TABLE OF CONTENTS

LIST OF ANNEXES ............................................................................................................................ iv

LIST OF TABLES ................................................................................................................................v
LIST OF FIGURES ............................................................................................................................ vii
ABBREVIATIONS .............................................................................................................................. ix
EXECUTIVE SUMMARY .................................................................................................................... 1
I. INTRODUCTION......................................................................................................................... 9
I.1 Description of the Project ..................................................................................................... 9
I.2 Scope of the Environmental and Social Impact Assessment Studies ................................. 9
I.3 Structure of the ESIA Report ............................................................................................. 10
II. PROJECT DESCRIPTION ........................................................................................................ 12
II.1 Project Location ................................................................................................................. 12
II.2 Land Ownership Status ..................................................................................................... 16
II.3 Population Projections ....................................................................................................... 21
II.3.1 Population Projection Methods ................................................................................... 21
II.3.2 Comparison of Population Projections ....................................................................... 23
II.4 Wastewater Projections for the Project .............................................................................. 24
II.4.1 Wastewater Flowrate Projections ............................................................................... 24
II.4.2 Wastewater Characterization ..................................................................................... 26
II.4.3 Effluent Characterization ............................................................................................ 27
II.4.4 Sludge Generation Rate Estimation ........................................................................... 28
II.5 Milas-Oren Sewerage Network .......................................................................................... 28
II.6 Milas-Oren Wastewater Treatment Plant Components ..................................................... 31
II.6.1 Preliminary Treatment ................................................................................................ 36
II.6.2 Advanced Biological Treatment .................................................................................. 36
II.6.3 Sludge Treatment Units .............................................................................................. 37
II.6.4 Disinfection Unit .......................................................................................................... 38
II.7 Auxiliary Facilities .............................................................................................................. 38
II.8 Personnel Requirements ................................................................................................... 40
II.9 Project Cost ....................................................................................................................... 40
II.10 Project Schedule ............................................................................................................ 40
III. LEGAL FRAMEWORK .............................................................................................................. 41
III.1 Turkish Legislation ............................................................................................................. 41
III.1.1 Turkish Environmental, Health and Safety Legislations ............................................. 41
III.1.2 Turkish Legislation on the Conservation of Nature and Wildlife ................................. 46
III.1.3 Labour Law ................................................................................................................. 46
III.1.4 Law on the Right to Information .................................................................................. 46
III.1.5 Permits ........................................................................................................................ 47
III.2 International Agreements and Standards .......................................................................... 47

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 III.2.1 International Environmental Conventions that Turkey is a Contracting Party ............ 47
III.2.2 World Bank Policies and Standards ........................................................................... 48
III.3 Gaps between National Legal Framework and World Bank Policies (OP 4.01 and OP
4.04) 52
III.3.1 Environmental Protection and Conservation .............................................................. 52
III.3.2 EIA Process and Requirements ................................................................................. 52
III.3.3 PPF Process and Requirements ................................................................................ 54
III.3.4 Differences between Project-related National Legislation and WBG Guidelines’ Limit
Values 54
IV. BASELINE CONDITIONS ......................................................................................................... 56
IV.1 Physical Environment ........................................................................................................ 56
IV.1.1 Land Use and Property ............................................................................................... 56
IV.1.2 Topography, Soils and Geology ................................................................................. 57
IV.1.3 Natural Hazards and Seismicity ................................................................................. 69
IV.1.4 Hydrogeology.............................................................................................................. 72
IV.1.5 Water Resources ........................................................................................................ 74
IV.1.6 Characteristics of Receiving Environment .................................................................. 78
IV.1.7 Protected Areas .......................................................................................................... 82
IV.1.8 Meteorology and Climatic Characteristics .................................................................. 89
IV.1.9 Noise Level ................................................................................................................. 96
IV.1.10 Air Quality ................................................................................................................ 99
IV.2 Ecology and Biodiversity .................................................................................................... 99
IV.3 Characteristics of Socio-Economic Environment ............................................................. 120
IV.3.1 Economical Characteristics ...................................................................................... 120
IV.3.2 Population ................................................................................................................. 128
V. ENVIRONMENTAL AND SOCIAL IMPACTS OF THE PROJECT AND MITIGATION
MEASURES ................................................................................................................................... 132
V.1 Scope-in/Scope-out Process ........................................................................................... 132
V.2 Impact Assessment Approach and Methodology ............................................................ 135
V.3 Potential Area of Influence ............................................................................................... 136
V.4 Environmental Impacts (Physical and Biological Environment) ....................................... 141
V.4.1 Air Quality ................................................................................................................. 148
V.4.2 Geology, Soils and Contaminated Land ................................................................... 156
V.4.3 Surface Water Resources ........................................................................................ 159
V.4.4 Groundwater Resources ........................................................................................... 162
V.4.5 Noise and Vibration .................................................................................................. 162
V.4.6 Biological Environment ............................................................................................. 167
V.4.7 Landscape and Visual (Aesthetics) .......................................................................... 172
V.4.8 Resources and Wastes ............................................................................................ 172
V.4.9 Climate Change ........................................................................................................ 179
V.5 Impacts on Socioeconomic Environment......................................................................... 180
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 V.6 Labour and Working Conditions ...................................................................................... 182
V.6.1 Working Conditions and Management of Worker Relationship ................................ 183
V.6.2 Protecting the Work Force ........................................................................................ 184
V.6.3 Occupational Health and Safety .............................................................................. 184
V.6.4 Workers Engaged by Third Parties and the Supply Chain ....................................... 187
V.6.5 Labour Influx ............................................................................................................. 188
V.6.6 Local Procurement.................................................................................................... 188
V.7 Community Health and Safety ......................................................................................... 188
V.8 Archaeological and Cultural Heritage .............................................................................. 190
VI. PROJECT ALTERNATIVES ................................................................................................... 192
VI.1 “No-Project” Alternative .................................................................................................... 192
VI.2 Site Alternatives for the WWTP ....................................................................................... 192
VI.3 Pumping Station Alternatives ........................................................................................... 193
VI.4 Technology Alternatives for the WWTP ........................................................................... 194
VI.4.1 Process Alternatives ................................................................................................. 194
VI.4.2 Sludge Management Methods .................................................................................. 199
VI.4.3 Disposal Methods ..................................................................................................... 204
VI.5 Comparison of Alternatives .............................................................................................. 207
VI.5.1 Comparison of Technology Alternatives ................................................................... 207
VI.5.2 Comparison of Sludge Management Methods ......................................................... 209
VII. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) ....................................... 212
VII.1 Mitigation Management Plan ........................................................................................ 213
VII.2 Monitoring Plan ............................................................................................................ 227
VII.3 Institutional Arrangements ........................................................................................... 237
VII.3.1 Environmental and Social Management Structure ................................................... 237
VII.3.2 Roles and Responsibilities ....................................................................................... 238
VII.3.3 Training ..................................................................................................................... 241
VII.4 Environmental and Social Monitoring Report ............................................................... 242
VIII. STAKEHOLDER ENGAGEMENT ........................................................................................... 243
VIII.1 Public Participation Meeting-I ....................................................................................... 243
VIII.2 Public Participation Meeting-II ...................................................................................... 248
VIII.3 Grievance Mechanism.................................................................................................. 253
IX. REFERENCES ........................................................................................................................ 257

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LIST OF ANNEXES
Annex 1 Contributors
Annex 2 Laboratory Reports
Annex 3 Brochure Distributed in PPM-1
Annex 4 PPM-1 Attendance List
Annex 5 Brochure Distributed in PPM-2
Annex 6 PPM-2 Presentation
Annex 7 PPM-2 Attendance List
Annex 8 Official Letters Regarding Property Statuses
Annex 9 EIA Exemption Decision

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LIST OF TABLES
Table II.1 Oren Neighbourhood Winter Population Projection ......................................................... 23
Table II.2 Oren Neighbourhood Summer Population Projection ...................................................... 24
Table II.3 Population-Dependent Water Consumption per Capita ................................................... 24
Table II.4 Wastewater Generation Rates in the Next Years According to Population Projection of
Oren District...................................................................................................................................... 25
Table II.5 The Total Amount of Wastewater Generated in Oren Neighbourhood ............................ 25
Table II.6 Wastewater Flows of the Settlements in the Scope of the Project (2054) ....................... 26
Table II.7 Milas – Oren WWTP Design Flowrates ............................................................................ 26
Table II.8 Milas - Oren WWTP Wastewater Characterization and Pollution Load ........................... 27
Table II.9 Milas – Oren WWTP Discharge Standards ...................................................................... 27
Table II.10 Sludge Generation Amounts .......................................................................................... 28
Table II.11 Technical Characteristics of the Sewerage System ....................................................... 29
Table II.12 Project Schedule ............................................................................................................ 40
Table III.1 Turkish EHS Legislation Related to the Project* ............................................................. 42
Table III.2 Project related Turkish Legislation on the Conservation of Nature and Wildlife ............. 46
Table III.3 Urban Wastewater Treatment Regulation Discharge Limits ........................................... 54
Table IV.1 Agricultural Potentials Represented by Different Land Use Capability Classes and Their
Characteristics .................................................................................................................................. 58
Table IV.2 Soil Sampling Measurement and Analysis Results ........................................................ 65
Table IV.3 Groundwater Levels Determined in Boreholes (and trial pits) ........................................ 72
Table IV.4 Rivers of Mugla ............................................................................................................... 74
Table IV.5 Lakes in Mugla ................................................................................................................ 74
Table IV.6 Dams of Mugla ................................................................................................................ 75
Table IV.7 Physicochemical and microbiological characteristics of Hanay Creek (December 2021)
.......................................................................................................................................................... 81
Table IV.8 Inventory of Immovable Cultural Assets in Milas District ................................................ 84
Table IV.9 Temperature Values ....................................................................................................... 90
Table IV.10 Average Monthly Precipitation and Maximum Precipitation Amounts .......................... 91
Table IV.11 Average and Minimum Relative Humidity Values ......................................................... 92
Table IV.12 Monthly Average, Maximum and Minimum Pressure Values ....................................... 93
Table IV.13 Monthly Average Foggy, Snowy, Snow Covered, Hail, Frosty and Stormy Days
Distribution........................................................................................................................................ 93
Table IV.14 Monthly Average Wind Speeds .................................................................................... 95
Table IV.15 Maximum Wind Speeds and Directions, Average Numbers of Stormy and Windy Days
(1960-2015) ...................................................................................................................................... 95
Table IV.16. Environmental Noise Limits for Industrial Plants ......................................................... 96
Table IV.17. Environmental Noise Limits for Construction ............................................................... 96
Table IV.18. Noise Level Guidelines of WBG .................................................................................. 97
Table IV.19. Background Noise Level Measurement Results .......................................................... 97
Table IV.20 Air Quality of Mugla....................................................................................................... 99
Table IV.21 PM10 and PM2.5 measurement results (July 2020) ........................................................ 99
Table IV.22 Annexes to the Bern Convention ................................................................................ 102
Table IV.23 Appendices to CITES.................................................................................................. 103
Table IV.24 IUCN Red List Categories and Criteria ....................................................................... 103
Table IV.25 National Threat Statuses for Vertebrates ................................................................... 104
Table IV.26 National Threat Categories for Bird Species .............................................................. 104
Table IV.27 Possible Flora Species in and around the Project Area ............................................. 112
Table IV.28 Possible Reptile and Amphibian Species in and around the Project Area ................. 117
Table IV.29 Possible Bird Species in and around the Project Area ............................................... 118
Table IV.30 Possible Mammal Species in and around the Project Area ....................................... 119
Table IV.31 Indicators for Development Level of Mugla ................................................................ 121
Table IV.32 Number of Tourists Entering Mugla by Mode of Transportation between 2016 and 2018
........................................................................................................................................................ 121
Table IV.33 Tourism Facility Statistics Prepared by TurkStat for Mugla Chamber of Commerce and
Industry. .......................................................................................................................................... 121
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Table IV.34 Agricultural Lands of Milas (TurkStat, 2019) .............................................................. 124
Table IV.35 Top Ten Agricultural Products of Milas (TurkStat, 2019) ............................................ 124
Table IV.36 Survey Results ............................................................................................................ 125
Table IV.37: Age and Gender Distribution of Mugla Province (TurkStat, 2019) ............................ 128
Table IV.38 Population of Mugla Districts (TurkStat, 2019) ........................................................... 129
Table IV.39 Age and Gender Distribution of Milas Province (TurkStat, 2019) ............................... 130
Table IV.40 Population of Oren, Turkevleri and Bozalan (TurkStat, 2019) .................................... 131
Table V.1 Colour Code Used in the Scope-in/Scope-out Process ................................................. 133
Table V.2 Potential Interactions between Project Activities and Environmental Resources.......... 134
Table V.3 Potential Interactions between the Project Activities and Social/Socio-economic
Receptors ....................................................................................................................................... 135
Table V.4 Impact Significance Matrix*............................................................................................ 136
Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social
Attributes ........................................................................................................................................ 142
Table V.6 Indicative Construction Machinery and Equipment List ................................................. 148
Table V.7. Emission Factor to be used to Calculate Dust Emissions ............................................ 148
Table V.8. Excavation Amounts ..................................................................................................... 149
Table V.9 Ambient Air Quality Limit Values – Turkish Regulations ............................................... 152
Table V.10. Emission Factors (USEPA) ......................................................................................... 153
Table V.11. Expected Amounts of Exhaust Emissions (kg/h) ........................................................ 153
Table V.12 Recommended Distances to Settlements for Odor Prevention and Nearest Receptors
........................................................................................................................................................ 155
Table V.13. Water Requirement of the Project .............................................................................. 159
Table V.14 Domestic Wastewater Discharge and Treatment Efficiency Criteria ........................... 160
Table V.15. Machinery and Equipment and their Noise Intensity Levels (L w)................................ 163
Table V.16. Distribution of Noise Generated Relative to Distance ................................................ 164
Table V.17. Estimated Noise Level around the Nearest Residential Building ............................... 165
Table V.18 Severity of Impacts on Resource/Receptor ................................................................. 168
Table V.19. List of Possible Waste Types to be Generated during Land Preparation and
Construction Phase of the Project .................................................................................................. 174
Table V.20 List of Possible Waste Types to be Generated During Operation Phase .................... 178
Table VI.1 Heavy Metal Limit Values in the Soil ............................................................................ 204
Table VI.2 Maximum Heavy Metal Content Limit Values for Stabilized Sludge to be used in Soil 205
Table VI.3 Organic Compound Limit Values for Stabilized Sludge to be used in Soil ................... 205
Table VI.4 Waste Acceptance Limit Values for Class II Landfill Facilities ..................................... 206
Table VI.5 Comparison of Wastewater Treatment Alternatives ..................................................... 208
Table VI.6 Comparison of Sludge Treatment and Disposal Methods ............................................ 211
Table VII.1 Construction Phase Impact Mitigation Plan ................................................................. 214
Table VII.2 Operation Phase Impact Mitigation Plan ..................................................................... 222
Table VII.3 Land Preparation and Construction Phase Monitoring Plan........................................ 228
Table VII.4 Operation Phase Monitoring Plan ................................................................................ 234
Table VII.5 Proposed Training Programme .................................................................................... 241
Table VIII.1 Results of Questionnaire Made after the PPM-1 ........................................................ 247
Table VIII.2 Grievance Redress Mechanism .................................................................................. 256

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LIST OF FIGURES
Figure 0.1 Location of the Project and the Project Components ....................................................... 2
Figure II.1 Districts of Mugla ............................................................................................................. 13
Figure II.2. Site location map ............................................................................................................ 14
Figure II.3. Nearest Settlements and their Distances to the WWTP Site ......................................... 15
Figure II.4 Photos from the Project Site ........................................................................................... 16
Figure II.5 Photos from the Planned Pumping Stations ................................................................... 17
Figure II.6 Photographs Taken from the WWTP Site ....................................................................... 18
Figure II.7 General Layout of the Project ......................................................................................... 20
Figure II.7 Exemplary Manhole Structures with Dimensions ........................................................... 30
Figure II.9 Exemplary Image of a Pumping Station .......................................................................... 31
Figure II.10 Milas – Oren WWTP Area ............................................................................................. 32
Figure II.11 Layout of Milas – Oren WWTP ..................................................................................... 33
Figure II.12 The Flow Diagram ......................................................................................................... 35
Figure II.13 Map of Energy Transmission Line ................................................................................ 39
Figure IV.1. Great Soil Groups and Land Use Capability Classes for the Project Area .................. 60
Figure IV.2 Erosion Levels of the Project Area and Its Vicinity ........................................................ 62
Figure IV.3 Photos from the WWTP Site and Soil Sampling ........................................................... 63
Figure IV.4 Soil Sampling Locations ................................................................................................ 64
Figure IV.5. General Geology Map................................................................................................... 67
Figure IV.6 General Geology Map Legend ...................................................................................... 68
Figure IV.7. Seismicity Map of Turkey ............................................................................................. 70
Figure IV.8. Active Fault Map of Turkey ........................................................................................... 71
Figure IV.9 Borehole Locations ........................................................................................................ 73
Figure IV.10 Hydrology Map of the Project Area and Its Vicinity ..................................................... 76
Figure IV.11 Dams in the Vicinity of the Project Area ...................................................................... 77
Figure IV.12 Photos of Receiving Environment – Hanay Creek ...................................................... 78
Figure IV.13 Surface Water and Seawater Sampling Locations ...................................................... 80
Figure IV.14 Protected Areas around the Project Area .................................................................... 86
Figure IV.15 Archaeological Protected Areas Around the Project Area ........................................... 87
Figure IV.16 Prohibited and Open Hunting Areas in Mugla (2019-2020) ........................................ 88
Figure IV.17 Average Temperature, Maximum Temperature and Minimum Temperature .............. 89
Figure IV.18 Average Monthly Precipitation and Maximum Precipitation Amounts ......................... 90
Figure IV.19 Average and Minimum Relative Humidity Values ....................................................... 91
Figure IV.20 Monthly Average, Maximum and Minimum Pressure Values ...................................... 92
Figure IV.21 Annual Wind Diagram of Wind Blow Numbers and Average Wind Speeds ................ 94
Figure IV.22 Seasonal Wind Diagram of Wind Blow Numbers ........................................................ 94
Figure IV.23 Seasonal Wind Diagram of Average Wind Speeds (m/sec) ........................................ 95
Figure IV.24 Noise Measurement Locations .................................................................................... 98
Figure IV.25 Some Photographs of the Planned WWTP Area ...................................................... 101
Figure IV.26 The Protection Area and Number of Protected Species ........................................... 106
Figure IV.27 The Protection Area and Spawning-Brood Development Areas ............................... 107
Figure IV.28. International and National Designed or Recognized Areas with and around the
Project Area .................................................................................................................................... 108
Figure IV.29. Bioecological Location of the Project........................................................................ 110
Figure IV.30. Distribution of 9677 Endemic Taxa Locations in Turkey Flora According to
Region,Subregion and Grid System (Turk Cografya Journey 69 (2017) 109-120) ........................ 111
Figure IV.31 Hanay Creek .............................................................................................................. 120
Figure IV.32 Employment and Unemployment Rates According to Years, TR32 (TurkStat, 2019)
........................................................................................................................................................ 122
Figure IV.33Sectorial Employment in TR32 (TurkStat, 2019) ........................................................ 123
Figure IV.34 Agricultural Lands of Mugla (TurkStat, 2019) ............................................................ 123
Figure IV.35 Number of Cattles in Mugla’s Disctricts (TurkStat, 2019) .......................................... 124
Figure IV.36 Population Pyramid of Mugla Province (TurkStat, 2019) .......................................... 129
Figure IV.37 Population Pyramid of Milas (TurkStat, 2019) ........................................................... 131
Figure V.1. Layout of the Oren Wastewater Treatment Plant and Sewerage Network ................. 137
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Figure V.2. Area of Influence of the Project ................................................................................... 138
Figure V.3 Potential Social Area of Influence ................................................................................. 139
Figure V.4 Sensitive Receptors in the Project Area ....................................................................... 140
Figure V.5 Distribution of Noise Generated in the Project Area with respect to Distance ............. 165
Figure V.6. Waste Management Hierarchy .................................................................................... 173
Figure V.7. Composition of Municipal Waste (former Ministry of Science, Industry and Technology,
2014) .............................................................................................................................................. 175
Figure VI.1 Exemplary Image of a Pumping Station ...................................................................... 194
Figure VI.2. Flow Diagram of the MBR Process ............................................................................ 195
Figure VI.3 Flow Diagram of the A2O Process .............................................................................. 196
Figure VI.4 Flow diagram of the Step Feed System ...................................................................... 197
Figure VI.5 Flow Diagram of the 5-Staged Bardenpho Process .................................................... 197
Figure VI.6 Flow Diagram of the UCT Process .............................................................................. 198
Figure VI.7 Flow Diagram of the Integrated Fixed Film Activated Sludge (IFAS) Process ............ 198
Figure VII.1 Environmental and Social Management Structure ..................................................... 237
Figure VII.2 Organizational Structure of MUSKI ............................................................................ 240
Figure VIII.1 PPM-1 Website Announcement (June 26, 2020, www.MUSKI.gov.tr) ...................... 244
Figure VIII.2 PPM-1 National Newspaper Announcement (June 26, 2020, Birgun) ...................... 244
Figure VIII.3 PPM-1 Local Newspaper Announcement (June 29, 2020, Milas) ............................. 245
Figure VIII.4 Photos from the PPM-1 (July 7, 2020) ...................................................................... 246
Figure VIII.5 PPM-II National Newspaper Announcement (February 2 nd, 2022, Birgun) ............... 249
Figure VIII.6 PPM-II Local Newspaper Announcement (February 2nd, 2022, Milas) ..................... 250
Figure VIII.7 PPM-II Website Announcement (February 3rd, 2022, www.muski.gov.tr) ................. 251
Figure VIII.8 Photos from the PPM-II (February 11th, 2022) .......................................................... 252
Figure VIII.9 Sample Grievance Mechanism .................................................................................. 255

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ABBREVIATIONS

AoI Area of Influence

BOD Biochemical Oxygen Demand
CCD United Nations Convention to Combat Desertification
CIMER Communication Centre of Presidency of Turkey
CITES Convention on International Trade in Endangered Species
CLRTAP Convention on Long Range Transboundary Air Pollution
COD Chemical Oxygen Demand
DLP Defect Liability Period
DS Dry Solids
EA Environmental Assessment
EC European Commission
EHS Environmental, Health and Safety
EIA Environmental Impact Assessment
EMEP European Monitoring and Evaluation Programme
EMP Environmental Management Plan
EP Equivalent Population
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
EU European Union
EUR European Euro
GP Good Practices
GRP Glass Reinforced Plastic
IFC International Finance Corporation
ILBANK Iller Bankasi A.S.
ILO International Labor Organization
KBA Key Biodiversity Area
MLSS Mixed Liquor Suspended Solids
MoEUCC Ministry of Environment, Urbanization and Climate Change
Mugla Metropolitan Municipality General Directorate of Water &
MUSKI
Sewerage Administration
OP Operational Policies
PPF Project Presentation File
pH Power of Hydrogen
PM Particulate Matter
POPs Stockholm Convention on Persistent Organic Pollutants
PPM Public Participation Meeting
PS Performance Standard
RAMEN Regulation on the Assessment and Management of Environmental Noise
RAMSAR International Importance as Particularly Water Birds Living Environment
SEP Stakeholder Engagement Plan
TN Total Nitrogen

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ABBREVIATIONS

TP Total Phosphorus
TSS Total Suspended Solids
TurkStat Turkish Statistical Institute
UN United Nations
UNESCO United Nations Educational, Scientific and Cultural Organization
UNFCCC United Nations Framework Convention on Climate Change
WB World Bank
WBG World Bank Group
WWTP Wastewater Treatment Plant

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 EXECUTIVE SUMMARY
İller Bankası A.Ş. (ILBANK) and World Bank (WB) have developed the Sustainable Cities
Project (SCP) to establish a support mechanism for participating second level metropolitan
municipalities to plan and invest in a sustainable future. The investments to be made within the
scope of SCP will follow environmental legislation of Republic of Turkey as well as World Bank
safeguard policies and standards. Under SCP financed by WB, two sub-loan agreements were
signed between General Directorate of Water and Wastewater Utility of Mugla Metropolitan
Municipality (MUSKI) and ILBANK in the wastewater sector. The project with MUS2-W2 code,
which is subject to this study, is in the scope of SCP-II.

Currently there is no sanitary sewerage system in the Oren Neighborhood. Wastewater

generated in the households is collected in septic tanks which are withdrawn by vacuum trucks. As
of 2019, 103 l/s wastewater is generated from Oren Center, Turkevleri-Bozalan Neighborhoods
(including marina) and Kilic Fishery. In addition to that, according to unofficial correspondence with
MUSKI, in 2020, 1,971 wastewater withdrawals were made with eight-ton vacuum trucks, which
corresponds to 15,768 tons of wastewater per year. However, the vast majority of existing septic
tanks are not impermeable, therefore, significant part of the generated wastewater is also
discharged into environment without any treatment.

This report has been prepared by Encon Çevre Danışmanlık Ltd. Şti. (ENCON) in the
scope of the Environmental and Social Impact Assessment (ESIA) study conducted for the Milas-
Oren Sewerage System and Wastewater Treatment Plant (WWTP) Project (the Project). The
Project has two components; one is the construction of a 74.5 km sewerage network in Oren
neighbourhood of Milas District with four buried pumping stations, and the other one is the
construction of Oren WWTP on one parcel located in the borders of Oren neighbourhood and
1,542 meter discharge line.

The diameters of pipes to be used in Oren’s sewerage system vary between Ø200 mm and
Ø3000 mm. The pipes will be HDPE corrugated and Glass Reinforced Plastic (GRP). System’s
design is made according to 2054 population and flowrate. The 74.5 km sewerage network
construction consists of installation of 53 km sewerage network, 9.5 km household connection and
12 km force main. Within the sewerage network, four underground pumping stations will be
constructed. While two of the pumping pumping stations will be constructed as package pumping
stations, the others will be constructed as reinforced concrete pumping stations.

The other component of the Project is Oren WWTP, which has a daily design capacity of
4,000 m3/day for the 1st Stage (until 2028), and total of 8,000 m3/day (4,000 m3/day + 4,000
m3/day) for the 2nd Stage (after 2028). The WWTP will be able to treat organic pollutants together
with nitrogen and phosphorus. After the treatment, treated effluent will meet the national legislative
quality criteria and necessary WBG EHS Guideline criteria and will be discharged to Hanay Creek
through 1,542 meter discharge line to be constructed. Milas – Oren WWTP consists of the following
units:

 Coarse Screen
 Pump Station
 Fine Screen
 Aerated Grit Chamber
 Rectangular Weir and Distribution Chamber
 Anaerobic BioP Tanks
 Aeration Tanks
 Final Sedimentation Distribution Chamber
 Final Sedimentation Tanks
 Treated Water Pit
 Disinfection Tank
 Sludge Pumping Station

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  Sludge Thickener
 Sludge Dewatering Building
 Blower Building
 Administrative Building
 Transformer and Generator Building
 Security Cabin/Guardhouse

A map showing the location of the Project and the Project components is presented below
in
Figure 0.1.

Figure 0.1 Location of the Project and the Project Components

The project will be in compliance with the good international practice, including World Bank
Policies, guides, standards and best practices documents alongside the national legislation.
Specific standards related to the project are as follows:

 World Bank OP 4.01 – Environmental Assessment

 World Bank OP 4.04 – Natural Habitats
 World Bank OP 4.11 – Physical Cultural Resources
 World Bank Group General Health and Safety Guidelines
 World Bank Group General EHS Guidelines: Water and Sanitation

According to the EU Environmental Impact Assessment (EIA) Directive the Oren WWTP is
subject to Annex II, as the capacity of the WWTP is below 150.000 PE. Similarly, sewerage
network is also subject to Annex II considering it within the scope of “Urban Development Projects”.
For the projects that are subject to Annex II, the member states determine the need of an
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Environmental Impact Assessment through a case-by-case basis examination or thresholds/criteria
set by the Member State. According to the Turkish EIA Regulation, the Project is not subject to the
mentioned legislation as the capacity of the WWTP is below both 150.000 PE for Annex I and
50.000 PE for Annex II requirement therein. Within this regard, EIA exempt decision is given for the
WWTP. However, considering the location and environmental and social aspects of the Project, the
Project has been proposed as a “Category A” Project by considering the OP 4.01 requirements.
For “Category A” projects, a comprehensive full-scale ESIA is required to be conducted.

The Project is located at Oren neighbourhood of Milas district of Mugla. The Project design
was made according to the projected populations for 2054. In 2054, the population to be served
and wastewater generation rate will be 23,863 and 123 l/s, respectively.

In the scope of the baseline studies for the Project and to determine the existing
contamination status of soils located in the site, two samples were taken from the site. Although
both samples were taken from the WWTP site, the concentrations of some parameters significantly
differ from each other, such as chromium, nickel and TPH. Chromium levels in uncontaminated soil
vary in between 2 and 60 mg/kg and soils with chromium levels up to 100 mg/kg are considered as
appropriate for agricultural activities (Seven v.d., 2018). Therefore, the chromium concentration
observed in the sampling location-1 which is 205.2 mg/kg, and its comparison with the
concentration observed in the second sampling location which is 57.17 mg/kg, indicate a possible
contamination in the location-1. Nickel levels in soils vary widely depending on local geology and
anthropogenic inputs, but concentrations typically range between 4 and 80 ppm (Seven v.d., 2018),
however in the sampling location-1 nickel concentration is measured as 223.1 mg/kg. On the other
hand in USA, the most commonly used soil cleanup standard for TPH is 100 mg/kg (Michelsen,
1993), in the current situation TPH levels in sampling location-2 is measured as 117.5 mg/kg.
Therefore, the assessment made by evaluating chromium levels is also valid when considering
TPH and nickel levels in the WWTP site.

Although it is not decided yet, it is expected that around 100 workers at the peak period of
construction phase and 10 workers in the operation phase of the Project will be employed.
Regardless of the exact number of people to be employed, priority will be given to the local
community during recruitment process. The sewerage network and WWTP is planned to be
completed in 24 months and 18 months, respectively, following tendering processes.

Within the scope of the Project, the excess sludge which will be generated during the
operation of WWTP, will be analysed to determine compliance with the Annex-2 of the Regulation
on Landfilling of Wastes and if it is deemed appropriate, the sludge will be collected by the licensed
disposal companies determined by MUSKI every year. After that, the sludge will be disposed at
landfill in accordance with the provisions of Urban Wastewater Treatment Regulation and other
relevant legislation. According to the information retrieved from MUSKI, the sludge will be
transported by competent and licensed firms to the landfill which has enough capacity. At the end,
the sludge will be stored in the landfill. On the other hand, incineration and other options will be
considered under the sludge management plan to be prepared prior to operational phase. Within
this regard, according to information obtained from MUSKI, EIA Positive decision for incineration
plant is obtained. However, whether the plant will be constructed or not is depends on the supply of
funding for this issue. Currently, waste to energy system is not considered because the plant
capacity is low, so the amount of sludge to be generated will be limited.

The Project’s impacts on environmental and social issues are as follows:

 Project would have environmental and social impacts during construction and
operation phases. Potential impacts of the Project during the construction phase would
be generally short term with low to medium magnitude that would be locally significant.
These impacts can be initially summarized as follows:
o Permanent change of land type at the WWTP site.
o Air emissions and increased level of noise generated from the operation of the
construction machinery and equipment.

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 o Soil contamination as a result of possible inadequate management of waste
generated on site, and possible leakage of hazardous materials (oil and
lubricants from outdoor equipment).
o Loss of topsoil as a result of poor management.
o Wastes to be produced by workers.
o Removal of vegetation during land preparation.
o Dust formation, increased level of noise, increased vehicle traffic and presence
of workers can cause distress/disturbance to residents.
o Disruption in traffic and infrastructure services.
 During both phases, significant adverse environmental impacts are not expected on
soil and air. The most important impact related with air quality would be observed
during construction phase at the Mugla Sitki Kocman University Fisheries Research
and Development Centre, which is adjacent to the WWTP site. The increase in dust
concentration might create problems for pools of the centre. In addition, there is a
hospital around TM-6 pumping stations, and therefore, important impacts might be
observed around this location.
 Oren WWTP’s operation phase would possibly create odour nuisance in the close
vicinity of the plant. Several levels of measures are recommended in the Chapter 7 of
this report. It is recommended to MUSKI to plant trees to the WWTP borders to
minimize impacts related with odour, noise, and dust generation, and aesthetics.
 One of the highest risks that Project carries is related with the ground characteristics of
WWTP site. The WWTP site has liquefaction and ground stability risks and these risks
should be managed.
 There is a minor risk of oil and chemical spills during the construction phase. However,
in overall, the impacts can be reduced to negligible in significance through proper
implementation of mitigation measures.
 Since the Project will be realized in settlements, the biological properties of the project
area are determined to be negligible.
 The project will have positive impacts on both socio-economy and community health
and safety, in general. Since the Project will solve wastewater problems of the region.
However, there might be some risks to community during construction and operation
phases. In construction phase, noise and dust generation, increase of traffic and
community encroachment might be encountered. On the other hand, in operation
phase, odor generation, operation failure of WWTP and community encroachment
might be encountered. However, in overall, the impacts can be reduced to low in
significance through proper implementation of mitigation measures.

For the management of anticipated impacts, an Environmental and Social Management

Plan (ESMP) has been developed. The ESMP has been prepared to assess and identify the
potential environmental and social impacts and risks arising out of the development of the Project
and recommend mitigation measures for significant adverse environmental and social impacts and
describes the monitoring and institutional requirements necessary to implement the ESMP. The
primary purpose of the ESMP is to ensure that the environmental requirements and social
commitments associated with the Project are carried forward into implementation and operational
phases of the Project and are effectively managed. Summary of the mitigation measures
developed for the anticipated impacts is as follows:

 For the impacts on soil environment:

o The amount of soil that could be subject to compaction and
contamination/pollution will be minimized by ensuring the use of only the
designated work sites and routes for the construction machinery and
equipment and field personnel
o Wastes and wastewater to be generated during the construction phase of the
Project will be stored and disposed in a controlled manner in accordance with
the relevant regulations, WBG EHS Guidelines and in line with the
management practices described in this report. Thus, it will not be possible for
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 the wastes and wastewater to be generated in the Project Area interact with
the soil environment and cause any impacts.
o Stripping of topsoil will not be conducted earlier than required to prevent the
erosion of soil.
o Topography will be restored for stop stabilization immediately after the
completion of construction at each location
o The areas that the construction works take place will be reinstated after the
completion of works.
 For the impacts on air environment:
o Dust should be minimized from open area sources, including storage piles, by
using control measures such as installing enclosures and covers, and
increasing the moisture content
o Continuous water spraying will be conducted at the WWTP site to minimize
dust impacts on Mugla Sitki Kocman University Fisheries Research and
Development, which is adjacent to the site, and during the works to be
performed around TM-6.
o Trees will be planted to the borders of WWTP, especially at the east and south
borders.
o Loading and unloading operations will be performed without
throwing/scattering.
o Wind shields/barriers will be placed at work sites, especially at the south and
east borders of the WWTP site and around the TM-6 Pumping Station, to
prevent dust dispersion.
 For the odor impacts:
o First level measures:
 Prevention of wastewater influents, which exceed treatment plant
capacity.
 Decrease in solid waste and activated sludge amounts.
 Increase disposal frequency of screenings.
 Proper and timely disposal of sludge in order to prevent flies and
odor.
 Increasing aeration rate in biological treatment process.
 Addition of chlorinated water to sludge thickeners if activated
sludge unit is in open area.
 Addition of lime to activated sludge.
 Keeping water level under control in order to prevent turbulence as
a result of instant decrease of water.
o If odor nuisance prevails after the proper implementation of first level
measures, the second level measures shall be taken. These are
 Plantation of trees in the WWTP site boundaries and the buffer
zone around the treatment plant for the prevention of odor
distribution.
 Addition of oxidizing material (such as hydrogen peroxide, sodium
hypochloride) (oxidizing materials, prevent generation of especially
hydrogen sulphide). Addition of sodium hydroxide can also be
considered. Sodium hydroxide will dissolve hydrogen sulphur gas
in water.
 Preventing anaerobic bacteria with control of pH levels or
disinfection.
 Oxidizing odorous compounds by the help of chemicals.
o If nuisance still prevails after implementation of first and second measures, the
final measure shall be determined as:
 Enclosing of preliminary treatment units, aeration tanks and bio-P
tanks.

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  For noise impacts:
o Construction noise barriers will be used at north-eastern boundary of the
WWTP site and around the TM-6 Pumping Station and by doing so, around 5
to 10 dBA noise reduction would be achieved at the receptor.
o Trees will be planted to the WWTP site, especially its north-eastern boundary,
and around the pumping stations.
o It will be ensured that machinery and equipment will not be operated together
in the close section of the WWTP Area to nearest building
o The works will be performed day-time; no night work unless it is absolutely
necessary.
 For the impacts on water resources:
o The MUSKI will minimize bypass of the treatment system.
o The effluent water quality of the wastewater treatment plant will be consistent
with applicable national requirements or internationally accepted standards.
o Broken pipes and other repairs to be undertaken without delay,
o Pumps and pumping stations to be adequately maintained,
o System overflows will be prevented as much as possible by using level-meters.
o No discharge will be made to water resources in the land preparation and
construction within the scope of the Project.
o The units of the Project that are in touch with water, wastewater and chemicals
will be constructed with using concrete with appropriate cement ratio and
durability in order to provide basement impermeability.
 For the impacts of waste generation:
o Wastes to be generated within the scope of the Project will be managed in
accordance with the waste management hierarchy.
o Wastes will only be temporarily stored on site and final disposal will be carried
out outside the facility.
o Waste recycling, transport and disposal will be carried out by means of
licensed companies and/or related municipalities.
o Incineration or burying of wastes by any means at site and/or dumping of
wastes to nearby roads or water resources will absolutely not be in question.
o All kinds of implementations that may threaten personnel or public health will
be avoided in all activities involving collection, temporary storage, transport
and disposal of wastes throughout the Project.
o Wastes to be temporarily stored on site will be delivered to licensed transport
vehicles appropriate to the type of waste for disposal. Information related to the
operations in this context will be recorded and the records will be kept in the
administrative building.
o Hazardous or non-hazardous inscription, waste code, stored waste amount
and storage date will be indicated/labelled on wastes temporary stored by
classifying according to their properties. The reaction of wastes with each other
will be prevented by the measures taken in the Temporary Storage Area.
 For the impacts on biodiversity:
o No protected and sensitive ecosystems or species are foreseen to exist within
the project area. However, prior to the land preparation phase, definite working
areas will be set up where activities (e.g. vegetation clearing, vegetation
removal, levelling and construction) and permanent structures (units and
roads) will be established;
o Construction work will be done gradually so that it will have enough time to
escape for possible fauna species to be found.
 For the impacts on socio-economic environment:
o Prior to construction activities, the Contractor will install all signs, barriers and
control devices needed to ensure the safe use of the road by traffic and
pedestrians, as required by the transport and traffic management plan to be
prepared.

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 o Local authorities and residents in a working area will be consulted and
informed before any detours for construction or diverted public traffic are
established
o Disruptions to traffic and road transport will be minimized. The contractor shall
ensure that the roads remain open to traffic during construction activities.
o Disposal sites and haul routes will be identified and coordinated with local
officials.
o Guidance, directives and recommendations of Republic of Turkey Ministry of
Health, Republic of Turkey Ministry of Family, Labor and Social Services, and
World Health Organization shall be followed and all relevant necessary
measures shall be taken in case of an outbreak of any other
pandemic/communicable disease including COVID-19.
 For the impacts on labour and working conditions:
o Except local recruitment, the Project impacts on labour and working conditions
are generally assessed as adverse and low in significance. In the management
of labor and working conditions the World Bank policies will be followed
together with the provisions of the related Turkish national legislation.
 For the impacts on community health and safety:
o All unit shutdown requirements will be scheduled at least one week beforehand
and MUSKI will make necessary adjustments.
o In major shutdowns of the plant or biological treatment units that require longer
times, nutrition levels will be maintained at the biological treatment units,
aeration will be stopped after one day for aerobic processes.
o During the longer shutdowns or failures, MUSKI will inform Provincial
Directorate of Environment, Urbanization and Climate Change regarding the
situation.
o During excessive loads that the WWTP cannot handle, the bypass line of the
plant will be used to bypass the load.
o Community Health, Safety, and Security Management Plan that is in line with
OP 4.01 and WBG EHS Guidelines (both general and sector specific) will be
developed by MUSKI or security services provider before the construction
phase. MUSKI and contractor will ensure that the plan is actively implemented.
 For the impacts on archaeological and cultural heritage:
o As required by Article 4 of Law on the Conservation of Cultural and Natural
Properties (2863 Numbered Law), chance finds procedure will be implemented
during land preparation and construction works.

As a part of the mitigation measures, it is recommended that an Environmental and Social

Management System (ESMS) covers all phases of the Project and consists of management plans
on different subjects should be developed. A list of recommended management plans for both
phases of the Project are presented below;

Construction Phase;

 A Soil Management Plan,

 An Oil and Chemical Spill Contingency Management Plan,
 A Dust Management Plan,
 A Noise Management Plan,
 A Water Resources and Effluent Management Plan,
 A Waste Management Plan,
 A Pollution Prevention Plan,
 A Transport and Traffic Management Plan,
 An Occupational Health and Safety Management Plan,
 A Community Health, Safety, and Security Management Plan,
 A Workforce Management Plan,

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  An Emergency Preparedness and Response Plan,
 A Stakeholder Engagement Plan (SEP).
 A Contractor Management Plan

Operation Phase;

 An Odor Management Plan,

 A Sludge Management Plan,
 A Waste Management Plan,
 An Occupational Health and Safety Management Plan,
 A Community Health, Safety, and Security Management Plan
 A Water Resources and Effluent Management Plan,
 An Emergency Preparedness and Response Plan,
 A Stakeholder Engagement Plan.

To ensure the continuity and effectiveness of the implementation of mitigation management

strategies defined, monitoring plays a key role and therefore, monitoring plans for construction and
operation phases are defined and presented in Chapter VII Environmental and Social Management
Plan of this report. The monitoring requirements cover monitoring of storage and reuse of
excavation waste, storage conditions of chemicals and hazardous materials, soil quality, air quality,
noise levels, effluent water quality of Oren WWTP and WWTP’s treatment performance,
requirements of Project’s grievance mechanism, labour and working conditions, community health
and safety, and socio-economic subjects.

MUSKI should manage an effective information disclosure system in line with the World
Bank Information Disclosure Policy, and should request from its possible contractors to do so. Also,
in order to collect the opinions of the community, MUSKI should operate an effective grievance
mechanism and stakeholder engagement.

Overall, with the realization of the Project, the wastewaters will be treated, discharge of
untreated wastewaters into environment will be prevented and the Project will have positive impact
on both the environment and public health.

The first public participation meeting (PPM-1) was held on July 7, 2020, at Oren with the
participation of 84 people. The discussions and Q&A sessions were fruitful and the community was
made aware of the Project and its possible environmental and social impacts. In general, the
community supports the Project since they have been awaiting this Project to start for many years.
Following the completion of the Draft ESIA Report, PPM-II was held at February 11th, 2022 with the
participation of 63 people. In this context, the findings of the ESIA studies were shared with the
public and stakeholders. Their opinions, concerns and suggestions were obtained and considered
and addressed in this Final ESIA as relevant.

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 I. INTRODUCTION
I.1 Description of the Project

İller Bankası A.Ş. (ILBANK) and World Bank (WB) have developed the Sustainable Cities
Project (SCP) to establish a support mechanism for participating second level metropolitan
municipalities to plan and invest in a sustainable future. The investments to be made within the
scope of SCP will follow environmental legislation of Republic of Turkey as well as World Bank
safeguard policies and standards. Under SCP financed by WB, two sub-loan agreements were
signed between General Directorate of Water and Wastewater Utility of Mugla Metropolitan
Municipality (MUSKI) and ILBANK in the wastewater sector. The project with MUS2-W2 code,
which is subject to this study, is in the scope of SCP-II.

This report has been prepared by Encon Çevre Danışmanlık Ltd. Şti. (ENCON) in the
scope of the Environmental and Social Impact Assessment (ESIA) study conducted for the Milas-
Oren Sewerage System and Wastewater Treatment Plant (WWTP) Project (the Project). Under the
scope of the Project, one component is the construction of sewerage networks in Oren
neighbourhood of Milas District. The other component is the construction of Oren WWTP on one
parcel located in the borders of Oren neighbourhood with additional discharge line.

The diameters of pipes to be used in Oren’s sewerage system vary between Ø200 mm and
Ø3000 mm. The pipes will be HDPE corrugated and GRP. System’s design is made according to
2054 population and flowrate. The 74.5 km sewerage network construction consists of installation
of 53 km sewerage network, 9.5 km household connection and 12 km force main. The other
component of the Project is Oren WWTP, which has a daily design capacity of 4,000 m3/day for the
1st Stage (until 2028), and total of 8,000 m3/day (4,000 m3/day + 4,000 m3/day) for the 2nd Stage
(after 2028). The WWTP will be able to treat organic pollutants together with nitrogen and
phosphorus. After the treatment, treated effluent will meet the national legislative quality criteria
and necessary WBG EHS Guideline criteria and will be discharged to Hanay Creek through 1,542
meter discharge line to be constructed.

I.2 Scope of the Environmental and Social Impact Assessment Studies

This ESIA Report in hand is prepared for the Project in full compliance with the World Bank
Safeguards Policies, to ensure that the upcoming stages of the project will meet these standards.
The ESIA studies for the Project were carried out through utilization of resources including the
related literature, previously prepared reports, information provided by MUSKI and ILBANK, and
outcomes of the field studies that covers sampling and measurement campaigns to determine
baseline conditions and surveys, interviews, and discussions made with dwellers, muhtars and
municipality representatives.

After gathering required data from the sources, the studies were carried out with impact
assessment using relevant impact assessment methodologies including mathematical calculations,
geographical information systems, sampling, analysis, face-to-face surveys, and interviews, and
experts’ opinions. The “List of Preparers and Contributors” who have contributed in the ESIA
studies is included in Annex 1 of this report.

Various documents were consulted during the preparation of the ESIA Report, including
legal reports, laws and regulations, technical and economic reports regarding the project,
publications on land use, natural resources, geology, socio-economic features of the area/region,
maps, various data on water quality, hydrology, and climatology obtained from different agencies
(see References). The impacts were identified and evaluated in the light of all results gathered
together.

Finally, the report was prepared by ENCON, covering baseline conditions of the physical,
biological, and socio-economic environments, assessments regarding the potential impact of the
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project on the outlined baseline conditions, mitigation measures, environmental and social
management plans (ESMPs) that covers construction and operation phases, evaluation of project’s
site and technology alternatives, and public participation activities.

I.3 Structure of the ESIA Report

The World Bank policies formed the basis of the development of environmental, social and
ESIA policies of the International Finance Institutions (IFIs). The general outline of this ESIA report
is guided by the requirements of the World Bank’s Operational Policy (OP) 4.01 Environmental
Assessment (EA) for Category A Projects 1, and includes the following major headings;

 Introduction
 Project description
 Policy, legal and administrative framework
 Baseline data
 Environmental and social impacts and risk and mitigation measures
 Analysis of alternatives
 Environmental and social management plan (ESMP)
 Public participation
 Annexes

The Project was structured around the above-mentioned main headings. The information
provided in the report was detailed under these headings to the extent that the best available data
allowed. Accordingly, the chapters included in the ESIA Report can be briefly explained as the
following:

 Chapter I. Introduction; leads an introduction to the project and ESIA Report, providing
project details and environmental and social impact studies.
 Chapter II. Project Purpose and Description; is a description of the project including its
location, components, technical specifications, associated construction and operation
activities, and a proposed schedule for implementation.
 Chapter III. Policy, Legal and Administrative Framework; explains national and
international legal requirements, and also identified environmental agreements that are
relevant to the project. It also gives an in-depth explanation on the EIA procedure in
Turkey.
 Chapter IV. Environmental and Social Baseline Conditions; describes the baseline
conditions in and around the proposed project area, including physical, biological and
socio-economic conditions.
 Chapter V. Environmental and Social Impact Assessment and Mitigation Measures;
assesses the potential positive and negative impacts of the project, identifying mitigation
measures.
 Chapter VI. Project Alternatives; is an analysis of feasible alternatives to the proposed
project site, technology, design and operation, including a “no project” alternative.
 Chapter VII. Environmental and Social Management Plan; describes the necessary
management strategies, monitoring activities, and responsibilities for implementation of the
identified mitigation measures.

1
A proposed Project is classified as Category A if it is likely to have significant adverse environmental impacts that are
sensitive, diverse, or unprecedented. The impacts may affect an area broader than the sites or facilities subject to physical
works. EA for a Category A project examines the project’s potential negative and positive environmental impacts, compares
them with those of feasible alternatives, and recommends any measures needed to prevent, minimize and mitigate, or
compensate for adverse impacts and improve environmental performance (The World Bank, 2011).

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  Chapter VIII Public Participation, gives the detailed information about the conducted
public participation meeting, sets out the comments of the community, and the results of
the questionnaire,

In line with the World Bank OP 4.01, supplementary information, such as list of preparers
and contributors, references, official letters, related reports, etc., which is relevant to the contents of
the chapters listed above, will be provided in the annexes of the ESIA Report.

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 II. PROJECT DESCRIPTION
II.1 Project Location

Mugla is a city in south-western Turkey and stretches along the Aegean coast. The city
center is located inland at an altitude of 660 m and lies at a distance of about 30 km from the
nearest coast. Districts of Mugla are Bodrum, Dalaman, Datça, Fethiye, Kavaklıdere, Köyceğiz,
Marmaris, Milas, Menteşe, Ortaca, Seydikemer, Ula and Yatağan. Mugla is surrounded by Aydın
Province on north, Denizli Province on east, Burdur Province on east-southeast and Antalya
Province on southeast. Major part of Mugla belongs to Aegean Region while the remaining small
portion belongs to Mediterranean Region.

The Project Area is located in the Oren Neighborhood of Milas District. The districts of
Mugla are shown in Figure II.1. In Figure II.2, the site location map of the Project is presented.

Air distances to the WWTP site are 33.5 km from Milas District Center and 44.5 km from
Mugla City Center. Oren WWTP site’s distances to nearest settlements are shown on a map given
in Figure II.3.

The construction works of sewerage network will be conducted on existing zoning roads
and no land acquisition is required. On the other hand, pumping stations will be built on public
lands that are registered as park, therefore, no land acquisition is required for pumping stations
either.

For the second component of the Project, which is Oren WWTP, parcel 407/1 will be used.
The parcel, previously owned by Mugla Metropolitan Municipality, currently belongs to MUSKI.
According to the information given by MUSKI, the parcel is currently in idle status and there is no
land use for any purpose. On the other hand, construction works of the discharge line will be
conducted on existing zoning roads and no land acquisition is required within this regard. Details
about the vicinity of the WWTP site are as follows:

 On the north, state road

 On the west, Mugla Sitki Kocman University Fisheries Research and Development
Center
 On the east and south; privately-owned plots where construction of yacht
manufacturing repair and boatyard is currently undergoing.

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Figure II.1 Districts of Mugla

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Figure II.2. Site location map

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Figure II.3. Nearest Settlements and their Distances to the WWTP Site

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 Photos from the WWTP site are presented in Figure II.4 and following this, the general
layout of the Project is presented in the Figure II.7.

Panoramic View of Oren WWTP Site

Planned Discharge Location - Hanay Creek

Downstream of the Discharge Location - Hanay Creek

Figure II.4 Photos from the Project Site

II.2 Land Ownership Status

The construction works of sewerage network and discharge line will be conducted on
existing zoning roads and no land acquisition is required. On the other hand, pumping stations will
be built on public lands that are registered as park, therefore, no land acquisition is required for
pumping stations either. Photos taken from the areas where pumping stations will be built are
provided in Figure II.5.

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 TM-5 Pumping Station

TM-6 Pumping Station

TM-7 Pumping Station

TM-8 Pumping Station

Figure II.5 Photos from the Planned Pumping Stations

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 For the second component of the Project, which is Oren WWTP, parcel 407/1 will be used.
The parcel, previously owned by Mugla Metropolitan Municipality, currently belongs to MUSKI. The
parcel was transferred to the use of MUSKI on May 28th, 2020. The official letters and documents
regarding the land ownership status of the Project components are provided in the Annex-8 of this
report.

In terms of auxiliary facilities, the construction/camp site will be established at the WWTP
site which currently belongs to MUSKI. For the energy transmission lines cadastral roads will be
used.

Although the energy transmission line has a linear route, only electric poles with a base
size of approximately 5m x 5m will be erected for the energy transmission line. For this reason, in
case of any expropriation process will be needed, the land acquisition area will be very limited as
the land acquisition will only be for the electric poles. Based on that, if energy transmission line will
pass on any private lands or private users on public parcels on the finalized design, then
expropriation and easement activities will be carried out based on the national Expropriation Law
(Official Gazette Date: 08.11.1983 Number of Official Gazette: 18215) and World Bank OP 4.12 -
Involuntary Resettlement. As per the Resettlement Policy Framework of Ilbank for the Project a
RAP (consistent with RPF) will be prepared by MUSKI, reviewed by Ilbank and submitted to WB for
review and approval. Expropriation activities and access to land will not take place without a World
Bank-approved RAP being in place and implemented. Meaning, for any loss of land or establishing
easement rights for the ETL components, compensations will be paid or deposited into escrow
accounts in accordance with the RAP before civil works start. After the expropriation activities,
ownership of the transmission line will be transferred to Turkish Electricity Transmission
Corporation (TEİAŞ). According to that, necessary procedures will be followed as well.

According to the information given by MUSKI, the parcel is currently in idle status and there
is no land use for any purpose. Photographs taken from the WWTP site are provided in Figure II.6.

Figure II.6 Photographs Taken from the WWTP Site

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 Moreover, as the WWTP site is accessible through the existing road network and the
sewerage network and discharge line will be constructed on public roads, construction of any
access/service road is not required.

However, no construction works should start in the parcels where public benefit decision is
taken for the ETL components and hence, expropriation or easement rights to be applied. In order
to enter the land, MUSKI has to prepare a RAP in line with the RPF and submit to ILBANK and WB
for review and approval. After RAP approved and implemented (meaning depositing compensation
to people’s accounts) then they can access lands.

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Figure II.7 General Layout of the Project

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II.3 Population Projections

Population projection is an essential part in the design of a sewage network and WWTP
projects. In order to meet the future demand, the population projection of the settlements located in
the service area should be handled properly. When calculating the future population and
accordingly the wastewater generation in the sewage and wastewater treatment facility projects,
generally, 30 years for the service period and 5 years for the realization of the facility (construction)
are accepted and thus, the target year of the project is determined. In the case of the Project at
hand, the target year is determined as 2054 and the population calculations are done accordingly.

The projections are conducted by using several calculation methods such as Ilbank
Population Calculation Method, Population Projection According to Zoning Plan. After the
calculations, the results are compared with each other and the most realistic one selected as a
design population.

II.3.1 Population Projection Methods

Ilbank Population Calculation Method

This method is developed and used frequently by Ilbank (former Bank of Provinces) and is
utilized prevalently during the design phase of infrastructure projects in Turkey. The calculation is
mainly based on geometric method.

According to this method, the following formulae are used; the first one is used to calculate
population growth coefficient (P) and the second one is used to calculate future population (Ng):

𝑎 𝑁𝑦
𝑃=( √ − 1) 𝑥100
𝑁𝑒

𝑃 𝑛𝑔−𝑛𝑦
𝑁𝑔 = 𝑁𝑦 (1 + )
100

Where:

P : Population growth coefficient

Ng : Projection year population
Ny : Latest census result
Ne : First census result
a : Time between first and last census (in years)
n : Calculation year

In this method, in order to avoid unrealistically high and/or low population projections,
upper and lower limit values are defined for P. Therefore;

 If P<1, then P is taken as 1;

 If 1<P<3, then P is taken as found, and
 If P>3, then P is taken as 3.

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 Population Projection According to Zoning Plan

Land use in residential areas (Peer) = 60%

Area of an Average Apartment = 100 m2

Average Household Size (TUIK) = 2.86 Capita

Total Housing Zone in the Zoning Plan = Housing + Developing Housing Zone (m2)

𝐻𝑜𝑢𝑠𝑖𝑛𝑔 𝑍𝑜𝑛𝑒 ∗ 60% ∗ 2.86

= 𝑁 (𝐶𝑎𝑝𝑖𝑡𝑎)
100 𝑚2

Housing Zone = 762,989.58 m 2

762989.58 ∗ 60% ∗ 2.86

= 13,093 𝐶𝑎𝑝𝑖𝑡𝑎
100 𝑚2

Land use in residential areas (Peer) = 100%

Area of an Average Apartment = 100 m2

Average Household Size (TUIK) = 2.86 Capita

Total Housing Zone in the Zoning Plan = Housing + Developing Housing Zone (m2)

𝐻𝑜𝑢𝑠𝑖𝑛𝑔 𝑍𝑜𝑛𝑒 ∗ 100% ∗ 2.86

= 𝑁 (𝐶𝑎𝑝𝑖𝑡𝑎)
100 𝑚2

Housing Zone =615,446.00 m 2

615146.00 ∗ 100% ∗ 2.86

= 17,601 𝐶𝑎𝑝𝑖𝑡𝑎
100 𝑚2

Land use in residential areas (Peer) = 30%

Area of an Average Apartment = 100 m2

Average Household Size (TUIK) = 2.86 Capita

Total Housing Zone in the Zoning Plan = Housing + Developing Housing Zone (m2)

𝐻𝑜𝑢𝑠𝑖𝑛𝑔 𝑍𝑜𝑛𝑒 ∗ 30% ∗ 2.86

= 𝑁 (𝐶𝑎𝑝𝑖𝑡𝑎)
100 𝑚2

Housing Zone =236,619.00 m 2

236619.00 ∗ %30 ∗ 2.86

= 2,031 𝐶𝑎𝑝𝑖𝑡𝑎
100 𝑚2

Türkevleri Neighborhood: 821 Capita

Total Population: 13,093 + 17,601 + 2,031 + 821 = 33,546 Capita

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II.3.2 Comparison of Population Projections

The population increase rate (Pavg) is obtained as 1.82 by using the census results of the
previous years (1940-2018) for Oren Neighborhood. However, another calculation was made at the
request of the administration using Population Projection According to Zoning Plan and the
resulting population was calculated as N = 33,546. The value of P avg calculated by Ilbank
Population Calculation Method was then accepted as 3.00 and the difference between the two
projections was accepted as a result of Secondary Housings (Summerhouse, time-share etc.) and
calculations were made accordingly.

According to the calculations, the projected populations are given in the Table II.1 and
Table II.2 in terms of summer and winter populations, respectively. Winter populations are
accepted as the resident population of Oren whereas; tourism contribution is also taken into
consideration during the summer period projection calculations.

Table II.1 Oren Neighbourhood Winter Population Projection

Years Population
2018 3.058
2019 3.150
2024 3.651
2029 4.233
2034 4.907
2039 5.689
2044 6.595
2049 7.645
2054 8.863
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

The summer populations of the settlement areas of the Oren neighbourhood, which
constitute the subject of the project, in line with the projected design stages and considering that
the region is a touristic one are considered with the addition of; the residential population, tourism
population, secondary housings, excursionists and hotel population.

In this context, these categories are defined as;

 Residential Population: Population residing in the region during both winter and
summer seasons.
 Tourism Population: Population coming to the region as a result of tourism activities
and staying in hotels, motels, hostels, resorts and similar touristic facilities.
 Secondary Housing: The periodic residents of the housing estates, timeshare and
private summer houses.
 Excursionists: Population found in the region for tourism purposes for less than a day.
 Hotel Population: The working population of hotels in the region.

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Table II.2 Oren Neighbourhood Summer Population Projection

Local Population Tourism Related Population

Years Total
Tourist Excursionist Hotel
Residents Secondary Housing
Population Population Personnel
2019 3,150 5,000 800 2,500 200 11,650
2024 3,651 5,429 900 2,857 243 13,080
2029 4,233 5,857 1,000 3,214 286 14,590
2034 4,907 6,286 1,100 3,571 329 16,193
2039 5,689 6,714 1,200 3,929 371 17,903
2044 6,595 7,143 1,300 4,286 414 19,738
2049 7,645 7,571 1,400 4,643 457 21,716
2054 8,863 8,000 1,500 5,000 500 23,863
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

For further information on the population projection calculations please see the document
named “Milas District Oren Neighbourhood Sewerage Network Project Identification Report”
prepared by IC Engineering, Architecture and Consulting Services Ltd. for this Project.

II.4 Wastewater Projections for the Project

II.4.1 Wastewater Flowrate Projections

In order to identify the required capacities of sewerage network and WWTPs, accurate
wastewater projections are as much important as population projections. The wastewater amount
calculations are performed based on the water consumption per capita values. Assumed water
consumption per capita data are provided in Table II.3. According to the accepted consumption
rates the wastewater amounts that is foreseen to be generated in the coming years are given in
Table II.4.

Table II.3 Population-Dependent Water Consumption per Capita

Population Type l/cap.d

Resident Population 260
Secondary Housing 260
Tourism 360
Excursionist 60
Hotel Personnel 100
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

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Table II.4 Wastewater Generation Rates in the Next Years According to Population Projection of Oren District

Local Population Tourism Related Population

Secondary Tourist Hotel
Years Residents Excursionist Total (l/sec)
Housing Population Personnel
(l/sec) Population (l/sec)
(l/sec) (l/sec) (l/sec)
2019 9.48 15.05 3.33 1.74 0.23 30.00
2024 10.99 16.34 3.75 1.98 0.28 33.50
2029 12.74 17.63 4.17 2.23 0.33 37.50
2034 14.77 18.92 4.58 2.48 0.38 41.50
2039 17.12 20.20 5.00 2.73 0.43 45.50
2044 19.85 21.50 5.42 2.98 0.48 50.50
2049 23.01 22.78 5.83 3.22 0.53 55.50
2054 26.67 24.07 6.25 3.47 0.58 61.50
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

Domestic Wastewater Generation

The entire project area produces domestic wastewater. In the previous section, 24-hour
wastewater generation of the District was determined. It is foreseen that the wastewater generated
will reach the sewerage network in 12 hours. The total amount of wastewater generated according
to the years is given in Table II.5 below.

Table II.5 The Total Amount of Wastewater Generated in Oren Neighbourhood

Years Flowrate
2019 30.00 * 2 = 60.00 l/sec
2024 33.50 * 2 = 67.00 l/sec
2029 37.50 * 2 = 75.00 l/sec
2034 41.50 * 2 = 82.00 l/sec
2039 45.50 * 2 = 91.00 l/sec
2044 50.50 * 2 = 101.00 l/sec
2049 55.50 * 2 = 111.00 l/sec
2054 61.50 * 2 = 123.00 l/sec
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

In addition to the domestic wastewater generation rates of the area that the Project will
serve, the wastewater flow coming from Turkevleri and Bozalan Neighborhoods which are
generally consist of holiday camps and summer houses, located in the western part of Oren
neighborhood are also considered as downstream flow for the Project. Also, the wastewater from
the marina within the borders of the Oren neighborhood will also be given in the system as
downstream flow.

Moreover, Kilic Fishery and Fish Farm located in Bozalan Neighborhood currently using a
sewage truck to collect its wastewaters and discharge it. The wastewater from this Fish Farm will
also be discharged into the new sewer system in the scope of the Project as downstream flow. The
total wastewater flowrates of the area that the project will serve at the target year (2054) is given in
Table II.6 below.

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Table II.6 Wastewater Flows of the Settlements in the Scope of the Project (2054)

Settlements Wastewater Flowrate (l/s)

Oren - Centre 100.00
Turkevleri – Bozalan Neighbourhoods (plus Marina) 23.00
Fishery 13.00
Total 136.00

Design Flowrates

The design flowrates of the Milas – Oren WWTP for 1st and 2nd stages are presented in
Table II.7. These flowrate determinations were conducted based on the approved feasibility reports
and the negotiations made with the related governmental authority.

Table II.7 Milas – Oren WWTP Design Flowrates

Flowrates 1st Stage (2028) 2nd Stage (2054)

Domestic Wastewater 4,000 m3/day 8,000 m3/day
Industrial Wastewater - -
3
Total Flowrate 4,000 m /day 8,000 m3/day
Maximum Flow Qmax 333 m3/h 666 m3/h
Average Flow Qavg 166.7 m3/h 333 m3/h
3
Minimum Flow Qmin 108 m /h 216 m3/h
Pumping Flow Qpump 350 m3/h 700 m3/h
Source: Milas District Oren Neighbourhood Sewerage Network Project Preliminary Design Report

II.4.2 Wastewater Characterization

For the characterization of wastewater, pollution load per capita data found by conducted
literature research was used. This was found to be sufficient and accurate since the only
wastewater source will be domestic and it is easy to find literature values for the characterization of
domestic wastewater.

During literature searches, different pollution load per capita values were found (Erdogan
et. al., 2005; WWTP Technical Specifications Communique, 2010; WWTP Design Guide, 2012;
ATV-A 281 E, 2001 etc.). The wastewater characterization calculations were performed by using
these entire different pollution load per capita values and ATV-DVWK standards. After the
calculations performed, the obtained wastewater characteristics and pollution load of Milas – Oren
WWTP are given in Table II.8.

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Table II.8 Milas - Oren WWTP Wastewater Characterization and Pollution Load

1st Stage (2028) 2nd Stage (2054)

Parameters (P=4,250 cap, Qavg=340 m3/d) (P=6,500 cap, Qavg=520 m3/d)
(Winter) Pollution Load Concentration Pollution Load Concentration
(kg/day) (mg/L) (kg/day) (mg/L)
BOD5 123 363 189 363
TSS 170 500 260 500
Nitrogen (N) 26 75 39 75
Phosphorus (P) 3 9 5 9
1st Stage (2028) 2nd Stage (2054)
Parameters (P=11,000 cap, Qavg=880 m3/d) (P=19,000 cap, Qavg=1,520 m3/d)
(Summer) Pollution Load Concentration Pollution Load Concentration
(kg/day) (mg/L) (kg/day) (mg/L)
BOD5 319 363 551 363
TSS 440 500 760 500
Nitrogen (N) 66 75 114 75
Phosphorus (P) 8 9 13 9
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

II.4.3 Effluent Characterization

Discharge standards for Milas – Oren WWTP has been determined based on the Urban
Wastewater Treatment Regulation (Official Gazette date: January 8, 2006, number: 26047) which
was published to accomplish the harmonization of national regulations with Directive 91/271/EEC
on Urban Waste Water Treatment and Directive 98/15/EEC amending Directive 91/271/EEC.
Discharge standards to be complied with are given in Table II.9 and these standards are accepted
as maximum limits. As the Project also follows WB standards and guidelines, the effluent quality
will meet the limit values stipulated by these. WBG General EHS Guidelines refers to WBG EHS
Guidelines for Water and Sanitation for guideline values for effluent quality of centralized,
municipal, wastewater treatment systems. The WBG EHS Guidelines for Water and Sanitation
states that effluent water quality should be consistent with applicable national requirements or
internationally accepted standards such as Council Directive 91/71/EEC of 21 May 1991 on Urban
Wastewater Treatment, whose discharge criteria is in line with the Turkish Urban Wastewater
Treatment Regulation. Therefore, following Turkish Urban Wastewater Treatment Regulation will
also keep the Project in line with international standards in terms of effluent quality.

The effluent of the WWTP will be discharged to the Hanay Creek through 1,542 meter
discharge line. Hanay Creek is not determined as a sensitive receiving body, thus the effluent of
the WWTP will be subjected to the limit values described in above paragraph. The Project will be
subjected to the limit values given for TN and TP as well.

Table II.9 Milas – Oren WWTP Discharge Standards

Urban Wastewater Treatment

Parameters Unit
Regulation Discharge Criteria

TSS mg/L 35
BOD mg O2/L 25
COD mg O2/L 125
15 (for population equivalent btw
TN mg N/L
10,000 and 100,000)
2 (for population equivalent btw 10,000
TP mg P/L
and 100,000)
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

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II.4.4 Sludge Generation Rate Estimation

For the selected design of the WWTP, specific density and volume of the sludge that is
expected to be generated after the sludge dewatering process, are estimated as 1.05-1.1 ton/m3
and 0.13-0.21 L/capita.d, respectively2. For the calculation of sludge generation amount, below
given formula is used.

Sludge Generation Amount = Total Population x Volume of Sludge x Sludge Density

Within the light of this information, estimated sludge generation amounts for the years and
seasons are given in Table II.10.

Table II.10 Sludge Generation Amounts

Winter Summer
Years
ton/d ton/d
2019 0.58 2.14
2024 0.67 2.40
2029 0.78 2.68
2034 0.90 2.97
2039 1.04 3.29
2044 1.21 3.62
2049 1.40 3.99
2054 1.63 4.38

II.5 Milas-Oren Sewerage Network

A new sewer system will be constructed to collect the wastewater of Oren Neighborhood of
Milas District. This new sewer system will be connected to the Milas – Oren WWTP.

The wastewater system consists of manhole shafts, parcel connections, secondary and
main collector network lines, and force mains, starting from the point where wastewater is
generated. The network lines are designed such that the wastewater can be delivered to the main
collector and thus the WWTP in the fastest way, without entering the reverse slope as much as
possible. As for the collecting lines, wide roads were preferred as much as possible considering the
grading. The system is determined to be a separate system. In separate systems, storm waters
and wastewaters are collected with different networks.

Within the hydraulic principles for determining the diameters of the channels in the sewage
system, the difference in water consumption at certain times of the day is the most important factor
affecting the results. The change in water consumption gives different flow rate on an hourly, daily
and weekly basis. The maximum flowrate during the day can be expressed as a function of the
average flowrate. For this reason, a peak flow factor will be used to stay safe in the design of sewer
channels, and the peak factor is determined as 2 for the project design of the channels.

Sewerage network channels are determined to be laid to a minimum depth as much as

possible depending on the conditions, and under normal conditions, the crown depths will be 1.60
m in the starting channels and 1.70 m in intermediate channels. Additionally, some manhole shafts

2Andreoli, C., Sperling, M., & Fernandes, F. (2007). Sludge treatment and disposal. London: IWA
Publishing.

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will be kept shallow where required to prevent excessive excavations on the reverse sloping roads
and these depths have been determined as 1.10-1.20 m.

The hydraulic calculations of the Oren sewerage system are made using the Kutter
formula;

𝑎√𝑅
𝑄=𝐹∗ √𝐽𝑅
𝑏 + √𝑅

Q: Flow rate of the pipe in full load (m3/s)

F: Cross sectional area of the pipe (m2)
a: Wall roughness Coefficient (100 in concrete pipes; 149 in HDPE pipes)
b: Kutter Coefficient (0.20 in concrete pipes; 0.10 in HDPE pipes)
R: Hydraulic Radius [R = F/r] (m)
r: Wetted Perimeter (m)
J: Channel Slope

According to the calculations made and conditions considered, the minimum, maximum
slope limits, fill rate, and maximum distance between the manhole shafts, are given in the Table
II.11.

Table II.11 Technical Characteristics of the Sewerage System

Minimum Maximum Max. Manhole

Diameter Minimum Maximum Fill Rate
Exceptional Exceptional Range
(mm) Slope Slope %
Slope Slope (m)
Ø200 200 - 7 4 40 60
Ø300 300 - 7 7 50 60
Ø400 600 900 25 15 60 70
Ø500 800 1000 25 15 60 70
Ø600 1000 1500 25 15 60 70
Ø800 1200 1800 50 - 60 80
Ø1000 2000 2500 75 - 70 100
Ø1200 2050 2500 75 - 70 125
Ø1400 2100 2500 75 - 80 150
Ø1600 2150 2500 75 - 80 150
Ø2000 2250 2500 75 - 80 150
Ø3000 2500 2500 75 - 80 150
Source: Milas District Oren Neighbourhood Sewerage Network Project Identification Report

In order to prevent blockages and provide the best flow in sewer systems, the minimum
diameters of the parcel connection and network pipes will be 150 mm and 200 mm, respectively.

Manhole Shafts will be installed in direction changing locations, slope changing locations,
and pipe connections. These manholes will be used for maintenance and cleaning of the channels.
These Manhole Shafts will be designed in compliance with the standards of the ILBANK
specifications, which are:

 The manholes must be water proof,

 The bottom of the manhole shafts must be sloped in line with the flow direction,
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  If the levels of the connection channels are different, appropriate chutes should be
used,
 Must have a wall thickness to withstand external loads,
 The selected manhole cover types should be ductile iron cast covers.

In manholes with chute, minimum chute height is planned as 0.75 m and maximum chute
height is planned as 4.00 m. In the diameter change locations, the crown levels of the pipes will be
levelled and there will be no transitions from large diameter pipes to small diameter pipes. The
channels are designed telescopic both horizontally and vertically. The shortest possible vertical
crossings have been made where the system crosses roads, streams, and channels.

The pipes that will be used in the sewer system will be HDPE corrugated pipes and GRP
pipes with SN8 rigidity. The exemplary manhole structures that will be used in the sewer systems
are given in the Figure II.8.

Figure II.8 Exemplary Manhole Structures with Dimensions

Pumping Stations

Within the scope of the Project, four underground pumping stations will be constructed.
While two of the pumping stations will be constructed as package pumping stations, the others will
be constructed as reinforced concrete pumping stations.

The pumps within the pumping stations are selected as submerged electromagnetic pulse
pumps. Within the pumping stations, sound insulation building materials will also be used, in order
to prevent generation of the excessive noise levels in the vicinity of the pumping stations.
According to the Design and Pre-evaluation Report of the Project, the final design of the pumps is
not decided yet apart from the numbers and locations. Thus, some changes may occur during the
upcoming period. An exemplary design of the envisaged system of pumping stations is given in
Figure II.9.

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Figure II.9 Exemplary Image of a Pumping Station

During the site selection process for these pumping stations the sites were selected as
public lands that are registered as parks, therefore no land acquisition processes will be triggered.
If any changes occur on the site selected for pumping stations during subproject implementation,
MUSKI will share this change for the approval of Ilbank and WB, and make necessary
amendments in the site specific environmental and social safeguards instruments accordingly.
Within this respect, an ESIA Addendum needs to be prepared when site selections are finalized for
the pumping stations. When selected sites are known, eligibility evaluation should be done as a
priority within the scope of the Project. Then, the ESIA Addendum will be conducted in line with the
requirements of OP/BP 4.01 and will cover all the impacts covered in this ESIA, as minimum. The
ESMP of this ESIA will be updated with the findings of ESIA Addendum.

II.6 Milas-Oren Wastewater Treatment Plant Components

Milas – Oren WWTP will be constructed as a part of this integrated Project. The Milas –
Oren WWTP is designed as an advanced biological wastewater treatment system to work with
Extended Aeration Activated Sludge Process. As mentioned before, the plant will have a daily
capacity of 4,000 m3/day for the 1st Stage, and total of 8,000 m3/day (4,000 m3/day + 4,000 m3/day)
for the 2nd Stage. The WWTP will be located on an area of 8278.11 m2. The 1st Stage of the plant
will be in operation until 2028. After 2028, the 2nd Stage of the plant will be realized. The area,
where the WWTP will be constructed, is given in Figure II.10. The layout of the WWTP is given in
Figure II.11.

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Figure II.10 Milas – Oren WWTP Area
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Figure II.11 Layout of Milas – Oren WWTP

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 Milas – Oren WWTP consists of the following units:

 Coarse Screen
 Pump Station
 Fine Screen
 Aerated Grit Chamber
 Rectangular Weir and Distribution Chamber
 Anaerobic BioP Tanks
 Aeration Tanks
 Final Sedimentation Distribution Chamber
 Final Sedimentation Tanks
 Treated Water Pit
 Disinfection Tank
 Sludge Pumping Station
 Sludge Thickener
 Sludge Dewatering Building
 Blower Building
 Administrative Building
 Transformer and Generator Building
 Security Cabin/Guardhouse

The Process Flow Diagram of the WWTP is presented in Figure II.12.

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Figure II.12 The Flow Diagram

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 The detailed technical information about the units is provided in the following sub-sections.

II.6.1 Preliminary Treatment

Preliminary treatment units of Milas - Oren WWTP consist of coarse and fine screens and
aerated grit chambers. Coarse and Fine screens are used for removing solid wastes such as
debris, found in the wastewater. Aerated Grit Chambers are used for removing grit from
wastewater streams.

Coarse Screens

Coarse screens remove rags, sticks, large solids and other debris ranging from 5 to 15 cm.
They can be as simple as a trash rack or as complicated as a mechanically cleaned bar screen.
Generally speaking, larger treatment facilities will install a mechanically cleaned bar screen
whereas small, outdated facilities are likely to use a manually cleaned bar screen.

Fine Screens

Where coarse screens use bars or rods to remove solids, fine screens employ wire cloth,
wedge wire elements or perforated plates. Fine screens are used to remove particles that may
cause maintenance issues for process equipment and/or operational problems to the treatment
process. Fine screen openings typically range from 1.5 mm to 5 cm. The smaller size openings
allow the fine screens to remove 20 to 35% of suspended solid and BOD.

Aerated Grit Chamber

Removal of grit and oil-grease within the wastewater will be ensured through aerated grit
chambers. In aerated grit chamber, inorganics like sand, pebble, silt, glass, metal etc. will be
removed. Grit chambers are equipped with aeration systems to keep low density organics
suspended and separating oil and grease. Grit chambers are designed to remove at least 85% of
the solid particles with diameters greater than 0.2 mm and specific gravity greater than 2.65.

The scraper/skimmer bridge moves back and forth regularly over the tank and collects and
sends the suspended grit to grit washer by its submersible pumps. The bridge also skims the oil
and grease and collects them in the hopper. Floating material such as oil and grease collected at
the hopper is transferred to the container for final disposal then.

II.6.2 Advanced Biological Treatment

Removal of carbon-based pollutants as well as nitrogen and phosphorus are carried out
simultaneously at the bio-phosphorus tanks, aeration tanks and final sedimentation tanks. These
units are considered as the advanced biological treatment components of Milas – Oren WWTP.
The detailed information about these units is given in following subsections.

Anaerobic Tanks (Bio-Phosphorus Tanks)

Biological phosphorus removal consists of two stages. These stages are storage of
phosphorus release in anaerobic environment and the storage of the excess of the released
phosphorus in anoxic/oxic environment. To enable phosphorus release, readily degradable
dissolved organic carbon in the inlet water shall be stored within the cell. When there is an electron

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acceptor in the environment, the microorganism will use the stored carbon in order to sustain its
activities and store excess phosphorus for regeneration of ATP.

Aeration Tanks

In the anoxic and oxic sections of the aeration tanks, biological treatment continues with
nitrification and denitrification processes. The amount of air required for nitrification is supplied and
the ammonium nitrogen at the inlet is converted into nitrate nitrogen. Generated nitrate nitrogen
then is used as an electron acceptor for the removal of biochemical oxygen demand. Then the
wastewater is transferred to aeration tanks for its further treatment in bio-P tanks. Aeration tanks
are designed as pre-denitrification systems.

Final Sedimentation Tanks

The secondary (final) sedimentation tanks allow the microorganisms and other solids to
settle after secondary or biological treatment. This sludge is pumped back into the inlet end of the
primary sedimentation tanks and settles with the raw sludge. At this stage the BOD may be
reduced to approximately 75 - 80% of the influent level and suspended solids are removed.

II.6.3 Sludge Treatment Units

Sludge Thickener

Sludge thickening process involves the concentration of thin sludges to more dense sludge
in special circular tanks designed for this purpose. Its use is largely restricted to the watery excess
sludge from the activated sludge process. It may also be used to concentrate sludge to primary
tanks or a mixture of primary and excess activated sludge prior to high rate digestion.

The thickening tank is equipped with slowly moving vertical paddles built like a picket
fence. Sludge is usually pumped continuously from the sedimentation tank to the thickener which
has a low overflow rate so that the excess water overflows and the sludge solids concentrate in the
bottom. A blanket of sludge is maintained by controlled removal which may be continuous at a low
rate. Sludge with a solids content of 8 -10% or more can be produced by this method. This means
that with an original sludge of 2%, about four-fifths of the water has been removed, and one of the
objectives in sludge treatment has been attained.

Sludge Dewatering

Sludge dewatering will be performed by decanters. Biological sludge that will be collected
from the final sedimentation tanks and the sludge that will be collected from sludge thickening
tanks will be sent to the sludge dewatering system. Sludge dewatering units will increase the solid
content of the sludge from 1% to 25%.

Sludge Disposal

After stabilization and dewatering, the excess sludge will be analysed to determine
compliance with the Annex-2 of the Regulation on Landfilling of Wastes and if it is deemed
appropriate, the sludge will be collected by the licensed disposal companies determined by MUSKI
every year. The sludge will be collected from the facility by transportation vehicles of licensed
companies and then will be stored in landfill.

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 If sludge would be determined as hazardous, the sludge will be sent to Anadolu Tehlikeli
Atik Depolama Sanayi ve Ticaret A.Ş. for disposal by competent and licensed firms.

II.6.4 Disinfection Unit

In Milas – Oren WWTP, the treated effluent will be discharged into the Hanay Creek and
hence, disinfection of the effluent is required. Disinfection is the process designed to kill or
inactivate most microorganisms in wastewater, including essentially all pathogenic organisms. In
this scope, the effluent of the Milas – Oren WWTP will be disinfected by using chlorination method.

II.7 Auxiliary Facilities

In the scope of the Project, several auxiliary facilities will be required. Related information
about these facilities is given below:

 In order to provide energy for the WWTP, energy transmission line will be needed.
According to the information given by MUSKI, the energy will be supplied from the
transformer no. 3 located 700 meters away from the WWTP. 35.4 kV (medium
voltage) of energy will be used from this transformer which has a capacity of 2
MVA. For the energy transmission line cadastral roads will be used. The
subcontractor will be responsible from the construction of energy transmission line.
Although the energy transmission line has a linear route, only electric poles with a
base size of approximately 5m x 5m will be erected for the energy transmission
line. For this reason, in case of any expropriation process will be needed, the land
acquisition area will be very limited as the land acquisition will only be for the
electric poles. Based on that, if energy transmission line will pass on any private
lands or private users on public parcels on the finalized design, then expropriation
and easement activities will be carried out based on the national Expropriation Law
(Official Gazette Date: 08.11.1983 Number of Official Gazette: 18215) and World
Bank OP 4.12 - Involuntary Resettlement, and a RAP (consistent with RPF) will be
prepared and implemented as needed. After the expropriation activities, ownership
of the transmission line will be transferred to Turkish Electricity Transmission
Corporation (TEİAŞ). According to that, necessary procedures will be followed as
well.
 The construction materials will be provided from close vicinity of the Project area.
There will be no need for borrow pits/quarries within the scope of the project since
the need will be met from the existing licensed quarries in the region.
 In terms of establishment of construction/camp site, the Contractor will be
responsible within the scope of Project.
 Regardless of the exact number of people to be employed, the priority will be given
to the local population. Therefore, there will be no accommodation at construction
site.
 Since the WWTP site is accessible through the existing road network and the
sewerage network and discharge line will be constructed on public roads,
construction of any access/service road is not required.

However, no construction works should start in the parcels where public benefit decision is
taken and hence, expropriation or easement rights to be applied. In order to enter the land, MUSKI
has to prepare a RAP in line with the RPF and submit to ILBANK and WB for review and approval.
After RAP approved and implemented (meaning depositing compensation to people’s accounts)
then they can access lands.

Map of energy transmission line are provided in Figure II.13.

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Figure II.13 Map of Energy Transmission Line

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II.8 Personnel Requirements

Although it is not decided yet, it is expected that around 100 workers at the peak period of
construction phase and 10 workers in the operation phase of the Project (WWTP and Sewerage
Network) will be employed. Regardless of the exact number of people to be employed, the priority
will be given to the local population. Therefore, there will be no accommodation on site.

II.9 Project Cost

The planned cost of the Project is 4,813,194 Euro.

II.10 Project Schedule

The tendering and contracting period of the Project is expected to take place in the Q1 of
2022, after the tendering period the construction works will start and last for 18 and 24 months for
the WWTP and sewerage network, respectively. The defect liability period (DLP) starts just after
that and lasts for 12 months. The anticipated schedule of the Project is provided in Table II.12.

Table II.12 Project Schedule

2022 2023 2024 2025

Year
Quarters Quarters Quarters Quarters
Item 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4

Wastewater Treatment Plant

Tender docs, tendering

Construction

DLP

Sewerage Network

Tender docs, tendering

Construction

DLP

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III. LEGAL FRAMEWORK
This chapter is constructed to elucidate the main aspects of the legal and administrative
framework followed in the design of ESIA studies and preparation of the report in hand. Various
national and international legislations explained in the following sections are also to be complied
with during different stages of the Project, including planning, pre-construction, construction and
operation.

III.1 Turkish Legislation

The key national laws and regulations presented in this section include the legal
requirements to reduce the potential environmental impacts that may arise from the construction
and operational activities of the Project. Turkish Legislation related to the Project is presented in
the following sections under relevant subtopics.

III.1.1 Turkish Environmental, Health and Safety Legislations

Environmental Law, which is ratified in August 1983, is one of the principal legislation
related to the Project. Several by-laws and decrees are enforced under the Environmental Law.

The Environmental Impact Assessment Regulation (Official Gazette date November 25,
2014, number 29186) defines the administrative and technical procedures and principles to be
followed throughout the EIA process. When an activity (a Project) is planned, the Project developer
is responsible for preparing an Environmental Impact Assessment (EIA) Report along with many
other permits required to realize the Project. However, facilities are subject to preparation of an EIA
Report depending on the type of the facility, its capacity, or the location of the activity. The activities
that are subject to the provisions of the Environmental Impact Assessment Regulation are listed in
Annex I and Annex II of the Regulation. For Annex I activities a full EIA report is required and those
Projects go through the full EIA process. For Annex II activities, a Project Presentation File (PPF) is
prepared in accordance with the outline given in the Regulation and the relevant process has to be
conducted. As a result of the submission of PPF, if “EIA is required” decision is given, a full EIA is
prepared.

The EIA process starts with submitting a brief report (EIA Application File), summarizing
the characteristics of the Project and the impact area, and the potential environmental impacts and
mitigation measures, prepared according to the format provided in Annex III of the EIA Regulation
to the Ministry of Environment, Urbanisation and Climate Change. Then the MoEUCC, General
Directorate of EIA, Permit and Inspection forms a committee from related governmental and non-
governmental agencies, which also includes the Project Owner and the consultant that would
prepare the EIA report. With the formation of this committee the scoping phase starts.

This committee aims to define the scope of the EIA report to be prepared for the Project.
The EIA scope is defined based on findings of the committee and the comments and suggestions
received from a public consultation meeting to be held at the Project site. The purpose of the
meeting is to give information regarding the Project and take the opinion of the public and answer
their questions regarding the Project.

In addition, the Ministry shall announce that the EIA process regarding the Project has
been initiated and information regarding the EIA process may be obtained also via the internet. The
scoping phase is completed with a meeting of this committee during which the EIA scope is agreed
on. Based on the agreed scope, the EIA studies are conducted and the report is prepared. After the
submission of the EIA Report to the General Directorate of EIA, Permit and Inspection, it is
checked with regard to the contents to decide whether the report is suitable for starting the review
process. If the content of the report is found to be appropriate, the review period starts and ends
with either a positive or negative decision.

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 Ministry of Environment, Urbanisation and Climate Change and the governorships are
responsible for informing the public that the review period of the EIA Report is started via
announcements using local and national media, boards, internet etc. Thus, public will be able to
access the EIA Report from the web site of the MoEUCC or the relevant Provincial Directorate and
comment on the Report. Those comments are reviewed in the Review Commission meeting and
the results are reflected in the EIA Report.

Infrastructure projects such as sewerage networks, water supply networks and storm water
systems are out of the scope of the Environmental Impact Assessment Regulation. Therefore, no
EIA study is required for the sewerage network component of this Project. Wastewater treatment
plants are scoped-in according to their daily capacity or equivalent population. While the treatment
plants with an equivalent population higher than 150,000 and/or capacity higher than 30,000
m3/day require full EIA study, which means these projects are listed under Annex I of the
regulation; the ones with an equivalent population in between 50,000 and 150,000 and capacity in
between 10,000 m3/day and 30,000 m 3/day require PPF, which means these projects are listed
under Annex II of the regulation. Therefore, the wastewater treatment plant of this Project, which
has 8,000 m3/day design capacity, does not require either an EIA or PPF. EIA exempt decision is
given in Annex-9 of this report.

Medium voltage overhead transmission lines are not subjected to the national EIA
Regulation. Energy transmission lines more than 15 km and higher than 154 kV are subjected to
EIA procedure, whereas the ones between 5 km and 15 km and higher than 154 kV are subjected
to Selection and Elimination criteria. By taking into consideration of the length and voltage of the
proposed energy transmission line, it is anticipated that the risks and impacts due to construction
and operation of the energy transmission line would be of a low magnitude.

The Project with all its components is out of the scope of the Turkish Environmental Impact
Assessment Regulation.

The rest of the Turkish EHS Legislation that the Project will comply with is presented in
Table III.1 below.

Table III.1 Turkish EHS Legislation Related to the Project*

Official Gazette Official Gazette

Legislation Implications for the Project Stages
Date Number
Waste Management
 Management of wastes generated by
construction staff during the construction
Waste Management stage and by operation staff during the
April 2, 2015 29314
Regulation operation stage
 Hazardous wastes generated at
construction and operation stages
Regulation on Landfill of  Final sludge generated during operation
March 26, 2010 27533
Wastes stage.
Regulation on the Control of  Waste oils generated at construction and
July 30, 2008 26952
Waste Oil operations stages.
Regulation on the Control of  Waste vegetable oils generated at
January 6, 2015 29378
Waste Vegetable Oil construction and operation stages.
Regulation on the Control of  Packaging wastes generated at
December 27, 2017 30283
Packaging Waste construction and operation stages.
Regulation on the Control of  Medical wastes generated at
January 25, 2017 29959
Medical Waste construction and operation stages.
Regulation on the Control of  Waste tires generated at construction
November 25, 2006 26357
Waste Tires and operation stages.
Regulation on the Control of  Waste batteries and accumulators
Waste Batteries and August 31, 2004 25569 generated at construction and operation
Accumulators stages.

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Table III.1 Turkish EHS Legislation Related to the Project*

Official Gazette Official Gazette

Legislation Implications for the Project Stages
Date Number
Regulation on the Control of
 Excavation materials, construction and
Excavation Materials,
March 28, 2004 25406 demolition wastes generated during
Construction and Demolition
construction stage.
Wastes
Regulation on the Control of  Management of waste vehicles currently
December 30, 2009 27448
Waste Vehicles stored in the Project Area.

Regulation on the Use of

 Management of final sludge generated
Domestic and Urban August 3, 2010 27661
during operation stage.
Sewage Sludge on Soil

Regulation on the  Management of final sludge generated

October 6, 2010 27721
Incineration of Wastes during operation stage.
Water Quality Control and Management
 Discharge of treated effluent during
Water Pollution Control operation stage.
December 31, 2004 25687
Regulation  Wastewater generated by the site staff
at construction stage
Regulation on the Water
 Drinking water supplied during
Intended for Human February 17, 2005 25730
construction and operation stages.
Consumption
Regulation on the Control of
Pollution Caused by
 Management of hazardous substances
Hazardous Substances in November 26, 2005 26005
at construction and operation stages.
and around Water
Environment
Regulation on the Protection  Protection of groundwater sources
of Ground Waters against April 7, 2012 28257 against pollution during construction and
Pollution and Deterioration operation stages.
 Discharge of treated effluent during
Surface Water Quality operation stage.
November 30, 2012 28483
Regulation  Monitoring of water quality at receiving
body during operation stage.
Regulation on the Monitoring
 Monitoring of water quality at receiving
of Surface Waters and February 11, 2014 28910
body during operation stage.
Groundwaters
 Effluent quality and treatment
Urban Wastewater
January 8, 2006 26047 efficiencies to be met during the operation
Treatment Regulation
stage of Oren WWTP
Air Quality Control and Management
Regulation on the Control of  Heating of the operational buildings
January 13, 2005 25699
Air Pollution from Heating during operation stage.
Regulation on the
Assessment and June 6, 2008 26898  Emissions during operation stage.
Management of Air Quality
 Dust emissions due to the construction
Industrial Air Pollution
July 3, 2009 27277 activities performed at construction stage.
Control Regulation
 Emissions during operation stage.
Regulation on the Control of  Odorous emissions generated during
July 19, 2013 28712
Odor Causing Emissions operation stage.
Regulation on the Monitoring
 Greenhouse gas emissions during
of Greenhouse Gas May 17, 2014 29003
construction and operation phases.
Emissions

Regulation on Exhaust Gas  Operation of Project vehicles, machinery

March 11, 2018 30004
Emission Control and equipment at all phases of the Project

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Table III.1 Turkish EHS Legislation Related to the Project*

Official Gazette Official Gazette

Legislation Implications for the Project Stages
Date Number
Noise Control and Management
Regulation on the
 Noise levels caused by noise sources
Environmental Noise
December 30, 2006 26392 within the Project site at the construction
Emissions Caused by
and operation stages.
Equipment Used Outdoors
Regulation on the
Assessment and  Noise emissions at construction and
June 4, 2010 27601
Management of operation stages
Environmental Noise
Soil Quality Control and Management
Regulation on the Control of
Soil Pollution and Lands  Risks of soil contamination at
June 8, 2010 27605
Contaminated by Point construction and operation stages.
Sources
Environmental Management, Permitting and Planning
Environmental Impact  Impacts during construction and
November 25, 2014 29186
Assessment Regulation operation stages.
 Audits performed by either Project
Environmental Auditing
November 21, 2008 27061 Owner or governmental authorities during
Regulation
construction and operation stages.
Environmental Permits and  Required permits and licenses at all
September 10, 2014 29115
Licensing Regulation stages of the Project.
Regulation on Wastewater
Collection and Disposal January 6, 2017 29940  At all stages of the Project.
Systems
Health and Safety
Occupational Health and  Health and safety measures to be taken
June 14, 2014 29030
Safety Regulation during construction and operation stages.
 Health and safety measures to be taken
Manual Handling Operations
July 24, 2013 28717 during manual handling activities at
Regulation
construction and operation stages.
 Health and safety measures to be taken
Preparation, Completion and during preparation, completion and
April 28, 2004 25446
Cleaning Works Regulation cleaning works at construction and
operation stages.
 Personal protection equipment to be
Personal Protection
November 29, 2006 26361 used during construction and operation
Equipment Regulation
stages.
Regulation on the Use of  Personal protection equipment to be
Personal Protection July 2, 2013 28695 used during construction and operation
Equipment at Workplaces stages.
 In case of a first aid requirement during
First Aid Regulation July 29, 2015 29429
construction and operation stages.
National Occupational
 Health and safety measures to be taken
Health and Safety Council February 5, 2013 28550
during construction and operation stages.
Regulation
Regulation on the Protection
of Workers Against the  Health and safety measures to be taken
April 30, 2013 28633
Dangers of Explosive during construction and operation stages.
Environments
Regulation on the Methods
 Health and safety trainings to be
and Essentials of
May 15, 2013 28648 performed during construction and
Occupational Health and
operation stages
Safety Trainings for Workers

Regulation on the Protection  Health and safety measures to be taken

of Workers from Noise July 28, 2013 28721 against the noise impacts during
Related Risks construction and operation stages.

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 Table III.1 Turkish EHS Legislation Related to the Project*

Official Gazette Official Gazette

Legislation Implications for the Project Stages
Date Number
Regulation on the Protection  Health and safety measures to be taken
of Workers from Vibration August 22, 2013 28743 against the vibration impacts during
Related Risks construction and operation stages.
Health and Safety Signs  Health and safety signs to be placed
September 11, 2013 28762
Regulation during construction and operation stages.
Regulation on the
 Health and safety measures to be taken
Occupational Health and
August 23, 2013 28744 for temporary workers during construction
Safety for Temporary or
and operation stages.
Fixed Term Jobs
Regulation on the  Constructional health and safety
Occupational Health and October 5, 2013 28786 measures to be taken during construction
Safety in Construction phase.
Communiqué on
 Determination of hazard classes during
Occupational Health and December 26, 2012 28509
construction and operation phases.
Safety Hazard Classes List
Management of Chemicals and Other Dangerous Substances
 Chemicals and hazardous goods to be
Water Pollution Control
December 31, 2004 25687 used during construction and operation
Regulation
phases.
Regulation on the
Classification, Labelling and  Chemicals and mixtures to be used
December 11, 2013 28848
Packaging of Materials and during construction and operation phases.
Mixtures
Regulation on the Road
 Hazardous goods to be transported
Transportation of Hazardous October 24, 2013 28801
during operation phase.
Goods
Land Use
Regulation on the
Protection, Usage and
December 9, 2017 30265  Change in the land use
Planning of Agricultural
Lands
General
Regulation on the
Implementation of the Law  Private security services to be used
October 7, 2004 25606
Concerning Private Security during construction and operation services
Services
Regulation Concerning the
 Construction works within the scope of
Buildings to be built in March 6, 2007 26454
the Project.
Earthquake Zones
Regulation on the Protection  Measures to be taken for fire protection
December 19, 2007 26735
of Buildings from Fire during construction and operation phases.
Regulation Concerning the
 Substances to be used during
Ozone Depleting April 07, 2017 30031
construction and operation phases.
Substances
Regulation Concerning the
Increase in the Efficiencies  Energy consumption during construction
October 27, 2011 28097
of Energy Consumption and and operation phases.
Energy Resources
*Relevant amendments of the listed legislation will be applicable.

MUSKI shall comply with the requirements of the current national legislations and codes of
practice, and fulfil all other legal requirements. Therefore, during each stage of the planned Project
and implementation of related management plans, all activities will be carried in accordance with
certain standards and limits set by the above-mentioned laws and regulations and any license
and/or permit required for the upcoming stages of the Project will be acquired accordingly.

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III.1.2 Turkish Legislation on the Conservation of Nature and Wildlife

Project-related Turkish legislation on conservation of nature and wildlife is presented below

in Table III.2.

Table III.2 Project related Turkish Legislation on the Conservation of Nature and Wildlife

Official Gazette Official Gazette

Legislation Implications for the Project Stages
Date Number
Regulation on the
Management of Natural
Assets, Natural Protected
 Measures to be taken during the
Areas, and State-Owned May 2, 2013 28635
construction stage.
Lands Located on
Environmental
Conservation Lands
Law on Conservation of
 Measures to be taken during chance finds
Cultural and Natural July 23, 1983 18113
at the construction stage.
Assets
 Monitoring requirements regarding hunting
Land Hunting Law July 11, 2003 25165
and wildlife.
 Measures to be taken during the
Law on Fisheries April 4, 1971 13799
construction and operation stages.
 Measures to be taken during the
Regulation on Fisheries March 10, 1995 22223
construction and operation stages.

III.1.3 Labour Law

The Turkish Labor Law (Law No: 4857) was enacted on 22.05.2003 and published in
official gazette on 10.06.2003. The purpose of this law is to regulate the working conditions and
work-related rights and obligations of employers and employees working under an employment
contract. This Law applies to all the establishments and to their employers, employer’s
representatives and employees, irrespective of the subject matter of their activities with the
exception of the activities and employment relationships listed in Article 4 of this law, some
examples to these exceptions are; sea and air transport activities, any construction work related to
agriculture which falls within the scope of family economy, domestic services, sportsmen, etc. This
law regulates the labor related subjects such as; The principle of equal treatment which aims to
avert discrimination based on language, race, sex, political opinion, philosophical belief, religion or
similar reasons; The transfer of the establishment or one of its sections which defines the process
of the transfer paying attention to not to victimize anyone; Temporary employment relationships in
order to protect the rights of both parties. Also, labor law regulates the employment contracts, types
and terminations, wages, organization of work, employment service, supervision and inspection of
working conditions, administrative penal provisions and supplementary, transitional and concluding
provisions of labor related subjects.

III.1.4 Law on the Right to Information

The Turkish Law on the Right to Information (Law No: 4982) was adopted in 09.10.2003
and published in the official gazette on 24.10.2003. The main objective of this law is to regulate the
procedure and the basis of the right to information according to the principles of equality,
impartiality, and openness that are the necessities of a democratic and transparent government.
This law is applied to the activities of the public institutions and the professional organizations
which qualify as public institutions. The Law which is formed of five parts in total explains the legal
obligations about information disclosure processes. The first part of the law defines the objective,
scope, and definitions of terms that are used in law. The second part of the Law makes statements
about the subjects of the Right to Information and the Obligation to Provide Information. According
to Articles 4 and 5 of this Law found in this part, everyone has the right to information and the
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responsible parties are obligated to provide information. The application process for accessing
information is explained in the third part of the law. In the fourth part of the Law the information that
is restricted is described some exemplary ones are; information and documents pertaining to the
state secrets, information, and documents pertaining to the economical interests of the state, etc.
Finally, the last part of the Law describes the miscellaneous aspects of this law such as entry into
force and execution.

III.1.5 Permits

The Project-related permits to be taken are as follows;

Permits for the WWTP:

 Wastewater Treatment Plant Project Approval

 Construction license
 Building license
 Operation license
 Temporary certificate of operation
 Environmental Permit and License

Permits for the sewerage network:

 Project Approval
 Construction license
 Permit for zoning amendment
 Permits for pumping stations

III.2 International Agreements and Standards

International financial institutions follow certain policies and procedures regarding

assessment and management of environmental and social impacts of the projects to be financed.
As requirements of international extent of the Project, environmental and social database and
impact assessment studies will also guarantee that Project’s design, construction and operation will
be satisfactory for international environmental standards alongside national legislation.

III.2.1 International Environmental Conventions that Turkey is a Contracting Party

Turkish national policy on protection of cultural heritage and conservation of biological

resources has been constituted on the base of relevant international agreements that Turkey is a
party which are ratified or acceded by laws or relevant legislation. In addition to these, there are
various laws and regulations on protection and conservation of natural habitats, wildlife and cultural
heritage.

The international agreements and conventions that Turkey had ratified are:

 Paris Convention on the Protection of the World Cultural and Natural Heritage (1975),
 Barcelona Convention on the Protection of the Mediterranean Sea Against Pollution
(1976),
 Bern Convention on Protection of Europe's Wild Life and Living Environment (1982),
 The Convention for the Protection of Marine Environment and the Coastal Region of
the Mediterranean (Barcelona Convention) (1981),
 Convention on Long Range Transboundary Air Pollution (CLRTAP) (1983)

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  Convention on Long-Range Transboundary Air Pollution and the Cooperative
Programme for Monitoring and Evaluation of the Long-Range Transmissions of Air
Pollutants in Europe (EMEP) (1983),
 Vienna Convention for the Protection of the Ozone Layer (1988),
 Montreal Protocol on Substances Depleting the Ozone Layer (1990),
 Convention on Biological Diversity (Rio Convention) (1992),
 The International Convention on the Established of an International Fund for
Compensation for Oil Pollution Damage (FUND 1992),
 International Convention on Civil Liability for Oil Pollution Damage (1992),
 UN Framework Convention on Climate Change (UNFCCC) (2004),
 Convention on Wetlands of International Importance, Especially as Waterfowl Habitat
(RAMSAR) (1994),
 Basel Convention on the Control of Transboundary Movements of Hazardous Wastes
and Their Disposal (1994),
 Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES) (1996),
 Kyoto Protocol (1997),
 UN Convention to Combat Desertification (CCD) (1998),
 European Landscape Convention (2001),
 United Nations Europe Economic Commission Convention on Transboundary Effects
of Industrial Accidents (2000),
 Convention on Access to Information, Public Participation in Decision-Making and
Access to Justice in Environmental Matters (Aarhus Convention) (2001),
 Rotterdam Convention on the Prior Informed Consent Procedure for Certain
Hazardous Chemicals and Pesticides in International Trade (Rotterdam Convention)
(2004),
 Stockholm Convention on Persistent Organic Pollutant (POPs),
 Convention on the Conservation of Migratory Species of Wild Animals (Bonn
Convention) (1972),
 Mediterranean Sea Protocol Concerning Specially Protected Areas and Biodiversity
(1988), including related protocols,
 Convention for the Protection of the Black Sea Against Pollution (Bucharest) (1994)
and its protocols including the Protocol for the Protection of Biological and Landscape
Diversity in the Black Sea (2004).

III.2.2 World Bank Policies and Standards

Since the main finance source of the Project is WB; the Project must be in compliance with
the good international practice, including WB Safeguard Policies, guides, performance standards
and best practices documents alongside the national legislation.

WB governs projects and activities by the Safeguard Policies in order to assure that they
are conducted in an environmentally, financially and socially sound manner. Safeguard Policies
include Environmental Assessments and other policies that define environmental and social
adverse effects of the projects as well as their reduction and prevention. These policies are
enlarged upon in “The World Bank Operations Manual”, which also provides guidance on
compilation with the Operational Policies (OP), Bank Procedures (BP) and Good Practices (GP).
OPs are defined as statements of policy objectives and operational principles including the roles
and obligations of both the Borrower and the Bank, while BPs are compulsory procedures to be
followed by both the Borrower and the Bank and GP are non-compulsory advisory material.
Specific policies related and maybe related to the Project are listed below:

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  Environmental and Social Policies

o OP/BP 4.01 Environmental Assessment

o OP/BP 4.04 Natural Habitats
o OP/BP 4.11 Physical Cultural Resources
o OP/BP 4.12 Involuntary Resettlement
o OP 7.50 International Waterways

 BP 17.50 Bank Disclosure Policy

The main objectives and tasks of the Project-related WB Safeguard Policies are explained
below:

OP/BP 4.01 Environmental Assessment

 To ensure the proposed projects’ environmental and social sustainability and

soundness
 To inform decision-makers about the environmental and social risks
 To increase transparency by providing stakeholder engagement in the decision-making
process

OP/BP 4.04 Natural Habitats

 To conserve natural habitats and biodiversity

 To avoid significant conversion/degradation of critical natural habitats
 To ensure the sustainability of services and product provided to human society by
natural habitats

OP/BP 4.11 Physical Cultural Resources

 To minimize and mitigate impacts on physical cultural resources

 To ensure that measures are in compliance with the framework of national and
international agreements

OP/BP 4.12 Involuntary Resettlement

 To avoid resettlement to the extent possible
 To minimize and mitigate impacts on private assets and private users
 Assess the potential economic and social impacts of land acquisition/resettlement on
affected people (on livelihoods of them),
 Promote the process of inclusive and meaningful consultation/participation of all PAPs
including all groups and genders; including vulnerable groups in the land acquisition
(and resettlement if any) preparation and planning, as well as information
dissemination to the PAPs. Environmental and Social meetings can be held together
where possible,
 Compensate for lost assets at full replacement cost, compensation arrangements
 Compensate informal/illegal land users for lost assets and provide assistance in
relocating, if needed,
 Compensate and obtain legal access to expropriated land before starting construction,
 Provide information and prepare special assistance programs for vulnerable groups
including the persons without any immovable property,
 Provide and prepare the plans for grievance redress and monitoring in line with the WB
policy guidelines.

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 OP 7.50 International Waterways

 To notify the riparian countries in case of any activities implemented affecting the
quality and quantity of water on international waterways. The waterways identified as
NOT an international waterway (do not trigger OP 7.50) in Turkey are as follows:
Susurluk, North Aegean, Gediz, Kuçuk Menderes, Buyuk Menderes, Western
Mediterranean, Antalya, Sakarya, Western Black Sea, Yesilirmak, Kizilirmak, Konya
Kapali, Eastern Mediterranean, Seyhan, Ceyhan, Eastern Black Sea, Burdur,
Afyon,Orta Anadolu, and Van. There is no international waterway within the scope of
the Project.

BP 17.50 Bank Disclosure Policy

 To support the decision-making process by allowing public access to information on

environmental and social aspects of the project.

Under the WB’s Operational Policy for Environmental Assessment (OP 4.01), projects are
classified as Category A, B and C, based on the level of their likely environmental and social
impacts. Brief definition of these categories is given as follows:

 Category A: A proposed project is classified as Category A if it is likely to have

significant adverse environmental impacts (based on type, location, sensitivity, and
scale of the project and the nature and magnitude of its potential impacts). These
impacts are generally large-scale, irreversible, sensitive, diverse, cumulative or
precedent setting and may affect an area broader than the sites or facilities financed by
the project. For a Category A project, the borrower is required to prepare an ESIA
which examines the project’s potential negative and positive environmental impacts as
well as its social impacts, compares them with those feasible alternatives (including the
“without project” situation), and recommends any measures needed to prevent,
minimize, mitigate, or compensate for adverse impacts and improve environmental and
social performance. ESIA also includes an Environmental and Social Management
Plan (ESMP) which details the measures to be taken during the implementation and
operation of a project to eliminate, reduce or offset adverse environmental and social
impacts, the actions needed to implement these measures as well as monitoring
indicators and actions and responsibilities.

 Category B: A proposed project is classified as Category B if the potential impacts on

the environment are typically site-specific, reversible in nature, less adverse than those
of Category A projects and for which mitigatory measures can be designed more
readily. The scope of Environmental Assessment for a Category B projects may vary
from project to project, but is narrower than that of Category A. Like Category A ESIA,
it examines the project's potential negative and positive environmental and social
impacts and recommends any measures needed to prevent, minimize, mitigate, or
compensate for adverse impacts and improve environmental performance. If the
project is recognized as Category B, this information may be contained in an ESMP
only unless there are site-specific issues which necessitating a site-specific
assessment in addition to the ESMP.

 Category C: A proposed project is classified as Category C if it is likely to have minimal

or no adverse environmental impacts. Beyond screening, no further Environmental
Assessment action is required for a Category C project.

Considering the location of the Project and the nature of its potential environmental and
social impacts, the Project would be categorized as Category A Project for which a full-scale
environmental and social impact assessment is required under WB screening criteria and OP 4.01.
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 It should be noted that Turkish laws, notably Law No. 2863 dated 21.07.1983 on the
Protection of Cultural and Natural Assets (revised through the amendment issued on 27.07.2004
dated Official Gazette) and practices meet the World Bank requirements for physical cultural
resources (OP 4.11). The Regulation on Research, Drillings and Excavations in Relation to the
Cultural and Natural Assets, which was published in the Official Gazette No. 18485 dated
10.08.1994 define the procedures and obligations concerning the cultural and natural assets found
out during construction.

The World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines
constitutes technical reference resources that include general and sector specific examples of
international good sector practices. It includes the information on applicable environmental, health
and safety issues for all industrial sectors. WBG uses the EHS Guidelines as a technical source of
information during project appraisal. EHS Guidelines include performance levels and
measurements that can be achieved at newly installed facilities using WBG's available
technologies at reasonable cost.

General Health and Safety Guidelines include the following main items;

 Environmental
o Air Emissions and Ambient Air Quality
o Energy Conservation
o Wastewater and Ambient Water Quality
o Water Conservation
o Hazardous Materials Management
o Waste Management
o Noise
o Contaminated Land
 Occupational Health and Safety
o General Facility Design and Operation
o Communication and Training
o Physical Hazards
o Chemical Hazards
o Biological Hazards
o Radiological Hazards
o Personal Protective Equipment
o Special Hazard Environments
o Monitoring
 Community Health and Safety
o Water Quality and Availability
o Structural Safety of Project Infrastructure
o Life and Fire Safety
o Traffic Safety
o Transport of Hazardous Materials
o Disease Prevention
o Emergency Preparedness and Response
 Construction and Decommissioning
o Environment
o Occupational Health and Safety
o Community Health and Safety

In addition to the General EHS Guidelines, WBG EHS Guidelines for Water and Sanitation
is also applicable.

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III.3 Gaps between National Legal Framework and World Bank Policies (OP 4.01 and OP
4.04)

III.3.1 Environmental Protection and Conservation

Turkish national policy on conservation of biological resources and protection of cultural

heritage has been constituted on the base of relevant international agreements (see Chapter
III.2.1) that Turkey is a party which are ratified or acceded by laws or relevant legislation. In this
regard, there are various national laws and regulations on protection and conservation of natural
habitats, wildlife and cultural heritage. Thus, Turkey had agreed on implementation of the
conservation measures specified in the international agreements and formulated them into national
legislation.

According to national legislation, the areas, with significant biological diversity, with local
endemics of importance, with species that has a threat status of endangered, etc. are given
protection status. With this regard, sites can be put under protection and conservation as national
park, nature conservation area, wildlife protection and/or development area, specially protected
area, water products production area.

In Turkey, there is no conservation concept for vegetation communities and habitats as is

provided in EU countries by the EU Habitats Directive. In Turkey, there is no specific habitat
compensation requirement. There is only a policy regarding forest areas, which aims to reforest at
least as much as the forest area lost due to development activities, fires, etc. Therefore, if an area
is not provided some type of protection status (, then it is not given any special attention in terms
of;

 Studying the area for classifying it as a natural habitat or an important/critical natural

habitat;
 Requiring detailed studies for the human activities (projects) to be conducted based on
the existing environmental/ecological factors (EIA or PPF is required based on the
project type); and
 Studying on putting limitations, or means of implementation for certain type of activities
in such areas.

Main issues between Turkish legislation and OP 4.04 are in fact related with Turkish
planning and environmental assessment requirements, but some other issues can be summarized
as follows:

 The process for identification of important natural habitats and lack of consultation with
relevant stakeholders in this process.
 Requirements of baseline studies in important natural habitats
 Identification of the projects that would be allowed in such areas.
 Study requirements (such as EIA reports) for the projects to be realized in
important/critical natural habitats.

III.3.2 EIA Process and Requirements

National regulatory process and procedures for the EIA reports are in general compatible
with the WB policies on environmental assessment (OP 4.01). EIA regulation requires the coverage
of all issues regarding biological diversity and terrestrial and aquatic flora and fauna in the EIA
reports. In these terms, they are compatible with WB policies on natural habitats (OP 4.04).

The main issues rise in the scope and details of the EIA studies and reports can be listed
as given in the following paragraphs:

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  Turkish EIA regulation allows consideration of all projects in an integrated fashion, but
does not necessarily require it. In other terms, definition of project boundaries is
generally done by the project owners. WB Policies require all projects to be evaluated
together with the associated facilities especially in terms of natural habitats.
o For example, in a project where construction material is required from borrow
areas, these borrow areas might or might not be evaluated in the EIA for the main
project. Thus, associated and auxiliary facilities are not always required to be
evaluated in one EIA. The associated facilities can be assessed in separate EIAs
to be approved by the MoEUCC.
o Another example would be a project requiring access roads. Generally, when
these are on site and short roads, they are included in the EIA since otherwise they
would not need any type of assessment. However, when they are longer roads that
would have connections to main roads or carry a status of provincial or state roads,
separate PPF or EIA reports could be prepared. Thus, EIA report for the main
project can be approved without evaluation of those roads.
 The area of influence is rather implicit in many EIA studies in Turkey, in many cases
without a specific or clear definition in the report. WB Policies require identification and
definitions of the project area of influence (including the associated facilities as well)
during scoping of the report.
 The studies on biodiversity and natural resources in the EIA reports are not always site
and season specific. Depending on the sensitivity of the project, use of literature and a
more regional evaluation is allowed by the authorities in the review and approval of the
reports. In many cases there is no seasonal sampling or observations except for rather
large scale and critical projects with potentially very significant impacts and
international loan involvement. WB Policies require reliable and actual data that
represents the conditions in the impact area before the project (baseline) and then
assessment of the impacts on the biological resources and habitats accordingly.
 Cumulative impacts are not being considered in EIA reports in Turkey yet. WB Policies
require assessment of the cumulative impacts of the development projects when there
is a valued ecosystem component in the area of influence of the project that can be
affected by other activities (existing, under construction or planned).
 There is no requirement for an environmental and social management plan (ESMP),
including monitoring plan, in Turkish EIAs. Generally, mitigation measures are provided
for the significant impacts in the impact assessment sections without formulating them
to an ESMP and/or getting into details to be provided in an ESMP. This argument is
valid for monitoring measures as well though sometimes there is a section on
monitoring in the EIA report based on the decision of the Scoping Committee. WB
Policies require a well-defined ESMP in the ESIA reports or as a result of the EIA
studies.
 There is a requirement for EIA monitoring during the construction phase of the projects,
which receive EIA Positive Decisions. However, this monitoring is not in terms of
monitoring of environmental performance or compliance with the relevant emission,
discharge and such standards. This monitoring mainly covers the issues committed in
the EIA report, mostly which are physical.
o For example in EIA monitoring the coordinates of the project area is checked if it is
the same as given in the EIA report or not.
o Another example is the treatment facilities to be installed. They are checked to
confirm if they are installed or not, but their performance (do they provide the
necessary treatment) are not checked.
 WB Policies require a well-defined monitoring plan in the ESIA reports or as a result of
the ESIA studies so that the environmental issues to be monitored and responsible
parties are clear and committed.
 In Turkish EIAs the social aspects of the projects generally assessed in a brief manner,
however WB Policies requires a more detailed assessment of the possible social
impacts of the project at hand.

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III.3.3 PPF Process and Requirements

National PPF process is basically a process for screening projects (which are listed in
Annex 2 of the EIA regulation) to decide if there is a need for a full EIA. In these terms, it does not
comply with the project classification of the WB for environmental assessments. That is to say WB
might require an ESMP based on a more simple impact assessment, when compared with EIA
assessments, for category B projects. However, in PDF reports in Turkey a simple impact
assessment is required, but it ends up generally with very limited environmental management and
monitoring measures and there is no requirement of monitoring. In fact, these differences are again
due to the scoping and review of these PPF reports and not due to the lack of relevant terms in the
legislation.

In this regard, main conflict or gap with the WB policies in terms of environmental
assessment comes into picture for the Annex 2 projects (which are like Category B projects of WB)
in Turkey.

 For these projects impact assessment in the PPF is rather superficial and does not
come up with relevant impact management and monitoring measures.

 These projects are accepted to be rather small scale and associated facilities for such
projects are either all ignored or very slightly mentioned.

 The biodiversity issues and natural habitats evaluations in PPF reports are almost all
depended on literature for many projects (if there is not international loan involvement
or a well-known sensitive area).

 The social assessment is not included in the PPF reports. Therefore, during the PPF
there aren’t any requirements for social studies, in terms of both desktop and field
research.

 There is no requirement for an ESMP, or a monitoring plan. Generally mitigation

measures are provided for the significant impacts in the impact assessment sections
without formulating them to an ESMP and/or getting into details to be provided in an
ESMP.

 There is no environmental performance monitoring and no ESIA monitoring

requirement either.

III.3.4 Differences between Project-related National Legislation and WBG Guidelines’ Limit
Values

Among the legislation presented in Chapter III.1.1, the key Project-related national
regulations are Surface Water Quality Regulation and Urban Wastewater Treatment Regulation in
terms of thresholds and limit values. While Surface Water Quality Regulation determines water
quality of the receiving body in its Annex-5 Table 3, Urban Wastewater Treatment Regulation sets
limit values for effluent quality and treatment efficiencies as presented in Table III.3.

Table III.3 Urban Wastewater Treatment Regulation Discharge Limits

Parameters Concentration (mg/L) Minimum Treatment Efficiency (%)

Biochemical Oxygen Demand (BOD5)
25 70-90
(without nitrification)
Chemical Oxygen Demand (COD) 125 75

Total Suspended Solids (TSS) 35 90

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 Parameters Concentration (mg/L) Minimum Treatment Efficiency (%)

35 (EP* > 10,000) 90

60 (EP 2,000-10,000) 70

2 (EP 10,000-100,000)
Total Phosphorus** 80
1 (EP >100,000)
15 (EP 10,000-100,000)
Total Nitrogen** 70-80
10 (EP >100,000)
* EP: Equivalent Population
** Requirements for discharges from urban waste water treatment plants to sensitive areas which are subject to
eutrophication

The WBG’s Environmental, Health and Safety Guidelines for Water and Sanitation, which
is another key document, does not provide limit values for effluent water quality parameters as in
Turkish Urban Wastewater Treatment Regulation. However, the Article 65 of the Guideline refers to
the “applicable national requirements or international accepted standards” for the effluent water
quality. The Turkish Urban Wastewater Treatment Regulation has been constituted on the base
European Union: Council Directive 91/271/EEC of 21 May 1991 Concerning Urban Wastewater
Treatment, which is the footnote-referred legislation of the Guideline, thus; there are no gaps in
between.

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IV. BASELINE CONDITIONS
IV.1 Physical Environment

This chapter is divided into subsections of geological, hydrogeological and hydrological

characteristics, seismicity and natural hazard conditions, soil, erosion and land use characteristics,
climate, environmental air quality and noise levels, landscape characteristics, biological
environment and protected areas located in the Project area, its vicinity and the region Results of
the investigation studies conducted under these subheadings are described in this chapter.

Descriptions and information provided in this chapter, regarding current conditions of the
Project area and its vicinity, are based on reports prepared by related public and private
institutions, field studies conducted for identification of physical environment, Geographical
Information Systems (GIS) studies and satellite imagery, data acquired from the Ministry of
Agriculture and Forest and data acquired from the meteorology stations of the General Directorate
of Meteorology.

IV.1.1 Land Use and Property

In this section detailed information on the land use and ownership status of the Project
area is given.

Land Use

The site (8278.11 m 2) designated for Milas-Oren WWTP currently consists of an area that
is used as pasture but currently idle and it is not used for any purpose (See sections II.1 and II.2 for
the photographs taken from the site). The site is selected due to the closeness to the Hanay Creek.
The WWTP area previously owned by Mugla Metropolian Municipality, currently belongs to MUSKI.
In the close vicinity of the WWTP area, there are roads, belt conveyor of Kemerköy Thermal Power
Plant, Mugla Sitki Kocman University Fisheries Research and Development Centre, and privately-
owned plots where construction of yacht manufacturing repair and boatyard is currently
undergoing.

The closest settlement to the WWTP site is located 50 meters at the northeast at Mugla
Sitki Kocman University Fisheries Research and Development Centre and the closest settlement
area is around 175 meters at the south-east. The WWTP area can be accessible with the current
roads; therefore, no access roads will be constructed.

In the scope of the Project, the WWTP will be constructed within the area that belongs to
MUSKI and there will be no need for land acquisition. On the other hand, construction of the
discharge line will take place in existing roads and no land acquisition is required within this
respect.

The new sewerage system will be constructed by following the same route of the existing
system and pumping stations will be built on public lands that are registered as park. Therefore,
there will be no resettlement and/or physical displacement of persons in and around the Project
Area.

In terms of auxiliary facilities, the construction/camp site will be established at the WWTP
site which currently belongs to MUSKI. For the energy transmission lines cadastral roads will be
used, therefore, no land acquisition will be required.

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 During the land preparation and construction phase of the Project, existing roads will be
used. For the road opening requirements, if needed, MUSKI will apply to related Municipality. All
the roads that will be used during Project are shown on zoning maps.

According to the 1/5000 and 1/1000 scale development/zoning plans, WWTP area has
been allocated as WWTP site and pumping station areas as park (public garden) sites. MUSKI
applied to Milas Municipality regarding the amendment of 1/5000 and 1/1000 scale
development/zoning plans for the allocation of related park sites to technical infrastructure (such as
pumping station) sites on July 06, 2020 (see Annex-8). As a result of this application respective
amendments are still under evaluation by the municipality.

Property

The WWTP site is selected due to the closeness to the Hanay Creek. In the scope of the
Project, the WWTP will be constructed within the area belongs to MUSKI and there will be no land
acquisition. Currently, the area is idle and it is not used for any purpose (See sections II.1 and II.2
for the photographs taken from the site).

The closest building to Oren WWTP is located 50 meters at the north-east, which is Mugla
Sitki Kocman University Fisheries Research and Development Centre, and the closest settlement
is around 175 meters at the south-east. The area can be accessible with the existing roads;
therefore, no access roads will be constructed.

There are no land related issues expected for sewerage network and discharge line, as
they will be constructed on existing roads.

On the other hand, pumping stations will be built on public lands that are registered as
park, therefore, no land acquisition is required for pumping stations either.

In terms of auxiliary facilities, the construction/camp site will be established at the WWTP
site which currently belongs to MUSKI. For the energy transmission lines cadastral roads will be
used. Although the energy transmission line has a linear route, only electric poles with a base size
of approximately 5m x 5m will be erected for the energy transmission line. For this reason, in case
of any expropriation process will be needed, the land acquisition area will be very limited as the
land acquisition will only be for the electric poles. Based on that, if energy transmission line will
pass on any private lands or private users on public parcels on the finalized design, then
expropriation and easement activities will be carried out based on the national Expropriation Law
(Official Gazette Date: 08.11.1983 Number of Official Gazette: 18215) and World Bank OP 4.12 -
Involuntary Resettlement, and a RAP (consistent with RPF) will be prepared and implemented as
needed. After the expropriation activities, ownership of the transmission line will be transferred to
Turkish Electricity Transmission Corporation (TEİAŞ). According to that, necessary procedures will
be followed as well.

However, no construction works should start in the parcels where public benefit decision is
taken and hence, expropriation or easement rights to be applied. In order to enter the land, MUSKI
has to prepare a RAP in line with the RPF and submit to ILBANK and WB for review and approval.
After RAP approved and implemented (meaning depositing compensation to people’s accounts)
then they can access lands.

IV.1.2 Topography, Soils and Geology

This chapter identifies existing topographical, soil and geological conditions along the
Milas-Oren Wastewater Treatment Plant, discharge line and sewerage network. As, the sewerage
system and discharge line will be constructed on the existing public roads and pumping stations will

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be built on public lands that are registered as park, the baseline studies given in this sub-section
mostly cover the WWTP area.

Topography

The project area is located in the Aegean region of Turkey, which is known with its tourism
potential. The Aegean Sea is located in the south of the Project area, the Milas district in the north,
the (Merkez) Mentese district in the east and the Bodrum Peninsula in the west.

The only streams that flow inside the town are the Kemer and Koca Streams which are
also located in the vicinity of the WWTP site. In addition, Hanay Creek can be mentioned also, as
this stream is the closest stream to town apart from Koca and Kemer Streams. The highest
elevation is +60 meters and the lowest elevation is around +1 meter within the zoning plan in the
Project area. The regional center has a topographic structure that slopes from north to south.

Soil

Turkish General Directorate for Rural Services database defines the land use capabilities
in 8 different classes as summarized in Table IV.1. These classes represent the agricultural
potential of the soils. In this classification system, soils are categorized between Class I, which
represent the arable lands on which agricultural activities can be conducted in the most efficient,
economic and simplest way without causing erosion, and Class VIII, which represent the lands that
are not arable, cannot even be used as grassland or forest areas but support only wildlife
development or can be used as resting area or national park by human. Characteristics of each
class are summarized in Table IV.1 (Former Ministry of Agricultural and Rural Services, July 2008).

The Land Use Capabilities of the soils corresponding to the WWTP area is agricultural
lands not suitable for soil cultivation as Class V. Map of great soil groups and land use capability
classes for the project area is represented in Figure IV.1.

Table IV.1 Agricultural Potentials Represented by Different Land Use Capability Classes and Their Characteristics

Agricultural
Class Definition of Land Use Capability
Potential
Class I lands are; flat or near flat, deep, fertile and easily cultivated so that the conventional
agricultural methods can be applied; potential for water and soil erosion are minimal; have
good drainage; are not prone to flood damage exposure; suitable for hoe plants and other
Class I
intensively grown crops; Class I irrigated lands with low precipitation rates have slope values
less than 1% slope, loamy structure, good water holding capacity and medium level
permeability.
Class II lands are decent lands that can only be processed after taking some special
precautions. Their difference from Class I lands are one or more of the limiting factors such
Class II
Agricultural as slight slope, moderate exposure to erosion, moderately thick soil, exposure to occasional
lands moderate floods and a moderate level of moisture that can easily be isolated.
suitable for Class III lands are moderately good lands for hoe plants which can generate solid income
agricultural provided they are utilized with a good cropping system and proper agricultural methods.
Class III soil Moderate slope, increased erosion sensitivity, excessive moisture, exposed soil, presence of
cultivation stones, having a lot of sand and/or gravel, low water holding capacity and low yield are
properties of this type of land.
Class IV lands can be constantly utilized as meadows. Field crops can also be occasionally
grown. High levels of slope, bad soil characteristics, erosion and climate are the factors
limiting agricultural activities on these lands. Soils with low slopes and poor drainage are
Class IV also classified as Class IV lands. These soils are not subject to erosion, but they are
unsuitable for growing many agricultural products as they have a low yield and a tendency to
suddenly dry up in the spring. In semi-arid regions, cropping systems incorporating legumes
are generally not possible due to climate.
Agricultural Class V lands are reserved for long-life plantations such as meadows and forests as they
Class V lands not generally are unsuitable for cultivated plants. A few factors such as stony structure and
suitable for sogginess hinder cultivation here. The land is flat or near-flat. It is not subject to an

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 Agricultural
Class Definition of Land Use Capability
Potential
soil excessive amount of wind and water erosion. Grazing and tree logging activities can be
cultivation carried out on condition that a good soil cover is constantly maintained.
Class VI lands require moderate precautions even when they are used as forest or meadow
Class VI since they have quite a bit of slope and are subject to severe erosion. Exposed, soggy or
very dry conditions make this type of land unsuitable for cultivation.
Class VII lands have high slope, are stony and have been subject to violent erosion.
Exposed soils, dry and/or some unfavourable conditions and swamps can be classified as
Class VII
Class VII soil. These can be used as forest or meadow without showing due care. If the
vegetation on these soils diminishes, erosion can get quite violent.
Class VIII lands exhibit features that prevent them from being used as forest, meadow or
cultivated land. This type of land is habitat to wild life and can also be used for recreational
Non-arable
Class VIII purposes or as catchment basins for streams. These include lands containing marshes,
lands
swamps, deserts as well as areas of high mountainous regions, rocky lands or lands with
very deep craters.

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Figure IV.1. Great Soil Groups and Land Use Capability Classes for the Project Area

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 According to the former Turkish General Directorate for Rural Services database analysis
(1998), the great soil groups of WWTP area includes hydromorphic soils.

Hydromorphic soils are characterized by excessive soil moisture. Drainage is generally

impaired due to the profile characteristics that prevent normal water infiltration or the soil is located
in a sedimentary area. Large soil groups in this lower row have different characteristics. In the
mapping studies in our country, only High Mountain Meadow Soils were distinguished from them.
These soils, formed in the place where the forest strip ends, are formed due to various materials in
bad drainage and cold climate conditions. There is a dark layer on top and gray colored soil under
it. The natural vegetation on them is grass, sedge and flowering plants. Due to the cold climate,
their productivity is limited. They are mostly used for grazing in summer.

In bad drainage areas, also Hydromorphic Alluvial Soils have been distinguished in
mapping studies of Turkey. These soils are not suitable for agriculture in their current form. Some
of these soils have surface or near surface, groundwater for most of the year. In some soils, in wet
cool seasons, the water is close to the surface, but in late summer, it drops below 1m for a short
time. Some of the soils are exposed to floods. Topography is flat or concave. Surface drainage and
internal drainage are very bad or there is no drainage. Therefore, especially the lower levers are
wet. The rising and lowering of the groundwater causes successive oxidation and reduction in the
part of the soil above it. The result is bluish-gray reduction and reddish oxidation (oxidation, rust)
spots. Although the depth is high in these soils, the reduced floors limit the root zone (Former
Ministry of Agricultural and Rural Services, July 2008).

Erosion levels of the project area and its vicinity is given in Figure IV.2. According to the
erosion map, Project area which includes the WWTP, the sewerage network, discharge line and
pumping stations is affected with moderate to low level of erosion. Factors such as structure of soil,
bareness of its surface, slope of the land and wrong cultivation of the soil are causes that increase
erosion risk of the soil. Although at Mugla province forest areas are not confronted with destructive
erosion danger due to effects of geographic conditions, measures taken for erosion control are
continued.

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Figure IV.2 Erosion Levels of the Project Area and Its Vicinity

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 Field trips to the WWTP site showed that it is likely encounter contaminated soils at this
area. Therefore, in the scope of the baseline studies for the Project and to determine the existing
contamination status of soils located in the site, two samples were taken from the site by ENCON
Laboratory on July 7, 2020. Photos from site and sampling study are provided in Figure IV.3.
Sampling locations are shown in Figure IV.4 and measurement and analysis results are presented
in Table IV.2. The laboratory reports are presented in Annex-2 of this report.

Figure IV.3 Photos from the WWTP Site and Soil Sampling

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Figure IV.4 Soil Sampling Locations

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Table IV.2 Soil Sampling Measurement and Analysis Results

Soil Sampling Location-1 Soil Sampling Location-2

Parameter
(X:581996, Y:4099345) (X:582162 Y:4099205)
Antimony (mg/kg) 3.985 1.875
Arsenic (mg/kg) <0.5 0.839
Boron (mg/kg) 28.56 16.35
Cadmium (mg/kg) <0.5 <0.5
Chromium (mg/kg) 205.2 57.17
Copper (mg/kg) 31.85 17.52
Lead (mg/kg) 7.657 5.104
Mercury (mg/kg) <0.1 <0.1
Nickel (mg/kg) 223.1 61.93
Selenium (mg/kg) <0.5 <0.5
Silver (mg/kg) <0.5 <0.5
Tin (mg/kg) <10.0 <10.0
Total Petroleum Hydrocarbons (TPH) (mg/kg) 47.95 117.5
Zinc (mg/kg) 54.23 33.72
Total Organic Halogen (TOX) (mg/kg) 24.0 <20

The soil sampling and analysis study provides insight on existing soil quality in the WWTP
site. Soil sample locations 1 and 2 correspond to expansion area and sludge treatment units,
respectively. These locations are selected in order to provide baseline conditions regarding to 1 st
and 2nd stage areas of WWTP. Addition to that, soil sample location 2 is also selected to observe
any possible sludge related contamination. Although both samples were taken from the WWTP
site, the concentrations of some parameters significantly differ from each other, such as chromium,
nickel and TPH.

Chromium levels in uncontaminated soil vary in between 2 and 60 mg/kg and soils with
chromium levels up to 100 mg/kg are considered as appropriate for agricultural activities (Seven
v.d., 2018). Therefore, the chromium concentration observed in the sampling location-1 and its
comparison with the concentration observed in the second sampling location indicate a possible
contamination in the location-1. Nickel levels in soils vary widely depending on local geology and
anthropogenic inputs, but concentrations typically range between 4 and 80 ppm (Seven v.d., 2018).
In USA, the most commonly used soil cleanup standard for TPH is 100 mg/kg (Michelsen, 1993).
Therefore, the assessment made by evaluating chromium levels is also valid when considering
TPH and nickel levels in the WWTP site.

In addition, during the soil sampling study carried out in the site, visually no pollution
source that could cause permanent soil pollution was observed. Therefore, possible soil pollution at
the site might have resulted from a one-time source.

Geology

In Mugla Province, oldest lithologies are from the Precambrian time, which are gneiss,
micaschist, fine grained schist and quartzite, starting from the mountainous part north of Yatagan
and Milas Districts and spreading further north. Paleozoic age rocks; cemented sandstones,
marbles and schists cover these Precambrian units from the south. Marbles and crystalline
limestones, clayey schists, sandstones, conglomerates, siliceous schists and phyllites can be
observed in the Yatağan - Mugla trough are also Paleozoic aged.

Main units that can be observed in Mugla and its vicinity are; Menderes Massif, Lycia
Nappes and Beydaglari autochthon. Menderes Massif starts with Precambrian gneiss, and covered
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with micaschits and followed by metamorphics such as metaquartzite, phyllite, recrystallized
limestones. Towards to top, molasses and flysch sedimentary rocks are deposited. The Lycian
Nappes include nappe slices sediments from various times, and ophiolite and ophiolitic melange
slices formed in the Late Cretaceous period. Beydaglari autochthon is made up of various
formations. Carbonate sequence of the autochthon starts with rudist reef deposits and semi-pelagic
massive limestones with planktonic foraminifera fossils deposited on top of it. Later under
transgressive conditions, units with abundant plantonic foraminifera deposited in the basin.

The Mugla Region has undergone intense tectonic activites in Cenozoic and resulted with
uplift and subsidence which exposed Precambrian and Paleozoic units. Many lakes formed due to
this tectonism and some of them filled with Quaternary alluvium. General Geology Map of project
site that was studied is presented in Figure IV.5.

Aegean Sea is a tectonically active region as a result of subduction of African Plate

beneath to the Eastern Turkey. This subduction causes to extension in the region which occurs
mainly in North-South and Southwest - Northeast direction. An active fault system and grabben
formation are the results of the extension. Fault system consists of mainly East - West, Northeast -
Northwest trending faults that creates seismicity in Western Anatolia and Mugla Province is also
affected by this system. While different names can be given, there are four main fault zones in the
Mugla region which are; Karaova-Milas, Mugla-Yatagan, Bodrum- Oren -Ula and Burdur-Fethiye
Fault Zone.

Geology of the Study Area

Quaternary alluvium sediments cover the entire study area. The WWTP area was used as
the filling area of the excavation material that excavated during the construction of a thermal power
plant. It was determined that the filling thickness varies in the between 3.60 and 8.00 m, depending
on the previous topography of the site and time.

Alluvium is made up of lenticular layers of clay, sand and small gravel materials in different
proportions. Silt and fine sand dominated lithologies are gray, dark gray due to organic residues,
and they are intercalated laterally and vertically. However, due to the precipitation conditions, silt
and sandy pebbly materials under the filling (excavation material) vary between 1.80 - 4.60 m
thicknesses.

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Figure IV.5. General Geology Map

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Figure IV.6 General Geology Map Legend

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IV.1.3 Natural Hazards and Seismicity

Natural Hazards

According to “Spatial and Statistical Distribution of Disasters in Turkey Information

Inventory” prepared by former Ministry of Public Works and Settlement in 2008, general natural
disasters observed in Mugla are; landslides and rock falls. Landslides are observed in Fethiye and
Central districts and rock falls are observed in Central and Marmaris Districts.

When Milas District is examined by Distribution of Disaster Events maps prepared by

former Ministry of Public Works and Settlement, records of earthquake, landslide, rock fall and
flood can be observed on maps, however it is not expected to observe natural disasters such as
flooding, active and potential mass movements (landslides) in the study area and its immediate
surroundings.

As a result, no risks related to natural disasters including landslide, rock fall, avalanche,
etc. are identified at the Project Area which covers both the WWTP and the sewerage network to
be considered as part of "Law on Aids Implemented with Mitigations taken for Natural Disasters on
Public Life" numbered 7269.

Seismicity

According to Map of Earthquake Regions of Turkey issued by Official gazette No. 30364
dated 18.03.2018, ground acceleration of Mugla province, including Milas District is classified as
between 0.2-0.3 g. Therefore, earthquake risk has to be taken into consideration in the design of
the WWTP. Earthquake Regions Map is given in Figure IV.7 and Active Fault Map of Turkey is
given in Figure IV.8.

Aegean Sea Region is tectonically active, earthquakes with various magnitudes can
happen Mugla Province, and its vicinity, thus, earthquake risk must be taken to consideration for
the design of the WWTP.

Turkish Earthquake Zones Map was prepared by the T.R. Ministry of Public Works and
Settlement and came into effect with Council of Ministers’ Decision no 96/8109 dated 18.4.1986.
According to this map, Mugla region is in 1st degree earthquake region.

According to Council of Ministers decision dated March 18, 2018, published in the Official
Gazette No. 30364 is, "Turkey Earthquake Building Regulation" which entered into force on
January 1, 2019, construction works are going to comply with the principles of the regulation
rigorously.

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Figure IV.7. Seismicity Map of Turkey

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Figure IV.8. Active Fault Map of Turkey
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IV.1.4 Hydrogeology

Within scope of Wastewater Treatment Plant Project, GAB Engineering and Consultancy
Company (“GAB”) conducted field work, drilling and laboratory studies in order to collect
geological-geotechnical data and their evaluations.

According to “Oren (Milas/MUGLA) WWTP Ground Investigation and Evaluation Report”

prepared by “GAB” following results were obtained related to hydrogeology from the studies
mentioned above:

 There is no lake around the project site.

 There is a surface water stream (drainage ensured) with continuous flow and high
salinity which limits the north of the study area.
 Groundwater levels determined in the wells drilled within the scope of the Project, are
related to seasonal precipitation and spring waters. Static water levels encountered in
the wells drilled in the project area are given in Table IV.3 below.

Table IV.3 Groundwater Levels Determined in Boreholes (and trial pits)

Coordinates (ITRF-96)
Drilling Well/Trial Pit No. Depth (m) Groundwater Depth (m)
X Y
DW-1 30.45 581957,65 4100648,67 2.67
DW-2 15.00 581958,21 4100695,87 3.15
DW-3 15.00 581911,85 4100647,65 3.70
DW-4 15.00 581898,43 4100680,44 4.00
DW-5 15.00 581892,11 4100746,22 3.70
DW-6 15.00 581942,65 4100754,88 3.60
TP-1 2.00 581941,88 4100721,95 -
TP-2 3.00 581965,14 4100660,84 -
TP-3 3.00 581904,86 4100711,96 -

The drilling wells showed that groundwater levels are ranging from 2.67 to 4.00 m in the
WWTP area. Accordingly, the groundwater-related problems are expected in cases where the
foundation depth of the WWTP units to be built exceeds 2.60 m It should also be noted that
depending on seasonal conditions and precipitation, the groundwater level may change. The
locations of the boreholes are presented in Figure IV.9.

In addition, during the soil sampling study carried out in the site, visually no pollution
source that could cause permanent soil pollution was observed. Therefore, possible soil pollution at
the site might have resulted from a one-time source. Within this context, no significant impact on
groundwater is foreseen due to a possible soil contamination.

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Figure IV.9 Borehole Locations
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IV.1.5 Water Resources

Project area is located in West Mediterranean Water Basin. West Mediterranean Water
Basin incudes Gokova Bay and Akdaglar mountains of Mugla province. The catchment area of the
basin is approximately 21,000 km 2. There are 322,000 hectares of plain in the basin. 211,500
hectares of the plains are irrigable. The waters of the Western Mediterranean Basin are discharged
to the Mediterranean with Dalaman and Esen Creek. These creeks are also two most important
streams of the province.

Main water courses in the Mugla are Kargicik Creek Namnam Creek, Kargi Creek,
Karaculha Creek, Kocadere Creek, Saricay Creek. The water potentials of these water courses are
given in Table IV.4 and maps of the hydrology of the Project area and its vicinity is shown in Figure
IV.10.

Natural lakes in Mugla Province can be listed as Bafa Lake, Koycegiz Lake, Sulungur
Lake, and Kocagol Lake. The areas of this main lakes located in the Mugla are given in Table IV.5.

Table IV.4 Rivers of Mugla

Flow Rate
Total Length Length in Province
Name (m3/sec)
(km) Borders (km)
Min Max Average
Dalaman Creek 190 65 9.51 1050 43
Kargıcık Creek 17 17 0.35 22.8 1.33
Esen Creek 128 80 1.65 271 14.9
Namnam Creek 33 33 0.014 556 9.65
Dipsiz Creek - - 0.114 - 4.707
Sancay - - - 220 1.32
Kartaculha River - - 0.001 2.2 0.071
Batis River - - - 35.4 0.189
Source: West Mediterranean Basin Protection Action Plan

Table IV.5 Lakes in Mugla

Name Area (ha)

Bafa Lake 2519
Koycegiz Lake 5500
Sulungur Lake 260
Kocagol Lake 260
Source: West Mediterranean Basin Protection Action Plan

Mugla Province Dams and Ponds

Information on ponds and dams of Mugla province are presented in Table IV.6 and
locations are shown in Figure IV.11.

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Table IV.6 Dams of Mugla

Name Lake Capacity hm3 Purpose

41.1 Cooling water for Milas Kemerköy Thermal Power
Geyikli Dam
Plant, Drinking water for Bodrum Peninsula
Mumcular Dam 19.4 Drinking water, Irrigation
Marmaris Dam 30 Drinking water, Irrigation
Bayir Dam 7.20 Irrigation
Akkoprü Dam 384.5 Irrigation, Drinking water, Flood protection
Akgedik Dam 31 Irrigation
Kazan Dam 3 Irrigation
Source: West Mediterranean Basin Protection Action Plan

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Figure IV.10 Hydrology Map of the Project Area and Its Vicinity

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Figure IV.11 Dams in the Vicinity of the Project Area

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IV.1.6 Characteristics of Receiving Environment

The Oren WWTP that will be constructed within the scope of the Project will discharge its
effluent through 1,542 meter discharge line to Hanay Creek which is located at the western part of
the WWTP and reaching directly to the sea. The creek bed is made of concrete. While the creek
current is approximately 5 meters wide at the upstream of the discharge point, at the downstream it
reaches up to 45 meters width due to cooling water that is being discharged from Kemerköy
Thermal Power Plant. The photos of Hanay Creek are provided in Figure IV.12Hata! Başvuru
kaynağı bulunamadı..

Planned Discharge Location - Hanay Creek

Upstream of the Discharge Location

Downstream of the Discharge Location

Kemerköy Thermal Power Plant Cooling Water Discharge Located at the Downstream of the Planned Discharge
Location

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Figure IV.12 Photos of Receiving Environment – Hanay Creek

To constitute a baseline inventory and to determine the existing quality of the receiving
environment a sampling study was conducted on December 14 th, 2021. In the scope of the study,
total of three surface water samples were taken from the upstream (upstream surface water
sampling location) and downstream (downstream surface water sampling location) of the planned
discharge location, and downstream of the Kemerköy Thermal Power Plant where cooling water is
being discharged (downstream surface water sampling location-2). Sampling locations are
presented on a map given in Figure IV.13. Laboratory reports are provided in Annex-2 of this
report.

The measurement and analysis results of Hanay Creek are presented in Table IV.7
together with the water quality classification criteria stipulated in the Water Pollution Control
Regulation and Surface Water Quality Regulation (indicated with “*" sign).

As seen from the Table IV.7, upstream and downstream of the planned discharge location
of the Hanay Creek is classified as Class IV in terms of total coliform. Class III due to pH and total
phosphorus parameters. Other measured parameters are mostly belongs to Class I and Class II.
Although total coliform levels are high, low E.coli and fecal coliform levels indicate that high total
coliform levels might be caused by entry of soil or organic matter into the water. Therefore, it can
be concluded that there is no reach or continuous direct discharge of sewerage to Hanay Creek.

On the other hand, downstream of the Kemerköy Thermal Power Plant where cooling
water is being discharged is classified as Class IV in terms of TDS and conductivity. Other
measured parameters are belongs to Class I and Class II. Within this regard, high levels of TDS
and conductivity might resulted from wastewaters originated from fossil fuel extraction activities that
enter the surface water.

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Figure IV.13 Surface Water and Seawater Sampling Locations

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Table IV.7 Physicochemical and microbiological characteristics of Hanay Creek (December 2021)

Upstream of the Downstream of the Downstream of the Water Pollution Control Regulation and Surface Water Quality
Planned Discharge Planned Discharge Kemerköy Thermal Regulation
Parameters Unit Location Location Power Plant Water Quality Classes
(X: 580469, (X: 580505, (X: 580644,
I II III IV
Y: 4099008) Y: 4098924) Y: 4098750)
Temperature °C 15.3 15.0 15.7 25 25 30 >30
pH - 8.58 8.55 8.28 6.5-8.5 6.5-8.5 6.0-9.0 <6.0 - >9.0
Dissolved Oxygen mg/L 9.29 9.31 9.16 8 6 3 <3
Ammonium mg NH4+-N /L <0.02 <0.02 <0.02 0.2 1 2 >2
Nitrite mg NO2--N /L 0.01 0.0090 0.004 0.002 0.01 0.05 >0.05
Nitrate mg NO3--N /L 0.274 0.306 <0.1 5 10 20 >20
TP mg/L 0.24 0.18 0.10 0.02 0.16 0.65 >0.65
TDS mg/L 322 601 37859 500 1500 5000 >5000
COD mg/L 18.53 18.04 10.61 25 50 70 >70
BOD mg/L 4.80 6.00 3.16 4 8 20 >20
TKN mg/L 0.92 0.62 0.76 0.5 1.5 5 >5
Fecal Coliform CFU/100 mL 37 52 0 10 200 2000 >2000
Total Coliform CFU/100 mL >100000 >100000 210 100 20000 100000 >100000
Escherichia coli CFU/100 mL 0 0 0 - - - -
TSS mg/L 613 144 42 - - - -
Turbidity NTU 249 80.90 4.11 - - - -
Salinity ‰ 0.3 0.54 38 - - - -
Conductivity* µS/cm 628 1098 56300 <400 1000 3000 >3000

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IV.1.7 Protected Areas

In order to identify and evaluate the protected areas within the Project Area and its
immediate vicinity, desktop studies and literature researches were carried out by using the
databases of the relevant institutions within the scope of the Project. For this purpose, sensitive
area list available in Annex 5 of the EIA Regulation was used as reference. This list covers areas
that need to be protected in accordance with international conventions that Turkey is contracting
party and nationally declared protected areas. As can be seen from the evaluations in the following
paragraphs, the nearest protected area is Gokova Special Protected Environmental Area, located
about 1.1 km away from the site.

National Parks, Natural Parks, Natural Monuments, Nature Reserve Areas, Wildlife
Protection Areas, Wild Animal Raising Areas, Cultural Assets, Natural Assets, Protected Areas,
Areas under Protection in accordance with Bosporus Law, Biogenetic Reserve Sites, Biosphere
Reserves, Special Environmental Protection Areas and Protected Areas related to Drinking and
Utility Water Reserves are not located within Project Site.

Utilized main data sources within the scope of the desktop studies, but not limited to, are
listed below:

 Database of Ministry of Agricultural and Forestry (former Ministry of Forestry and Water
Affairs) (http://geodata.ormansu.gov.tr)
 Database of Ministry of Agricultural and Forestry, General Directorate of Nature
Conservation and National Parks (http://www.milliparklar.gov.tr)
 Database of Ministry of Culture and Tourism, General Directorate of Cultural Heritage
and Museums (http://kve.ulakbim.gov.tr)
 Map of Prohibited and Open Hunting Areas in Mugla Province for years 2018-2019

Protected Areas in accordance with National Legislation

Areas required to be protected in accordance with the legislation of the country defined
under Annex 5 (Sensitive Regions) of the EIA Regulation are listed in the following items and the
evaluations related to the indicated areas are presented therein.

National Parks, Nature Parks, Nature Monuments and Nature Conservation Areas defined
in Article 2 and 3 of the National Parks Law

There are 11 Natural Parks in Mugla Province. The closest one to the Project Area is
Cubucak Nature Park which is located 26.7 km southeast of the Project Area (covering both the
WWTP and the sewerage network).

There are 2 National Parks in Mugla Province. The closest one to the Project Area is
Marmaris National Park and it is located 27.9 km southeast of the Project Area.

Sirtlandagi Aleppo Pine Nature Conservation Area is located 27.0 km northwest of the
Project Area, at the Mugla-Milas Province Border.

There are 5 nature monuments in Mugla Province and the closest one is Olive Tree Nature
Monument and it is located 41.5 kilometers west of the Project Area.

The closest Biogenetic Reserve Area (Calabrian pine) is located 9.1 km away from the
Project area. The closest Seed Stand Type (Calabrian pine) is 9 km west of the Project area.

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 Wildlife Protection Areas, Wildlife Development Areas and Wild Animal Nestling Areas
determined in accordance with the Land Hunting Law

Map of prohibited and open hunting areas for years 2019-2020, prepared by Ministry of
Agricultural and Forestry, General Directorate of Nature Conservation and National Parks, is
presented in Figure IV.16. As could be seen from the map given in Figure IV.14, the closets wildlife
development area is Mugla-Koycegiz WDA that is located about 39.3 km southeast of the Project
Area. There are various hunting areas in the Province as well as prohibited hunting areas (see
Figure IV.16).

Areas defined as Cultural Property, Natural Property, Protected Site and Protected Area
according to 2863 numbered Law on Protection of Cultural and Natural Properties dated July 21
1983, Article 3, Paragraph 1, Clause (a) (Definitions); Sub-clauses 1, 2, 3 and 5; and areas
identified and registered in the same Law and amendments

WWTP site is located at a distance of 1613 m distance to Grade 1 archaeological protected

area, and 1310 m distance to Grade 3 archaeological protected area. Archaeological protected
areas around the Project Area are given in Figure IV.14 and Figure IV.15. In addition to those,
Oren’s city centre is declared as Grade 3 archaeological protected area considering its urban
texture.

Aquaculture Production and Breeding Sites within the scope of Aquaculture Law

Dalyan channels which is in Koycegiz district is completely prohibited hunting inland waters
in Mugla province.

Closest natural lake to the Project Area is Metruk Tuzlası Wetland, which is located
26.7 km northwest of the Project Area. The closest dam in operation to the Project Area is
Mumcular Dam, which is located about 17.9 km northwest of the Project Area.

Areas defined in Air Quality Assessment and Management Regulation

According to the 7th Article of Air Quality Assessment and Management Regulation, zones
and sub-zones for air quality identification are listed in Annex-1 of Memorandum 2013/37. With the
relevant circular, Turkey is divided into various regions and sub-regions. With this distinction, the
Ministry tried to determine the pollution profile of the provinces. The list in Annex-III of the circular is
divided into two groups according to the pollution profile of provinces substances: "high pollution
potential cities" and "low pollution potential cities". Pollution profiles of provinces were carried out
within the 2012-2013 winter season air quality data and air quality bulletins received from air quality
monitoring stations connected to the national air quality monitoring network. According to this, the
Mugla Province is in the list of "high pollution potential".

Areas identified and declared as Special Environmental Protection Areas by the Cabinet of
Ministers in accordance with the 9th Article of Environment Law

There are 5 special environmental protection areas in Mugla Province. Gokova Special
Environmental Protection Areas are the closest ones which are located about 1.1 km southeast of
the Project Area.

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 Areas defined in Pasture Law

The Project Area is not located in pasture land which is subjected to 4342 numbered
Pasture Law.

Areas designated in accordance with the Regulation of the Wetland Conservation

There are 7 wetland areas in Mugla Province. These are; Koyceyiz Lake, Bafa Lake,
Dalyan Wetland, Dalyan Wetland Ecosystem, Girdev Lake, Golkoy Lake, Gulluk Delta. There are
not any RAMSAR areas in Mugla Province.

Other Protected/Restricted Areas

In addition to presented information above, the areas listed below (also listed in Annex 5 of
the EIA Regulation) do not exist in the Project Area:

 Areas in accordance with the 17th, 18th, 19th and 20th Articles in the Water Pollution
Control Regulation
 Protected areas within the scope of Bosporus Law
 Forest Areas within the scope of Forest Law
 Areas subject to construction ban in accordance with the Coastal Law
 Areas designated in accordance with the Law on the Vaccination of Pesticides and
Improvement of Olive Cultivation
 Areas subjected to construction ban and areas of which their present characteristics
should be protected according to Approved Environment Plans (areas of which their
natural characteristics should be protected, biogenetic reserve areas, geothermal
areas, etc.)
 Agricultural Areas: Agricultural development areas, irrigated areas, potentially irrigated
areas, areas with land use capability class of I, II, III and IV, rainfed agricultural lands
classified as I and II and specific product plantations areas
 Wetlands: Natural or artificial, permanently or temporarily, standing water or flowing,
freshwater, hard or salt water, all the wetlands have importance for the organisms
especially for aquatic birds, sea depth range below six meters during the low tide,
swamp, reeds and turbaries and ecologically wetlands on their coastal sides
 Lakes, rivers, groundwater operation sites
 Areas important for endemic species that is endangered or potentially endangered or
important for scientific researches, biosphere reserve, biotopes, biogenetic reserve
areas, areas have unique characteristics for geologic and geomorphologic formations

In order to identify the cultural assets and protection areas in the vicinity of the Project
Area, the database of cultural heritage of Turkey (http://kve.ulakbim.gov.tr) has been queried. As
the Project Area is located about 39.6 km southwest of Mugla city center, cultural assets have been
searched in district basis (i.e. by considering Milas district of Mugla Province). The identified
immovable cultural assets that are vicinity of the project area are listed in Table IV.8.

Table IV.8 Inventory of Immovable Cultural Assets in Milas District

Asset Subtype Number in Milas District

Monuments 1
Archeological Protection Area 75
Military 6
Other 2
Religious 28
Natural Protection Area 8

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Asset Subtype Number in Milas District
Natural Assets 11
Industrial and Commercial 6
Folk Culture 206
Administrative 9
Ruins 24
Cultural 44
Graveyards 14
Civil Architecture Sample 40
Total 474

Protected Areas in accordance with International Conventions

Areas required to be protected in accordance with the international conventions to which

Turkey is a party and defined under Annex 5 (Sensitive Regions) of the EIA Regulation are listed in
the following items and the evaluations related to the indicated areas are presented therein.

Other Protected/Restricted Areas

There are no areas within the context of below mentioned protected/restricted areas;

 Mediterranean Monk Seal Living and Reproduction Areas, I. and II. Conservation
Zones defined in Important Sea Turtle Reproduction Areas from the protected areas in
accordance with the Convention for the Protection of the Wildlife and Habitats of
Europe (BERN Convention)
 Areas protected under the Convention on the Protection of the Mediterranean from
Pollution (Barcelona Convention)
 Areas designated as Special Protection Area in Turkey in accordance with the Protocol
on the Protection of Special Protection Areas in the Mediterranean
 Fields on the list of 100 Coastal Historic Sites with Joint Prevention in the
Mediterranean published by the selected United Nations Environment Program in
accordance with the Geneva Declaration
 The coastal areas that are the living and feeding environment of Native Species of
Hazardous Dangers to the Mediterranean included in 17 th Article of the Geneva
Declaration
 Cultural, historical and natural areas that are protected by the Ministry of Culture under
Cultural Heritage and Natural Heritage status according to the 1st and 2nd articles of
the Convention for the Protection of the World's Cultural and Natural Heritage
 Protected areas in accordance with the Convention for the Protection of Wetlands with
International Importance as Particularly Water Birds Living Environment (RAMSAR
Convention)
 European Landscape Contract

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Figure IV.14 Protected Areas around the Project Area

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Figure IV.15 Archaeological Protected Areas Around the Project Area

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Figure IV.16 Prohibited and Open Hunting Areas in Mugla (2019-2020)

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IV.1.8 Meteorology and Climatic Characteristics

The region has a climate characteristic composed of the synthesis of Aegean and
Mediterranean climates. It is warm and rainy in winter, and hot and dry in summer and has micro-
climate area features in peninsula, which is also valid for Oren. There is hardly any moisture in the
summer months. In the winter months, the humidity rate is quite low. It is hot and dry in the summer
months, quite warm and rainy in the winter months.

The primary factors affecting the air quality are the natural factors such as topography,
meteorology, natural vegetation, and the human factors such as population increase, unplanned
urbanization and industrialization. Domestic heating and industry take place near the top in ranking
of the basic factors affecting the air quality in Mugla province.

For the ESIA studies, comparing to the Milas meteorological observation station, which is
located inland and around 40 km away from the sea and consequently its direct effects, the
Marmaris meteorological observation station is considered to best represent the Project Area. The
data presented in the following subsections are retrieved from the State Meteorology Services
Marmaris Meteorological Observation Station.

Temperature Distribution

Marmaris Meteorology Station records show that annual mean temperature is 19.1 °C. The
highest temperature is recorded as 45ºC in August. The lowest temperature is recorded as –4.5ºC
in February. The graphical and tabular representation of the average, maximum, minimum
temperature records measured in this station are given in Figure IV.17 and Table IV.9, respectively

Figure IV.17 Average Temperature, Maximum Temperature and Minimum Temperature

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Table IV.9 Temperature Values

Average Maximum Average Minimum Average Maximum Minimum

Months Temperature Temperatures Temperatures Temperature Temperature
(°C) (°C) (°C) (°C) (°C)
January 11.3 15.1 8.3 23.1 -4
February 11.4 15.4 8.3 24 -4.5
March 13.3 17.6 9.8 28.7 -1.8
April 16.5 21.1 12.7 31.2 2.8
May 21 26.1 16.6 37.2 0.5
June 25.7 31.2 20.8 42.3 12.6
July 28.3 34.2 23.2 44.2 17.8
August 28.1 34.1 23.3 45 18.5
September 24.6 30.4 20.4 42.6 10.8
October 20.3 25.6 16.8 38.9 7.8
November 16.2 20.5 13 31 -4
December 13 16.6 10 24.5 -1.5
Annual 19.1 24.0 15.3 34.4 4.6

Precipitation Distribution

Marmaris Meteorology Station records show that annual average total precipitation is 59,8
mm. Total precipitation is maximum in September with 232 mm and minimum in July with 5 mm.
Average monthly precipitation and daily maximum precipitation amounts are given graphically in
Figure IV.18 and tabulated in Table IV.10.

Figure IV.18 Average Monthly Precipitation and Maximum Precipitation Amounts

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Table IV.10 Average Monthly Precipitation and Maximum Precipitation Amounts

Months Average Total Precipitation (mm) Maximum Precipitation (mm)

January 146.6 88.1
February 118.1 95.1
March 73.7 61
April 39.7 42.4
May 16.1 39
June 4.7 39.2
July 0.3 5
August 0.7 15.1
September 15.9 231.6
October 47 102.2
November 94.5 124.5
December 160.4 86.6
Annual 59.8 77.5

Humidity Distribution

Marmaris Meteorology Station records show that average annual humidity is 60.5%.
Minimum monthly relative humidity is recorded in July (49.8%) and maximum relative humidity is
recorded in December (67.6%). The monthly average and minimum relative humidity values are
given graphically in Figure IV.19 and in tabular format in Table IV.11.

Figure IV.19 Average and Minimum Relative Humidity Values

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Table IV.11 Average and Minimum Relative Humidity Values

Months Average Humidity (%) Minimum Humidity (%)

January 66.3 5
February 65.9 8
March 64.3 4
April 63 2
May 60.2 3
June 52.8 4
July 49.8 5
August 52.2 1
September 56.4 5
October 62.1 10
November 65.9 7
December 67.6 8

Pressure Distribution

Annual mean local pressure measured in Marmaris Meteorology Station is 1010.4 hPa.
During the whole observation period, minimum pressure is recorded as 979.10 hPa in January and
maximum pressure is recorded as 1028,90 hPa in February. Monthly average, maximum and
minimum pressure values recorded in the station are provided in Figure IV.20 and Table IV.12.

Figure IV.20 Monthly Average, Maximum and Minimum Pressure Values

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Table IV.12 Monthly Average, Maximum and Minimum Pressure Values

Months Average Temperature (hPa) Maximum Pressure (hPa) Minimum Pressure (hPa)

January 1013.70 1030.00 979.10

February 1012.60 1028.90 985.00
March 1011.60 1027.60 991.40
April 1010.00 1026.30 992.40
May 1009.60 1020.00 997.40
June 1007.70 1019.20 995.80
July 1004.80 1013.00 997.40
August 1005.30 1014.70 998.60
September 1009.20 1019.00 1000.00
October 1012.40 1022.60 998.50
November 1014.10 1028.00 998.80
December 1013.90 1028.30 992.80

Annual 1010.4 1023.13 993.93

Foggy, Snowy, Hail, Frosty and Stormy Days Distribution

Marmaris Meteorology Station records show that the number of annual average snowy
days is 2.8 and annual average number of days with snow blanket is 0.7. The snow cover depth is
recorded only on January as 3 cm. Monthly distribution of average foggy, snowy, snow covered,
hail, frosty and stormy days are given in Table IV.13.

Table IV.13 Monthly Average Foggy, Snowy, Snow Covered, Hail, Frosty and Stormy Days Distribution

Number of Average Average Average Average

Number of
Months Snow Covered Number of Number of Hail Number of Number of
Snowy Days
Days Foggy Days Days Frosty Days Stormy Days
January 0.1 0 0.5 0.5 4.1
February 0.1 0.4 0.4 3.5
March 0.1 0.3 0.3 2.3
April 0.2 0.2 1.7
May 0 0 1.6
June 0 0.7
July 0.2
August 0.1
September 0.8
October 0 0.1 2.5
November 0 0.1 0.1 3.1
December 2.5 0.6 0.3 4.4
Annual 2.8 0.7 0 1.9 1.4 25

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 Wind Distribution

The annual and seasonal distribution of wind blow numbers and wind speeds recorded in
Marmaris Meteorological Station are graphically represented in Figure IV.21, Figure IV.22 and
Figure IV.23. According to annual wind blow numbers, 1st dominant wind direction is NNE (north-
northeast). 2nd dominant wind direction is N (north). 3rd dominant wind direction is NE (northeast)
and 4th dominant wind direction is SSE (south-southeast).

Figure IV.21 Annual Wind Diagram of Wind Blow Numbers and Average Wind Speeds

Figure IV.22 Seasonal Wind Diagram of Wind Blow Numbers

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Figure IV.23 Seasonal Wind Diagram of Average Wind Speeds (m/sec)

The annual average wind speed is 3.2 m/sec and monthly average wind speeds are
presented for each month in Table IV.14.

Table IV.14 Monthly Average Wind Speeds

Months Jan. Feb. Mar. Apr. May June July Aug. Sept. Oct. Nov. Dec.
Average Wind
3.6 3.8 3.4 3 2.7 3.1 3.6 3.2 2.8 2.6 3 3.6
Speed (m/sec)

Marmaris Meteorology Stations records show that the direction of the highest wind speed is
south (S) with 41.7 m/sec. The number of annual average stormy days is 2.8 and number of annual
average strong windy days is 8. Maximum wind speeds, directions and average stormy and strong
windy day numbers are provided in Table IV.15.

Table IV.15 Maximum Wind Speeds and Directions, Average Numbers of Stormy and Windy Days (1960-2015)

Direction of Maximum Maximum Wind Speed Average Number of Average Number of

Months
Wind (m/sec) Stormy Days Strong Windy Days
January S 41.7 4.8 9.1
February S 38.2 5 8.4
March SSE 32.2 4.2 8.2
April SSE 39.2 2.8 7.4
May SE 26.4 1.1 6.4
June SE 27 1.6 7.8
July N 26 2.1 10.4
August NNE 28 1.6 8.5
September NNE 27.5 1.1 6.4

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 Direction of Maximum Maximum Wind Speed Average Number of Average Number of
Months
Wind (m/sec) Stormy Days Strong Windy Days
October SSE 34.1 1.4 6.6
November S 35.7 2.8 7.6
December SW 37.3 4.9 9.5

IV.1.9 Noise Level

Environmental noise in Turkey is regulated by the Regulation on the Assessment and

Management of Environmental Noise (RAMEN) which is published on 04.06.2010 in Official
Gazette No: 27601. This regulation is intended to ensure that precautions are taken to prevent
disturbance to peace and tranquility, and to ensure the physical and mental health of persons
potentially exposed to environmental noise. For this purpose, the regulation sets out requirements
regarding noise mapping, acoustic reporting, environmental noise assessment for determination of
noise exposure levels and preparation and application of action plans to prevent or mitigate
negative impacts of noise exposure on human being and environment.

The operation noise limit values defined in the RAMEN Annex VII Table 4 are presented in
Table IV.16.

Table IV.16. Environmental Noise Limits for Industrial Plants

Lday Levening Lnight

Areas
(dBA) (dBA) (dBA)
Educational, cultural and health facilities as noise
sensitive areas, and places densely populated with 60 55 50
summer houses and camp grounds
Areas densely populated with residences among the
areas containing commercial structures and noise 65 60 55
sensitive structures all together
Areas with dense work places among the areas
containing commercial structures and noise sensitive 68 63 58
structures all together
Industrial Areas 70 65 60

For construction activities noise limit values are defined in Table 5 Appendix VII of RAMEN
and presented in Table IV.17.

Table IV.17. Environmental Noise Limits for Construction

Type of Activity (Construction, Demolition and Repair) Lday (dBA)

Building 70
Road 75
Other Sources 70

WBG Standards

Noise limit levels are described under, WBG Environmental, Health and Safety (EHS)
Guidelines, General EHS Guidelines: Environmental Noise. The noise limit values are based on
World Health Organization Guidelines for Community Noise. Noise levels defined by WBG EHS
Guidelines are presented in Table IV.18. WBG EHS Guidelines requires that noise impacts should
not exceed the levels presented in Table IV.21, or result in a maximum increase in background
noise levels of 3 dB at the nearest receptor location off-site.

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Table IV.18. Noise Level Guidelines of WBG

One Hour LAeq (dBA)

Receptor
Daytime 07:00 – 22:00 Nighttime 22:00 – 07:00
Residential, institutional, educational 55 45
Industrial, commercial 70 70

Noise during the construction phase will be mainly generated due to the activities of
construction machinery and equipment. To determine the impact significance, background noise
levels should be known. Therefore, a noise level measurement study was conducted to determine
background levels around the WWTP site. Since the sewerage system component of the Project
will be constructed in the city centre, where there are numerous noise sources, no measurement
was conducted.

Two locations were selected as sensitive receptors and these are presented on Figure
IV.24 below. Noise Measurement Location-1 (NML-1) is the nearest sensitive receptor to the
WWTP site, which is Sitki Kocman University Fisheries Research and Development Centre. NML-2
represents background noise levels at summer housings located at 180 m east of the WWTP site.
The background noise measurements were carried out at these points on July 6th and 7th, 2020 by
ENCON Laboratory and the results are presented in Table IV.19. Assessment of noise impacts of
the Project is provided in Section V.4.5.

Table IV.19. Background Noise Level Measurement Results

Measurement Results
Measurement
(Leq) (dBA)
Coordinates
Measurement Type of the (UTMED50-Z35) WBG General EHS
RAMEN Periods
Points Receptor Guideline Periods
Daytime Evening Night Daytime Nighttime
X Y
(07.00-19.00) (19.00-23.00) (23.00-07.00) (07.00-22.00) (22.00-07.00)
NML-1* Educational 581954 4099159 53.8 53.1 50.2 53.7 50.6
NML-2 Residential 582120 4099020 54.0 47.7 47.6 53.1 47.6

As it is seen from Table IV.19, background noise levels were very close to each other at
NML-1 and NML-2 during the periods determined by the Regulation on the Assessment and
Management of Environmental Noise (RAMEN) and WBG General EHS Guidelines: Environmental
Noise. However, nighttime measurements are already above the limits that are defined in WBG
General EHS Guidelines: Environmental Noise. The high measurement results might be related
with traffic. Based on these measurement results, background noise levels should not be exceeded
more than 3 dB at the nearest receptor location off-site during the construction and operation
phases of the Project.

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Figure IV.24 Noise Measurement Locations

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IV.1.10 Air Quality

In Mugla, there are two air quality monitoring stations that belong to MoEUCC. One of
these stations is located at Yatagan, while the other one is located at the Mugla city centre. There
is no monitoring station in Oren and considering its population density and industries, it is
anticipated that there should not be much pollution stress on air environment in Oren. However, it
should be noted that SOx, NOx and CO2 emissions of Kemerköy Thermal Power Plant located in
Oren contributes to air pollution in the region.

Mugla’s air pollution data taken from Musluhittin monitoring station, which only monitors
PM10 and SO2 parameters, is presented in the Table IV.20 below. The data belongs to period
between January 2019 and July 2020. As seen from the table, while daily average PM10
concentration is a little higher than the regulatory limit value, SO 2 concentration is in compliance
with the Regulation on the Assessment and Management of Air Quality limit value.

Table IV.20 Air Quality of Mugla

PM10 SO2
Measurement Location Daily Average Limit Value Hourly Average Limit Value
(µg/m³) (µg/m³) (µg/m³) (µg/m³)

Mugla-Musluhittin 51.82 50 20.88 350

There is no active air quality monitoring stations in the local level. Therefore, to constitute a
baseline inventory and to determine air quality in the Project area; 24-hour PM10 and PM2.5
measurements were conducted at the nearest sensitive receptor, which is 50 m to the WWTP site.
The measurement location is same with the NML-1 presented in Figure IV.24. The measurement
results are presented in Table IV.21.

Table IV.21 PM10 and PM2.5 measurement results (July 2020)

Result (µg/Nm3)
Coordinates of the Type of the
Measurement Location Sensitive Receptor PM10 PM2.5

581996/4099345 Educational* 32.74 <6.0

* Mugla Sitki Kocman University Fisheries Research and Development Centre

According to the Industrial Air Pollution Control Regulation, PM10 values should not exceed
50 µg /Nm³ more than 35 times in a year. On the other hand, according to WBG General EHS
Guidelines: Air Emissions and Ambient Air Quality PM10 and PM2.5 values should not exceed 50 µg
/Nm³ and 25 µg /Nm³, respectively. Therefore, PM10 and PM2.5 baseline measurement results
satisfy both national and WBG General EHS Guidelines ambient air quality limit values.

IV.2 Ecology and Biodiversity

For this Report, biological environment was investigated which included habitat structures
of the Project area, protected areas and key biodiversity areas (KBA). For this purpose, both
desktop studies and field survey were carried out. The related literature and previous studies have
been reviewed and the general biological characteristics of the region have been revealed. Also a
field visit was conducted with an expert biologist on July 7th, 2020.

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 Definition of Study Area

The project area is located within the borders of Oren neighbourhood of Milas district in
Mugla Province. As mentioned in the previous sections, the project consists of two components,
the sewerage line and the WWTP. Both components have heights ranging from 0 to 10 m altitudes
above sea level.

The Mediterranean climate is dominant in the project area which located in the Aegean
region. The average annual temperature is around 20°C. In July and August, this temperature
increases to 32 -44°C. Although the temperature does not fall below 10°C in winter, rainy and warm
weather is dominant in winter.

Since the project area is located in the Aegean region, it is located entirely in the
Mediterranean Plant Geography region and it has the characteristics of the Mediterranean climate.
However, since the regions where the activities in the project area are located close to the
settlements, the anthropogenic effect is quite high.

The sewerage network covers a very large area within the Oren neighbourhood. However,
due to the nature of the Project, the sewerage network will be constructed in residential areas while
sewerage network and discharge line will be installed mainly on roadsides. Therefore, the sewer
lines and discharge line will be built on areas that do not have high value in terms of biological
diversity.

The WWTP part of the project covers an area of 8,278.11 m2. The area where WWTP will
be built is located 400 m from the sea. The closest settlement to the planned WWTP is 175 m
away. The WWTP is generally surrounded by distributed trees and scrubs, herbaceous species
and riparian vegetation. Also, there is a dry dock construction site on the west of the project area.
For this reason, rubbles of construction and uncontrolled site entry of work machines has been
partially destroyed the area. Some photographs of the WWTP area are given in Figure IV.25.

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Figure IV.25 Some Photographs of the Planned WWTP Area

Standards and Guidelines

Ecology and Biodiversity part of the Project is guided by the requirements of the World
Bank’s Operational Policy (OP) 4.04 in order to manage environmental risks and impacts on
ecology and biodiversity. (OP) 4.04 aims that the protection of critical natural habitats and to be
taken mitigation measure to minimizing habitat loss. According to the (OP) 4.04 this issue is
explained as “…If the environmental assessment indicates that a project would significantly convert
or degrade natural habitats, the project includes mitigation measures acceptable to the Bank. Such
mitigation measures include, as appropriate, minimizing habitat loss (e.g., strategic habitat
retention and post-development restoration) and establishing and maintaining an ecologically
similar protected area…”. As appropriate, the project will take the necessary measures and

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implement commitments. Also Annex A of the (OP) 4.04 straightens out to determine the critical
and/or natural habitats.

In the line with the (OP) 4.04, assessments of the baseline conditions and determined
significance criteria for impacts assessments were detailed according to IFC Performance
Standards 6 (PS6). IFC PS6 covers areas of biodiversity conservation, ecosystem services and
sustainable management of living resources, which are all fundamental to achieve sustainable
development. The objectives of PS6 are outlined as follows:

 To protect and conserve biodiversity;

 To maintain the benefits from ecosystem services; and
 To promote the sustainable management of living natural resources through the
adoption of practices that integrates conservation needs and development priorities.

The requirements of PS6 are applied to projects: (i) located in modified, natural, and critical
habitats; (ii) that potentially impact on or are dependent on ecosystem services over which the
client has direct management control or significant influence; or (iii) that include the production of
living natural resources (e.g. agriculture, animal husbandry, fisheries and forestry) based on the
risks and impacts identification process.

Legal and Regulatory Framework

Bern Convention

Bern Convention was put forward in 1982 in order to protect the European wildlife and
natural habitats. Species to be protected according to the Bern Convention are listed in four
appendices, which are presented in Table IV.22 with their explanations:

Table IV.22 Annexes to the Bern Convention

Annex Explanation
I Strictly protected flora species
II Strictly protected fauna species
III Protected fauna species
IV Prohibited means and methods of killing, capture and other forms of exploitation

The Convention aims at conserving and promoting biodiversity, developing national

policies for the conservation of wild flora and fauna and their natural habitats, protection of the wild
flora and fauna from the planned development and pollution, developing trainings for protection
practices, promoting and coordinating the researches made regarding this subject. It has been
signed by 26 member states of the European Council (as well as Turkey) with the aim of
conserving the wild life in Europe. Species that are not included within the appendices of the
Convention are those that do not require any special protection. Species are not listed individually
but instead are protected due to the habitat protection approach of the Bern Convention. All of the
nations, which are party to the BERN Convention, have signed the Convention on Biological
Diversity as well. Parties of this convention are responsible from ensuring sustainable use of
resources in line with their national development trends and conserving the threatened species.

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 CITES

CITES stands for the Convention on International Trade in Endangered Species of Wild
Flora and Fauna. It is an international agreement that has been ratified by governments of 164
states (including Turkey), whose aim is to ensure that international trade in specimens of wild
animals and plants does not threaten their survival. The principles of CITES are based on
sustainability of the trade in order to safeguard ecological resources (live animals and plants, vast
array of wildlife products derived from them, including food products, exotic leather goods, etc.).
CITES was signed in 1973 and entered in force on July 1, 1975. Turkey ratified the Convention in
1996. Categories and species included in CITES are listed in three different appendices based on
their protection statuses. These appendices and their explanations are given in Table IV.23.

Table IV.23 Appendices to CITES

Appendix Explanation
covers the species, which are under the threat of extinction. Trade in the specimens of these
I
species is not allowed except extraordinary circumstances
includes species, which are not threatened with extinction, but trade in specimens is restricted
II
in order to prevent utilization incompatible with their survival
for which other parties of CITES is applied for assistance in controlling trade and which are
III
conserved at least in one country.

The International Union for Conservation of Nature (IUCN) publishes its Red List of
Threatened Species, which intends to draw attention to species whose populations are at risk or
under threat. The IUCN places a species on the Red List only after studying its population and the
reasons for its decline. Some countries pay greater attention to IUCN-listed species than Bern-
listed species, since the Red List relies on more research. The 1994 (ver.2.3) and 2001 (ver.3.1)
categories and criteria of the IUCN Red List are presented below in Table IV.24. The Red List
Categories and Criteria had been re-formed through evaluating more open and easier to use
systems. As a result the IUCN Commission made revisions in February 2000, and the new set of
categories and criteria were published in 2001.

Table IV.24 IUCN Red List Categories and Criteria

IUCN Red List Categories and Criteria IUCN Red List Categories and Criteria
1994 (ver. 2.3) 2012 (ver. 4.0)
EX Extinct EX Extinct
EW Extinct in the Wild EW Extinct in the Wild
CR Critically Endangered CR Critically Endangered
EN Endangered EN Endangered
VU Vulnerable VU Vulnerable
LR Lower Risk
cd : conservation dependent NT Near Threatened
nt : near threatened LC Least Concern
lc : least concern
DD Data Deficient DD Data Deficient
NE Not Evaluated NE Not Evaluated

Demirsoy, A. (2002). General and Turkish Zoogeography (RDB)

This reference prepared by Prof. Dr. Ali Demirsoy and published by the former Ministry of
Environment and Forestry lists the threat/conservation statuses for vertebrates in Turkey as
presented in Table IV.25.

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Table IV.25 National Threat Statuses for Vertebrates

Category Definition
Ex Extinct
E Endangered
R Rare species
V Vulnerable species
I Status of taxon is unknown
K The category of taxon is unknown due to data deficiency
O Species that are not threatened
nt Widespread, abundant species that are not threatened

Kiziroglu, I. (2009). The Pocket Book for Birds of Turkiye (RDB for Birds)

Birds of the biodiversity study area were also assessed according to national threat
categories defined in The Pocket Book of Birds of Turkey (Kiziroglu, 2009) within the categories
defined in Table IV.26.

Table IV.26 National Threat Categories for Bird Species

Category A
A.1.2 (CR) Critically endangered and breeding species in Turkey
A.2 (EN) Endangered and breeding species in Turkey
A.3 (VU) Vulnerable and breeding species in Turkey
A.3.1 (D) Declining, vulnerable and breeding species in Turkey
Near threatened, breeding species do not face to risk now but are likely to qualify for threatened
A.4 (NT)
category in the near future in Turkey
A.5 (LC) Least concern, breeding species that are widespread in Turkey
A.6 (DD) Data deficient, breeding species on which there is deficient information in Turkey
A.7 (NE) Not evaluated, Breeding species which have not been evaluated in Turkey
Category B
B.1.2 (CR) Critically endangered and non-breeding species in Turkey
B.2 (EN) Endangered and non-breeding species in Turkey
B.3 (VU) Vulnerable and non-breeding species in Turkey
B.3.1 (D) Declining, vulnerable and non-breeding species in Turkey
Near threatened, non-breeding species do not face to risk now but are likely to qualify for threatened
B.4 (NT)
category in the near future in Turkey
B.5 (LC) Least Concern, non-breeding species that are widespread in Turkey
B.6 (DD) Data deficient, non-breeding species on which there is deficient information in Turkey
B.7 (NE) Not Evaluated, non-breeding species which have not been evaluated in Turkey

Protected Areas and Internationally Recognized Areas within the Region of the
Project Area

The map showing the national protected areas and internationally recognized areas in the
project area or its immediate surroundings can be shown in
Figure IV.28. International recognized areas investigated as KBA (Key Biodiversity Area),
IBA (Important Bird Area) and AZE (the Alliance for Zero Extinction).

Turkey’s KBAs have been identified on a national scale by Doga Dernegi (the Nature
Society of Turkey) in collaboration with the Ministry of Agriculture and Forestry (former Ministry of
Environment and Forestry), Birdlife International and Royal Society for the Protection of Birds.

Important Bird Areas were identified by a database prepared by Birdlife International and
Royal Society for the Protection of Birds.
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 The Alliance for Zero Extinction (AZE), established in 2004 and comprising 88 biodiversity
conservation NGOs, is dedicated to the identification and safeguard of all KBAs holding effectively
the entire global population of at least one Critically Endangered or Endangered species. A total of
587 AZE sites have been identified. (Brooks T M., et al.,2016) AZE members work to rebuild
populations of endangered and critically endangered species through efforts to eliminate human
threats such as commercial exploitation, disease and the introduction of invasive species.

Effective conservation of all AZEs is by definition essential to achieve the CBD target of
preventing extinctions of known threatened species (all such sites are under threat and the loss of
any one of them in the short- to medium-term would almost certainly result in global extinction of at
least one species)

AZEs hold ≥95% of the global population of any Critically Endangered or Endangered
species, and hence are locations at which species extinctions are imminent unless appropriately
safeguarded (i.e. protected or managed sustainably in ways consistent with the persistence of
populations of target species); 588 such sites have been identified for 919 highly threatened
vertebrate and conifer species. Terrestrial AZE sites have been identified globally for all mammals,
birds, amphibians, selected reptile clades (Testudines, Crocodylia and Iguanidae) and conifers
(Butchart, S. H. M. et al., 2012)

AZEs are sites meeting three criteria:

 endangerment (supporting at least one Endangered or Critically Endangered species,

as listed on the IUCN Red List);
 irreplaceability (holding the sole or overwhelmingly significant (≥95%) known
population of the target species, for at least one life history segment);
 discreteness (having a definable boundary within which the character of habitats,
biological communities, and/or management issues have more in common with each
other than they do with those in adjacent areas)

One suggestion for safeguarding AZE sites is to begin by considering two levels of
protection: any protection and “targeted” protection. A second and more long-term goal can be to
work towards “targeted” protection for all AZE sites, with “targeted” defined on a case-by-case
basis centered on the threats to and ownership of each site and the AZE species’ management
needs.

 Level 1: Any protection: Any level of official protection for unprotected or partially-
protected AZE sites. All unprotected or partially-protected AZE sites receive a basic
level of official protection
 Level 2: Targeted protection: Protection based on threats to the sites on a case-by-
case basis centered on the threats to and ownership of each site. Some sites are at
risk due to specific threats, such as invasive species, trafficking, or logging. Working to
reduce or eliminate these threats will be key to the long-term persistence of such sites.

As can be seen on the map, the nearest national protected area to the sewerage system
part of the Project Gokova Specieal Protected Area with a distance of 1.1 km. In addition, the
Datca and Bozburun Peninsula KBA and IBA border is 20 m away from the sewerage system part
of the Project.

Gokova Special Environmental Protection Area covers a large area of 57,690 hectares.
The area is home to 34 species that are protected by national and international conventions.
However, it is seen that these species are distributed in the southern coasts of Gokova Bay,
especially in the region between “Yedi Islands and Tuzla Bay”, and they do not intensively use the
area where the Project Area is located. Akbuk Bay and around (black dot in Figure IV.26)
southeast of Hanay Creek, are inhabited by Epinephelus marginatus and Sciaena umbra species.
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Akbuk Bay is about 17 km away from Hanay Creek, and the fish species protected in the area are
mobile aquatic fauna species.

Figure IV.26 The Protection Area and Number of Protected Species

Anadromous fish species are fish that complete their growth and development in the seas
and go to inland waters to spawn when they reach reproductive maturity. In other words, it defines
fish species that migrate from marine waters to inland waters. No fish species protected within the
scope of the Gökova Special Environmental Protection Area enter the Hanay Creek by
anadromous migration.

The region has freshwater inlets due to its natural structure. This situation increases the
productivity of the coastal ecosystem and causes many species to prefer this area as a spawning
area. However, as shown from the map below, the region where the project area is located is not
among the dense areas used by the species for spawning.

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Figure IV.27 The Protection Area and Spawning-Brood Development Areas

Hanay Creek is an anthropogenic creek, which currently has a concrete creek bed and
from which the cooling water of the thermal power plant is discharged. The water to be treated and
discharged at the wastewater treatment plant is not expected to adversely affect the aquatic
environment in the Gökova SEPA, where the creek flows.

As a result, it has been determined that sensitive species in Gokova Special Environmental
Protection Area do not use the Hanay Creek for breeding or spawning purposes. According to that,
the Gokova Special Environmental Protected Area is not included in the Project’s Area of Influence.

In Turkey, there are three AZE sites determined. The closest one to the Project area is
Gulluk Mountain with 210 km away. In addition, the other closest AZE site is Nissos Saria kai Voria
Karpathos where is a Greece Island located in 139 km southwest of the Project area. Both AZE
sites are quite far away from the Project area and these sites will not affected from the Project
activities.

These areas are wild and natural areas with high biodiversity value. A large part of the
project area will be built in the city. The area to be WWTP is relatively poor in terms of biodiversity.
Therefore, the project area is not considered to reflect the characteristics of the protected areas in
the environment.

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Figure IV.28. International and National Designed or Recognized Areas with and around the Project Area

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 Vegetation and Habitat Types of the Terrestrial Ecosystem

Project area is located in C1 grid in grid square system of flora of Turkey and
phytogeographically speaking, is located in a transition zone of Mediterranean zone. Climate
feature of the region has the Mediterranean climate characteristic due to the project area is located
in the Aegean region (see Figure IV.29).

The grid square system is a method used to understand spatial distributions of species.
According to the system, distributions of endemic species of Turkey are shown in Figure IV.30.
When the distribution of the endemics taxa in Turkey is analysed as the grid system, it was
determined that C1 square area where the project is located, below an average of Turkey with
0.9% (Turk Cografya Journey 69 (2017) 109-120).

In addition, planned WWTP area covers 8278.11 m2. Settlements start about 175 m from
the project area and the anthropogenic effect is dominant therefore vegetation of close vicinity of
the area has poor vegetation. Randomly distributed trees and scrubs and ruderal areas are
dominant in the area. Also, there is riparian vegetation near the area. It is possible to examine the
planned WWTP area as two types of vegetation in general:

a) Riparian vegetation: The dominant plants of this vegetation that grows in streams in the
research area are plants like Platanus orientalis, Ulmus minor, Nerium oleander, Vitex agnus-
castus, Rubus sanctus, Bolboschoenus maritimus, Juncus heldreichianus, Ononis spinosa, Melisa
officinalis. All of these plants have more or less water demand.

b) Ruderal vegetation: This type of vegetation grows mostly on field edges and roadsides
in the study area. Dominant shrub species like Rosa canina, Prunus divaricata ssp. divaricata,
Quercus coccifera, Paliurus spina-christi, Crataegus monogyna ssp. azarella and Pyrus
amygdaliformis var. amygdaliformis. In addition, Hirschfeldia incana, Rapistrum rugosum,
Sisymbrium officinale, Hypericum triquetrifolium, Daucus carota, Notobasis syriaca, Carlina
corymbosa are widely available as herbaceous plants.

Habitat Types of the Project Area

All components of the Project cover poor vegetation features and modified. There are
seven habitat types in the sewerage line and WWTP area according to EUNIS Habitat
Classification. None of these habitats are critical or sensitive habitats. Flora species of these
habitats are widespread and adapted to human pressure. Habitat types of the Project area are
described as follow:

G1.3: Mediterranean Stream Trees: This habitat is spread along stream near the project
area. The dominant plants of this habitat are Platanus orientalis, Nerium oleander, Vitex agnus-
castus and Ulmus minor.

F5.5: Warm Mediterranean Shrubs: It represents maquis in the form of a green bush in the
project area. Its characteristic species are Quercus coccifera, Quercus infectoria, Olea europaea
and Phillyrea latifolia.

I1.2: Agricultural areas and cultured areas: Represents olive groves and dry agricultural
areas within the project area.

E1.6: Mediterranean subnitrophilous grass communities: These habitats which located in

field and road sides have mostly annual cheeky plant species.

J4.2: Disused road, rail and other constructed hard-surfaced areas: Road surfaces and car
parks, together with the immediate highly-disturbed environment adjacent to roads, which may
consist of roadside banks or verges.

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 J1.4: Urban and suburban industrial and commercial sites still in active use: Buildings with
public access, such as hospitals, schools, churches, cinemas, government buildings, shopping
complexes and other places of public resort.

J 2.1: Scattered residential buildings: Houses or flats in areas where buildings, roads and
other impermeable surfaces are at a low density.

a. Project Location in the Grid Square System (Davis 1988)

b. Phytogeographical Regions Map in Turkey (www.ktü.edu.tr)

Figure IV.29. Bioecological Location of the Project

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Figure IV.30. Distribution of 9677 Endemic Taxa Locations in Turkey Flora According to Region,Subregion and Grid
System (Turk Cografya Journey 69 (2017) 109-120)

Flora Species

The flora vegetation of the project area is very weak. The planned sewerage line,
discharge line and wastewater treatment plant area consists of unnatural or semi-natural areas. For
this reason, possible flora species of the areas consist of herbaceous plants and widely distributed
species. According to field studies and literature reviews, the flora types of the Project area are
presented in the Table IV.27.

According to Table IV.27 there are not any endemic and/or sensitive flora species are
expected within the sewerage line and WWTP areas.

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 Table IV.27 Possible Flora Species in and around the Project Area

BERN CITES
Phytogeographical
Family Taxon Endemism IUCN App
Region
App1 App1 App2 3
SPERMATOPHYTA
GYMNOSPERMAE
PINACEAE Pinus brutia Ten. Mediterranean - LC - - - -
ANGIOSPERMAE
RANUNCULACEAE
Ranunculus ficaria L. subsp. ficariiformis Rouy & Fouc. Widespread - - - - - -
Ranunculus arvensis L. Widespread - - - - - -
PAPAVERACEAE Papaver rhoeas L. Widespread - LC - - - -
CRUCIFERAE Hirschfeldia incana (L.) Lag.-Foss. Widespread - - - - - -
Biscutella didyma L. Widespread - - - - - -
Widespread -
Thlaspi perfoliatum L. -
- - - -
Capsella bursa-pastoris (L.) Medik Widespread - LC - - - -
Nasturtium officinale R. Br. Widespread - LC - - - -
Sinapis arvensis L. Widespread - LC - - - -
Sisymbrium officinale ( L.) Scop. Widespread - LC - - - -
Erysimum smyrnaeum Boiss. & Bal. Widespread - - - - - -
CARYOPHYLLACEAE Minuartia hybrida (Vill.) Schischk. subsp.hybrida Widespread - - - - - -
Holosteum umbellatum L. var. umbellatum Widespread - - - - - -
Silene vulgaris (Moench) Garcke var. vulgaris Widespread - LC - - - -
Silene behen L. Widespread - - - - - -
ILLECEBRACEAE Herniaria incana Lam. Widespread - - - - - -
GUTTIFERAE Hypericum perforatum L. Widespread - LC - - - -
Hypericum triquetrifolium Turra Widespread - - - - - -
MALVACEAE Malva sylvestris L. Widespread - LC - - - -
LINACEAE Linum bienne Miller Mediterranean - - - - - -
GERANIACEAE Geranium lucidum L. Widespread - - - - - -

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 BERN CITES
Phytogeographical
Family Taxon Endemism IUCN App
Region
App1 App1 App2 3
Erodium moschatum (L.) L'Herit. Mediterranean - - - - - -
POLYGONACEAE Rumex tuberosus L. subsp. tuberosus Widespread - - - - - -
Rumex bucephalophorus L. Widespread - - - - - -
Polygonum equisetiforme S,ibth. & Sm. Widespread - - - - - -
TAMARICACEAE Tamarix smyrnensis Bunge Widespread - LC - - - -
RHAMNACEAE Paliurus spina-christi Miller Widespread - - - - - -
LEGUMINOSAE Cersis siliquastrum L. subsp. siliquastrum Widespread - - - - - -
Anagyris foetida L. Mediterranean - LC - - - -
Vicia cracca L. subsp. stenophylla Vel. Widespread - - - - - -
Vicia sericocarpa Fenzl var. sericocarpa Widespread - - - - - -
Lathyrus aphaca L var. affinis (Guss.) Arc. Widespread - - - - - -
Lathyrus clymenum L. Mediterranean - LC - - - -
Mediterranean - -
Ononis spinosa L. subsp. leiosperma (Boiss.) Sirj
- - - -
Mediterranean - -
Ononis pubescens L.
- - - -
Medicago sativa L. subsp. sativa Widespread - - - - - -
Medicago minima (L.) Bart. var. minima Widespread - - - - - -
Mediterranean - -
Scorpiurus muricatus L. var. subvillosus (L.) Fiori - - - -
Coronilla parviflora Willd. Mediterranean - - - - - -
Onobrychis aequidentata (Sibth. & Sm.) d'Urv. Mediterranean - - - - - -
ROSACEAE Rubus sanctus Schreber Widespread - - - - - -
Potentilla recta L. Widespread - - - - - -
Widespread - -
Sangiosorba minor Scop subsp. muricata (Spach) Brig
- - - -
UMBELLIFERAE Eryngium campestre L. var. campestre Widespread - - - - - -
Tordylium aegaeum Runem. Mediterranean - - - - - -
Scandix australis L. subsp. grandiflora (L.) Thell. Widespread - - - - - -

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 BERN CITES
Phytogeographical
Family Taxon Endemism IUCN App
Region
App1 App1 App2 3
Daucus carota L. Widespread - LC - - - -
DIPSACACEAE Pterocephalus plumosus (L.) Coulter Widespread - - - - - -
Scabiosa argentea L. Widespread - - - - - -
Scabiosa sicula L. Mediterranean - - - - - -
COMPOSITAE Inula viscosa (L.) Aiton Widespread - - - - - -
Xanthium strumarium L. supsp. strumarium Widespread - - - - - -
Anthemis chia L. Mediterranean - - - - - -
Bellis perennis L. European-Siberia - - - - - -
Senecio vernalis Waldst. et Kit Widespread - - - - - -
Notobasis syriaca (L.) Cass. Mediterranean - - - - - -
Centaurea solstitialis L. subsp. solstitialis Mediterranean - - - - - -
Centaurea cyanus L. Widespread - LC - - - -
Scariola viminea (L.) F:W:Schmidt Widespread - LC - - - -
Crepis sancta (L.) Babcock Widespread - - - - - -
Crepis reuterana Boiss. subsp. reuterana Mediterranean - - - - - -
- -
Sonchus asper (L.) Hill subsp. glaucescens (Jordon) Ball Widespread
- - - -
- -
Lapsana communis L. subsp. adenophora (Boiss.) Rech. Fil Widespread
- - - -
Chondrilla juncea L. var. juncea Mediterranean - - - - - -
PRIMULACEAE Anagallis arvensis L.var. arvensis Widespread - - - - - -
STYRACACEAE Styrax officinalis L. Widespread - LC - - - -
APOCYNACEAE Nerium oleander L. Mediterranean - LC - - - -
- -
GENTIANACEAE Centaurium erythraea Rafn. Subsp. turcicum (Velen) Melderis Widespread - - - -
Mediterranean - -

BORAGINACEAE Alkanna tinctoria (L.) Tausch subsp. anatolica Hub.-Mor. - - - -

Echium italicum L. Mediterranean - - - - - -

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 BERN CITES
Phytogeographical
Family Taxon Endemism IUCN App
Region
App1 App1 App2 3
Anchusa azurea Miller var. azurea Widespread - - - - - -
- -
Anchusa undulata L. subsp. hybrida (Ten.) Coutinho Mediterranean - - - -
SCROPHULARIACEAE Misopates orantium (L.) Rafin. Widespread - - - - - -
Veronica cymbalaria Bodard Mediterranean - - - - - -
Veronica anagallis-aquatica L. Widespread - LC - - - -
Verbascum sinuatum L. var. sinuatum Mediterranean - - - - - -
VERBANACEAE Vitex agnus-castus L. Mediterranean - DD - - - -
LABIATAE Prunella vulgaris L. European-Siberia - LC - - - -
Origanum vulgare L subsp. hirtum (Link) Iestwart Mediterranean - - - - - -
Mediterranean - -
Melissa officinalis L. subsp. altissima (Sm) Arcengeli
- - - -
Salvia viridis L. Mediterranean - - - - - -
Salvia virgata Jacq. Iran-Turan - - - - - -
EUPHORBIACEAE Euphorbia apios L. Mediterranean - - - - - -
MORACEAE Ficus carica L. subsp. caica Widespread - - - - - -
SALICACEAE Populus nigra L. subsp. nigra Plantation - - - - - -
Salix alba L. European-Siberia - LC - - - -
PLANTAGINACEAE Plantago major L. subsp. intermedia (Gilib.) Lange Widespread - - - - - -
Plantago lanceolata L. Widespread - LC - - - -
LILIACEAE Ornithogalum orthophyllum Ten. Widespread - - - - - -
Asphodelus aestivus Brot. Mediterranean - LC - - - -
ORCHIDACEAE Ophrys mammosa Desf. Mediterranean - LC - - - -
- -
CYPERACEAE Bolboschoemus maritimus (L.) Pallas var. maritimus Widespread -
- - -
GRAMINEAE Trachynia distachya (L. ) Link Mediterranean - - - - - -
Hordeum bulbosum L. Widespread - LC - - - -
Bromus tectorum L. Widespread - - - - - -
Poa bulbosa L. Widespread - - - - - -

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 BERN CITES
Phytogeographical
Family Taxon Endemism IUCN App
Region
App1 App1 App2 3
Poa annua L. Widespread - LC - - - -
Brachypodium sylvaticum (Hudson) P.Beauv. Europan-Siberia - - - - - -
Piptatherum miliaceum (L.) Cosson subsp. tmomasii (Duby) - -
Widespread -
Freitag - - -
Calamagrostis pseudophragmites (Haller fil.) Koeler European-Siberia - LC - - - -
- -
Dactylis glomerata L. subsp. hispanica (Roth) Nyman Widespread -
- - -
Phragmites australis (Cav.) Trin. ex Steudel European-Siberia - LC - - - -
Polypogon viridis (Gouan) Breistr. European-Siberia - LC - - - -

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 Wildlife Features of the Project Area

Since the project will be constructed in the city center, it is not expected to have habitat
types that will inhabit wildlife. However, as a result of the studies conducted by examining the
literature and previous studies, it was possible to make an inventory for the fauna species. The
investigations were carried out as reptiles-amphibians, birds and mammals.

Amphibians and Reptilians

Reptile and amphibian species are concentrated in riparian habitat beside the planned
WWTP area. Amphibian and reptile species likely to be found in the area are shown in Table IV.28.

Among the detected species, only tortoise (Testudo graeca) is in the category “VU”
(Vulnerable: Sensitive) (Table IV.20) according to IUCN. However, tortoise is a widely spread
reptile species found in every region except the Eastern Black Sea region in Turkey. Other reptile
species are not in any threatened category. According to the IUCN species "LC: Least Concern"
category is located in this region, and Turkey in general are widespread species of Western
Palearctic zoogeographical.

Table IV.28 Possible Reptile and Amphibian Species in and around the Project Area

Threatened Status

International National
Species Name Turkish Name English Name

Endemism
CITES
BERN
IUCN

RDB
Bufo bufo Siğilli Kurbağa Common Toad LC Annex II - nt -
Bufotes variabilis Gece Kurbağası Green Toad DD Annex II - nt -
Phelophylax
Ova Kurbağası Marsh Fog LC Annex II - nt -
bedriagae
Balkan Çizgili
Mauremys rivulata Western Caspian Turtle LC - - -
Kaplumbağası
Testudo graeca Tosbağa Spur-thighed Tortoise VU Annex II Annex II nt -
Mediodactylus
İnceparmaklı keler Kotschy's Gecko LC Annex II - nt -
kotschyi
Hemidactylus turcicus Geniş parmaklı keler Turkish Gecko LC Annex III - - -
Laudakia stellio Dikenli Keler Hardim LC Annex II - nt -
Lacerta trilineata İri Yeşil Kertenkele Balkan green lizard LC Annex II - nt -
Ophisops elegans Tarla Kertenkelesi Wester sanke-eyed lizard LC Annex II - nt -
Ablepharus kitaibelii İince kertenkele European copper skink LC Annex II - nt -
Trachylepis aurata Tıknaz Kertenkele Levant skink LC Annex III - nt -
Blanus strauchi Kör Kertenkele Anatolian worm lizard LC Annex III - nt -
Typlops vermicularis Kör Yılan Blind snake LC Annex III - nt -
Platyceps najadum İnce Yılan Dahl's whip snake LC Annex II - nt -
Platyceps collaris Toros Yılanı Taurus whip snake LC Annex II - nt -
Eirenis modestus Uysal Yılan Ring-headed dwarf snake LC Annex III - nt -
Natrix natrix Yarısucul Yılan Grass Snake LR/ Annex III - nt -
Natrix tasellata Su Yılanı Dice Snake LC Annex II - nt -
Telescopus fallax Kedigözlü Yılan Soosan Snake LC Annex II - nt -

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 Birds

In the Project area, it is possible that some of the bird species are found in a certain period
of the year (spring-breeding and / or autumn-migration) and are usually that leave the region in the
fall. It has been determined that the project site is not on the main migration route for large
migratory birds flying with long wings. It is not a preferred transition area for migratory birds due to
the lack of suitable wintering habitats (permanent) wetlands (such as river-lake) and nutrient-rich
steppe areas for the project site and its immediate surroundings. Flocks of birds using as
accommodation and wintering areas during migration were not observed.

Since the Project area is located in the city center, there are mostly passeriform birds and
cosmopolitan species. Possible bird species expected to be seen in the project area are presented
in Table IV.29.

According to Table IV.29 Streptopelia turtur categorized as VU according to the IUCN Red
List but this species is very common (widespread) in Mugla and in Turkey.

Table IV.29 Possible Bird Species in and around the Project Area

Threatened Status

International National

Species Name Turkish Name English Name

Endemism
CITES
BERN
IUCN

RDB
Buteo buteo Şahin Common buzzard LC Annex III Annex II A.3 -

Larus michahellis Gümüş Martı Yellow-legged gull LC Annex III A.4 -

Columba livia Kaya Güvercini Rock pigeon LC Annex III A.5 -

Columba palumbus Tahtalı Woodpigeon LC - A.4 -

Streptopelia decaocto Kumru Collared dove LC Annex III A.5 -

Streptopelia turtur Üveyik Turtle dove VU Annex III A.3.1 -

Cuculus canorus Guguk Cuckoo LC Annex III A.2 -

Athene noctua Kukumav Little owl LC Annex II Annex II A.2 -

Tachymarptis melba Ak Karınlı Ebabil Alpine swift LC Annex II A.3.1 -

Galerida cristata Tepeli Toygar Crested lark LC Annex III A.3 -

Alauda arvensis Tarlakuşu Sky lark LC Annex III A.4 -

Hirundo rustica Kır Kırlangıcı Barn swallow LC Annex II A.5 -

Delichon urbicum Ev Kırlangıcı House martin LC Annex II A.3 -

Motacilla alba Ak Kuyruksallayan White wagtail LC Annex II A.3.1 -

Phoenicurus ochruros Kara Kızılkuyruk Black redstart LC Annex II A.2 -

Saxicola rubetra Çayır Taşkuşu Whinchat LC Annex II A.3 -

Turdus merula Karatavuk Blackbird LC Annex II A.3 -

Hippolais pallida Ak Mukallit Olivceous warbler LC Annex II A.3 -

Phylloscopus collybita Çıvgın Chiff chaff LC Annex II A.3.1 -

Muscicapa striata Benekli Sinekkapan Spotted flycatcher LC Annex II A.3 -

Parus major Büyük Baştankara Great tit LC Annex II A.3.1 -

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 Threatened Status

International National

Species Name Turkish Name English Name

Endemism
CITES
BERN
IUCN

RDB
Sitta neumayer Kaya Sıvacısı Rock nuthatch LC Annex II A.2 -

Lanius collurio Kızıl Sırtlı Örümcekkuşu Red-backed shrike LC Annex III A.2 -

Garrulus glandarius Alakarga Jay LC - A.3.1 -

Corvus corone corone Avrupa Leş Kargası Carrion crow LC - A.5 -

Passer domesticus Ev Serçesi House sparrow LC - A.5 -

Carduelis carduelis Saka Goldfinch LC Annex II Annex I A.3.1 -

Miliaria calandra Tarla Çintesi Corn bunting LC Annex III Annex II A.4 -

Mammals

The project area is not expected to support the wildlife considering the location of the
project components. The mammalian species of the region, like other fauna groups, are widely
distributed species with high adaptation to the city. Sewerage lines, discharge line and WWTP will
be constructed within settlements and areas where human impact is intense. Therefore, the area is
not expected to accommodate mammalian species that will require protection. Possible mammal
species expected to be seen in the project area are presented in Table IV.30.

Table IV.30 Possible Mammal Species in and around the Project Area

Threatened Status

International National

Species Name Turkish Name English Name

Endemism
CITES
BERN
IUCN

RDB

Erinaceus concolor Kirpi Hedgehog LC - - nt -

Rhinolophus Büyük Nalburunlu Greater Horseshoe
LC Annex II - V -
ferrumequinum Yarasa Bat
Rhinolophus Küçük Nalburunlu Shorter Horseshoe
LC Annex II - V
hipposideros Yarasa Bat

Myotis mystacinus Bıyıklı Siyah Yarasa Whiskered Bat LC Annex II - V -

Pipistrellus pipistrellus Cüce Yarasa Common Pipistrelle LC Annex III - V -

Sciurus anomalus Anadolu Sincabı Caucasian Squirrel LC Annex II - R/I -

Rattus rattus Ev Sıçanı Black Rat LC - - nt -

Mus domesticus Ev Faresi House Mouse LC - - nt -

Hystrix indica Oklu Kirpi Porcupine LC Annex II - R -

Vulpes vulpes Kızıl Tilki Red Fox LC - Annex III nt -

Mustela nivalis Gelincik Least Weasel LC Annex III - nt -

Martes foina Kaya Sansarı Stone Marten LC Annex III Annex III nt -

Sus scrofa Yaban Domuzu Wild Boar LC Annex III - nt -

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 Aquatic Environment

The treated water of the WWTP project will be discharged to Hanay Creek and its
characteristics are provided in Chapter IV.1.6. It directly drains into the sea without connecting to
another stream. The creek bed is made of concrete, and the cooling water is being discharged from
Kemerköy Thermal Power Plant to the Hanay Creek. The creek is an anthropogenic creek that has
lost its natural characteristics.

In the field studies, it was observed that there is flow in the creek (see Figure IV.31).
However, no fish were detected in the creek due to anthropogenic effects. The mouth of the sea is
located at a distance of about 1 km to the discharge point. Fish species can live in brackish waters
at the intersection of the creek and the sea. The most dominant species in the region is mullet
belonging to the Mugilidae family. Mullet is seen as a widespread species in Turkey and classified
as "LC: Least Concern" according to IUCN. However, it is known that the environment, whose
temperature increases due to cooling water discharge, creates a barrier for mullet species.

Figure IV.31 Hanay Creek

IV.3 Characteristics of Socio-Economic Environment

In this section, information regarding the economic activities and demographic features of
Mugla province and Milas district on the regional scale and Oren, Bozalan, and Turkevleri regions
on the local scale are presented to the extent possible. The state data retrieved from TurkStat is
supported with the results of field studies and site surveys conducted at Oren.

IV.3.1 Economical Characteristics

According to the “Socio-Economic Development Ranking Survey of Provinces and Regions

-2011” which was published by former Ministry of Development, Regional Development and
Structural Adaptation General Directorate, Mugla was ranked as the 8 th in Turkey as socio-
economic development. According to this index, Mugla with a population less than 1 million (along

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with Eskisehir) is one of the First Level Advanced Provinces. The table below shows the basic
indicators of the province of Mugla.

Table IV.31 Indicators for Development Level of Mugla

Parameters Value
Socio-economic development ranking (Ministry of Development, 2011) 8th
GDP per capita (TurkStat, 2018) 9.448 $
Number of Firms in Top 1000 (Istanbul Association of Manufacturers, 2018) 2
Number of Foreign Financed Firms (TOBB, 2019) 8
Total Exportation (TÜİK, 2019) 559 Million $
Primary school enrolment rate 2012 and after-net (%) (Turkey % 91.92) (TurkStat, 2018) %90.49
Secondary Education Schooling Rate (Turkey % 93,28) (TurkStat, 2018) %92.01
Number of Students Per Classroom (Primary School-Secondary School) (Turkey 24) (TurkStat, 2018) 18
Number of Hospital Bed per 100,000 Persons (Turkey 283) (TurkStat, 2018) 211
Forest Area / Total Area Ratio (General Directorate of Forestry ) %67.54
Tourism Facility Licensed Bed Numbers (MUTSO-TurkStat, 2018) 197,054
Total number of overnights (TurkStat, 2019) 14,497,222

Mugla located in a region that historical and cultural heritage traces are present. From the
scope of employment and income, the most important sector is tourism. 1,124 km coastal length,
Mugla pine honey, Milas carpet, Bodrum tangerine and natural beauties are the prominent values
of Mugla. While foreign tourists visit the province for summer vacation, winter season is not
evaluated enough from tourism scope. With advanced tourism opportunities such as airports,
seaports and marinas, hotels and beach facilities it is one of the most popular destinations of
Turkey.

In Table IV.32 and Table IV.33, Mugla Chamber of Commerce and Industry’s latest
available data showing number of tourists entering to Mugla and tourism facility statistics are
presented, respectively. It should be noted that data presented in Table IV.32 does not contain
access by road, which is the primary choice for most of the local tourists.

Table IV.32 Number of Tourists Entering Mugla by Mode of Transportation between 2016 and 2018

Local Tourist Foreign Tourist Total

Year
Airline Seaway Total Airline Seaway Total Tourist

2016 31760 131881 163641 1368353 123284 1491637 1655278

2017 32648 153572 186220 1609791 214364 1824155 2010375
2018 47625 120397 168022 2225080 320660 2713762 2713762

Table IV.33 Tourism Facility Statistics Prepared by TurkStat for Mugla Chamber of Commerce and Industry.

Tourism Certified Municipal Certificated Total

Year
Facility Room Bed Facility Room Bed Facility Room Bed
2016 506 64693 139995 1231 31416 67460 1737 96109 207455
2017 496 64015 138955 863 27299 61409 1359 91314 200364
2018 505 63356 137225 870 26547 59829 1375 89903 197054

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 While there is a decline in total bed number, according to “Mugla Business and Investment
Setting” report prepared by Southern Aegean Development Agency, Mugla owns 11.3% of the total
beds of Turkey. The most visited destinations in Turkey are respectively Istanbul, Antalya and
Mugla.

Important sectors other than tourism are seafood and animal products, mining and
quarrying, fresh fruit and vegetables, ship and yacht. For development of the economy of Mugla,
the province has potential future for medical tourism, renewable energy, organic agriculture,
agriculture based industry, ecology tourism and medicinal and aromatic plant production.

Mugla’s exports mainly consists of four main sectors; manufacturing, mining and stone
quarry, agriculture, forestry and fishing. Their total contribution to expropriation of Turkey is around
559 Million $.

The Southern Aegean Region, identified as TR32 Region, is composed of Aydin, Denizli
and Mugla provinces. Turkey’s 4.1% population lives in this region. TR32 Region constitutes 4.6%
of total labor force, 4.7% of total employment, and 3.2% of total unemployment of Turkey.

In 2019, employment and unemployment rates of TR32 are 51.2% and 9.2%, respectively.
The employment rate in the region is higher than Turkey’s average, which is 45.7%, and
unemployment rate in the region is lower than Turkey’s average, which is 13.7%. The employment
and unemployment rates according to years are presented in Figure IV.32.

60
53
50,3 50,3 51,5 51,2
50
50

46 46,3 47,1 47,4

Percentage, %

40 45,5 45,7

30

20 13,7
9,9 10,3 10,9 10,9 11
10
9,2
7,2 6,9 6,7 7,1 6,9
0
2014 2015 2016 2017 2018 2019
Years
Employment Rate Turkey Employment Rate TR32
Unemployment Rate Turkey Unemployment Rate TR32

Figure IV.32 Employment and Unemployment Rates According to Years, TR32 (TurkStat, 2019)

The shares of service, agriculture and industry sectors within the region are 41.1%, 39.6%
and 19.1%, respectively (see Figure IV.33).

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 Sectorial Employment

19,1
41,1
Service
Agriculture
39,6
Industry

Figure IV.33Sectorial Employment in TR32 (TurkStat, 2019)

In Milas District, where Oren neighborhood is located at, agriculture is the main sector that
contributes most to the district’s economy, but mining and industry have also great importance. The
district ranks first in the province in terms of the number of industrial workplaces registered to
Turkish Union of Chambers and Commodity Exchanges and employment. Milas Airport and Gulluk
Port strengthen the district’s transportation and storage infrastructure. The vast majority of fish
production, packaging and feed mills of the region are located in Milas and vicinity, and 68% of
Turkey's farmed fish production is met. There are many feldspar and marble quarries and marble
processing facilities in the district. Milas has the 2 nd place after Yatagan for the number of workers
in mining sector.

While agricultural lands of Mugla’s districts are presented in Figure IV.34, the breakdown of
Milas’s agricultural land is provided in Table IV.34, and following that top ten agricultural products
of Milas and their amounts are presented in Table IV.35. As seen from Figure IV.34, Milas ranks
first in terms of agricultural land acreage among Mugla’s districts. Mugla’s 42.7% of agricultural
lands consist of olive groves (53080 ha, around 8 million trees). There are 16 businesses in Milas
that produce organic olive and olive oil.

Figure IV.34 Agricultural Lands of Mugla (TurkStat, 2019)

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Table IV.34 Agricultural Lands of Milas (TurkStat, 2019)

Agricultural Land Area

Fruits and spices 53779 ha
Cereals, grains and others 13673 ha
Vegetable 4902 ha
Fallow 200 ha
TOTAL 72554 ha
Milas’s Total Acreage 2067 km2
Agricultural Land / Milas’s Total Acreage 35%

Table IV.35 Top Ten Agricultural Products of Milas (TurkStat, 2019)

Agricultural Products Amount (ton) Ratio to the Total Production (%)

Corn (silage) 299250 41.52
Clover 80000 11.10
Olive oil 77545 10.75
Tomatoes 63389 8.79
Watermelon 62600 8.68
Italian ryegrass 21900 3.03
Common vetch 17500 2.42
Triticale 15300 2.12
Cucumber 9360 1.29
Wheat 8553 1.18

In addition to agriculture, Milas also ranks first in terms of stockbreeding among districts of
Mugla as it can be seen from Figure IV.35. Milas also ranks first in honey production with 2800 ton.

Figure IV.35 Number of Cattles in Mugla’s Disctricts (TurkStat, 2019)

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 Milas is one of the regions in Turkey whose inhabitants kept their Turkmen heritage in its
liveliest. As aside clothing and traditions, this heritage also includes the art of carpet weaving. It is
generally admitted that a distinctive breed of Milas rugs came into existence in the 16 th century.
Although very few in numbers (one or two producers), carpet weaving is still valid for some of the
villages of Milas including Oren, Turkevleri, and Bozalan.

The residents of Oren were making their living from agriculture (citrus, sesame, tobacco,
cotton, and cereals), husbandry, and waving until 1990. After 1990, growth in tourism has changed
the economy of Oren and its vicinity. Then hotel management, restaurant management, yachting,
and service jobs have become widespread and started to contribute to the economy of Oren (Milas
District Governorship Information Notice, 2018). TurkStat does not provide any economic data on
neighbourhood level; therefore, site surveys were used to gather as much data as possible on
socio-economics of Oren and its vicinity. Eighteen surveys were conducted in Oren during the first
public participation meeting held on July 7, 2020. The information gathered by these surveys are
presented in Table IV.36. As seen from below, mostly elderly people participated to the survey
studies and almost all of them are on retirement pension. Unemployment rate among the
participants is quite high (28.58%) comparing to Muğla’s data presented above. However, all
participants have social securities and 53% of them have savings.

Table IV.36 Survey Results

Information on Participants
Number of surveys 18
Ratio of female participants 29.40%
Ratio of male participants 70.60%
Average age of the participants 53
Percentage of participants between the ages of 20 and 30 12.50%
Percentage of participants between the ages of 30 and 40 6.25%
Percentage of participants between the ages of 40 and50 12.50%
Percentage of participants between the ages of 50 and 60 37.50%
Percentage of participants between the ages of 60 and 70 25%
Percentage of participants between the ages of 70 and 80 6.25%
Percentage of people living in Milas 12 months of a year 35.71%
Percentage of people living in Milas less than 6 months of a year 42.85%
Percentage of residents who have been in Milas for more than 10 years 33.30%
Percentage of residents who have been in Milas for less than 10 years 66.70%
Sources of Income
Salary 46.66%
Retirement pension 20.04%
Commercial income and retirement pension 6.66%
Commercial income 6.66%
Rent and retirement pension 6.66%
Tourism income and rent 6.66%
Tourism income and retirement pension 6.66%
Main Unemployment Reason
Retired 57.13%
Unemployed 28.58%
Seasonal unemployment 14.29%
Total Annual Income in 2019
Less than 100.000 TL 40%
More than 100.000 TL 60%
Savings

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Yes 53.85%
No 46.15%
Social Security
Yes 100%
No 0%
Private Health Insurance
Yes 18.75%
No 81.25%
INFRASTRUCTURE AND EXPENDITURES
How many square meters is the usage area of the house you currently live in?
Greater than 150 m² 16.67%
Between 149 and 90 m² 33.33%
Between 81 and 89 m² 8.33%
Between 20 and 80 m² 41.67%
Number of rooms
5 16.66%
4 72.22%
3 5.55%
2 5.55%
Does your house have a garden?
Yes 100%
No 0%
How many square meters is the garden of your house?
Between 10 and 80 m² 46.15%
Between 80 and 180 m² 15.38%
Between 180 and 500 m² 30.76%
More than 500 m² 7.70%
What is the main drinking water supply source in your house?
City network 88.90%
Demijohn 5.55%
Private well 5.55%
What is the main domestic water supply source in your home?
City network 88.24%
Water tank 5.88%
Tap water in the garden 5.88%
What is the main irrigation source in your home/garden?
No additional source 28.58%
Well 64.28%
Other 7.14%
Do you have electricity at home?
Yes 100%
No 0%
Monthly average electrical consumption (in TL)
Between 50 and 100 TL 18.75%
Between 100 and 200 TL 68.75%
More than 200 TL 12.50%
What kind of toilet do you have?
Siphon flush toilet 89.47%
Squatting toilet 5,.6%
Garden toilet 5.26%

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What kind of wastewater system do you have in your household?
Regularly pumped-out by municipality’s sewer trucks 37.50%
Regularly pumped-out by private sewer trucks 12.50%
Septic Tank / Pit Latrine 43.75%
Other 6.25%
How much money do you spend annually to solve your wastewater problems?
On average 2.822 TL
Wastewater-related problems in the households
Odor 33.34%
Pollution 16.67%
Shortage of sewage trucks and costs 16.67%
No sewerage and infrastructure 8.33%
Technical faults 8.33%
Official formalities 8.33%
No problems 8.33%
How do you manage domestic wastes?
Milas Municipality regularly collects 94.44%
Other 5.56%
How much money do you spend annually for energy?
On average 1080 TL
How much money do you spend monthly for water?
On average 130.33 TL
How much do you spend on kitchen expenses (food, beverage, etc.) per month?
On average 2200 TL
What is your first choice to take loan in case needed?
Credit card 53.33%
Bank 40%
Close relatives 6.67%
Are you in debt?
Yes 41.18%
No 58.82%
The average debt of those who answered yes to the question 63.750 TL
All of them took loans from banks

The biggest industry in Oren is Kemerköy Thermal Power Plant and associated coal mines.
Other than the plant, there are no attraction centres in Oren for active population. In off-season,
Oren’s population decreases to 3000 from 30000 and mostly elderly residents stay in the village
according to the interviews made with the public.

Oren has three schools; one primary school, one secondary school and one high school.
The total number of students in the neighbourhood is 450. There are 30 classrooms and 50
teachers in these schools (Milas District Directorate of National Education, 2020). It can be said
that education infrastructure in Oren is strong with sufficient number of schools, classrooms, and
teachers. For university-level education, nearest university is Mugla Sitki Kocman University.

Despite strong education infrastructure, Oren has very limited health services. There is
only one primary care clinic in Oren. The clinic is occupied with three doctors. This indicates that
number of population per doctor is 1000 for winter period and this value is way beyond the Turkish
average (498.2) and OECD average (341.3). The ratio is much worse for summer season, where
the population reaches ten-fold. The nearest full-fledged hospital, which is 75. Yıl State Hospital, is

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at Milas and 50 km away from Oren. In addition to the state hospital, there is also one private
hospital in Milas.

IV.3.2 Population

Provincial Level

Mugla ranks twenty fourth province of Turkey in terms of total population, as of 2019, its
population is 983.142. Population density (number of people per square kilometer) is 76.5, it is
lower than Average of Turkey (108.05) when compared with. It is a famous settlement in the
Aegean Region, with a small part of its territory in the Mediterranean Region, where the holiday
resorts such as Ortaca, Dalaman, Fethiye, Marmaris, Milas, Datca and Bodrum are located. The
province has 13 districts (TurkStat,2019).

Substantial part of the Mugla population consists of age group of 0-24 and this group
comprises 30.67 percent of total population. Age and gender distribution of Mugla is given in Table
IV.37 and it is shown that the age group of “35-39” (8.22%) and “40-44” (8.06%) has the highest
ratio within the total population.

Table IV.37: Age and Gender Distribution of Mugla Province (TurkStat, 2019)

Age Age Total Age

Age Group Male Female Total Group/Total Group/Total Group/Total
Male (%) Female (%) (%)
0-4 29105 27367 56472 5,81 5,67 5,74
5-9 31229 29343 60572 6,24 6,08 6,16
10-14 31500 29459 60959 6,29 6,10 6,20
15-19 30289 27719 58008 6,05 5,74 5,90
20-24 34457 31078 65535 6,88 6,44 6,67
25-29 34264 31115 65379 6,84 6,45 6,65
30-34 36254 35238 71492 7,24 7,30 7,27
35-39 41246 39523 80769 8,24 8,19 8,22
40-44 40927 38329 79256 8,18 7,94 8,06
45-49 38486 36403 74889 7,69 7,54 7,62
50-54 35112 33309 68421 7,01 6,90 6,96
55-59 33472 32026 65498 6,69 6,64 6,66
60-64 27345 26597 53942 5,46 5,51 5,49
65-69 21057 21615 42672 4,21 4,48 4,34
70-74 15115 16206 31321 3,02 3,36 3,19
75-79 9892 11557 21449 1,98 2,40 2,18
80-84 6243 7973 14216 1,25 1,65 1,45
85-89 3517 5365 8882 0,70 1,11 0,90
90+ 1092 2318 3410 0,22 0,48 0,35

Population pyramid of Mugla province is presented in Figure below. When the population
pyramid examined, it can be said that Mugla has contracting population pyramid profile. By
considering these data, the dependency ratio (of Mugla is 43.9% and this ratio is slightly lower than
the average ratio of Turkey (47.46%).

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 Population Pyramid
90+

80-84

70-74

60-64

50-54
Age Female
40-44 Male
30-34

20-24

10-14

0-4
10,00 5,00 0,00 5,00 10,00

Figure IV.36 Population Pyramid of Mugla Province (TurkStat, 2019)

According to the data obtained from Address Based Population Registration System, 2019
results, population of the Milas district, where project area is located, is 141,107. With this
population, Milas has the 3rd highest population behind Bodrum and Fethiye respectively. The
population distribution of Mugla and the population of the districts are given in Table IV.38.

Table IV.38 Population of Mugla Districts (TurkStat, 2019)

District Male Female Total Male (%) Female (%)

Bodrum 89244 86191 175435 50,87 49,13
Dalaman 22295 19729 42024 12,71 11,25
Datca 11442 10961 22403 6,52 6,25
Fethiye 81656 81030 162686 46,54 46,19
Kavaklıdere 5472 5320 10792 3,12 3,03
Koycegiz 18610 18316 36926 10,61 10,44
Marmaris 49719 45030 94749 28,34 25,67
Mentese 57869 57190 115059 32,99 32,60
Milas 71538 69569 141107 40,78 39,66
Ortaca 25083 24944 50027 14,30 14,22
Seydikemer 32264 29389 61653 18,39 16,75
Ula 12836 12566 25402 7,32 7,16
Yatagan 22574 22305 44879 12,87 12,71

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 District Level

Milas ranks third with its 141,107 population among districts of Mugla. The population
density is 68.7, which is lower than both Mugla average 76.5 and Turkey average 108.05. Age and
gender distribution of the population is presented in Table IV.39. The table shows that the age
distribution of Milas is balanced and the age group of “35-39” (7.68%) and “30-34” (7.26%) has the
highest ratio within the population. The average age in Milas is 38.7, which is 42 for Mugla and
32.7 for Turkey. The dependency ratio of Milas is calculated as 47.2 %, while it is 43.9% in Mugla
and 47.46% in Turkey.

Table IV.39 Age and Gender Distribution of Milas Province (TurkStat, 2019)

Age Age Total Age

Age Group Male Female Total Group/Total Group/Total Group/Total
Male (%) Female (%) (%)
0-4 4499 4182 8681 3.2 3.0 6.15
5-9 4651 4143 8794 3.3 2.9 6.23
10-14 4500 4308 8808 3. 3.1 6.24
15-19 4261 4063 8324 3.0 2.9 5.90
20-24 4440 4127 8567 3.1 2.9 6.07
25-29 4859 4494 9353 3.4 3.2 6.63
30-34 5142 5102 10244 3.6 3.6 7.26
35-39 5463 5289 10752 3.9 3.7 7.62
40-44 5270 4909 10179 3.7 3.5 7.21
45-49 5072 4980 10052 3.6 3.5 7.12
50-54 5001 4910 9911 3.5 3.5 7.02
55-59 5260 4920 10180 3.7 3.5 7.21
60-64 4320 3981 8301 3.1 2.8 5.88
65-69 3149 3178 6327 2.2 2.3 4.48
70-74 2307 2482 4789 1.6 1.8 3.39
75-79 1538 1847 3385 1.1 1.3 2.40
80-84 999 1342 2341 0.7 1.0 1.66
85-89 645 927 1572 0.5 0.7 1.11
90+ 162 385 547 0.1 0.3 0.39
TOTAL 71538 69569 141107 50.7 49.3 100

Population pyramid of Milas is presented in Figure IV.37. When the population pyramid
examined, it can be said that Mugla has contracting population pyramid profile.

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 Population Pyramid of Milas
'90+'

'80-84'

'70-74'

'60-64'
Age Group

'50-54'
Female
'40-44'
Male
'30-34'

'20-24'

'10-14'

'0-4'
6 4 2 0 2 4 6

Figure IV.37 Population Pyramid of Milas (TurkStat, 2019)

Neighbourhood Level

Three neighbourhoods of Milas – Oren, Turkevleri, and Bozalan - are in the scope of the
Project. The demographic information of these neighbourhoods are retrieved from TurkStat and
presented in Table IV.40. It should be noted that during summer season, these numbers could go
up-to ten times.

Table IV.40 Population of Oren, Turkevleri and Bozalan (TurkStat, 2019)

Neigbourhood Male Female Total

Oren 1546 1492 3038
Turkevleri 424 402 826
Bozalan 279 240 519
TOTAL 2249 2134 4383

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V. ENVIRONMENTAL AND SOCIAL IMPACTS OF THE PROJECT AND
MITIGATION MEASURES
The main purpose of the ESIA is to identify and assess the potential positive and adverse
impacts that may arise due to the Project activities on the natural environment and on the socio-
economic wellbeing and conditions of the population (community and workforce) at the local and
regional level. This assessment is based on the Project characteristics and activities and the
baseline conditions in the Project area.

As a result of this assessment relevant mitigation measures would be developed for

avoiding, preventing and minimizing significant adverse impacts and enhancing beneficial impacts.
Furthermore, the assessment includes the significance of residual impacts remaining on the
environment and community as a result of the Project following implementation of the mitigation
measures. Consequently, monitoring activities for checking effectiveness of the proposed
mitigation measures would be identified.

V.1 Scope-in/Scope-out Process

The ESIA scoping process for the Project considered relevant project activities and the
environmental and social aspects they would interact with in order to identify the issues to be
focused on in the ESIA studies. The analysis of these potential interactions has been done using a
color code (see Table V.1) in a modified Leopold matrix (see Table V.2). This approach provided
the means to identify the potential interactions each Project activity may have on a range of
resources/receptors within the Project Area of Influence (AoI).

The Turkish EIA Regulation defines the area of influence as "the area affected by a
planned project before operation, during operation and after operation". The area of influence may
be different for different types of impacts and different environmental components (physical,
biological, social) (World Bank ESMAP, December 2012).

According to World Bank Group (WBG) International Finance Corporation (IFC)

Performance Standard (PS) 1 Assessment and Management of Environmental and Social Risks
and Impacts, the Area of Influence (AoI) is to encompass the following as appropriate:

 The area likely to be affected by: (i) the Project (e.g. Project sites, immediate air shed
and watershed, or transport corridors) and the Project Sponsors’ activities and facilities
that are directly owned, operated or managed (including by contractors) and that are a
component of the project (e.g. tunnels, access roads, borrow and disposal areas
construction camps); (ii) impacts from unplanned but predictable developments caused
by the project that may occur later or at a different location; or (iii) indirect project
impacts on biodiversity or on ecosystem services upon which Affected Communities’
livelihoods are dependent.
 Associated facilities, which are facilities that are not funded as part of the project and
that would not have been constructed or expanded if the project did not exist and
without which the project would not be viable.
 Cumulative impacts that result from the incremental impact, on areas or resources
used or directly impacted by the project, from other existing, planned or reasonably
defined developments at the time the risks and impacts identification process is
conducted.

In this respect, the Project together with all of its components and auxiliary facilities
(sewerage network including the pumping stations, Oren WWTP, energy transmission lines and
construction camp) has been considered in the ESIA to the extent the level of information allowed.

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Table V.1 Colour Code Used in the Scope-in/Scope-out Process

(White) An interaction is not reasonably expected. Aspect “scoped out”

An interaction is reasonably possible, but none of the resulting Aspect “scoped out”, but rationale
(Grey) impacts are likely to lead to significant effects, and/or interaction is is provided in relevant section of
addressed through embedded mitigation measures. current report
An interaction is reasonably possible and at least one of the resulting “Scoped in” – subject to impact
(Red)
impacts is likely to lead to a negative effect that is significant. assessment.
“Scoped in” – subject to impact
(Green) Impacts which are considered likely to be positive.
assessment.

Those interactions that are coloured white are scoped out of further consideration in the
impact assessment process and no discussion is warranted in the ESIA report. Those interactions
that are coloured grey are also scoped out, but during the impact assessment process these
potential interactions have been reviewed to confirm that resulted impacts are not significant and/or
are appropriately addressed through one or more embedded controls. Those interactions marked
with red and green are scoped in and subject to impact assessment as part of the ESIA process.
These impacts would be assessed for their significance and additional mitigation measures,
beyond the already planned embedded controls, would be proposed as necessary.

Table V.2 and

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 Table V.3 summarize the potential interactions between the Project and environmental
resources (air, water, noise, etc.) and socioeconomic receptors.

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Table V.2 Potential Interactions between Project Activities and Environmental Resources

Environmental Resources

Surface Water Resources

Biological Environment

Resources and Wastes

Landscape and Visual
Noise and Vibration
Contaminated Land
Geology, Soils and
Project stage/activity

Climate Change
Groundwater

(Aesthetics)
Air Quality
Construction
Vegetation clearance, levelling works and
construction activities at Oren WWTP site
Excavation of surface material for laying down of
sewerage system

Provision of material, equipment, and service

Use of energy

Generation of domestic and hazardous waste

Operation

Water supply and use (domestic)

Emissions and odour

Generation of domestic wastewater

Generation of solid waste including sludge

Provision of material, equipment, and service

Regular and timely maintenance works at WWTP,

discharge line, sewerage network and pumping
stations

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Table V.3 Potential Interactions between the Project Activities and Social/Socio-economic Receptors

Social / Socio-economic Receptors

Socio-Economics Other Social Receptors

Community Cultural Situation/ Social

Archaeological and Cultural heritage

Worker Health and Safety (Labour &

Community Health and Safety and

Infrastructure and Services
Community Demographics
Project stage/activity

Working Conditions)
Ecosystem Services
Local Economics

Livelihood
Cohesion

Land Use

Security
Construction
Employment of personnel and procurement of goods
and services (from local market)

Labor influx

Construction traffic (transportation of workers and

materials)
Operation of construction machinery, equipment and
generators

Road closures

Wastes/wastewater handling and disposal

Operation
Employment of personnel and procurement of goods
and services (from local market)
Maintenance of sewerage system, discharge line,
pumping stations and WWTP

Waste handling and disposal

Emissions and odour

V.2 Impact Assessment Approach and Methodology

The purpose of impact assessment and mitigation is to identify and evaluate the
significance of potential impacts (positive or negative) on identified receptors and resources
according to defined assessment criteria; to develop and describe the measures that will be taken
to avoid or minimize any potential adverse effects and enhance potential benefits; and to report the
significance of the residual impacts that remain following mitigation.

The assessment of environmental and social impacts has been done based on the criteria
provided below using mainly expert judgement, relevant standards and guidelines:

 Nature of the impact: Positive (+), Negative (-)

 Type of Impact: Direct, Indirect, Cumulative
 Extent/area of Impact: On-site/project footprint, Local, Regional, National
 Duration of Impact: Short term, Mid-term, Long term, Permanent
 Likelihood of Impact Occurrence: Very likely/certain, Likely, Unlikely

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 The magnitude and severity of the adverse impacts have been assessed based on the
criteria given above and significance of the impacts has been determined based on this
assessment and sensitivity of the receiver/source exposed to the impact, as much as possible. The
matrix given in Table V.4 combines the sensitivity information with the magnitude of impacts. The
significance of the impact is first designated without mitigation measures and then evaluated with
proposed mitigation measures. This evaluation serves to determine the significance of the residual
impacts (impact left after employing mitigation measures).

Table V.4 Impact Significance Matrix*

Sensitivity of Magnitude of Impact

Receptor High Medium Low Negligible/None
High High High Medium Negligible/None
Medium High Medium Low Negligible/None
Low Medium Low Low Negligible/None
* Adapted from Scottish Natural Heritage – A handbook on environmental impact assessment, 2013

V.3 Potential Area of Influence

Project’s location is presented in Figure V.1. As described before, the Project will have
impacts especially on the vicinity of the Project sites. The potential area of influence for the Project
includes the neighbourhoods that are located in the sewerage network service area, discharge line,
pumping stations, WWTP, energy transmission line, construction camp and its close vicinity. In
short, the settlement areas located in the Oren, Turkevleri, and Bozalan Neighbourhoods are
considered as the potential area of influence, which is shown in Figure V.2. Project’s potential
social area of influence and the distances between WWTP and nearest settlements are show on a
map given in Figure V.3, which is similar with the potential area of influence. The identified
sensitive receptors are shown on a map presented in Figure V.4.

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Figure V.1. Layout of the Oren Wastewater Treatment Plant and Sewerage Network

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Figure V.2. Area of Influence of the Project

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Figure V.3 Potential Social Area of Influence

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Figure V.4 Sensitive Receptors in the Project Area

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V.4 Environmental Impacts (Physical and Biological Environment)

In Table V.5 identification of level of impact in terms of environmental resources (air,

geology, water, etc.) for two project phases (construction and operation phases) are presented.

Project would have environmental impacts during construction and operation phases.
Potential impacts of the Project during the construction phase would be generally short term with
low to medium magnitude that would be locally significant. These impacts can be initially
summarized as follows:

 Air emissions and increased level of noise generated from the operation of the
construction machinery and equipment.
 Soil contamination as a result of inadequate management of waste generated on site,
and possible leakage of hazardous materials (oil and lubricants from outdoor
equipment).
 Wastes to be produced by workers.

In terms of auxiliary facilities, impacts during the construction activities are expected to be
similar to the impacts regarding to main Project components, therefore, these impacts are
evaluated together for both main Project components and auxiliary facilities. Although the energy
transmission line has a linear route, only electric poles with a base size of approximately 5m x 5m
will be erected for the energy transmission line. For this reason, excavation works will be limited for
the electric pole and construction activities will be carried out in a short period of time. Therefore,
impacts related to energy transmission line during the construction phase will be low in significance
and short-term. On the other hand, for operation phase, impact regarding to electrocution from
energy transmission line could be considered as significant if not properly managed.

During the operation phase significant adverse environmental impacts are not expected.
The operation of the WWTP might create noise, odour, and sludge related impacts on sensitive
receptors, which could be considered as significant if not properly managed. Maintenance and
repair works of the WWTP, discharge line, sewerage network, pumping stations and energy
transmission line might have minor environmental impacts such as generation of waste and
increased level of noise. These impacts will be local and short-term with low in significance.

The following table provides a detailed overview of the identified impacts and their
assessment as a result of the execution of project activities in different project phases, types of
activities and baseline conditions on the Project area.

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact

Sensitivity Magnitude Impact Impact

Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

A. CONSTRUCTION PHASE

1. Air Quality

1 Increase in dust concentration      Medium Low Low Low

2 Increase in exhaust emissions      Medium Low Low Low
3 Impact on human health      Medium Negligible Negligible Negligible

2. Geology, Soils and Contaminated Land

1 Contamination of soil      Medium Low Low Low

2 Loss of topsoil at Oren WWTP site      Medium Medium Medium Low
3 Erosion Potential       Medium Medium Medium Low
Liquefaction and ground stability
4      High High High Low
related risks at Oren WWTP Site

3. Surface Water Resources

1 Surface water quality      Medium Low Low Negligible

4. Groundwater Resources

1 Groundwater quality      Medium Low Low Negligible

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact
Sensitivity Magnitude Impact Impact
Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

5. Noise and Vibration

1 Increase in Noise Level      Medium Medium Medium Low

2 Increase in Vibration Level      Medium Low Low Negligible

6. Biological Environment

No significant impacts on
1 biological environment are Low Low Low Negligible
expected

7. Landscape and Visual (Aesthetics)

Impairment of quality of life due to

1 the overall presence of annoying      Medium Medium Medium Low
construction works and activities
and altered landscape
8. Resources and Wastes

1 Improper waste management      Medium Low Low Low

9. Climate Change

Contribution to climate change

1      Medium Low Low Negligible
through GHG emissions

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact
Sensitivity Magnitude Impact Impact
Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

10. Socioeconomic Environment

Job creation and local

1         Positive
procurement
Negligible/
2 Infrastructure damage        Low Low Low
None

11. Occupational Health and Safety

Workers’ exposure to work-related

1 occupational health and safety         High High High Low
risks

12. Community Health and Safety

Project traffic and construction

1         Low Medium Low Low
activities related risks

None/
2 Community encroachment          Low Medium Low
Negligible

13. Archaeological and Cultural Heritage

Negligible/
1 Chance finds          Low Low Low
None

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact
Sensitivity Magnitude Impact Impact
Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

B. OPERATION PHASE

1. Air Quality
Air and odorous gas emissions
1      Medium Medium Medium Low
from Oren WWTP
2. Geology, Soils and Contaminated Land

1 Loss of Land      Medium Low Low Negligible

2 Soil contamination      Medium Low Low Negligible

3. Surface Water Resources

1 Change in surface water quality      Positive

4. Groundwater Resources

1 Change in ground water quality      Medium Low Low Negligible

5. Noise and Vibration

1 Increase in Noise Level      Medium Low Low Low

6. Biological Environment

1 Discharge of the treated effluent      Positive

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact
Sensitivity Magnitude Impact Impact
Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

7. Landscape and Visual (Aesthetics)

The existence of the WWTP and

1      Low Low Low Low
energy transmission line

8. Resources and Wastes

Generation of different types of
waste during maintenance and
1     Medium Low Low Low
repair works and sludge from Oren
WWTP
9. Climate Change
1 GHG emissions      Medium Low Low Negligible
10. Socioeconomic Environment
Job creation and local
1          Positive
procurement
11. Community Health and Safety

Community’s exposure to disease

Negligible/
1 due to improper handling of       Low Medium Low
None
wastes, including sludge

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Table V.5 Matrix Table with Identification of Impact Level in Terms of Environmental and Social Attributes

Impact
Sensitivity Magnitude Impact Impact
Likelihood of Significance
Nature Type Extent/area Duration of the of the Significance
Occurrence without
Receptor Impact with ESMP
ESMP
High High High High

Very likely/ certain

No Environmental Attributes

On-site/project
Medium Medium Medium Medium

Negative (-)

Cumulative
Positive (+)

Permanent
Short term

Long term
Low Low Low Low

Regional

Mid-term
footprint

National

Unlikely
Indirect

Likely
Direct

Local
Negligible/ Negligible/ Negligible/ Negligible/
None None None None

Increased traffic due to waste and

2      Low Low Low Low
sludge disposal

3 Failure of operation      Medium High High Low

None/
4 Community encroachment       Low Medium Low
Negligible

Electrocution from Energy

5       Medium High High Low
Transmission Lines

12. Occupational Health and Safety

Workers’ exposure to work-related

1 occupational health and safety       High High High Low
risks

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V.4.1 Air Quality

Construction Phase

The major impacts on air quality during the construction phase of this project will be related
with the material handling, vehicle movement and emission from heavy construction machinery
(trucks, excavators, etc.). Air pollution will be mainly dust emissions and exhaust emissions as well
as GHG emissions. The sensitive receptors that will be exposed to these air emissions will be the
local population who lives near the construction sites.

During construction phase of the project, there will be vehicle movement for transportation
of various construction materials to the project site. Impacts on air quality will be mainly due to dust
emissions caused by the vehicle movement on unpaved roads and earthworks to be performed
within the Project Area. In addition to the fugitive dust emissions, exhaust emissions will originate
from vehicles used in construction activities. In order to determine fugitive dust and exhaust
emissions during the construction phase, the number of machinery and equipment to be used for
the construction should be known. The machinery requirement of the Project is not determined by
MUSKI yet and therefore, the construction machineries and equipment to be used during the
construction phase is assumed and presented in Table V.6.

Table V.6 Indicative Construction Machinery and Equipment List

Construction Machinery/Equipment Number

Dump Truck 6
Excavator 2
Loader 2
Mini Loader 3
Mobile Crane 2
Sprinkler 1
Grader 1

The amount of fugitive dust emission generated during the construction phase of the
Project is calculated with the emission factors defined in IAPCR. The emission factors are
presented in Table V.7.

Table V.7. Emission Factor to be used to Calculate Dust Emissions

Emission Factors
Sources Unit
Uncontrolled Controlled
Dismantling/Excavation 0.025 0.0125
Loading 0.010 0.0050 kg/ton
Unloading 0.010 0.0050
Storage 5.800 2.9000 kg dust/ha.day
Transportation (total distance) 0.700 0.3500 kg/km- vehicle
Source: Industrial Air Pollution Control Regulation, Appendix 12.

According to the project schedule, construction activities are planned to last for 18 months
(approximately 450 work days) and daily shifts will last for 8 hours. Construction works will start
with earthworks, which will last for 240 days. Earthworks consist of levelling, excavation, temporary
storage, loading and transportation of excavation material.

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 The total amount of excavated material that will be generated as a result of construction
activities is 69,664.20 m3 (see Table V.8). 12,379.51 m3 of the extracted material will be temporarily
stored in the Project site for backfilling. Excavation is planned to be conducted step by step.
However, the worst case scenario is assumed in the calculations and all the activities are assumed
to be conducted simultaneously.

Table V.8. Excavation Amounts

Excavation Depth Excavation

Unit Footprint (m2)
(m) Amount (m3)

Coarse Screen 8.00 2.00 16.00

Pump Station 48.00 4.50 216.00
Fine Screen 9.60 2.00 19.20
Aerated Grit Chamber 110.00 3.00 330.00
Rectangular Weir and Distribution Chamber 5.00 3.50 17.50
Anaerobic BioP Tanks 72.00 4.50 324.00
Aeration Tanks 720.00 4.50 3,240.00
Final Sedimentation Distribution Chamber 5.00 4.50 22.50
Final Sedimentation Tanks 50.00 4.50 225.00
Treated Water Pit 6.00 3.00 18.00
Disinfection Tank 48.00 3.00 144.00
Sludge Pumping Station 36.00 4.50 162.00
Sludge Thickener 28.00 4.50 126.00
Sludge Dewatering Building 80.00 6.00 480.00
Blower Building 147.00 6.00 882.00
Administrative Building 64.00 3.00 192.00
Transformer and Generator Building 96.00 1.50 144.00
Security Cabin/Guardhouse 12.00 3.00 36.00
Sewerage Network 37,100.00 1.70 63,070.00
Total Excavation 69,664.20

The amount of dust emission expected as a result of the construction activities of the
Project have been calculated and presented in detail below.

Total Excavation Volume : 69,664.20 m3

Density of Excavation Material : 1.8 ton/m3
Total Amount of Excavation : 125,395.6 ton
Total Volume of Excavation Material will be Reused : 12,379.51 m3
Total Volume of Excavation Material will be sent to Disposal : 57,284.69 m3
Total Amount of Excavation Material will be sent to Disposal : 103,112.4 ton
Distance within the Plant (unpaved roads) : 0.2 km
Truck Capacity : 26 ton
Total Number of Trips : 103,112.4 ton /26 ton
: 3,965 trips
Number of Trucks :6
Number of Trips per Truck : 661 trips/truck
Total Distance to be travelled (round trips on unpaved roads) : 152 km
Excavation Duration : 240 days
Work Hours in a Day :8
Hourly Excavated Material Amount : 53.70 ton/hour

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 Uncontrolled Dust Emissions:

Emission from excavation:

Excavation emission factor (uncontrolled): 0.025 kg/ton

Amount of PM10 emissions: 53.70 ton/hour * 0.025 kg/ton = 1.34 kg/hour

Loading emission factor (uncontrolled): 0.010 kg/ton

Amount of PM10 emissions: 53.70 ton/hour * 0.010 kg/ton = 0.54 kg/hour

Emission from transportation activities

Transportation emission factor (uncontrolled): 0.700 kg/km-vehicle

Amount of PM10 emissions: 152 km x 0.700 kg/km-vehicle x (1/240 days) x (1/8 hours)
= 0.05 kg/hour

Emission from storage

12,379.51 m3 of excavated soil will be stored for its reuse in the WWTP Area and sewerage
network. The storage height will be 3 m. Thus, required storage area is 4,126 m2, which is 0.41 ha.

Storage emission factor (uncontrolled): 5.8 kg/ha

Amount of PM10 emissions:0.41 ha x 5.8 kg/ha x (1/24 hours) = 0.09 kg/hour

Total uncontrolled PM10 emissions

Total: 1.34+0.54+0.05+0.09= 2.02 kg/hour

Controlled Dust Emissions:

Emission from excavation:

Excavation emission factor (controlled): 0.0125 kg/ton

Amount of PM10 emissions: 53.70 ton/hour * 0.0125 kg/ton = 0.67 kg/hour

Loading emission factor (controlled): 0.005 kg/ton

Amount of PM10 emissions: 53.70 ton/hour * 0.005 kg/ton = 0.27 kg/hour

Emission from transportation activities

Transportation emission factor (controlled): 0.350 kg/km-vehicle

Amount of PM10 emissions: 152 km x 0.35 kg/km-vehicle x (1/240 days) x (1/8 hours)
= 0.027 kg/hour

Emission from storage

Storage emission factor (controlled): 2.9 kg/ha

Amount of PM10 emissions: 0.41 ha x 2.9 kg/ha x (1/24 hours) = 0.04 kg/hour

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 Total uncontrolled PM10 emissions

Total: 0.67+0.27+0.027+0.04 = 1.00 kg/hour

According to the calculations, the total amounts of uncontrolled and controlled PM 10

emissions are expected as 2.02 kg/hour and 1.00 kg/hour, respectively. As stated above, these
emission rates are calculated based on the worst-case scenario. However, it is found that the
emission rate for uncontrolled activities is greater than the limit value defined for non-stack sources
in IAPCR, which is 1 kg/hour. Therefore, mitigation measures defined in this section will be applied
tightly during the construction phase of the Project to keep the impacts related with fugitive dust
emissions in low significance.

Dust will be generated mainly during the excavation works performed for the construction
of the sewerage network, discharge line, pumping stations and WWTP. The sewerage network and
discharge line will follow the cadastral roads and the construction will be performed gradually. For
the pumping stations, construction activities will take place on the route of sewerage network.
Therefore; the receptors will be limited to the vicinity of construction works and these receptors are
presented in Figure V.3. Their sensitivity is assessed as medium, especially the ones in populated
areas (i.e. city centre). The most sensitive receptor to dust is considered as Sitki Kocman
University Fisheries Research and Development Centre, which is located adjacent to the WWTP
site. Additionally, there is a hospital around TM-6 Pumping Station. Therefore, necessary mitigation
measures described in the further sections of this report should be taken to not to impact the
regular operation.

Standards for PM10 (particles with aerodynamic diameter smaller than 10μm) are defined
for particles which are respirable by humans and therefore, PM10 is the accepted measure of
particles in atmosphere. In this context, the Regulation on Air Quality Assessment and
Management defines the standards in terms of PM10.

Regulation on the Assessment and Management of Air Quality (RAMAQ)

Regulation on Assessment and Management of Air Quality was put into force in Official
Gazette dated June, 6 2008 and numbered 26898. With this regulation, the Regulation on
Protection of Air Quality was abolished. Long and short terms standards were specified for the
harmonization of environmental regulations in the process of accession to the European Union.
However, the regulation sets a transition period for the application of these limit values.

Industrial Air Pollution Control Regulation (IAPCR)

Industrial Air Pollution Control Regulation (IAPCR) published in Official Gazette dated July
3, 2009 and numbered 27277 aims to control emissions in form of smoke, dust, gas, vapor and
aerosol which are released to the atmosphere as a result of activities of industrial plants and
energy generation facilities, to protect human beings and the environment from pollution, and to
manage and prevent negative impacts of air pollution which result in significant problems on public
health. With this regulation, the Regulation on Air Pollution Caused by Industry has been abolished.

Ambient air quality limit values for various pollutants defined in above-mentioned
legislations are presented in Table V.9.

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Table V.9 Ambient Air Quality Limit Values – Turkish Regulations

Limit Value*
Parameter Duration
(µg/m3)
Hourly (cannot be exceeded more than 24 times a year) 350
24 hour 125
SO2
Long term limit 60
Annual and winter season (October 1 - March 31) 20
Hourly (cannot be exceeded more than 18 times a year) 250
NO2
Annual 40
24 hour (cannot be exceeded more than 35 times a year) 50
Particulate Matter (PM 10)
Annual 40
CO 8 hour daily maximum 10,000
* Regulation on Assessment and Management of Air Quality
** Industrial Air Pollution Control Regulation

WBG Standards

In addition to the Turkish legislations, the ambient air quality limit values stipulated in the
WBG General EHS Guidelines shall be complied. The WBG General EHS Guidelines –
Environmental Air Emissions and Ambient Air Quality refers primarily to national legislated
standards or in their absence to WHO Air Quality Guidelines. Therefore, the national legislated
standards will be followed.

During the construction phase of the project, the above-mentioned regulations and
standards will be complied with. As a result, when the works to be carried out within the scope of
construction activities and corresponding work load are taken into account, it can be concluded that
the impacts will be low in significance upon implementation of the mitigation measures and
adherence to good construction methods.

The following techniques for the reduction and control of air emissions will be implemented
during the construction phase in accordance with relevant Turkish regulations and international
standards:

 Dust should be minimized from open area sources, including storage piles, by using
control measures such as installing enclosures and covers, and increasing the
moisture content.
 Daily backfilling, bedding and covering materials will be stored at temporary storage
areas, the materials will be moisturized and compacted to prevent the materials moving
with the help of wind.
 Continuous water spraying will be conducted at the WWTP site to minimize dust
impacts on Mugla Sitki Kocman University Fisheries Research and Development,
which is adjacent to the site, and during the works to be performed around TM-6,
where there is a hospital nearby.
 Inner roads of the WWTP will be covered to prevent dust formation.
 Speed limitations will be defined and obeyed for construction vehicles.
 The drop height of potentially dust generating materials will be kept as low as possible.
 Trees will be planted to the borders of WWTP, especially at the east and south
borders.
 When there is traffic flow on the existing roads, where the works performed at, dust
suppression measures will be continuously applied to ensure traffic safety. If there is
no traffic existing in the local roads, dust suppression measures will be applied only at
local residential and business areas.
 Loading and unloading operations will be performed without throwing/scattering.

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  During transportation, excavated materials will be covered with nylon canvas or
materials with grain size larger than 10 mm.
 Exhaust systems of the vehicles will be controlled regularly (biennially) through exhaust
emission decals.
 Modern equipment and tools that can provide EU emission standards during the
construction activities will be selected.
 Work sites will be sprayed regularly, particularly in spring and summer, to reduce the
effects of dust-causing activities such as excavation and backfilling.
 Wind shields/barriers will be placed at work sites, especially at the south and east
borders of the WWTP site and around the TM-6 Pumping Station, to prevent dust
dispersion.
 Relevant provisions of the IAPCR and RAMAQ will be complied with to minimize air
emissions sourced from construction machinery and trucks.
 Tire cleaning ponds will be installed at the exit of WWTP site to prevent mud transport
on roads.
 Any damage caused by insufficient or lack of dust suppression measures (i.e. pollution
of the surrounding area, transportation of dust with wind to a residential area, wind-
blown dust deposits etc.) will be compensated by the construction contractor.

In addition to the fugitive dust emissions, there will be exhaust emissions of heavy
construction machinery. Primary emissions from exhaust gases of vehicles are NO 2, CO, HC, SO2
and PM. Emission characteristics depend on parameters such as; age of the vehicle, engine
speed, working temperature, ambient temperature and pressure, type and quality of fuel. Emission
factors developed by USEPA for gasoline and diesel fuelled vehicles are presented in Table V.10.

Table V.10. Emission Factors (USEPA)

EMISSIONS (g/km/vehicle)
POLLUTANTS
Gasoline Diesel Fuel

Nitrogen oxides (NOx) 1.20 9.00

Carbon monoxide(CO) 39.0 15.0

Sulphur dioxide(SO2) 0.08 1.50

Hydrocarbons (HC) 2.60 2.90

Particulate Matter (PM) 0.40 0.80

The indicative list of construction machinery to be used for the construction activities were
previously presented in Table V.6. Exhaust emissions of the machinery are presented in Table
V.11.

Table V.11. Expected Amounts of Exhaust Emissions (kg/h)

Emissions (kg/hour)
NOX CO SO2 HC PM
0.153 0.255 0.026 0.049 0.014

According to the calculations made, exhaust emissions are quite below the IAPCR limit
values for all parameters. Although no significant exhaust emission is expected during the

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construction phase, a set of mitigation measures that are summarized below and also presented in
Chapter VII will be implemented for further reduction of any related impacts on air environment.

 Well and adequate maintained vehicles shall be used. Regular maintenance of

machinery and equipment will be ensured.
 Construction vehicles will not be permitted to keep engines running while waiting to
enter the site or waiting on-site.
 Relevant provisions of the Regulation on Air Pollution Control Sourced from Industry
and Regulation on the Assessment and Management of Air Quality will be complied
with to minimize air emissions sourced from construction machinery and trucks.

In addition to that only electric poles with a base size of approximately 5m x 5m will be
erected for the energy transmission line. For this reason, excavation works will be limited for the
electric posts and construction activities will be carried out in a short period of time. Therefore,
impacts related to energy transmission line will be low in significance and short-term.

In conclusion, with the implementation of above-listed mitigation measures, Project’s

impacts on air environment will be low, short-term, local/ on-site/project footprint and with low
significance.

Operation Phase

The operation phase of the Project is not expected to cause significant dust and exhaust
emissions. However, as stated in the IFC’s EHS Guidelines for Water and Sanitation, air emissions
from wastewater treatment operations may include hydrogen sulfide, methane, gaseous or volatile
chemicals used for disinfection processes, and bioaerosols. Hydrogen sulfide and methane are
known as odorous gases. Therefore, odor impacts will be observed during the operation phase of
the Project.

During the operation phase, odor is generally generated in physical treatment and sludge
units of wastewater treatment plants. Screens, aeration tanks, sedimentation tanks, sludge
thickeners and dewatering units and operations performed within these units can result in
generation of odor which may result in disruptive impacts around the treatment plant. In addition,
pumping stations can also cause odor emissions even though they will be buried underground and
will have odor removal units with activated carbon filters.

Wastewater influent contains high amounts of organic material. Organic materials are
decomposed into odorous compounds by bacteria in biological treatment process. Activated sludge
contains high amounts of bacteria and organic matter which can be decomposed by bacteria in
short amount of time. Odor is generated as a result of compounds generated during this process.

As stated previously, wastewater treatment operations may emit hydrogen sulfide,

methane, gaseous or volatile chemicals used for disinfection processes, and bioaerosols. Among
those, hydrogen sulfide and methane gases are the most significant odorous gas. Due to the
sludge treatment performed in the WWTP, ammonia, sulphur compounds, fatty acids, aromatic
compounds and some hydrocarbons can also cause odor. Petroleum and organic solvents are also
sources of disruptive odor.

Establishing a buffer zone between the treatment plant and residential areas and isolating
odor is the main method to prevent odor generated in the treatment plant to be dispersed to
settlements. Suggested buffer zone distances between treatment plants units and residential areas
are presented in Hata! Başvuru kaynağı bulunamadı.. Distance of the treatment units to the
nearest residential/commercial area is also presented in the table. As seen below, the nearest

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receptors are in the recommended buffer zone, thus mitigation measures shall be applied seriously
to reduce the nuisance on these receptors.

Table V.12 Recommended Distances to Settlements for Odor Prevention and Nearest Receptors

Treatment unit Buffer zone, m Nearest Building, m

Sedimentation Tank 122 60
Aeration Tank 152 25
Sludge Disposal Units 305 70
Source: Tchobanoglous, 1991

By good operation conditions and relevant measures taken for deodorization, disruptive
odors can be prevented. Below proposed mitigation measures will be implemented in three levels
for the WWTP. The first level measures are as follows:

 Prevention of wastewater influents, which exceed treatment plant capacity.

 Decrease in solid waste and activated sludge amounts.
 Increase disposal frequency of screenings.
 Proper and timely disposal of sludge in order to prevent flies and odor.
 Increasing aeration rate in biological treatment process.
 Addition of chlorinated water to sludge thickeners if activated sludge unit is in open
area.
 Addition of lime to activated sludge.
 Keeping water level under control in order to prevent turbulence as a result of instant
decrease of water.

If odour nuisance prevails after the proper implementation of first level measures, the
second level measures will be taken. These are as follows:

 Plantation of trees in the WWTP site boundaries and the buffer zone around the
treatment plant for the prevention of odor distribution.
 Addition of oxidizing material (such as hydrogen peroxide, sodium hypochloride)
(oxidizing materials, prevent generation of especially hydrogen sulphide). Addition of
sodium hydroxide can also be considered. Sodium hydroxide will dissolve hydrogen
sulphur gas in water.
 Preventing anaerobic bacteria with control of pH levels or disinfection.
 Oxidizing odorous compounds by the help of chemicals.

If nuisance still prevails after implementation of first and second measures, following final
measures will be implemented

 Enclosing of preliminary treatment units, aeration tanks and bio-P tanks.

Apart from that, following mitigation measures will be implemented within the scope of
Project.

 Establishment of an operating grievance mechanism to manage odor related

grievances.
 Maintaining pipelines and ensuring effective management and operation of the
sewerage system including effective maintenance of all elements of the sewerage
system and rapid response to emergencies.
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  Regular maintenance and cleaning works shall be conducted on the machinery and
equipment in order to prevent occurrence of odor.
 Regular and sufficient ventilation at the pumping stations will be provided.
 Trees will be planted around the pumping station areas.

Significant odor related nuisances are not expected to be observed as long as the
measures mentioned above are taken. In addition, in the operation phase of the Project, necessary
action shall be taken to comply with the provisions of Regulation on the Control of Odor-Causing
Emissions. There are no mandatory numerical standards set in Turkey for odor concentration in
ambient air at the site boundary or at receptor locations. If a new regulatory limit value will be set in
the future, the Project shall comply all the mandatory numerical standards.

In conclusion, with the implementation of mentioned mitigation measures, the impact will
be medium, long-term, local and with low significance.

V.4.2 Geology, Soils and Contaminated Land

Construction Phase

There are some geological risks in the construction phase of Oren WWTP as described in
the Soil Investigation Report prepared by GAB Mühendislik ve Danışmanlık Ltd. Şti. Therefore,
MUSKI shall take necessary mitigation measures to minimize risks and related impacts. The risks
are summarized below:

 The groundwater table levels observed in the boreholes drilled in the WWTP site vary
between 2.67 and 4 m.
 The site has a liquefaction potential after 7.5 m depth.

Soil Investigation Report also recommends mitigation measures as presented below to

reduce the stability risks:

 The excavation works should be performed under the supervision of senior

geology/geotechnical engineer.
 To lower the liquefaction potential and support the bearing capacity of ground, piling
options should be developed.
 50 cm thick filling material with suitable grain sizes should be laid under the foundation
of all structures.
 Drainage of site should be ensured.

Through proper implementation of abovementioned crucial measures, it is considered that

the significance of impacts related with liquefaction and ground stability can be decreased from
high to low.

Additionally, according to requirements specified in the Regulation on Soil Pollution Control

and Point Source Contaminated Fields, firstly MUSKI is obliged to notify the Ministry of
Environment, Urbanisation and Climate Change (MoEUCC) regarding to the soil pollution in the
Project Area, according to the procedure defined in the regulation. After that, based on the
inspections that will be carried out by the MoEUCC regarding to MUSKI’s notification, if the site will
be defined as a contaminated site that needs to be cleaned up, the site will be cleaned up by firms
authorized by the MoEUCC and MUSKI will be the responsible entity to ensure clean up. Within the
scope of cleanup activities, following measures will be taken for the contaminated areas during the
construction phase:

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  Vehicles containing any excavated soil will be suitably covered to limit potential dust
emissions, and truck bodies and tailgates will be sealed to prevent any discharge
during transport;
 Only licensed waste haulers will be used to collect and transport contaminated soil to
an appropriate treatment/disposal site and illegal disposal of the soil will be prohibited;
 The use of contaminated soil for landscaping will be prohibited.

Another impact of the construction of the Project is loss of topsoil, which is mostly valid for
the WWTP site since the sewerage system and discharge line will follow cadastral roads and
pumping stations will be buried underground. Therefore, necessary mitigation measures to lower
the impact significance are developed and presented.

In the construction phase of the project, soil contamination may be seen due to accidental
oil leakages in the areas where the works are carried out as well as improper disposal of wastes.
This may affect the soil quality in the project area, if necessary mitigation measures are not taken.
These impacts can be easily managed and mitigated to low in significance.

Additionally, hazardous materials to be used during the construction of energy transmission

lines such as insulating oil/grease, fuel, etc. might cause soil pollution. However, these impacts can
also be easily managed and mitigated to low in significance.

Potential impacts and possible risks on the soil environment in case that necessary
measures will not be taken during land preparation and construction phase of the Project are
summarized below:

 Soil compaction as a result of soil stripping, levelling excavation and filling activities,
work of construction machinery;
 Mixing of soil layers as a result of excavation and filling activities;
 Loss of topsoil at the WWTP site;
 Soil contamination as a result of oil or fuel leaks or spillage that may result from
incidents and unexpected events; and
 Soil pollution which may occur in case of uncontrolled storage or disposal of solid
and/or liquid wastes to be generated within the scope of the Project.
 Erosion potential due to earthworks

The proposed mitigation measures are as follows:

 In order to minimize the impacts on soil environment, the amount of soil that could be
subject to compaction and contamination/pollution will be minimized by ensuring the
use of only the designated work sites and routes for the construction machinery and
equipment and field personnel.
 Wastes and wastewater to be generated during the construction phase of the Project
will be stored and disposed in a controlled manner in accordance with the relevant
regulations, WBG EHS Guidelines and in line with the management practices
described in this report. Thus, it will not be possible for the wastes and wastewater to
be generated in the Project Area interact with the soil environment and cause any
impacts.
 The areas that the construction works take place will be reinstated after the completion
of works.
 By establishing a suitable drainage system in the field, the potential impact of surface
runoff will be minimized. In this context, drainage channels will be constructed in
accordance with the topographical conditions of the site.

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  In order to develop background data on soil contamination status at the WWTP site,
MUSKI or the construction contractor will conduct a soil sampling study at the site
before any activity.
 Topsoil at the WWTP site will be stripped (minimum 30 cm) before any activity on site
and properly stored to be reused for the landscaping works .
 Stripping of topsoil will not be conducted earlier than required to prevent the erosion of
soil (wind and water).
 The disturbed areas and soil stock piles will be kept moist to avoid wind erosion of soil
 Construction activities (especially excavation works) will be undertaken in the dry
weather condition as much as possible.
 The fuel required for the construction equipment and vehicles to be used within the site
during construction phase will be supplied primarily from the nearest station; if deemed
necessary, fuels that may possibly be stored at site will be stored in the areas where
necessary impermeability precautions are taken.
 Measures to be taken in case of leaks and spills that may arise from construction
machinery and vehicles, and unexpected accidents will be described in site-specific
Emergency Response Plan to be prepared.
 The provisions of the Regulation on the Control of Excavation Soil, Construction and
Demolition Wastes shall be complied during land preparation and construction phase
of the Project.
 Following the completion of construction works, the stripped topsoil will be reused
within the project areas, such as landscaping of WWTP and pumping station areas.
 Topography will be restored for stop stabilization immediately after the completion of
construction at each location.
 The excavation works will be performed under the supervision of senior
geology/geotechnical engineer.
 To lower the liquefaction potential and support the bearing capacity of ground, piling
options will be developed.
 50 cm thick filling material with suitable grain sizes will be laid under the foundation of
all structures.
 For the amount of the topsoil that cannot be reused will not be wasted and the unused
topsoil will be transferred to locations close to the current topsoil storage area by
consulting with the potential users; farmers, livestock owners.
 In case of a damage caused to the existing roads, community assets, individual’s crops
and assets during land preparation and construction phases, the construction
contractor will compensate the losses by identifying damage in accordance with the
WB’s safeguards with the supervision of MUSKI. MUSKI’s grievance mechanism will
be used in the event of any damage or loss.
 A Soil Management Plan should be prepared prior to the construction phase.
 An Oil and Chemical Spill Contingency Management Plan should be prepared prior to
the construction phase.
 Provisions of the Regulation on the Control of Soil Pollution and Sites Contaminated by
Point Sources shall be complied within the scope of the Project.

Project’s anticipated impacts on geology, soils, and contaminated land are assessed as
low in significance.

Operation Phase

In the operation phase of the Project, the activities will have a limited physical interaction
with the environment. In the operation phase of the Project, no additional significant direct impacts
on topography, soil and land use are anticipated under normal operating conditions. Impacts of
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operation phase of the Project are related with the risks arise during repair and maintenance works,
such as spillage/leakage of wastewater, oil, and chemicals to soil and the permanent land use
change at the WWTP site, which is not used for any purpose before this Project. Therefore, the
impact significance is determined as negligible.

V.4.3 Surface Water Resources

Water Supply during Construction Phase

During the construction phase, employees’ needs and dust suppression will create water
supply requirement. The drinking water needs of employees will be fulfilled by bottled water to be
purchased from the local market and the domestic water required will be met by water trucks until
the network connections are constructed. For dust suppression and tire cleaning, water will be
provided to site by water trucks with sprinkler system. The total amount of daily water requirement
is calculated based on the multiplication of number of employees that will be working at the peak
time of the phase and the daily water requirement for a person, which is 0.23 m3 (TurkStat, 2018).
Although the number of personnel required is not determined yet, it is assumed as 100. Therefore,
the daily water requirement of employees during the construction phase will be;

100 employees x 0.23 m3/employee.day=23 m3/day

Together with the amount of water required for dust suppression and tire cleaning, which
are predicted to be 10 m3/ day, the total water requirement during the construction phase will be 43
m3/day.

The quality of drinking water that will be supplied to the Project shall be in compliance with
the Regulation Concerning the Water Intended for Human Consumption together with the
internationally accepted standards, such as WHO and WBG’s General EHS Guidelines.

Water Supply during Operation Phase

During the operation phase of the Project, the drinking water will be procured from the local
market, and for the other needs the tap water will be used as the connections to the water network
will be constructed. The total amount of water required by employees is calculated as in the
previous section. Although the number of personnel required is not determined yet, it is assumed
as 10. Therefore, the daily water requirement of employees during the operation phase will be;

10 employees x 0.23 m3/employee.day=2.30 m3/day

In addition to the daily needs of the personnel, there will be operational water
requirements, and these are presented together with the Project’s water requirement according to
its phases in Table V.13.

Table V.13. Water Requirement of the Project

Water Requirement
Project Phase Intended Use
3
m /h m3/day m3/year
Drinking water / Tap
Construction 0.96 23.00 8,395
water
Construction Dust Suppression 1.25 10.00 3,650
Construction Tire Cleaning 1.25 10.00 3,650
Drinking water / Tap
Operation 0.10 2.30 840
water

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 Discharge of Treated Effluent

Domestic wastewater discharge criteria to the receiving bodies are regulated under Urban
Wastewater Treatment Regulation Annex-IV Table 1 and Table 2. The discharge limits given in the
regulation are presented below in Table V.14.

Table V.14 Domestic Wastewater Discharge and Treatment Efficiency Criteria

Parameters Concentration (mg/L) Minimum Treatment Efficiency (%)

BOD5 25 70-90
COD 125 75
TSS 35 90
TP 2 80
TN 15 70-80

Currently, there is no WWTP in Oren and the generated wastewater is either discharged
uncontrollably to receiving bodies or sent to the nearest WWTPs after pumped-out from septic
tanks by sewer trucks. The realization of the Project will enable MUSKI to manage the collection,
treatment and discharge of wastewater in Oren. The wastewater that is collected by sewerage
network and sent to Oren WWTP for treatment will be discharged to Hanay Creek after reaching
effluent concentrations and minimum treatment efficiencies given in Table V.14. Therefore, the
realization of the Project will positively affect the environment as well as public health.

Impacts on Surface Water

Construction Phase

In the construction phase of the Project, the water requirement will be very low. Since the
water demand/requirement within the scope of the Project will be provided/supplied by water
network which will be connected at the beginning of the construction period and by purchasing from
the market, a direct impact on surface water within the AoI of the Project is not expected.

Also, during the construction phase of the WWTP tire cleaning ponds will be inserted to
both entrance and exits of the construction site. The water found in the cleaning ponds will never
be discharged into the environment under any circumstances; the water will be collected in
leakproof containers and will be disposed in a proper way.

Construction activities may pose the potential for accidental release/leakages of petroleum-
based products, such as lubricants, hydraulic fluids, or fuels during their storage, transfer, or use in
equipment. All chemical storage containers, including diesel fuel, and hazardous liquid waste
drums/containers should be placed in secondary containment so as to minimize the risk of soil,
surface water and groundwater contamination during construction.

In the construction phase of the project the impact will be direct and negative with short -
term duration, local and negligible significance.

Operation Phase

During the operation phase of the Project, the regular maintenance works to be performed
on sewerage network, discharge line and pumping stations might create impacts similar to the ones
in construction phase. In Oren WWTP’s operation on the other hand, there will be storage of some
chemicals such as acids, bases, disinfectants, lubricants, etc. All storage tanks and drums will be

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placed on concrete areas with proper secondary containments. When necessary; spill kits,
absorbent pads or materials and adsorbent sands will be provided near the chemical storage areas
at all times. On the other hand, generated wastewater will be given to the influent of the WWTP. In
terms of water quality, the WWTP discharge will be in compliance with the discharge standards
defined in Urban Wastewater Treatment Regulation of Turkey. Additionally, due to the multiple
parallel units in the WWTP, possible negative consequences arising from the failure of any of the
units will be prevented by enabling the use of the parallel unit. It is unlikely that two units will fail at
the same time, so it is unlikely that creek quality will be affected. However, during the longer
shutdowns or failures, MUSKI will inform Provincial Directorate of Environment, Urbanisation and
Climate Change regarding the situation. With these measures, potential releases to environment,
an adverse impact to soil, surface water, and groundwater will be prevented.

In terms of flooding, there is no flood risk in Milas-Oren according to the models prepared
within the scope of the Western Mediterranean Basin Flood Management Plan studies (Ministry of
Agriculture and Forestry General Directorate of Water Management, 2019. Western Mediterranean
Basin Flood Management Plan). On the other hand, wastewater discharged into the creek might
change the hydrology of the stream. However, during the site visit the width of the creek bed which
is approximately 45 meters, was found to be sufficient for effluent discharge. Therefore, the creek
bed can handle the flow.

To conclude, operation phase impacts of the Project is generally found to be positive on

water resources. However, measures should be taken to prevent any unexpected deterioration on
the receiving water quality. During the operation phase of the project the impact will be direct and
positive with long term duration.

Mitigation Measures

Water to be used in dust suppression during land preparation and construction phase of
the Project will be absorbed by soil or lost by evaporation. Therefore, there will not be any surface
runoff formation or wastewater generation due to watering for dust suppression.

Within the scope of the measures to be taken in order to protect the water resources in the
region, the limited amount of domestic wastewater generated at site will be collected in the
container of toilet cabins to be established or leak-proof septic tanks to be constructed in the
Project Area during construction phase and will be sent to the nearest WWTPs after pumped-out
from septic tanks by sewer trucks. No discharge will be made to water resources in the land
preparation and construction within the scope of the Project.

In the operation phase of the Project, the following measures will be taken:

 In order to develop background data on water quality, MUSKI or the construction

contractor will conduct water quality measurements at the Hanay Creek before any
activity on site.
 MUSKI will minimize bypass of the treatment system.
 An Emergency Response and Preparedness Plan to be developed and implemented
 The water quality of Hanay Creek will be monitored regularly, and if deemed,
necessary further mitigation measures will be developed.
 The effluent water quality of the wastewater treatment plant will be consistent with
applicable national requirements or internationally accepted standards.
 MUSKI will search options to increase the effluent water quality based on the
assimilative capacity of the receiving body, if needed.
 Broken pipes and other repairs to be undertaken without delay,
 Pumps and pumping stations to be adequately maintained,
 System overflows will be prevented as much as possible by using level-meters.

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 In all phases, the Project will follow the provisions of the national legislation together with
WBG EHS Guidelines and good international practices.

V.4.4 Groundwater Resources

Construction Phase

In construction phase, the major impact on groundwater may be seen due to accidental oil
leakages in the areas where the works with construction machinery are carried out as well as
improper disposal of wastes. This may affect the groundwater quality in the project area, if
necessary mitigation measures are not taken. However, it can be said that the impacts will not be
significant upon implementation of the mitigation measures and adherence to good engineering
methods.

It is assessed that in the construction phase of the Project, the impact significance will be
negligible.

Operation Phase

The impacts on groundwater resources in the operation phase will be similar to the ones of
the construction phase. The impacts will be mostly related with the accidental spills/leakages and
poor management of generated wastes and sludge. The impacts will be low and negligible in
significance upon adherence to good engineering methods.

Mitigation Measures

Within the scope of the measures to be taken in order to protect the water resources in the
region, the limited amount of domestic wastewater generated at site will be collected in the
container of toilet cabins to be established or leak-proof septic tanks to be constructed in the
Project Area during construction phase and will be sent to the nearest WWTPs after pumped-out
from septic tanks by sewer trucks. No discharge will be made to water resources in the land
preparation and construction within the scope of the Project.

The units of the Project that are in touch with water, wastewater and chemicals will be
constructed with using concrete with appropriate cement ratio and durability in order to provide
basement impermeability. Thus, no leakages to soil and groundwater will occur during the
operation phase of the Project.

In all phases, the Project will follow the provisions of the national legislation together with
WBG EHS Guidelines and good international practices.

V.4.5 Noise and Vibration

A noise measurement study was conducted at the Project area in order to measure the
background noise level of the area. When the baseline study results are compared with the
standards given in national legislation and WBG EHS, it can be seen that the background noise
levels are generally in compliance. However, nighttime measurements are already above the limits
that are defined in WBG General EHS Guidelines: Environmental Noise. The high measurement
results might be related with traffic. Therefore, noise impacts should not result in a maximum
increase in background noise levels of 3 dB at the nearest receptor location off-site within the
scope of Project activities according to the WBG General EHS Guidelines and noise limit values of
RAMEN should also be complied with according to national legislation.

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 Construction Phase

The project activities within the construction phase are associated with a range of activities
that generate noise. The noise would be potentially generated by transportation vehicles,
machinery and outdoor equipment used for preparation of the terrain, trenching and drilling.

The indicative list of machinery and equipment, which will be used during the land
preparation and construction phase and are likely to cause noise, and their number and noise
intensity levels are presented in Table V.15.

Table V.15. Machinery and Equipment and their Noise Intensity Levels (Lw)

Machinery and Equipment Number Noise Intensity Level* (dBA)

Truck 6 85
Excavator 2 115
Loader 2 115
Mini Loader 3 115
Crane 2 105
Sprinkler 1 85
Grader 1 111
Source: Industrial Noise Control and Environmental Noise, Ozguven H.N.

In order to assess the noise impacts of the activities that will be conducted during phase,
the total noise generations should be calculated for the worst-case scenario and should be
compared with the national legislative and WBG EHS Guidelines requirements. To satisfy this
need, noise generation calculation is performed below with the assumption of worst case scenario.
The worst case scenario assumes that all machines and equipment operates simultaneously at
maximum noise intensity levels at the same location in the Project Area.

The formulas given below were used for the calculation of noise levels regarding land
preparation and construction phase of the Project. Formula (1) is used to calculate total noise level
at the source according to noise intensity level of each equipment, Formula (2) is used to calculate
the noise level that reaches a definite distance (Lpt), and Formula (3) used to include topographical
absorption effect into consideration.

Lwt = 10 log ∑𝑛𝑖=1 10Lwi/10 (1)

Lpt = Lwt + 10log (Q/4πr2) (2)
C1 = 5xlog(do/d) (3)

Lwt : Noise level at the source

Lpt : Noise level that reaches a defined distance
Q : Orientation coefficient/atmospheric reduction factor (assumed as 1)
r : Distance from the source
C1 : Topographical noise absorption
d : Distance

As it is mentioned before, in the equations given above, it is accepted that construction

equipment and machinery are used at the same physical location, non-stop at maximum noise
intensity levels (worst case scenario). Therefore, it is expected that in reality noise level caused by
construction activities will be much smaller than the worst case scenario calculation result.

Lwt = 10 log ∑𝑛𝑖=1 10Lwi/10

= 10 log (6x108.5+2x1011.5+2x1011.5+3x1011.5+2x1010.5+1x108.5+1x1011.1)
Lwt = 123.8 dBA

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 The calculation of noise level that reaches to the nearest residential building (which is 50 m
away from the border of the WWTP area) is as follows:

Lpt = Lwt + log (Q/4πr2)

Lpt (50m) = 123.8+10 log(1/4x3.14x502)
Lpt (50m) = 78.8 dBA

Topographical absorption for 50 m:

C1 = 5xlog(do/d)
C1 =5xlog(1/50)
C1 =-8.49 dBA

Lpt at 40 m by taking into consideration of topographical absorption

Lpt (50m) total= Lpt (50m) + C1

Lpt (50m) total= 78.8 dBA -8.49 dBA
Lpt (50m) total= 70.3 dBA

The distribution of noise generated with respect to distance from the source is presented in
tabular format in Table V.16 and graphically in Figure V.5. Environmental noise level decreases
below the regulatory limit value defined for construction activities (70 dBA) at a distance about 138
m from the source.

Table V.16. Distribution of Noise Generated Relative to Distance

Lpt with topographical Lpt with topographical

Distance (m) Lpt (dBA) Distance (m) Lpt (dBA)
absorption (dBA) absorption (dBA)
15 89.3 83.4 500 58.8 45.3
50 78.8 70.3 600 57.3 43.4
100 72.8 62.8 700 55.9 41.7
138 70.0 59.3 800 54.8 40.2
150 69.3 58.4 900 53.7 39.0
200 66.8 55.3 1000 52.8 37.8
300 63.3 50.9 1500 49.3 33.4
400 60.8 47.8 2000 46.8 30.3

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Figure V.5 Distribution of Noise Generated in the Project Area with respect to Distance

As seen from the above, under the worst case conditions, noise level near the closest
building to the center of the WWTP Area caused by the construction phase of the Project is above
regulatory limit values. In addition, the noise that will be generated at the site will cause a
cumulative impact on the background noise level by reaching the nearest building at different
levels. In this context, the cumulative noise level expected at the settlement is calculated
numerically by logarithmically adding of the noise resulting from the construction activities to the
background noise level measured at the settlement. The cumulative noise at the receptor is given
in Table V.17.

Table V.17. Estimated Noise Level around the Nearest Residential Building

Calculated Cumulative Noise WBG

Background Noise Level (dBA) RAMEN
Measurement Construction Level (dBA) Residential
Noise Limit
Location Noise Level at Noise Limit
RAMEN Periods WBG Periods RAMEN WBG (dBA)
50 m (dBA) (dBA)
Daytime Daytime
53.8 53.7 70.3 70.3 68 55
(07-19) (07-22)
NML-1
(50 m northeast Evening 53.1 70.3 70.3 63
of the border of (19-23) Night
the WWTP Area) 50.6 70.3 45
Night (22-07)
50.2 70.3 58
(23-07)

As seen from the Table V.17, while the cumulative noise level of the nearest receptor is
above the limit values given in Turkish RAMEN. In addition to RAMEN, the calculated cumulative
noise levels exceed the limits defined by WBG General EHS Guidelines. In that case, necessary
measures defined below shall be taken to decrease the noise level at the nearest receptor.

On the other hand, it is unlikely in reality that all construction machinery and equipment are
used at the same physical location and non-stop at maximum noise intensity levels (worst case
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scenario). In addition, as the construction activities will occur outdoors, it is expected that there will
be a decrease in noise level depending on the distance due to the atmospheric reduction in real
conditions. Similarly, vegetation cover is among the factors that could reduce the impact during the
spread of noise. However, since calculations are based on the worst case approach, factors such
as effect of location, atmospheric reduction, vegetation cover, etc. have not been taken into
consideration. According to all these evaluations, it is expected that in real terms the noise level at
the nearest building will be lower than the calculated value during construction activities of the
Project.

As the noise to be generated at the Project Area during construction activities could have
an impact beyond the borders of the Project Area during certain times of the construction phase
and the background noise level at certain parts of the neighborhood could increase within the limit
values of RAMEN and WBG EHS Guidelines.

In addition to that only electric poles with a base size of approximately 5m x 5m will be
erected for the energy transmission line. For this reason, excavation works will be limited for the
electric posts and construction activities will be carried out in a short period of time. Therefore,
impacts related to energy transmission line will be low in significance and short-term. As explained
above, if any of the electric poles or transmission lines hit or pass-through private parcels or private
users on public lands, a RAP, consistent with the Project RPF, will be prepared by MUSKI ahead of
the civil works and access to private lands.

In order to prevent noise transmission following mitigation measures will be taken:

 A Noise Management Plan that is in line with the OP/BP 4.01 Environmental
Assessment and WBG EHS Guidelines (both general and sector specific) will be
prepared by the construction contractor prior to the construction phase.
 Construction noise barriers will be used at north-eastern boundary of the WWTP site
and around the TM-6 Pumping Station and by doing so, around 5 to 10 dBA noise
reduction would be achieved at the receptor.
 Trees will be planted to the WWTP site, especially its north-eastern boundary, and
around the pumping stations.
 It will be ensured that machinery and equipment will not be operated together in the
close section of the WWTP Area to nearest building (north-eastern boundary) so that
the noise level at the nearest buildings does not exceed the regulatory and WBG
General EHS Guidelines limit values as it is calculated so.
 Attention will be given to the selection of equipment with low noise level.
 The maintenance of the construction machinery and equipment will be carried out
regularly and regulatory speed limitations will be followed for construction vehicles and
this should be included in the construction site transport and traffic management plan
to be prepared by the contractor.
 The works will be performed day-time; no night work unless it is absolutely necessary.
 A grievance mechanism will be established to manage noise related grievances as
well.

Vibration that will affect humans or the structures in the vicinity is not expected to occur as
there will be no blasting activity within the project.

Operation Phase

During the operation phase of the Project, noise will be generated from WWTP equipment
such as engines, compressors, pumps and blowers. The level of noise generated from the
equipment is expected to be constant as all equipment will be in operation during the plant
operation hours (24 hours). Equipment generating noise during the operation of the plant will be

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located in isolated closed buildings and some of them will be submerged in wastewater. So, no
significant noise is expected to be generated during the operation of the WWTP. However, as the
nearest building to the WWTP is 50 m away, natural noise barriers such as trees should be planted
to the east and south borders of the WWTP. During the procurement of equipment and machinery,
sound levels given in the technical specifications/data sheet will be taken into consideration.
Moreover, relevant provisions and limit values of national legislations and World Bank Group’s
General EHS Guidelines and Sectorial Guidelines will be complied with during the operation phase.

On the other hand, all pumping stations will be built underground and building materials
that provide sound insulation will be used. Also, machinery and equipment at the pumping stations
will be in enclosed structures. Therefore, no significant impact is expected from the pumping
stations regarding noise generation. However, regular maintenance activities will be carried in
order to ensure that.

The impact is assessed as direct and negative with long term duration, local and low in
significance.

V.4.6 Biological Environment

In this section, potential impacts of the proposed construction activities for the Project on
the biological environment are considered. These impacts could be in effect during both the
construction and operation phases of the project. Potential impacts will affect terrestrial and aquatic
flora-fauna directly or indirectly. Therefore, impacts of project activities can be further divided into
the target group of biological elements as terrestrial.

The following subsections define the potential impacts of the project considering the
foreseen project activities during construction and operation. The potential impacts are assessed
for terrestrial and aquatic flora and fauna. Mitigation measures to be taken in order minimize these
impacts are also included in the assessments.

The impact of project activities on ecological components is related to the size of the
impact and the vulnerability of the recipient. For terrestrial flora-fauna species, size and
significance of the effects according to the matrices presented below have been determined in
accordance with the criteria determined according to the ecological sensitivities of the species. It is
known that the features of each step in the systematic classification of species are different from
each other and accordingly the shapes and dimensions of the influence from the Project will vary
within themselves. Sensitivities of terrestrial flora and fauna species determined within the Project
Area are explained in detail in the report. Criteria for significance for ecological components are
explained in following topic.

Impact Assessment Criteria

The impact assessment criteria for the impacts on ecology and biodiversity were
determined, as high, moderate or low, based on the evaluation of magnitude of impact and
sensitivity/value of the receptors/resources. OP 4.04 definitions are used in habitat and species
assessments. These definitions are explained step-by-step.

According to OP 4.04, Annex A, Natural Habitats, Critical Natural habitats, Significance

conversion and Degradation defined as:

“Natural habitats are land and water areas where (i) the ecosystems' bio-logical
communities are formed largely by native plant and animal species, and (ii) human activity has not
essentially modified the area's primary ecological functions. All natural habitats have important
biological, social, economic, and existence value. Important natural habitats may occur in tropical
humid, dry, and cloud forests; temperate and boreal forests; Mediterranean-type shrub lands;

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natural arid and semi-arid lands; mangrove swamps, coastal marshes, and other wetlands;
estuaries; sea grass beds; coral reefs; freshwater lakes and rivers; alpine and sub alpine
environments, including herb fields, grasslands, and paramos; and tropical and temperate
grasslands. “

“Critical Natural habitats: (i) existing protected areas and areas officially proposed by
governments as protected areas (e.g., reserves that meet the criteria of the World Conservation
Union [IUCN] classifications), areas initially recognized as protected by traditional local
communities (e.g., sacred groves), and sites that maintain conditions vital for the viability of these
protected areas (as determined by the environ-mental assessment process); or (ii) sites identified
on supplementary lists prepared by the Bank or an authoritative source determined by the Regional
environment sector unit (RESU). “

Significance conversion: Such sites may include areas recognized by traditional local
communities (e.g., sacred groves); areas with known high suitability for bio-diversity conservation;
and sites that are critical for rare, vulnerable, migratory, or endangered species.

Listings are based on systematic evaluations of such factors as species richness; the
degree of endemism, rarity, and vulnerability of component species; representativeness; and
integrity of ecosystem processes.

Significant conversion may include, for example, land clearing; replacement of natural
vegetation (e.g., by crops or tree plantations); permanent flooding (e.g., by a reservoir); drainage,
dredging, filling, or channelization of wetlands; or surface mining. In both terrestrial and aquatic
ecosystems, conversion of natural habitats can occur as the result of severe pollution.

Conversion can result directly from the action of a project or through an indirect mechanism
(e.g., through induced settlement along a road).

Degradation is modification of a critical or other natural habitat that substantially reduces

the habitat's ability to maintain viable populations of its native species.”

Based on these criteria, sensitivity criteria for ecological components within the scope of
the project have been determined as given in Table V.18.

Table V.18 Severity of Impacts on Resource/Receptor

Ecosystem Severity of Impact

Component High Medium Low
Internationally Recognised
Areas (e.g. UNESCO Natural
World Heritage Sites,
UNESCO Man and the
Biosphere
Designed Areas Reserves, Key Biodiversity Nationally designated areas. N/A
Areas, and wetlands
designated under the
Convention on Wetlands of
International Importance (the
Ramsar Convention))
Habitats is natural or critical
natural habitat under the OP
4.04 definitions and/or
Areas of habitat that represent Natural habitats that do not
Habitats that trigger critical
>1% distribution within meet the criteria for either
habitat under the following
Turkey or are threatened at a medium or high sensitivity.
Habitats IFC PS6 Criteria:
national level.
Habitats that support species Habitats that support species
 Criterion 4: Highly
of Medium sensitivity. of Low sensitivity.
threatened and/or unique;
and/or ecosystems
 Criterion 5: Key

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 Ecosystem Severity of Impact
Component High Medium Low
evolutionary processes
Habitats that support species
of High sensitivity
Species populations that Nationally/regionally important
trigger critical habitat under concentrations of a
the Vulnerable (VU) species, or
following IFC PS6 Criteria: locally important
concentrations of Critically Locally important populations
Endangered (CR) and/or of Near Threatened (NT) or
 Criterion 1:Critically
Endangered (EN) species. Vulnerable (VU) species, or
Species Endangered (CR) and/or
Locally important populations locally important populations
Endangered (EN) species;
of endemic/range restricted of species listed on Annexes
 Criterion 2: Endemic
species. to the Bern Convention.
and/or restricted-range
Populations of migratory
species; and/or
species that represent >1 %
 Criterion 3:Migratory of the national (Turkish)
and/or congregator species. population.

Construction Phase Impacts on Ecology

In the construction phase of a project some direct or indirect impacts could be occurred.
The loss of habitat and biodiversity are the most important examples to direct impacts. However,
the planned Project will be realized in an already modified area. There is not any critical natural
vegetation which harbours wildlife, so there will not any sensitive habitat and vegetation loss during
the Project construction activities.

Another direct impact of the construction phase will be the vehicle traffic for construction.
The fauna species which have limited mobility will be prone to fauna mortality. The risk of crushing
will increase as the animals cross the road.

Indirect impacts of construction include disturbance in terms of noise and visual nuisance
and pollution. Some of the secondary impacts have been identified as changes in the composition
of soil and water quality, changes in air quality (dust generation, etc.), wastes to be generated due
to project activities and noise pollution that might impact species’ behaviour especially that of fauna
elements.

Internationally and National Recognized Areas

IFC PS6 states that internationally and/or nationally recognized areas of high biodiversity
value are likely to be qualified as critical habitat. The closest natural protected area is Gokova
Special Protected Area and the closest KBA-IBA is Datca-Bozburun Peninsula KBA and IBA.
Although this seems to be ecologically important, it is obvious that the biological structure of the
project area and its immediate environment does not provide the characteristics of the protected
areas. In addition there are not any AZE sites within and around the Project Area. The impact of
construction activities on Internationally and National Recognized Areas is assessed as negligible.

Terrestrial Flora

The most major impacts of this kind of projects on the terrestrial environment are generally
habitat and vegetation loss or damage. However Project will be built in semi-natural area with poor
vegetation. There are a lot of settlements in the vicinity of project area. Therefore, there are no
sensitive habitats or flora species and such an effect will not be the issue.

The effects of the construction activities will include dust. These effects may soon lead to
effects on plant species within the vicinity of the project area, but none of these effects will have a

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lasting effect on species. When necessary measures are taken and after the construction activity is
over, it is expected that the composition of the plant species will return to its original state in time.

According to the OP 4.04 “Natural habitat” definition, land part of the project area does not
have any natural habitat and wild life. To conclude, the impacts on the biological environment
during construction will be limited. It is considered that all the impacts will be minimized or
eliminated completely if necessary precautions are taken. The impact of construction activities on
terrestrial flora species is assessed as negligible.

Terrestrial Fauna

There are poor vegetation and settlements in the immediate vicinity of the project area.
This makes mammals and bird species not preferring these areas. However, the effects of
construction activities on fauna species in the region can be seen. These effects will mostly consist
of secondary effects. Due to the construction activities, mortalities may be observed due to
disturbed fauna species and traffic congestion. At the same time, dust and noise formation due to
construction activities may also have a negative impact on fauna species. All these effects can be
eliminated by taking appropriate measures. The impact of construction activities on terrestrial fauna
species is assessed as negligible .

Aquatic Environment

Hanay Creek, where the discharge will be made, is a creek that has lost its natural
characteristics due to anthropogenic effects. However, due to the construction activities, it is likely
that destruction in the physical and chemical properties of the species constituting the aquatic
biodiversity might occur. These impacts can be reduced to a low level with the relevant mitigation
measures. The impact mitigation measures to be taken on this issue are presented in the following
sections.

Operation Phase Impacts on Ecology

The negative impact of the project's operational activities on terrestrial flora and fauna is
not expected. When necessary preventive measures are taken, natural life will continue in its
former state.

In addition, during the operation, the receiving body will be free from intense pollution due
to the treated effluent discharge. This will be an important step towards conserving biodiversity and
protecting the water quality of the Hanay Creek. With the Project, the treated water will be
discharged to receiving body with nitrogen and phosphorus removal through the advanced
biological treatment process. Therefore, it is considered that the effect on the species in the
environment will be at the minimum level. This is considered as the most important positive impact
of the project on the biological environment.

Mitigation Measures

The mitigation measures to be taken to the possible impacts on the terrestrial biologic
environment from the Project activities during the construction and operation phases are given
below.

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 Terrestrial Environment

 Prior to the land preparation phase, definite working areas will be set up where
activities (e.g. vegetation clearing, vegetation removal, leveling and construction) and
permanent structures (units and roads) will be established,
 Project construction sites and access roads will be separated from other areas with
appropriate signboards, signs and fences. Therefore, staff and vehicle access to the
area will be limited to the construction site,
 Avoid and/or minimize dust emissions by lightly watering the immediate surroundings
of construction sites, and wetting the stored material,
 Construction waste generated due to project activities will first be stored at designated
storage areas and then disposed,
 Construction work will be done gradually so that it will have enough time to escape for
possible fauna species to be found,
 If there is a nest of birds species, the nest should be marked with a safety strip about 3
meters in diameter and an expert ornithologist should be informed,
 If there is a species that has limited mobility, transfer to safer locations if encountered
during construction,
 Measures to reduce noise are provide in Chapter V.4.5 Noise for details,
 Measures to reduce dust and air pollution are provide in Chapter V.4.1 Air Quality for
details,
 Project workers will not be allowed to bring any live animals or plants into the
construction site to avoid the risk of pest/invasive species establishing in the Project
Area,
 Construction and operation sites will be fenced in order to prevent fauna species’
entrance into these areas.

Aquatic Environment

The following mitigation measures are recommended in order to minimize the potential
impacts of the Project on aquatic species:

 Mixing any chemical substances, that is used in the construction area, in waterbed
and/or aquatic ecosystems will be prevented.
 Excavation materials will not be dumped onto riverbed.
 Especially during the breeding season of fish species (April-June), any intervention on
riverbed will be prevented.
 The natural structure of the riparian vegetation will be preserved which forms the
spawning and sheltering area for many aquatic organisms.
 Monitoring studies in Hanay Creek will be conducted in operational phase with aquatic
biologist on appropriate seasons, as appropriate.

In case any construction sources impact on rivers and/or streams within the scope of the
Project, following criteria of water quality should be taken into consideration and should be
monitored for the continuity of aquatic species.

 Water temperature is one of the most important factors impacting the life in aquatic
ecosystems and it changes according to seasons, circulation of air and depth. Increase
in temperature decrease the gas solubility (such as oxygen and corbondioxide) in
water (Polat, 1997). In addition, increase in temperature can cause change in density
and also viscosity of water. Beside, temperature affects species distribution, feeding,
spawning and general behavior.
 Dissolved oxygen (DO) is another parameter that is recommended to be continuously
monitored during the construction and operation phases of the Project. It is quite

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 important for organisms that are dependent on aerobic metabolism. Amount of
dissolved oxygen decreases with increasing temperature and organic matter
concentrations. It increases with increasing air pressure (Yaramaz, 1992). In addition,
factors like salinity and flow rate also affect amount of dissolved oxygen (Wetzel,
1983).
 Electrical conductivity (EC) value, which defines the electrical transmission capability of
water ions, and it is directly changes with many parameters such as anion, cation, salt
density, temperature, akcalinity, dissolved solids in the water. Besides, Bremond et
Vuichard (1973) states that electrical conductivity is an indicator of dissolved matter
and fluctuates between 150 and 750 µS/cm in inland waters suitable for fish species.
When it reaches a concentration of 3,000 µS/cm, it causes disruption of ecological
balance in water.
 One of the water quality parameters is pH, which is an indicator of acidic and basic
characteristics of water. It is very important in terms of fish life and productivity.
Freshwater fish usually prefer pH levels between 6.5 and 8.5.

V.4.7 Landscape and Visual (Aesthetics)

Construction Phase

During construction phase of the project, due to the nature and location of the works, there
will be impairment of quality of life. All the sewerage network and pumping station works will be
performed in the city centre and this will create nuisance for the people living or working nearby the
sites. However, the impacts will be short-term. In order to mitigate, which are assessed to have
medium significance, the sewerage network and discharge line construction works will be limited to
day-time only. Moreover, the construction plan will be disclosed to the public and this will also ease
the traffic planning. Therefore, the impact significance after implementation of mitigation measures
would be low.

As for the construction of the WWTP, discharge line and energy transmission line, the
impacts of the works will again be short-term. In order to mitigate the impacts of the construction of
the WWTP the construction works will be limited to day time similar to the sewerage network. In
order to reduce the nuisance for the people residing in the area the construction plan of the WWTP
will be shared with public and the public will be informed about the issues regarding the traffic.
Since the pumping stations will be built underground, no impact on landscape and visual is
expected by them.

Operational Phase

In operational phase, the aesthetics impacts will be mostly related with the WWTP and
energy transmission line, which will be a permanent impact. Pumping stations will be buried and
built on public lands registered as park. Landscaping of pumping stations will be conducted
compatible with the existing landscape of the park areas and trees will be planted, as appropriate.
In order to decrease the impacts of WWTP, it is recommended MUSKI to plant trees at the borders
of the plant and paint the visible buildings to colours suits to the background.

V.4.8 Resources and Wastes

As a result of the use of resources, construction and operation/maintenance activities as

well as domestic requirements of the personnel, different types of wastes will be generated
throughout the life of the Project.

All the wastes to be generated during the land preparation and construction and operation
phases of the Project are required to be properly managed in line with the requirements of national

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waste management legislation and international good practice in order to avoid impacts on soils,
nearby water resources and flora and fauna elements. This Chapter identifies the wastes to be
generated in this context and assesses the impacts associated with waste generation. Waste
management measures to be applied in accordance with relevant Turkish regulations and
international standards (i.e. WBG EHS Guidelines) are also described in this Chapter. The potential
impacts on the physical, biological and socio-economic environment in the construction and
operation phases of the Project, as well as measures to prevent/minimize these effects have been
elaborated in detail.

The possible sources that will generate various type of waste are listed below:

 Municipal solid waste

 Packaging waste such as wood, paper, cardboard, and plastic etc.
 Hazardous and special wastes that may be generated within the scope of the land
preparation and construction and operation phases of the Project can be listed as
contaminated vessels, cloths and overheads, waste batteries and accumulators, waste
oils etc.
 Excavation and construction wastes
 Final sludge

Wastes to be generated in the scope of project activities will be managed in accordance

with the waste management hierarchy as given in Figure V.6. In this respect, waste generation will
be avoided/prevented at the source. In cases where prevention is not possible at the source,
respectively; minimization of waste generation, selection of materials that will not cause generation
of hazardous waste as much as possible, separate collection of wastes according to their type
(hazardous, non-hazardous, recyclable, etc.), reuse of generated wastes at site as much as
possible, assessment of alternatives such as recycling and energy recovery for wastes (where
reuse is not possible) will be considered. The final step in the hierarchy of waste management
involves the final disposal of wastes in accordance with relevant regulations, where reuse,
recycling and energy recovery options are not possible.

Figure V.6. Waste Management Hierarchy

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 Construction Phase

During construction phase of the Project, activities such as vegetation clearance, levelling,
construction and installation of main operation and auxiliary units, procurement, transportation and
assembly of units and equipment will be carried out. Solid waste types expected to be generated
within the scope of these activities are; municipal wastes, packaging wastes of system equipment
(e.g. wood, cardboard, plastic, etc.), hazardous wastes, special wastes, excavation and
construction wastes (e.g. scrap metal, wood, concrete waste, etc.), and waste system equipment
(panels, cables, electronic components). Hazardous and special wastes might contain chemical
substances (e.g. paint, solvent) or packaging materials and cloths contaminated with oils, waste
oils resulting from operation and maintenance of machinery and vehicles, solvents, accumulators,
batteries, filters, machine parts. These kinds of wastes will be stored in special compartments in
the Temporary Storage Area allocated for this purpose, in containers, separated from the non-
hazardous wastes. This area will have an impermeable base/ground and will be protected from the
surface flows and rain. Additionally, necessary drainage for the area will be provided. Hazardous
wastes will be collected and disposed of by companies licensed by the Ministry of Environment,
Urbanization and Climate Change.

Table V.19 lists the types of wastes that can be generated during the construction phase of
the Project and their waste codes according to the waste lists given in the annexes of the Waste
Management Regulation

Table V.19. List of Possible Waste Types to be Generated during Land Preparation and Construction Phase of the
Project

Waste Code Definition of Waste Code

13 Oil Wastes and Liquid Fuel Wastes (Excluding Edible Oils, 05 and 12)
13 02 Waste Engine, Transmission and Lubrication Oils
15 Waste Packages, Unspecified Absorbents, Wipes, Filter Materials and Protective Clothing
15 01 Packaging Wastes (Including Packaging Wastes Separately Collected by the Municipality)
15 02 Absorbents, Filter Materials, Cleaning Cloths and Protective Clothing
16 Wastes Not Specified Otherwise in the List
16 06 Batteries and Accumulators
17 Construction and Demolition Wastes (Including Excavations from Contaminated Sites)
17 01 Concrete, Brick, Tile and Ceramic
17 02 Wood, Glass and Plastic
17 04 Metals (Including Alloys)
17 05 Soil (Including Excavations from Contaminated Sites), Stones and Dredging Sludge
17 09 Other Construction and Demolition Wastes
Municipal Wastes Including Separately Collected Fractions (Domestic and Similar Commercial,
20
Industrial and Institutional Wastes)
20 01 Separately Collected Fractions (Except 15 01)
20 03 Other Municipal Wastes

Solid waste management studies in Mugla province continue within the framework of
Waste Management Regulation. In the province, solid wastes collected by Bodrum, Dalaman,
Datça, Fethiye, Kavaklıdere, Köyceğiz, Marmaris, Menteşe, Milas, Ortaca, Seydikemer, Ula and
Yatağan Municipalities are stored by the Metropolitan Municipality in a total of six Solid Waste
Landfills in Datça, Fethiye, Milas, Marmaris, Menteşe and Ortaca in Muğla Province.

Municipal wastes within the scope of the Waste Management Regulation are referred to
domestic wastes or commercial, industrial and institutional wastes similar to domestic wastes in
terms of its content or structure, which are defined with waste code of 20, in the Waste List given in
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Annex-4 of the Regulation and of whose management responsibility belongs to the municipality.
Therefore, these types of wastes will be stored separately from hazardous wastes and recyclable
wastes and will be collected regularly by Milas Municipality. Milas Solid Waste Landfill Facility of
Muğla Metropolitan Municipality is located in Milas district. The facility serves in Bodrum and Milas
districts and the wastes generated in these districts are stored. Milas Solid Waste Landfill Facility is
arranged in 2 lots and will be able to meet the 25-year need of the region. The facility has a storage
volume of 1 million 235 thousand 186 cubic meters and 250 tons of waste per day can be disposed
of at the facility. The infrastructure of the Milas Municipality is sufficient for managing the wastes
produced in the Project site.

In addition, a pre-treatment facility will be established in the facility area, where waste with
economic value in mixed waste will be separated. In this way, it is aimed to use the facility for a
longer period by reducing the amount of stored waste.

In order to determine the amount of municipal wastes to be generated at site, the average
daily municipal waste per person is taken as 1.08 kg according to the municipal waste statistics of
TURKSTAT in year 2014 (TURKSTAT, 2014). The estimated amount of municipal waste to be
generated during the construction phase of the Project, based on the number of people working, is
given below. This amount includes also separately collected fractions such as paper, cardboard,
glass, metal, plastic, etc. together with biodegradable wastes:

 100 persons x 1.08kg/person.day=108 kg/day

There will be no cafeteria in the construction site. Thus, there will be no food preparation
related waste generation within the context of the Project. The food will be supplied through
catering services.

The general composition of the municipal waste in Turkey is as demonstrated in Figure V.7
according to the results of the solid waste composition determination study made within the scope
of the Solid Waste Master Plan Project. 34% of municipal waste consists of kitchen wastes.
Separately collectable and recyclable fractions such as paper, cardboard, bulk cardboard, plastic,
glass and metal constitute 25% of municipal waste.

Figure V.7. Composition of Municipal Waste (former Ministry of Science, Industry and Technology, 2014)

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 Considering the information provided in Figure V.7, it is also valid for the municipal wastes
to be generated within the scope of the Project. The only difference will be the kitchen waste
percentages since there will be no kitchen/cafeteria in the Project. By reflecting this and the
assumption of only 5% food waste, the composition of the municipal waste will be as follows:

 Food Waste : 5%
 Other Combustible : 27%
 Other Non-combustible : 31%
 Paper : 16%
 Cardboard : 2%
 Bulky Cardboard : 6%
 Plastic : 3%
 Glass : 8%
 Metal : 2%

Now, it can be said that approximately 5.4 kg of food wastes and 40 kg of separately
collectable and recyclable wastes will be generated daily during the construction phase of the
Project.

Waste vegetable oil will not be generated at site during the construction activities as meals
for the staff will be provided by catering companies. Waste tire generation and storage will not take
place due to the fact that the tire changes of the construction machines and other vehicles to be
used at this stage will be carried out at the facilities in the region providing service for this purpose.
Besides, there will not be any significant amount of medical waste generation at site within the
scope of the Project, as there will no infirmary in the project site and Oren Primary Care Clinic will
be used for possible medical interventions in case of an incident during the activities. The negligible
amount of medical waste generation might happen as a result of the first-aid applications.

Vegetation clearing and levelling works will be carried out at certain locations in order to
flatten the area during the construction phase of the Project. For all activities regarding excavation
storage, transport and reuse; provisions of Regulation on the Control of Excavation, Construction
and Demolition Wastes will be complied.

The construction machinery will require oil changes during the land preparation and
construction phase of the Project, at least once in every two-month period of the phase. Oil
changes of the construction machinery will be carried out at services licensed for the maintenance
of the machinery. Thus, there will be no waste oil generation in the land preparation and
construction phase of the Project.

The annual amount of waste battery per person in Turkey is six and this value corresponds
to 140 grams (Ministry of Environment and Forestry, General Directorate of Environmental
Management, 2009). According to this, the annual waste battery production of 100 people to be
employed during the construction phase of the Project is calculated as 14 kg.

No significant impact resulting from waste generation is expected due to the nature and
scale of the Project, as explained above. Therefore, the impact is assessed as direct and negative
with short term duration, local and low significance. However, mitigation measures proposed in the
following sections in order to prevent and/or minimize likely impacts will be implemented such as:

 Wastes to be generated within the scope of the Project will be managed in accordance
with the waste management hierarchy.
 Wastes will only be temporarily stored on site and final disposal will be carried out
outside the facility

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  Removal of the excavated material, which will not be used for backfilling, from the site
at regular intervals without waiting These materials will be transferred to Municipality’s
permitted excavation waste storage sites by licensed transportation companies.
 Waste recycling, transport and disposal will be carried out by means of licensed
companies and/or related municipalities.
 Incineration or burying of wastes by any means at site and/or dumping of wastes to
nearby roads or water resources will absolutely not be in question.
 All kinds of implementations that may threaten personnel or public health will be
avoided in all activities involving collection, temporary storage, transport and disposal
of wastes throughout the Project.
 Wastes to be temporarily stored on site will be delivered to licensed transport vehicles
appropriate to the type of waste for disposal. Information related to the operations in
this context will be recorded and the records will be kept in the administrative building.
 Hazardous or non-hazardous inscription, waste code, stored waste amount and
storage date will be indicated/labelled on wastes temporary stored by classifying
according to their properties. The reaction of wastes with each other will be prevented
by the measures (impermeable base, drainage, top cover, different compartments
based on type of wastes, etc.) taken in the Temporary Storage Area. The permit for the
Temporary Storage Area will be obtained from the Muğla Provincial Directorate of
MoEUCC.

Operation Phase

In the operation phase, there might be waste generation resulting from damaged,
malfunctioned or end-of-life equipment and material that could be replaced or controlled during
maintenance and repair activities to be performed periodically or in case of a breakdown. Also,
procurement of new equipment, pieces and others will also result generation of packaging waste.
Besides, personal protective equipment, clothes and rags used during maintenance and repair
activities might result a limited amount of waste generation. Milas Solid Waste Landfill Facility is
arranged in 2 lots and will be able to meet the 25-year need of the region. The facility has a storage
volume of 1 million 235 thousand 186 cubic meters and 250 tons of waste per day can be disposed
of at the facility. The infrastructures of the Milas Municipality is sufficient for managing the wastes
produced in the Project site.

10 workers will be employed in the project's operation phase. Therefore, municipal waste
generation will be 13.5 kg/day and using the same approach as in land preparation and
construction, the recyclable portion of the municipal waste and the amount of food waste will be 10
kg/day and 1.35 kg/day, respectively. In addition, in addition to recycling municipal waste,
recyclable waste such as packaging waste, paper, cardboard, plastic and scrap metals are
expected to be taken into account.

In the operation phase of the Project, due to the oil change needs of equipment such as
blowers, there will be limited amount of waste oil generation.

Table IV.17 lists the waste types and waste codes that may occur during the operational
phase of the Project, according to the waste lists given in the Waste Management Regulation's
Annex.

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Table V.20 List of Possible Waste Types to be Generated During Operation Phase

Waste Code Definition of Waste Code

13 Oil Wastes and Liquid Fuel Wastes (Excluding Edible Oils, 05 and 12)
13 02 Waste Engine, Transmission and Lubrication Oils
13 03 Waste Insulation and Heat Conduction Oils
15 Waste Packages, Unspecified Absorbents, Wipes, Filter Materials and Protective Clothing
15 01 Packaging Wastes (Including Packaging Wastes Separately Collected by the Municipality)
15 02 Absorbents, Filter Materials, Cleaning Cloths and Protective Clothing
16 Wastes Not Specified Otherwise in the List
16 02 Electrical and Electronic Equipment Waste
16 06 Batteries and Accumulators
Waste from Waste Management Facilities, Offsite Wastewater Treatment Plants and Water Preparation
19
Facilities for Human Consumption and Industrial Use
19 08 Wastewater Treatment Plant Wastes Not Described otherwise
Municipal Wastes Including Separately Collected Fractions (Domestic and Similar Commercial,
20
Industrial and Institutional Wastes)
20 01 Separately Collected Fractions (Except 15 01)
20 03 Other Municipal Wastes

The most important waste that will be generated as a result of the activities of the WWTP is
sludge together with the screenings. The solid content of the sludge that will be generated will be
increased through sludge dewatering and drying units. The water that will be extracted from the
sludge cake will be sent back to the inlet of the WWTP. After dewatering, the sludge cake will be
transferred to a covered and appropriate container through the belt conveyor. After that, the excess
sludge will be analysed to determine compliance with the Annex-2 of the Regulation on Landfilling
of Wastes and if it is deemed appropriate, the sludge will be collected by the licensed disposal
companies determined by MUSKI every year. After that, the sludge will be disposed in accordance
with the provisions of Urban Wastewater Treatment Regulation and other relevant legislation.
According to the information retrieved from MUSKI, the sludge will be transported by competent
and licensed firms to the landfill which has enough capacity. Sludge will be stored in the landfill.

If sludge would be determined as hazardous, the sludge will be sent to Anadolu Tehlikeli
Atik Depolama Sanayi ve Ticaret A.Ş. for disposal by competent and licensed firms.

The impact is assessed as direct and negative with long-term duration, on-site and low in
significance. Mitigation measures proposed in the following sections in order to prevent and/or
minimize likely impacts will be implemented such as:

 Wastes to be generated within the scope of the Project will be managed in accordance
with the waste management hierarchy.
 Wastes will only be temporarily stored on site and final disposal will be carried out
outside the facility
 Waste recycling, transport and disposal will be carried out by means of licensed
companies and/or related municipalities.
 Incineration or burying of wastes by any means at site and/or dumping of wastes to
nearby roads or water resources will absolutely not be in question.
 All kinds of implementations that may threaten personnel or public health will be
avoided in all activities involving collection, temporary storage, transport and disposal
of wastes throughout the Project.
 Wastes to be temporarily stored on site will be delivered to licensed transport vehicles
appropriate to the type of waste for disposal. Information related to the operations in
this context will be recorded and the records will be kept in the administrative building.

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  Hazardous or non-hazardous inscription, waste code, stored waste amount and
storage date will be indicated/labelled on wastes temporary stored by classifying
according to their properties. The reaction of wastes with each other will be prevented
by the measures (impermeable base, drainage, top cover, different compartments
based on type of wastes, etc.) taken in the Temporary Storage Area. The permit for the
Temporary Storage Area will be obtained from the Muğla Provincial Directroate of
MoEUCC.
 A Sludge Management Plan and Waste Management Plan will be prepared and
implemented, and more sustainable alternatives for sludge disposal will be researched
by MUSKI.

V.4.9 Climate Change

According to IPCC Guideline for National Greenhouse Gas Inventories, waste sector
includes the following components:

 Solid waste disposal (4A)

 Biological treatment of solid waste (4B)
 Incineration and open burning of waste (4C)
 Wastewater treatment and discharge (4D)
 Other (4E) (IPCC, 2006)

In scope of this report, components 4A and 4B and partly components 4C, 4D and 4E are
investigated. According to 2007 data, waste sector is the second highest source of greenhouse gas
emissions in Turkey. However, there is no inventory on greenhouse gas emissions from generation
and disposal of WWTP sludge.

In addition, activities which are subject to greenhouse gas monitoring, reporting and
verification are presented under heading “Activities subject to monitoring, reporting and verification
of greenhouse gas emissions” in Annex-1 of the Regulation on Tracking Greenhouse Gas
Emissions (dated May 17, 2014, Official Gazette No: 29003), and any of the components of this
Project are not listed in Annex-1 of the Regulation.

Construction Phase

The Project’s contribution to the climate change during the construction phase will be due
to the emission of GHG. The majority of greenhouse gas emissions will be due to construction
machinery/equipment usage. The major greenhouse gas emission will be CO 2 emissions resulting
from the combustion of petroleum-based products, like gasoline, in internal combustion engines.
Relatively small amounts of methane and nitrous oxide will also be emitted during fuel combustion.
Therefore, these emissions will contribute to the climate change.

The project’s contribution to the climate change through GHG emissions is assessed as a
negative and direct impact. The impact’s extent will be regional and duration will be short-term.
Although the sensitivity of the receptor is considered as medium, due to the usage of small number
of construction machinery/equipment, the significance of the impact is considered as low.

With the realization of proper mitigation measures, GHG emissions can be minimized.

Within this regard, the following measures are suggested to mitigate the potential impacts
of the project on climate change through greenhouse gas emissions:

 Construction operations of the project will be in line with good industrial practices.
 Speed restrictions and equipment to optimize fuel efficiency will be adopted by
construction vehicles.
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  Regular maintenance of construction vehicles and equipment will be applied.
 Energy uses associated with construction vehicles and equipment will be monitored.
 Trainings will be performed on project personnel regarding energy efficiency

Operation Phase

The project’s contribution to the climate change during the operation phase will be similar
to the one explained for the construction phase and the significance of the impact will be low. In the
operation phase, usage of fossil fuel burning equipment/machinery (including procurement of
materials) usage will be limited.

GHG emissions generated operation phase of the project can be considered as relatively
short term emissions. With the realization of proper mitigation measures, GHG emissions can be
minimized.

Within this regard, the following measures are suggested to mitigate the potential impacts
of the project on climate change through greenhouse gas emissions:

 Operations of the project will be in line with good industrial practices.

 Trainings will be performed on project personnel regarding energy efficiency.

V.5 Impacts on Socioeconomic Environment

Improvement of the existing roads or establishment of new access roads is not foreseen
within the scope of the Project as both components will use existing cadastral roads.

The construction phase of the Project will last for 24 months (18 months for WWTP, 24
months for sewerage network) hence; vehicle load on existing traffic infrastructure will be
somewhat significant. However; as part of the Project, existing traffic volume will be affected only
during transportation of the excavation materials and receiving the relevant technical equipment.
During the construction phase of the Project, the traffic access will be interrupted. The major impact
of the works will be the ones related with the traffic.

In the operation phase of the Project, main traffic load contributions will be observed due to
the sewage trucks of the close vicinity neighbourhoods, which have no connection to sewerage
network, and recycle and disposal companies’ trucks. It is anticipated that accumulation of sludge
cake and other disposable and/or recyclable wastes will be slow. Thus, the operation phase
impacts on transport network are considered as negligible.

Moreover, since the Project is located in a touristic area, the impacts on the tourism should
also be assessed. The impact on tourism enterprises and local businesses during the construction
will only be temporary and anticipated to be insignificant. Roads might be closed for a short-time,
therefore, tourism enterprises and local businesses will not be significantly affected during the
construction phase.

Within this regard, a project specific SEP will be prepared by MUSKI as well. The SEP will
include a robust stakeholder engagement and active management programme which enables
regular updates on construction progress and activities to all Project Affected Parties, including
reference to the Project Grievance mechanism to enable the prompt addressal of any issues which
may arise. Within this respect, any party who may potentially be significantly affected by temporary
economic displacement, will be identified within the SEP and regular engagement/communication
will be undertaken with these parties.

Additionally, in case of an any unforeseen delays in the Project that could impact on the
project timeline and ultimately impede access to local businesses which may subsequently lead to
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related potential livelihood impacts, a RAP (consistent with RPF) will be prepared and
implemented. The RAP will also consider an appropriate response to any potential temporary
economic displacement as a result of the construction programme.

On the other hand, as stated before in the present case, there is no wastewater treatment
plant in the region. The hotels and other tourism complexes located in the region solve their
wastewater problems by their own means. For these facilities, the most common solution is to
install a package treatment plant followed by a septic tank. However, the summerhouses located in
the region are dealing with the problem in a primitive way, such as septic tanks. During the
withdrawal of these tanks by sewage trucks, odor and leakage of the wastewater occur quite
frequently. While this method is creating environmental nuisance among the residents of the
region, it also causes financial and managerial burden. It is envisaged that the realization of the
Project will positively contribute to the residents and investors of the region.

Mitigation Measures

Within this regard, the following measures are suggested to mitigate the potential impacts
of the Project on socioeconomic environment:

 In case any road, facility, building etc. will be damaged due to the activities originating
from the construction activities the necessary maintenance, improvement and
compensation works will be done by the Contractor promptly in accordance with the
responsible authority.
 Prior to construction activities, the Contractor will install all signs, barriers and control
devices needed to ensure the safe use of the road by traffic and pedestrians, as
required by the transport and traffic management plan to be prepared.
 The Contractor will take and ensure the implementation of necessary precautions in
terms of road traffic safety along the road by cooperating with the relevant
authority/administration. In addition, precautions will also be taken in the entry and exit
of the treatment plant.
 Local authorities and residents in a working area will be consulted and informed before
any detours for construction or diverted public traffic are established
 Trucks, trailers and other vehicles to be used to transport necessary equipment and
materials will be provided to comply with the speed limits. MUSKI will ensure that the
Contractor will comply with Highways Traffic Law, Road Transport Law and the
regulations issued in compliance with these laws, as well as WB policies, standards,
and guidelines.
 Signs, crossing guards and other appropriate safety features will be incorporated at
grade level rail and road crossings.
 Disruptions to traffic and road transport will be minimized. The contractor shall ensure
that the roads remain open to traffic during construction activities.
 Disposal sites and haul routes will be identified and coordinated with local officials.
 Construction vehicles will use temporary roads constructed for that purpose to
minimize damage to agricultural land and local access roads. Where local roads are
used, they will be maintained and reinstated to their original condition after the
completion of work.
 MUSKI will ensure that the contractor will prepare and implement a Transport and
Traffic Management Plan during the construction phase.
 MUSKI will ensure that a Waste Management Plan prepared and implemented during
both construction and operation phases.
 MUSKI will disclose construction plan to the public. This will help people to know when
there will be interruptions in traffic and on which roads the access will be limited.
 At the beginning of construction activities, a MUSKI Representative will conduct face to
face meetings with the tourism enterprises and local businesses in order to inform

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 them about the usage of grievance mechanism for the cases of significant income
losses.
 The construction activities around the tourism enterprises will be performed at off-
season (October 15-May 15), to the extent possible.

Apart from that, the necessary measures regarding the COVID-19 Pandemic will be taken
during both construction and operation phases of the Project such as;

 Guidance, directives and recommendations of Republic of Turkey Ministry of Health,

Republic of Turkey Ministry of Family, Labor and Social Services, and World Health
Organization shall be followed and all relevant necessary measures shall be taken in
case of an outbreak of any other pandemic/communicable disease including COVID-19
 Preparation and implementation of site-specific contingency / emergency / crisis
management / action plan regarding COVID-19 and any other
pandemic/communicable disease risk. Contingency plans should consider
arrangements for the storage and disposal arrangements for medical waste, which may
increase in volume and which can remain infectious for several days (depending upon
the material). To ensure that individuals roles and responsibilities are clear,
contingency plans should be communicated widely.
 Provide regular trainings to workers on COVID-19 symptoms, how to be protected and
what to do when symptoms appear.

V.6 Labour and Working Conditions

This section presents application of WB OP/BP 4.01 and WBG General EHS Guidelines for
the Project.

Although the number of personnel to be recruited is not yet decided it is estimated 100
workers will be employed during construction and 10 will be employed for operation. During
recruitment the priority will be given by MUSKI and contractors to local people during the
recruitment process.

On the overall, labour and working conditions for the construction and operation phase
include the issues listed below:

 Working Conditions and Management of Worker Relationship

 Protecting the Work Force
 Occupational Health and Safety
 Workers Engaged by Third Parties and the Supply Chain

Commitments on labour and working conditions are concluded with a range of mitigation
measures for managing labour-related risks and impacts.

The legal frame for the chapter can be drawn with two major national laws relevant to the
Project:

 The Labour Law (Act. No. 4857) which regulates the relations between an employer
and an employee;
 Occupational Health and Safety Law (Law No: 6331) which regulates management of
all occupational health and safety issues

Turkish Labour Law and related regulations covers the basic principles of international
labor standards and the OP/BP 4.01 and WBG General EHS Guidelines in the issues of equal
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treatment of employees, restrictions on the working age and employment of children, avoidance of
forced labour and ensuring occupational health and safety at the workplaces. Monitoring of the
implementation is essential to ensure full compliance of the activities with the relevant legislation.

Turkey has ratified a broad range of International Labor Organization (ILO) Conventions
including the following:

 Forced Labor Convention

 Minimum Age (Industry) Convention (Revised)
 Labor Clauses (Public Contracts) Convention
 Protection of Wages Convention
 Right to Organize and Collective Bargaining Convention
 Equal Remuneration Convention
 Social Security (Minimum Standards) Convention
 Abolition of Forced Labor Convention
 Discrimination (Employment and Occupation) Convention
 Equality of Treatment (Social Security Convention)
 Workers' Representatives Convention
 Minimum Age Convention
 Human Resources Development Convention
 Tripartite Consultation (International Labor Standards) Convention
 Occupational Safety and Health Convention
 Termination of Employment Convention
 Occupational Health Services Convention
 Safety and Health in Construction Convention
 Safety and Health in Mines Convention
 Worst Forms of Child Labor Convention
 Protection Framework for Occupational Safety and Health Convention

The requirements defined in the Turkish Occupational Health and Safety Law regarding the
HR Policy will be fulfilled in accordance with the ILO conventions.

V.6.1 Working Conditions and Management of Worker Relationship

MUSKI will ensure that the contractors and sub-contractors provide workers with
documented information that is clear and understandable, regarding their rights under national
labor law; including collective agreements, their rights related to hours of work, wages, overtime,
compensation, and benefits as of start-up of working relationship and when any material changes
occur.

MUSKI will ensure that the contractors and sub-contractors will not discourage workers
from electing worker representatives, forming or joining workers’ organizations of their choosing, or
from bargaining collectively, and will not discriminate or retaliate against workers who participate,
or seek to participate, in such organizations and collective bargaining.

MUSKI will pay particular concern on principles of non-discrimination and equal

opportunity. In this respect, MUSKI will not make and ensure that the contractors will not make
employment decisions (i.e. recruitment and hiring, compensation, wages and benefits, working
conditions and terms of employment, access to training, job assignment, promotion, termination of
employment or retirement, and disciplinary practices) on the basis of personal characteristics
unrelated to job requirements. Wages, work hours and other benefits shall be per the Turkish Labor
Law.

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 MUSKI will provide a grievance mechanism for workers to raise workplace concerns.
MUSKI will inform the workers about the grievance mechanism at the time of recruitment and make
it easily accessible to them.

V.6.2 Protecting the Work Force

MUSKI will ensure measures to prevent child labour and forced labour. In this respect,
children under 18 years of age will not be employed during construction and operation stages.
Contractors will develop an age verification system to ensure no one under 18 years old are
involved in hazardous works.

Stipulations of Ministry Circular on Covid-19 Measures to be taken at Construction Sites

will be followed during all phases of the Project as long as the COVID-19 pandemic outbreak
prevails.

V.6.3 Occupational Health and Safety

Construction stage of the Project includes assembling works for equipment and the use of
duty vehicles in this scope. As described in the WBG EHS Guidelines for Water and Sanitation;
work at sanitation facilities is often physically demanding and may involve hazards such as open
water, trenches, slippery walkways, working at heights, energized circuits, and heavy equipment.
The nature of the work may also involve entry into confined spaces, including manholes, sewers
pipelines, storage tanks, wet wells, digesters, and pump stations.

Before the commencement of the construction works, contractor will prepare a site-specific
Emergency Preparedness and Response Plan and Occupational Health and Safety Management
Plan for the Project based on construction site OHS risk assessment in line with the Turkish
Legislation and international standards such as ILO standards inclusive of:

 Regulation on Occupational Health and Safety (Official Journal of 09.12.2003; No:

25311)
 Regulation on Occupational Health and Safety in Construction Works (Official Journal
dated 05.10.2013; No: 28786)
 Regulation on the Use of Personal Protective Equipment in Workplaces (Official
Journal dated 25.04.2013; No: 28628 – amended: 24.04.2017; No: 30047)
 Regulation on the Procedures and Principles of Occupational Health and Safety
Trainings of Employees (Official Journal dated15.05.2013; No: 28648)
 ILO Conventions including Occupational Safety and Health Convention (No. 155),
Occupational Health Services Convention (No. 161), and Safety and Health in
Construction Convention (No. 167)
 WBG EHS General and Sector-specific Guidelines

In addition to preparing its own OHS management plan, the contractor will also ask the
subcontractor to prepare an OHS management plan in line with the Project’s OHS requirements.
These requirements will be added to the bid documents to be prepared for construction tenders.

OHS Plan for the construction phase will include the measures listed below in order to
prevent accidents and risks but not limited to:

 All Project staff shall comply with the environmental, health and safety policies and
guidelines.
 An OHS Management Plan will be prepared before the commencement of works that
will also cover measures to address COVID-19 and/or any other
pandemic/communicable disease risk.
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  In order to minimize the risks and hazards that may arise (e.g. natural disasters,
accidents, equipment malfunctions etc.) on human health and safety, safe working
environments in the working sites will be established and physical hazards and risks
will be prevented.
 The relevant plans and procedures of the relevant Turkish legislation and the MUSKI
will be complied within the OHS measures and practices.
 Employees will be informed about the hazards that may cause from their work and thus
a safer work environment will be created.
 Training will be given to employees according to the Regulation on the Procedures and
Principles of Occupational Health and Safety Trainings. In this context, a training
program will be prepared, training records will be kept and evaluation activities will be
carried out after the trainings.
 Personal protective equipment will be provided to all employees and necessary training
will be given for their use.
 Work areas will be equipped with warning signs (e.g. "Hazard", "Entry Prohibited", etc.)
in accordance with the quality and potential risks of the work to be performed in that
area.
 All necessary precautions will be taken in the Project Area to prevent possible fires
from construction activities. Uncontrolled fires in and out of the field will be prevented.
 Smoking in areas where there is a risk of fire will be prohibited. All employees must
have knowledge of what to do in the event of a fire.
 Project staff will include first aid trained personnel. In case of emergency where an
intervention is required, personnel will be sent to the nearest health centre by
appropriate means.
 The Contractor will apply the sufficiency of the technical requirement of the machinery,
equipment, and tools to be used in the activities.
 Moving parts of machinery and equipment will be equipped with appropriate protective
systems (e.g. metal shields etc.), minimizing the risk of injury or damage to the person
using the machine or equipment.
 Personal factors that may create and control risks during activities (e.g. long hair,
jewellery and accessory use, clothing etc.) will be removed from the site by the
regulations brought by the field management. Project staff will be informed about the
relevant regulations within the scope of the training program.
 Drivers and operators will be trained to comply with traffic rules and to control the
vehicles and equipment they use against risks and hazards originating from vehicle
traffic. Required traffic signs will be placed in the Project Site and its surroundings.
Machine operators and other employees will be informed and alerted about the
relevant signs. The wastes to be generated within the scope of the construction phase
of the Project will be managed under the Waste Management Regulation and the
negative impacts on public health will be minimized.
 Areas where excavation work is to be carried out will not be accessible other than the
authorized personnel. The loading and unloading activities shall be carried out together
with the persons to oversee the personnel to carry out the activity.
 Persons and/or organizations with the necessary permits will be assigned to ensure the
security of the Project Area, especially the WWTP site. These persons and/or
organizations shall regularly monitor the facility and its surroundings. The special
security applications and officials’ authorities within the scope of the Project shall
comply with the provisions of Regulation on the Implementation of the Law on Private
Security Services and the Law on Private Security Services.
 In addition to safety personnel, monitoring of the WWTP site for security purposes will
be provided by a closed circuit camera system that will be installed at appropriate
distances on the site boundary (e.g. 30-40 m) to provide daytime and night-time
monitoring of the whole area.
 Since the works will be performed at areas close to the public, the public access to
these areas shall be restricted by any means. If a trench needed to be left open for

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 night, the sufficient illumination of the area shall be ensured by MUSKI and necessary
signs shall be placed, and the area shall be enclosed with barriers.
 An adequate OHS organizational structure will be defined, as defined by the local
legislation and necessary number of OHS officers should be assigned to be at the site
during working hours.
 A risk assessment will be done before commencing the works and personnel will be
trained regarding any potential risks.
 OHS Personnel will daily inspect the site and if any additional risk is observed relevant
plans and trainings will be renewed.
 Emergency Preparedness and Response (EPR) Plan to cover the issues about the
contagious diseases as well as COVID-19 pandemic will be prepared and
implemented.
 MUSKI will ensure that the contractors will have code of conduct (CoC) and this CoC
will be signed during the start of the work. Employees should be trained/informed on
the rules that apply on site grounds in particular to interaction with local community.
 Where a worker may be exposed to any chemical, physical or biological hazard to such
an extent that her/his health may be adversely affected, appropriate preventive
measures shall be taken, including:
o Replacing dangerous goods with harmless or less dangerous substances
where possible
o Applying technical measures to the plant, machinery, equipment or process
o Where it is not possible to comply with above measures, applying other
effective measures, including the use of personal protective equipment and
protective clothing
 Where workers are required to enter any area in which a toxic or harmful substance
may be present, or in which there may be an oxygen deficiency, or a flammable
atmosphere, adequate measures shall be taken to guard against danger.
 The wastes will not be destroyed or disposed of in a way that is harmful to health in the
construction site.

Mitigation measures that will be taken during the operation phase are listed below:

 The whole WWTP site will be fenced, the access of local people and wildlife will be
controlled and encroachment will be prevented. The entry of personnel and third
parties into the facility will be carried out in a controlled manner.
 Personal Protective Equipment will be provided for the workers according to the nature
of work to be performed. The necessary trainings will be carried out for their use.
 Smoking will be prohibited where the risks of fire is high. All the workers will be
informed about the action plan in a case of fire
 All equipment will be operated in proper working order.
 Procedures approved by the MUSKI in the maintenance and repair activities and the
requirements of the technical specifications of the supplier companies will be complied
with.
 The necessary health and safety signs and traffic signs will be placed around the
project site. Employees will be informed and alerted about the subject matter markings.
 Trainings will be given to employees and operational and maintenance personnel
within the scope of the Regulation on Procedures and Principles of Occupational
Health and Safety Trainings and measurement and evaluation activities will be carried
out after the trainings.
 Entrance of operation and maintenance personnel and third parties will be carried out
in a controlled manner.
 Equipment that meets international standards in terms of electrical performance and
safety will be used.

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  After the plant is constructed, necessary electrical test will be carried out to check that
the electrical connections and other related equipment are made properly before the
plant is taken into operation.
 An Emergency Preparedness and Response Plan including the issues about the
contagious diseases as well as COVID-19 pandemic will be prepared before the plant
is taken into operation.
 Automatic cleaning screens should be used instead of manually cleaning screens to
prevent entrance of cleaning workers into the channels.
 Appropriate ventilation systems should be installed at where methane accumulation is
expected.
 Railings will be installed around all tanks and pits.
 MUSKI will prepare a Confined Spaces Entry Procedure that is consistent with WBG
EHS Guidelines and applicable national requirements.
 MUSKI will conduct trainings for operators who work with disinfectants regarding safe
handling practices and emergency response procedures.
 MUSKI will distribute sufficient number of personal gas detection equipment to its
employees.
 MUSKI will advise individuals with asthma, diabetes, or suppressed immune systems
not to work at the treatment plant and its auxiliary facilities due to greater risk of
infection.
 MUSKI will ensure the compliance of all the activities with national standards and WBG
EHS Guidelines.
 The OHS Management Plan will be prepared before the commencement of the WWTP
that will also cover measures to address COVID-19 and/or any other
pandemic/communicable disease risk.
 An adequate OHS organizational structure will be defined, as defined by the local
legislation and necessary number of OHS officers should be assigned to be at the site
during working hours.
 A risk assessment will be done before commencing of the WWTP and personnel will
be trained regarding the risks.
 OHS Personnel will daily inspect the site and if any additional risk is observed relevant
plans and trainings will be renewed.

V.6.4 Workers Engaged by Third Parties and the Supply Chain

MUSKI will ensure that subcontractors are reputable and legitimate enterprises and have
an appropriate ESMS that will allow them to operate in a manner consistent with the labor
conditions provided by MUSKI.

MUSKI will monitor the performance of subcontractors such that human rights policy and
labor rights of all workers are exercised properly.

MUSKI will ensure that workers of subcontractors have access to the overall grievance
mechanism to be established for the Project.

MUSKI will monitor its primary supply chain for safety issues related to supply chain
workers, and where necessary MUSKI will introduce procedures and mitigation measures to
ensure that suppliers are taking steps to prevent or to correct life-threatening situations.

In order to realize those, MUSKI will prepare a Contractor Management Plan and ensure its
implementation.

MUSKI shall ensure that the impacts and measures defined by this ESIA and the relevant
ESMP are followed by the Contractor.

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 In the event of any significant incident (e.g. environmental, social, labor or lost-time
incidents) the Contractor shall immediately notify MUSKI and MUSKI shall inform ILBANK and WB
within three business days. Then, within 30 days, a report on the root causes of the incident and
the corrective actions to be taken will be presented to ILBANK and WB.

V.6.5 Labour Influx

In case when personnel or material or services required for the works to be carried out in a
construction project cannot be sourced from local sources; technical personnel with adequate
capacity or materials that meet international standards must be brought from outside the project
area. In such cases, suppliers, potential suppliers and potential jobseekers might move to the close
vicinity of the project area to provide goods and services to the Project and create an influx in the
region. In order to call this situation as workforce influx, which can be observed in any project,
people who will work on the project or provide goods and services to the project should be settled
quickly in the region. In such a case, people who settle in the area due the project may have a
negative impact on the local population (especially if the area is rural, remote and small).

As mentioned earlier, 100 employees in the construction phase and 10 employees in the
operation phase is expected to be employed. In order to avoid the negative impacts of the
workforce influx, MUSKI will give priority to the local people in recruitment and this will be added to
the terms of the contracts of the Contractor and possible subcontractors in order to ensure this. In
contract process, MUSKI will request the contractor to plan the workforce and request from the
contractor to prepare a Workforce Management Plan if the requirement for a workforce other than
the one specified in this ESIA is seen. MUSKI will evaluate and submit this plan to ILBANK for
approval. In addition, there will be no accommodation within the scope of the Project. The Project is
not expected to cause workforce influx, if an unusual situation is not triggered. Therefore, it is
thought that the impacts of workforce influx will be insignificant.

MUSKI and the Contractor shall ensure that code of conduct and public communication
trainings are given to all employees as an orientation training to prevent a possible future dispute.

V.6.6 Local Procurement

If it is possible and feasible to do so, local procurement options will be selected at all
phases of the Project and this will have a positive impact on the local economy of the region.

V.7 Community Health and Safety

Construction Phase Impacts

The community health and safety impacts of the Project are mostly limited to the
construction phase. In the construction phase, emissions of gaseous pollutants and fugitive dust
from equipment and machinery used, noise generation, poor handling of wastes to be generated,
requirement to shut down the entire plant and/or specific units for construction works and risks
associated with community encroachment might create negative impacts on community health and
safety. Impacts associated with emissions, noise and waste generation will be managed with the
proper implementation of mitigation measures presented previously in the related sections of this
report.

Construction works will involve increased traffic of heavy vehicles and equipment at local
level and traffic interruptions. Accidents and incidents leading to fatalities could result from traffic
operation while transporting equipment and materials to the construction sites as well as from truck
and vehicle movements. The significance of the impact is considered as medium and through the
implementation of mitigation measures; it could be reduced to low. Impacts associated with traffic

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will be managed with the proper implementation of mitigation measures presented previously in the
related sections of this report.

Another risk would be community encroachment to the active worksites. The risks
associated with this issue would be easily mitigated to negligible significance through
implementation of mitigation measures presented at the end of this section.

Operation Phase Impacts

Similar to the impacts during the construction phase, improper handling of wastes would
create negative impacts on community health and safety. Differently from the construction phase,
sludge will be generated as a result of the operation of the WWTP. In case that the final sludge will
not be handled properly and/or disposed in an uncontrolled manner, magnitude of its impacts on
community health and safety would be somewhat significant.

There will be an increase in the traffic load between the WWTP site and sludge disposal
sites in the operation phase. This increase will be lower than the one anticipated to happen during
construction phase since material transport during the operation phase will be limited with disposal
of wastes and sludge generated. The significance of the impact would be low. In the operation
phase of the WWTP, there would be times that the entire plant or specific units need shutdown due
to excessive precipitation, planned or unplanned maintenance requirements, or any other foreseen
or unforeseen challenges. A shutdown has major consequences for wastewater treatment,
especially biological wastewater treatment. Stopping a physical-chemical treatment generally does
not present many problems; however, turning down of aerobic and anaerobic treatment units has
major impact on the speed of the start-up process, which directly affects effluent quality. The
significance of the shutdown or failure related impacts on community health and safety would be
high without proper implementation of mitigation measures.

Similar to the construction phase, community encroachment to the active worksites is also
a risk in operation phase. The risks associated with this issue would be easily mitigated to
negligible significance through implementation of mitigation measures presented at the end of this
section

Additionally, electrocution through energy transmission line is a risk in operation phase.

The risks associated with this issue would be easily mitigated to low significance through
implementation of mitigation measures presented at the end of this section

Mitigation Measures

In terms of community health and safety aspects, the generated wastes and sludge will be
disposed in accordance with the measures presented in Chapter V.4.8. In addition to that, MUSKI
will ensure that the Sludge Management Plan to be prepared before the commencement of the
operation phase covers community health and safety point of view. For the electrocution through
energy transmission line regular vegetation clearance and maintenance requirements of the energy
transmission line route will be carried out while communicating with the related authority.

For the WWTP and/or unit shutdowns or failures during the operation phase, following
measures will be applied:

 All unit shutdown requirements will be scheduled at least one week beforehand and
MUSKI will make necessary adjustments.
 In major shutdowns of the plant or biological treatment units that require longer times,
nutrition levels will be maintained at the biological treatment units, aeration will be
stopped after one day for aerobic processes.

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  During the longer shutdowns or failures, MUSKI will inform Provincial Directorate of
Environment, Urbanization and Climate Change regarding the situation.
 During excessive loads that the WWTP cannot handle, the bypass line of the plant will
be used to bypass the load.

For the community encroachment that might happen during both construction and
operation phases of the Project, similar mitigation measures will be implemented. These measures
are as follows:

 Community Health, Safety, and Security Management Plan that is in line with OP 4.01
and WBG EHS Guidelines (both general and sector specific) will be developed by
MUSKI or security services provider before the construction phase. MUSKI and
contractor will ensure that the plan is actively implemented.
 Persons and/or organizations with the necessary permits will be assigned to ensure the
security of the Project Area (e.g. private security companies/officials). These persons
and/or organizations shall regularly monitor the facility and its surroundings. The
special security applications and officials' authorities within the scope of the project
shall comply with the provisions of the Regulation on the Implementation of the Law on
Private Security Services and the Law on Private Security Services.
 The entrance to the existing WWTP will continue to be restricted through strengthening
security procedures such as repair of existing fences, installation of security cameras
at key access points and use of a site visitor register.
 Sufficient lighting of the existing WWTP and active construction worksites will be
ensured.

V.8 Archaeological and Cultural Heritage

Construction phase

During the construction phase (earth and construction works) of these type of projects it is
possible to discover unknown archaeological locations or findings. In this context, a potential
damage to archaeological or cultural heritage elements in the project area is possible. Uninformed
employees cannot identify and warn about possible chances for findings. Thus, it is possible to lose
or destroy important undiscovered archaeological locations, together with potentially valuable
evidence. With a properly managed chance finds procedure this impact can be mitigated.

In a case of damage to and loss of assets during any phase of the Project, MUSKI will
compensate for the losses by swiftly identifying the damage on site or through its Grievance
Mechanism (building control team, written grievances, grievances collected from web site etc.).
MUSKI will make efforts to avoid any temporary and/or permanent damage or loss that may occur
during the construction. In addition, contracts made with contractor and sub-contractors will include
clauses to cover the damages given during the construction period stemming from civil works.

As required by Article 4 of Law on the Conservation of Cultural and Natural Properties

(2863 Numbered Law), chance finds procedure will be implemented during land preparation and
construction works. In this context, related Civilian Authority or Museum Directorate will be
informed latest in three days in case of finding any movable or immovable cultural asset by chance
during construction works. Construction works will be stopped immediately. In case of result of any
damage on protected areas or cultural assets due to the Project during construction phase, the
damage will be compensated by the Contractor. In case of a chance find, the communication with
the relevant stakeholders will be performed.

The impact is assessed as direct and negative with short term duration, on-site and low
significance.

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 Operation phase

No significant impacts on archaeological and cultural heritage are expected in the

operation phase as there is no activity other than the maintenance/repair works, which will be
limited.

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VI. PROJECT ALTERNATIVES
The planned Project will be constructed in the vicinity of Oren neighbourhood of Milas
District in Mugla Province. The Project Area covers a land of 8278.11 m2. Within the scope of the
project, it is planned to treat wastewater collected from Oren neighbourhood and its close vicinity.
In the following sections, factors considered in the site and technology selection will be described
and evaluation of alternatives will be presented.

In the light of the information given by MUSKI and the Ilbank the locations for the pumping
stations and WWTP is chosen as these lands were already categorized as public lands and owned
by Milas Municipality. The required permits regarding the transfer of these areas from Milas
Municipality to MUSKI were obtained.

VI.1 “No-Project” Alternative

No project alternative concerns the scenario that the Project does not become operational
and negative or positive possible consequences of the scenario.

As explained in the previous sections, the domestic wastewater generated in the service
area of the Project is currently being discharged to receiving environment without any treatment.

In case of the project is not actualized, the situation will continue and the wastewater of the
region will be discharged uncontrollably without treatment. Therefore, its negative impacts will
continue and the discharge will create pollution stress on the environment. Furthermore, in order to
ensure that the settlements located in the service area of the Project will not be able to benefit from
wastewater services in a healthy and sustainable manner since necessary treatment is not applied.
Therefore, adverse impacts could continue to occur on public health, especially in terms of bathing
water.

Since the WWTP site is already belongs to MUSKI, there will not be any new area use.
Therefore, the Project will not cause a significant change on land use.

Construction phase short term impacts such as noise and dust generation will not occur if
the Project is not actualized. However, these impacts will be kept in regulation limits and will not
have significant impacts on local residents anyway.

Due to the abovementioned reasons, no project alternative is not considered as a

reasonable alternative. The benefits of the positive impacts of the project are of great importance to
the surrounding population.

VI.2 Site Alternatives for the WWTP

Site selection criteria for the planned WWTP are listed below;

 Need of collection and treatment of wastewater at Oren and its close vicinity,
 The absence of residences in the immediate vicinity of the treatment plant,
 The absence of any rare and endangered flora and fauna species in the WWTP Area,
 The ownership of the area belongs to the General Directorate of Water and Sewerage
Administration of Mugla,
 The facility should be easily accessible at all times during the year, energy,
communication and drinking water connections should be made easily,
 The site should be close to a large body of water and/or a green field where the treated
wastewater can be discharged or can be used for irrigation purposes,
 The wastewater treatment facility should have a low elevation area where the collected
wastewater can be brought with gravity flow;
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  A moderately-slope site, if possible, should be preferred, especially as it would allow a
suitable hydraulic profile.

The area that meets the above criteria at the most appropriate level has been selected as
the Project Area which is also subject to this ESIA Report. The planned Milas – Oren Wastewater
Treatment Plant is at a point where most of the wastewater coming from the pump stations is
reached with gravity flow. Wastewater collected from TM 5 - 8, will be provided to the facility by
evaluating the most feasible condition of operating conditions. Also, as the site that the WWTP will
be constructed belongs to MUSKI, during the site selection this situation was considered.

VI.3 Pumping Station Alternatives

There are many criteria that should be taken into account in the construction of the
pumping station and should be examined by different engineering disciplines such as
infrastructure, hydraulic, electricity, machinery, ground engineering. The optimum solutions
regarding all these considerations are also made taking into account the possible environmental
and social impacts (noise, odor, etc.).

The pumping stations that are planned under the scope of the Project will be constructed in
a manner that these stations will be completely closed to the outside and have no effect on human
health in terms of emissions of toxic gases or pest formation, etc. In addition, each pumping station
will also be equipped with an active carbon filtered odor removal unit and will be built using
advanced technology.

During the site selection process for these pumping stations, the sites were selected
paying particular attention to that they are not categorized as agricultural lands but public lands
which are registered as parks. As it stated in the previous sections of the report, the sites that
chosen for constructing the pumping stations were originally belonged to Milas Municipality and the
required permits are obtained regarding the transfer of these sites to MUSKI. Also, the site
selection was made accordingly to the assessment and technical studies such as hydraulic
calculations and the selection of the optimum alternative was ensured. In addition, the areas where
the pumping stations are located are planned to be properly afforested and put into use as a park if
possible.

Four underground pumping stations will be constructed within the scope of Project. It is
planned that two of the pumping stations will be constructed as package pumping stations whereas
the others will be buried reinforced concrete pumping stations. Advantages and disadvantages of
the buried pumping stations compared to above ground pumping stations are given below:

Advantages of the buried pumping stations:

 Less noise and odor emission impacts

 Better landscape and aesthetics
 Protection from severe weather damages

Disadvantages of the buried pumping stations:

 Higher cost
 Difficult for maintenance activities

Package pumping stations are also underground structures that can reach a depth of up to
5 m used for pumping wastewater at low flow rates. Its technical features are the same as semi
buried-aboveground reinforced concrete pumping stations and it does not differ except that it is

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completely buried. An exemplary design of the envisaged system of pumping stations is given in
Figure VI.1.

Figure VI.1 Exemplary Image of a Pumping Station

VI.4 Technology Alternatives for the WWTP

VI.4.1 Process Alternatives

In this section, the alternatives of the advanced biological treatment of the Milas – Oren
Wastewater Treatment Plant are examined. When BOD/COD concentrations and the discharge
criteria are taken into consideration within the scope of feasibility study, the necessity of the
advanced treatment for the removal of nitrogen and phosphorus is understood.

In order to identify the process alternatives, working principle of the system is determined.
Sequencing batch or continuous treatment configurations can be applied. Sequencing batch
configuration is not recommended for touristic regions due to possible difficulties in operation and
high design flowrates. The big difference between summer and winter flowrates makes hard to
design and apply different operation alternatives (i.e. while operating whole lines during summer
and operating less lines during winter). Therefore, continuous configuration is recommended for the
plant.

The alternatives of the continuous advanced biological treatment for the plant are:

 Membrane Bioreactor (MBR)

 Conventional Activated Sludge Systems
 Integrated Fixed Film Activated Sludge (IFAS).

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 Membrane Bioreactor (MBR)

Membrane Bioreactor System (MBR) is actually an improved version of conventional

activated sludge process. It is a suspended growth system separating the treated effluent and
biomass with low pressure membrane filtration. MBR consist of a bioreactor providing biological
treatment and filtration unit (with pores of 0.02-1 microns) providing physical separation
(ultrafiltration and microfiltration). An effluent with hardly any solids and microorganisms can be
obtained. MBR can achieve % 80-%98 COD removal. Continuous flow on the filter surface prevent
filter from clogging by filtered solids. Still pores of the membrane are clogged in time and the
permeability decreases. Thus backwash of the filter with chemicals (citric acid or sodium
hypcloride) or treated water within certain periods is needed.

When compared to conventional activated sludge, MBR systems requires %50 less area.
Also final sedimentation is not required in MBR systems, therefore filamentous growth and bulking
sludge problems occurring in sedimentation tanks are not possible. Separation of biomass is done
by filters. Moreover, MBR systems can be operated with high MLSS concentrations which cause
decrease in bioreactor volume and enable high organic loads. Also, toxic organics create less
operational problems and nitrification is not affected negatively as much in conventional activated
sludge. However, the configuration is more complex and control is harder than conventional
systems because treatment process takes place in single tank. Necessary engineering services for
operation and monitoring of development cost more than conventional systems. Moreover, initial
investment cost is higher than conventional systems because membranes are expensive and
delicate automation and control systems are necessary. For MBR to be able to operate properly in
long run, pre-treatment may be required; which requires additional costs. Furthermore, membranes
must be renewed within certain periods. Energy used during backwash and chemicals used in
backwash increases cost. Consequently, initial investment cost and operational cost are higher
than conventional systems, thus MBR systems are not utilized frequently.

Other drawbacks of the MBR are the clogging of the membrane frequently during treatment
of industrial and domestic wastewater, absence of high flowrate system application examples, and
the need of field test during project design, which consumes time and cause additional cost. Figure
VI.2 presents overall flow diagram of MBR process.

Figure VI.2. Flow Diagram of the MBR Process

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 Conventional Activated Sludge Systems

A2O (denitrification first or simultaneous systems), Step Feed, Bardenpho and UCT are the
conventional activated sludge systems. These systems can be converted to each other via placing
gates in transition points of tanks and inserting pipes. For the treatment plant, these systems are
recommended and explained below:

A2O Process

A2O is a modification of the AO process which provides phosphorus removal via anaerobic
tank and nitrogen removal via anoxic tank. Hydraulic retention time of anoxic tank is about 1-1.5
hours. Denitrification takes place in anoxic reactor. In order to denitrify the nitrate produced via
nitrification in aerobic tank, recycling of some portion of the effluent of the aerobic tank to anoxic
tank entry and well mixing with the raw waste water is required. Necessary carbon source for
denitrification is contained in raw wastewater and conveyed to anoxic tank via activated sludge
recycle line. When it is not required anoxic and aerobic tanks to be separated, by providing recycle
in oxidation tanks and forming anoxic and aerobic parts in each tank, simultaneous nitrogen
removal can be achieved. Simultaneous systems are more suitable to treatment plants with low
flowrates.

Entry of the dissolved oxygen to anoxic tank via nitrate recycle line must be minimized.
Nitrogen removal efficiency is directly proportional to internal recycle ratio. A 2O process is not
affected negatively by the changes in flowrate and pollution strength. Also, extended aeration
systems of the process provide sludge stabilization; thus there is no need to apply additional
sludge stabilization methods. Figure VI.3, A2O shows the flow diagram of the process.

Figure VI.3 Flow Diagram of the A2O Process

Step Feed System

Step Feed configuration is capable of removing carbon and nitrogen and it is applied to
optimize the biological nitrogen removal. Raw wastewater is given to tanks at 2 or 3 points.
Therefore, second and the following anoxic tanks receive carbon source for denitrification from raw
wastewater. Increased denitrification efficiency and relatively constant MLSS concentration through
reactor can be counted as the advantages of this configuration. It is suitable for high nitrogen
concentrations. Figure VI.4 shows the flow diagram of the process.

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Figure VI.4 Flow diagram of the Step Feed System

Bardenpho Process (5 Staged)

5 Staged Bardenpho Process is a configuration providing nitrogen, phosphorus and carbon

removal. 5 Staged Bardenpho is obtained by adding an additional anaerobic tank to the beginning
and a recycle line from final sedimentation to that anaerobic tank to the 4 Staged Bardenpho.
Carbon sources both present in raw wastewater and/or produced from endogenous respiration are
used for denitrification. Nitrate coming from recycle line and/or present in raw wastewater
denitrified with the carbon sources in wastewater. Ammonium nitrogen goes to the first aerobic tank
where the wastewater nitrified and then the second anoxic tank where denitrification is performed
by released carbon in the endogenous respiration. The second aerobic tank is smaller than the first
one, is used to increase dissolved oxygen concentration and remove the nitrogen gas from
environment. Flow diagram of 5 staged Bardenpho process is presented in Figure VI.5 below.

Figure VI.5 Flow Diagram of the 5-Staged Bardenpho Process

UCT Process

Activated sludge system configurations with the anaerobic, aerobic and anoxic tank are
needed to remove nitrogen and phosphor from wastewater. Nitrate and oxygen concentration
should be minimized in the recycle line from anoxic tank to improve phosphor removal and avoid
negative effects on treatment performance. That is why UCT process, which is a modification of
A2O process, is developed. Nitrate is recycled from aerobic to anoxic tank to reduce nitrate
concentration in the anaerobic tank and sludge is recycled from the final sedimentation tank to
anoxic tank and also from anoxic to anaerobic tank. UCT process is especially applicable for the
wastewater which has the low COD/TP to be able to increase phosphor removal.

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Figure VI.6 Flow Diagram of the UCT Process

Integrated Fixed Film Activated Sludge (IFAS) Process

Hybrid system is obtained by the integration of the biofilm layers into the suspended
activated sludge system. As IFAS have more biomass, higher quality effluent standards and higher
influent loads are obtained. IFAS can be used in the domestic wastewater treatment plant, differs
from activated sludge process in that all biomass is not suspended, it will grow by holding onto a
media integrated in the aeration tank. Anaerobic and anoxic tanks are required for the nitrogen and
phosphorous removal as in the conventional activated sludge process.

Advantages of IFAS are;

 Need small area,

 Odorless and aesthetic treatment technology,
 Resistance to shock loads,
 High quality of effluent,
 Short time needed for the plant construction and installation.

Disadvantages of IFAS are;

 Non-widespread technology,
 High quality of staff needed for the maintenance and repair,
 Higher initial investment and operating costs than conventional activated sludge
systems.

Figure VI.7 Flow Diagram of the Integrated Fixed Film Activated Sludge (IFAS) Process

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VI.4.2 Sludge Management Methods

Sludge treatment is one of the most difficult processes in terms of operation and planning
in wastewater treatment plants. Although the amount of sludge produced corresponds to a low
percentage of 1% to 6% by volume of wastewater, the investment and operation costs of the
sludge treatment units are a higher in the total cost of the plant. In general waste management;
primarily strategy is to prevent waste generation or to minimize , then to recover it if possible, if it
cannot be recovered, it is essential to dispose of it in harmony with the environment. Sludge should
be reused on the soil, used as additional fuel in cement plants, anaerobic digestion and energy
recovery methods, and environmentally compatible and regularly stored and incinerated. In
general, the sludge from the system with the pumps is first condensed and then decomposed by
suitable sludge stabilization method selected under the sludge management, dewatered, dried and
removed using the final disposal methods.

Sludge Thickening Alternatives

The concentration of the solid content of sludge coming from the wastewater treatment
units is increased by removing a portion of liquid fraction and volume is decreased in sludge
thickening.

Volume reduction decrease;

 Capacity of tanks and equipment required,

 Quantity of chemical required,
 Amount of heat required for the subsequent sludge thickening units

Gravity Thickening

Solid matter that has high density in the sludge and can precipitate spontaneously is
separated from water and becomes concentrated by gravity. It is applied to the preliminary settling
sludge which has the high inorganic and perceptible solid content. Sludge thickening is
accomplished in circular sedimentation basins. The solids concentration reached in the
gravitational sludge thickening is generally 5-10% solids content for preliminary settling sludge, 2-
3% solid content for waste activated sludge, 3-6% solid content for drip-filtered filter sludge and 4-
7% for mixed sludge.

Floatation Thickening

It is primarily used to thicken the solids in biological process. The incoming solids is
concentrated as 2~8 times degree. Separation of solids is achieved by introducing fine air bubbles
created under pressure of several atmospheres into the liquid, attaching to solids to cause flotation
of solids. The condensed sludge that accumulates on the surface of the tank is stripped away.
Coagulant addition can also be performed to better perform solid/liquid separation in process.
Disadvantages of flotation thickening are equipment cost, maintenance-repair and high operating
cost depending on energy requirement.

Mechanical Thickening (Centrifugation)

It is a common method for sludge thickening and dewatering. During the centrifugation
process, centrifugal force separates the solid substances and free water in the sludge. The most
advanced centrifuges are spinner type solids decanter type centrifuges. Entrance of the sludge is
continuous and the solid materials are gathered around the horizontal cylinder and paddled out of
the cradle. The water of the sludge is removed from the thickener by means of weirs.
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 Advantages of centrifugation;

 Better concentration performance

 Easier and closed system operation
 Need low area
 Easy maintenance and repair
 Lower risk of odor problem and formation of pathogens

Disadvantages of centrifugation;

 Higher initial investment cost

Gravity Belt Thickening

Gravity belt thickeners which are used in the waste activated sludge, aerobic and
anaerobic digestive sludge and some industrial sludge are applied in solids concentrations less
than 2%. Treatment sludge is distributed on the condensation band in the pore structure and the
water is directed by gravity effect after the addition of polymer. Through the use of a series of
scraper knives placed along the course of the band, the water is allowed to pass from the sludge to
the band.

Disadvantages of gravity belt thickening;

 Need high polymer addition and equipment,

 The need for backwashing of the band increases the formation of filtrate water, which
acts as additional pollution load to the treatment plant,
 Need good ventilation due to odor formation.

Sludge Stabilization Alternatives

Stabilization is applied in order to eliminate problems such as reduction of pathogenic

organisms, prevention of unwanted odors, decay, deterioration and spoilage in the contents of
treatment sludge. The most important feature in the stabilization process is the volatile or organic
content of the treatment sludge.

If sludge incineration applications are preferred as a final disposal, since the amount of
energy to be obtained as a result of the combustion process depends on the calorific value of the
sludge, it may be considered that not to conduct stabilization of the sludge since the stabilization of
the sludge will reduce calorific value of the sludge.

In this case, however, the dewatered sludge must be transferred to the incineration
process without prolonged storage. The main technologies used for sludge stabilization are as
follows:

Aerobic Digestion

Aerobic digestion can be applied to waste active sludge or mixed sludge (primary
sedimentation + waste active sludge or primary sedimentation + dripping filter sludge). Waste
activated sludge into a separate tank and aerated for a few days. Thus, the volatile solid materials
in the sludge are biologically stabilized.

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 Advantages of aerobic digestion;

 Low initial investment cost,

 Less operational problem.

Disadvantages of aerobic digestion;

 High energy need to provide necessary oxygen to the system,

 No useful final product such as methane can be obtained and lack of energy recovery.

Anaerobic Digestion

Sludge in the anaerobic digestion, one of the most common processes used for sludge
stabilization, is heated at about 35°C to decompose organic and inorganic substances in the
mesophilic environment in the absence of molecular oxygen. Condensed primary sludge and
excess the biological sludge is pumped to the digesters where air intake is off and well mixing
conditions are provided. The organic substances in the waste sludge are biodegraded and
converted into various end products such as methane and carbon dioxide. The most important
parameter in reactor design is the waiting period, which can be accepted between 20-25 days. The
most important advantage of anaerobic digestion is that biogas can be obtained as a product and
heat and electricity can be supplied by the gas cogeneration system collected in the gas reservoirs.

Electricity is generated by inserting the generator into the generator. The generator meets
some of the electricity needed by the treatment plant. The cooling water from the gas motor is used
as heat energy to protect the existing mesophilic temperature of the sludge digester.

Chemical Sludge Stabilization

In chemical stabilization, the lime is added to the raw water to raise pH above 12. The
environment created by high pH is not suitable for the survival of microorganisms. Thus,
microorganism will not cause rot, bad smell and harmful health. Despite the low initial investment
cost, the operating cost is high due to the high amount of chemical addition and sludge formation.

Stabilization in the Aeration Tank

Extended aeration activated sludge systems have a high sludge age and therefore excess
biological sludge removed from the system is in a stabilized state. Larger tank volumes and more
oxygen supply are needed due high sludge age. It is stated that the process according to our
specification will be done according to ATV-DVWK-A131. Aerobic sludge stabilization in ATV-A131
is also recommended.

In such a case, additional units need to be done;

 Mechanical Thickener
 Aerobic Sludge Stabilization Pool
 Diffuser System
 Mixers, dosing pumps PE dosing unit
 Blower Unit
 Lime Unit is required.

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 Disadvantages of aerobic sludge stabilization tank;

 No energy recovery,
 More costly due to the energy costs which is spent for aeration,
 Weaker dewatering character of digested sludge,
 Process is affected by temperature, tank geometry, amount of solids in the input
sludge, the quality of mixing / ventilation equipment and the type of tank building
material.

Also; in some facilities that are in MUSKI’s responsibility, for example existing Marmaris
Wastewater Treatment Plant; the aerobic sludge stabilization pool and lime unit were constructed.
It has been declared by the plant manager that the sludge stabilization pool has never been used
to date since these facilities were built. It is not possible to use the stabilization pool in all seasons
of the year since there are serious seasonal differences in the summer and winter pollution load of
the incoming wastewater. On the basis of all these evaluations, it was concluded that since it is not
economical and useful in the operation and it would be more appropriate to not construct aerobic
sludge stabilization due to insufficient land.

Sludge Dewatering Alternatives

To facilitate the final disposal of treatment sludge and to reduce the amount of sludge to be
removed, it is necessary to increase the content of solids and reduce the water content. The
reduction in the volume of sludge is of great importance for the capacity and investment of the final
disposal facilities. In addition, it reduces the cost of transporting and transporting sludge. Sludge
dewatering by mechanical methods, is the most preferred method for dewatering treatment sludge,
have low area requirement and higher dewatering efficiency. Decanter centrifuges, belt filter
presses and filter presses are most widely used dewatering equipment. Other mechanical sludge
dewaters are vacuum filters and drill presses which their usage rates are low.

Dewatering with Centrifugation

Today, centrifugation is one of the most common used methods. Centrifugation dewatering
is the treatment of sludge under the influence of centrifugal forces, making it more dense sludge.
The sludge, which usually contain chemicals such as polyelectrolyte, alum and limestone, are
given to centrifuges rotating about a horizontal axis at a speed of 1,600-2,000 rpm. The sludge
drained from the ditch is conveyed to the entrance to the wastewater treatment plant. The
dewatering yields are 90-95%, and the solids content of the outlet sludge can vary between 20-
25%.

Advantages of centrifugation dewatering;

 Need less space,

 No odor problem because it is a closed system,
 High dewatering efficiency.

Disadvantage of centrifugation dewatering;

 High investment cost.

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 Dewatering in Belt Filter

Dewatering with a belt filter is based on the principle that the squeezing of the sludge with
the pressure effect applied to the sludge will remove the water. Polymer addition is required to
purify the sludge quenching feature. Sludge is compressed between the two strips with a porous
surface, with the tension provided by the cylinders of different diameters. Belt filter designs have
basic features such as polymer conditioning, gravity drainage, under-compression and under-
compression. The filtration area provided by the belt filter, the use of additional rollers, and the belt
rotation speed are factors affecting the dewatering efficiency. Belt filter dewatering can be
dewatered to 18-20% solids in general, depending on the yield sludge characterization.

Dewatering in Filter Press

Filter press dewatering is the method of dewatering mechanical sludge which provides the
oldest and highest output solid matter ratio. Higher pressures are applied in filter press dewatering.
It is a suitable method to be used in industrial sewage sludge which has discontinuous sludge feed
and low water supply ability. 28-30% solid matter ratios can be achieved.

Sludge Drying Alternatives

The water in the sludge has to be evaporated in order to dry the sludge. Since the water in
the sludge has different properties, it is generally considered in two main parts; free water not
bound to solid particles and part of the water that is difficult to evaporate. Both natural and
mechanical dewatering and drying methods have been developed for the sludge disposal with
different moisture contents according to the final sludge disposal method. The dried sludge is
biologically stable and has low water content as well as burning and storage, and so on. The
advantages of sludge drying are that the problem of odor is low, transport, handling and storage
costs are reduced considerably by reducing the volume of wet sludge in large volumes.

The biggest advantages of dried the treatment sludge is the possibility of using the final
product as following areas;

 Use as fertilizer in agriculture and forestry,

 Use as energy in cement plants, energy plants and incineration plants,
 Use for topsoil landscaping, fill and regular storage.

Thermal Drying

Thermal drying reduces the content of moisture in the sludge far below that obtained by
mechanical dehydration methods. Advantages of the dried sludge are lower transportation costs,
reduction of pathogens and better storage and marketing.

In the contact drying process, heat is indirectly transferred to the sludge through the heated
surface while heat is directly supplied to the particles in the convection drying process. The most
common types of drying are tape, drum and fluid bed dryers.

The sludge is poured onto the conveyor belt and the hot air is fed into the system. Since
the speeds of the driers are adjustable, it is possible to obtain between 65% and 90% solids. The
drying capacities of the dryers vary between 500 - 4000 kg H2O / hr. Mixing with dry matter (pre-
dried slurry) is required at the beginning of the system in order to pass the adhesive phase to
prevent plugging.

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 Solar Drying

Wet sludge is dried in specially prepared greenhouse areas where are extremely
transparent, with special coverings that prevent uncontrolled air change and therefore unnecessary
heat loss. With ventilators located in the unit, the drying air of the ambient air is introduced into the
circuit by the optimal air flow rate. Solar drying, climatic conditions and mud drying characteristics
are parameters that determine the design of the drying facility. Space required for drying depends
on sludge characteristics and atmospheric conditions such as precipitation, relative humidity and
temperature. The disadvantage of solar drying is that very high area is needed.

Lime Drying

By the addition of slaked lime, to a hygienic and pathogen free product is obtained from the
waste sludge. This is achieved by reaction heat and alkalization. The obtained product has organic
content, can be used in agriculture and in soil lacking in lime.

VI.4.3 Disposal Methods

Land application, storage, incineration and composting alternatives can be applied for final
disposal. Information about the final disposal methods that can be applied to the treatment sludge
to be formed at the Milas – Oren Treatment Plant is as in the following.

Field Application

The application of treatment sludge to agricultural areas aims to increase the use of
sludge, fertilizer as a source of nutrients or as soil conditioner and to increase agricultural
production. The pH of the soil to be applied to the treatment sludge must be 6.5. Thus, the
movement of heavy metals within the soil is limited.

Regulation on the Use of Soil and Municipal Sewage Sludge, which was published in the
Official Gazette dated 03.08.2010 and numbered 27661, covers the technical and administrative
principles related to soil controlled use in such a way that treatment sludge does not harm soil,
plant, animal and human. It is strictly forbidden to use raw sludge to the soil according to the
Regulation. In treatment sludge, there are limit values for heavy metals, organic compounds and
dioxins. Heavy metal content limit values for soil and stabilized sludge to be used in soil are
presented in Table VI.1 and Table VI.2.

Table VI.1 Heavy Metal Limit Values in the Soil

6≤ph<7 pH≥7
Heavy Metal (Total)
mg. Kg-1 Oven Dry Soil mg. Kg-1 Oven Dry Soil
Lead 70 100
Cadmium 1 1,5
Chromium 60 100
Copper 50 100
Nickel 50 70
Zinc 150 200
Mercury 0,5 1

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Table VI.2 Maximum Heavy Metal Content Limit Values for Stabilized Sludge to be used in Soil

Heavy Metal (Total) Limit Values (mg kg-1 dry matter)

Lead 750
Cadmium 10
Chromium 1000
Copper 1000
Nickel 300
Zinc 2500
Mercury 10

The maximum permissible values of stabilized sludge for organic compound are given in
Table VI.3 below. The limit value for the stabilized sludge content for the polychlorinated
dibenzodioxin / dibenzofurans is specified as 100 ng Toxic Equivalent kg-1 dry matter.

Table VI.3 Organic Compound Limit Values for Stabilized Sludge to be used in Soil

Organic Compounds Limit Values

(mg kg-1 dry matter)
AOX (Absorbable organic halogens) 500
LAS (Linear alkyl benzene sulphonate) 2600
DEHP (Diptalate (2-ethylhexyl)) 100
NPE (Nonyl phenol and nonyl phenol ethoxylates with 1 and 2 ethoxy groups ) 50
PAH (sum of polycyclic aromatic hydrocarbons or polyaromatic hydrocarbons) 6
PCB (sum of polychlorinated biphenyl compounds 28, 52, 101, 118, 138, 153, 180) 0,8

There are important restrictions on the use of the sludge in the soil both in terms of soil
quality, and in the treatment sludge, heavy metals, organic compounds and dioxin content.

There are significant restrictions on the soil quality of the treatment sludge in terms of
heavy metal, organic compound and dioxin content. Therefore, heavy metal content of the
treatment sludge within the limit values does not mean that the sludge can be used in the soil.

Composting

Composting is the process of decomposition of waste sludge by biological activity.

Composting boxes and tunnel reactors are widely used in composting process. The heavy metal
content in the final product has critical importance and must provide specifications about the end
product standards, local and national legislation.

Disadvantages of composting;

 Operating costs are higher than laying out of the raw sludge.
 Ventilation causes energy consumption. In order to ensure an optimum C/N ratio, it
may be advantageous to mix the treatment sludge with other wastes, and in the case
where it is necessary to purchase these wastes, it can turn into a disadvantage.

Landfill

Regulation on the Regular Storage of Wastes, which was published in the Official Gazette
dated 26.03.2010 and numbered 27533, covers the technical and administrative basis for the
prevention and management of environmental effects that may occur during the disposal process
of waste through the regular storage method.

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 Regular Storage Facilities belonging to the Metropolitan Municipalities is considered as II.
Class regular storage facility in the line with the description of the facility with the substructure
required for the storage of municipal wastes and non-hazardous wastes. II. Class regulated storage
facilities acceptance limit values are given in the Table VI.4 below.

Table VI.4 Waste Acceptance Limit Values for Class II Landfill Facilities

Parameter Unit Limit Value

As mg / lt 0,05
Ba mg / lt 2
Cd mg / lt 0,004
Cr mg / lt 0,05
Cu mg / lt 0,2
Hg mg / lt 0,001
Mo mg / lt 0,05
Ni mg / lt 0,04
Pb mg / lt 0,05
Sb mg / lt 0,006
Se mg / lt 0,01
Zn mg / lt 0,4
Chloride mg / lt 80
Floride mg / lt 1
Sulfate mg / lt 100
DOC (Dissolved Organic Carbon) mg / lt 50
TDS (Total Dissolved Solid) mg / lt 400
pH mg / lt ≥6
Total Organic Carbon mg / lt 50.000 - %5

The most important provisions in the Regulation on the Regular Storage of Wastes are
included in Temporary Article 4. Temporary Article 4 is stated below:

 In Appendix-IV to the Regulation on the General Principles of Waste Management,

sludge classified as non-hazardous does not require compliance with the Dissolved
Organic Carbon (DOC) limit value in a separate lot storage in the Class 2 regular
storage area Class on condition that all other parameters given in Appendix-2 is
provided, at least 30% by weight of dry matter is involved and of bad smell is
eliminated.

Incineration

The disposal of sewage sludge directly for agricultural purposes or to the landfill site is
subject to increasingly stringent legal controls. Mixing domestic solid wastes and waste sludge
optimize the operation of the combustion plants. The volumetric reduction in very significant
quantities is the result of the burning.

It is estimated that incineration will be increasingly used by burning sewage sludge, despite
the high investment costs in incineration systems, the incidence of incineration criteria, increased
costs associated with the processing of emission gases, and the difficulty of disposal of ash
resulting from combustion.

The Regulation on the Waste Incineration, which was published in the Official Gazette
dated 06.10.2010 and numbered 27721, is designed to prevent the adverse impacts of the
incineration of wastes on the environment, in particular the risks that may arise for pollution
resulting from emissions in air, soil, surface waters and groundwater and human health.

Some definitions related to sludge management within the scope of the Regulation are as
follows:

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 Combined incineration plant: The main objective of the project is to develop a waste
management system for the production of energy, waste acceptance unit, temporary storage unit,
pretreatment unit, waste feed and air supply systems, boiler, flue gas treatment units, including all
units in co-incineration facilities, including measuring equipment and systems used to control
incineration, flue, burning operations, recording and monitoring of incineration conditions, for the
temporary storage of incineration residues and for the treatment of wastewaters all installations are
considered to be incinerators (but if the incineration process is aimed at the thermal disposal of the
waste, not the product or energy production).

Current incineration or co-incineration plant: It means an incinerator or co-incinerator plant

which has been operating on the date of entry into force of this Regulation and which has already
submitted licensed installations or license application files.

Incineration plant: The units included in the facility for waste storage, preheating unit, waste
treatment and waste disposal systems, boiler, flue gas treatment systems, regular storage of
residues resulting from combustion and wastewater treatment, control and burning of flue, including
any other thermal disposal operations such as pyrolysis, gasification, or plasma processes,
including the combustion of waste by oxidation, which may or may not recover the resulting
combustion heat, including all the units involved in the process, including measurement devices
and systems used to monitor and record thermal disposal refers to any kind of system.

The moisture content of the sludge is important for the incineration because dewatered
sludge with a moisture content of 70% or more cannot sustain the combustion process and require
additional fuel. For the sludge to be used as an alternative fuel, it must have a dry matter content of
at least 85%. Cement factories around the treatment plant accept dried sludge as fuel in calorific
value range 2,700-3,000 kcal.

The main advantages of the incineration method are listed below;

 After burning, there is a significant reduction in the volume of the treated sludge (it is
linked to the organic matter content of the sludge being burnt).
 Sewage sludge is used as energy.
 It is possible to use the by-products produced after the burning of the treatment sludge
by recycling (asphalt road filler, concrete production and brick making).
 This process is not affected much by the sludge composition.
 They are reliable (known / implemented) systems.
 The smells are minimized due to the system being closed and high temperatures.

VI.5 Comparison of Alternatives

VI.5.1 Comparison of Technology Alternatives

A scoring system was established during the comparison of treatment alternatives

considered for the design of Milas – Oren Wastewater Treatment Plants and the following criteria
were taken into consideration:

 To be able to provide discharge standards,

 Ease of operation and maintenance,
 Investment costs,
 Operation and maintenance costs,
 Flexibility to flow and load changes,
 Resistance to toxic substances,
 Land requirements,
 Aesthetic.

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 These criteria are graded according to importance by weighted percentage and percentile.
According to the treatment technology, each criterion is given between 0 and 5 points (5 best
points, 1 weakest point, 0 ineffective points). Weighted scores were obtained by multiplying the
importance grade and the technology score, and the total score was obtained by their aggregation.
It is accepted that the technology alternative with the highest total score is the most feasible option.
Table VI.5 shows the results of the evaluation.

Table VI.5 Comparison of Wastewater Treatment Alternatives

Conventional
Significance
Concept MBR Process Activated IFAS Process
Level
Sludge Systems
Providing Discharge Standards 15 5 4 5
Ease of Operation and Maintenance 10 2 5 3
Land Requirements 10 5 3 4
Electricity and Maintenance Costs 20 2 4 3
Resistance to flow and load changes 10 3 5 4
Investment Costs 20 2 4 2
Aesthetic 5 4 3 4
Sludge Disposal Costs 10 4 2 3
Total (weighted score) 100 3.15 3.85 3.35

Table VI.5 compares the advantages and disadvantages of three different biological
treatment processes capable of nitrogen and phosphorus removal. Conventional activated sludge
systems containing different configurations of classical activated sludge systems have been
evaluated together at this stage. All processes can provide discharge standards, but the highest
quality effluent is obtained by MBR and IFAS processes.

Operating conventional activated sludge systems is easier than operating IFAS systems.
The fact that the application examples are not common in our country and that the application
examples for high wastewater treatment are limited is disadvantageous in terms of operation.

The MBR process requires the least land due to the fact that the final settling tanks are not
needed. On the contrary, conventional activated sludge processes require higher space
requirements than other systems because of the higher pool volumes and the need for the final
settling tank. In IFAS systems too, low ventilation pool volumes arise due to the adherence of some
of the biomass to the media. Also the filtration unit instead of the last settling tank can also be
used.

MBR systems have a disadvantage in terms of operating cost due to high electricity
consumption and frequent blockage of MBR units. In conventional activated sludge systems,
operating cost is much lower than other systems. In IFAS systems, low sludge production, high
energy consumption is the issue.

The application example for resistance to flow and shock pollution loads are the most
common conventional activated sludge systems is more advantageous than other alternatives. In
the MBR process biological treatment performance against shock loads is significantly affected. In
case of shock loading in MBR application examples, the caps are automatically closed in biological
reactors and no water is taken into the system. This is a major drawback to the business. The IFAS
system has been evaluated as a process resistant to shock pollution loads and flow rates due to its
two types of microbial lifecycle.

In the MBR system, the initial investment cost is higher than conventional systems due to
the high membrane cost and the need for precise measurement-automation. Similarly, the IFAS
process is often patented technology and has high initial investment costs.

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 MBR systems have a view and aesthetic advantage because they have closed and low
space requirements. IFAS processes also have an aesthetic appearance because they can be
used with purification plants in patented application examples. Since conventional activated sludge
systems are composed of open and high-volume units, they have an aesthetic appearance.
However, the aesthetic criterion has a lower significance level because the areas where the
treatment facilities are located for the project area are not intensive and the areas are far from the
city centre.

Since the most sludge production from the treatment alternatives under consideration is
related to the conventional systems, it has the highest score in terms of sludge disposal costs.
Since the least sludge production occurs in the MBR and IFAS processes, a lower rating is made.

Sewage sludge that is generated after the treatment process in all wastewater treatment
plants operated by MUSKI is disposed of at Solid Waste Regular Storage Facilities operated by the
Environmental Protection and Control Department.

The result of technical evaluation of treatment technologies is the technologically most

suitable alternative for conventional Milas – Oren Wastewater Treatment Plant is the conventional
activated sludge systems.

VI.5.2 Comparison of Sludge Management Methods

Sludge treatment is one of the most difficult processes in terms of operation and planning
in wastewater treatment plants. Although the amount of the originating sludge corresponds to a low
percentage like 1% to 6% of wastewater in volume, the investment and operation costs of the
sludge treatment units have a higher share in the total cost of the plant. Therefore, it is of great
importance to select the most suitable sludge treatment system.

Generally, in waste management; it is firstly essential not to generate waste or to minimize

waste generation, and then if possible, to ensure recovery thereof, and if it is not possible, to
dispose of it in an environment-friendly way. If sludge shall be recovered, the methods to use it on
soil, to use it as additional fuel in cement plants and to generate energy with anaerobic digesters
shall be assessed. In case it is disposed of in an environment-friendly way, then the regular storage
and drying/burning methods are assessed.

When the sludge treatment and disposal alternatives, the project site, the location and
other related conditions of the wastewater treatment plants are taken into account, meeting legal
standards, operational and maintenance costs and ease of operation, initial investment costs and
land requirements of the place to be selected shall be considered.

The assessment method for the sludge treatment system is the same as the one used for
wastewater treatment technologies. The criteria are weighted in percentiles according to the
significance level. The weighted scores have been achieved by multiplying the scores indicating
significance level with the technology scores (Table VI.6).

It is required to select the most feasible disposal method for the sludge according to the
characteristics of the sludge generated from the treatment plant as a by-product and considering
the environmental conditions.

Within the framework of the five basic criteria determined upon examination of Table VI.6,
the most appropriate method is the incineration system, as no sludge stabilization is required,
energy recovery is ensured, the products generated as a result of incineration are suitable for re-
use, and it decreases to a large extent in volume. The incineration operation is a system with a
high initial investment cost and operating cost, and which highly requires qualified personnel to
operate it.

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 The environmental conditions that affect selection of the disposal method are climate,
presence of infertile soils in the region, availability or non-availability of thermal power plants or
cement plants, presence of unused quarries and mines, and cheapness or expensiveness of the
land in such regions where the population is dense. Due to the fact that the activity field and its
surroundings are located within the boundaries of the tourism center, and that, correspondingly, the
land acquisition prices are high; the land selection process for the incineration plant to be
constructed for disposal of the sludge generated in the treatment plants across Mugla province has
not yet been completed.

The other alternative is that the treatment sludge may be dried and stored by the licensed
companies. In this context, the analyses of the sludge shall be carried out in accordance with the
parameters specified in Appendix-2 of the “Regulation on Regular Storage of Wastes” entering into
force after publication in the Official Gazette dated 26.03.2010 and numbered 27533, and the final
disposal form shall be determined according to the results of the analyses. Albeit, while disposing
of the sludge, it is required to pay attention to the Provisional Article 4 of the “Regulation on the
Amendment of the Regulation on Regular Storage of Wastes” entering into force after publication in
the Official Gazette dated 11.03.2015 and numbered 29292.

As another alternative, it is recommended to prioritize use of the sludge in agricultural

activities. Because organic materials shall improve the structure of soil, the water holding capacity
of soil, the infiltration and aeration of the soil; in addition, the macro nutrients and micro nutrients
shall contribute to plant development. Through this method, it shall be possible to recover the
sludge, which is a waste matter, into economy. However, when it is assessed in terms of socio-
economic aspects, the social approach to the use of wastewater treatment sludge in agricultural
activities is negative.

It is necessary that the society is firstly informed and its awareness on this issue is raised.
If the sludge cannot be used in the agricultural activities, energy recovery is provided by
transferring them to the cement plants as the final disposal method.

Within this regard, final decision on sludge management is that the excess sludge which
will be generated during the operation of WWTP, will be analysed to determine compliance with the
Annex-2 of the Regulation on Landfilling of Wastes and if it is deemed appropriate, the sludge will
be collected by the licensed disposal companies determined by MUSKI every year. After that, the
sludge will be disposed in accordance with the provisions of Urban Wastewater Treatment
Regulation and other relevant legislation. According to the information retrieved from MUSKI, the
sludge will be transported by competent and licensed firms to the landfill which has enough
capacity. At the end, sludge will be stored in the landfill. Currently, the only option available is
landfilling, but incineration and other options will also be considered under the sludge management
plan to be prepared prior to operational phase. Within this regard, according to information
obtained from MUSKI, EIA Positive decision for incineration plant is obtained. However, whether
the plant will be constructed or not is depends on the supply of funding for this issue.

During the operation period, documents related to the amount of sludge delivered to the
licensed disposal company shall be issued, and a record shall be kept within the scope of
monitoring.

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Table VI.6 Comparison of Sludge Treatment and Disposal Methods

Sludge Stabilization Sludge Dewatering Sludge Drying Sludge Removal

Significance

Stabilization

Stabilization

Stabilization
Concept

Lime Drying

Composting
Centrifugal

Application
Sun Drying
Dewatering

Dewatering

Dewatering
F i l t e r Press
Belt Press
Anaerobic

(Cement etc.
Incineration
Extended
Chemical

Aeration

Methods
Thermal
Aerobic

facilities)
System
Sludge

Landfill
Land
Land requirement* 20 3 4 4 3 5 4 4 4 1 3 1 3 2 4

Operation and maintenance

20 3 2 3 5 4 3 2 3 4 4 4 4 4 3
difficulties

Investment costs 20 3 3 4 3 3 4 4 3 4 4 3 3 4 1

Operation and maintenance

25 2 4 3 3 4 3 3 3 4 2 4 4 3 5
costs
Feasibility 15 4 5 1 5 5 4 3 4 5 2 2 3 4 5

Total (Weighted Score) 100 2.9 3.6 3.1 3.7 4.15 3.55 3.2 3.4 3.5 3 2.9 3.25 3.35 3.60

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VII. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)
The ESMP has been prepared to assess and identify the potential environmental and
social impacts and risks arising out of the development of the Project components and auxiliary
facilities and recommend mitigation measures for significant adverse environmental and social
impacts and describes the monitoring and institutional requirements necessary to implement this
Plan.

The primary purpose of this ESMP is to ensure that the environmental requirements and
social commitments associated with the Project are carried forward into implementation and
operational phases of the Project and are effectively managed. The specific objectives are:

1. Anticipating and avoiding, reducing, mitigating and if these are not achieved
compensating any adverse environmental, social and health impacts resulting from the
project activities;
2. Prevent or compensate any loss of the affected person;
3. Conducting all project activities in accordance with the applicable national legislation
and in compliance with the World Bank’s Environmental and Social Framework (ESF)
4. Prevent environmental degradation as a result of either individual subprojects or their
cumulative effects;
5. Enhance positive environmental and social outcomes;
6. Ensure that the ESMP is feasible and cost-efficient;
7. To act as an Action Plan in order to ensure that the project impact mitigation measures
are properly implemented and monitored; and
8. Ensure that all stakeholders concerns are addressed.

This ESMP has been prepared consistent with the World Bank guidance specified in the
OP4.01.

This ESMP was developed based on the findings of the impact assessment studies.
Identification of risks, mitigation and monitoring activities are considered for the two main phases of
the Project, which are “Construction” and “Operation”. In order to achieve environmental and social
outcomes consistent with the WB OP given in the Terms of Reference of the Project, potential
adverse environmental and social impacts anticipated in each phase of the project components will
be identified; requirements for effective and timely interventions will be defined; and means for
meeting these requirements will be described in the context of this ESMP.

In order to reflect developments on detailed Project design, this ESMP will be improved
and evolved in the future. Hence, this ESMP is a living document that will be continuously reviewed
and updated by taking into account of these subjects:

 Monitoring results,
 Test and trial results performed during Project’s operation phase,
 Changes on national legislation and international standards, and
 Changes on Project parameters (if any).

The following chapters were prepared to outline the legislative background for
management, organizations that will be responsible for the implementation of this ESMP,
specifications of the Project, mitigation plans for construction and operation phases of the Project,
monitoring plan, public participation, and inspection and reporting.

The purpose of the Mitigation Management and Monitoring Plan presented under this
chapter is to apply mitigation measures to reduce the impacts of the Project, describe the roles of
the participating parties and key personnel responsible for the implementation of the mitigation

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measures, and identify procedures to ensure that the mitigation measures are implemented
adequately during all phases of the Project.

VII.1 Mitigation Management Plan

Impact mitigation measures and activities are developed for all phases of the Project for
both project components and auxiliary facilities including energy transmission lines and working
camps in the scope of this ESMP and are in compliance with the national legislation as well as
international standards. Impact mitigation management plan is presented in Table VII.1 and Table
VII.2 for construction and operation phases, respectively.

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Table VII.1 Construction Phase Impact Mitigation Plan
Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
The impacts on soil environment will be most visible at the WWTP site. However, the following measures should be
taken at all areas of the Project, not limited to the WWTP site.
 Topsoil will be stripped to a sufficient depth (minimum 30 cm) prior to the start of the construction activities. To
avoid soil compaction, stripping operation will not be done when soil is wet. Average height of topsoil stacks
will be 1.5 meters. Side slope of these stacks will not exceed 3:1 (h:v).
 In order to minimize the impacts on soil environment, the amount of soil that could be subject to compaction
and contamination/pollution will be minimized by ensuring the use of only the designated work sites and routes
for the construction machinery and equipment and field personnel. In case of the need for the area relevant
permit will be obtained before the construction.
 The fuel required for the construction equipment and vehicles to be used within the site during construction
phase will be supplied primarily from the nearest station; if deemed necessary, fuels that may possibly be
stored at site will be stored in the areas where necessary impermeability precautions are taken;
 Measures to be taken in case of leaks and spills that may arise from construction machinery and vehicles, and
unexpected accidents will be described in site-specific Emergency Response Plan to be prepared;
 In order to develop background data on soil contamination status at the WWTP site, MUSKI or the construction
contractor will conduct a soil sampling study at the site before any activity;
 According to requirements specified in the Regulation on Soil Pollution Control and Point Source
Contaminated Fields, firstly MUSKI is obliged to notify the Ministry of Environment, Urbanisation and Climate
Change (MoEUCC) regarding to the soil pollution in the Project Area, according to the procedure defined in the The number of events that trigger spill response
regulation. After that, based on the inspections that will be carried out by the MoEUCC regarding to MUSKI’s Soil analysis results
notification, if the site will be defined as a contaminated site that needs to be cleaned up, the site will be
Contaminated soil amount
cleaned up by firms authorized by the MoEUCC and MUSKI will be the responsible entity to ensure clean up.
Low (for soil Within the scope of cleanup activities, following measures will be taken for the contaminated areas during the Contaminated soil treatment/disposal methodology
Contractor
contamination) construction phase: Included in Stripped/stored/reused topsoil amount
Soil Soil Contamination, o Vehicles containing any excavated soil will be suitably covered to limit potential dust emissions, and MUSKI
C1 Adverse Medium (for loss construction Environmental spill/leak incident records/report
Environment Topsoil Loss truck bodies and tailgates will be sealed to prevent any discharge during transport; Supervision
of topsoil at Oren costs
o Only licensed waste haulers will be used to collect and transport contaminated soil to an appropriate Consultant Excavation amount
WWTP site)
treatment/disposal site and illegal disposal of the soil will be prohibited; Reused excavation amount
o The use of contaminated soil for landscaping will be prohibited.
Amount of excavated material that is sent to final
 The provisions of the Regulation on the Control of Excavation Soil, Construction and Demolition Wastes shall disposal
be complied during land preparation and construction phase of the Project; Monitoring report findings
 Provisions of the Regulation on the Control of Soil Pollution and Sites Contaminated by Point Sources shall be
complied within the scope of the Project;
 Wastes and wastewater to be generated during the construction phase of the Project will be stored and
disposed in a controlled manner in accordance with the relevant regulations and in line with the management
practices described in this report. Thus, it will not be possible for the wastes and wastewater to be generated in
the Project Area interact with the soil environment and cause any impacts.
 Following the completion of construction works, the stripped topsoil will be reused within the project areas,
such as landscaping of WWTP and pumping stations;
 For the amount of the topsoil that cannot be reused will not be wasted and the unused topsoil will be
transferred to locations close to the current topsoil storage area by consulting with the potential users; farmers,
livestock owners;
 In case of a damage caused to the existing roads, community assets, individual’s crops and assets during land
preparation and construction phases, the construction contractor will compensate the losses by identifying
damage in accordance with the WB’s safeguards with the supervision of MUSKI. MUSKI’s grievance
mechanism will be used in the event of any damage or loss.
 A Soil Management Plan should be prepared prior to the construction phase.
 An Oil and Chemical Spill Contingency Management Plan should be prepared prior to the construction phase
 The areas that the construction works take place will be reinstated after the completion of works
 By establishing a suitable drainage system in the field, the potential impact of surface runoff will be minimized.
In this context, drainage channels will be constructed in accordance with the topographical conditions of the
site;
Contractor
 Construction activities (especially excavation works) will be undertaken in the dry weather condition as much Included in
Soil as possible; MUSKI
C2 Erosion potential Adverse Medium construction Monitoring report findings
Environment
 Stripping of topsoil will not be conducted earlier than required to prevent the erosion of soil (wind and water); Supervision costs
Consultant
 The disturbed areas and soil stock piles will be kept moist to avoid wind erosion of soil;
 Topography will be restored for stop stabilization immediately after the completion of construction at each
location.

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 The excavation works should be performed under the supervision of senior geology/geotechnical engineer;
Liquefaction and Construction contract
 To lower the liquefaction potential and support the bearing capacity of ground, piling options should be Contractor Included in
ground stability
C3 Soil Adverse High developed. Supervision construction Drainage network design
related risks at
 50 cm thick filling material with suitable grain sizes should be laid under the foundation of all structures. Consultant costs Monitoring report findings
Oren WWTP site
 Drainage of site should be ensured.
A Dust Management Plan that is in line with OP 4.01 and WBG EHS Guidelines (both general and sectorial) should
be prepared before the construction phase to ensure:
 Dust should be minimized from open area sources, including storage piles, by using control measures such as
installing enclosures and covers, and increasing the moisture content;
 The drop height of potentially dust generating materials will be kept as low as possible;
 When there is traffic flow on the existing roads, where the works performed at, dust suppression measures will
be continuously applied to ensure traffic safety. If there is no traffic existing in the local roads, dust suppression
measures will be applied only at local residential and business areas;
 Wind shields/barriers will be placed at work sites, especially at the south and east borders of the WWTP site
and around the TM-6 Pumping Station, to prevent dust dispersion;
 Work sites will be sprayed regularly, particularly in spring and summer, to reduce the effects of dust-causing
activities such as excavation and backfilling;
 Continuous water spraying will be conducted at the WWTP site to minimize dust impacts on Mugla Sitki
Kocman University Fisheries Research and Development, which is adjacent to the site, and during the works to
be performed around TM-6, where there is a hospital nearby;;
 Trees will be planted to the borders of WWTP, especially at the east and south borders;
 Inner roads of the WWTP will be covered to prevent dust formation; Visual observations
 Speed limitations will be defined and obeyed for construction vehicles; Exhaust emission decal follow-up
Contractor
 Daily backfilling, bedding and covering materials will be stored at temporary storage areas, the materials will be Included in Air quality (Settled dust and PM10/PM2.5)
Air Dust emissions, MUSKI measurement results, if any
C4 Adverse Low moisturized and compacted to prevent the materials moving with the help of wind; construction
Environment exhaust emissions Supervision costs Maintenance records of all machinery and equipment
 Tire cleaning ponds will be installed at the exit of WWTP site to prevent mud transport on roads; Consultant
Monitoring report findings
 Loading and unloading operations will be performed without throwing/scattering;
 During transportation, excavated materials will be covered with nylon canvas or materials with grain size larger Air quality grievance records
than 10 mm;
 Exhaust systems of the vehicles will be controlled regularly (biennially) through exhaust emission decals;
 Modern equipment and tools that can provide EU emission standards during the construction activities will be
selected;
 Well and adequate maintained vehicles shall be used. Regular maintenance of machinery and equipment will
be ensured;
 Relevant provisions of the Regulation on Air Pollution Control Sourced from Industry and Regulation on the
Assessment and Management of Air Quality will be complied with to minimize air emissions sourced from
construction machinery and trucks;
 Construction vehicles will not be permitted to keep engines running while waiting to enter the site or waiting
on-site;
 Any damage caused by insufficient or lack of dust suppression measures (i.e. pollution of the surrounding
area, transportation of dust with wind to a residential area, wind-blown dust deposits etc.) will be compensated
by the construction contractor;
 A Pollution Prevention Plan that is in line with OP 4.01 and WBG EHS Guidelines (both general and sectorial)
should be prepared.

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
A Noise Management Plan that is in line with OP 4.01 and WBG EHS Guidelines (both general and sectorial)
should be prepared before the construction phase to ensure
 The machinery and equipment to be used during the land preparation and construction activities will not be
operated at the same point/location but homogeneously distributed in the site;
 Attention will be given to the selection of equipment with low noise level;
Noise level measurement results
 The maintenance of the construction machinery and equipment will be carried out regularly and regulatory Contractor
speed limitations will be followed for construction vehicles and this should be included in the Transport and Included in Construction machinery and equipment maintenance
Increase in noise MUSKI log
C5 Noise Adverse Medium Traffic Management Plan to be prepared by the Contractor construction
levels Supervision costs Noise grievance records
 The works will be performed day-time; no night work unless it is absolutely necessary; Consultant
Monitoring report findings
 Construction noise barriers will be used at north-eastern boundary of the WWTP site and around the TM-6
Pumping Station and by doing so, around 5 to 10 dBA noise reduction would be achieved at the receptor.
 Trees will be planted to the WWTP site, especially its north-eastern boundary, and around the pumping
stations.
 Establishment of a grievance mechanism defined in the SEP to manage noise related grievances as well.
A Water Resources and Effluent Management Plan that is in line with the OP 4.01 and WBG EHS Guidelines (both
general and sectorial) should be prepared before the construction phase to ensure:
 Surface runoff or wastewater generation due to dust suppression activities will be prevented;
 The limited amount of domestic wastewater generated at site will be sent to a temporary isolated impermeable Visual observations
septic tank, then it will be sent to the nearest WWTPs after pumped-out from septic tanks by sewer trucks.; Surface water / groundwater quality analysis and
Water  The units of the Project that are in touch with water, wastewater and chemicals will be constructed with using Contractor measurements that include spill-related pollutants,
Resources Water requirement concrete with appropriate cement ratio and durability in order to provide basement impermeability. Thus, no Included in when needed
MUSKI
C6 and wastewater Adverse Low leakages to soil and groundwater will occur during the operation phase of the Project. construction Septic-tank impermeability
(Surface and generation Supervision costs
groundwater)  Construction activities may pose the potential for accidental release/leakages of petroleum-based products, Consultant Septic-tank pump out records
such as lubricants, hydraulic fluids, or fuels during their storage, transfer, or use in equipment. All chemical
Wastewater disposal agreements
storage containers, including diesel fuel, and hazardous liquid waste drums/containers should be placed in
secondary containment so as to minimize the risk of soil, surface water and groundwater contamination during Monitoring report findings
construction
 A Pollution Prevention Plan that is in line with OP 4.01 and WBG EHS Guidelines (both general and sectorial)
should be prepared.
A Waste Management Plan shall be prepared that is in line with OP 4.01 and WBG EHS Guidelines (both general
and sectorial) should be prepared before the construction phase
 Wastes to be generated within the scope of the Project will be managed in accordance with the waste
management hierarchy;
 Wastes will only be temporarily stored on site and final disposal will be carried out outside the facility;
 Removal of the excavated material, which will not be used for backfilling, from the site at regular intervals
without waiting These materials will be transferred to Municipality’s permitted excavation waste storage sites by
licensed transportation companies;
 Waste recycling, transport, and disposal will be carried out by means of licensed companies and/or Milas Types and amounts of waste generated
Municipality; Waste segregation practices (amount of waste per type)
 Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water Contractor
Included in Proper temporary waste storage area on site and
resources will absolutely not be in question; MUSKI related storage records
C7 Waste Waste generation Adverse Low construction
 A Pollution Prevention Plan that is in line with OP 4.01 and WBG EHS Guidelines (both general and sectorial) Supervision costs Waste Disposal Agreements and Records
should be prepared Consultant
Waste Grievance Records
 All kinds of implementations that may threaten personnel or public health will be avoided in all activities
Monitoring Report Findings
involving collection, temporary storage, transport and disposal of wastes throughout the Project;
 Wastes to be temporarily stored on site will be delivered to licensed transport vehicles appropriate to the type
of waste for disposal. Information related to the operations in this context will be recorded and the records will
be kept in the administrative building, and
 Hazardous or non-hazardous inscription, waste code, stored waste amount and storage date will be
indicated/labelled on wastes temporary stored by classifying according to their properties. The reaction of
wastes with each other will be prevented by the measures (impermeable base, drainage, top cover, different
compartments based on type of wastes, etc.) taken in the Temporary Storage Area. The permit for the
Temporary Storage Area will be obtained from the Muğla Provincial Directorate of MoEUCC.

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 The sewerage network lines, discharge line and pumping stations will mostly be constructed within the urban
area. Therefore, no protected and sensitive ecosystems or species are foreseen to exist within the project
area. However, prior to the land preparation phase, definite working areas will be set up where activities will be
conducted.
 Construction works at the WWTP site will be done gradually so that it will give enough time to possible fauna to
escape.
 Mixing any chemical substances, that is used in the construction area, in waterbed and/or aquatic ecosystems
will be prevented.
 Excavation materials will not be dumped onto riverbed.
 Especially during the breeding season of fish species (April-June), any intervention on riverbed will be
prevented.
 Avoid and/or minimize dust emissions by lightly watering the immediate surroundings of construction sites, and No accidental mortality of fauna species
wetting the stored material Contractor No mixing any chemical substances and excavation
Terrestrial and Disturbance on  The access of local people and wildlife in the construction site will be controlled by fencing the working area. Included in material
MUSKI
C8 Freshwater flora and fauna Adverse Low The entry of personnel and third parties into the facility will be carried out in a controlled manner, construction
Biodiversity species Supervision costs Reforming the spawning and sheltering area for aquatic
 Project construction sites and access roads will be separated from other areas with appropriate signboards, Consultant organisms
signs and fences. Monitoring Report Findings
 Construction waste generated due to project activities will first be stored at designated storage areas and then
disposed
 Monitoring studies in Hanay Creek will be conducted in operational phase with aquatic biologist on appropriate
seasons, as appropriate
 Project workers will not be allowed to bring any live animals or plants into the construction site to avoid the risk
of pest/invasive species establishing in the Project Area,
 If there is a species that has limited mobility, transfer to safer locations if encountered during construction
 If there is a nest of birds species, the nest should be marked with a safety strip about 3 meters in diameter and
an expert ornithologist should be informed
 The natural structure of the riparian vegetation will be preserved which forms the spawning and sheltering area
for many aquatic organisms.
A Transport and Traffic Management Plan that is in line with the WBG EHS Guidelines (both general and sectorial)
will be constituted and implemented to ensure the following:
 Disruptions to traffic and road transport will be minimized. The contractor shall ensure that the roads remain
open to traffic during construction activities;
 Trucks, trailers and other vehicles to be used to transport necessary equipment and materials will be provided
to comply with the speed limits. MUSKI will ensure that the Contractor will comply with Highways Traffic Law,
Road Transport Law and the regulations issued in compliance with these laws, as well as WB policies,
standards, and guidelines.
 Prior to construction activities, the Contractor will install all signs, barriers and control devices needed to
ensure the safe use of the road by traffic and pedestrians, as required by the transport and traffic management
plan to be prepared.
 The Contractor will take and ensure the implementation of necessary precautions in terms of road traffic safety Construction Plan
along the road by cooperating with the relevant authority/administration. In addition, precautions will also be Contractor Public disclosure of road closures and diversions
Increased traffic taken in the entry and exit of the treatment plant. Included in
MUSKI Traffic flow and patterns
C9 Traffic Difficulties in road Adverse Low  Signs, crossing guards and other appropriate safety features will be incorporated at grade level rail and road construction
Supervision costs Number of complaints
access crossings;
Consultant Number of road traffic accidents
 Safe-driving training will be provided for all Project proponents and their main suppliers;
Number of drivers trained
 Local authorities and residents in a working area will be consulted and informed before any detours for
construction or diverted public traffic are established;
 Disposal sites and haul routes will be identified and coordinated with local officials;
 Construction vehicles will use temporary roads constructed for that purpose to minimize damage to agricultural
land and local access roads. Where local roads are used, they will be maintained and reinstated to their
original condition after the completion of work;
 In case any road, facility, building etc. will be damaged due to the activities originating from the construction
activities the necessary maintenance, improvement and compensation works will be done by the Contractor
promptly in accordance with the responsible authority;
 MUSKI will disclose construction plan to the public. This will help people to know when there will be
interruptions in traffic and on which roads the access will be limited.

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 Workers will be provided with documented information that is clear and understandable, regarding their rights
under national labor law; including collective agreements, their rights related to hours of work, wages, overtime,
compensation, and benefits as of start-up of working relationship and when any material changes occur,
 Workers will not be discouraged from electing worker representatives, forming or joining workers’ organizations
of their choosing, or from bargaining collectively, and will not discriminate or retaliate against workers who
participate, or seek to participate, in such organizations and collective bargaining, Workers’ Grievance Records
Contractor
 Particular concern will be paid on principles of non-discrimination and equal opportunity. In this respect, Included in Presence of union or workers’ representative
MUSKI
C10 Labor Force Working Conditions Adverse Low employment decisions (i.e. recruitment and hiring, compensation, wages and benefits, working conditions and construction
terms of employment, access to training, job assignment, promotion, termination of employment or retirement, Supervision costs Findings of Monitoring Report
and disciplinary practices) will not be made on the basis of personal characteristics unrelated to job Consultant Labor/social security records
requirements. Wages, work hours and other benefits will be per the Turkish Labor Law,
 A grievance mechanism defined in the SEP will be implemented to raise workplace concerns. The workers will
be informed about the grievance mechanism at the time of recruitment and make it easily accessible to them.
 A Code of Conduct will be defined by MUSKI and signed by all workers of the Project, including contractors
and subcontractors before works start.
 Employment of child labor and forced labor will be prevented.
 Contractors will be required to have age verification system, ensuring no one under 18 years old are involved
in hazardous works as indicated in the LMP.
 Stipulations of Ministry Circular on Covid-19 Measures to be taken at Construction Sites will be followed.
 Guidance, directives and recommendations of Republic of Turkey Ministry of Health, Republic of Turkey
Protecting the Ministry of Family, Labor and Social Services, and World Health Organization shall be followed and all relevant Contractor
Workforce necessary measures shall be taken in case of an outbreak of any other pandemic/communicable disease Included in
MUSKI
C11 Labor Force Adverse Low including COVID-19. construction No child and forced labor
(including Supervision
 Preparation and implementation of site-specific contingency / emergency / crisis management / action plan costs
pandemic) Consultant
regarding COVID-19 and any other pandemic/communicable disease risk. Contingency plans should consider
arrangements for the storage and disposal arrangements for medical waste, which may increase in volume and
which can remain infectious for several days (depending upon the material). To ensure that individuals roles
and responsibilities are clear, contingency plans should be communicated widely.
 Provide regular trainings to workers on COVID-19 symptoms, how to be protected and what to do when
symptoms appear.
 Construction operations of the project will be in line with good industrial practices. Contractor
 Speed restrictions and equipment to optimize fuel efficiency will be adopted by construction vehicles. Included in
Climate MUSKI Monitoring Result Findings
C12 Emission of GHG Adverse Low  Regular maintenance of construction vehicles and equipment will be applied. construction
Change Exhaust decal follow-up records
 Energy uses associated with construction vehicles and equipment will be monitored. Supervision costs
 Trainings will be performed on project personnel regarding energy efficiency Consultant

 As required by Article 4 of Law on the Conservation of Cultural and Natural Properties (2863 Numbered Law),
chance finds procedure will be implemented during land preparation and construction works. In this content: Visual observation
Archaeological Contractor
- Construction works will be stopped immediately in case of finding any movable or immovable cultural No costs Official notification to authorities
C13 and cultural Chance finds Adverse Low asset by chance. Supervision involved Number of chance finds
heritage - Related Civilian Authority or Museum Directorate will be informed latest in three days. Consultant
Monitoring Report Findings
- Works will not proceed until official notification is received

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 An occupational health and safety engineer/expert should be appointed and an adequate OHS organizational
structure should be defined, as per the national legislation.
 A risk assessment should be done before commencing the works and personnel should be trained regarding
any potential risks.
 Project and site-specific OHS Management Plan based on construction site OHS risk assessment and that will
also cover measures to address COVID-19 and/or any other pandemic/communicable disease risk, which will
be in line with the WBG EHS guidelines (both general and sector specific) should be developed before the
commencement of works and implemented on site.
 An Emergency Preparedness and Response Plan based on construction site OHS risk assessment and
covering also the issues about the contagious diseases as well as COVID-19 pandemic should be prepared.
 Site implementations should be monitored by OHS Engineer,
 All Project staff shall comply with the environmental, health and safety policies and guidelines.
 Project staff will include first aid trained personnel. In case of emergency where an intervention is required,
personnel will be sent to the nearest health centre by appropriate means.
 The Contractor will maintain the sufficiency of the technical requirement of the machinery, equipment, and tools
to be used in the activities.
 Moving parts of machinery and equipment will be equipped with appropriate protective systems (e.g. metal
shields etc.), minimizing the risk of injury or damage to the person using the machine or equipment.
 Personal factors that may create and control risks during activities (e.g. long hair, jewellery and accessory use,
clothing etc.) will be removed from the site by the regulations brought by the field management. Project staff
will be informed about the relevant regulations within the scope of the training program.
 Drivers and operators will be trained to comply with traffic rules and to control the vehicles and equipment they
use against risks and hazards originating from vehicle traffic. Required traffic signs will be placed in the Project Incident Records
Site and its surroundings. Machine operators and other employees will be informed and alerted about the Number of nonconformities
relevant signs. Period of disease occurrence
 Areas where excavation work is to be carried out will not be accessible other than the authorized personnel. Number of personnel who are infected with an
The loading and unloading activities shall be carried out together with the persons to oversee the personnel to infectious disease
carry out the activity. Contractor
Included in Training records
Occupational MUSKI
C14 Labor Force Adverse High  Since the works will be performed at areas close to the public, the public access to these areas shall be construction
Health and Safety Supervision Work Permits
restricted by any means. If a trench needed to be left open for night, the sufficient illumination of the area shall costs
be ensured by MUSKI and necessary signs shall be placed, and the area shall be enclosed with barriers. Consultant Monitoring Report Findings
 Work areas will be equipped with warning signs (e.g. "Hazard", "Entry Prohibited", etc.) in accordance with the H&S reports
quality and potential risks of the work to be performed in that area. H&S meetings
 Personal Protective Equipment will be provided for the workers according to the nature of work to be Emergency drills
performed. The necessary trainings will be carried out for their use,
 Smoking will be prohibited where the risks of fire is high and all necessary precautions will be taken in the Grievance records
Project Area to prevent possible fires from construction activities. All the workers will be informed about the
action plan in case of a fire,
 The relevant plans and procedures of the relevant Turkish legislation and the MUSKI will be complied within
the OHS measures and practices.
 Employees will be informed about the hazards that may cause from their work and thus a safer work
environment will be created.
 All equipment will be operated in proper working order,
 The necessary health and safety signs and traffic signs will be placed around the project site. Employees will
be informed and alerted about the subject matter markings,
 Trainings will be given to employees and operational and maintenance personnel within the scope of the
Regulation on Procedures and Principles of Occupational Health and Safety Trainings and measurement and
evaluation activities will be carried out after the trainings,
 Equipment that meets international standards in terms of performance and safety will be used at the plant,
 Appropriate ventilation systems should be installed at where methane accumulation is expected,
 In order to minimize the risks and hazards that may arise (e.g. natural disasters, accidents, equipment
malfunctions etc.) on human health and safety, safe working environments in the working sites will be
established and physical hazards and risks will be prevented.
 Railings will be installed around all tanks and pits,
 Confined Space Entry Procedure will be prepared in accordance with applicable national requirements and
internationally accepted standards,
 Trainings for operators who work with chemicals will be conducted regarding safe handling practices and
emergency response procedures,

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 Sufficient number of personal gas detection equipment will be provided for the employees,
 Stipulations of Ministry Circular on Covid-19 Measures to be taken at Construction Sites will be followed.
 Incidents or accidents related to the Project will be notified and reported in line with the national and WB’s
standards and all incidents will be registered.
 In the event of any significant incident or accident (e.g. environmental, social, labor or lost-time incidents) the
Contractor shall immediately notify MUSKI and MUSKI shall inform ILBANK and WB within three business
days. Then, within 30 days, a report on the root causes of the incident and the corrective actions to be taken
will be presented to ILBANK and WB.
 MUSKI will ensure that the contractors will have code of conduct (CoC) and this CoC will be signed during the
start of the work. Employees should be trained/informed on the rules that apply on site grounds in particular to
interaction with local community
 Where a worker may be exposed to any chemical, physical or biological hazard to such an extent that her/his
health may be adversely affected, appropriate preventive measures shall be taken, including:
o Replacing dangerous goods with harmless or less dangerous substances where possible
o Applying technical measures to the plant, machinery, equipment or process
o Where it is not possible to comply with above measures, applying other effective measures, including the
use of personal protective equipment and protective clothing
 Where workers are required to enter any area in which a toxic or harmful substance may be present, or in
which there may be an oxygen deficiency, or a flammable atmosphere, adequate measures shall be taken to
guard against danger.
 The wastes will not be destroyed or disposed of in a way that is harmful to health in the construction site.

 Subcontractors will be reputable and legitimate enterprises and have an appropriate ESMS that will allow them
Workers Engaged to operate in a manner consistent with the labor conditions requirements, Contractor
Included in Sub-contractor Agreements
by Third Parties  The performance of subcontractors will be monitored such that human rights policy and labor rights of all MUSKI
C15 Labor Force Adverse Low construction Grievance Records
and the Supply workers are exercised properly, Supervision costs Monitoring Report Findings
Chain  The workers of subcontractors will have access to the overall grievance mechanism to be established for the Consultant
Project.
Landscape and Contractor
Nuisance for the  The construction works will be limited to day time only. No costs Visual observation
C16 Visual Adverse Medium Supervision
People  The construction plan will be disclosed to the public. involved Monitoring Report Findings
(Aesthetics) Consultant
General
Community
construction related  A Community Health, Safety, and Security Management Plan that is in line with WBG OP/BP 4.01 Contractor Included in
Incident records
C17 Health and Adverse Low Environmental Assessment and WBG EHS Guidelines (both general and sector specific) will be developed by Supervision construction
impacts on Grievance records
Safety the construction contractor Consultant costs
community
 Community Health, Safety, and Security Management Plan that is in line with WBG OP/BP 4.01 and WBG
EHS Guidelines (both general and sector specific) will be developed by MUSKI or security services provider
before the construction phase. MUSKI and contractor will ensure that the plan is actively implemented.
 Persons and/or organizations with the necessary permits will be assigned to ensure the security of the Project
Area (e.g. private security companies/officials). These persons and/or organizations shall regularly monitor the Contractor
Community facility and its surroundings. The special security applications and officials' authorities within the scope of the Included in Active CCTV system
C18 Health and Encroachment Adverse Low project shall comply with the provisions of the Regulation on the Implementation of the Law on Private Security MUSKI construction Security reports
Safety Services and the Law on Private Security Services. Supervision costs Visitor logs
Consultant
 In addition to safety personnel, monitoring of the Project Site for security purposes will be provided by a closed
circuit camera system which will be installed at appropriate distances on the site boundary (e.g. 30-40 meters)
to provide daytime and night-time monitoring of the whole area.
 Entry of staff and third parties into the working site will be carried out in a controlled manner from the doors at
which authorized security personnel will work.

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 Impact
Definition of Type of Significance
No. Topic Measures to be Taken Responsibility Cost Key Performance Indicators
Potential Impact Impact Before
Mitigation
 All details of the Gender-Based Violence (GBV) and Sexual Exploitation and Abuse/Sexual Harassment
(SEA/SH) survivors will be kept strictly confidential in the Grievance Register Database; and
 The GM Officer will not ask for, or record, information on more than the following related to the GBV and
SEA/SH allegation:
Gender-Based - The nature of the complaint (what the complainant says in her/his own words without direct
Contractor
Violence (GBV) and questioning); Included in
Stakeholder MUSKI
C19
Engagement
Sexual Exploitation Adverse Low - If, to the best of the survivor’s knowledge, the perpetrator was associated with the project; and construction Grievance records
and Abuse/Sexual - If possible, the age and sex of the survivor. Supervision costs
Harassment Consultant
- The GM officer would be responsible to share the service providers (provincial directorate of
family and social services, municipality’s or local NGOs’ women and care centers with the
survivor
- The GM officer would direct the case to the legal authorities as per the national legislation in
the country, with the consent of the survivor
 At the beginning of construction activities, a MUSKI Representative will conduct face to face meetings with the Contractor
Impacts on Tourism tourism enterprises and local businesses in order to inform them about the usage of grievance mechanism for Included in Grievance records
Socioeconomic MUSKI
C20 and Local Adverse Low the cases of significant income losses. construction
Environment Construction schedule
Businesses  The construction activities around the tourism enterprises will be performed at off-season (October 15-May Supervision costs
15), as much as possible. Consultant

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Table VII.2 Operation Phase Impact Mitigation Plan
Definition of Type of Impact Significance
No. Topic Measures to be Taken Responsibility Costs Key Performance Indicators
Potential Impact Impact Before Mitigation
An Odour Management Plan will be prepared and implemented that offers strategies to ensure the following
especially at the WWTP site:
The first level measures:
 Prevention of wastewater influents which exceed treatment plant capacity.
 Reduction of solid waste and activated sludge amounts.
 Increasing disposal frequency of screenings.
 Proper and timely disposal of sludge to prevent flies and odour.
 Increasing aeration rate in biological treatment process.
 Addition of chlorinated water to sludge thickeners if activated sludge is in open area.
 Addition of lime to activated sludge.
 Keeping water level under control in order to prevent turbulence as a result of instant decrease of water.
If odour nuisance prevails after the proper implementation of first level measures, the second level measures
shall be taken. These are:
 Addition of oxidizing material (such as hydrogen peroxide, sodium hypochloride) (oxidizing materials,
prevent generation of especially hydrogen sulphide). Addition of sodium hydroxide can also be considered. Grievance Records
Sodium hydroxide will dissolve hydrogen sulphur gas in water.
O1 Odor Odor nuisance Adverse Medium MUSKI Included in the operational costs Odor Measurement Results
 Preventing anaerobic bacteria with control of pH levels or disinfection.
Monitoring Report Findings
 Oxidizing odorous compound by the help of chemicals.
 Planting trees in the WWTP site and the buffer zone around the treatment plant for the prevention of odour
distribution.
If nuisance still prevails after implementation of first and second measures, the final measure shall be
determined as:
 Enclosing of preliminary treatment units, aeration tanks and bio-P tanks

Apart from that, following mitigation measures will be implemented throughout the Project.
 Establishment of an operating grievance mechanism to manage odor related grievances.
 Maintaining pipelines and ensuring effective management and operation of the sewerage system including
effective maintenance of all elements of the sewerage system and rapid response to emergencies.
 Regular maintenance and cleaning works shall be conducted on the machinery and equipment in order to
prevent occurrence of odor.
 Regular and sufficient ventilation at the pumping stations will be provided.
 Trees will be planted around the pumping station areas.

 During the procurement of equipment and machinery, sound levels given in the technical
specifications/data sheet will be taken into consideration,
 Relevant provisions and limit values of national legislations and World Bank Group’s General EHS
Guidelines and Sectorial Guidelines will be complied with during the operation phase.
Noise Measurement Results
Increase in noise  Equipment generating noise during the operation of the plant will be located in isolated closed buildings and
O2 Noise Adverse Low MUSKI Included in the operational costs Grievance Records
levels some of them will be submerged in wastewater, if necessary.
Monitoring Report Findings
 All pumping stations will be built underground and building materials that provide sound insulation will be
used.
 Natural noise barriers such as trees will be planted particularly to the east and south borders of the WWTP
and around the pumping stations.

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 Definition of Type of Impact Significance
No. Topic Measures to be Taken Responsibility Costs Key Performance Indicators
Potential Impact Impact Before Mitigation
A Water Resources and Effluent Management Plan shall be prepared and implemented that includes measures
and procedures for operational activities.
 Broken pipes and other repairs to be undertaken without delay,
 Pumps and pumping stations to be adequately maintained,
 All storage tanks and drums will be placed on concrete areas with proper secondary containments. When
necessary; spill kits, absorbent pads or materials and adsorbent sands will be provided near the chemical Incident Records
Sewage storage areas at all times. Monitoring Report Findings
Overflows
Water  System overflows will be prevented as much as possible by using level meters, Hanay Creek monitoring
O3 Adverse Low MUSKI Included in the operational costs results
Resources  Bypass of the treatment system will be minimized
Discharge of Results of further researches
treated effluent  Effluent water quality of the WWTP will comply with the limit values stipulated in the Urban Wastewater
Treatment Regulation and World Bank Group’s General EHS Guidelines and Sectorial Guidelines,
 An Emergency Response and Preparedness Plan to be developed and implemented
 The water quality of Hanay Creek will be monitored regularly, and if deemed, necessary further mitigation
measures will be developed.
 MUSKI will search options to increase the effluent water quality based on the assimilative capacity of the
receiving body, if needed.
A Sludge Management Plan and a Waste Management Plan that are both in line with WB Operational Policies
and WBG EHS Guidelines (both general and sector specific) will be prepared and implemented that cover the
following:
 Wastes to be generated within the scope of the Project will be managed in accordance with the waste
management hierarchy.
 Wastes will only be temporarily stored on site and final disposal will be carried out outside the facility.
 Waste recycling, transport and disposal will be carried out by means of licensed companies and/or related
municipalities.
 Incineration or burying of wastes by any means at site and/or dumping of wastes to nearby roads or water Proper temporary waste
resources will absolutely not be in question. storage are on site and related
 All kinds of implementations that may threaten personnel or public health will be avoided in all activities storage records
involving collection, temporary storage, transport and disposal of wastes throughout the Project. Type and amount of wastes
 Wastes to be temporarily stored on site will be delivered to licensed transport vehicles appropriate to the generated including sludge
Waste and solid type of waste for disposal. Information related to the operations in this context will be recorded and the
O4 Solid Waste Adverse Low MUSKI Included in the operational costs Waste Disposal Agreements
generation records will be kept in the administrative building.
and Records
 After stabilization and dewatering, the excess sludge will be analysed to determine compliance with the
Annex-2 of the Regulation on Landfilling of Wastes and if it is deemed appropriate, the sludge will be Waste Grievance Records
collected by the licensed disposal companies determined by MUSKI every year. After that, the sludge will Monitoring Report Findings
be disposed in accordance with the provisions of Urban Wastewater Treatment Regulation and other Waste segregation practices
relevant legislation. According to the information retrieved from MUSKI, the sludge will be transported by (amount of waste per type)
competent and licensed firms to the landfill which has enough capacity. Sludge will be stored in the landfill.
 If sludge would be determined as hazardous, the sludge will be sent to Anadolu Tehlikeli Atik Depolama
Sanayi ve Ticaret A.Ş. for disposal by competent and licensed firms.
 Hazardous or non-hazardous inscription, waste code, stored waste amount and storage date will be
indicated/labelled on wastes temporary stored by classifying according to their properties. The reaction of
wastes with each other will be prevented by the measures (impermeable base, drainage, top cover,
different compartments based on type of wastes, etc.) taken in the Temporary Storage Area.
 More sustainable alternatives for sludge disposal will be researched by MUSKI.
 Workers will be provided with documented information that is clear and understandable, regarding their
rights under national labor law; including collective agreements, their rights related to hours of work, wages,
overtime, compensation, and benefits as of start-up of working relationship and when any material changes
occur,
 Workers will not be discouraged from electing worker representatives, forming or joining workers’ Workers’ Grievance Records
organizations of their choosing, or from bargaining collectively, and will not discriminate or retaliate against Presence of union or workers’
workers who participate, or seek to participate, in such organizations and collective bargaining, representative
O5 Labor Force Working Conditions Adverse Low MUSKI Included in the operational costs
 Particular concern will be paid on principles of non-discrimination and equal opportunity. In this respect, Findings of Monitoring Report
employment decisions (i.e. recruitment and hiring, compensation, wages and benefits, working conditions
and terms of employment, access to training, job assignment, promotion, termination of employment or Labor/social security records
retirement, and disciplinary practices) will not be made on the basis of personal characteristics unrelated to
job requirements. Wages, work hours and other benefits will be per the Turkish Labor Law,
 A grievance mechanism for workers will be provided to raise workplace concerns. The workers will be
informed about the grievance mechanism at the time of recruitment and make it easily accessible to them.
 Employment of child labor and forced labor will be prevented.
Protecting the  MUSKI will be required to have age verification system, ensuring no one under 18 years old are involved in
O6 Labor Force Adverse Low MUSKI Included in the operational costs No child and forced labor
Workforce hazardous works as indicated in the LMP.
 Stipulations of Ministry Circular on Covid-19 Measures to be taken at Construction Sites will be followed.

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 Definition of Type of Impact Significance
No. Topic Measures to be Taken Responsibility Costs Key Performance Indicators
Potential Impact Impact Before Mitigation
 Subcontractors will be reputable and legitimate enterprises and have an appropriate ESMS that will allow
Workers Engaged them to operate in a manner consistent with the labor conditions requirements,
by Third Parties  The performance of subcontractors will be monitored such that human rights policy and labor rights of all Grievance Records
O7 Labor Force Adverse Low MUSKI Included in the operational costs
and the Supply workers are exercised properly, Monitoring Report Findings
Chain  The workers of subcontractors will have access to the overall grievance mechanism to be established for
the Project.
Climate  Operations of the project will be in line with good industrial practices.
O8 Emission of GHG Adverse Low MUSKI Included in the operational costs Monitoring Result Findings
Change  Trainings will be performed on project personnel regarding energy efficiency.

The existence of  It is recommended MUSKI to plant trees at the borders of the plant
Landscape
the Treatment Plant  MUSKI should paint the visible buildings to colours suits to the background.
O9 and Visual Adverse Low MUSKI Included in the operational costs Monitoring Report Findings
and pumping  Landscaping of pumping stations will be conducted compatible with the existing landscape of the park
(Aesthetics)
stations areas and trees will be planted, as appropriate.
 Generated wastes will be managed as described in the Waste Management Plan. Uncontrolled disposal of
wastes is forbidden and all wastes will be sent to final disposal and/or recycle by licensed companies.
 Generated sludge will be collected in impermeable containers and will be sent to final disposal based on
the characteristics of the sludge, in accordance with the Sludge Management Plan. Uncontrolled sludge
Community’s disposal is forbidden.
exposure to
disease due to  All unit shutdown requirements will be scheduled at least one week beforehand and MUSKI will make Monitoring Report Findings
Community improper handling necessary adjustments.
Period of disease occurrence
O10 Health and of wastes, including Adverse High  In major shutdowns of the plant or biological treatment units that require longer times, nutrition levels will be MUSKI Included in the operational costs
Safety Training records
sludge maintained at the biological treatment units, aeration will be stopped after one day for aerobic processes.
Recirculation will be turned down for anaerobic processes, and pH regulation and nutrient dosing will be Grievance records
conducted only when the gas production is less than 10% of the original gas production.
Failure of operation
 During the longer shutdowns or failures, MUSKI will inform Provincial Directorate of Environment,
Urbanisation and Climate Change regarding the situation.
 During excessive loads that the WWTP cannot handle, the bypass line of the existing plant will be used to
bypass the load.
 Community Health, Safety, and Security Management Plan that is in line with WBG OP/BP 4.01 and WBG
EHS Guidelines (both general and sector specific) will be developed by MUSKI or security services
provider before the commencement of operation phase. MUSKI will ensure that the plan is actively
implemented.
 Persons and/or organizations with the necessary permits will be assigned to ensure the security of the
Community Project Area (e.g. private security companies/officials). These persons and/or organizations shall regularly Active CCTV system
Health, Community monitor the facility and its surroundings. The special security applications and officials' authorities within the Security reports
O11 Adverse Low MUSKI Included in the operational costs
Safety and encroachment scope of the project shall comply with the provisions of the Regulation on the Implementation of the Law on Visitor logs
Security Private Security Services and the Law on Private Security Services.
 The entrance to the existing WWTP will continue to be restricted through strengthening security procedures
such as repair of existing fences, installation of security cameras at key access points and use of a site
visitor register.
 Sufficient lighting of the WWTP will be ensured.
Community Electrocution from
 Regular vegetation clearance and maintenance requirements of the energy transmission line route will be Incident Records
O12 Health and Energy Adverse Low MUSKI Included in the operational costs
carried out while communicating with the related authority. Monitoring Report Findings
Safety Transmission Lines

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 Definition of Type of Impact Significance
No. Topic Measures to be Taken Responsibility Costs Key Performance Indicators
Potential Impact Impact Before Mitigation
 All Project staff shall comply with the environmental, health and safety policies and guidelines.
 Private security officers will be hired in order to provide the security of the plant. The special security
applications within the scope of the Project, and the competent authorities shall be in compliance with the
provisions of the Law on Private Security Services and the Implementation of the Law on Private Security
Services;
 Personal Protective Equipment will be provided for the workers according to the nature of work to be
performed. The necessary trainings will be carried out for their use.
 Smoking will be prohibited where the risks of fire is high. All the workers will be informed about the action
plan in a case of fire.
 All equipment will be operated in proper working order.
 Procedures approved by the MUSKI in the maintenance and repair activities and the requirements of the
technical specifications of the supplier companies will be complied with.
 The necessary health and safety signs and traffic signs will be placed. Employees will be informed and
alerted about the subject matter markings.
 Trainings will be given to employees and operational and maintenance personnel within the scope of the
Regulation on Procedures and Principles of Occupational Health and Safety Trainings and measurement
and evaluation activities will be carried out after the trainings.
 Equipment that meets international standards in terms of performance and safety will be used.
 Appropriate ventilation systems should be installed at where methane accumulation is expected.
 MUSKI will distribute sufficient number of personal gas detection equipment to its employees.
 MUSKI will advise individuals with asthma, diabetes, or suppressed immune systems not to work at the
confined spaces due to greater risk of infection. Incident Records
 MUSKI will ensure the compliance of all the activities with national standards and WBG EHS Guidelines. Period of disease occurrence
 All pandemic outbreak measures recommended by Ministry of Health will be taken. Number of personnel who are
infected with an infectious
 In order to minimize the risks and hazards that may arise (e.g. natural disasters, accidents, equipment disease
malfunctions etc.) on human health and safety, safe working environments in the working sites will be
established and physical hazards and risks will be prevented. Number of nonconformities
Occupational and  The relevant plans and procedures of the relevant Turkish legislation and the MUSKI will be complied Training records
O13 Labor Force Community Health Adverse Medium within the OHS measures and practices. MUSKI Included in the operational costs Work Permits
and Safety
 Work areas will be equipped with warning signs (e.g. "Hazard", "Entry Prohibited", etc.) in accordance with Monitoring Report Findings
the quality and potential risks of the work to be performed in that area. H&S reports
 All necessary precautions will be taken in the Project Area to prevent possible fires from maintenance and H&S meetings
operation activities.
Emergency drills
 Project staff will include first aid trained personnel. In case of emergency where an intervention is required,
Grievance records
personnel will be sent to the nearest health centre by appropriate means.
 MUSKI will maintain the sufficiency of the technical requirement of the machinery, equipment, and tools to
be used in the activities.
 Moving parts of machinery and equipment will be equipped with appropriate protective systems (e.g. metal
shields etc.), minimizing the risk of injury or damage to the person using the machine or equipment.
 Personal factors that may create and control risks during activities (e.g. long hair, jewellery and accessory
use, clothing etc.) will be removed from the site by the regulations brought by the field management.
Project staff will be informed about the relevant regulations within the scope of the training program.
 Drivers and operators will be trained to comply with traffic rules and to control the vehicles and equipment
they use against risks and hazards originating from vehicle traffic. Required traffic signs will be placed in
the Project Site and its surroundings. Machine operators and other employees will be informed and alerted
about the relevant signs.
 The wastes to be generated within the scope of the construction phase of the Project will be managed
under the Waste Management Regulation and the negative impacts on public health will be minimized.
 Areas where excavation work is to be carried out will not be accessible other than the authorized
personnel. The loading and unloading activities shall be carried out together with the persons to oversee
the personnel to carry out the activity.
 In addition to safety personnel, monitoring of the WWTP site for security purposes will be provided by a
closed circuit camera system that will be installed at appropriate distances on the site boundary (e.g. 30-40
m) to provide daytime and night-time monitoring of the whole area.
 Since the maintenance works for sewerage network will be performed at areas close to the public, the
public access to these areas shall be restricted by any means. If a trench needed to be left open for night,
the sufficient illumination of the area shall be ensured by MUSKI and necessary signs shall be placed, and
the area shall be enclosed with barriers.

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 Definition of Type of Impact Significance
No. Topic Measures to be Taken Responsibility Costs Key Performance Indicators
Potential Impact Impact Before Mitigation
 Entrance of operation and maintenance personnel and third parties will be carried out in a controlled
manner.
 After the plant is constructed, necessary electrical test will be carried out to check that the electrical
connections and other related equipment are made properly before the plant is taken into operation.
 Automatic cleaning screens should be used instead of manually cleaning screens to prevent entrance of
cleaning workers into the channels.
 Railings will be installed around all tanks and pits.
 MUSKI will prepare a Confined Spaces Entry Procedure that is consistent with WBG EHS Guidelines and
applicable national requirements.
 MUSKI will conduct trainings for operators who work with disinfectants regarding safe handling practices
and emergency response procedures.
 The whole WWTP site will be fenced, the access of local people and wildlife will be controlled and
encroachment will be prevented. The entry of personnel and third parties into the facility will be carried out
in a controlled manner.
 OHS Management Plan will be prepared before the commencement of the WWTP that will also cover
measures to address COVID-19 and/or any other pandemic/communicable disease risk.
 An adequate OHS organizational structure will be defined, as defined by the local legislation and necessary
number of OHS officers should be assigned to be at the site during working hours.
 A risk assessment will be done before commencing the works and personnel will be trained regarding any
potential risks.
 OHS Personnel will daily inspect the site and if any additional risk is observed relevant plans and trainings
will be renewed.
 Emergency Preparedness and Response (EPR) Plan to cover the issues about the contagious diseases as
well as COVID-19 pandemic will be prepared and implemented.
 MUSKI will ensure that the contractors will have code of conduct (CoC) and this CoC will be signed during
the start of the work. Employees should be trained/informed on the rules that apply on site grounds in
particular to interaction with local community.
 All details of the Gender-Based Violence (GBV) and Sexual Exploitation and Abuse/Sexual Harassment
(SEA/SH) survivors will be kept strictly confidential in the Grievance Register Database; and
 The GM Officer will not ask for, or record, information on more than the following related to the GBV and
SEA/SH allegation:
- The nature of the complaint (what the complainant says in her/his own words without direct
Gender-Based
questioning);
Violence (GBV) and
Stakeholder - If, to the best of the survivor’s knowledge, the perpetrator was associated with the project;
O14 Sexual Exploitation Adverse Low MUSKI Included in operation costs Grievance records
Engagement and
and Abuse/Sexual
- If possible, the age and sex of the survivor.
Harassment
- The GM officer would be responsible to share the service providers (provincial directorate of
family and social services, municipality’s or local NGOs’ women and care centers with the
survivor
- The GM officer would direct the case to the legal authorities as per the national legislation in
the country, with the consent of the survivor

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VII.2 Monitoring Plan

In order to ensure the continuity and effectiveness of the implementation of mitigation

management strategies defined, monitoring plays a key role. The main objective of the Monitoring
Plan is to provide a basis for the evaluation of the impacts of the Project.

Information collected with the monitoring can be used to improve management plans
during all phases of the Project. While impact assessment attempts to encompass all relevant
potential impacts to identify their significance and include appropriate responses for these impacts,
unanticipated impacts may still arise, which can be managed or mitigated before they become a
problem using the information obtained through monitoring. Therefore, monitoring will ensure the
successful implementation of the mitigation/management plans and optimize environmental
protection through good practice at each and every stage of the Project.

Consequently, monitoring studies will provide implementation of impact mitigation

measures and optimization of environmental protection by using best practices at the all stages of
the Project.

Some of the monitoring parameters are determined in the scope of engineering design
studies. Monitoring studies will ensure the accordance with the relevant legislation, contract
necessities and implementation of impact mitigation measures.

Monitoring activities are submitted in tabular form in Table VII.3 and Table VII.4.

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Table VII.3 Land Preparation and Construction Phase Monitoring Plan

When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?
Amount of refilled,
stored, and disposed
excavation materials
Once in a week
Amount of stripped starting from the
and reused topsoil by To assess the efficiency Visual observation Included in Contractor
Storage and usage Construction site and initialization of
C1 indicating reuse of the waste construction
of excavation waste storage areas Records land preparation MUSKI
locations management cost
and construction
Storage conditions of phase
topsoil (humidity and
pile height)

Visual observation Once in a week

Conditions of the starting from the
storage area To see if the chemicals Included in Contractor
Storage and usage Site inspections initialization of
C2 are handled in a proper Storage areas construction
of chemicals Number of leaks, land preparation MUSKI
way Environmental incident cost
spills, etc. and construction
registry phase

Upon grievance
and any
contamination
observed during
Soil quality, including, spot checks
pH, heavy metals,
phosphorus, Sampling and analysis Once prior to
nitrogen, Na, Ca, To assess if there are Spot checks initialization of
any pollution/ Work sites and land preparation Included in Contractor
salts, PAHs
C3 Soil pollution contamination in the storage areas Grievance registration and construction construction
hydrocarbons MUSKI
soils phase cost
Number of oil/fuel Environmental incident
and chemical registry Once in a week
leakages/spills starting from the
initialization of
land preparation
and construction
phase

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 When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?

Visual observation Once in a week

starting from the
Construction site, Waste records Included in Contractor
Amount of waste To record the waste initialization of
C4 Wastes storage areas, and construction
generated per types categories and amounts Site inspections land preparation MUSKI
administration office cost
and construction
Disposal truck register phase

Quarterly starting
Settled dust and from the
PM10/2.5 Nearest sensitive initialization of
Sampling/analysis construction Included in Contractor
receptors for
C5 Air Quality To assess the air quality phase construction
Maintenance records measurements Maintenance records MUSKI
cost
of all machinery and (Nearest resident) Upon grievance
equipment (for settled dust
and PM10/2.5)

Included in Contractor
To assess the noise At the complainants Noise level
Upon grievance construction
levels house/workplace measurements MUSKI
cost

C6 Noise Noise levels Quarterly starting

At Mugla Sitki Kocman
from the Included in
To assess the noise University Fisheries Noise level
initialization of construction Contractor
levels Research and measurements
construction cost
Development Center
phase

Surface water / Sampling and in situ / In case of a

groundwater quality To assess if there are laboratory measurements major spill
analysis and At related water body Included in Contractor
any discharge of Spill In case of a
C7 Water Resources measurements that (wells, surface water construction
pollutants to the surface notices/correspondences leak/spill reaches MUSKI
include spill-related bodies, etc.) cost
waters to authorities in case of to water
pollutants
major spills resources

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 When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?
At related
groundwater body
(wells etc.)
Seasonally
To establish baseline At Hanay Creek: Sampling and in situ / starting from pre-
Contractor
data  Upstream of the laboratory measurements construction
discharge point works
 Downstream of
the discharge
point
Traffic flow and
patterns
Number of
complaints
Number of road Monthly starting
traffic Accidents from the
To assess the project Access roads, and Included in Contractor
initialization of
C8 Traffic Number of drivers caused effects on the work site and its Accident records construction
land preparation MUSKI
trained traffic vicinity cost
and construction
phase
Records of safe-
driving training for all
Project proponents
and their main
suppliers

Daily basis
Visual observation starting from the
Included in Contractor
Number of chance To protect and conserve On and around the initialization of
C9 Chance Finds Official notification to construction
finds the cultural heritages working location land preparation MUSKI
authorities cost
and construction
phase

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 When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?

Number of received
grievances Grievance records
Number of open and (grievance log, received
closed grievances To assess the success grievance forms, etc.) Monthly during Included in Contractor
C10 Grievances Average grievance in responding the needs Administration office the construction construction
response and closure of PAPs Grievances related to the phase cost MUSKI
time GBV and SEA/SH
Variety of grievance allegation
channels

Grievance records Upon grievances

To see if there are any and events Included in Contractor
C11 Community conflicts Number of conflicts conflicts with the Administration office Conflicts with security starting from the construction
community personnel and workers of initialization of cost MUSKI
the Project the Project

Number of
accidents/Injuries
Visual observation
Number of Daily basis
nonconformities Site inspection starting from the
To evaluate the project Included in Contractor
Occupational Health initialization of
C12 Period of disease in terms of OHS Construction site Incident Records construction
and Safety land preparation MUSKI
occurrence implementations cost
Training Records and construction
phase
Number of personnel Work Permits
who are infected with
an infectious disease
Number of employed
person from the local
Job creation and community Employment records Prior to
To record the job Included in Contractor
impacts on local construction and
C13 Business related effects of the Oren and its vicinity Procurement records construction
businesses during MUSKI
growth/increase in Project cost
Inspection construction
income for local
communities

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 When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?
At the beginning
of construction
activities
Access restriction, Number of affected Face-to-face meetings Once in a month
business owner To assess if there are with business owners and Included in
disruption of tourism In the vicinity of the starting from the
C14 any impacts on local field surveying construction MUSKI
and business Loss of income from work sites initialization of
businesses and tourism cost
activities access restrictions land preparation
Grievance Registration
and construction
phase
Upon grievance

Quantity and Once in a week

conditions of cleaning starting from the
tools To keep the general Visual observation initialization of
Environmental hygiene and health Within and around the Included in Contractor
First aid box land preparation
C15 conditions on a healthy work sites Health records of workers construction
hygiene and construction MUSKI
Number of infectious level cost
Grievance Registration phase
and contamination
cases Upon grievance

To prevent any potential Grievance Registration Monthly during

Complaints to Utility Work sites (excavated Included in Contractor
Impacts on harm on the excavation works
C16 Service Providers areas) Meetings with service construction
infrastructure infrastructure MUSKI
providers Upon grievance cost

To monitor improper
Quarterly starting
working conditions, child Employment records Included in Contractor
from the
C17 Labor Force Local employment labor, forced labor and Administration office construction
operation phase
unregistered Grievance records cost MUSKI
of the Project
employment

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 When the
Where the
Which parameters Why the parameters How the parameters parameters
No. Subject parameters shall be Costs Responsibility
shall be monitored? shall be monitored? shall be monitored? shall be
monitored?
monitored?

Security reports Weekly during

Community
the construction
encroachment cases
To control if community Visitor logs phase Included in Contractor
C18 Encroachment encroachment is Administration office construction
prevented Daily during the cost MUSKI
Condition of CCTV
System checks construction
system
phase

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Table VII.4 Operation Phase Monitoring Plan

When the
Which
Why the parameters Where the parameters How the parameters shall be parameters
No. Subject parameters shall Cost Responsibility
shall be monitored? shall be monitored? monitored? shall be
be monitored?
monitored?

Conditions of the
chemical and
disinfectant Daily basis
storage area starting from the
Storage and To see if the chemicals Visual observation Included in
Maintenance initialization of
O1 usage of are handled in a proper Storage areas operation MUSKI
records of Chemical dosing system checks the operation
chemicals way cost
chemical dosing phase of the
system Project

Number of leaks,
spills, etc.
Weekly basis
Type and amount Visual observation starting from the
Treatment plant site, Included in
of wastes To record the waste initialization of
O2 Wastes storage areas and Waste Records operation MUSKI
generated categories and amounts the operation
administration office Site inspections cost
including sludge phase of the
Project
Nearest sensitive
receptors
To assess the impacts At pumping stations Grievance records Included in
O3 Odor Odor level of the odor on the Manholes Site Inspection Upon grievance operation MUSKI
vicinity Close vicinity of the WWTP Sampling/analysis/measurement cost
Close vicinity of the
pumping stations

Nearest sensitive
receptors Included in
To assess the noise Upon grievance
O4 Noise Noise level or Noise measurement operation MUSKI
levels Once in a year
At the complainant's cost
house/workplace

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 When the
Which
Why the parameters Where the parameters How the parameters shall be parameters
No. Subject parameters shall Cost Responsibility
shall be monitored? shall be monitored? monitored? shall be
be monitored?
monitored?

At least the At planned Oren WWTP’s: Monthly starting

following: pH, EC, To assess if there are  Discharge point In-situ measurements from the
Included in
O5
Surface Water BOD, COD, TN, any discharge of  Upstream of the commencement
operation MUSKI
Quality TP, TSS, Total pollutants to the surface Laboratory analysis and of the operation
discharge point cost
measurements
Coliform, Fecal waters  Downstream of the of Milas-Oren
Coliform, E.coli discharge point WWTP

Continuous
Legislation monitoring for the
applicable detectable by
parameters, and Automatic measurement for automation Included in
Effluent water To assess the efficiency Oren WWTP discharge measurement
O6 parameters to be relevant parameters, and operation MUSKI
quality of the treatment unit device
followed according laboratory analysis for others cost
to the WBG
guidelines Weekly basis for
others
Number of
received
grievances
Number of open Grievance records (grievance
and closed log, received grievance forms,
To assess the success etc.) Quarterly during Included in
grievances
O7 Grievances in responding the needs Administration office the operation operation MUSKI
Average grievance
of PAPs phase cost
response and Grievances related to the GBV
closure time and SEA/SH allegation
Variety of
grievance
channels

To see if there are any Grievance records Included in

Community Number of Upon grievance
O8 conflicts with the Administration office Conflicts with security personnel operation MUSKI
conflicts conflicts and/or incident
community and workers of the Project cost

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 When the
Which
Why the parameters Where the parameters How the parameters shall be parameters
No. Subject parameters shall Cost Responsibility
shall be monitored? shall be monitored? monitored? shall be
be monitored?
monitored?

Number and
duration of Weekly during
Shutdown/failure reports
unit/plant operation phase
shutdowns To control if the Included in
Failure of
O9 provisions given in ESIA Administration office operation MUSKI
operation
are managed properly cost
Amount of
During each
discharge during Measurements
shutdown/failure
shutdown/failure

Number of
accidents/Injuries
Number of Visual observation Daily basis
nonconformities starting from the
Occupational To evaluate the project Site inspection Included in
Period of disease initialization of
O10 Health and in terms of OHS Worksites Incident Records operation MUSKI
occurrence the operation
Safety implementations Training Records cost
phase of the
Number of Work Permits Project
personnel who are
infected with an
infectious disease
Community
encroachment Security reports Weekly during
cases To control if community operation phase Included in
Community Visitor logs
O11 encroachment is Administration office operation MUSKI
Encroachment
Condition of CCTV prevented cost
Daily during
system System checks
operation phase
Electrocution Visual observation
Number of To control if the Included in
from Energy Energy Transmission Line Weekly during
O12 accidents/Injuries provisions given in ESIA Site inspection operation MUSKI
Transmission Route operation phase
are managed properly Incident Records cost
Lines
Quarterly starting
Employment records Included in
To keep the records of from the
O13 Labor Force Employment data Administration office operation MUSKI
employment Grievance records operation phase
cost
of the Project

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VII.3 Institutional Arrangements

Main responsible organization for implementation of this ESMP is MUSKI. Besides, on

different phases of the Project, various parties (Contractors, Ilbank, WB etc.) will take responsibility
on various works in the scope of the ESMP. All mentioned works will be coordinated by the MUSKI.
Mitigation management and monitoring tables, which are given in this ESMP, summarize relevant
responsibilities.

In that scope, it is suggested to add below mentioned liabilities to tender documents of any
possible contractor(s):

 Technical characteristics of the ESMP

 Environmental, social, and health and safety liabilities
 Other environmental and social issues that can show-up

VII.3.1 Environmental and Social Management Structure

As the possible impacts of the Project are varied according to the land preparation and
construction, and operation phases and/or impact levels are different, environmental and social
management is assessed separately. ESMP consists of three main components in that scope,
which are as follows:

 Mitigation Management Plan

 Monitoring Plan
 Monitoring Report

Graphical representation of the environmental and social management structure is given in

the figure below.

Environmental and Social Policy

Permits and Environmental and Social Commitments

Other Relevant Environmental and Social Documents

Environmental and Social Management Plan

Updates on the Environmental and Social Management Plan

During Land Preparation and Construction and Operation
Phases

Figure VII.1 Environmental and Social Management Structure

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VII.3.2 Roles and Responsibilities

MUSKI holds ultimate responsibility for the environmental and social performance of the
overall Project, including the technical performance of its contractors and any other subcontractors.
Organizational structure of the MUSKI is provided in Figure VII.2. Within this regard, the
Wastewater Project Chiefship, which is under the Plan Project Investment and Construction
Department, Planning and Investment Branch Directorate, will be the responsible unit from the
implementation and monitoring of the Project. MUSKI’s environmental engineer who is under the
Wastewater Project Chiefship and currently responsible from conducting, managing and monitoring
environmental and social subjects within the projects funded by the World Bank, will act as the
Environmental Manager of this Project, will oversee the implementation of the ESMP and
monitoring progress. The environmental engineer will be supported by environmental and social
consultants, when necessary. Environmental engineer will appoint a representative in the treatment
plant to lead the development of this ESMP, and site implementation of it.

In addition, MUSKI’s social expert who will be employed under Wastewater Project
Chiefship for this Project, will act as the Social Affairs Manager of this Project, and will manage the
social issues determined in the ESIA Report, this ESMP, and their monitoring progress. The social
expert will also manage the grievance mechanism and stakeholder engagement.

However, if necessary, additional coordination team within MUSKI will be established.

Overall, MUSKI is highly experienced in the internationally financed projects.

Supervision consultant will include at least one Environmental Expert, one Social Expert
and one Occupational Health and Safety Expert. Within this context, obligation to employ an OHS
specialist/expert will be added to the contractual requirements of Supervision Consultant. Number
of experts will be increased if necessary. Supervision Consultant will provide supervision of
construction and/or rehabilitation works and installation of equipment. The expert will identify and
manage environmental, social and OHS related risks and initiate corrective actions where
necessary. The expert will also monitor and evaluate performance of services provided by the
contractor. In addition, regular monthly report regarding to environmental, social and OHS issues of
the Project during construction phase will be provided by Supervision Consultant.

ILBANK, being the financial intermediary, is responsible for the satisfactory implementation
of the project including the environmental and social performance. The regional directorate of
ILBANK in Mugla will act as controller of the project compliance during construction period and will
work closely with the MUSKI for the successful accomplishment of the project.

The World Bank and ILBANK will be promptly notified of any incident or accident related to
the Project which has, or is likely to have, a significant adverse effect on the environment, the
affected communities, the public or workers including but not limited to; incidents and accidents
encountered during construction works, environmental spills, etc.

Sufficient detail will be provided regarding the incident or accident, findings of the Root
Cause Analysis (RCA), indicating immediate measures or corrective actions taken or that are
planned to be taken to address it, compensation paid, and any information provided by any
contractor and supervision consultant, as appropriate. It will be ensured that the incident report is in
line with the World Bank’s Environment and Social Incidence Response Toolkit. Subsequently, per
the Bank’s request, a report on the incident or accident and propose any measures to prevent its
recurrence will be prepared.

Therefore, MUSKI will report details of any significant environmental or social incidents
(e.g. fatalities, lost time incidents, environmental spills etc.) within three business days and submit
an incident report, including RCA, precautions and compensation measures taken within 30
business days. ILBANK will forward the incident report to the World Bank immediately upon receipt
from MUSKI. Prompt notification of accident and incidents will remain inclusive under the
contractor’s ESMP.

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 The contractor will construct the project in line with the approved design documents and
will be the responsible body to implement and apply the mitigation measures given in this ESIA
during construction phase. The contractor will adhere its responsibilities specified in this ESIA and
ensure that it is aware of its duties and responsibilities within this ESIA for compliance with national
regulation and WB OPs. The contractor will employ a full time OHS specialist and a full time
environmental and social expert who will instruct and consult the workers on compliant working
structure and implementation of ESIA (including grievance redress mechanism and the applicable
stakeholder engagement activities). Within this context, obligation to employ an OHS
specialist/expert will be added to the contractual requirements of the Contractor. Furthermore, a
competent ESHS manager of contractor will monitor implementation of measures given in the
mitigation plan. The prompt notification of accident and incidents within the scope of construction
works in line with the above-described provisions is the responsibility of the contractor. The
contractor will keep an incident register at construction site throughout the construction and defects
liability period.

The contractor will develop monthly and quarterly Environmental and Social Monitoring
Reports in order to submit to the ILBANK though MUSKI and supervision consultant. During the
construction phase, the contractor firm will train its workers on environmental and social aspects
(including OHS) as per WB’s OPs and national regulations in order to raise environmental and
social awareness. During the defects liability period, the contractor will be responsible for any
repairs of the newly constructed facilities, in accordance with legal regulations as of provisional
acceptance. Within the liability period, the contractor will implement measures given in
Environmental and Social Mitigation Plan for operation.

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Figure VII.2 Organizational Structure of MUSKI

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VII.3.3 Training

One of the main necessities of the ESMP is trainings for the MUSKI’s and contractor’s top
level management and employees. Table VII.5 provides examples of the basic trainings for the
ESMP implementation. The training programs will be developed and delivered by the MUSKI.

Table VII.5 Proposed Training Programme

Module 1

Training course Environmental and social supervision, monitoring and reporting

Participants Environmental staff, technical staff and administrative staff of MUSKI

Soon after the project effectiveness but at least 1 month before the construction of the first
Time
contract. The follow-up training will be scheduled as needed.

Duration Four days of training twice a year to be repeated on a yearly basis until the end of the DLP.

General environmental and social management relating to the Project

Requirements on environmental and social monitoring
Monitoring and implementation of mitigation measures
Guide and supervise contractor in implementation of the ESMP
Content of the
Documentation and reporting
Training
Code of conduct
Sexual exploitation, abuse and harassment training/ awareness
Risk response and control
Other areas to be determined

Trainer Environmental and Social Consultant or Ilbank

Module 2

Training course Implementation of mitigation measures

Contractor, related authorities: On-site construction management staffs, environmental staffs of

Participants
contractor, related authorities

Time After signing the works contract

Duration Three days of training twice a year to be repeated on a yearly basis depending on needs.

Overview of potential impacts and mitigation measures

Requirements of environmental monitoring
Occupational Health and Safety Training
Role and responsibilities of the contractor
Content of the
Content and methods of implementation of environmental mitigation measures
Training
Response and risk control
Preparation and submission of report
Risk response and control
Other areas to be determined

Trainer MUSKI with support of ILBANK

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VII.4 Environmental and Social Monitoring Report

Environmental and Social Monitoring Report is one of the most important tools to record
the monitoring activities.

In that scope, an Environmental and Social Monitoring Report will be prepared in quarterly
basis, in Turkish and English. Monitoring report will at least include all the issues defined in the
monitoring plan.

Results of technical assessments of relevant issues given in Table VII.3 and Table VII.4
will be presented in the monitoring report. The results shall be compared with the national
legislative requirements and World Bank Group EHS Guidelines. The results of the visual
observations together with the key issues observed will be submitted in written form. The report
should focus on the negative findings as well as the good practices. The negative findings should
be supported with the photographical evidence. For each negative observation, a corrective action
should be suggested with a reasonable due date. Any analysis/sampling/measurement report
should be given as an annex of the report together with the relevant assessment and necessary
remediation activities. The findings of the Environmental and Social Monitoring Reports will keep
this ESMP as a living document; thus, the ESMP should be reviewed and revised by the
environmental and social unit of the Municipality according to these findings, if necessary to do so.

The contractor will develop monthly and quarterly Environmental and Social Monitoring
Reports and submit these reports to MUSKI. MUSKI will produce and submit ILBANK quarterly
progress reports including the environmental and social performance of the Project. ILBANK will
prepare and submit to the World Bank regular monitoring reports on the environmental, social,
health and safety performance of the Project semi-annually (every 6 months).

The reports will be prepared in both Turkish and English, and annual performance reports
will be disclosed through MUSKI’s website and at least Turkish versions will be made physically
available at Oren, Turkevleri, and Bozalan neighbourhoods’ muhtar offices.

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VIII. STAKEHOLDER ENGAGEMENT
Stakeholder engagement is the basis for building strong, constructive, and responsive
relationships that are essential for the successful management of a project's environmental and
social impacts. The purpose of stakeholder engagement is to establish and maintain a constructive
relationship with a variety of external stakeholders over the entire life of the project. Initiating the
engagement process in the early phases of the project helps ensure timely public access to all
relevant information and provides the stakeholders with an opportunity to input into the project
design and the assessment of impacts.

Currently, a Project specific Stakeholder Engagement Plan (SEP) is not developed for the
Project. MUSKI aims to finalize the SEP, before the commence of the construction activities, after
the draft SEP is disclosed for public consultations along with the ESIA and other relevant site
specific instruments of the subproject. MUSKI is currently developing site specific SEPs for all of
the sub-projects under their responsibility. Therefore, in this section the information on public
consultation activities and the grievance mechanism for the Project are mentioned along with the
purpose and scope of the SEP.

The SEP will cover the measures to be adopted by MUSKI and the contractors to ensure
effective and efficient community relations during all phases of the Milas-Oren Sewerage System
and Wastewater Treatment Project.

The SEP will developed for;

 To involve and interact with the Project Affected Person, Stakeholders and other
institutions that may be affected by the project or that may affect the project during
the construction phases;
 To ensure continuous and good relations with the members of the local community
and affected parties.
 To minimise impacts and manage those that are unavoidable in order to maintain
good relations
 To increase pre-construction awareness in areas such as construction schedule,
impacts, mitigation measures and recruitment
 To enable pre-notification for any disturbance to infrastructure or utilities;
immediate action for unplanned disturbances
 To avoid impacts to access -- for education, health care, cultural heritage sites,
pasture access, etc.
 To prepare and implement a Grievance Management Procedure, and establishing
a project grievances mechanism that allows for taking, investigating, following up,
reporting and resolving grievances from all stakeholders

VIII.1 Public Participation Meeting-I

Public Participation Meeting-I (PPM-I) was conducted on July 7, 2020 at Oren. Tools used
during the planning stage for informing public are described below. Similar tools can be used for
informing the public in the further stages of the Project. The aim of the public participation meeting
is to inform people who may be potentially affected from the project and to understand their
concerns, opinions and suggestions about the project.

PPM-I was first announced on June 26, 2020 through MUSKI’s website with presentation
to be made during the PPM attached to gather communities’ opinions prior to the meeting. The
announcement is presented in Figure VIII.1. Following that national and local newspaper
announcements were published on June 26 and June 29, 2020 as presented in Figure VIII.2 and
Figure VIII.3, respectively. In addition to these, the correspondence letters were sent to muhtars of
Oren, Turkevleri, and Bozalan neighbourhoods by MUSKI.

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Figure VIII.1 PPM-1 Website Announcement (June 26, 2020, www.MUSKI.gov.tr)

Figure VIII.2 PPM-1 National Newspaper Announcement (June 26, 2020, Birgun)

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Figure VIII.3 PPM-1 Local Newspaper Announcement (June 29, 2020, Milas)

The PPM-1 took place at Oren Labranda Cafeteria by taking necessary COVID-19
measures at 10:30 on July 7, 2020. Before the commencement of meeting, information brochures
regarding the Project were distributed to attendants and A0 maps of the Project made available for
them. The brochure is provided in Annex-3 of this document.

The meeting was held with the participation of representatives from MUSKI, Mugla
Metropolitan Municipality, Milas Municipality, and ENCON. MUSKI performed the moderation of the
meeting. The meeting started with an introduction and explanation of the purpose and scope of the
meeting which is to inform the locals about the Project at hand and understand their concerns,
opinions and suggestions about the project, and followed by a presentation given by ENCON and a
final discussion session where questions, concerns and suggestions were received.

Eighty-four people participated to the meeting including muhtars of Oren, Bozalan and
Turkevleri. The meeting lasted for 1.5 hours. Photographs taken during the meeting are presented
in Figure VIII.4.

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Figure VIII.4 Photos from the PPM-1 (July 7, 2020)

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 Questions received during the Q&A session of the meeting and answers given to them are
summarized below:

Q1: Will odor problems occur due to collectors to be built within the sewerage system?
(Resident of Oren)
A1: When the wastewater velocity in the collectors is above a certain level, odors caused
by H2S can be prevented. This situation will also be taken into consideration in the system to be
built, so odors that may emanate from the collectors will be prevented.

Q2: Where will the treatment plant effluent be discharged, will the wastewater mix with the
sea?
A2: After the treatment, the effluent reaches the quality specified in the legal regulations
and it will be discharged to the Kemer stream 3 located near the facility. The water of Kemer stream
reaches the sea, but since the facility will be built with the principle of advanced biological
treatment, the treatment will be performed at high efficiency, so the effluent from the treatment
plant will not cause pollution in the sea.

Q3: Which regions does the project cover?

A3: The regions covered by the project are Oren, Turkevleri and Bozalan Neighborhoods.

Q4: Will residents have to pay any fee while connecting to the channel?
A4: Pipes to be made between households and sewer collectors will be made under the
responsibility of the residents, but these pipes will only be 1-2 m long. Also, the channel
participation fee will be charged from the households for the connection.

Q5: Will this project prevent water problems frequently experienced in the region?
A5: Within the scope of this project, only a sewerage system and wastewater treatment
plant will be built, the drinking water network is not included in this project.

Q6: What are the exact start date and end date of the project? When will the project be
finalized?
A6: The World Bank will provide the financing of the project. This meeting is held in
accordance with the World Bank procedures. Your opinions that are gathered with this meeting will
be taken into consideration in the ESIA report that is being prepared, and then the tender phase
will begin after the approval of the ESIA report by ILBANK and the World Bank. In the tender
phase, if the necessary approvals are obtained from the World Bank, the construction of the project
will start. If there is no setback during these processes, the project construction is expected to start
in 2021. The project will take approximately 18 to 24 months to complete.

Following the Q&A session, 18 people were selected for socio-economic questionnaire.
Part of the questionnaire findings is previously presented in Chapter IV.3.1. The remaining relevant
information are presented in Table VIII.1 below.

Table VIII.1 Results of Questionnaire Made after the PPM-1

PERCEPTIONS AND EXPECTATIONS

Do you think you are informed enough about the Oren Sewage and Wastewater Treatment Plant Project?
No 26.32%
I have partial information 42.10%
Yes 31.58%
What would you like to learn the most about the project?
When will it start and when will it end

3 After the PPM, the discharge location was changed to Hanay Creek.

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Whether treated wastewater will be used in agriculture
Whether the project covers drinking water supply network
How the connections will be made between the sewer system and detached houses
Where/From which sources (TV, radio, newspaper, municipality announcement, internet, meeting, etc.) did you get the
information about the project?
By my own means 9.09%
Municipal Announcement 54.55%
Internet 18.18%
Social media 9.09%
Newspaper 9.09%
Did you find the public participation meeting useful?
Yes 57.14%
No 28.57%
I don't know 14.29%
What are the benefits of the project in your opinion? Please indicate in order of importance? (health, education,
infrastructure, increase in livelihoods, etc.)
100% of the participants have stated that the main benefit of the project is health.
What are the damages of the Project in your opinion and what do you suggest to prevent these damages?
Wastewater treatment plant discharge that will be made to the sea
Do you think that the region will be affected (either positive or negative) by the implementation of the sewerage network
and wastewater treatment plant?
Yes 31.25%
No 62.50%
I don't know 6.25%

MUSKI will prepare the mentioned SEP with regard to the information provided above.

VIII.2 Public Participation Meeting-II

PPM-II was conducted on February 11th, 2022 at Oren. Tools used during the planning
stage for informing public are described below. The aim of the public participation meeting was to
inform people who may be potentially affected from the Project and to understand their concerns,
opinions and suggestions about the Project.

PPM-II was firstly announced through national and local newspapers that were published
on February 2nd, 2022 as presented in Figure VIII.5 and Figure VIII.6, respectively. Following that,
PPM-II was announced on February 3rd, 2022 through MUSKI’s website as presented in Figure
VIII.7. In addition, official letters were written by MUSKI to the relevant public authorities, the
muhtars of the Project affected neighborhoods were invited through face-to-face meetings/phone
calls and announcements were made in the Oren neighborhood.

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Figure VIII.5 PPM-II National Newspaper Announcement (February 2nd, 2022, Birgun)

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Figure VIII.6 PPM-II Local Newspaper Announcement (February 2nd, 2022, Milas)

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Figure VIII.7 PPM-II Website Announcement (February 3rd, 2022, www.muski.gov.tr)

The PPM-II took place at Oren Labranda Cafeteria, by taking necessary COVID-19
measures, at 10:30 on February 11th, 2022. Before the commencement of meeting, information
brochures regarding the Project were distributed to attendants and A0 maps of the Project made
available for them. The brochure is provided in Annex-5 of this document.

The meeting was held with the participation of representatives from MUSKI, Mugla
Metropolitan Municipality, Milas Municipality, and ENCON. MUSKI performed the moderation of the
meeting. The meeting started with an introduction and explanation of the purpose and scope of the
meeting which is to inform the locals about the Project at hand and understand their concerns,
opinions and suggestions about the Project, and followed by a presentation given by ENCON and a
final discussion session where questions, concerns and suggestions were received. The
presentation is provided in Annex-6 of this document.

Sixty-three people participated to the meeting and the meeting lasted for 1.5 hours.
Photographs taken during the meeting are presented in Figure VIII.8.

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Figure VIII.8 Photos from the PPM-II (February 11th, 2022)

Questions received during the Q&A session of the meeting and answers given to them are
summarized below:

Q1: When will the construction phase start? (Resident of Oren)

A1: After this meeting, findings of this public participation meeting will be incorporated into
the final ESIA report. Then, the final ESIA report will be submitted for the approval of ILBANK and
World Bank. After the approval, the tendering period which is expected to last a year at most, will
be started. Following that, construction phase of the Project will begin.

Q2: When will the construction phase of the Project be completed and the Project will be
implemented? (Resident of Oren)
A2: The construction of the sewerage network and WWTP will take 24 months and 18
months, respectively.

Q3: Will the treated effluent water from the WWTP be discharged directly to the sea? In
addition, will the treatment in the WWTP be carried out chemically or biologically? (Resident of
Oren)
A3: Wastewater coming to the WWTP will be treated and then discharged to Hanay Creek
in accordance with the discharge standards specified in the Urban Wastewater Treatment
Regulation. Discharge permits were obtained from related authorities in this regard. In addition,
advanced biological treatment will be carried out at the WWTP and the treated wastewater will be
discharged after disinfection.

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 Q4: Can we use the treated wastewater for irrigation? (Resident of Oren)
A4: Wastewater coming to the WWTP will be treated and discharged to Hanay Creek in
accordance with the discharge standards specified in the Urban Wastewater Treatment Regulation.
In other words, treatment of wastewater in accordance with standards suitable for agricultural
irrigation is not considered.

Q5: Why are pumping stations foreseen in the project, can't the wastewater be conveyed
by gravity? (Resident of Oren)
A5: Although the topography of the project area is relatively flat, deep excavations cannot
be made and elevation differences cannot be adjusted due to the groundwater levels.

Q6: Does the project cover the 1st degree archaeological site? (Resident of Oren)
A6: No, the project does not cover the 1st degree archaeological site.

Q7: Will there be any expropriation within the scope of the Project? (Resident of Oren)
A7: The WWTP area is currently owned by MUSKI. Construction of the sewerage network
and discharge line will take place in existing roads and no land acquisition is required within this
respect. Pumping stations will be built on public lands that are registered as park. Therefore, there
will be no resettlement and/or physical displacement of persons in and around the Project Area.

VIII.3 Grievance Mechanism

In accordance with WB policies, a process will be established by which people who deem
that they have been adversely affected by the Project during planning, construction or operation
can bring grievances to the Project for consideration and, if required, resolution.

Managing grievances, including avoiding and minimizing them as well as their timely and
effective resolution, is an integral part of a sound stakeholder engagement strategy. Experience
shows that significant numbers of grievances arise from misunderstandings, and that such
grievances can be avoided, or their numbers reduced, through proactive and consistent
engagement with communities. Engagement also helps anticipate and review community concerns
to prevent them from escalating into grievances. A project-specific Grievance Mechanism (GM) is
beneficial in addressing community and individual concerns and complaints before they escalate
beyond control.

MUSKI has an already established GRM. Within that, MUSKI will be responsible for overall
implementation of the GM to ensure that all stakeholder comments, suggestions and objections are
addressed promptly and sensitively. Therefore, the GM will enable receiving comments/grievances
both in English and Turkish to be able to serve to all potential stakeholders of the Project. The
GRM will be in accordance with the provisions of the WB standards.

Any grievance related to this Project will be evaluated and responded.

Grievances/suggestions may be received via the following:

 Notification of grievances by hotline “185” and “153”,

 The grievances received via the MUSKI website,
 Receipt of grievances at meetings,
 The grievances received via other means such as Presidency’s Communication
Center (CIMER).
 By filling in and conveying of grievance forms that will be available at project site
and neighborhood headman's office
 Through MUSKI representative of the Project:
o Contact Person: Emine Başaran Tamer
o Phone: +90 535 107 40 57
o Toll free number: 444 48 01
o Address: Orhaniye Mah. Uğur Mumcu Bulvarı No:41 Menteşe/MUĞLA
o E-mail: [email protected]
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 MUSKI will additionally ensure that a grievance mechanism is available for those working
in the project; MUSKI project staff and workers of contractors during construction and operation of
sewerage system and wastewater treatment plant in Oren. MUSKI should assess grievance and
suggest solutions for employees of contractors and subcontractors to construct an internal
grievance mechanism which is easily accessible for all workers. The formal grievance mechanism
procedures will be prepared by MUSKI. Any grievance related coming from the employees will be
evaluated and responded MUSKI has to meet the requirements of national legislation on social
benefits, wages.

The formal grievance mechanism procedures will be prepared by MUSKI. This internal and
external grievance mechanism will focus on both stakeholders and public. All complaints received
are collected in the PIU complaints mechanism section, which consists of the staff of MUSKI.
Afterwards, received complaints are recorded in the database and stored. Then, PUB GM Officer,
communicates with the person who made the complaint, in order to confirm that the complaint is
delivered in seven days by telephone or e-mail. After that, he/she prepares the draft response and
submits it to the Project Management approval. Following the response, the Complaint / Complaint
Form is updated according to the outcome of the process and the complainant gets the result
within 5 days Complaints follow-up process, recorded in the monitoring and evaluation system. At
the end, MUSKI should inform the statistics of the complaints to ILBANK. Complaints / feedback
received will be resolved within a certain time period as specified in the national law and the ”Beyaz
Masa” system of the MUSKI. Basic steps in a grievance mechanism are explained in the Figure
VIII.9.

If complainant’s request that their names are not included on the registration form,
especially for GBV/SEA survivors, this request will be fulfilled.

Direct and contracted workers also have the opportunity to benefit from other grievance
mechanisms such as CIMER that are used nation-wide and which is accessible for every
employee.

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 Receive, register and
acknowledge the register

Evaluate and Investige

Complaint is legit Complaint is not legit

Develop a resolution for the

complaint and offer the solution
to the complainant Reject the complaint or refer to
a proper channel

Complainant does not

Complainant accepts
accept

Implement the solution Recourse or appeal

Monitor, document and

close

Feedback and Improve

Figure VIII.9 Sample Grievance Mechanism

Table VIII.2 presents the minimum key elements of a grievance mechanism that could be
used by Construction Contractor is presented below table:

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Table VIII.2 Grievance Redress Mechanism

Parameters to be Durati
Level Relevant Authority Means of Application Activities
identified on
MUSKI

Contact Person: Emine  Face to face

 The question or
Başaran Tamer application, Name and
complaints are
Phone: +90 535 107 40 57  Phone call, surname of the
Complainant; assessed.
Toll free number: 444 48 correspondence, The person is 15-30
1 01  Subject of the
 e-mail, provided with days
Address: Orhaniye Mah. Grievance;
 online feedback. If not
Uğur Mumcu Bulvarı No:41 
application, Location of the resolved, it is directed
Menteşe/MUĞLA Grievance; to legal ways.
E-mail:  correspondence
emine.basarantamer@mus  Contact details
ki.gov.tr (phone/mobile
number, address, The question or
Construction Contractor e-mail etc.); complaints are
Office 
 Face to face
Organization assessed.
name (if related) The person is 30
2 Contact Person*: application,
 Date &time provided with days
Phone*:  phone call feedback. If not
Address*:
resolved, it is directed
E-mail*:
to legal ways.
* This section will be updated when the contractor is awarded.

MUSKI and Construction Contractor should have separate free phone lines for receiving
the grievances.

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