN-027

REINSTATEMENT AND EROSION CONTROL REQUIREMENTS FOR THE 48" PIPE

TANAP WorleyParsons

1/9/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR10(10.3) \ REPORT FOR ESIA DISCLOSURE MEETINGS

REPORT FOR ESIA DISCLOSURE MEETING TANAP CINAR

25/11/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\13_Terrestrial Fauna Baseline Report - Ek 6 -Reptile and Amfibi Field Forms

Reptile and Amfibi Field Forms 1/5/2013


Reptiles TANAP

ESIA – RAP - GLD-PLN-LAC-GEN-003_P3-1 Resettlement Action Plan (RAP) for TANAP Project

Golder Associates 05/10/2015

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\TNP-PLN-SOC-GEN-010 RAP Monitoring Plan

Resettlement Action Plan (RAP) Monitoring Plan

TANAP 12/05/2017

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ TANAP-CIN-TRA-TNP-0493

Revised Version of Biodiversity Action Plan TANAP CINAR

02/05/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SPREAD 7 Night Push to Tal

Row security personnel control schedule 07- 08 /02/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SPREAD 7 Night Push to (1)

Row security personnel control schedule 26 – 27 /02/2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex III_GRADKO Laboratory Accreditation Certificate

Schedule of Accreditation UKAS 31/10/2011

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Water and Sediment Quality BL Report - Sea Water&Sediment Quality Report

Sea Water and Sediment QualityBaseline Report TANAP 2/6/2014

New Data 15 May 2017 \ TNP-PRE-SEC-GEN-007-EBRD 11.05.2017 Security Department TANAP 11/05/2017


New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 04 TANAP-SYA-LET-WRP-0172

Security Licenses and permits SICIM YUKSEL AKKORD JV

04/06/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-001 Security Management Plan (Rev.2)

Security Management Plan TANAP FERNAS

21.02.2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ SYA-PLN-SEC-PL2-001

SECURITY MANAGEMENT PLAN TANAP WorleyParsons SYA ‐ Sicim‐Yuksel‐Akkord JV

14/08/15

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ PLK-PLN-SEC-PL4-002

SECURITY MANAGEMENT PLAN TANAP Punj Lioyd Limak Kalyon

22.09.2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Management Plan 347

Security Management Plan WorleyParsons TANAP TAFFEN

07/06/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 13 Security Risk Assessment

SECURITY RISK ASSESSMENT TANAP SICIM YUKSEL AKKORD JV

25.02.2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Training Plan

Security Training Plan

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Exercises Plan

Site Plus Security Exercises Plan

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00008 Site Safety Inspection Report for CS5

Site safety inspection report form (CS - 5) TANAP 17/01/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00001 Site Safety Inspection Report for CS1

Site safety inspection report form (CS 1) TANAP 21/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00006 Site Safety Inspection Report for LOT1 -

Spread 2 - Ilэca Camp

Site safety inspection report form (Lot 1 / Spead 2 IIica Camp)

TANAP 23/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00005 Site Safety Inspection Report for LOT1 - Spread 2 - Pasinler Camp

Site safety inspection report form (Lot 1 / Spead 2 Pasinler Camp)

TANAP 22/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00007 Site Safety Inspection Report for LOT1 - Spread 9 - Refahiye Camp

Site safety inspection report form (Lot 1 / Spead 9 Refahiye Camp)

TANAP 24/12/2016


EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00003 Site Safety Inspection Report for LOT1 - Spread 1 - Posof Camp

Site safety inspection report form (Lot 1 / Spread 1 Posof region)

TANAP 20/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00004 Site Safety Inspection Report for LOT1 - Spread 1 - Selim Camp

Site safety inspection report form (Lot 1 / Spread 1 Selim Camp)

TANAP 19 - 21/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \TNP-HSM-FRM-015-00024 Site Safety Inspection Report for MS1 Camp

site

Site safety inspection report form (MS - 1 Camp Site)

TANAP 19-20/03/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00002 Site Safety Inspection Report for MS1 Camp site

Site safety inspection report form (MS 1 Camp Site)

TANAP 20/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \TNP-HSM-FRM-015-00029 Site Safety Inspection Report for SP-7 Dutluca Camp site

Site safety inspection report form (SP-7 Dutluca Camp Site)

TANAP 29/03/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00027 Site Safety Inspection Report for SP-8 Ilэcak Camp site

Site safety inspection report form (SP-8 Iiicak Camp Site)

TANAP 28/03/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \TNP-HSM-FRM-015-00028 Site Safety Inspection Report for SP-8

Karaorman Camp site

Site safety inspection report form (SP-8 Karaorman Camp Site)

TANAP 28/03/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00012 Site Safety Inspection Report for Spread-3 KELKЭT Fly Camp

Site safety inspection report form (Spread 3 - Kelkit Fly Camp)

TANAP 24/01/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00011 Site Safety Inspection Report for Spread-3 ЗADIRKAYA Camp

Site safety inspection report form (Spread 3) TANAP 23/01/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \TNP-HSM-FRM-015-00013 Site Safety Inspection Report for Spread-4 HAFЭK Camp

Site safety inspection report form (Spread 4 - Hafik Camp)

TANAP 25/01/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \TNP-HSM-FRM-015-00010 Site Safety Inspection Report for LOT3 - Spread 5 …


EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ TNP-HSM-FRM-015-00009 Site Safety Inspection Report for LOT3 - Spread 6 …


Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Slope Assessment Report %96 Priority 1

Slope Assessment Report - Priority 1 Areas TANAP WorleyParsons

26/3/2015


Areas - WRP-REP-EGG-PLG-010

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Slope Assessment Report %96 Priority 2 Areas - WRP-REP-EGG-PLG-011


11/8/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Slope Assessment Report %96 Priority 3 Areas - WRP-REP-EGG-PLG-012


5/10/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - TNP-PLN-SOC-GEN-002_P3-1

SOCIAL ACTION PLAN TANAP 15/07/2016

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 3 SOCIAL ACTION PLANANNEX 3 SOCIAL MANAGEMENT GUIDELINES FOR CONTRACTORS

15/07/2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - Social Baseline Report

Social Baseline Report AYDSFIDG 24/3/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1F HOUSEHOLD QUESTIONNAIRE_AGI

SOCIAL IMPACT ASSESSMENT STUDYHOUSEHOLD QUESTIONNAIRE (FOR AGI’s)

TANAP 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1E HOUSEHOLD QUESTIONNAIRE_ROUTE

SOCIAL IMPACT ASSESSMENT STUDYHOUSEHOLD QUESTIONNAIRE(ROUTE SURVEY)

TANAP 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1C SETTLEMENT QUESTIONNARE_AGI

SOCIAL IMPACT ASSESSMENT STUDYSETTLEMENT QUESTIONNAIRE (FOR AGI’s)

TANAP 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1D SETTLEMENT QUESTIONNARE_ESKISEHIR OFF TAKE

SOCIAL IMPACT ASSESSMENT STUDYSETTLEMENT QUESTIONNAIRE (FOR ESKISEHIR CONNECTION)

TANAP 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1B SETTLEMENT QUESTIONNAIRE_PHONE INTERVIEW

SOCIAL IMPACT ASSESSMENT STUDYSETTLEMENT QUESTIONNAIRE (PHONE INTERVIEW)

TANAP 2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Baseline Report - APPENDIX 1A SETTLEMENT QUESTIONNAIRE_ROUTE

SOCIAL IMPACT ASSESSMENT STUDYSETTLEMENT QUESTIONNAIRE(ROUTE SURVEY)

TANAP 2013

ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.6 Social Impact Assessment-Offshore TANAP

ESIA – ESMS Docs – ESMP - Social Monitoring Plan - TNP-PLN-SOC-GEN-003_P3-1

SOCIAL MONITORING PLAN TANAP 18/07/2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.4. Socio-economic Baseline Studies - 4. Socio-economic Baseline Studies

Socio-economic Baseline Studies

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Soil Characteristics TANAP


7.3.1.2

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Contamination Baseline Study Report - Soil Contamination BL Rep.

Soil Contamination Baseline Study Report TANAP 24/7/2014

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 12 Standard Operating Procedures (Sample)

SOPs Standart Operating Procedures – Site Security Likely scenarios & course of action

Documents 21122016\3.3 Specific Process Used to Calculate Sulphides in Soil - WRP-SPC-EGG-GEN-010

SPECIFICATION FOR PHASE 3 SUBSURFACE INVESTIGATION WORKS

TANAP Worley Parson

27/8/2015

ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.1 Specification for Reinstatement

Specification for Reinstatement Worley Parsons 26/11/2015

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-6 - Annex-6.1 Specification for Reinstatement

Specification for Reinstatement Worley Parsons TANAP

26/11/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-6 \ Annex-6.1 Specification for Reinstatement

Specification for Reinstatement TANAP WorleyParsons

26-11-15

New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex-6 \ Annex-6.1 Specification for Reinstatement

Specification for Reinstatement WorleyParsons TANAP

26/11/2015

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 6 \ Annex-6.1 Specification for Reinstatement

Specification for Reinstatement TANAP WorleyParsons

26/11/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ SPREAD 5 DOРANKENT CAMP CCTV LAYOUT PLAN

SPREAD 5 DOРANKENT CAMP CCTV LAYOUT PLAN

Bordoter

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ SPREAD 6 POLATLI CAMP CCTV LAYOUT PLAN

SPREAD 6 POLATLI CAMP CCTV LAYOUT PLAN Bordoter

ESIA – ESMS Docs – ESIA – Chapter 6 STAKEHOLDER ENGAGEMENT TANAP

Documents 21122016\11.2 Updated SEP - TNP-PLN-SOC-GEN-001-Rev P3-1

Stakeholder Engagement Plan TANAP 26/10/2016

New Data May 4 2017 \ TNP-PLN-SOC-GEN-001-Rev P3-2 Stakeholder Engagement Plan TANAP 30/01/2017

Documents 21122016\11.2 Updated SEP - Annex 1_Stakeholder Engagement Implementation Guideline For Construction Phase

STAKEHOLDER ENGAGEMENT PLANANNEX 1 STAKEHOLDER ENGAGEMENT IMPLEMENTATIONGUIDELINE FOR CONSTRUCTION PHASE

TANAP 26/10/2016

Stakeholder Engagement Plan StakeholderEngagement Plan Golder Associates 18/8/2013

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2a-Stakeholder Engagement Plan

StakeholderEngagement Plan Golder Associates 18/08/2013

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Statement of compliance


Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 5 Statement of compliance SITE PLUS

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A IV_2010-2013_Measurement Results

Station Report: Measurement results for SO2, PM10 and NOX

2010-2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex V_Measurement Results (Canakkale_Biga)

Station Report: Measurement results for SO2, PM10 and NOX

2010 – 2013

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Risk Assessment-Feb 2017

Station Risk Analysis and Assessment results TANAP 01/03/2017

Documents 21122016\1.8 Status of Current Emergency Response Plans - 1.8 Status of Current Emergency Response Plans (Read me)

Status of Current Emergency Response Plans

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.5)\ TANAP-TNP-LET-FRN-0055

Stop Work Notice TANAP 23/09/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ TANAP-FRN-LET-WRP-0116 - Submission for Subcontractor Agreement

SUBCONTRACTOR AGREEMENT 25/05/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 01 TANAP-SYA-LET-WRP-0048 (1)

Subcontractor list SICIM YUKSEL AKKORD JV

06/03/2015

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Water Quality Baseline Report - Surface Water BL Rep.

Surface Water Quality Baseline Report TANAP 2/6/2014

Documents 21122016\4.1 Detailed Incident Analysis Reports - SYA Fatal Crash Executive Sum._Rev.0

SYA FATAL CRASH INCIDENT EXECUTIVE REPORT

5/9/2016

ESIA – ESMS Docs – ESIA - TOC Table of content TANAP

ESIA – ESMS Docs – ESIA – Chapter 7 - Index Table of content of Chapter 7: Environmental Baseline Features

TANAP

ESIA – ESMS Docs – ESIA – Chapter 8 – Chapter 8_Index Table of content of chapter 8 – Impact Assessment

TANAP

New Data 15 May 2017 \ TANAP-TNP-LET-SYA-0093_submission of assurance review report_Lot 2

TANAP Assurance Review Report Findings TANAP 14/11/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex A - TNP-PCD-ENV-GEN-006

TANAP Change Find Requirements TANAP 19/07/2016

Documents 21122016\2.4 Labour Data Breakdown - 2.4 TANAP Contractor Employment Status ( As of 01 December 2016)

TANAP Contractor Employees ( As of 01 December 2016)

TANAP 1/12/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ TANAP comments 24052017

TANAP coomments 24052017 TANAP 24/05/2017

Documents 21122016\2.6 TANAP HR Audit on Subcontractors - 2.6 TANAP HR Audit on Subcontractors


TANAP HR Audit on Subcontractors (Read me)

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ 17.01.03 EBRD TANAP ISSUES REQUIRING ADDITIONAL INFORMATION AND CLARIFICATION Latest

TANAP ISSUES REQUIRING ADDITIONAL INFORMATION AND CLARIFICATION Latest

TANAP

Documents 21122016\2.7 Local Hiring Plans - HZR-REP-SOC-GEN-001 TANAP Manpower Baseline report TANAP HAZAR STRA TEJI

11/12/2015

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2b-Stakeholder Register

TANAP PROJECT APPENDIX 3.2b- STAKEHOLDER LIST

Documents 21122016\4.1 Detailed Incident Analysis Reports - Executive-OHPL 16.03.2016

TANAP PROJECT INCIDENT EXECUTIVE REPORT (overhead powerline Arc)

3/2016

Documents 21122016\4.1 Detailed Incident Analysis Reports - Executive Summary-Tire Burst 09.03.2016

TANAP PROJECT INCIDENT EXECUTIVE REPORT (rollover of machinery)

3/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ TNP-REP-SOC-GEN-001 RAP Q1 Internal Monitoring Report

TANAP PROJECT RESETTLEMENT ACTION PLAN (RAP) 1ST QUARTERLY INTERNAL MONITORING REPORT (MARCH 2017)

TANAP 30/03/2017

Documents 21122016\2.5 Procedures for Third Party Monitoring on Labour - TANAP PROJECT SITE AUDIT PROCEDURE

TANAP PROJECT SITE CONTROL PROCEDURE 01/03/2016

New Data 15 May 2017 \ SOC_Presentation Social_11052017 TANAP PROJECT SOCIAL IMPACT MANAGEMENT TANAP 11/05/2017

Documents 21122016\4.1 Detailed Incident Analysis Reports - Executive Summary-Railway 03.02.2016

TANAP PROJECT TRAFFIC INCIDENT EXECUTIVE REPORT

2/2016

Documents 21122016\11.1 Copies of All Presentations - TANAP EBRD Presentation

TANAP project update TANAP 11/2016

EXECUTIVE-SUMMARY-ENG-No-Memo-07262016 TANAP Project’s Executive Summary of ESIA and Supporting Environmental and Social Safeguard Documents

TANAP 22/7/2016

ESIA - Executive Summary - EXECUTIVE SUMMARY_ENG TANAP Project’s Executive Summary of ESIA and Supporting Environmental and Social Safeguard Documents FOR SUBMISSION TO WORLD BANK’S BOARD AS PER PELOSI REQUIREMENT

TANAP 22/07/2016

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \

EBRD.ESAP.TANAPresponse.24.05.2017

TANAP Response:

APPENDIX C: ENVIRONMENTAL AND SOCIAL ACTION PLAN

TANAP 24/05/2017

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ EBR014_TANAP ESDD Report_Rev2.TANAP.response.24.05.2017

TANAP response: Final Report of the Independent Environmental and social consultant 24/05/2017

TANAP 24/05/2017

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APP 3.2c-Project Brochure

TANAP Trans Anatolian Natural Gas Pipeline – The path of energy and cooperation

TANAP


ESIA – RAP – ANNEXES - Chp 7 – Consultation - App 7.1 GLAC rev P3-1 TANAP TRANS ANATOLIAN NATURAL GAS PIPELINEGUIDE TO LAND ACQUİSİTİON AND COMPENSATİON

06/2014

Documents 21122016\11.1 Copies of All Presentations - Presentation_29.11.2016

TANAP: LOT 1 29/11/2016

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN-ENV-GEN-008_P4-0 - Appendix-1_all_maps

TANAPTRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT – LOT 2

TANAP

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ WRP-REP-MEC-GEN-001-P3-2. Technical bid evaluation report.emission values

Technical bid evaluation report emission values

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ WRP-TNO-PRS-CSG-002_waste heat recovery

Technical Note Compressor Stations Waste Heat Recovery

TANAP WorleyParsons

06/08/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Technical Note for Design of Pipelines in Karst - WRP-TNO-EGG-PLG-001

TECHNICAL NOTE FOR DESIGN OF PIPELINES IN KARST

TANAP WorleyParsons

24/6/2015

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Technical Specification for Seismic Trenches - WRP-SPC-PPL-PLG-005

Technical Specification for Seismic Trenches 4/2/2016

ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Man. Plan - TKF-PLN-ENV-PL3-011_P4-0

TEKFEN Aggregates Management Plan Tekfen 29/04/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY RELATIONS PLANS OF CCs -TKF-PLN-ENV-PL3-015_P4-0

TEKFEN Community Relations Plan Tekfen 21/05/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY SAFETY MANAGEMENT PLANS OF CCs - TKF-PLN-ENV-PL3-014_P4-0

TEKFEN Community Safety Management Plan Tekfen 21/05/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLANS OF CCs - TKF-PLN-ENV-PL3-016_P4-0

Tekfen Employment and Training Plan Tekfen 08/06/2015


Tekfen Erosion, Reinstatement and Landscaping Plan

Tekfen 30/06/2015

Documents 21122016\6.1 Description of Timing and Baseline Survey Methodologies\BAP\Annex-6 - Annex-6.4 Tekfen Erosion Control and Stabilisation Plan for LOT-3

TEKFEN Erosion, Reinstatement and Landscaping Plan

TEKFEN TANAP

30/6/2015

Documents 21122016\3.1 Hydrotest Management Plan – Procedure - TKF-PLN-ENV-PL3-022.Environmental Hydrotest Monitoring Plan

TEKFEN Hydrostatic Test Environmental Monitoring Plan

TEKFEN TANAP

5/12/2016

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-001-P4-2

TEKFEN Project Security Management Plan TANAP TEKFEN

15.12.2016


(SECURITY MANAGEMENT PLAN)

BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ Appeals Committee \ToR_TANAP_Appeals Committee Experts

Terms of Reference for Appeals Committee Experts

1/01/2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report - Terrestrial Archaeology Baseline Report

Terrestrial Archaeology BaselineReport SAVB 24/7/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report\PHOTO_29052014

Terrestrial Archaeology PHOTOs


Terrestrial Habitats and Ecosystems TANAP


Terrestrial Invertebrates TANAP


Terrestrial Vegetation TANAP

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 4 SVAN 958

Test results of Calibration AVL 19/6/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 4 SVAN 958 1

Test results of Calibration Protos 30/10/2013

ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.4 - Equator Principles THE EQUATOR PRINCIPLES Equator Principles Financial Institutions

06/2013

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ Trainings in Gцnen-Karaorman 2016 \ Inspection Notes

THEORETICALLY AND PRACTICALLY SECURITY EDUCATION

Site Plus TANAP

22/11/2016

Documents 21122016\11.1 Copies of All Presentations - 3rd Party Environmental and Social Monitoring

Third Party Environmental & Social Monitoring

New Data 15 May 2017 \ 3rd Party Environmental Monitoring_EBRD_11_05_2017_final

Third Party Environmental Monitoring TANAP CINAR

11/05/2017

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \Waste Facility Inspection Report \ TNP-REP-ENV-GEN-009

Third party facility E&S inspection checklist – Waste Management

TANAP 17-03-2017

New Data 15 May 2017 \ 3rd Party Social Monitoring_EBRD_11_05_2017

Third Party Social Monitoring TANAP CINAR

11/05/2017


Threatened species TANAP

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - TRAFFIC MANAGEMENT PLANS OF CCs - FRN-PLN-SOC-PL1-003_P4-0

TRAFFIC MANAGEMENT PLAN FERNAS 24/06/2015

ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - TRAFFIC MANAGEMENT PLANS OF CCs - PLK-PLN-SOC-PL4-004_P4-1

TRAFFIC MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 27/05/2016


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-006-Traffic Management Plan- P4-C

Traffic Management Plan TANAP 11-11-16

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ Gendarmerie Training Dutluca Eskiюehir 2017 \ E__T_M KATILIM BELGE

Training Attendance Form TANAP Punj Lioyd Limak Kalyon

17/02/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \

ROW Security Training Dutluca Eskiюehir 2017 \ E__T_M KATILIM BELG

Training Attendance Form TANAP Punj Lioyd

Limak Kalyon

08/02/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ SPREAD 6 – POLATLI \ POLATLI VPSHR TRAINING ATTENDANCE SHEET-1, 2, 3, 4

Training attendance sheet

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ SPREAD 5 – DOGANKENT \ DOРANKENT VPSHR TRAINING ATTENDANCE SHEET-1, 2

Training attendance sheet

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 11 Spread-4 Training Plan

Training Plan


Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ Security Drills in Gonen - Karaorman 2017 \ Gonen Training and Karaorman Training

Training report: Class training TANAP 03/02/2017

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 1 Analysis Reports

Trans anatolian natural gas pipeline (TANAP) project environmental and social impact assessment report baseline studies – Environmental Noise and vibration measurement report

CINAR 13/8/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 1 The Analysis Reports_PM10

Trans anatolian natural gas pipeline (TANAP) project environmental and social impact assessment report baseline studies – PM10 measurement report

CINAR 13/8/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 1 The Anlys Rep_PM10_Addtnl Camp Sites

Trans anatolian natural gas pipeline (TANAP) project environmental and social impact assessment report baseline studies – PM10 measurement report

CINAR 29/5/2014

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 1 The Anlys

Trans anatolian natural gas pipeline (TANAP) project environmental and social impact

CINAR 29/5/2014


Rep_PM2_5_Addtnl Camp Sites assessment report baseline studies - PM2.5 measurement report

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Quality (PM10&PM2.5) Baseline Report - A 1 The Analysis Reports_PM2_5

Trans anatolian natural gas pipeline (TANAP) project environmental and social impact assessment report baseline studies - PM2.5 measurement report

CINAR 14/8/2013

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Vibration BL Report - A 1 Analysis Reports_Additional Camp Sites

Trans anatolian natural gas pipeline (TANAP) project report baseline studies – Environmental

Noise measurement report

CINAR 29/5/2014

Documents 21122016\2.3 Labour Union Agreements In Place Lot 2& 3\Lot 3 - TANAP-TKF-LET-WRP-0651

Trans anatolian natural gas pipeline project – lot 3 – World Bank due diligence

TEKFEN 1/2/2016

Documents 21122016\2.3 Labour Union Agreements In Place Lot 2& 3\Lot 2 - TANAP-SYA-LET-WRP-0533

TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT - LOT2

SICIM YUKSEL AKKORD JV

3/2/2016

Documents 21122016\4.3 Transport of Dangerous Goods and Materials - 4.3 Transport of Dangerous Goods & Materials (Read Me)

Transport of Dangerous Goods & Materials

Documents 21122016\2.2 Turkish Labour Law (in English) - 2.2 Turkish Labour Law (Read me)

Turkish Labour Law

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Typical Drawing - Concrete Coated Pipe - WRP-DGA-PPL-PLG-030

Typical drawing concreate coated pipe TANAP WorleyParsons

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Typical Drawing Fault Crossings 56%94 & 48%94 Tanap Gas Pipeline - WRP-DGA-PPL-PLG-042

Typical drawing fault crossing 48’’ & 56’’ TANAP gas pipeline

TANAP WorleyParsons

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Typical Drawing - Karst Drainage Requirement - WRP-DGA-EGG-PLG-001

Typical drawing karst drainage requirement TANAP WorleyParsons

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Wetlands & Seismic Act\Typical Drawing - Saddle Bag for Buoyancy Control - WRP-DGA-PPL-PLG-031

Typical drawing saddle bag for buoyancy control TANAP WorleyParsons

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting

Wetlands & Seismic Act\Typical Drawing - Screw Anchor Detail - WRP-DGA-PPL-PLG-032

Typical Drawing screw anchor detail TANAP

WorleyParsons

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\11.Typical Drawings

Typical Drawings

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Vehicle Inspection \ Vehicle and Visitor Inspection Records 1 - 5

Vehicle and Visitor Inspection Records Site Plus 11/2016


New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT_emission inventory and relevant evaluation data \ WRP-REP-PRS-CSG-001-vent & blow down report

Vent and Blowdown Report TANAP WorleyParsons

9/11/2015

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR3(3.2) \ WRP-REP-PRS-CSG-001-vent & blow down report

Vent and Blowdown Report TANAP WorleyParson

09/11/2015

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ 1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-006- Waste Management Plan- P4-

0

Waste Management Plan TANAP 13-02-17

Documents 21122016\3.2 Water Intake Assessment & Allocation - 3.2 Water Intake Assessment & Allocation (Read me)

Water Intake Assessment & Allocation - 3.2 Water Intake Assessment & Allocation (Read me)

Documents 21122016\11.1 Copies of All Presentations - LOT-1 EBRD- Presentation

WELCOMESEUROPEAN BANK FOR RECONSTRUCTION AND DEVELOPMENT TEAM

FERNAS TANAP

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.5)&PR4(4.1) \ FRN-PLN-HSE-PL1-025 Winterizaiton Plan p4-1

WINTERIZATION PLAN TANAP FERNAS

31.08.2016

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\22_Terrestrial Archaeology Baseline Report\Att.2_Ann 3 – Tm 27, 30,33,36,39,and 42


Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.2. Physical Baseline Studies - Photographs

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.3. Biological Baseline Studies - Terrestrial

Documents 21122016\4.6 H&S Requirements for Camps & Accommodations - 4.6 SYA-PLN-HSE-GEN-012-P4-0 - 4.6TKN-PLN-HSM-GEN-003-P4-0

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.3. Biological Baseline Studies - Marine

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.4. Socio-economic Baseline Studies - Photographs

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-2.6.5. Archaeological Baseline Studies - Photographs

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental Master Plan and Legands\Plan Hьkьmleri Onaylэ\100.000 цlзekli_Mekansal


Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental Master Plan and Legands\Plan Hьkьmleri Onaylэ\Balэkesir

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes - Annex 3-CC Sub-Management Plans

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes – Annex 1 – National and International standards of TANAP project

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes – Annex 4 – Environmental Management Guidelines for Contractors

Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-ENV-GEN-002 P3-2 Annexes\Annex 6-Cultural Heritage Management Plan

Documents 21122016\1.10 Quality Management System Procedure for Contractors

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - 01-5188 Sayэlэ Цzel Gьvenlik Hizmetlerine Dair Kanun

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - 02-5188 Sayэlэ Цzel Gьvenlik Hizmetlerine Dair Kanunun Uygulanmasэna Эl...

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - 03-Цzel Gьvenlik Hizmetlerinin Birleюtirilmiю Genelgesi

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - FRM.54 R.01 EРЭTЭM TUTANAРI

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - FRM.061 R00 TEBLЭР-TEBELLЬР BELGESЭ

Documents 21122016\1.11 Traning Programmes & Rules of Engagement Code of Conduct - FRM.063 R.00 ORYANTASYON EРЭTЭM RAPORU

Documents 21122016\1.11 Traning Programmes & Rules of Engagement

Code of Conduct - TLM.001 R00 GЦREV YERЭ ЦZEL TALЭMATI

Documents 21122016\2.3 Labour Union Agreements In Place Lot 2& 3\Lot 2 - sendika toplu sцzleюme

Documents 21122016\2.8 Example of Employment Contract - Sample employment contract-Fernas

FERNAS

Documents 21122016\2.8 Example of Employment Contract - Sample employment contract-SYA


Documents 21122016\2.8 Example of Employment Contract - Sample employment contract-Tekfen

Documents 21122016\2.8 Example of Employment Contract - TANAP sample employee contract

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Engineering Design Validation Pipeline Crossings of Active Tectonic Faults

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Stability,Surface Fault Rupture)\Pipeline River Corssing Civil Protection Works Specification

Documents 21122016\4.2 Communicable Disease Management Plan

Documents 21122016\4.6 H&S Requirements for Camps & Accommodations - 4.6 SYA-PLN-HSE-GEN-012-P4-0

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Genel Devriye-Keюifзi Gцrevlisi Gцrev Esaslarэ Talimatэ

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Silah Depolama ve Bakэm Talimatэ

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Silah Devir Teslim Talimatэ

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Silah Emniyet ve Kaza Цnleme Talimatэ

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Silahlэ Gьvenlik Nцbetзisi Gцrev Talimatэ

Documents 21122016\4.7 Security Risk Assessment for Use of Weapons on the Project - Silahlэ Ziyaretзi Kabul ve Silah Alma-Etme Esaslarэ Talimatэ

Documents 21122016\4.8 Emergency Response Drill Examples

Documents 21122016\4.9 Procedures For UXO identifications - 20- 4536 Sayэlэ Denizlerde ve Yurt Yьzeyinde Gцrьlen Patlayэcэ Madde ve ...

Documents 21122016\4.9 Procedures For UXO identifications - 21-Denizlerde ve Yurt Yьzeyinde Gцrьlen Patlayэcэ Madde ve Юьpheli Cisim...

Documents 21122016\5.3 Long Term Lease Agreement and Arrangements for the Forest Lands - 5.3 SAMPLE LONG TERM LEASE AGREEMENT WITH FOREST AUTHORITIES

Documents 21122016\5.5 Access Road Register

Documents 21122016\5.8 Social Investment Fund (strategy)

Documents 21122016\6.4 Itn. Con. & Stand. And EU Directives


benchmark biodiversity impact assessment

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \Waste Facility Inspection Report \ Annex2_Inspections docs

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.5)\ WRP-QAC-FRM-001-00004-P3-2

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ SKM_C30817010614191

05.01.2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 05 TANAP-WRP-TRA-SYA-0307

TANAP WorleyParsons

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 10 Spread-3 Training Plan

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 2, 3,6

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 3-SP- 8 25.02.2017 Dut

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7-26.02.2017 Daily Shif

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Material Removal \ Material Removal Form 2 and 3 and old version form

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Perimeter Patrol Activity \ perimeter foot patrol Feb 26 2017 TOM Reader

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Perimeter Patrol Activity \ Perimeter Patrol Activity Records Book

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Perimeter Patrol Activity \ Perimeter Patrol Activity Records NIZAMIYE 1 and 2 TOM Reader

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Perimeter Patrol Activity \ Perimeter Patrol Feb 26-27 Motor TOM Readers

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ ROW Security Training Dutluca Eskiюehir 2017 \ Trainings in Gцnen-Karaorman 2016 \ Trainings in Gцnen-Karaorman 2016\ KARAORMAN


KAMP E__T_M 22.11.20 and KARAORMAN KAMP E__T_M 22.11.20

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Report-02.03.2017 \ PR2(2.10) \ Stations \ Akasaklэ eрitim ve tatbikat tutanak

New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ TANAP-CIN-TRA-TNP-0493.pdf \

ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Management Plan - Annex C

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Quality (SO2, NOX, O3) Baseline Report\ANNEXES\Annex I_The Analysis Reports

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-3 Lab Results for Core Sample

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-4 SDigital Data

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-5 Information and Calibration for Equipmant

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-6 Education Documents

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-7 Photos

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-8 Mozaic Map

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-

9 Seismic Profile

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-1 Bathymetric Map and Report

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-2 Lab Results


EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ RAP Disclosure

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APPENDIX B: IFC EHS GUIDELINES COMPLIANCE ASSESSMENT TABLE

Demonstrates Compliance Item is considered in compliance with Local and/or International requirements/standards (based on IESC review of TANAP ESIA)

Compliance Anticipated

Item is considered in compliance with Local and/or International requirements/standards (based on IESC site visit of construction corridor and TANAP operational standards and existing construction phase Environment, Social and OHS documentation)

Partial Compliance

Project’s progress and/or information/data available to date are partially adequate to fulfil Local and/or International requirements/standards, further work is needed to achieve compliance

Not Applicable Item does not apply to this Project

General IFC EHS Guidelines Requirements Compliance Category

Environmental Protection

1. Air Emissions and Ambient Air Quality

Ambient Air Quality

1.1. Emissions do not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards, or in their absence, the current WHO Air Quality Guidelines.

Demonstrates Compliance

1.2. Projects with significant sources of air emissions, and potential for significant impacts to ambient air quality, should prevent or minimize impacts by ensuring that: emissions do not contribute a significant portion to the attainment of relevant ambient air quality guidelines or standards. As a general rule, this Guideline suggests 25 percent of the applicable air quality standards to allow additional, future sustainable development in the same airshed.


1.3. At facility level, impacts should be estimated through qualitative or quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models to assess potential ground level concentrations. Local atmospheric, climatic, and air

quality data should be applied when modeling dispersion, protection against atmospheric downwash, wakes, or eddy effects of the source, nearby structures, and terrain features. The dispersion model applied should be internationally recognised, or comparable.

Demonstrates

Compliance

1.4. Facilities or projects located within poor quality airsheds, and within or next to areas established as ecologically sensitive (e.g. national parks), should ensure that any increase in pollution levels is as small as feasible, and amounts to a fraction of the applicable short-term and annual average air quality guidelines or standards as established in the project-specific environmental assessment. Suitable mitigation measures should also include the relocation of significant sources of emissions outside the airshed in question, use of cleaner fuels or technologies, application of comprehensive pollution control measures, offset activities at installations controlled by the project sponsor or other facilities within the same airshed, and buy-down of emissions within the same airshed.


Point Sources

1.5. The stack height for all point sources of emissions should be designed according to good international industry practice (GIP).


1.6. Emissions from small combustion process installations (3 MWth - 50 MWth), operated more than 500 hours per year, and those with an annual capacity utilisation of more than 30 percent should be in compliance with standards, recommended by General EHS guidelines of IFC.

Not Applicable

Fugitive Sources

1.7. Volatile Organic Compounds (VOC) emissions associated with equipment leaks should be prevented and controlled by techniques including: Equipment modifications; Implementation a leak detection and repair (LDAR) program that controls fugitive

emissions by regularly monitoring to detect leaks, and implementing repairs within a predefined time period;



Substitution of less volatile substances; Collection of vapours through air extractors and subsequent; Treatment with destructive control devices; Use of floating roofs on storage tanks.

1.8. Dust control methods should be implemented to prevent particulate matter (dust) emissions including the following: Covers, water suppression, or increased moisture content for open materials storage piles; Use of water suppression for control of loose materials on paved or unpaved road surfaces.


1.9. Open burning of solid wastes, whether hazardous or nonhazardous, is not considered good practice and should be avoided.


1.10. No new systems or processes should be installed using CFCs, halons, 1,1,1- trichloroethane, carbon tetrachloride, methyl bromide or HBFCs.


Mobile Sources – Land-based

1.11 Emissions from on-road and off-road vehicles should comply with national or regional programs. In the absence of these, the following approach should be considered: Implementation of the manufacturer recommended engine maintenance programs; Drivers should be instructed on the benefits of driving practices that reduce both the risk of

accidents and fuel consumption, including measured acceleration and driving within safe speed limits;

Operators with fleets of 120 or more units of heavy duty vehicles, or 540 or more light duty vehicles within an airshed should consider additional ways to reduce potential impacts including replacing older vehicles with newer, more fuel efficient alternatives; Converting high-use vehicles to cleaner fuels, where feasible;

Installing and maintaining emissions control devices, such as catalytic converters; Implementing a regular vehicle maintenance and repair program.


Greenhouse Gases (GHGs)

1.12. The following measures should be implemented to reduce and control greenhouse gases: Carbon financing; Protection and enhancement of sinks and reservoirs of greenhouse gases; Carbon capture and storage technologies; Limitation and / or reduction of methane emissions; Enhancement of energy efficiency.


Air quality monitoring

1.13. Air quality monitoring program should be developed. The monitoring parameters selected should reflect the pollutants of concern associated with project processes. The air quality monitoring program should consider the following elements: baseline calculations; monitoring type and frequency (data on emissions and ambient air quality generated

through the monitoring program should be representative of the emissions discharged by the project over time);

monitoring locations; sampling and analysis methods (monitoring programs should apply national or international

methods for sample collection and analysis).

Partial Compliance

1.14. Annual Stack Emission Testing of boilers with capacities between =3 MWth and < 20 MWth should be carried out to control SO2, NOx and PM (for gaseous fuel- fired boilers, only NOx). SO2 can be calculated based on fuel quality certification if no SO2 control equipment is used. If Annual Stack Emission Testing demonstrates results consistently and significantly better than the required levels, frequency of Annual Stack Emission Testing can be reduced from

annual to every two or three years. Annual Stack Emission Testing of boilers with capacities between =20 MWth and < 50 MWth should be carried out to control SO2, NOx and PM (for gaseous fuel-fired boilers, only NOx). Emission Monitoring: SO2. Plants with SO2 control equipment: Continuous. NOx: Continuous monitoring of either NOx emissions or indicative NOx emissions using

combustion parameters. PM: Continuous monitoring of either PM emissions, opacity, or indicative PM emissions

using combustion parameters / visual monitoring.

Partial Compliance

1.14. Air quality monitoring for turbines should include: Partial


Annual Stack Emission Testing: NOx, SO2 and PM (NOx only for gaseous fuel-fired diesel engines).

If Annual Stack Emission Testing results show constantly (3 consecutive years) and significantly (e.g. less than 75 percent) better than the required levels, frequency of Annual Stack Emission Testing can be reduced from annual to every two or three years.

Emission Monitoring: NOx: Continuous monitoring of either NOx emissions or indicative NOx emissions using combustion parameters. SO2: Continuous monitoring if SO2 control equipment is used. PM: Continuous monitoring of either PM emissions or indicative PM emissions using operating parameters.

Compliance

2. Energy Conservation

Energy Management Programs

2.1. Energy management programs should include the following elements: Identification, and regular measurement and reporting of principal energy flows within a

facility at unit process level; Preparation of mass and energy balance; Definition and regular review of energy performance targets, which are adjusted to account

for changes in major influencing factors on energy use;

Regular comparison and monitoring of energy flows with performance targets to identify where action should be taken to reduce energy use;

Regular review of targets, which may include comparison with benchmark data, to confirm that targets are set at appropriate levels.


Energy Efficiency

2.2. For any energy-using system, a systematic analysis of energy efficiency improvements and cost reduction opportunities should include a hierarchical examination of opportunities to: Demand/Load Side Management by reducing loads on the energy system; Supply Side Management by reduce losses in energy distribution; improve energy

conversion efficiency; exploit energy purchasing opportunities; use lower- carbon fuels.


2.3. In process heating systems, a system heat and mass balance should be developed for examination of savings opportunities.


2.4. Special measures for heating load reduction should be used including the following: Ensure adequate insulation to reduce heat losses through furnace/oven etc. structure;

Recover heat from hot process or exhaust streams to reduce system loads; In intermittently-heated systems, consider use of low thermal mass insulation to reduce

energy required to heat the system structure to operating temperature; Control process temperature and other parameters accurately to avoid, for example,

overheating or overdrying; Examine opportunities to use low weight and/or low thermal mass product carriers, such as

heated shapers, kiln cars etc.; Review opportunities to schedule work flow to limit the need for process reheating between

stages; Operate furnaces/ovens at slight positive pressure, and maintain air seals to reduce air in-

leakage into the heated system, thereby reducing the energy required to heat unnecessary air to system operating temperature;

Robust Scheduled maintenance programs.


2.5. Losses in heat distribution systems should be reduced through the following actions: Promptly repair distribution system leaks; Regularly verify correct operation of steam traps in steam systems, and ensure that traps

are not bypassed;

Insulate distribution system vessels, such as hot wells and de-aerators, in steam systems and thermal fluid or hot water storage tanks;

In steam systems, return condensate to the boiler house for re-use, since condensate is expensive boiler-quality water and valuable beyond its heat content alone.


2.6. The following efficiency opportunities should be examined for process furnaces or ovens, and utility systems, such as boilers and fluid heaters: Regularly monitor CO, oxygen or CO2 content of flue gases to verify that combustion

systems are using the minimum practical excess air volumes; Consider combustion automation using oxygen-trim controls; Minimise the number of boilers or heaters used to meet loads;



Use flue dampers to eliminate ventilation losses from hot boilers held at standby; Maintain clean heat transfer surfaces; In steam boiler systems, use economisers to recover heat from flue gases to pre-heat

boiler feed water or combustion air; Adopt automatic (continuous) boiler blowdown; Recover heat from blowdown systems through flash steam recovery or feed- water

preheat; With fired heaters, consider opportunities to recover heat to combustion air through the

use of recuperative or regenerative burner systems; Oxy Fuel burners; Fuel quality control/fuel blending and etc.

2.7. Special measures to improve process cooling efficiency should be used including the following: Ensure adequate insulation; Control process temperature; Operate cooling tunnels at slight positive pressure and maintain air seals to reduce air in-

leakage into the cooled system;

Examine opportunities to pre-cool using heat recovery to a process stream requiring heating, or by using a higher temperature cooling utility;

In cold and chill stores, minimise heat gains to the cooled space by use of air curtains, entrance vestibules, or rapidly opening/closing doors;

Do not use refrigeration for auxiliary cooling duties, such as compressor cylinder head or oil cooling;

Use energy efficiency techniques in air conditioning applications.


2.8. The efficiency of cooling systems should be improved by effective refrigeration system design and increased refrigerant compression efficiency, as well as minimisation of the temperature difference through which the system works and of auxiliary loads used to operate the refrigeration system.


2.9. Refrigerant compression efficiency should be improved by avoiding operation of multiple compressors at part-load conditions; considering turndown efficiency when specifying chillers.


2.10. Energy use of refrigeration system auxiliaries (e.g. evaporator fans and chilled water pumps) should be reduced.


Compressed Air Systems

2.11. Special energy conservation measures should be used including : examination of each true user of compressed air to identify the air volume needed and the

pressure at which this should be delivered; air use reduction opportunities review.


2.12. Monitoring of pressure losses in filters should be provided. Adequately sized distribution pipework designed to minimise pressure losses should be used.


3. Wastewater and Ambient Water Quality

General applicability and approach

3.1. In the context of their overall ESHS management system, facilities should understand the quality, quantity, frequency and sources of liquid effluents in its installations.


3.2. Segregation of liquid effluents principally along industrial, utility, sanitary, and rainwater categories should be planed and implemented, in order to limit the volume of water requiring specialised treatment.


3.3. Opportunities should be identified to prevent or reduce wastewater pollution through such measures as recycle/reuse within their facility, input substitution, or process modification.


3.4. Wastewater discharges should be compliant with the applicable: (i) discharge standard (if the wastewater is discharged to a surface water or sewer), and (ii) water quality standard for a specific reuse.


3.5. Water use efficiency should be provided to reduce the amount of wastewater generation.


3.6. Process modification should be implemented, including waste minimisation, and reducing the use of hazardous materials to reduce the load of pollutants requiring treatment.


3.7. When wastewater treatment is required prior to discharge, the level of treatment should be based on: National and local standards as reflected in permit requirements and sewer system capacity



to convey and treat wastewater if discharge is to sanitary sewer; Assimilative capacity of the receiving water for the load of contaminant being discharged

wastewater if discharge is to surface water; Intended use of the receiving water body; Presence of sensitive receptors; GIP for the relevant industry sector.

Liquid Effluent Quality

3.8. Discharges of process wastewater, sewage, wastewater from utility operations or rainwater to surface water should not result in contaminant concentrations in excess of local ambient water quality criteria or, in the absence of local criteria, other sources of ambient water quality. Receiving water use and assimilative capacity, taking other sources of discharges to the receiving water into consideration, should also influence the acceptable pollution loadings and effluent discharge quality. Temperature of wastewater prior to discharge should not result in an increase greater than 3°C of ambient temperature at the edge of a scientifically established mixing zone which takes into account ambient water quality, receiving water use and assimilative capacity

among other considerations.


3.9. Discharges of industrial wastewater, sewage, wastewater from utility operations or rainwater into public or private wastewater treatment systems should: Meet the pre-treatment and monitoring requirements of the sewer treatment system into

which it discharges; Not interfere, directly or indirectly, with the operation and maintenance of the collection

and treatment systems, or pose a risk to worker health and safety, or adversely impact characteristics of residuals from wastewater treatment operations;

Be discharged into municipal or centralised wastewater treatment systems that have adequate capacity to meet local regulatory requirements for treatment of wastewater • Generated from the project. Pre-treatment of wastewater to meet regulatory requirements before discharge from the project site is required if the municipal or centralised wastewater treatment system receiving wastewater from the project does not have adequate capacity to maintain regulatory compliance.


3.10. The quality of treated process wastewater, wastewater from utility operations or rainwater discharged on land, including wetlands, should be established based on local regulatory requirements. Where land is used as part of the treatment system and the ultimate receptor is surface water, water quality guidelines for surface water discharges specific to the industry sector process should apply. Potential impact on soil, groundwater, and surface water, in the context of protection, conservation and long term sustainability of water and land resources should be assessed when land is used as part of any wastewater treatment system.


3.11. Septic systems should be used for treatment and disposal of domestic sanitary sewage in areas with no sewerage collection networks. When septic systems are the selected form of wastewater disposal and treatment, they should be: Properly designed and installed in accordance with local regulations and guidance to

prevent any hazard to public health or contamination of land, surface or groundwater. Well maintained to allow effective operation. Installed in areas with sufficient soil percolation for the design wastewater loading rate. Installed in areas of stable soils that are nearly level, well drained, and permeable, with

enough separation between the drain field and the groundwater table or other receiving waters.


3.12. Treatment technologies should be used to achieve the desired discharge quality for process wastewater and to maintain consistent compliance with regulatory requirements. The design and operation of the selected wastewater treatment technologies should avoid uncontrolled air emissions of volatile chemicals from wastewaters. Residuals from industrial wastewater treatment operations should be disposed in compliance with local regulatory requirements. Recommended water management strategies for utility operations include: Adoption of water conservation opportunities for facility cooling systems; Use of heat recovery methods or other cooling methods to reduce the temperature of

heated water prior to discharge to ensure the discharge water temperature does not result in an increase greater than 3°C of ambient temperature;



Minimising use of antifouling and corrosion inhibiting chemicals by ensuring appropriate depth of water intake and use of screens;

Testing for residual biocides and other pollutants of concern should be conducted to determine the need for dose adjustments or treatment of cooling water prior to discharge. Rainwater should be separated from process and sewage streams. Surface runoff from process areas or potential sources of contamination should be prevented. Runoff from process and storage areas should be segregated from potentially less contaminated runoff. Runoff from areas without potential sources of contamination should be minimised. Sludge from rainwater catchments or collection and treatment systems should be disposed in compliance with local regulatory requirements, in the absence of which disposal has to be consistent with protection of public health and safety, and conservation and long term sustainability of water and land resources.

3.13. Recommended sewage management strategies include: Segregation of wastewater streams to ensure compatibility with selected treatment option; Segregation and pre-treatment of oil and grease containing effluents prior to discharge into

sewer systems; If sewage from the industrial facility is to be discharged to surface water, treatment to

meet national or local standards for sewage discharges; If sewage from the industrial facility is to be discharged to either a septic system, or where

land is used as part of the treatment system, treatment to meet applicable national or local standards for sewage discharges is required;

Sludge from sewage treatment systems should be disposed in compliance with local regulatory requirements.


3.14. A wastewater and water quality monitoring program with adequate resources and management oversight should be developed and implemented. The wastewater and water quality monitoring program should consider monitoring parameters, monitoring type and frequency, monitoring locations, data quality.


4. Water Conservation

Water conservation program

4.1. Water conservation programs should be implemented commensurate with the magnitude and cost of water use. These programs should promote the continuous reduction in water consumption and achieve savings in the water pumping, treatment and disposal costs.


4.2. The essential elements of a water management program should involve: Identification, regular measurement, and recording of principal flows within a facility. Definition and regular review of performance targets, which are adjusted to account for

changes in major factors affecting water use. Regular comparison of water flows with performance targets to identify where action

should be taken to reduce water use. 4.3. Water should be reused in multi-stage washing and rinsing processes or from one process for another with less exacting water quality requirements.


4.4. Measures for water saving should be implemented to reduce consumption of building and sanitary water, including: Regularly maintain plumbing, and identify and repair leaks; Install self-closing taps, automatic shut-off valves, spray nozzles, pressure reducing valves,

and water conserving fixtures; Operate dishwashers and laundries on full loads, and only when needed; Install water-saving equipment in lavatories, such as lowflow toilets.


4.5. Water conservation opportunities in cooling systems should include: Use of closed circuit cooling systems with cooling towers rather than once-through cooling

systems; Limiting condenser or cooling tower blowdown to the minimum required to prevent

unacceptable accumulation of dissolved solids; Use of air cooling rather than evaporative cooling; Use of treated waste water for cooling towers; Reusing/recycling cooling tower blowdown.


4.6. Large quantities of water may be used by steam systems, and this should be reduced by the following measures: Repair of steam and condensate leaks, and repair of all failed steam traps; Return of condensate to the boilerhouse, and use of heat exchangers (with condensate

return) rather than direct steam injection where process permits;



Flash steam recovery; Minimising boiler blowdown consistent with maintaining acceptably low dissolved solids in

boiler water; Minimising deaerator heating.

5. Hazardous Materials Management

General Hazardous Materials Management

5.1. The level of risk should be established through an on-going assessment process based on: The types and amounts of hazardous materials present in the project. Analysis of potential spill and release scenarios using available industry statistics on spills

and accidents where available. Analysis of the potential for uncontrolled reactions such as fire and explosions. Analysis of potential consequences based on the physical geographical characteristics of

the project site, including aspects such as its distance to settlements, water resources, and other environmentally sensitive areas.


5.2. The management actions to be included in a Hazardous Materials Management Plan should be commensurate with the level of potential risks associated with the production, handling, storage, and use of hazardous materials.


5.3. Where there is risk of a spill of uncontrolled hazardous materials, facilities should prepare a spill control, prevention, and countermeasure plan as a specific component of their Emergency Preparedness and Response Plan.


5.4. The plan should be tailored to the hazards associated with the project, and include: Training of Operators on release prevention, including drills specific to hazardous materials

as part of emergency preparedness response training; Implementation of inspection programs to maintain the mechanical integrity and operability

of pressure vessels, tanks, piping systems, relief and vent valve systems, containment infrastructure, emergency shutdown systems, controls and pumps, and associated process equipment;

Preparation of written Standard Operating Procedures (SOPs) for filling USTs, ASTs or other containers or equipment as well as for transfer operations by personnel trained in the safe transfer and filling of the hazardous material, and in spill prevention and response;

SOPs for the management of secondary containment structures; Identification of locations of hazardous materials and associated activities on an emergency

plan site map;

Documentation of availability of specific personal protective equipment and training needed to respond to an emergency;

Documentation of availability of spill response equipment; Description of response activities in the event of a spill, release, or other chemical

emergency.


5.5. Recommended practices to prevent hazardous material releases from transfer processes include: Use of transfer equipment that is compatible and suitable for the characteristics of the

materials transferred and designed to ensure safe transfer; Regular inspection, maintenance and repair of fittings, pipes and hoses; Provision of secondary containment, drip trays or other overflow and drip containment

measures, for hazardous materials containers at connection points or other possible overflow points.


5.6. Special measures should be implemented to prevent overfills of vessels and tanks, including: Prepare written procedures for transfer operations; Installation of gauges on tanks to measure volume inside;

Use of dripless hose connections for vehicle tank and fixed connections with storage tanks; Provision of automatic fill shutoff valves on storage tanks to prevent overfilling; Use of a catch basin around the fill pipe to collect spills; Use of piping connections with automatic overfill protection; Pumping less volume than available capacity into the tank or vessel by ordering less

material than its available capacity; Provision of overfill or over pressure vents that allow controlled release to a capture point.


5.7. Special measures should be implemented to avoid uncontrolled reactions or conditions resulting in fire or explosion, including: Storage of incompatible materials (acids, bases, flammables, oxidisers, reactive chemicals)



in separate areas, and with containment facilities separating material storage areas; Provision of material-specific storage for extremely hazardous or reactive materials; Use of flame arresting devices on vents from flammable storage containers; Provision of grounding and lightning protection for tank farms, transfer stations, and other

equipment that handles flammable materials; Selection of materials of construction compatible with products stored for all parts of

storage and delivery systems, and avoiding reuse of tanks for different products without checking material compatibility;

Storage of hazardous materials in an area of the facility separated from the main production works. Where proximity is unavoidable, physical separation should be provided using structures designed to prevent fire, explosion, spill, and other emergency situations from affecting facility operations;

Prohibition of all sources of ignition from areas near flammable storage tanks.

Control Measures

5.8. Secondary containment should be used to control accidental releases of liquid hazardous materials during storage and transfer. Secondary containment design and construction should hold released materials effectively until they can be detected and safely recovered. Appropriate secondary containment structures consist of berms, dikes, or walls capable of containing the larger of 110 percent of the largest tank or 25 percent of the combined tank volumes in areas with above-ground tanks with a total storage volume equal or greater than 1,000 liters.


5.9. Transfer of hazardous materials from vehicle tanks to storage should be affected in areas with surfaces sufficiently impervious to avoid loss to the environment and sloped to a collection or a containment structure not connected to municipal wastewater / rainwater collection system.


5.10. Where it is not practical to provide permanent, dedicated containment structures for transfer operations, one or more alternative forms of spill containment should be provided, such as portable drain covers, automatic shut-off valves on storm water basins, or shut off valves in drainage or sewer facilities, combined with oil-water separators.


5.11. Storage of drummed hazardous materials with a total volume equal or greater than 1,000 liters should be affected in areas with impervious surfaces that are sloped or bermed to contain a minimum of 25 percent of the total storage volume.


5.12. Double-walled, composite, or specially coated storage and piping systems should be used particularly for underground storage tanks (USTs) and underground piping. If double

walled systems are used, they should provide a means of detecting leaks between the two walls.


5.13. Leak detection may be used in conjunction with secondary containment, particularly in high-risk locations. Leak detection is especially important in situations where secondary containment is not feasible or practicable, such as in long pipe runs. Acceptable leak detection methods include: Use of automatic pressure loss detectors on pressurised or long distance piping; Use of approved or certified integrity testing methods on piping or tank systems, at regular

intervals; Considering the use of SCADA if financially feasible.


5.14. Special measures should be implemented for underground storage of hazardous materials to manage the risks of fire or explosion, vapor losses into the atmosphere, leaks of hazardous materials, including: Avoiding use of USTs for storage of highly soluble organic materials; Assessing local soil corrosion potential, and installing and maintaining cathodic protection

(or equivalent rust protection) for steel tanks; For new installations, installing impermeable liners or structures under and around tanks

and lines that direct any leaked product to monitoring ports at the lowest point of the liner or structure;

Monitoring the surface above any tank for indications of soil movement; Reconciling tank contents by measuring the volume in store with the expected volume,

given the stored quantity at last stocking, and deliveries to and withdrawals from the store; Testing integrity by volumetric, vacuum, acoustic, tracers, or other means on all tanks at

regular intervals; Evaluating the risk of existing UST in newly acquired facilities to determine if upgrades are

required for USTs that will be continued to be used, including replacement with new systems or permanent closure of abandoned USTs.



5.15. Hazardous Materials Risk Management Plan should be prepared to prevent and control of catastrophic releases of toxic, reactive, flammable, or explosive chemicals that may result in toxic, fire, or explosion hazards.


5.16. An Emergency Preparedness and Response Plan incorporated into and consistent with, the facility’s overall ES/OHS MS, should be prepared to cover the following: Planning Coordination: Procedures should be prepared for informing the public and

emergency response agencies; documenting first aid and emergency medical treatment; taking emergency response actions; reviewing and updating the emergency response plan to reflect changes, and ensuring that employees are informed of such changes;

Procedures should be prepared for using, inspecting, testing, and maintaining the emergency response equipment;

Employees and contractors should be trained on emergency response procedures.


5.17. When hazardous materials are in use above threshold quantities, the management plan should include a system for community awareness, notification and involvement that should be commensurate with the potential risks identified for the project during the hazard assessment studies (availability of general information to the potentially affected community on the nature and extent of project operations, and the prevention and control measures in place to ensure no effects to human health; the potential for off-site effects to human health or the environment following an accident at planned or existing hazardous installations; specific and timely information on appropriate behavior and safety measures to be adopted in the event of an accident including practice drills in locations with higher risks).


6. Waste Management

General Waste Management

6.1. Facilities that generate and store wastes should practice the following: Establishing waste management priorities at the outset of activities based on an

understanding of potential Environmental, Health, and Safety (EHS) risks and impacts and considering waste generation and its consequences;

Establishing a waste management hierarchy that considers prevention, reduction, reuse, recovery, recycling, removal and finally disposal of wastes;

Avoiding or minimising the generation waste materials, as far as practicable; Where waste generation cannot be avoided but has been minimised, recovering and

reusing waste; Where waste cannot be recovered or reused, treating, destroying, and disposing of it in an

environmentally sound manner.


6.2. Effective planning and implementation of waste management strategies should include: Review of new waste sources during planning, siting, and design activities, including during

equipment modifications and process alterations, to identify expected waste generation, pollution prevention opportunities, and necessary treatment, storage, and disposal infrastructure;

Definition of opportunities for source reduction, as well as reuse and recycling; Definition of procedures and operational controls for onsite storage; Definition of options / procedures / operational controls for treatment and final disposal.


6.3. Potential impacts and risks associated with the management of any generated hazardous waste should be assessed during its complete life cycle.


6.4. It should be ensured that contractors handling, treating, and disposing of hazardous waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies and following good international industry practice for the waste being handled.


6.5. Processes should be designed and operated to prevent, or minimise, the quantities of wastes generated and hazards associated with the wastes generated in accordance with the following strategy:

Substituting raw materials or inputs with less hazardous or toxic materials, or with those where processing generates lower waste volumes;

Applying manufacturing process that convert materials efficiently; Instituting good housekeeping and operating practices, including inventory control to

reduce the amount of waste resulting from materials that are out-of- date, off-specification, contaminated, damaged, or excess to plant needs;

Instituting procurement measures that recognise opportunities to return usable materials such as containers and which prevents the over ordering of materials;

Minimising hazardous waste generation by implementing stringent waste segregation to prevent the commingling of non-hazardous and hazardous waste to be managed.



6.6. Total amount of waste may be significantly reduced through the implementation of recycling plans, which should consider the following elements: Identification and recycling of products that can be reintroduced into the manufacturing

process or industry activity at the site; Investigation of external markets for recycling by other industrial processing operations

located in the neighbourhood or region of the facility; Providing training and incentives to employees in order to meet objectives.


6.7. If waste materials are still generated after the implementation of feasible waste prevention, reduction, reuse, recovery and recycling measures, waste materials should be treated and disposed of and all measures should be taken to avoid potential impacts to human health and the environment. Such measures should include the following: On-site or off-site biological, chemical, or physical treatment of the waste material to

render it nonhazardous prior to final disposal; Treatment or disposal at permitted facilities specially designed to receive the waste.


6.8. In the absence of qualified commercial or government-owned waste vendors and disposal Operators (taking into consideration proximity and transportation requirements), facilities generating waste should consider using: Have the technical capability to manage the waste in a manner that reduces immediate

and future impact to the environment; Installing on-site waste treatment or recycling processes; As a final option, constructing facilities that will provide for the environmental sound long-

term storage of wastes on-site or at an alternative appropriate location up until external commercial options become available.


Waste storage

6.9. Wastes should be stored in a manner that prevents the commingling or contact between incompatible wastes.


6.10. Different type of wastes should be stored in different closed containers away from direct sunlight, wind and rain.


6.11. Periodic inspections of waste storage areas should be conducted with documenting the findings.


6.12. Secondary containment should be included wherever liquid wastes are stored in volumes greater than 220 liters. The available volume of secondary containment should be at least 110 percent of the largest storage container, or 25 percent of the total storage capacity (whichever is greater), in that specific location.


6.13. Adequate ventilation should be provided where volatile wastes are stored. Demonstrates Compliance

6.14. Hazardous waste storage activities should also be subject to special management actions, conducted by employees who have received specific training in handling and storage of hazardous wastes: Provision of readily available information on chemical compatibility to employees, including

labelling each container to identify its contents; Clearly identifying (label) and demarcating the area, including documentation of its location

on a facility map or site plan; Conducting periodic inspections of waste storage areas and documenting the findings; Preparing and implementing spill response and emergency plans to address their accidental

release; Avoiding underground storage tanks and underground piping of hazardous waste.

Partial Compliance

Transportation

6.15. On-site and Off-site transportation of waste should be conducted so as to prevent or minimise spills, releases, and exposures to employees and the public.

All waste containers designated for off-site shipment should be secured and labeled with the contents and associated hazards, be properly loaded on the transport vehicles before leaving the site, and be accompanied by a shipping paper that describes the load and its associated hazards.


Monitoring

6.16. Monitoring activities associated with the management of hazardous and nonhazardous waste should include: Regular visual inspection of all waste storage collection and storage areas for evidence of

accidental releases and to verify that wastes are properly labelled and stored. Regular audits of waste segregation and collection practices;

Partial Compliance


Periodic auditing of third party treatment, and disposal services including re-use and recycling facilities when significant quantities of hazardous wastes are managed by third parties;

Regular monitoring of groundwater quality in cases of Hazardous Waste on site storage and/or pre-treatment and disposal.

7. Noise

Prevention and Control

7.1. Noise impacts should not exceed the following levels: 55 One Hour LAeq (dBA) at daytime for residential; institutional; educational receptors; 45 One Hour LAeq (dBA) at night time for residential; institutional; educational receptors; 70 One Hour LAeq (dBA) at daytime and night time for industrial; commercial receptors.


7.2. Noise prevention and mitigation measures should be applied where predicted or measured noise impacts from a project facility or operations exceed the applicable noise level guideline at the most sensitive point of reception. Noise reduction options that should be considered include: Selecting equipment with lower sound power levels; Installing silencers for fans;

Installing suitable mufflers on engine exhausts and compressor components; Installing acoustic enclosures for equipment casing radiating noise; Improving the acoustic performance of constructed buildings, apply sound insulation; Limiting the hours of operation for specific pieces of equipment or operations, especially

mobile sources operating through community areas; Reducing project traffic routing through community areas wherever possible Developing a mechanism to record and respond to complaints.


Monitoring

7.3. Noise monitoring programs should be designed and conducted by trained specialists. Typical monitoring periods should be sufficient for statistical analysis.


8. Contaminated Land

Prevention of land contamination

8.1. Contamination of land should be avoided by preventing or controlling the release of hazardous materials, hazardous wastes, or oil to the environment.


8.2. When contamination of land is suspected or confirmed during any project phase, the cause of the uncontrolled release should be identified and corrected to avoid further releases

and associated adverse impacts.


8.3. Contaminated lands should be managed to avoid the risk to human health and ecological receptors.


8.4. The preferred strategy for land decontamination is to reduce the level of contamination at the site while preventing the human exposure to contamination.


Risk assessment

8.5. Where there is potential evidence of contamination at a site, the following steps should be provided: Identification of the location of suspected highest level of contamination through a

combination of visual and historical operational information; Sampling and testing of the contaminated media (soils or water); Evaluation of the analytical results against the local and national contaminated sites

regulations; Verification of the potential human and/or ecological receptors and exposure pathways

relevant to the site in question.


8.6. Interim risk management actions should be implemented at any phase of the project life cycle if the presence of land contamination poses an “imminent hazard”, i.e., representing

an immediate risk to human health and the environment if contamination were allowed to continue, even a short period of time. Appropriate risk reduction should be implemented as soon as practicable to remove the condition posing the imminent hazard.


8.7. If the presence of land contamination poses an “imminent hazard”, a detailed site- specific, environmental risk assessment should be used to develop strategies that yield acceptable health risks, while achieving low level contamination on-site.


8.8. The risk factors and conceptual site model within the contaminant risk approach described should also provide a basis to manage and mitigate environmental contaminant health risks.



Occupational Health and Safety

9. General Facility Design and Operation

Integrity of Workplace Structures

9.1. Permanent and recurrent places of work should be designed and equipped to protect OHS: Surfaces, structures and installations should be easy to clean and maintain, and not allow

for accumulation of hazardous compounds; Buildings should be structurally safe, provide appropriate protection against the climate,

and have acceptable light and noise conditions; Fire resistant, noise-absorbing materials should, to the extent feasible, be used for cladding

on ceilings and walls; Floors should be level, even, and non- skid; Heavy oscillating, rotating or alternating equipment should be located in dedicated

buildings or structurally isolated sections.


Severe Weather and Facility Shutdown

9.2. Work place structures should be designed and constructed to withstand the expected elements for the region and have an area designated for safe refuge, if appropriate.


9.3. Standard Operating Procedures (SOPs) should be developed for project or process shut-down, including an evacuation plan. Drills to practice the procedure and plan should also be undertaken annually.


Workspace and Exit

9.4. The space provided for each worker, and in total, should be adequate for safe execution of all activities, including transport and interim storage of materials and products. Passages to emergency exits should be unobstructed at all times. Exits should be clearly marked to be visible in total darkness. The number and capacity of emergency exits should be sufficient for safe and orderly evacuation of the greatest number of people present at any time, and there should be a minimum two exits from any work area. Facilities also should be designed and built taking into account the needs of disabled persons.


Fire Precautions

9.5. The workplace should be designed to prevent the start of fires through the implementation of fire codes applicable to industrial settings.


9.6. Facilities should be equipped with fire detectors, alarm systems, and fire-fighting equipment. The equipment should be maintained in good working order and be readily accessible. It should be adequate for the dimensions and use of the premises, equipment installed, physical and chemical properties of substances present, and the maximum number of people present.


9.7. Fire and emergency alarm systems that are both audible and visible. Demonstrates Compliance

Lavatories and Showers

9.8. Adequate lavatory facilities (toilets and washing areas) should be provided for the number of people expected to work in the facility and allowances made for segregated facilities, or for indicating whether the toilet facility is “In Use” or “Vacant”. Toilet facilities should also be provided with adequate supplies of hot and cold running water, soap, and hand drying devices. Where workers may be exposed to substances poisonous by ingestion and skin contamination may occur, facilities for showering and changing into and out of street and work clothes should be provided.


9.9. Adequate supplies of potable drinking water should be provided from a fountain with an upward jet or with a sanitary means of collecting the water for the purposes of drinking. Water supplied to areas of food preparation or for the purpose of personal hygiene (washing or bathing) should meet drinking water quality standards.


9.10. Where there is potential for exposure to substances poisonous by ingestion, suitable arrangements are to be made for provision of clean eating areas where workers are not exposed to the hazardous or noxious substances.


Safe Access

9.11. Passageways for pedestrians and vehicles within and outside buildings should be segregated and provide for easy, safe, and appropriate access.


9.12. Equipment and installations requiring servicing, inspection, and/or cleaning should Demonstrates


have unobstructed, unrestricted, and ready access. Compliance

9.13. Hand, knee and foot railings should be installed on stairs, fixed ladders, platforms, permanent and interim floor openings, loading bays, ramps, etc.


9.14. Openings should be sealed by gates or removable chains. Demonstrates Compliance

9.15. Covers should, if feasible, be installed to protect against falling items. Demonstrates Compliance

9.16. Measures to prevent unauthorised access to dangerous areas should be in place. Demonstrates Compliance

First Aid

9.17. The employer should ensure that qualified first-aid can be provided at all times. Appropriately equipped first-aid stations should be easily accessible throughout the place of work.


9.18. Eye-wash stations and/or emergency showers should be provided close to all workstations where immediate flushing with water is the recommended first-aid response.


9.19. Remote sites should have written emergency procedures in place for dealing with

cases of trauma or serious illness up to the point at which patient care can be transferred to an appropriate medical facility.

Demonstrates

Compliance

Air Supply

9.20. Sufficient fresh air should be supplied for indoor and confined work spaces. Factors to be considered in ventilation design include physical activity, substances in use, and process related emissions. Air distribution systems should be designed so as not to expose workers to draughts.


9.21. Mechanical ventilation systems should be maintained in good working order. Point- source exhaust systems required for maintaining a safe ambient environment should have local indicators of correct functioning.


9.22. Re-circulation of contaminated air is not acceptable. Air inlet filters should be kept clean and free of dust and microorganisms. Heating, ventilation and air conditioning (HVAC) and industrial evaporative cooling systems should be equipped, maintained and operated so as to prevent growth and spreading of disease agents or breeding of vectors of public health concern.


10. Communication and Training

OHS Training

10.1. Provisions should be made to provide OHS orientation training to all new employees. Demonstrates Compliance

10.2. Training should consist of basic hazard awareness, sites specific hazards, safe work practices, and emergency procedures for fire, evacuation, and natural disaster, as appropriate. Any site-specific hazard or color coding in use should be thoroughly reviewed as part of orientation training.


10.3. If visitors to the site can gain access to areas where hazardous conditions or substances may be present, a visitor orientation and control program should be established to ensure visitors do not enter hazard areas unescorted.


10.4. The employer should ensure that workers and contractors, prior to commencement of new assignments, have received adequate training and information enabling them to understand work hazards and to protect their health from hazardous ambient factors that may be present.


10.5. A basic occupational training program and specialty courses should be provided, as needed, to ensure that workers are oriented. Workers with rescue and first-aid duties should receive dedicated training so as not to inadvertently aggravate exposures and health hazards to themselves or their coworkers. Training would include the risks of becoming infected with blood–borne pathogens through contact with bodily fluids and tissue. Through appropriate contract specifications and monitoring, the employer should ensure that service providers, as well as contracted and subcontracted labor, are trained adequately before assignments begin.


Area Signage, Labeling of Equipment, Communicate Hazard Codes

10.6. Hazardous areas (electrical rooms, compressor rooms, etc.), installations, materials, safety measures, and emergency exits, etc. should be marked appropriately. Signage should be in accordance with international standards and be well known to, and easily understood by workers, visitors and the general public as appropriate.



10.7. All vessels that may contain substances that are hazardous as a result of chemical or toxicological properties, or temperature or pressure, should be labeled as to the contents and hazard, or appropriately color coded. Similarly, piping systems that contain hazardous substances should be labeled with the direction of flow and contents of the pipe, or color coded whenever the pipe passing through a wall or floor is interrupted by a valve or junction device.


10.8. Copies of the hazard coding system should be posted outside the facility at emergency entrance doors and fire emergency connection systems.


10.9. Information regarding the types of hazardous materials stored, handled or used at the facility, including typical maximum inventories and storage locations, should be shared proactively with emergency services and security personnel to expedite emergency response when needed.


10.10. Representatives of local emergency and security services should be invited to participate in periodic (annual) orientation tours and site inspections to ensure familiarity with potential hazards present.


11. Physical Hazards

Rotating and Moving Equipment

11.1. Machines design should eliminate trap hazards and ensuring that extremities are kept out of harm’s way under normal operating conditions. Where a machine or equipment has an exposed moving part or exposed pinch point that may endanger the safety of any worker, the machine or equipment should be equipped with, and protected by, a guard or other device that prevents access to the moving part or pinch point. Guards should be designed and installed in conformance with appropriate machine safety standards.


11.2. Turning off, disconnecting, isolating, and de-energising machinery with exposed or guarded moving parts, or in which energy can be stored (e.g. compressed air, electrical components) during servicing or maintenance, in conformance with a standard such as c.


11.3. Designing and installing equipment, where feasible, to enable routine service, such as lubrication, without removal of the guarding devices or mechanisms.


Noise

11.4. No employee should be exposed to a noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. In addition, no unprotected ear should be exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C).


11.5. The use of hearing protection should be enforced actively when the equivalent sound level over 8 hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average maximum sound level reaches 110dB(A). Hearing protective devices provided should be capable of reducing sound levels at the ear to at least 85 dB(A).


11.6. For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or duration should be reduced by 50 percent.


11.7. Prior to the issuance of hearing protective devices as the final control mechanism, use of acoustic insulating materials, isolation of the noise source, and other engineering controls should be investigated and implemented.


11.8. Periodic medical hearing checks should be performed on workers exposed to high noise levels.


Vibration

11.9. Exposure to hand-arm vibration from equipment such as hand and power tools, or whole-body vibrations from surfaces on which the worker stands or sits, should be controlled through choice of equipment, installation of vibration dampening pads or devices, and limiting the duration of exposure. Exposure levels should be checked on the basis of daily exposure time and data provided by equipment manufacturers.


Electrical

11.10. All energised electrical devices and lines should be marked with warning signs. Demonstrates Compliance

11.11. Devices should be locked out (de- charging and leaving open with a controlled locking device) and tagged-out (warning sign placed on the lock) during service or maintenance.


11.12. All electrical cords, cables, and hand power tools should be checked for frayed or exposed cords. Manufacturer recommendations for maximum permitted operating voltage of the portable hand tools should be followed.


11.13. Double insulating / grounding should be applied for all electrical equipment used in Demonstrates


environments that are, or may become, wet; using equipment with ground fault interrupter (GFI) protected circuits.

Compliance

11.14. Power cords and extension cords should be protected against damage from traffic by shielding or suspending above traffic areas.


11.15. Use of appropriate labeling of service rooms housing high voltage equipment (‘electrical hazard’) and where entry is controlled or prohibited.


11.16. “No Approach” zones should be established around or under high voltage power lines. Partial Compliance

11.17. Rubber tired construction or other vehicles that come into direct contact with, or arcing between, high voltage wires may need to be taken out of service for periods of 48 hours and have the tires replaced to prevent catastrophic tire and wheel assembly failure, potentially causing serious injury or death.


11.18. Conduct detailed identification and marking of all buried electrical wiring prior to any excavation work.


Eye Hazards

11.19. Use of machine guards or splash shields and/or face and eye protection devices, such as safety glasses with side shields, goggles, and/or a full face shield. Machine and equipment guarding should conform to standards published by organisations such as CSA, ANSI and ISO.


11.20. Moving areas where the discharge of solid fragments, liquid, or gaseous emissions can reasonably be predicted away from places expected to be occupied or transited by workers or visitors. Where machine or work fragments could present a hazard to transient workers or passers-by, extra area guarding or proximity restricting systems should be implemented, or PPE required for transients and visitors.


11.21. Provisions should be made for persons who have to wear prescription glasses either through the use over glasses or prescription hardened glasses.


Welding / Hot Work

11.22. Provision of proper eye protection such as welder goggles and/or a full-face eye shield for all personnel involved in, or assisting, welding operations. Additional methods may include the use of welding barrier screens around the specific work station (a solid piece of light metal, canvas, or plywood designed to block welding light from others). Devices to extract and remove noxious fumes at the source may also be required.


11.23. Special hot work and fire prevention precautions and Standard Operating Procedures

(SOPs) should be implemented if welding or hot cutting is undertaken outside established welding work stations, including ‘Hot Work Permits, stand-by fire extinguishers, stand-by fire watch, and maintaining the fire watch for up to one hour after welding or hot cutting has terminated. Special procedures are required for hot work on tanks or vessels that have contained flammable materials.

Demonstrates

Compliance

Industrial Vehicle Driving and Site Traffic

11.24. Provide training and licensing industrial vehicle Operators in the safe operation of specialised vehicles such as forklifts, including safe loading/unloading, load limits.


11.25. Ensure moving equipment with restricted rear visibility is outfitted with audible back-up alarms.


11.26. Establish rights-of-way, site speed limits, vehicle inspection requirements, operating rules and procedures, and control of traffic patterns or direction. Restrict the circulation of delivery and private vehicles to defined routes and areas, giving preference to ‘one-way’ circulation, where appropriate.


Working Environment Temperature

11.27. Extreme temperatures in permanent work environments should be avoided through implementation of engineering controls and ventilation.


11.28. Monitor weather forecasts for outdoor work to provide advance warning of extreme weather and scheduling work accordingly. Provide temporary shelters to protect against the elements during working activities or for use as rest areas.

Partial Compliance

11.29. Adjustment of work and rest periods should be regulated according to temperature stress management procedures provided by ACGIH67, depending on the temperature and workloads.


11.30. Personnel should be provided with protective clothing and access to adequate hydration such as drinking water or electrolyte drinks. Consumption of alcoholic beverages should be avoided.



Ergonomics, Repetitive Motion, Manual Handling

11.31. Use of mechanical assists to eliminate or reduce exertions required to lift materials, hold tools and work objects, and requiring multi-person lifts if weights exceed thresholds.


11.32. Selecting and designing tools that reduce force requirements and holding times, and improve postures.


11.33. Provide user with adjustable work stations. Demonstrates Compliance

11.34. Incorporating rest and stretch breaks into work processes, and conducting job rotation.


11.35. Implement quality control and maintenance programs that reduce unnecessary forces and exertions.


11.36. Take into consideration additional special conditions such as left handed persons. Demonstrates Compliance

Working at Heights

11.37. Provide installation of guardrails with mid-rails and toe boards at the edge of any fall hazard area.


11.38. Ladders and scaffolds should be properly used by trained employees. Demonstrates Compliance

11.39. Use of fall prevention devices, including safety belt and lanyard travel limiting devices to prevent access to fall hazard area, or fall protection devices such as full body harnesses used in conjunction with shock absorbing lanyards or self-retracting inertial fall arrest devices attached to fixed anchor point or horizontal life-lines.


11.40. Provide personnel with appropriate training in use, serviceability, and integrity of the necessary PPE.


11.41. Inclusion of rescue and/or recovery plans, and equipment to respond to workers after an arrested fall.


Illumination

11.42. Work area light intensity should be adequate for the general purpose of the location and type of activity, and should be supplemented with dedicated work station illumination, as needed.


11.43. Emergency lightening should be provided in case of tripping the main light source. Demonstrates Compliance

12. Chemical Hazards

Air Quality

12.1. Maintain levels of contaminant dusts, vapors and gases in the work environment at concentrations below those recommended by the ACGIH as TWA-TLV’s (threshold limit value)—concentrations to which most workers can be exposed repeatedly (8 hours/day, 40 hrs/week, week-after week), without sustaining adverse health effects.


12.2. Developing and implementing work practices to minimise release of contaminants into the work environment.


12.3. Where ambient air contains several materials that have similar effects on the same body organs (additive effects), taking into account combined exposures using calculations recommended by the ACGIH. Where work shifts extend beyond eight (8) hours, calculating adjusted workplace exposure criteria recommended by the ACGIH.


Fire and Explosions

12.4. Flammables should be stored away from ignition sources and oxidising materials. Further, flammables storage area should be: Remote from entry and exit points into buildings;

Away from facility ventilation intakes or vents; Have natural or passive floor and ceiling level ventilation and explosion venting; Use spark-proof fixtures; Be equipped with fire extinguishing devices and self-closing doors.


12.5. Provide bonding and grounding of, and between, containers and additional mechanical floor level ventilation if materials are being, or could be, dispensed in the storage area.


12.6. Where the flammable material is mainly comprised of dust, provide electrical grounding, spark detection, and, if needed, quenching systems.


12.7. Define and label fire hazards areas to warn of special rules (e.g. prohibition in use of smoking materials, cellular phones, or other potential spark generating equipment).



12.8. Provide specific worker training in handling of flammable materials, and in fire prevention or suppression.


Corrosive, oxidising, and reactive chemicals

12.9. Corrosive, oxidising and reactive chemicals should be segregated from flammable materials and from other chemicals of incompatible class (acids vs. bases, oxidisers vs. reducers, water sensitive vs. water based, etc.), stored in ventilated areas and in containers with appropriate secondary containment to minimise intermixing during spills. Workers who are required to handle corrosive, oxidising, or reactive chemicals should be provided with specialised training and provided with, and wear, appropriate PPE (gloves, apron, splash suits, face shield or goggles, etc.).


Asbestos Containing Materials (ACM)

12.10. The use of asbestos containing materials (ACM) should be avoided in new buildings or as a new material in remodeling or renovation activities. Existing facilities with ACM should develop an asbestos management plan which clearly identifies the locations where the ACM is present, its condition, procedures for monitoring its condition, procedures to access the locations where ACM is present to avoid damage, and training of staff who can potentially come into contact with the material. The plan should be made available to all

persons involved in operations and maintenance activities. Repair or removal and disposal of existing ACM in buildings should only be performed by specially trained personnel following host country requirements, or in their absence, internationally recognised procedures.


13. Biological Hazards

Measures to prevent biological hazards

13.1. If the nature of the activity permits, use of any harmful biological agents should be avoided and replaced with an agent that, under normal conditions of use, is not dangerous or less dangerous to workers. If use of harmful agents cannot be avoided, precautions should be taken to keep the risk of exposure as low as possible and maintained below internationally established and recognised exposure limits.


13.2. Work processes, engineering, and administrative controls should be designed, maintained, and operated to avoid or minimise release of biological agents into the working environment. The number of employees exposed or likely to become exposed should be kept at a minimum.


13.3. The employer should review and assess known and suspected presence of biological agents at the place of work and implement appropriate safety measures, monitoring,

training, and training verification programs.


13.4. Measures to eliminate and control hazards from known and suspected biological agents at the place of work should be designed, implemented and maintained in close co-operation with the local health authorities and according to recognised international standards.


13.5. Work involving agents in Groups 3 and 4 should be restricted only to those persons who have received specific verifiable training in working with and controlling such materials. Areas used for the handling of Groups 3 and 4 biological agents should be designed to enable their full segregation and isolation in emergency circumstances, include independent ventilation systems, and be subject to SOPs requiring routine disinfection and sterilisation of the work surfaces.


14. Radiological Hazards

Acceptable effective dose limits for workplace radiological hazards

14.1. Places of work involving occupational and/or natural exposure to ionising radiation should be established and operated in accordance with recognised international safety standards and guidelines. The acceptable effective dose limits appear: Five consecutive year average – effective dose– 20 mSv/year for workers (min. 19 years of

age);

Single year exposure– effective dose– 50 mSv/year for workers (min. 19 years of age); 6 mSv/year for apprentices and students (16-18 years of age);

Equivalent dose to the lens of the eye –150 mSv/year for workers (min. 19 years of age); 50 mSv/year for apprentices and students (16-18 years of age);

Equivalent dose to the extremities (hands, feet) or the skin – 500 mSv/year for workers (min. 19 years of age); 150 mSv/year for apprentices and students (16-18 years of age).


14.2. Exposure to non-ionising radiation (including static magnetic fields; sub-radio frequency magnetic fields; static electric fields; radio frequency and microwave radiation; light and near-infrared radiation; and ultraviolet radiation) should be controlled to internationally recommended limits.



14.3. In the case of both ionising and non- ionising radiation, the preferred method for controlling exposure is shielding and limiting the radiation source. Personal protective equipment is supplemental only or for emergency use. Personal protective equipment for near-infrared, visible and ultraviolet range radiation can include appropriate sun block creams, with or without appropriate screening clothing.


15. Personal Protective Equipment (PPE)

Providing Personal Protective Equipment (PPE) for workers additional protection

15.1. Worker, co-workers, and occasional visitors should be provided with appropriate PPE that offers adequate protection.


15.2. Proper maintenance of PPE should include cleaning when dirty and replacement when damaged or worn out. Proper use of PPE should be part of the recurrent training programs for employees.


15.3. Selection of PPE should be based on the hazard and risk ranking and selected according to criteria on performance and testing established.


16. Special Hazard Environments

Confined Space

16.1. Engineering measures should be implemented to eliminate, to the degree feasible, the existence and adverse character of confined spaces.


16.2. Permit-required confined spaces should be provided with permanent safety measures for venting, monitoring, and rescue operations, to the extent possible. The area adjoining an access to a confined space should provide ample room for emergency and rescue operations. 16.3. Access hatches should accommodate 90% of the worker population with adjustments for tools and protective clothing.


16.4. Prior to entry into a permit-required confined space: Process or feed lines into the space should be disconnected or drained, and blanked and

locked-out; Mechanical equipment in the space should be disconnected, de-energised, locked-out, and

braced, as appropriate; The atmosphere within the confined space should be tested to assure the oxygen content

is between 19.5 percent and 23 percent, and that the presence of any flammable gas or vapour does not exceed 25 percent of its respective Lower Explosive Limit (LEL);

If the atmospheric conditions are not met, the confined space should be ventilated until the target safe atmosphere is achieved, or entry is only to be undertaken with appropriate and

additional PPE.


16.5. Safety precautions should include Self Contained Breathing Apparatus (SCBA), life lines, and safety watch workers stationed outside the confined space, with rescue and first aid equipment readily available.


16.6. Before workers are required to enter a permit-required confined space, adequate and appropriate training in confined space hazard control, atmospheric testing, use of the necessary PPE, as well as the serviceability and integrity of the PPE should be verified. Further, adequate and appropriate rescue and / or recovery plans and equipment should be in place before the worker enters the confined space.


Lone and Isolated Workers

16.7. Where workers may be required to perform work under lone or isolated circumstances, Standard Operating Procedures (SOPs) should be developed and implemented to ensure all PPE and safety measures are in place before the worker starts work. SOPs should establish, at a minimum, verbal contact with the worker at least once every hour, and ensure the worker has a capability for summoning emergency aid.


16.8. If the worker is potentially exposed to highly toxic or corrosive chemicals, emergency eye-wash and shower facilities should be equipped with audible and visible alarms to summon aid whenever the eye- wash or shower is activated by the worker and without intervention by the worker.


17. Monitoring

Occupational health and safety monitoring program

17.1. The occupational health and safety monitoring program should be developed. It should include the following: regular inspection and testing of all safety features and hazard control measures; surveillance of the working environment: Employers should document compliance using an

appropriate combination of portable and stationary sampling and monitoring instruments; surveillance of workers health;



training activities for employees and visitors should be adequately monitored and documented.

Accidents and Diseases monitoring

17.2. The employer should establish procedures and systems for reporting and recording: Occupational accidents and diseases; Dangerous occurrences and incidents. These systems should enable workers to report immediately to their immediate supervisor any situation they believe presents a serious danger to life or health. The systems and the employer should further enable and encourage workers to report to management all: Occupational injuries and near misses; Suspected cases of occupational disease; Dangerous occurrences and incidents.


17.3. All reported occupational accidents, occupational diseases, dangerous occurrences, and incidents together with near misses should be investigated with the assistance of a person knowledgeable/competent in occupational safety.


Community Health and Safety

18. Water Quality and Availability

18.1. Project activities involving wastewater discharges, water extraction, diversion or impoundment should prevent adverse impacts to the quality and availability of groundwater and surface water resources.


18.2. Drinking water sources, whether public or private, should at all times be protected so that they meet or exceed applicable national acceptability standards or in their absence the current edition of WHO Guidelines for Drinking-Water Quality.


18.3. The potential effect of groundwater or surface water abstraction for project activities should be properly assessed through a combination of field testing and modeling techniques, accounting for seasonal variability and projected changes in demand in the project area.


18.4. Project activities should not compromise the availability of water for personal hygiene needs and should take account of potential future increases in demand.


19. Structural Safety of Project Infrastructure

19.1. The following issues should be considered and incorporated as appropriate into the planning, siting, and design phases of a project: Inclusion of buffer strips or other methods of physical separation around project sites to

protect the public from major hazards associated with hazardous materials incidents or

process failure, as well as nuisance issues related to noise, odours, or other emissions; Incorporation of siting and safety engineering criteria to prevent failures due to natural

risks posed by earthquakes, tsunamis, wind, flooding, landslides and fire. To this end, all project structures should be designed in accordance with engineering and design criteria mandated by site-specific risks, including but not limited to seismic activity, slope stability, wind loading, and other dynamic loads.


20. Life and Fire Safety

20.1. All new buildings should be designed, constructed, and operated in full compliance with local building codes, local fire department regulations, local legal/insurance requirements.


21. Traffic Safety

21.1. Traffic safety should be promoted by all project personnel during displacement to and from the workplace, and during operation of project equipment on private or public roads.


21.2. Road safety initiatives proportional to the scope and nature of project activities should include: Adoption of best transport safety practices across all aspects of project operations with the

goal of preventing traffic accidents and minimising injuries suffered by project personnel

and the public; Regular maintenance of vehicles and use of manufacturer approved parts to minimise

potentially serious accidents caused by equipment malfunction or premature failure. Where the project may contribute to a significant increase in traffic along existing roads, or where road transport is a significant component of a project, recommended measures include: Minimising pedestrian interaction with construction vehicles; Collaboration with local communities and responsible authorities to improve signage,

visibility and overall safety of roads; Coordination with emergency responders to ensure that appropriate first aid is provided in



the event of accidents; Using locally sourced materials, whenever possible, to minimise transport distances; Employing safe traffic control measures.

22. Transport of Hazardous Materials

22.1. The procedures for transportation of hazardous materials (Hazmats) should include: Proper labelling of containers, including the identify and quantity of the contents, hazards,

and shipper contact information; Ensuring that the volume, nature, integrity and protection of packaging and containers

used for transport are appropriate for the type and quantity of hazardous material and modes of transport involved;

Ensuring adequate transport vehicle specifications; Training employees involved in the transportation of hazardous materials regarding proper

shipping procedures and emergency procedures; Providing the necessary means for emergency response on call 24 hours/day.


22.2. Guidance related to major transportation hazards should be implemented in addition to measures presented in the preceding section for preventing or minimising the consequences of catastrophic releases of hazardous materials, which may result in toxic, fire, explosion, or

other hazards during transportation. Projects which transport hazardous materials at or above the threshold quantities should prepare a Hazardous Materials Transportation Plan.


22.3. Procedures and practices for the handling of hazardous materials and Emergency Preparedness and Response Plan should be developed for quick and efficient responses to accidents that may result in injury or environmental damage.


23. Disease Prevention

Communicable Diseases

23.1. Recommended interventions at the project level include: Providing surveillance and active screening and treatment of workers; Undertaking health awareness and education initiatives, for example, by implementing an

information strategy to reinforce person-to-person counselling addressing systemic factors that can influence individual behaviour as well as promoting individual protection, and protecting others from infection, by encouraging condom use;

Training health workers in disease treatment; Conducting immunisation programs for workers in local communities to improve health and

guard against infection;

Providing treatment through standard case management in on-site or community health care facilities;

Promoting collaboration with local authorities to enhance access of workers families and the community to public health services and promote immunisation.


Vector-Borne Diseases

23.2. Client in close collaboration with community health authorities, can implement an integrated control strategy for mosquito and other arthropod-borne diseases that might involve: Prevention of larval and adult propagation through sanitary improvements and elimination

of breeding habitats close to human settlements; Elimination of unusable impounded water; Increase in water velocity in natural and artificial channels; Considering the application of residual insecticide to dormitory walls; Promoting use of repellents, clothing, netting, and other barriers to prevent insect bites,

and other measures.


24. Emergency Preparedness and Response

Communication Systems

24.1. Alarm bells, visual alarms, or other forms of communication should be used to reliably alert workers to an emergency.


24.2. Testing warning systems at least annually (fire alarms monthly), and more frequently if required by local regulations, equipment, or other considerations.


24.3. Installing a back-up system for communications on-site with off-site resources, in the event that normal communication methods may be inoperable during an emergency.


24.4. If a local community may be at risk from a potential emergency arising at the facility, the company should implement communication measures to alert the community.



24.5. Emergency information should be communicated to the media through: • A trained, local spokesperson able to interact with relevant stakeholders, and offer

guidance to the company for speaking to the media, government, and other agencies; •

Written press releases with accurate information, appropriate level of detail for the emergency, and for which accuracy can be guaranteed.


Emergency Resources

24.6. A mechanism should be provided for funding emergency activities. Demonstrates Compliance

24.7. The company should consider the level of local fire fighting capacity and whether equipment is available for use at the facility in the event of a major emergency or natural disaster. If insufficient capacity is available, firefighting capacity should be acquired that may include pumps, water supplies, trucks, and training for personnel.


24.8. The company should provide first aid attendants for the facility as well as medical

equipment suitable for the personnel, type of operation, and the degree of treatment likely to be required prior to transportation to hospital.

Demonstrates

Compliance

24.9. Appropriate measures for managing the availability of resources in case of an emergency should include: Maintaining a list of external equipment, personnel, facilities, funding, expert knowledge,

and materials that may be required to respond to emergencies; Providing personnel who can readily call up resources, as required; Tracking and managing the costs associated with emergency resources; Considering the quantity, response time, capability, limitations, and cost of these

resources, for both site-specific emergencies, and community or regional emergencies; Considering if external resources are unable to provide sufficient capacity during a regional

emergency and whether additional resources may need to be maintained on-site.


24.10. Where appropriate, mutual aid agreements should be maintained with other organisations to allow for sharing of personnel and specialised equipment.


24.11. The company should develop a list of contact information for all internal and external resources and personnel. The list should be maintained annually.


25. Training and Updating

25.1. Training programs and practice exercises should be provided for testing systems to ensure an adequate level of emergency preparedness.


25.2. Training should be conducted annually and perhaps more frequently, when the response includes specialised equipment, procedures, or hazards, or when otherwise mandated.


25.3. Provide training exercises to allow personnel the opportunity to test emergency preparedness.


26. Business Continuity and Contingency

26.1. Measures to address business continuity and contingency should include the following: Identifying replacement supplies or facilities to allow business continuity following an

emergency; Using redundant or duplicate supply systems as part of facility operations to increase the

likelihood of business continuity; Maintaining back-ups of critical information in a secure location to expedite the return to

normal operations following an emergency.


Trans Anatolian Natural Gas Pipeline Project Rev 4 Environmental and Social Action Plan June 2017 Page 1


No.1 Action Environmental & Social Risks (Liability/Benefits)

Requirement (Legislative, EBRD PR, Best Practice)

Resources, Investment Needs, Responsibility

Timetable / Frequency of Monitoring for Action

Target and Evaluation Criteria for Successful Implementation

Status

0.0

Facilitate and coordinate the International Environmental and Social Consultant, as agreed between EBRD and TANAP, to conduct monitoring of the project on 6 monthly intervals prior to operation of Phase 0. The audits will review the project against project commitments made in the ESIA and various Management Plans and against this ESAP. Reports will be reviewed by the company and released into the public domain.

Monitoring of project performance. EBRD PR1-10 Resources: External Investment: Responsibility:

6 monthly prior to Phase 0 operations

Actions completed / status updated

0.1

Operations phase monitoring will be implemented based on a ToR acceptable to EBRD using a consultant agreed by EBRD. The final scope of work for the monitoring will be provided to EBRD for approval on a no objection basis.

Monitoring of project performance. EBRD PR1-10 Resources: External Investment: Responsibility:

To be in place prior to beginning of operations phase

Actions completed / status updated

PR1 Assessment and Management of Environmental and Social Impacts and Issues

1.1 Disclose Offshore ESMS documentation including the Emergency Management Plan

Offshore ESMPs and Emergency Management Plan have been developed in draft form and being finalised but not yet disclosed.

EBRD PR1 (1.4) EIA EU Directive 2011/92/EU

Resources: In-house Investment: Responsibility:

Disclose prior to commencing offshore construction

ESMS documentation complete & disclosed.

1.2 Provide a cost estimate for operatonal phase Biorestoration monitoring and maintenance sufficient for the length of the pipeline corridor and ensure sufficient contingency budget allocations for any newly identified biodiversity remedial and offset activities.

Financial provisions for implementation of BAP & Biorestoration monitoring and maintenancerequirements may not be sufficient to adequately characterise biorestoration effectiveness.

EBRD PR1 (1.7) Resources: In-house Investment: Responsibility:

Prior to operations phase Rationale behind costs provided and deemed sufficient

PR2 Labour and Working Conditions

2.1 Develop strengthened documentation and key actions for agreement with TANAP and EBRD on overtime, to be incorporated into the ESMS, as follows:

(a) Develop and conduct a program of engagement with CC workers through appropriate mechanisms (e.g. HR Managers) to clarify overtime policy at the site level and strengthen worker understanding of policy;

(b) Continue to implement procedures, plans and employment contrcats consistent with working hour policies. TANAP to share labour audit reports from external provider (Practical Solutions) with EBRD.

Overtime work and fatigue management were raised on several separate occasions in the grievance mechanism. There is confusion at a site level as to the TANAP policy on overtime. TANAP is working to address overtime issues through a “Working Hours Action Plan”, but it is noted that emphasis is directed to legal compliance around overtime, and it is not clear what fatigue management measures are in place and how these measures are linked with effective overtime management. Further, contractors are financially incentivised for being on time/advance of deadlines, which may contribute to the issue of overtime and fatigue. IESC recognises that the reduction of LTIs is a focus area for TANAP.

EBRD PR2 (2.1) ILO Core Labour Standards

Resources: In-house / Contractors Investment: Responsibility:

(a) Engagement program shared with EBRD by Sept 2017. Ongoing engagement as per program. (b) Labour Audit Reports completed by external provider (Practical Solutions) during construction activities to be shared with EBRD.

Program rolled out to all workers.

Fewer grievances are lodged about overtime/fatigue.

All documents are consistent.

Fewer non-conformances by contractors

2.2 Fatigue Management: (a) Develop a Fatigue Management Plan for TANAP and

implement this across the project; (b) Agree the Plan and its timeframe for implementation with

the EBRD; (c) Implement the Plan as agreed.

EBRD PR2 Resources: In-house / Consultant Investment: Responsibility:

Fatigue Management Plan to be developed by TANAP prior to EBRD Board meeting

Plan developed and agreed Plan implemented as agreed

2.3 Termination and retrenchment provisions: (a) Share with EBRD the Retrenchment Plans of each of the

CCs; (b) Share the first two quarterly monitoring reports of the

Retrenchment Plans, undertaken by TANAP of the CCs.

Interviews with short term labour suggests that not all CCs are making clear what the working conditions (including retrenchment/termination) are. TANAP requires provision of a document of resignation or notice of termination, in practice notice periods for dismissal may be occurring inconsistently, particularly in

relation to casual / short-term work. It is noted that the CCs are required to prepare Retrenchment Plans.

EBRD PR2 (2.5) ILO Core Labour Standards


September 2017 for Retrenchment Plans Quarterly Monitoring Reports as these are available, by latest

December 2017

Engagement conducted and documented. Form amended.

PR3 Resource Efficiency and Pollution Prevention and Control

3.1 Provide annual reporting of GHG emissions to the EBRD in line with their accepted methodology.

The EBRD requires that operations that produce more than 25,000 tonnes CO2-equivalent annually, (which TANAP does), quantify and report these emissions to the EBRD annually, in accordance with the

EBRD PR3 (3.4) Resources: In-house / Consultant Investment:

1st Quarter 2018 & annually thereafter

Annual reporting conducted

1 These numbers refer to the action item, and are not a reference to the relevant section of the Performance Requirements. Reference to Performance Requirements are provided in the column titled Requirement (Legislative, EBRD, PR, Best Practice).







Status

EBRD Methodology for Assessment of Greenhouse Gas Emissions. Responsibility:

PR4 Health and Safety

4.1 Develop a program on the prevention and management of communicable diseases in Project-affected communities:

(a) Develop the program Terms of Reference for EBRD approval;

(b) Implement the program as agreed, including regular monitoring and reporting;

(c) Share with EBRD for the Banks’ comment the plans for worker training on communicable diseases.

CCs’ Community Safety MPs make commitments to provide periodic communicable disease training to workers and training on worker interactions with community members. The Community Safety MP requires that the CCs will prepare studies on incidence of communicable diseases in affected Provinces, based on epidemiological information available, to ensure that all precautions are taken to prevent the transmission of such diseases due to the presence of workers. Engagement is required by CCs with local health authorities to agree appropriate mitigation strategies as required. This is reflected in CCs’ MPs, although it is not clear if such engagement / studies have been undertaken by all CCs. It is noted that TANAP has plans in place for worker training. Communicable disease management is provided for occupational

response, in the Medical Emergency Response Plan, however this Plan does not extend to community health response to Project-induced communicable disease.

EBRD PR4 (4.8) Resources: Contractors / Consultant Investment: Responsibility:

August 2017 (ToRs and the worker training plans) September 2017 (commencement of Program implementation)

Epidemiological studies conducted and findings incorporated in management approach / community health programs

PR5 Land Acquisition, Involuntary Resettlement and Economic Displacement

5.1 RAP Fund Management: (a) Provide EBRD with a copy of the final RAP Fund

Management Procedure and associated documents (including brochure for information dissemination);

(b) Provide for EBRD the stakeholder engagement plan, Annex 2 on RAP implementation, including specific provisions for engagement with vulnerable households.

The Cut-off date from the original RAP could not be met, and BOTAS has developed a practicable approach to evaluating and compensating every additional claim and justified complaint even after the cut-off date. TANAP should ensure that this commitment is met through the retrospective study to compensate all eligible PAPs (i.e. all members of households’ dependent on land income in addition to identified title holder, descendants of deceased land title holders with no formal paper, people with no formal title to land; customary users of land, disputed ownership, etc., as per the revised Entitlements Matrix) and subsequent monitoring and auditing processes.

EBRD PR5 (5.2) Resources: In-house / Consultant Investment: Responsibility:

August 2017 (implementation of engagement on the RAP Fund procedure)

Process determined and implementation commenced

5.2 Livelihood Restoration Program (LRP):

(a) Provide for EBRD comment the LRP for AGI-affected settlement prior to the Plan’s disclosure;

(b) Proivde a copy of the completed Offshore Fisheries LRP to EBRD.

TANAP is commissioning a retrospective study (due for completion in

July 2017) to identify and compensate PAPs who have not been yet been compensated under the new Entitlements Matrix framework. Further, TANAP has committed to providing for full replacement cost for all assets and will ensure that lost income is fully restored through the compensation process.

EBRD PR5

(5.5/5.6)

Resources:

Investment: Responsibility:

Prior to EBRD Board

meeting

Livelihood Restoration

Program developed in line with PR 5. EBRD to agree on contents of Program.

5.3 RAP Monitoring: (a) Provide to EBRD a copy of the Quarterly Internal

Monitoing Report (which includes monitoring of the RAP Fund, and implementation of the Corrective Actions Register);

(b) Provide to EBRD the results of external regular monitoring of the RAP, including payments from the RAP Fund.

Livelihood Restoration Plan (LRP), RAP Fund Guidance and documentation. Some payments are reported to have already been made from the RAP Fund, and for transparency these should be reconciled following approval of guidance on implementation of the Fund. The new RAP documents should be developed according to the identified timeline and publicly disclosed in a mode appropriate to the intended audience. The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators, implementation schedule, and budget. These RAPs would be subject to IESC/independent monitoring and review throughout implementation in accordance with GIP. Both internal and external monitoring have commenced, with

the 1st Quarterly Internal Monitoring Report (March 31, 2017) reviewed by the IESC in May 2017. TANAP has contracted independent experts for RAP External Monitoring and will produce their 1st Semi-Annual External Monitoring Report in June 2017.A site visit and investigation by the RAP External Monitoring Team was completed as of May 5, 2017. This monitoring, in turn will, inform the Impact Evaluation at the conclusion of the LA and livelihood restoration program.

EBRD PR5 (5.5) Resources: Consultant Investment: Responsibility:

Prior to EBRD Board meeting and quarterly for internal RAP monitoring and semi-annually for external RAP monitoring throughout construction period.

RAP External Monitoring Team Audit completed and first Semi-annual external monitoring Report. Results submitted to EBRD / IESC for review. Actions agreed and Corrective Actions tracked and monitored.

PR6 Biodiversity and Living Natural Resources







Status

6.1 Develop and implement a Biodiversity Offset Strategy document that:

(a) Quantifies residual impacts to Priority Biodiversity Features and Critical Habitats, as defined in the BAP [Rev P3 – 10]

(b) Identifies specific biodiversity; management actions, in accordance with the mitigation hierarchy, to achieve No Net Loss / Net Gain outcomes of these species and habitats of conservation importance;

(c) Quantifies No Net Loss / Net Gains based on the successful implementation of the above actions over a reasonable timeframe.

The BAP [Rev P3 - 10] does not quantify how the project’s biodiversity management actions will result in No Net Loss of Priority Biodiversty Features and/or Net Gain of Critical Habitats, as per EBRD’s Performance Requirement 6

EBRD PR6

Resources: Third Party / Internal Investment: Responsibility:

Submission of the draft Biodiversity Offset Strategy Q3 2017 Final report to be disclosed by TANAP prior to EBRD Board Meeting

Submission of the draft Biodiversity Offset Strategy Final report disclosed by TANAP prior to EBRD Board Meeting

PR7 Indigenous People

7.1 Not applicable

PR8 Cultural Heritage

PR10 Information Disclosure and Stakeholder Engagement

10.1 Disclosure and actions to address common grievances: (a) Conduct disclosure to communities of summary grievance

data and measures taken by TANAP and CCs to address the common causes of grievances;

(b) Include a specific section regarding resettlement related grievances to be disclosed in summary form to relevant resettlement-affected stakeholders, with measures taken by TANAP to address the common causes of these grievances.

The main grievances received since project commencement relate to damage to property and land, and the land acquisition process. A quarter of all complaints registered related to damage to land. The grievance process provides for legal redress, and Appeals Committees are additionally established to provide third party review of grievances between TANAP and complainants. This Committee intends to provide an additional level of independent review of any unresolved complaints or grievances.

EBRD PR10 (10.2)


September 2017 & thereafter annually

Disclosure completed. Records available demonstrating disclosure conducted.

10.2 Provide evidence to EBRD of the modality of public disclosure of existing key project ESMPs, including the BAP and RAP documents.

ESIA documents were disclosed on the TANAP website, with key documents in English and Turkish. Supplementary reports prepared included the RAP for Above-Ground Installations (AGIs) and the RAP for the Pipeline, prepared and disclosed due to material changes in the Project. However, while the IESC recognizes that disclosure has been achieved online, the modality of disclosure to communities in a form and format readily understood by stakeholders is ongoing with the development of additional resettlement-related documents (i.e. including the RAP Fund procedure and associated brochure). The latest version of the BAP has yet to be disclosued and should be undertaken in line with GIIP.

EBRD PR10 (10.3)


Prior to EBRD Board meeting

Information provided and issue resolved. Information provided and issue not resolved, additional actions agreed