TANAP ESDD Report - Final - English

FINAL REPORT OF THE:
INDEPENDENT ENVIRONMENTAL & SOCIAL

CONSULTANT
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE OF THE

TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT
FINAL
JUNE 2017
INDEPENDENT ENVIRONMENTAL & SOCIAL CONSULTANT
ENVIRONMENTAL AND SOCIAL DUE DILIGENCE
TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT
Prepared for: European Bank for Reconstruction and Development
Prepared by: Sustainability Pty Ltd
Suite 3, 118 Flora Terrace
North Beach, Western Australia, 6020
www.sustainability.net.au
+61 (0)8 9246 6666
Team Members: John Miragliotta Project Director
Marc Barendrecht Environmental Specialist
Amy Sexton Social/Cultural Heritage Specialist
Catherine Grant Social Advisor
Saniye Onur Local Environmental Specialist

TABLE OF CONTENTS
ACRONYMS AND ABBREVIATIONS ........................................................................................ I

EXECUTIVE SUMMARY ....................................................................................................... III
PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF
ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES ............................................................ III
PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS ........................................... V
PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY................................................................VII
PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY .................................................................. VIII
PERFORMANCE REQUIREMENT 5: LAND ACQUISITION, INVOLUNTARY RESETTLEMENT
AND ECONOMIC DISPLACEMENT ................................................................................................ IX
PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL RESOURCES ...................XII
PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE .................................................................. XIV
PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND STAKEHOLDER
ENGAGEMENT ............................................................................................................................ XIV
REPORT ORGANISATION .................................................................................................. XVI
1. INTRODUCTION ........................................................................................................... 1
1.1 SCOPE OF WORK ........................................................................................................................... 1
1.1.1 Reviews and Assessments .................................................................................................. 2
1.1.2 Site Reconnaissance........................................................................................................... 3
1.1.3 Reporting .......................................................................................................................... 3
1.2 LENDER POLICIES ......................................................................................................................... 6
1.2.1 EBRD Performance Requirements ........................................................................................ 6
1.3 SOURCES OF INFORMATION ......................................................................................................... 6
2. SUMMARY OF PROJECT CHARACTERTISTICS .............................................................. 7
2.1.1 Current Progress ................................................................................................................ 8
3. INSTITUTIONAL AND LEGAL FRAMEWORK ............................................................... 10
4. ENVIRONMENT, SOCIAL, HEALTH & SAFETY REVIEW AND AUDIT ........................... 12
5. COMPLIANCE AGAINST EBRD PERFORMANCE REQUIREMENTS ............................... 13
5.1 PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF
ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES ............................................................. 13
5.1.1 Environmental and Social Assessment ................................................................................ 13
5.1.2 Environmental and Social Management System .................................................................. 18
5.1.3 Environmental and Social Policy ........................................................................................ 19
5.1.4 Environmental and Social Management Plans ..................................................................... 19
5.1.5 Organisational Capacity and Commitment .......................................................................... 21
5.1.6 Supply Chain Management ............................................................................................... 22
5.1.7 Project Monitoring and Reporting ...................................................................................... 22
5.2 PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS .............................. 28
5.2.1 Human Resource Policies and Working Relationships ........................................................... 28
5.2.2 Child and Forced Labour ................................................................................................... 30
5.2.3 Non-Discrimination and Equal Opportunity ......................................................................... 30
5.2.4 Workers Organisations ..................................................................................................... 30
5.2.5 Working Conditions .......................................................................................................... 30
5.2.6 Retrenchment.................................................................................................................. 32
5.2.7 Grievance Mechanism....................................................................................................... 32
5.2.8 Non-Employee Workers .................................................................................................... 33
5.2.9 Supply Chain ................................................................................................................... 33
Trans Anatolian Natural Gas Pipeline Project Rev 5

Environmental Due Diligence June 2017
5.2.10 Security Personnel ........................................................................................................... 33
5.3 PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY AND POLLUTION
PREVENTION AND CONTROL ...................................................................................................... 40
5.3.1 Resource Efficiency .......................................................................................................... 40
5.3.2 Pollution Prevention and Control ....................................................................................... 40
5.3.3 Greenhouse Gases ........................................................................................................... 42
5.3.4 Water ............................................................................................................................. 43
5.3.5 Waste ............................................................................................................................. 43
5.3.6 Hazardous Substances ..................................................................................................... 43
5.4 PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY ........................................................... 47
5.4.1 Occupational Health and Safety......................................................................................... 47
5.4.2 Community Health and Safety ........................................................................................... 49
5.4.3 Infrastructure, Building and Equipment Design and Safety ................................................... 49
5.4.4 Hazardous Materials Safety ............................................................................................... 50
5.4.5 Traffic and Road Safety .................................................................................................... 50
5.4.6 Natural Hazards ............................................................................................................... 50
5.4.7 Exposure to Disease ......................................................................................................... 50
5.4.8 Emergency Preparedness and Response ............................................................................ 51
5.5 PERFORMANCE REQUIREMENTS 5: LAND ACQUISITION, INVOLUNTARY
RESETTLEMENT, AND ECONOMIC DISPLACEMENT .................................................................... 56
5.5.1 Physical and Economic Displacement ................................................................................. 56
5.5.2 Consultation .................................................................................................................... 57
5.5.3 Compensation ................................................................................................................. 59
5.5.4 Grievance Mechanism....................................................................................................... 61
5.5.5 RAP/LRP Documentation .................................................................................................. 62
5.5.6 RAP/LRP Implementation.................................................................................................. 62
5.5.7 Monitoring ...................................................................................................................... 63
5.6 PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL
RESOURCES ................................................................................................................................. 68
5.6.1 Assessment of Biodiversity and Living Natural Resources ..................................................... 69
5.6.2 Conservation of Biodiversity .............................................................................................. 77
5.7 PERFORMANCE REQUIREMENT 7: INDIGENOUS PEOPLE.......................................................... 87
5.8 PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE .......................................................... 88
5.8.1 Assessment and Management of Impacts on Cultural Heritage ............................................. 88
5.8.2 Consultation .................................................................................................................... 89
5.9 PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND
STAKEHOLDER ENGAGEMENT ..................................................................................................... 91
5.9.1 Stakeholder Engagement Plan ........................................................................................... 91
5.9.2 Operational Grievance Mechanism ..................................................................................... 92
5.9.3 Information Disclosure ..................................................................................................... 92
6. COMPLIANCE AGAINST TURKISH ENVIRONMENTAL, HEALTH, SAFETY,
AND SOCIAL LAWS, REGULATIONS, AND PERMITS................................................... 95
6.1 HOST GOVERNMENT AGREEMENTS ............................................................................................ 95
6.2 EIA PROCESS IN TURKEY ............................................................................................................ 95
7. COMPLIANCE AGAINST OTHER APPLICABLE STANDARDS / LAWS /
CONVENTIONS ........................................................................................................... 98
7.1 EU DIRECTIVES ........................................................................................................................... 98
7.2 INTERNATIONAL LAWS / CONVENTIONS .................................................................................. 98
7.3 IFC EHS GUIDELINES .................................................................................................................. 98
7.4 TANAP PROJECT HSES STANDARDS ........................................................................................... 98
8. HIGH LEVEL COMPLIANCE ASSESSMENT OF ASSOCIATED
INFRASTRUCTURE...................................................................................................... 99

APPENDIX A: DOCUMENT LIST ........................................................................................................... 113
APPENDIX B: IFC EHS GUIDELINES COMPLIANCE ASSESSMENT TABLE........................................... 162
APPENDIX C: ENVIRONMENTAL AND SOCIAL ACTION PLAN ............................................................ 183
TABLES
Table 5-1 PR 1 Findings Summary.................................................................................................... 24
Table 5-8 PR 10 Findings Summary .................................................................................................. 93
Table 8-1 High Level Compliance Evaluation – Associated Infrastructure ............................................ 100
FIGURES
Figure 1.1 TANAP Pipeline Overview ................................................................................................... 4
Figure 1.2 TANAP Pipeline Route Within Turkey ................................................................................... 5
Figure 5.1 Pipeline Route Assessment Process ................................................................................... 16
Figure 5.2 ESIA Consultation approach .............................................................................................. 17
Figure 6.1 Turkish EIA Process ......................................................................................................... 97

ACRONYMS AND ABBREVIATIONS
ADB Asian Development Bank
AGI Above-Ground Installation
BAP Biodiversity Action Plan
BAT Best Available Technology
bcma billion cubic meters per annum
BOP Blow Out Preventer
BTC Baku-Tbilisi-Ceyhan
CAP Corrective Action Plan
CC Construction Contractor
CST Compressor Station
ERP Emergency Response Plan
CFC Chlorofluorocarbon
CHMP Cultural Heritage Management Plan
CHSS Community, Health, Safety, and Security
EBRD European Bank for Reconstruction and Development
EHS Environment, Health and Safety
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EPs Equator Principles
ERMP Employee Relations Management Plan
ES Environmental and Social
ESAP Environmental and Social Action Plan
ESHS Environmental, Social, and Health and Safety
ESIA Environmental and Social Impact Assessment
ESMP Environmental and Social Management Plan
ESMS Environmental and Social Management System
ESR Environmental and Social Review
EU European Union
FFD Full Field Development
FGR Flare Gas Recovery
FID Final Investment Decision
GHG Greenhouse Gas
GIP Good International Practice
HCFC Hydrochlorofluorocarbon
H&S Health and Safety
HR Human Resource
HSES Health, Safety, Environmental and Social
HSE Health, Safety and Environmental
HUC Hook-Up and Commissioning
IBA Important Bird Area
IESC Independent Environmental and Social Consultant
IFC International Finance Corporation
ILO International Labour Organisation
IP Indigenous Peoples
ISD Inherently Safer Design
JV Joint Venture
KBA Key Bird Area
KPI Key Performance Indicator
LARP Land Acquisition and Resettlement Procedures
LTMOBM Low Toxicity Mineral Oil Based Muds

Environmental and Social Due Diligence June 2017
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MEG monoethylene glycol
MoEU Ministry of Environment and Urbanisation
MP Management Plan
MSDS Material Safety Data Sheet
NCR Non-Conformance Report
NGO Non-Governmental Organisation
NO2 Nitrogen Dioxide
Nitrous Oxide Nitrous Oxide
OHS Occupational, Health and Safety
OMS Operating Management System
OSID Online Stakeholder Interaction Database
The Convention for the Protection of the Marine Environment of the
OSPAR
North-East Atlantic
OSRP Oil Spill Response Plan
PAHs Polycyclic Aromatic Hydrocarbons
PAP Project-Affected Person
PPE Personal Protective Equipment
PS Performance Standard
PR Performance Requirement
RfP Request for Proposal
RAP Resettlement Action Plan
SCP Southern Caucasus Pipeline
SD Shah Deniz
SEP Stakeholder Engagement Plan
SMP Social Management Plan
SOP Standard Operating Procedure
SPS Safeguard Policy Statement
Sustainability Sustainability Pty Ltd
TAP Trans Adriatic Pipeline
TANAP Trans Anatolian Pipeline
TSP Total Suspended Particle
USEPA United States Environmental Protection Agency
VOC Volatile organic compounds

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EXECUTIVE SUMMARY
This report contains the Environmental and Social Due Diligence (ESDD) for the TANAP Project in
Turkey. Sustainability Pty Ltd (Sustainability) was engaged by the European Bank for Reconstruction
and Development (EBRD) as the Independent Environmental and Social Consultant (IESC) to conduct
the ESDD. The ESDD was developed based on an extensive document review and incorporated a site
visit to Lots 1 and 3 of the TANAP pipeline route.
The Project is substantially commenced, with construction works having started on all 4 Lots of the
pipeline route. Construction contracts for the offshore pipeline have been awarded but works have
not yet commenced. Relevant dates for the remainder of the construction period include:
• Commencement of offshore construction – July 2017;
• Mechanical Completion of Phase 0 pipeline – December 2017;
• Supply of gas to Eskişehir (offtake station) Phase 0 complete – June 2018;
• Material Completion of Phase 1 pipeline works – December 2018;
• Gas supply to Europe – June 2019.
The IESC observed strong adherence to the EBRD Environmental and Social Policy requirements as
communicated through the respective Environmental and Social Performance Requirements (PRs) of
the EBRD. TANAP personnel involved in the ESDD process were open, transparent, and willing to
provide all requested documentation and assistance to the IESC before, during and after the site visit
in order to facilitate the finalisation of this ESDD. The structure of the ESDD Report is outlined at the
end of this Executive Summary.
With respect to compliance with the PRs, the IESC has observed no Material Non-Compliances, and a
number of Partial Compliances, which are explained further in this Executive Summary and again in
more detail in the body report. The partial compliance items identified are considered readily
addressed through the development and implementation of the Environmental and Social Action Plan
presented in Appendix C of this ESDD Report.
Applicable Performance Requirements are PR1, PR2, PR3, PR4, PR5, PR6, PR8 and PR10.
PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF

ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES
The TANAP project is under development in Turkey consistent with the Project’s Host Government
Agreement (HGA), which provide guidance on the expected Environmental and Social (E&S)
standards and requirements, preparation of an ESIA, and the project’s social investment program.
The Project carried out an ESIA as the means of scoping and assessing its environmental and social
impacts, commensurate with the environmental and social impacts presented by the Project. The
ESIA was publicly disclosed on the TANAP website (22 June 2015). Turkey’s Ministry of Environment
and Urbanisation (MoEU) approved the ESIA in June 2014.
E&S aspects and impacts have been considered during Project scoping and planning, with due
consideration of the mitigation hierarchy and Good International Practice (GIP). Route selection was a

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key focus for ensuring that E&S impacts were minimised while providing for technical feasibility in
installation. E&S criteria were used to narrow the Preferred Route Corridor from 2km to 500m. Within
this 500-metre corridor the centreline for the corridor was delineated and the Right of Way (RoW)
disturbance area of 36 metres was located. The ESIA was conducted on the full 500-metre pipeline
corridor on Route H. Significantly, there is no physical displacement of households along the entire
corridor route. Route selection changes were implemented throughout the construction phase to
avoid significant cultural heritage sites and designated wildlife areas, among others, managed
through a Management of Change (MoC) process.
Stakeholder engagement and consultation has been carried out throughout scoping, preconstruction,
and construction phases, and the key issues raised through consultation are considered within the
final ESIA and ESMPs. Consultation provided for the input of local, regional, national and international
stakeholders, and separate inputs of local authorities and vulnerable groups, including women and
children locally. TANAP has in place a web-based online stakeholder interaction database (OSID) to
track, record and manage all stakeholder engagement activities including grievance management.
At the commencement of the Project, TANAP employed a three-tiered contractor structure to

implement the Project, with an Engineering, Procurement, Construction and Management (EPCM)
contractor managing the selected Construction Contractors (CCs) in the field. TANAP has recently
modified this structure to an integrated two-tier organisation (with TANAP and CCs), removing the
EPCM contractor from the organisational structure. The IESC noted during the audit that the ESMS
was out of date with respect to roles and responsibilities and subsequent system documentation. In
many instances, the same individuals are working in the same roles (i.e. former EPCM staff are now
directly employed by TANAP) so while day to day activities appear to remain well-managed and
understood by staff, ESMS documentation reviewed during the audit did not reflect the current
organisational structure and so may not effectively manage potential risks (e.g. arising from incidents,
staff changes). The IESC team considers this issue to be compliant with this PR, given that the issue
is known, changes substantially commenced, and is considered to be part of normal ESMS review and
improvement during the life of the Project. Furthermore, subsequent evidence provided to the IESC
indicates that the revision of TANAP documents is complete, and that CC reviews are ongoing and will
be provided to the IESC as they are approved.
The ESIA assessed potential E&S impacts of the project on communities and the related ESMPs were
prepared to manage any outstanding residual risks. Internal and third party monitoring is undertaken
of delivery of ESIA and ESMP commitments. This includes third party monitoring by Turkish
consultants, Çınar Engineering Consulting Co. (Çinar), of:
• Construction Impacts Management Plan (ESIA Appendix 5.1);
• Community Safety Management Plan (Appendix 5.2);
• Community Relations Plan (Appendix 5.3);
• Employment and Training Plan (Appendix 5.4);
• Procurement and Supply Management Plan (Appendix 5.5);
• Aggregate Management Plan (Appendix 5.6);

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• Traffic Management Plan (Appendix 5.7);
• Cultural Heritage Management Plan (Appendix 5.8);
• Erosion, Reinstatement and Landscaping Plan (Appendix 5.9);
• Pollution Prevention Plan (Appendix 5.10);
• Waste Management Plan (Appendix 5.11);
• Emergency Response Plan (Appendix 5.12).
Some gaps were observed in the review of the ESIA related to the assessment of offshore
construction impacts. The review found that the ESIA did not adequately assess the impacts related
to the potential for vessel to vessel interactions and vessel interactions with marine fauna. Vessel to
vessel interactions are considered a high risk given the stated level of high shipping traffic and vessel
use in the offshore project area. Subsequent evidence provided is sufficient to demonstrate
compliance to the IESC. Specifically, as there was limited information available regarding offshore
construction methodology during the ESIA development, a comprehensive HAZID was conducted
post-ESIA development, which assesses construction related risks, including vessel to vessel
interactions. Prior to commencement of offshore construction activities, the existing HAZID will be
updated and a set of Task Risk Assessments will be developed by the Contractor to identify and
mitigate potential Project-related risks for offshore activities. Disclosure of Offshore ESMS
documentation is also planned to occur to ensure requirements of EBRD PRs are met.
As one of the major goods or services purchased by the Project, the lengths of pipe for the
construction of the pipeline presented a significant potential supply chain management risk, with
suppliers located within Turkey and internationally, in China. Evidence from TANAP describes the
desktop environmental assessment of Pipe producers that was undertaken during the pre-qualification
process including an OHS inspection by the EPCM. Documentation demonstrates TANAP’s efforts in
broadly ensuring E&S requirements can be managed appropriately in its supply chain through the
suppliers’ requirements for implementing an ESMS commensurate to the complexity, nature and scale
of the Project.
PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS

No material non-compliances were identified as part of the review against labour and working
conditions criteria. Some partial compliances were observed in other areas within this PR.
During discussions related to employee grievances, overtime work and fatigue management were
raised on several separate occasions to the IESC. Interviews revealed confusion at a site level as to
the TANAP policy on overtime. TANAP does not encourage overtime work for its employees, however,
due to the nature of the project, overtime work may occur within the legal limits. During interviews
on site with Lot 1 Contractor Fernas, personnel reported that overtime was allowed under Fernas
company policy. . TANAP is working to address overtime issues through a “Working Hours Action
Plan” that substantively addresses overtime issues, including stakeholder complaints of overtime, CC
compliance with TANAP overtime policies, and enforcing legal compliance with the Turkish Labour
Code. The Action Plan aims to reach compliance with the Labour Code by December 31, 2017. The

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IESC notes that the Action Plan emphasis is directed to legal compliance around overtime. While
there is a commitment to ensure that overtime hours are worked safely and without duress, it was
not clear how fatigue management measures are linked with effective overtime management. It is
also noted that contractors are financially incentivised for being on time/advance of deadlines, which
may contribute to the issue of overtime and fatigue. To this end, additional information was provided
to the IESC by TANAP in the form of the H&S Incentive Procedure (TNP-PCD-HSM-GEN-025) which
aims to promote awareness of H&S and incentivise workers regarding their H&S performance in order
to ensure that there is a balance between schedule / milestone incentives. During meetings with the
IESC on 12 May 2017, TANAP also noted that the link between financial incentives and effective
fatigue management is an area of current concern, and provided the example of hydrotesting,
whereby additional resources were engaged rather than the use of longer hours (Lot 1 had two
hydrotest crews, and it now has three crews and a fourth is being mobilised).
TANAP, through its contracting arrangements, ensure no child or forced labour is in use in the Project
through employment procedures. Nationally, Turkey has ratified the core ILO conventions including
on non-discrimination and TANAP’s role includes ensuring compliance with core labour standards on
behalf of the Project. Worker organisations are in place in parts of the Project, and all employees are
free to join labour unions.
Interviews with short term labour suggests that not all CCs are making clear what the working
conditions (including retrenchment/termination) are, and in absence of a TU, the individuals
interviewed stated that any issues have been raised through the Muhtar to the relevant CC for
resolution through the Grievance Mechanism. While the TANAP Project Site Audit Procedure provided
as evidence includes requirement for provision of document of resignation or notice of termination,
there appears to be confusion at a ground level regarding termination and retrenchment. This may be
exacerbated in the case of short-term contracts that are open-ended, or, renewed without formal
extension of the completion date. While notice periods for dismissal of staff are in accordance with
Turkish Labour Law requirements, in practice notice periods for dismissal may be occurring
inconsistently, particularly in relation to casual / short-term work. For example, TANAP reported that
the third-party audits have not found inconsistencies with national legislative requirements, however
in interviews with locally engaged staff at Ardiçli village, it was stated that following the completion of
a one year contract at the CC, a short-term contract was commenced with a subcontractor with no
contract in place and little notice for ‘termination’ of the worker. Internal audits are conducted of CCs
indicating compliance checks against labour issues including overtime and communications on
contracts with workers. These audits are documented in the TANAP Project Site Control Procedure,
the scope of which is to audit working conditions and rights of workers including working hours,
leave, payroll, Social Security, and terminations/new hires by carrying out a physical audit at least in
one camp monthly.
Some working conditions and amenities observed at Lot 1 did not appear appropriate to the nature of
the work being conducted and the climatic conditions at the time. TANAP presented to the IESC
information regarding non-conformance reporting (NCRs) and management. NCR requirements
address the process in place to develop and assess criticality of NCRs, and steps for root cause
analysis, corrective action implementation and NCR closure. This observation was noted in relation to

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works conducted at Lot 1 and it is recognised that working conditions observed at Lot 3 were much
improved.
In relation to security, the IESC considers that reasonable efforts have been made to align with this
PR, including adequate due diligence of security providers and presence of Standard Operating
Procedures guiding activities. Training on use of force and appropriate conduct towards communities
by security personnel is considered efficient to demonstrate compliance (e.g. Security Risk
Assessment, training records, Security Management Plan).
PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY

Observed performance against this PR was found to be strong, and in full compliance with the PRs.
The ESIA and ESMPs provide the overarching Project principles for the application of resource
efficiency and pollution prevention principles. These Principles are defined as: identify and understand
impacts; consult with others; design and avoid adverse impacts and minimise use of natural
resources. The ESMPs includes environmental control strategies designed to reduce waste and
conserve natural resources through engineering and procurement environmental design controls and
construction and installation controls.
PR 3 requires that the ESIA process identifies opportunities and alternatives for resource efficiency in
accordance with GIP. The Compressor Stations (CSTs) are a major emitter of GHG during operation
of the pipeline, as identified in the ESIA. A Best Available Technology (BAT) assessment has been
conducted and provides sufficient detail so as to verify that EBRD guidance requirements have been
met in relation to how the adoption of resource efficiency and waste reduction considerations helped
to define the technology chosen in the CSTs. The BAT included detail on the realisation of the energy
savings that are possible because of the adoption of BAT for the CSTs and demonstrated that energy
efficiency measures have been identified.
Regarding onshore hydrotest water, this will preferentially be taken from surface water bodies. After
use, it is intended that water be treated until it meets the required Project Standards and discharged
back to the closest receiving environment (surface water). Where possible, addition of chemical
corrosion inhibitors will be avoided, although in some cases they may be required. The hydrotesting
process is managed through an Environmental Hydrotest Monitoring Plan, developed under TANAP
guidance for each CC over the four Lots. Each water abstraction and discharge point along the entire
route was assessed for water quality and ecological restrictions and appropriate management
measures proposed (i.e. exclusion of fish spawning periods for extraction activities).
The ESIA has assessed impacts related to GHG emissions, although it does not appear to contain
consideration of technically and financially achievable options to minimise emissions of GHG in the
assessment process. Upon IESC request, supplementary evidence was provided, in the form of the
BAT emissions inventory and relevant evaluation data, that demonstrates that resource efficiency
measures have been considered during design (e.g. ability to limit venting of gas, alternative forms of
power supply during operations or waste heat recovery systems).
As per the requirements of both Turkish and EU legislation, TANAP utilises licenced contractors to
transport and dispose of hazardous waste. The EBRD PRs recommend that clients ascertain whether
licenced disposal sites are being operated to acceptable standards. TANAP has conducted site

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verification audits of a sample of disposal facilities along the pipeline route to ensure that their waste
is being disposed of appropriately by the contractor.
PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY

The IESC team has not recorded any material non-compliances within PR 4, while there are several
partial compliance areas.
A review of the Project incident database identified that there were many incidents that involved near
misses and first aid / lost time injuries related to pipeline lifting activities. One of the recorded
fatalities was also a lifting incident. The detailed incident report related to the lifting fatality stated
that root causes of the incident were insufficient training and a lack of suitable procedures for the
tasks. Interviews with employees on the Lot indicated that it was normal practice for personnel to be
in the designated ‘danger zone’ during lifts, amongst other system failings. The fact that it was
considered normal working practice to be within the ‘danger zone’ during lifts also indicates that there
may have been a lack of appropriate supervision and conduct of workplace inspections of lifting
activities by TANAP in the field. It is also unclear if corrective actions (i.e. retraining all lifting
personnel) were rolled out to all CCs on other Lots or were contained to just the Lot on which the
incident occurred.
The IESC team has some concern that lifting activities in particular are leading to a relatively high
occurrence of reported incidents / near misses. Given that lifting of pipe is one of the most common
activities on the Project which has the potential for serious injury or fatalities, a certain level of
control and supervision of the tasks by TANAP would be expected, particularly given that lifts on the
Project are not controlled under the permit to work system TANAP reports that Lessons Learnt
documents of incidents are being shared with all lots and stations, and actions are being followed up
by LOT and Station Leads (Delivery Manager, Lot HS Lead, etc). Relevant procedures and official
letters provided and discussed with TANAP in meetings held on 12 May 2017 indicate that appropriate
remedial actions are being implemented by TANAP in relation to lifting activities.
Other areas of concern relate to CC performance in managing community safety on site (e.g. fencing,
signage, accessibility of open trenches, engagement with affected communities); and the Project’s
use of epidemiological studies to inform management of communicable diseases and implementation
of community health programs. TANAP reports that trench registers are being kept for the entire
route, including the barricading status of open trenches, and are being closely followed up by the
Construction and HS Teams. Additionally, the Community Relations Team is undertaking Community
Safety Awareness meetings including access to open trenches, ROW, risks related with unauthorised
site access, and construction and traffic safety with communities throughout the pipeline route.
In alignment with a key construction phase project risk, there was evidence of strong management of
potential road safety impacts to both workers and communities. These included travel management
tools, vehicle controls and monitoring, and community and worker training, and specific training with
women and children to minimise public health risks due to vehicle traffic. TANAP is commended for
investing significantly and providing strong management of potential road safety impacts to both
workers and communities. These included travel management tools, vehicle controls and monitoring,

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and community and worker training, and specific training with women and children to minimise public
health risks due to vehicle traffic.
Construction Contractor MPs and procedures are aligned with those prepared by TANAP, and
documentation reflects a mitigation hierarchy approach. Awareness-raising within the workforce of
interactions with the community, interactions with emergency responders, and awareness for the
community of potential project hazards are all included in worker training.
Community Safety MPs provide for communicable disease training to the workforce and engagement
with local health authorities to agree appropriate mitigation actions, who have also been investigated
and engaged should any incidences of communicable diseases eventuate. Local engagement and
employment practices have been key in mitigating any potential effects of population influx, including
community exposure to disease.
Emergency Response Plans (ERPs) have additionally been developed and approved by TANAP,
including provision for engagement and training with external emergency responders by the Project,
led by TANAP’s Security and Emergency Response departments. These plans are supplemented by
mapping of available health services along the pipeline, and address potential for community conflicts
that may occur as a result of the Project. Regular walk-overs and fly-overs of the pipeline are in place
for the construction phase of the Project to monitor potential pipeline intrusion, while building
intrusion systems are being implemented during construction for all AGIs.
ERPs related to operation of the pipeline are currently in development and are stated to be ready six
months prior to operation. Offshore construction ERPs including an Oil Spill Emergency Response
Plan required to manage response to vessel interactions have been drafted and TANAP plan to
complete these prior to construction in the offshore package commencing in late June 2017. TANAP
are required to have these developed and disclose these plans prior to commencement of offshore
works.
PERFORMANCE REQUIREMENT 5: LAND ACQUISITION, INVOLUNTARY

RESETTLEMENT AND ECONOMIC DISPLACEMENT
No material non-compliances were identified as the part of the review against land acquisition,
involuntary resettlement and economic displacement criteria. The RAPs present the overall impacts,
policy and legislative framework, land acquisition process, consultations and disclosure details and
implementation arrangements, indicative implementation schedules and budgets and significant
further work has been undertaken by TANAP and Lenders to develop additional commitments to meet
international requirements in land acquisition and resettlement.
The suite of key documents relating to TANAP land acquisition, involuntary resettlement and
economic displacement activities are the 2014 Resettlement Action Plan (RAP), the RAP for Above
Ground Installations (AGIs RAP) and a RAP for the Pipeline (Pipeline RAP), and the Guide to Land
Acquisition and Compensation (GLAC), developed for stakeholders.
Following an Implementation Audit and World Bank due diligence investigations, a new suite of
studies, commitments, processes, and documents was developed and implemented by TANAP to fulfil
international standards in land acquisition and livelihood restoration. The areas covered by the

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additional corrective actions identified by TANAP address: Compensation and Entitlements; Livelihood
Restoration; Vulnerable Groups; Grievance Redress Mechanism; Community Engagement and
Disclosure Policy; Monitoring Process; and Local Employment.
Full compliance was observed in relation to avoidance or minimisation of displacement. Route

realignment has been carried out during the construction phase to manage deviations from the ESIA
approved alignment, in accordance with Project procedures. The pipeline requires temporary (3-year)
acquisition of 6,340ha, while 263ha of land was acquired permanently for AGIs, across 578 land
parcels and 936 Project Affected Persons (PAPs).
Partial non-compliances were observed in relation to consultation, assessment and census,

compensation for displaced persons, the Project grievance mechanism, RAP/LRP documentation and
implementation, and monitoring.
BOTAS, the entity responsible for land acquisition, TANAP and CCs’ also undertake consultation with
stakeholders, requiring identification and consultation with approximately 97,000 landowners, land
shareholders and land users. Consultation and engagement has included: Information meetings prior
to negotiations/census data gathering; 2 rounds of negotiation meetings; crop determination
studies/meetings; preconstruction information meetings; and land entry meetings. Land exit meetings
will also be undertaken following reinstatement (approximately 3 years after land entry).
Consultation processes provide for engagement with vulnerable groups including women. TANAP has
committed to undertaking additional engagement and disclosure actions to strengthen the Project’s
responsiveness to stakeholders’ issues.
The cut-off date from the original RAP could not be met, as construction commenced in advance of
this date and identification of PAPs and assets inventory had not been completed, however BOTAS
has developed a practicable approach to evaluate and compensate every additional claim and justified
complaint that falls before or after the relevant cut-off date because the international standards on
applying a cut-off date could not be met.
As at August 2016, approximately 5,450 formal land users have been identified (i.e. users occupying
privately owned or treasury owned land, both documented and non-documented, to be compensated
through BOTAS) and 324 informal users (i.e. users occupying publicly owned land such as pastures or
forest lands, unauthorized or tolerated users, to be compensated through the RAP Fund, administered
by TANAP). BOTAS cannot acquire land from or compensate these categories that fall outside the
Turkish legal RAP requirements, hence the need to establish a mechanism from the Project that
provides for compensation to international standards, including transaction costs, transitional
payments, support to vulnerable households, and compensation for unviable land parcels. A RAP
Fund Management Procedure focusing on RAP Fund strategy and implementation principles has been
drafted and is currently being delivered to Project-affected settlements and PAPs, along with the new
GLAC (Guide to Land Acquisition). The RAP Fund Evaluation Committee has additionally been
established.
Permanent land acquisition is required for approximately 260ha for the AGIs, while approximately
6,600ha is required for a temporary period of 3 years (easement land for the construction corridor, or
unrestricted access for the ROW). This land is to be returned to owners after construction, with some

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restrictions on agriculture / buildings in easement areas. TANAP is commissioning a retrospective
study (due for completion in July 2017) to identify and compensate PAPs who have not been yet been
compensated under the new Entitlements Matrix framework (ref: Summary of Corrective Actions).
Further, TANAP has committed to providing for full replacement cost for all assets and will ensure
that lost income is fully restored through the compensation process.
The procedure for demonstrating avoidance of expropriation appears to be a gap. While TANAP’s LA
process allows for negotiation with landowners, 67% of agreements are not amicable and trigger the
expropriation process, which does not meet with GIP and suggests the process of determining and
compensating landowners is rushed, in addition to absentee owners or other factors, resulting in
significant expropriation by international standards. While acknowledging that the pipeline component
of the project is linear, temporary and land acquisition has been completed, it should be clear to
TANAP that the expropriation process has not caused undue hardship to those losing access to their
resources. Through the Corrective Action Register, TANAP have committed to ensure that all eligible
PAPs are informed on entitlements in order to come forward for losses that have not yet been
compensated. TANAP will compensate all additional claims that are valid, consistent with the
conditions and criteria set in TANAP’s information brochures and GLAC document.
A grievance mechanism and Online Stakeholder Information Database, OSID, are in place for the
Project. As part of TANAP’s has commitment to strengthen this mechanism, an Appeals Committee
has been established (in January 2017), with notification at the community level from February 2017.
TANAP has also committed to strengthening disclosure of summary grievance information to
stakeholders.
TANAP has committed to development of a range of new RAP documents, documented in the
Summary of Corrective Actions in the Pipeline RAP. These include the Livelihood Restoration Plan
(LRP), RAP Fund guidance and documentation. The RAP Fund intends to fill the gap between
payments that can be provided for by BOTAS (as the national responsible agency) and international
requirements managed and implemented by TANAP. Some payments are reported to have already
been made from the RAP Fund, and for transparency these should be reconciled following approval of
guidance on implementation of the Fund. RAP Fund Management Procedure has been drafted and
disclosure with PAPs commenced. TANAP has contracted independent experts for RAP External
Monitoring and will produce their 1st Semi-Annual External Monitoring Report in June 2017.
The Pipeline RAP additionally identifies measures to strengthen ongoing implementation of the RAP.
This includes a study to investigate potential impacts to fisherfolk in the Sea of Marmara and
thereafter develop an appropriate Livelihood Restoration Plan. The study has been carried out, (i.e.
with adequate time to investigate, plan and respond, in advance of any impacts occurring). Similarly,
the AGI RAP provides for the development of an LRP to PAPs who have experienced a permanent loss
of livelihoods. Mitigation measures are yet to be developed and will differ from those who experience
temporary loss, which should be clearly managed and communicated to stakeholders.
The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators,
implementation schedule, and budget. These RAPs would be subject to IESC/independent monitoring
and review throughout implementation in accordance with GIP. A RAP Monitoring Plan has been

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completed, and both internal and external monitoring has commenced so as to inform the impact
evaluation at the conclusion of the LA and livelihood restoration program.
PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL

RESOURCES
The biodiversity assessments and studies have been completed in consideration of the IFC 2012
Performance Standards and with specific reference to Performance Standard 6 (PS): Biodiversity
Conservation and Sustainable Natural Resource Management of Living Natural Resources. TANAP has
developed a Biodiversity Action Plan (BAP) with specific reference to the IFC 2012 PS6 and the
Turkish National Biodiversity Strategy and Action Plan3.
The TANAP route selection described in the ESIA Chapter 5 describes the process for defining the
TANAP route and included consideration of a range of factors included the presence of protected
areas, sensitive habitats, scrublands, meadows, pastures and wetlands. A number of route
alternatives were identified to avoid key biodiversity conservation areas including the Posof Ardahan
Wildlife Development Area, Kakgol-Sahara National Park, Sarikamis Allahaukber Mountains National
Park, and the Akdagmadeni Forest (Important natural area).
Baseline studies were completed between 2013 and 2014 and include comprehensive desktop studies
supplemented with targeted site surveys focused on the areas where impacts to priority biodiversity
values are likely to occur.
The TANAP Biodiversity Action Plan (BAP) was developed with the specific objective to identify the
species and habitats in consideration of national and international significance and to consequently
determine the applicable area specific actions required to protect and conserve biodiversity within the
36m pipeline Right of Way (RoW). The BAP has identified the presence of critical habitats,
intersections of the ROW with protected or conservation areas and the presence of ecologically
sensitive species within the ROW.
The BAP includes a discussion of EUNIS habitat types encountered along the TANAP route including
30 different terrestrial habitat types classified as Level III and 6 level III freshwater habitats. Habitat
types classified as significant under the Turkish ‘National Biodiversity Strategy and Action Plan” were
also identified as priority habitats including steppe, coastal sand-dunes, and mountainous forest
ecosystems.
The re-assessment of critical habitat in the BAP identified 67 terrestrial and 27 freshwater critical
habitats. The terrestrial critical habitats cover only 0.39% of the 500m LSA corridor assessed in the
ESIA and 5.6% of the ROW (36m). This represents a significant decrease in terrestrial critical habitat
affected by the Project from that identified in the initial ESIA studies following the BAP re-assessment.
However, this reassessment of critical habitat area is based on the presence or absence of critical
habitat triggering species or values within the project’s direct impact area and removes critical habitat
areas where the triggering species or values were found to be undisturbed by direct impacts of the
ROW. The IESC finds that the TANAP critical habitat assessment is not in full compliance with the IFC
PS6 GN and is therefore in partial compliance with the requirements of PR6 to ensure net biodiversity
gain of critical habitat and no net loss of priority biodiversity features.

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The BAP states that the impact assessment undertaken in the ESIA confirms a low degree of impact
expected on natural and critical habitat, and states that significant permanent and long term impacts
are not expected and the defined mitigation measures are sufficient for the recovery of habitats. The
BAP also refers to the ESIA in confirming no long term or permanent significant impact to Species of
Conservation Concern. However, the BAP does recognise the threat of permanent impacts on SCCs
from alien invasive species, including the pathways for introduction of weed species, within the
pipeline ROW and reiterates the importance of the Alien Invasive Species Guidance Document.
Furthermore, the TANAP’s “Erosion, Reinstatement, and Landscaping Plan” and the “Specification for
Reinstatement” includes the range of actions for reinstatement and bio restoration of the project sites
to achieve pre-development biodiversity criteria. The performance of the bio restoration efforts in
achieving the stated biodiversity objectives is proposed to be monitored and reported through the
“Bio-Restoration Monitoring Plan (October, 2016).
Section 3.2.1 of the most recent version of the BAP does include discussion on the application of the
mitigation hierarchy for critical habitats. The BAP describes how mitigation measures are applied for
each critical habitat that occurs along the Project and identifies where additional conservation actions
are required to ensure no net loss of priority species. Annex 9 of the BAP includes a range of
measures designed to ensure a net gain in critical habitat that is impacted by the Project. However,
these net gain actions are not described in a way that demonstrate how a net gain would be
achieved. There is no quantification of the no net loss/ net gain objectives of the BAP to demonstrate
full compliance with PR6. Neither the ESIA nor the BAP provide sufficient detail of the project related
direct, indirect, and residual impacts on populations; species and ecosystems identified in the baseline
studies. There is insufficient assessment of the project impacts on critical habitat other than the direct
impacts within the ROW and the potential for introduced pest species (weeds). The impact
assessment on biodiversity values provides insufficient discussion on why aspects such as habitat
fragmentation, fauna avoidance and impacts from increased third party access are not considered.
The project has not demonstrated full compliance with PS6 GN15 in its assessment of impacts to
critical habitat and has provided insufficient evidence that bio restoration works on the ROW will be
adequate to achieve the biodiversity outcomes required to demonstrate compliance with PR6. The
IESC has found that TANAP has relied heavily on the assumptions that mitigation of temporary
disturbance through bio-restoration and alien species control will be effective in ensuring no residual
impacts to priority biodiversity values and critical habitat. There is little discussion in the ESIA that
supports the assumption that bio-remediation will ensure no permanent or long term impacts to
priority biodiversity values and critical habitat. The limitations of bio-reclamation are stated in various
sections of the ESIA that refer to challenges in achieving propagation or translocation of some
species, and the inability to replace tree species over the ROW to ensure the integrity of the pipeline
is maintained.
The effectiveness of the mitigation measures, including bio-restoration and alien species controls,
should be discussed in further detail and, where possible, refer to examples where these mitigation
measure have been effective in ensuring no loss of priority biodiversity values or critical habitat.
However, if relevant and geographic specific examples of successful bio-restoration are not available,

Page xiii
then the assumption that there will be no residual impact to priority features and critical habitat
cannot be supported.
In consideration of the limitations found with the TANAP critical habitat assessment and management
approach, and recognising the current status of Project construction. The IESC recommends that
TANAP develop and implement an Offset Management Strategy document that supplements the BAP.
PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE

TANAP is in full compliance with the requirements of PR 8.
A total of 161 sites were identified in the ESIA process, and mitigation actions defined. Eleven sites
were identified as unavoidable at preconstruction phase. A Cultural Heritage Management Plan
(CHMP) is in place, including a Chance Find Procedure, which is reflected in each of the CCs’ MPs.
The CCs’ Archaeologist, who liaises with the TANAP Cultural Heritage Officer and the Museum
Directorate, monitors ground clearance work. Third party monitoring of implementation of the CHMP
is also undertaken by Çinar.
During the construction phase to date, five route changes have been implemented at the eleven
unavoidable sites, following engagement and mitigation actions implemented under the direction of
the with the relevant authorities (Museum Directorate of the Ministry of Culture and Tourism).
Ongoing and close engagement has been undertaken with the Museum Directorate of the Ministry of
Culture and Tourism, as the responsible agency for advice and direction on archaeological finds and
appears to have been effective in managing and mitigating potential impacts to tangible heritage in
line with the mitigation hierarchy approach. However, consultation with affected communities and
other stakeholders has been largely limited. Invitations to specialist interest groups at the ESIA
consultation phase has been recorded. IESC notes that consultation with affected communities is
carried out for intangible cultural heritage and registered tangible cultural heritage elements.
However, the chance finds are managed differently due to security reasons (the risk of illegal
excavations).
PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND

STAKEHOLDER ENGAGEMENT
No material non-compliances were observed in reviewing the information disclosure and stakeholder
engagement criteria. Partial compliance was observed in relation to operational grievance
mechanism, and information disclosure.
Policies and standards are in place for the Project regarding stakeholder engagement,
communications and social impact management and requirements. The total number of consultation
meetings during the construction phase (as at November 2016) was 1,234, including meetings with
women, safety awareness for children, and with local authorities, across all Lots and stations.
Comments raised during project disclosure were reflected and analysed and incorporated into Project
SMPs, completing the feedback loop in line with GIP.
The Project SEP was published (18 August 2013) on the TANAP website in Turkish and English,
appropriate to the nature, scale and risks posed by the Project and reflecting engagement actions

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specific to different stakeholder groups (e.g. vulnerable groups). This SEP has been recently updated
and finalized (30 January 2017) and includes additional guidance on stakeholder engagement
implementation for CCs during the construction phase, and provides for updated roles and
responsibilities.
ESIA documents were disclosed on the TANAP website, with key documents in English and Turkish.
The current SEP specifies periodic review of the document in line with PR 10 requirements for
ongoing provision of information to stakeholders appropriate to the nature of the Project and its
adverse impacts. PR 10 requires at least annual reporting to stakeholders for Category A projects;
commitment on this aspect is included in the SEP. The modality of disclosure of Project documents
was described by TANAP. For RAP documentation, the disclosure process was addressed adequately
through provision of written summary information in the local language, available to public disclosure
meetings, which subsequently informed the final RAPs prior to their disclosure. Additional
engagement planning and disclosure material is required of TANAP on the next phase of RAP activity
(i.e. in identifying and appropriately compensating new PAPs) and in the development and disclosure
of the BAP.
The grievance mechanism is operational and is aligned with the CCs. All grievances are logged in an
online grievance recording and tracking system. A total of 790 complaints have been received from
1/1/14 to 17/11/16 with 85% closed over an average of 15-day response time (30 days is the time
limit in the procedure for closure of complaints). The most common grievances since project
commencement relate to damage to property/land; land acquisition and compensation process;
damage to irrigation infrastructure; damage to roads; and outstanding subcontractor payments (as
per: Complaints issues – Top 20, 17.Nov. 2016). An Appeals Committee has been established to
provide third party review of unresolved grievances between TANAP and the Complainant.
Documentation on this committee has been developed and is to be provided to the IESC. Legal
redress is possible regardless of establishment of the Appeals Committee with complainants able to
take matters to court independently. This has not occurred in the Project to date; a third-party
valuation had been sought to resolve land valuation, and a policy of resolution by mutual agreement
is in place by the project.

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REPORT ORGANISATION
Subsequent sections of this Environmental and Social Review to Support Financing report are
organised as follows:
• Section 1 – Introduction;
• Section 2 – Summary Project Description;
• Section 3 – Institutional and Legal Framework;
• Section 4 – Environment, Social, Health and Safety Review and Audit Overview;
• Section 5 – Compliance with EBRD PRs;
• Section 6 – Compliance with Turkish Legislation
• Section 7 – Compliance with Other Applicable Laws / Conventions / Treaties
• Section 8 – High-level assessment of export gas pipelines projects against Lender Group
requirements for associated facilities.
• ESDD Appendices
The basic findings of the review are presented in the form of observations, comments, and
recommendations according to each standard assessed against. Direct comparison between each
requirement and reviewed Project documentation is provided in a table format at the end of each
section where relevant comments and suggested action, if necessary, to achieve compliance are also
included. The findings presented in the summary table sections form the basis of the Environmental
and Social Action Plan contained in Appendix C of this report. Descriptions of the Project have been
provided only to a degree necessary to provide context for the observations and recommendations
provided in the text.

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1. INTRODUCTION
This report contains the Environmental and Social Due Diligence (ESDD) for the TANAP Project in
Turkey. Sustainability Pty Ltd (Sustainability) was engaged by the European Bank for Reconstruction
and Development (EBRD) as the Independent Environmental and Social Consultant (IESC) to conduct
the ESDD.
The TANAP Project involves a 1,850km pipeline to facilitate the transport of natural gas produced
from the Shah Deniz Phase II development in Azerbaijan to Turkey and Europe (Figure 1.1). The
TANAP Project will connect the South Caucasus Pipeline Expansion Project (SCPx) in Georgia to the
Trans Adriatic Pipeline (TAP) Project, which commenced construction in March 2015 and extends
through Greece and Albania and across the Adriatic Sea to southern Italy.
The TANAP is being developed by a group of shareholders who currently comprise of Southern Gas
Corridor Closed Stock Joint Company (58%), BOTAS (30%) and BP (12%) and are herein referred to
collectively as the “Sponsors”. The TANAP Project, in conjunction with the South Caucasus Pipeline
(SCP) and the Trans-Adriatic Pipeline (TAP) form the elements of the Southern Gas Corridor.
TANAP will run from the Turkish border with Georgia, beginning in the Turkish village of Türkgözü in
the Posof district of Ardahan, will run through 20 provinces ending at the Greek border in the İpsala
district of Edirne (Figure 1.2). Two off-take stations are located within Turkey for national natural gas
transmission, one located in Eskişehir and the other in Thrace. With 19km running under the Sea of
Marmara, the main pipeline within Turkey reaches a total of 1,850km, along with off-take stations
and above-ground installations, with their numbers and properties detailed below:
• 7 compressor stations,
• 4 measuring stations,
• 11 pigging stations,
• 49 block valve stations and
• 2 off-take stations to supply Turkey’s national natural gas network.
In addition to the aboveground installations, temporary camps to accommodate workers, pipe storage
areas and access roads necessary during the construction phase will also be built.
TANAP is a Category A project, requiring comprehensive Environmental and Social Impact

Assessment (ESIA) in accordance with the EBRD Environmental and Social (ES) Policy. Based on the
above, the EBRD engaged Sustainability to review the existing ESIA documentation and conduct the
ESDD (to the extent possible based on available information) of the Project. The focus of the ESDD is
on the TANAP Project, however a cursory review (to identify main risks or gaps and discussion about
the significance of any identified gaps) of associated facilities, including the SCPx, TAP, and SD2
documentation is also within the scope of this ESDD.
1.1 SCOPE OF WORK

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

Page 1
• Summarizing the relevant characteristics of the Project including its associated facilities and
area of influence related to environmental and social aspects based upon a review of existing
information and appropriate site reconnaissance. Relevant characteristics include: the Project
description; institutional and legal framework; environmental and social conditions;
environmental and social impacts (direct, indirect and induced) and risks; analysis of
reasonable alternatives; environmental and social mitigation, compensation, and remedial
measures; monitoring system in place including indicators; and consultation and engagement
of affected population;
• Evaluating the adequacy of, and likely costs associated with, the proposed Project
environmental, social, and health and safety assessments, management and action plans and
procedures and present conclusions and recommendations associated with identified issues;
• Confirming to EBRD the compliance of the proposed development plan for the Project with
the applicable environmental, health, safety and social requirements, including statutory
requirements and project requirements under the Applicable Standards, and;
• Coordinating and assist the EBRD in the due diligence process in respect of environmental
and social matters in connection with the financing of the Project, answering questions and
attending meetings and conference calls as required.
Sustainability, as the IESC, provided independent review, assessment and comment on the TANAP
Project’s compliance with EBRD standards for the purposes of Project financing. This included
advising the EBRD on the adequacy of the Project’s assessments, management and mitigation
controls and monitoring measures against EBRD standards.
On account of TANAP forming a sub-component of a larger gas chain, which encompasses the TAP,
SCPx and the Shah Deniz Phase II Development, Sustainability also undertook a high level
environmental due diligence review of these associated facilities, based on publicly-available ESIAs
and management plans. Sustainability also drew upon its current experience as the IESC for Lenders
on the Shah Deniz II Development and the previous high-level assessments completed for the TAP
and SCPx Projects.
Key tasks undertaken in the documentation of this ESDD Report included:
1.1.1 Reviews and Assessments

Review of key HSES documentation, which included, but was not limited to:
• The ESIAs produced for the Project including the information prepared for the trans-boundary
notification and consultation;
• The Environmental and Social Management Plans (ESMPs) and relevant additional specific
plans including the Stakeholder Engagement Plan (SEP);
• Environmental and Social Management System (ESMS);
• Other relevant HSES materials including baseline studies, surveys, and additional
assessments, and;

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• Relevant Land Acquisition and Compensation (LAC) and Resettlement Action Plan (RAP)
documentation and Grievance Mechanism.
1.1.2 Site Reconnaissance

The IESC conducted a single site visit from the 23 – 27th November 2016, with EBRD team members
also attending. Tasks associated with the site visit included:
• Inspection of Project site locations that are agreed with the Sponsors and Lenders including
pipeline construction, compression and metering stations;
• Inspection of the associated facilities (as defined under EBRD’s Performance Requirement 1)
as appropriate, and;
• Interviews with Project HSES and other personnel and key stakeholders as relevant to the
scope of work.
The Site Visit Report is included as Appendix D.
1.1.3 Reporting
The primary objective of the Reporting task is to produce an Environmental and Social Due Diligence
(ESDD) Report (this Report).

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Figure 1.1 TANAP Pipeline Overview

Page 4
Figure 1.2 TANAP Pipeline Route Within Turkey

Page 5
1.2 LENDER POLICIES
1.2.1 EBRD Performance Requirements

EBRD-financed projects are expected to be designed and operated in compliance with good
international practices relating to sustainable development. To assist clients and their projects achieve
this, the EBRD has defined ten performance requirements covering the key areas of environmental
and social issues and impacts. In order to obtain financial support from the EBRD clients should meet
a set of 10 PRs, as follows:
• PR 1: Environmental and Social Appraisal and Management;
• PR 2: Labour and Working Conditions;
• PR 3: Pollution Prevention and Abatement;
• PR 4: Community Health, Safety and Security;
• PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement;
• PR 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;
• PR 7: Indigenous Peoples;
• PR 8: Cultural Heritage;
• PR 9: Financial Intermediaries; and
• PR 10: Information Disclosure and Stakeholder Engagement.
The PRs should be read in conjunction with the EBRD’s ES Policy. The EBRD is bound by its founding
agreement to adhere to sound banking principles and “promote in the full range of its activities
environmentally sound and sustainable development.” The ways in which the EBRD promotes such
development are described in the EBRD’s Environmental Policy document. One specific step taken by
the EBRD to address this mandate and the General Principles and Objectives set out in the Policy is to
ensure that all its investment and technical cooperation projects undergo environmental and
socioeconomic appraisal along with the financial, economic, legal and technical due diligence, and to
ensure that appropriate monitoring is undertaken following approval of projects by the Board of
Directors.
1.3 SOURCES OF INFORMATION

The review and audit was based on 1) publicly available ESIA documentation, and 2) Information
provided by TANAP, which is not available in the public domain. The main sources of information
used to prepare this Report included, among others: the ESIA and appendices; ESMPs and
supplementary slide packs prepared by TANAP and a range of implementation evidence requested by
the IESC as a result of the site visit. A full list of all documents used to prepare this Report is
provided in Appendix A.

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2. SUMMARY OF PROJECT CHARACTERTISTICS
The TANAP Project is part of the Southern Gas Corridor, which aims to transport natural gas from
Shah Deniz 2 Gas Field and other fields in the South Caspian Sea to Turkey and Europe in Azerbaijan.
The Southern Gas Corridor comprises the South Caucasus Pipeline (SCP), TANAP and the
TransAdriatic Pipeline (TAP). The TANAP corridor starts from the Georgia/Turkey border at
Türkgözü/Posof/Ardahan where it connects to SCP and ends at the Turkey/Greece border in
İpsala/Edirne, where it feeds into the TAP Pipeline. There is an off-take station at Eskişehir, Turkey,
and another one at Thrace, Turkey to connect to the Turkish natural gas distribution network.
The TANAP Project is a 56-inch and 48-inch pipeline system of 1,850km, and will transport natural
gas to the required specifications and quantity in stages starting with 16 bcma as initial phase leading
up to a high flow case of 31 bcma which is the last phase. 6 bcma will be delivered to BOTAŞ (Boru
Hatları ile Petrol Taşıma A.Ş.) to be used within the Republic of Turkey via off-take stations by Gas
Transport Agreement (GTA). The construction of the Project is expected to last for 4 years, and a
phased approach will be pursued where the target for completion of the construction and starting
operation is by the middle of 2018. The initial capacity of 16 bcma (First Stage) is expected to expand
to 24 bcma by 2023 (Second Stage) and to 31 bcma by 2026 (Third Stage), upon construction of the
required additional compressor stations. TANAP is planned to begin from the Georgia/Turkey border
and go through the provincial borders of Ardahan, Kars, Erzurum, Erzincan, Bayburt, Gümüşhane,
Giresun, Sivas, Yozgat, Kırşehir, Kırıkkale, Ankara, Eskişehir, Bilecik, Kütahya, Bursa, Balıkesir,
Çanakkale, Tekirdağ and Edirne. At the beginning of the Environmental and Social Impact Assessment
(ESIA) process the pipeline was planned to be divided into two branches after crossing Marmara Sea
and the second branch would pass Tekirdağ and enter Bulgaria through Kırklareli. However, due to
the change in the marketing strategy of Azerbaijan, natural gas to Europe by the Bulgarian section
was cancelled. The TANAP system will be fully automated with main and back-up control centres to
meet the requirements of gas transmissions and associated environmental and safety considerations.
The main pipeline facilities include the required number of compression facilities, block valve stations,
distribution and custody transfer metering facilities. The pipeline crosses terrain with challenging
geotechnical features, including landslides and other geo-hazards, in addition to crossing regions with
different levels of urbanization and economic activity. TANAP includes:
• Onshore pipeline:
o A main natural gas pipeline from the Turkey/Georgia border to the Turkey/Greece
border.
o Diameter: 56 inches to the Eskişehir Compressor Station and 48 inches from

Eskişehir.
o Compressor Station to the Turkey/Greece border.
o Total pipe length: 1850 km.
o Onshore length: 1832 km.
o Nominal capacity: 31 bcma in high-flow case.
o Design Pressure: 95.5 barg.

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o Main design according to ASME B31.8, 2012.
• Offshore pipeline section:
o Looping at Marmara Sea crossing.
o Diameter: 2 x 36 inches.
o Length: 18 km, approximately.
• Compressor Stations:
o 7 compressor stations at intermediate points for fulfilling pressure requirements. A

separate compressor train is foreseen for the gas supply to BOTAS in CST-5A
(identified as CST-5AL).
• Metering Stations:
o 1 custody receiving border metering station at the entry point.
o 1 delivery border metering station at the exit point.
o 2 fiscal metering stations at Eskişehir and Thrace Offtakes.
• Pig Launcher and Receiver facilities:
o at each compressor station (including phase compressors).
o at each metering station.
o at both sides of the shore approaches of the Dardanelles Strait Crossing.
• Block Valve Stations:
o 49 in accordance with ASME B31.8, 2012 requirements.
• Off-take Points:
o 2 in Turkey, with metering stations.
• Supervisory Control and Data Acquisition (SCADA) automation, control and

Telecommunication equipment:
o Main Control Centre in Ankara, Turkey.
o Back-up Control Centre located with Compressor Station CST-5A in Eskişehir, Turkey.
2.1.1 Current Progress

The Project is substantially commenced, with construction works having commenced on all 4 Lots.
Construction contracts for the offshore pipeline have been awarded but have not yet commenced. A
summary of construction progress at the time of the field visit, in November 2016, across all Lots is
outlined below. It is acknowledged that these figures are impacted by the inclusion of Lot 4 progress,
as works at Lot 4 had only recently commenced at that time. The completion figures for Lots 1 -3 are
significantly higher:
• 65% of pipeline welds completed;

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• 45% of pipeline lowered into construction trench;
• 38% of backfilling completed.
Relevant dates for the remainder of the construction period include:
• Final pipeline manufacture and delivery – Completed March 2017;
• Commencement of offshore construction – July 2017;
• Mechanical Completion of Phase 0 pipeline – December2017;
• Supply of gas to Eskişehir (offtake station) Phase 0 complete – June 2018;
• Material Completion of Phase 1 pipeline works – December 2018;
• Gas supply to Europe – June 2019.

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3. INSTITUTIONAL AND LEGAL FRAMEWORK
The key legal regime for the construction and operation of the TANAP Project is set out in the
applicable Host Government Agreements between Turkey and Azerbaijan (see Section 6). The Host
Government Agreement requires Project Environmental and Social Standards complying with National
Laws and also taking due account of international standards and practices generally prevailing in the
Natural Gas pipeline industry, including relevant Performance Standards of the International Finance
Corporation.
Turkey is signatory to numerous international and regional conventions that oblige the government to
prevent pollution and protect specified habitats, flora and fauna. Those of relevance to the TANAP
Project include:
Convention on the International Transportation of Hazardous Wastes, Basel, ratified by Turkey on 1994
Convention on the Persistent Organic Pollutants, Stockholm, ratified by Turkey on 2010
United Nations Climate Change Framework Convention, Bonn, ratified by Turkey on 2004
Convention on Protection of Ozone Layer, Vienna, ratified by Turkey on 1991
Convention on Long-Range Transboundary Air Pollution, ratified by Turkey on 1983
Convention on Biological Diversity. Turkey ratified this convention in 1992
Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (Turkey is a
member country).
International Convention for the Prevention of Pollution from Ships (MARPOL), ratified by Turkey on 1990
Convention on Migratory Species of Wild Animals (CMS) (Turkey is a not yet member country).
Ramsar Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar)
(Turkey is a contracting body)
Convention concerning the Protection of World Cultural and Natural Heritage (WHC) (Turkey ratified this
convention)
Convention for the Conservation of European Wildlife and Natural Habitats (BERN) (1984) (ratified by Turkey)
Convention on Wetlands of International Importance, Especially as Waterfowl Habitat (RAMSAR) (1994)
(ratified by Turkey)
European Landscape Convention (2001) (ratified by Turkey)
Convention to Combat Desertification (CCD) (1998) (ratified by Turkey)
Convention on substances depleting Ozone Layer, Montreal, ratified by Turkey on 1991
Kyoto Protocol, ratified by Turkey on 2009
Convention on the Transboundary Effects of Industrial Accidents, 2000
While not currently a member of the EU, much of Turkeys legislation has been drafted based on EU
legal provisions as a pre-cursor to membership talks that are currently ongoing. The key legislation
governing environment requirements in Turkey is the Environment Law (1983). The purpose of this
legislation is to protect the environment based on the principles of sustainable environment and
sustainable development.
Adopting the principle “Polluter Pays”, the Law encompasses principles about punishment and closure
of the facilities polluting the environment and the liabilities for informing the related authorities about
any changes to be made on the production process of the facilities. It sets the framework for other
environmental (and social) legislation within Turkey, including (as relevant to the Project):
• Law on Protection of Soil and Land Use (2005);
• Law on Pasture Land (1998);
• Conservation of Cultural and Natural Assets Law (1983);

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• Forestry Law (1956);
• Groundwater Law (1960);
• Health and Safety Law (2012);
• Labour Law (2003);
• Shore Law (1990);
• Law on Protection of Animals (2004);
• Law on the Transit Transport of Petroleum with Pipelines (2000);
• Regulation on Control of Water Pollution (2004);
• Regulation on Control of Hazardous Wastes (2005);
• Regulation on EIA (2008);
• Regulation on Management of Surface Water Quality (2012); and
• Regulation on Permits and Licenses to be Secured According to the Environment Law (2009);

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4. ENVIRONMENT, SOCIAL, HEALTH & SAFETY REVIEW
AND AUDIT
The Compliance Summary Table at the end of each PR in Section 5 provides a systematic review of
project compliance with the EBRD Environmental and Social Policy, as defined through the applicable
Performance Requirements (PRs). The review is intended to provide a baseline against which to
judge future performance of projects through the annual environmental and social reporting process.
Between 2 and 10 indicators are identified for each of the applicable PRs: 1, 2, 3, 4, 5, 6, 7, 8 and 10.
Within each sub-section, an introductory paragraph is included to provide the most relevant
observations and to facilitate the understanding of the compliance table that follows. Therefore, the
narrative paragraphs preceding the compliance tables for each Performance Requirement are aimed
to provide the “rationale” for the identified gaps, and explanation of the IESC prescriptions.
Justification for any derogation from a PR is summarised and supporting documents referenced. For
each indicator within a PR, the following three steps are completed:
• Decide whether the indicator is applicable. For Category A and B projects the starting point is
that all indicators are applicable unless the project has no significant aspects relevant to the
indicator (i.e. no risks), in which case the indicator should be scored "NA" and a brief
summary of the reason given.
• Decide whether an opinion is possible. If not (for example if the indicator will apply, but it is
too early in the project) score as "NOP" and a brief summary of why is provided. Where lack
of opinion represents a material omission to the review, reference to where this is addressed
in the report is made and recommendations are summarised.
• Indicators are scored as follows and a brief justification provided.
Exceeding Compliance:
EC The project has gone beyond the expectations of EBRD’s PR requirements. EBRD should be able to use
projects rated EC as a role model for positive Environmental and Social effects.
Fully Compliant:
FC The project is fully in compliance with EBRD’s requirements, and EU and local environmental, health and
safety policies and guidelines.
Partial Compliance:
PC The project is not in full compliance with EBRD’s requirements, but has systems, processes or mitigation
measure in place which are working towards addressing the deficiencies.
Material Non-compliance:
MNC The project is not in material compliance with EBRD’s requirements, and the systems, processes and
mitigation measures in place are not working towards addressing the deficiencies.
No Opinion Possible:
NOP Based on the data provided to date, the IESC team has not been able to form a definitive position on the
subject being discussed.
• Comments/Issues: Provide a brief commentary on the relevance of this requirement for the
project and an explanation of the chosen score.
• Actions Required: Where applicable, briefly describe any actions required by the client to
achieve full compliance with each requirement.

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5. COMPLIANCE AGAINST EBRD PERFORMANCE
REQUIREMENTS
5.1 PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF
ENVIRONMENTAL AND SOCIAL IMPACTS AND ISSUES
The EBRD outlines their requirements for assessment and management of environmental issues in
PR1. PR1 establishes the importance of integrated assessment to identify the environmental and
social impacts and issues associated with projects and the client’s management of environmental and
social performance throughout the life of the Project.
In addition to the ESIA documentation, a range of additional documentation has been requested and
provided and has been considered in this ESDD. This was undertaken to have a clear understanding
of the ESMS supporting the ESIA documents and, as mentioned above, this report is based only on
that information which has been received from TANAP or that which is in the public domain.
5.1.1 Environmental and Social Assessment
ESIA
The overarching agreement guiding development of the TANAP project with the Government of
Turkey is the Host Government Agreement (HGA, 26.06.2012). The HGA specifies the requirement
for the TANAP Project to identify E&S Standards, in line with Turkish national requirements and with
due account of prevailing international industry practices and the IFC Performance Standards (Article
17.1). The HGA further requires that TANAP prepare an ESIA in accordance with E&S Standards, for
approval by the Turkish Government, and that the ESIA include an environmental and social
investment program (Article 17.2).
The environmental and social impacts of the Project have been assessed through a systematic
process applied for all Project components as identified through the ESIA scoping process. The
primary assessment document is the TANAP ESIA which was publicly disclosed on the TANAP website
on the 22nd June 2015. The ESIA was approved by the Turkish Ministry of Environment and
Urbanisation (MoEU) in June 2014.
The ESIA involved a comprehensive assessment of the Project commensurate with and proportional
to the environmental impacts the Project presents. Prior to the detailed ESIA, a Project scoping
phase was undertaken of which the primary focus was to identify the preferred route of the pipeline
to minimise environmental and social impacts while maintaining a technically feasible installation
process. This process is outlined in detail in Chapter 5 of the ESIA and summarised in Figure 5.1
below. A predetermined set of criteria was used to determine the preferred route and these criteria
included environmental and social considerations. Preliminary assessment of the route was initially a
desktop exercise which determined a Preferred Route Corridor (PRC) of 2 kilometres in width. Once
the corridor was determined, a preferred centreline was chosen using a combination of desktop and
field data to reduce the PRC to a width of 500 metres. Within this 500-metre corridor the centreline
for the corridor was delineated and the Right of Way (RoW) disturbance area of 36 metres was
located. The ESIA was conducted on the full 500-metre pipeline corridor.

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Parameters considered during the determination of the 500-metre corridor included the following:
• General Topographical Properties;
• Soil Properties;
• Land Usage Status;
• General Geological-Geomorphologic Properties;
• Stratigraphy;
• Engineering Properties of the Rock Units;
• Surface Fault Hazards and Seismicity;
• Areas with Potential Geological Risks (Erosion, Landslide, Elevated Ground Water Layers and
Aquifers, Karstic Zones);
• Hydrological Properties;
• Ecological Properties (Protected Areas (National Parks, etc.), Sensitive Habitats, Forests,
Scrublands, Meadows-Pastures and Wetlands);
• Archaeological Sites;
• Tangible and Intangible Cultural Heritage;
• Socio-Economic Properties (Demographics, Economic Properties); and
• Existing and/or planned state authority infrastructure(s).
Potential social impacts were assessed on the effects of the following parameters:
• Effects on traffic and mobility;
• Effects on infrastructures and utility services;
• Opportunities for local economy;
• Changes to local employment conditions;
• Effects on livelihood from farming activities;
• Effects on livelihood from livestock activities;
• Effects on local healthcare services and facilities;
• Effects on human health and safety;
• Effects on local education services and facilities;
• Increase of tensions and conflicts;
• Disturbance and nuisance to daily activities;
• Influence on local population;
• Effects on intangible cultural heritage; and

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• Effects on cultural sites and archaeology.
This planning process led to a series of documented route revisions prior to the ESIA PRC and RoW
centreline being approved at Revision H. Within this process, at total of 156 different route changes
were documented. Clear evidence of avoidance of key environmental features such as national parks
and designated wildlife areas, forested areas and identified biodiversity features was observed during
the review of Project documentation.
Further route changes post Revision H have been necessary as field construction activities have
discovered previously unidentified limitations to the proposed RoW. These route changes are
managed through the TANAP Environmental Management of Change (MoC) procedure. Completed
MoC examples that incorporated a range of environmental and social checks were reviewed by the
IESC team during the site inspection.
The IESC team could see clear evidence that environmental and social aspects and impacts were
considered in detail during Project scoping and planning stages and that the mitigation hierarchy and
Good International Practice (GIP) was implemented in the route selection process.

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Figure 5.1 Pipeline Route Assessment Process

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Stakeholder engagement and consultation was undertaken during the scoping phase and results of
the consultation process incorporated into the final ESIA process. Public Participation Meetings (PPM),
Social Baseline data collection and disclosure activities were carried out along the entire pipeline route
as preliminary engagement, in accordance with the activities described in Figure 5 2 below and in line
with GIP and in line with the nature and scale of the Project.
Figure 5.2 ESIA Consultation approach

At the local level, social baseline data collection and engagement was carried out with a range of
stakeholders including local governors, local NGOs, media and communities, using primary research
methods and public disclosure meetings. Regionally, NGO & Interest Group Meetings were held in
Ankara & İstanbul, while International NGO & Interest Group meetings were held in Ankara.
A web-based online stakeholder interaction database (OSID) using software called Darzin has been
established to track, record and manage all stakeholder engagement activities including grievance
management, which has been active through pre-construction and construction and will continue into
the operations phase.
ESIA Methodology
A clear impact assessment methodology was undertaken in the conduct of the ESIA, outlined in
Chapter 2 of the ESIA Report. The ESIA was managed by international consultants Golder Associates
Ltd (Golder) to ensure compliance with both Turkish and international requirements. Local
consultants Çinar conducted the baseline studies under guidance from Golder. The impact
assessment methodology is stated to follow guidance of the European Environmental Agency (EEA)
and utilises a Drivers-Pressures-State-Impact-Response (DPSIR) framework. The ESIA was
conducted in compliance with the Turkish Regulation on Environmental Impact Assessment (2008)
and in consideration of EU Directive 2011/92/EU.

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The scoping process allowed for the identification of Valued Environmental and Social Components
(VECs) that were defined as the distinct components of the physical, biological and social
environment in the Project Area of Influence (AOI) that are subject to National or International
policies, conventions, agreements, legislative or administrative acts aimed at their protection /
enhancement.
Some gaps were observed in the review of the ESIA related to the assessment of offshore
construction impacts. The review found that the ESIA did not adequately assess the impacts related
to the potential for vessel to vessel interactions and vessel interactions with marine fauna. Vessel to
vessel interactions are considered a high risk given the stated level of high shipping traffic and vessel
use in the offshore project area. Subsequent evidence provided is sufficient to demonstrate
compliance to the IESC. Specifically, as there was limited information available regarding offshore
construction methodology during the ESIA development, a comprehensive HAZID was conducted post
ESIA development, which assesses construction related risks, including vessel to vessel interactions.
Prior to commencement of offshore construction activities, the existing HAZID will be updated and a
set of Task Risk Assessments will be developed by the Contractor to identify and mitigate potential
Project-related risks for offshore activities. The primary objective of the Task Risk Assessments is to
ensure that any Project risks are appropriately mitigated and reduced to as low as reasonably
practicable. The Contractor is currently developing Emergency Management Plans for TANAP
approval. It was also reported to the IESC that all works will be completed under close
communication with local Marine Authorities and that communications have already commenced in
this regard.
Cumulative and Transboundary Assessment

The ESIA assesses the potential for cumulative and transboundary impacts in Chapter 10 of the
document. This assessment considers the interaction between existing and planned Projects within
Turkey and the cumulative impacts of these on the physical, biological and social aspects of the
Project. Minor transboundary impacts are possible on some of the major waterways crossed by the
Pipeline route that flow into neighbouring countries. The IESC team considers the assessment of
these potential impacts has been appropriately undertaken and of a suitable scale to the Project
characteristics.
5.1.2 Environmental and Social Management System

TANAP has developed and implemented a detailed Environmental and Social Management System
(ESMS) with which to manage the Project’s environmental and social aspects. TANAP has
documented the ESMS in line with ISO 14001 requirements. The ESMS was observed to be
appropriate to the size and scale of the Project, documenting E&S policy, management plans,
procedures and guidance. The TANAP ESMS was communicated to the Project subcontractors to
ensure that their respective ESMS’ reflected the requirements of the TANAP ESMS. These
requirements were communicated through TANAP’s Environmental and Social Management Plan
(ESMP) (TNP-PLN-ENV-GEN-001) and through Environmental and Social Requirements for Contractors
(ILF-SPC-ENV-GEN001). Samples of Construction Contractors (CCs) ESMS documentation was
reviewed during the site visit where it was confirmed that it meets the requirements of TANAPs
environmental and social objectives outlined in these documents.

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In line with the ESMS, weekly environmental coordination meetings are conducted and weekly reports
are issued; coordination meetings between TANAP E&S and construction team members are also held
regularly, and monthly construction meetings are held at construction sites. There are different types
of reporting (daily, weekly, monthly, quarterly) depending on the elements of the ESMS being
implemented. TANAP conducts regular audits and inspections of CCs in line with their ESMS
requirements. A range of documentation relating to implementation of the ESMS was reviewed as
part of the ESDD and the IESC team considers that the ESMS is working in a streamlined and
coordinated manner.
At the commencement of the Project, TANAP employed a three-tiered contractor structure to

implement the Project, with an Engineering, Procurement, Construction and Management (EPCM)
contractor managing the selected CCs in the field. TANAP formally made an organisational change
from 15 September 2016 to an integrated two-tier organisation (with TANAP and CCs), removing the
EPCM contractor from the organisational structure. The IESC noted during the audit that the ESMS is
out of date with respect to roles and responsibilities and subsequent system documentation. In many
instances, the same individuals are working in the same roles (i.e. former EPCM staff are now directly
employed by TANAP) so while day to day activities appear to remain well-managed and understood
by staff, ESMS documentation reviewed during the audit does not reflect the current organisational
structure and so may not effectively manage potential risks (e.g. arising from incidents, staff
changes). As a work in progress, the IESC team considers this issue to be compliant with this PR,
given that the issue is known, changes substantially commenced, and is considered to be part of
normal ESMS review and improvement during the life of the Project. Subsequent evidence1 provided
to the IESC by TANAP indicates that the revision of TANAP documents is complete, and that CC
reviews are ongoing and will be provided to the IESC as they are approved.
The ESMS structure (and ESMPs) for the offshore pipeline construction has been developed in draft
form, and is currently being finalised. Disclosure thereof is planned to occur upon finalisation. The
IESC reviewed the draft documents at meetings held in Ankara on 12 May 2017 and the
documentation appears suitable to meet the requirements of the EBRD PRs.
5.1.3 Environmental and Social Policy

TANAP and their CCs have documented Health & Safety, Environmental and Social Policies that have
been approved and signed off by the Board of Directors.
5.1.4 Environmental and Social Management Plans

Within the ESMS a series of ESMPs have been documented to manage the Project’s environmental
and social aspects during design, construction and operation. The following ESMPs were created to
manage the impacts identified during the ESIA process:
• Construction Impacts Management Plan;
• Community Safety Management Plan;
• Community Relations Plan;
1 Including updated management plans, and TANAP presentations in Ankara meetings on 12/05/2017

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• Employment and Training Plan;
• Procurement and Supply Management Plan;
• Aggregates Management Plan;
• Traffic Management Plan;
• Cultural Heritage Management Plan;
• Erosion, Reinstatement and Landscaping Plan;
• Pollution Prevention Plan;
• Waste Management Plan; and
• Emergency Response Plan.
The framework for this suite of management plans is described in the TANAP Environmental and
Social Management Plan (TNP-PLN-ENV-GEN-001). In conjunction with these above management
plans, management and mitigation measures are also further described in the:
• Environmental Action Plan (TNP-PLN-ENV-GEN-002);
• Social Action Plan (TNP-PLN-SOC-GEN-002);
• Environmental Monitoring Plan (TNP-PLN-ENV-GEN-003);
• Social Monitoring Plan (TNP-PLN-SOC-GEN-001); and
• Biodiversity Action Plan.
The ESIA provided the basis for a number of Social SMPs, including:
• Community Relations Management Plan, addressing: Consultation Meetings, Construction

impacts activities and grievance management;
• Local Employment & Workers Management Plan: local recruitment process, worker
disciplinary actions, and employee grievances;
• Local Procurement Management Plan: supplier of local goods and services, and control of
payments to local companies & workers;
• Community Safety Management Plan: Construction impacts of the local affected communities;
mitigation measures of high risk areas; and training and awareness meetings with
communities; and
• Traffic Management Plan: E&S evaluation of traffic impacts with associated mitigation
measures.
Further, with a material change in the approach by the Project to management of resettlement and
land acquisition, additional RAPs were developed and publicly disclosed:
• RAP for AGIs: approach to management of resettlement (including permanent land

acquisition) for the above ground installations (TNP-PLN-SOC-GEN-008-P3-0); and

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• RAP for the Pipeline: approach to management of resettlement (and temporary land
acquisition) along the pipeline corridor (TNP-PLN-SOC-GEN-006-P3-0).
A range of other documentation in the form of procedures, work method statements and forms and
templates also form part of the ESMPs, which have been developed in line with ISO 14001 and the
Plan-Do-Check-Act approach.
These requirements have been communicated and enforced amongst the CCs. TANAP requires all
CCs to develop their own versions of these ESMPs, which are subsequently reviewed by TANAP for
suitability and approved for use.
As discussed in Section 5.1.2, the offshore construction ESMPs have now been developed in draft and
were able to be reviewed during meetings held with TANAP on 12 May 2017. The IESC believes the
documentation reviewed is suitable for purpose and meets the EBRD PRs.
Effective contractor management is provided for in the ESMPs, including a process for the
management of non-compliance of CCs, sighted by the IESC. However, the implementation of
contractor management mechanisms appears to differ between CCs. Regular internal and third party
monitoring is provided for through the ESMS, and records that this activity is carried out were sighted
by the IESC. However, the differing levels of capacity between CCs suggest that additional support
and performance management is required by TANAP to ensure implementation is carried out as
documented. This may be in the form of additional TANAP support staff available to those CCs who
are not as experienced or are demonstrating underperformance on site, while also providing
increased performance management focused on those specific Lots (See also PRs 2 and 4.). Non-
conformance reporting / quality management procedures have been developed, which include
performance monitoring and improvement requirements for contractors. Contractors are required to
specify KPIs and their monitoring frequency, along with specified internal and external quality audits.
Following performance reviews, any corrective action plans are developed and implemented for
regular reporting to TANAP, and escalation as appropriate based on the criticality of any non-
conformances (e.g. stop work for immediate risks, or periodic reporting to TANAP as required). As at
26.2.17, TANAP reports of 543 non-conformances raised during the Project to date to vendors and
contractors, that 90% are closed and 6% overdue. The NCRs have been raised on environmental
issues 91 times, health and safety 127 times, social and community liaison 12 times and security 16
times. In the year to date, 52 NCRs have been raised with 35% overdue.
The IESC team considers that the level of detail and breadth of coverage within the ESMPs is suitable
to manage the environmental and social impacts presented by the Project’s activities.
5.1.5 Organisational Capacity and Commitment

TANAP has a defined organisation structure, which is suitable to implement a Project of this size and
magnitude. Sufficient environmental and social personnel have been employed to implement the
ESMS and manage environmental and social issues that are present on the Project.
TANAP’s E&S team organisation is comprised of an HSSE manager, under which reports individual
Environmental and Social Impact Managers, environmental and social impact specialists (responsible
by Lots, Stations and Offshore), environmental and social impact specialist assistants and a RAP

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specialist. Site-based organisation is comprised of Lot Site Managers, to whom report environmental
and social impact specialist leads by Lot, thereunder environmental and social impact specialists by
spread. It is noted that former EPCM staff are broadly now engaged directly by TANAP.
Training of staff includes core competencies required by workers, covered in induction training and on
the Code of Conduct to ensure appropriate worker conduct is well understood and implemented,
sighted by the audit team [refer to document list Appendix A].
Modification to the organisational roles and responsibility as part of the changes to the ESMS, as
discussed in Section 5.1.2, is complete for TANAP documentation and nearly complete for CCs.
5.1.6 Supply Chain Management

Suppliers of major goods and services to the Project were chosen through a tender process, which
included HSES pre-qualification requirements and a request for certificates of ISO 18001 and ISO
14001 certification, or a description of how HSEC aspects are managed if certification has not been
achieved. This includes the sample of the contract for 56” selected pipeline suppliers for Lots 1, 2 and
3, which clearly specifies management systems requirements and project standards. The contract
defines the requirements of contractors to develop, staff, implement and improve their own ESMS in
alignment with TANAP’s ESMS and policies; national and international statutory and regulatory
requirements; ISO 14001 Standards; and all requirements, mitigations and commitments stipulated in
the Project ESIA and ESMPs.
As one of the major goods or services purchased by the Project, the lengths of pipe for the
construction of the pipeline present a significant potential supply chain management risk, with
suppliers located within Turkey and internationally in China. Evidence from TANAP describes the
desktop environmental assessment of Pipe producers that was undertaken during the pre-qualification
process including an OHS inspection by the EPCM. While aspects of E&S issues were included in this
inspection, a separate E&S inspection was not conducted. Documentation demonstrates TANAP’s
efforts in broadly ensuring E&S requirements can be managed appropriately in its supply chain
through the suppliers’ requirements for implementing an ESMS commensurate to the complexity,
nature and scale of the Project. However, an E&S inspection or strengthening of prequalification
questionnaires on social issues could reasonably have been undertaken (by TANAP or by the EPCM)
to ensure that management at suppliers’ sites was sufficient. This would have included an assessment
of aspects relating to the prevention of child / forced labour in line with the requirements of PR2.
Assessment of this aspect is not considered sufficient and is described further in the section on PR2
below.
The EBRD PRs recommend that clients ascertain whether licenced disposal sites are being operated to
acceptable standards. Evidence has been supplied to validate that TANAP has conducted site
verification audits of licenced waste disposal facilities along the pipeline route to ensure that Project
generated waste is being disposed of appropriately by the contractor.
5.1.7 Project Monitoring and Reporting

TANAP has documented and is implementing the following monitoring activities as part of their ESMS:
• Environmental Action Plan;

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• Environmental Monitoring Plan;
• Social Action Plan;
• Social Monitoring Plan;
• Commitments Register;
• Resettlement Action Plan; and
• Biodiversity Action Plan.
The Environmental Monitoring Plan (TNP-PLN-ENV-GEN-003-P3-2) has been prepared by TANAP and
is currently being implemented on the Project. This Plan defines the Environmental Monitoring
requirements for the Project, which is established based on the FEED phase Environmental and Social
Monitoring Procedure and defined in the ESIA. It ensures the appropriate management of
environmental impacts in all phases of construction, operation and de-commissioning of the Project.
Environmental & Social monitoring plans are applied to the detailed planning, reporting and follow up
of environmental and social performance measurement and monitoring throughout the Project.
TANAP establishes measurable environmental and social performance indicators (KPIs) to track
Project progress in achieving the objectives and targets and to evaluate and improve environmental
and social performance.
The Environmental Action Plan (TNP-PLN-ENV-GEN-002_P3-2) outlines how TANAP intends to ensure
that the environmental aspects of the Projects construction, operation and decommissioning are
managed in line with Project requirements. It is noted that this document currently only refers to the
requirements of the IFC Performance Standards (2012) when committing to international standards.
Evidence of implementation of the commitments made in the Project monitoring document suite was
observed during the site visit and through revision of documents in the ESDD process.
Compliance with Turkish legal requirements is overseen by the MoEU and mainly relies on quarterly
third-party monitoring reports by Çinar, distributed electronically to relevant parties, and with a hard
copy sent to the Ministry and local authorities. It is noted that Çinar is the same company who
gathered the in-country baseline data, developed the local ESIA and the BAP and there may be a
perceived conflict of interest issue with regard to using the same company for the ESIA development
and independent monitoring over the ESIA implementation. Evidence, in the form of detailed
organisation charts have been provided by TANAP to demonstrate that the levels of independence
between separate teams is sufficient and eliminates the potential for conflict of interest queries by
interested third parties.
The IESC were unable to verify the financial provision for implementation of BAP monitoring
requirements to determine if these are sufficient for monitoring of biorestoration effectiveness in
critical habitat and to ensure sufficient consideration of ongoing maintenance of biorestoration works.
The details of these cost estimates are yet to be developed by TANAP for its operational budget. The
IESC team recommends that a detailed cost breakdown is provided in order to justify that the
financial allocation is sufficient for the length of the pipeline corridor and ensure sufficient
contingency budget allocations for any newly identified biodiversity remedial and offset activities.

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Table 5-1 PR 1 Findings Summary
PR
Performance Requirement Score Comments/ Issues Actions Required
Ref.
1 Assessment and Management of Environmental and Social Impacts and Issues
1.1 Environmental and Social FC The environmental and social impacts have been assessed through a
Assessment systematic process applied for all Project components as identified
through the ESIA scoping and through engagement with key
Government stakeholders in Turkey. The ESIAs have been developed
to meet national standards, TANAP policy and guidance provided by
international institutions such as the IFC, EBRD and EU.
Some gaps were observed in the review of the ESIA related to the
assessment of offshore construction impacts. The review found that
the EISA did not adequately assess the impacts related to the
potential for vessel to vessel interactions and vessel interactions with
marine fauna. Vessel to vessel interactions are considered a high risk
given the stated level of high shipping traffic and vessel use in the
offshore project area. Additional evidence provided by TANAP is
sufficient to demonstrate compliance., including a HAZID which
assesses this risk, and which will be updated prior to the
commencement of construction activities. A set of Task Risk
Assessments will also be developed, and the Contractor is currently
developing comprehensive Emergency Management Plans.
1.2 Environmental and Social FC At the commencement of the Project, TANAP employed a three-tiered
Management Systems contractor structure to implement the Project, with an Engineering,
Procurement, Construction and Management (EPCM) contractor
managing the selected CCs in the field. TANAP has recently modified
this structure to an integrated two-tier organisation (with TANAP and
CCs), removing the EPCM contractor from the organisational
structure. At the time of the audit, the ESMS was out of date with
respect to roles and responsibilities and subsequent system
documentation. In many instances, the same individuals are working
in the same roles (i.e. former EPCM staff are now directly employed
by TANAP) so while day to day activities currently appear to remain
well-managed and understood by staff, ESMS documentation

Page 24
PR
Ref.
reviewed during the audit does not reflect the current organisational
structure and so may not effectively manage potential risks (e.g.
arising from incidents, staff changes). As a work in progress, the IESC
team considers this issue to be compliant with this, given that the
issue is known, changes substantially commenced, and is considered
to be part of normal ESMS review and improvement during the life of
the Project. Additional evidence provided to the IESC by TANAP
indicates that the revision of TANAP documents is complete, and that
CC reviews are ongoing and will be provided to the IESC as they are
approved.
The shift to an integrated team was instituted in August 2016, and

the process of E&S integration is approximately 70% complete. The
Integrated Management System (IMS) team appear to have adequate
support, human and financial resources to implement the ESMS, with
competent professionals supported by external experts as required.
1.3 Environmental and Social Policy2 FC TANAP has a documented Environmental and Social Policy. TANAP
subcontractors also have documented Environmental and Social
policies.
1.4 Environmental and Social PC TANAP has developed and implemented a detailed suite of  Disclose Offshore ESMS documentation to
Management Plan Environmental and Social Management Plans (ESMPs) for the Project. ensure requirements of EBRD PRs have been
As discussed in 1.2, ESMS documentation, revision of TANAP met.
documentation is complete, while CC documentation is nearly
complete (currently under review by TANAP).
Adequate for purpose offshore ESMPs have been developed, although

are still subject to disclosure in order to meet PR requirements.
1.5 Organisational Capacity and FC TANAP has a defined organisation structure, which is suitable to
Commitment implement a Project of this size and magnitude. Sufficient
environmental and social personnel have been employed to
implement the ESMS and manage environmental and social issues
2Where the project represents a substantial extension to the client activities, confirm that Policy and supporting management systems and plans are appropriate for the new
activities.

Page 25
PR
Ref.
that are present on the Project.
Refer to discussion in PR Ref 1.2 regarding discussion on

organisational structure.
1.6 Supply Chain Management FC The major project activity of potential E&S supply chain risk is of
pipeline procurement; pipeline procurement was carried out following
pre-qualification of potential suppliers from mills in Turkey and China.
OHS inspection of pipeline mills was reported to have been carried out
by the EPCM prior to selection of the mills. Seven pipe mills in total
were supplying to the Project, supplying to TANAP as well as other
Projects. Pre-qualification processes broadly addressed E&S
requirements at the mills and contracts with major suppliers specify
ESMS requirements and Project E&S standards. See also PR2.
As a key tool for ensuring supplier compliance with E&S requirements,
CCs are required to develop and implement Non-Conformance
reporting (NCRs) /Quality management plans to define KPIs and
quality reporting requirements. NCRs include criticality assessment
and root cause analysis, auditing/improvement processes to reduce
repetition of non-conformances, and requirements for reporting to
TANAP.
1.7 Project Monitoring and Reporting3 PC TANAP has documented and is implementing the following monitoring TANAP provide a more detailed cost breakdown
activities as part of their ESMS: to justify that the financial allocation for BAP
 Environmental Action Plan; Biorestoration monitoring is sufficient for the
 Environmental Monitoring Plan; length of the pipeline corridor and ensure
 Social Action Plan; sufficient contingency budget allocations for any
 Social Monitoring Plan; newly identified biodiversity remedial and offset
 Resettlement Action Plan; and activities.
 Biodiversity Action Plan.
Regular monitoring and reporting of HSES requirements against
3 At appraisal stage there will be limited information. Compliance assessment should address specific plans for monitoring and reporting (against for example ESAP
requirements) and also consider whether there is evidence of weak monitoring/reporting by client on other relevant projects - which may reduce confidence in future
performance.

Page 26
PR
Ref.
stated Key Performance Indicators (KPIs) was observed.
Çinar is observed to be the same company who gathered the in-

country baseline data, developed the local ESIA and the BAP.
Evidence provided is sufficient to demonstrate that there is no conflict
of interest associated with the same company also performing
independent third-party monitoring of Project implementation.
Financial provisions for implementation of BAP monitoring

requirements may not be sufficient to adequately characterise
biorestoration effectiveness.

Page 27
5.2 PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING
CONDITIONS
No material non-compliances were identified as the part of the review against labour and working
conditions criteria. Full compliance was observed in relation to child and forced labour, non-
discrimination and equal opportunity, and worker organisations. Some partial compliances were
observed in other areas within PR 2, outlined below.
5.2.1 Human Resource Policies and Working Relationships

The Host Govt Agreement requires that the labour standards applicable to the TANAP Project are
pursuant to National Laws, and no less beneficial than the provisions of the State’s relevant legislation
generally applicable to its citizens. It also requires that the Project Standards “take due account of
international standards and practices generally prevailing in the natural gas pipeline industry,
including relevant Performance Standards of the International Finance Corporation” (Article 17.1).
Turkey has ratified the core ILO Conventions on freedom of association, non-discrimination, child
labour and forced labour. The ESIA included assessment of labour issues in ESIA chapter 8.3.
The ESMP for this area is included in the Employment and Training MPs for TANAP and each of the
CCs (See ESIA Appendix 5.4 – pg 3-4 is on contracting and training requirements); addresses hiring,
training, compensation, benefits, work hours and grievance mechanism.
Project contractors’ HR policies included in their Employment and Training Management Plans are
reviewed and approved by TANAP. Third party monitoring is undertaken of implementation of these
MPs by Çinar. Additional third-party monitoring is conducted by Practical Solutions Group Dan Hiz.
Ltd. Sti on procedures in relation to TANAP contractor and sub-contractor working hours, leave, and
pay (TANAP Project Site Control Procedure, 01/03/2016). This reporting is provided to TANAP (stated
by TANAP during audit). The authorities are conducting their own labour law related inspections at
all workplaces in compliance with the legislation.
HR policies are consistent with national laws and implementation thereof is being monitored by a
Turkish labour law firm to ensure compliance (Practical Solutions Group). This is ensured by site
visits, audits, and interviews on site monthly. Requirements apply to all people working on the Project
regardless whether national or expatriate. Documentation on roles and responsibilities between the
Project and CCs requires updating to reflect the change in structure away from having an EPC in
place (see also Section 5.1.2).
The Report of “Manpower Analysis Study in Settlements on TANAP Natural Gas Pipeline Route” (HZR-
REP-SOCGEN-001) provided workforce analysis, and evaluation of the manpower capacity of the
provinces in which TANAP is active, to inform management of employment and training for the
Project. KPIs are in place for local employment (including unskilled, semi-skilled and skilled staff at
the national, province, district, village levels) in line with GIP, documented in Employment and
Training MPs for each CC (e.g. FRN-PLN-SOC-PL1-001).
All workers are reported to be advised of their rights and working conditions at the time of
engagement by human resources (including induction, code of conduct, probation period, grievance
mechanism). Additionally, this is provided for in CCs sample employment contracts (ref: Fernas

Page 28
sample contract). Induction records were sighted and are consistent with lender requirements.
However, it was reported to the audit team during the site visit by some local community contract
workers that contract terms were not clearly understood. This suggests that induction requirements
may not be applied consistently across all CCs.
Correspondence sighted (TANAP-TKF-WRP-0651) indicates that CCs are free to associate and union
agreements are in place where threshold limits are met (i.e. greater than 50% worker membership
with a single TU organisation); there are TUs in place at Lots 2 and 3 (refs: TANAP-SYA-LET-WRP-
0533 and TANAP-TKF-LET-WRP-0651).
It was noted during discussions on-site and in the head office related to employee grievances (see
5.2.7), that overtime work and fatigue management were raised on several separate occasions.
Interviews revealed there is confusion at a site level as to the TANAP policy on overtime. The IESC
understands that TANAP does not encourage overtime working for its employees, however, due to
nature of the project, overtime working may occur within the legal limits. During interviews on site
with Lot 1 Contractor Fernas, personnel reported that overtime was allowed under Fernas company
policy. According to the World Bank TANAP Disclosure Package, TANAP is working to address
overtime issues through a “Working Hours Action Plan” that substantively addresses overtime issues,
including stakeholder complaints of overtime, CC compliance with TANAP overtime policies, and
enforcing legal compliance with the Turkish Labour Code. The Action Plan aims to reach compliance
with the Labour Code by December 31, 2017. The IESC notes that the Action Plan emphasis is
directed to legal compliance around overtime. While there is a commitment to ensure that overtime
hours are worked safely and without duress, it is not clear how fatigue management measures are
linked with effective overtime management. It is also noted that contractors are financially
incentivised for being on time/advance of deadlines, which may contribute to the issue of overtime
and fatigue (see 1.3 Contractor Management and Non-Conformances regarding holding back
payments). The IESC acknowledges TANAP’s recent focus on the above issues of overtime and
fatigue management. To this end, additional information was provided to the IESC in the form of the
H&S Incentive Procedure (TNP-PCD-HSM-GEN-025), which aims to promote awareness of H&S and
incentivise workers regarding their H&S performance in order to ensure that there is a balance
between schedule / milestone incentives. During meetings on 12 May 2017, TANAP also noted that
the link between financial incentives and effective fatigue management is an area of current concern,
and provided the example of hydrotesting, whereby additional resources were engaged rather than
the use of longer hours (Lot 1 had 2 hydrotest crews, and it now has 3 crews and a 4th is being
mobilised).
The provision of employee assistance programs as GIP was discussed during the field audit (e.g.
support following presence of workers at serious accidents/fatalities while working on the Project).
TANAP stated that employees are covered under the Turkish (public) Social Insurance System, which
includes indemnity for work related incidents, valid for all workers (both CCs and TANAP employees).
TANAP has initiated a private insurance coverage (MARSH) for its employees in the event of work
related accidents, however this does not extend to CCs employees (TANAP has not set up separate
(private) insurance to cover CC workers in the event of work related accidents they may be involved
in).

Page 29
5.2.2 Child and Forced Labour
TANAP procures a wide range of goods and services, and the IESC found that no audits/inspections
of the TANAP supply chain with a focus on working conditions and child/forced labour has been
conducted to determine compliance with this PR (see related to discussion in Ref 1.6). The pipe
manufacturer pre-qualification questionnaire sighted does not contain provisions to assess the risk of
child and forced labour. However, the Health, Safety, Social and Environmental Requirements for
Suppliers and Vendors require supplier compliance with Turkish laws and regulations including the
Regulation on the Procedures and Principles of the Employment of Children's and Young Workers.
5.2.3 Non-Discrimination and Equal Opportunity

Nationally, Turkey has ratified the core ILO conventions including on non-discrimination and TANAP’s
role includes ensuring compliance with core labour standards on behalf of the Project. There was no
evidence of non-conformances of these requirements while on site.
The TANAP Employment and Training Management Plan makes an explicit commitment to non-
discrimination and equal opportunity (see ESIA Appendix 5.4 pg 1).
5.2.4 Workers Organisations

Worker organisations are in place in parts of the Project, and all employees are free to join labour
unions. Membership tends to reflect blue collar/white collar representation in each CC/TANAP
workforce. Turkish legislative requirements are that 51% of the workforce must have membership of
one Trade Union (TU) to enable an agreement to be established with the Company. The CCs in Lots 2
and 3 have an agreement with one national TU (“Yolic”/ “Is-Yol”). It was stated that all the workers
and some of the subcontractors are members of this union. Subsequent correspondence sighted
(TANAP-SYA-LET-WRP-0533) confirms that most of the workers of the contractor (as of February
2016, 600 of 700) are members of the TU, and the others do not belong to another organisation.
Further, the collective bargaining agreement came into force on 01/01/2016 and it valid until
31/12/2017 (applicable to workers in Sivas and Erzincan camp sites). Per the same correspondence,
the collective bargaining agreement specifies weekly working hours, and overtime payments in line
with the Labour Law. It was reported that negotiations are ongoing for Lots 1 and 4.
In the absence of trade union membership, there is a functional grievance mechanism in place for
employees (see 5.2.7).
5.2.5 Working Conditions

conditions (including retrenchment/termination) are (see 5.2.6) and in absence of a TU, the
individuals interviewed stated that any issues have been raised through the Muhtar to the relevant CC
for resolution through the Grievance Mechanism. TANAP CLOs are also in place and receive
comments from local workers, in addition to receiving and resolving comments/grievances via
Muhtars. While the TANAP Project Site Audit Procedure provided as evidence includes requirement for
provision of document of resignation or notice of termination, there appears to be confusion at a
ground level regarding termination and retrenchment. This may be exacerbated in the case of short-
term contracts that are open-ended, or, renewed without formal extension of the completion date.

Page 30
While notice periods for dismissal of staff are in accordance with Turkish Labour Law requirements4,
which should reflect ILO Convention 158 Termination of Employment Convention, 1982 (which Turkey
has ratified), in practice notice periods for dismissal may be occurring inconsistently, particularly in
relation to casual / short-term work. For example, TANAP reported that the third-party audits have
not found inconsistencies with national legislative requirements, however in interviews with locally
engaged staff at Ardiçli village, it was stated that following the completion of a one year contract at
the CC, a short-term contract was commenced with a subcontractor with no contract in place and
little notice for ‘termination’ of the worker. Internal audits are conducted of CCs (e.g. evidence from
EPCM audit of CC (WRP-REP-ENV-PL1-001; WRP-REP-ENV-PL2-003) indicating compliance checks
against labour issues including overtime and communications on contracts with workers. These
audits are documented in the TANAP Project Site Control Procedure, the scope of which is to audit
working conditions and rights of workers including working hours, leave, payroll, Social Security,
terminations/new hires and so on by carrying out a physical audit at least in one camp monthly.
The TANAP Health and Safety team is engaged in the design and inspection of CC accommodation.
This includes for example, that TANAP review the Lot 4 camp design to ensure requirements are met,
and for those now in place, regular inspections of accommodation. The Construction Camp
Management Plans describes weekly inspections by Camp Management personnel to ensure hygiene,
maintenance, and safety requirements are maintained. Stations contractors are supplying their own
camps however it was not possible to view one during the field audit. The Health and Safety team
audit food, accommodation, and medical facilities. A visual inspection of the camp at Lot 2 indicated
appropriate accommodation requirements are met.
the work being conducted and the climatic conditions at the time (see also PR4 on OHS). A lack of
in-field amenities including toilets, shelters and heating were observed in a range of separate
locations in the field at Lot 1. Temperature in the field during the site visit was approximately -5 to -
10C. Remains of a campfire on bare ground were observed in the Erzurum Wetland (Critical Habitat
area). TANAP presented to the IESC information regarding non-conformance reporting (NCRs) and
management. NCR requirements address the process in place to develop and assess criticality of
4 Article 29 of the Turkish Labour Law Turkish requires 30 days notice to implement collective dismissal for
economic, technical or similar reasons, affecting a specific number of workers of an organization.
In relation to individual termination and retrenchment, international Law, specifically ILO Convention 158
Termination of Employment Convention, 1982 on the issue of notice periods for dismissal of staff states that “a
worker whose employment is to be terminated shall be entitled to a reasonable period of notice or compensation
in lieu thereof, unless he is guilty of serious misconduct, that is, misconduct of such a nature that it would be
unreasonable to require the employer to continue his employment during the notice period”. The Turkish Labour
Law allows termination without notice for reasons that are less stringent than the ILO provision for “serious
misconduct”. According to the Turkish Labour Law, the employer can immediately terminate an employment
contract for a just cause whether for a definite or indefinite period, before its expiry or without the prescribed
notice periods. The law provides a list of reasons for breaking the contract for just cause which are divided in
three groups for the employee and four groups for the employer (Art. 24 and 25), namely, reasons of health;
immoral or dishonourable conduct or other similar behaviour and force majeure. There is also a fourth group for
the employer which is the employee being under arrest or under custody. The employer is entitled to break the
employment contract, whether for a definite or indefinite period, before its expiry or without the prescribed
notice periods in the above cases.

Page 31
NCRs, and steps for root cause analysis, corrective action implementation and NCR closure; this is
addressed further in PR 1.
Construction camp facilities provide adequate accommodation for workers, documented in Camp MPs
(e.g. TKN-PLN-HSM-GEN-003-P4-0).
5.2.6 Retrenchment
Local workers are being recruited by CCs for finite periods of time for work in each pipeline section
before retrenchment. It was reported and documented that workers are informed in advance of their
appointment about the duration, scope, and worker conditions (including demobilisation processes) at
their appointment. There is a large, skilled workforce in Turkey, therefore the Project is trying to
maximise local employment opportunities as the work in each area progresses. Opportunities for
local employment exist now during the current construction phase of work and retrenchment is
carried out rather than engage and move local unskilled labour outside their village/district; this is
also an approach to minimise any potential influx issues between villages/districts. It was reported
that retrenchment activities including notification and final payments, are carried out in accordance
with Turkish legal requirements.
Specific retrenchment programs are carried out by CCs, including provision of references to good
performers and providing employment again on other construction contracts (e.g. as reported by
Fernas) and TANAP reports that CCs prepare Retrenchment Plans (not sighted).
conditions (including retrenchment) are; in absence of a TU, the individuals interviewed stated that
any issues have been raised through the Muhtar to the relevant CC for resolution through the
Grievance mechanism (see 2.5 for further discussion).
5.2.7 Grievance Mechanism

All TANAP workers (worker and non-employee workers) have access to SpeakOut, TANAP’s whistle-
blower mechanism. Training on SpeakOut is provided during induction for all workers, and
signage/access is provided in camps and offices. During induction, workers are informed that any
complaint they have should go through the CRO of CC, or direct to TANAP. If the complainant wishes
to remain anonymous, then it is possible to call through a dedicated hotline or use a non-identifying
form for lodging the complaint; most complaints are not anonymous. TANAP reports that status
update and trend analysis of worker complaints will be announced on Community Relations
noticeboards available in camp sites, to be updated monthly.
CC Tekfen additionally has access for all its staff to the grievance mechanism ‘Sound off’ (ref: TANAP-
TKF-LET-WRP-0651). Coordination between CC and TANAP grievance mechanisms is documented in
the CC’s SMP with implementation monitoring by TANAP through internal and external auditing. CCs
are required to establish their own grievance mechanism, which are in effect for both community and
worker grievances. The Community Relations and Human Resources Departments coordinate
grievance handling in accordance with the grievance mechanism, Turkish law, and Project
requirements. All grievances are recorded in OSID (Online Stakeholder Interaction Database,
regarding grievances raised and corrective actions.

Page 32
The TANAP Grievance Mechanism (TNP-PCD-SOC-GEN-001) was updated on 31/1/17, and is
considered by the IESC to be compliant with the Performance Requirements.
Demobilisation process and late payment of salaries are the main topics of grievances raised by
workers overall, while Fernas also reported issues of unfair dismissal, and of poor food quality at
camp, which was resolved and rectified through the internal monthly monitoring system.
5.2.8 Non-Employee Workers

Engagement of non-employee workers carried out by CCs is undertaken in accordance with the
contractor management processes and procedures that are in place. TANAP has developed guidance
for CCs (through the former EPCM) for their development of ESMPs including Worker Management
MPs, that required approval by TANAP prior to their implementation to ensure minimum requirements
are met across all CCs. Skilled/unskilled work opportunities are locally advertised including (generally
reported) notification of working conditions and contract duration. Contract workers are informed that
the construction phase is temporary (20,000 people engaged); there is no obligation in contractor
employment agreements to provide ongoing employment. At the first consultation meeting in
settlements along the pipeline corridor, announcements are made of employment opportunities, the
type of labour required and duration, in accordance with the Local Employment MP.
Minimum working conditions for contractors are also third party monitored and are subject to
regulatory inspections.
5.2.9 Supply Chain

TANAP procures a wide range of goods and services required to complete the Project. Related to the
discussion in Ref 1.6, TANAP has not conducted any audits/inspections of their supply chain with a
focus on working conditions and child/forced labour to determine if they are compliant with this PR.
Pipe manufacturer pre-qualification questionnaire sighted does not contain provisions to assess the
risk of child and forced labour. However, the Health, Safety, Social and Environmental Requirements
for Suppliers and Vendors (ILF·SPC-HSE-GEN-001, Rev P2-0, 07.03 .2014) requires supplier
compliance with Turkish laws and regulations including the Regulation on the Procedures and
Principles of the Employment of Children's and Young Workers (#25425, 06.04.2004).
5.2.10 Security Personnel

The Host Govt Agreement provides that:
• the TANAP Project Entity shall provide the security of manned Facilities, including material
storage yards and permanent installations, in accordance with National Laws; and
• the Parties will develop a security plan to co-ordinate these activities.
TANAP specifies its security requirements to contractors through the Security Management Appendix
of the CC contract (consistent across all CCs), and directs communications through each CC’s Security
Manager. Each CC has a security subcontractor. Governors of each area determined whether security
guards are armed or unarmed, and this was reported to be detailed in a Security Risk Assessment for
the use of arms (sample Security Risk Assessments and security due diligence materials were
provided for IESC review).

Page 33
Private security legislation additionally guides implementation of local legal requirements with respect
to security personnel, roles, and responsibilities. In Turkey, the law regulating the private security
industry is Law No. 5188 on Private Security Services, enacted in 2004, which regulates the private
security industry and allows for armed private security services. Licensing for private security
companies and guards is mandatory, and the Ministry of the Interior is the national authority in
charge of controls and inspections for the industry. Legal provisions include the identifying
requirements of guards (i.e. distinguishing uniforms, identification cards), and competencies and
powers of guards. Use of force is provided for, in accordance with Article 981 of Turkish Civil Law and
Article 7 of Law No. 5188 on Private Security Services, and a special licence is required for private
security companies owning weapons. Private security companies cannot provide services and
activities that are/would normally be reserved to police forces or other public security authorities in
Turkey. Turkish national-level private security legislation is considered ‘strict’ in relation to that of
other nations in the EU. 5
A suite of security related documents has been developed by TANAP. An evaluation plan, crisis
management, and training plan have been developed to guide security-related events and activities
and sample training records of Contractors have been provided for review. A protocol between the
Gendarmerie (law enforcement authority in rural areas) and TANAP for the construction phase is
under review. A project specific Security Management Plan has been developed for implementation
by Fernas. This Plan specifies that Government Private Security Commissions in each of the following
determined that security contractors will carry or use a weapon; in: Erzrum, Kars, Ardahan, Erzincan,
Sivas, Gümüshane, and Giresun. Some of these districts include Kurdish populations. The Plan
requires that the Security Subcontractor Company provide a statement that they are willing to comply
with the “Voluntary Principles on Security and Human Rights (VPSHR)”, and photographic evidence of
the training sessions have been provided. The plan also specifies plan roles and responsibilities;
reasonable use of (lethal) force/rules of engagement; provisions for weapons storage, handling and
use; licencing; staff qualifications and training; and reporting. Coordination between the Security
Coordinator, Law Enforcement, and Regional police/Gendarme Commanders is also articulated,
specifying mechanisms in crisis events / natural disasters.
TANAP Security Department has responsibility for security analysis, inspection, training functions, as
well as the Security Management System during the operations phase, to be run from the Main
Control Centre (for the whole of the project, near Ankara).
Camp security managers are responsible for communications with HS Manager and Camp manager on
Camp Emergency Response matters, including drills, and with other stakeholders such as TANAP,
Local Authorities and local Communities (e.g. Camp management system SYA-PLN-HSE-GEN-012 and
see also PR4 item 4.9 regarding community conflicts/demonstrations).
IESC considers that reasonable efforts have been made to align with this PR, including adequate due
diligence of security providers and presence of Standard Operating Procedures guiding activities.
Training on use of force and appropriate conduct towards communities by security personnel is
5 Private Security services in Europe: CoESS Facts and Figures 2013 (Confederation of European Security
Services)

Page 34
considered efficient to demonstrate compliance (e.g. Security Risk Assessment, training records,
Security Management Plan).

Page 35
PR
Ref.
2 Labour and Working Conditions
2.1 Human Resource Policies and PC It was noted during discussions on-site and in the head office related Develop strengthened documentation and key
Working Relationships to employee grievances, that overtime work and fatigue management actions for agreement with TANAP and EBRD on
were raised on several separate occasions. Interviews revealed there overtime, to be incorporated into the ESMS, as
is confusion at a site level as to the TANAP policy on overtime. The follows:
IESC understands that TANAP does not encourage overtime working  Develop and conduct a program of engagement
for its employees, however, due to nature of the project, overtime with CC workers through appropriate
working may occur within the legal limits. During interviews on site mechanisms (e.g. HR Managers) to clarify
with Lot 1 Contractor Fernas, personnel reported that overtime was overtime policy at the site level and strengthen
allowed under Fernas company policy. According to the World Bank worker understanding of policy;
TANAP Disclosure Package, TANAP is working to address overtime  Continue to implement procedures, plans and
issues through a “Working Hours Action Plan” that substantively employment contracts consistent with working
addresses overtime issues, including stakeholder complaints of hour policies. TANAP to share audit reports
overtime, CC compliance with TANAP overtime policies, and enforcing from Practical Solutions with EBRD.
legal compliance with the Turkish Labour Code. The Action Plan aims
to reach compliance with the Labour Code by December 31, 2017. Fatigue Management:
The IESC notes that the Action Plan emphasis is directed to legal  Develop a Fatigue Management Plan for TANAP
compliance around overtime. While there is a commitment to ensure and its CCs;
that overtime hours are worked safely and without duress, it is not  Agree the Plan and its timeframe for
clear how fatigue management measures are linked with effective implementation with the EBRD;
overtime management. It is also noted that contractors are  Implement the Plan as agreed.
financially incentivised for being on time/advance of deadlines, which
may contribute to the issue of overtime and fatigue.
The IESC acknowledges TANAPs recent focus on the issues of

overtime and fatigue management. To this end, additional information
was provided to the IESC in the form of the H&S Incentive Procedure
(TNP-PCD-HSM-GEN-025), which aims to promote awareness of H&S
and incentivise workers regarding their H&S performance in order to
ensure that there is a balance between schedule / milestone
incentives. During meetings on 12 May 2017, TANAP also noted that
the link between financial incentives and effective fatigue

Page 36
PR
Ref.
management is an area of current concern, and provided the example
of hydrotesting, whereby additional resources were engaged rather
than the use of longer hours (Lot 1 had 2 hydrotest crews, and it now
has 3 crews and a 4th is being mobilised).
2.2 Child and Forced Labour FC TANAP and, through its contracting arrangements, the CCs, ensure no
child or forced labour is in use in the Project through employment
procedures. This includes confirmation of age through provision of
identification (proof of age) at recruitment, and the requirement to
report to the relevant Government agency of compliance with national
legislation that precludes employment of anyone under 18 years of
age. All employees (TANAP and CCs) provide social security,
demonstrating no staff are engaged forcibly.
2.3 Non-Discrimination and Equal FC Nationally, Turkey has ratified the core ILO conventions including on
Opportunity non-discrimination and TANAP’s role includes ensuring compliance
with core labour standards on behalf of the Project. There was no
evidence of non-conformances of these requirements while on site.
2.4 Workers Organizations FC Worker organisations are in place in parts of the Project, and all
employees are free to join labour unions
2.5 Wages, benefits, and conditions of PC Interviews with short term labour suggests that not all CCs are  Termination and retrenchment provisions:
work and accommodation making clear what the working conditions (including  Share with EBRD the Retrenchment Plans of
retrenchment/termination) are. TANAP requires provision of a each of the CCs
document of resignation or notice of termination, in practice notice  Share the first two quarterly monitoring reports
periods for dismissal may be occurring inconsistently, particularly in of the Retrenchment Plans, undertaken by
relation to casual / short-term work. It is noted that the CCs are TANAP of the CCs.
required to prepare Retrenchment Plans.
2.6 Retrenchment6 PC With respect to notice periods, interviews with short term labour  Refer to PR Ref 2.5
suggests that not all CCs are making working conditions (including
retrenchment / termination procedures) clear. TANAP requires
provision of a document of resignation or notice of termination, in
practice notice periods for dismissal may be occurring inconsistently,
particularly in relation to casual / short-term work.
6Will not be applicable to many projects at appraisal stage. However evidence, within the last 3 years of client approach to retrenchment which is not compatible with the
Policy should be taken into consideration.

Page 37
2.7 Grievance Mechanism FC An operational grievance mechanism is in place with appropriate
documentation, which appears to be being used effectively. Informal
mechanisms for raising grievances were also noted (e.g. though
Muhtars at village level for local workers), although it appears that
some of these informally raised grievances may not be registered for
tracking, monitoring and reporting within in the central recording and
tracking system (OSID). OSID has oversight and overall management
by TANAP, of all TANAP and CCs complaints, provided these have
been appropriately uploaded into the system.
2.8 Non-Employee Workers FC Engagement of non-employee workers carried out by CCs is

undertaken in accordance with the contractor management processes
and procedures that are in place. Skilled/unskilled work opportunities
are locally advertised including (generally reported) notification of
working conditions and contract duration. Contract workers are
informed that the construction phase is temporary (20,000 people
engaged); there is no obligation in contractor employment
agreements to provide ongoing employment. At the first consultation
meeting in settlements along the pipeline corridor, announcements
are made of employment opportunities, the type of labour required
and duration, in accordance with the Local Employment MP.
Working conditions of the employees of the contractors are also third

party monitored.
2.9 Supply Chain FC TANAP procures a wide range of goods and services required to
complete the Project. TANAP has not conducted any
audits/inspections of their supply chain with a focus on working
conditions and child/forced labour to determine if they are compliant
with this PR. Pipe manufacturer pre-qualification questionnaire
sighted does not contain provisions to assess the risk of child and
forced labour. However, the Health, Safety, Social and Environmental
Requirements for Suppliers and Vendors (ILF·SPC-HSE-GEN-001, Rev
P2-0, 07.03 .2014) requires supplier compliance with Turkish laws
and regulations including the Regulation on the Procedures and
Principles of the Employment of Children's and Young Workers
(#25425, 06.04.2004).

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2.10 Security Personnel Requirements FC The IESC considers that reasonable efforts have been made to align
with PR 2.10 Security Personnel Requirements, including the
adequate due diligence of security providers, their training on the use
of force and appropriate conduct towards communities by security
personnel occurs.

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5.3 PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY AND
POLLUTION PREVENTION AND CONTROL
This section provides comments on the baseline characterisation and the impact analysis with respect
to pollution prevention and abatement measures expected for all Project-related facilities during both
construction and operations. The analysis focuses on the adequacy of mitigation measures and
pertinent ESMPs reviewed. In this section, the attention is focused on the topics included in PR 3,
Resource Efficiency and Pollution Prevention and Control.
5.3.1 Resource Efficiency

The ESIA and ESMPs provides the overarching Project principles for the application of resource
efficiency and pollution prevention principles. These Principles are defined as: identify and understand
impacts; consult with others; design and avoid adverse impacts and minimise use of natural
resources. The ESMPs includes environmental control strategies designed to reduce waste and
conserve natural resources through engineering and procurement environmental design controls and
construction and installation controls.
PR 3 requires that the ESIA process identifies opportunities and alternatives for resource efficiency in
accordance with GIP. Regarding the Compressor Stations (CSTs), it is not clear in the ESIA and
supporting documentation available for review how this has occurred. The CSTs are a major emitter
of GHG during operation of the pipeline, as identified in the ESIA. A BAT assessment has been
conducted and provides sufficient detail to verify that EBRD guidance requirements have been met in
relation to how the adoption of resource efficiency and waste reduction considerations helped to
define the technology chosen in the CSTs. The BAT included detail on the realisation of the energy
savings possible because of the adoption of BAT for the CSTs and demonstrated that energy
efficiency measures have been identified.
5.3.2 Pollution Prevention and Control

A Pollution Prevention MP has been developed by TANAP and its construction contractors to minimise
and manage pollution on the environment. Avoidance and minimisation of emissions is demonstrated
in the ESIA and through the incorporation of appropriate controls.
This MP sets out the ESIA compliance requirements and relevant responsibilities associated with
pollution prevention and spill prevention and response. It provides a list of the relevant ESIA
commitments and who has responsibility for the task(s) required for compliance with the
commitment, in line with the tasks and responsibilities assigned within the TANAP Environmental and
Social Compliance Registers. Contractor responsibilities are clearly defined and include the
requirement to develop a specific Pollution Prevention MP. Examples of CC Pollution Prevention MPs
were reviewed for suitability during the ESDD process. CC MPs are also publicly disclosed on the
TANAP website.
5.3.2.1 Air Quality

Project emissions were analysed and assessed through the conduct of an atmospheric dispersion
modelling exercise. TANAP utilised AERMOD, a USEPA approved modelling software, to conduct
emission modelling for particulates and gaseous emissions caused by Project activities. Emissions

Page 40
from the modelling exercise were compared against the requirements of the Turkish Regulation on Air
Quality Assessment and Management (2008) as well as the WHO Ambient Air Quality Guidelines and
EU Directive 2008/50/EC/.
Construction
Generation of particulate matter was the primary impact identified during construction activities and
these are managed in the Pollution Prevention MP. Particulate emissions at sensitive receptors
(human and ecological) were assessed with appropriate methodology. Mitigation measures included
consideration of technically and financially feasible options to reduce construction emissions.
Operation
The primary emission source during operations are the CSTs located along the pipeline route (4
CSTs). These are designed to increase the gas pressure to adjust the gas flow to the desired
throughput. Each compressor station will be operated by gas turbines and the gas supply will be
provided from the gas flow in the pipeline. As such these facilities will have associated gaseous
emissions which required assessment. The ESIA states (in Chapter 2) that best practice technology
has been considered in reducing emissions from the CSTs. Modelled Ground Level Concentrations
(GLCs) of gaseous emissions surrounding the CSTs indicate that they are below applicable Project
Standards.
The maximum rated output of the CSTs is 157MW (for three out of four of the CSTs). EU Directive
2010/75 requires that facilities with power rating greater than 100MW shall have their emissions
monitored continuously. This should be confirmed once the infrastructure design has been defined
further.
Management and monitoring plans for air emissions during operation phases (both routine and non-
routine) of the Project have not yet been developed; although the design requirements for equipment
are specified and include minimum emission performance standards. The emissions to air from the
CST’s has been predicted using air dispersion models.
5.3.2.2 Water Quality

The Project generates two main streams of waste water from its construction activities; these being
effluent water generated from Project camps/facilities and hydrotest waste water.
The ESIA states that waste water from domestic requirements will be captured and treated in water
treatment facilities prior to being discharged to the environment. Prior to discharge, testing would be
undertaken to ensure compliance with Project Standards.
Onshore hydrotest water will preferentially be taken from surface water bodies. After use, it is
intended that water be treated until it meets the required Project Standards and discharged back to
the closest receiving environment (surface water). Where possible, addition of chemical corrosion
inhibitors will be avoided, although in some cases they may be required. The hydrotesting process is
managed through an Environmental Hydrotest Monitoring Plan, developed under TANAP guidance for
each CC over the four Lots. Each water abstraction and discharge point along the entire route was
assessed for water quality and ecological restrictions and appropriate management measures
proposed (i.e. exclusion of fish spawning periods for extraction activities).

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Water intake for hydro testing is taken based on permits granted by DSI, the General Directorate for
State Hydraulic Works. Water intake is metered at the source and instant flow rate monitors are
used. To reduce the intake of water, used hydrotesting water is pumped from one section to another.
Used hydro testing water goes through sedimentation and filtration before the discharge; and
laboratory tests are conducted to ensure water meets Project Standards prior to discharge.
Hydrostatic testing of offshore equipment and marine section of the pipeline involves pressure testing
with water (typically filtered seawater, unless equipment specifications do not allow it) to verify
equipment and pipeline integrity. Chemical additives (corrosion inhibitors, oxygen scavengers, and
dyes) may be added to the water to prevent internal corrosion or to identify leaks. A range of
measures have been proposed to minimise pollution to the marine environment from hydrotesting,
although these have yet to be formalised within the ESMPs and require review against EBRD PRs
when completed.
Water supplied to the construction camps is extracted from groundwater bores at the site under
permit from the DSI. Sanitary wastewater from the camps is treated at on-site wastewater treatment
plant and discharged to an approved location after it meets applicable Project Standards. As for the
wastewater from construction sites, it is understood that such water is collected in septic tanks and
then transported to the camps for treatment.
During operation, the collection of process waste water in the Above Ground Facilities is possible. It
will be collected in impermeable storage containers and either pumped to waste water treatment
plants if nearby or transferred by truck to an appropriate facility.
5.3.2.3 Soil
Soils were studied with specific reference to their ability to produce acidic conditions (due to sulphide
oxidation) upon excavation. Specifications for this soil testing were documented in a Subsurface
Investigation Works procedure, primarily designed to determine soil conditions and their potential for
corrosion of steel and concrete. If hostile soil conditions were encountered, then changes to the
pipeline route were considered or specific management and mitigation measures introduced.
5.3.3 Greenhouse Gases

The ESIA has assessed impacts related to GHG emissions, although it does not appear to contain
consideration of technically and financially achievable options to minimise emissions of GHG in the
assessment process. Upon IESC request, supplementary evidence was provided, in the form of the
BAT emissions inventory and relevant evaluation data, that demonstrates that resource efficiency
measures have been considered during design (e.g. ability to limit venting of gas, alternative forms of
An assessment of GHG emissions has been conducted in Section 8.1.1 of the ESIA. Emissions were
calculated using the guidance outlined in INGAA, 2005. Greenhouse gas emission estimation
guidelines for natural gas transmission and storage – Volume 1 – GHG emission estimation
methodologies and procedures.
Section 10.5 of the ESIA estimates total annual GHG emissions as follows (CO2-equivalent):
• GHGs emissions during construction phase: 78,883 tonnes per year;

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• GHGs emissions from operation: 1,956,049 tonnes per year; and
• GHGs emissions during decommissioning: 7,888 tonnes per year.
The EBRD requires that operations that produce more than 25,000 tonnes CO2-equivalent annually
quantify and report these emissions to the EBRD annually, in accordance with the EBRD Methodology
for Assessment of Greenhouse Gas Emissions.
5.3.4 Water
Combined with the discussion in 5.3.2, abstraction of water for hydrotest activities is assessed in the
ESIA; with more detail on each abstraction point given in the BAP and within the CCs respective
Hydrotest Management Plans. Examples reviewed demonstrated that both ecological and social
aspects were considered when assessing the abstraction and discharge points for each hydrotest
location, as required by PR 3.
5.3.5 Waste
The ESIA includes a detailed assessment of waste streams generated by the Project during
construction, operation and decommissioning. Management and mitigation measures are documented
in a Waste Management Plan and Pollution Prevention Plan developed by TANAP and each CC has
developed their own equivalent plans for implementation on the Project. The Plan’s includes key
responsibilities and accountability; waste forecasting requirements; segregation; application of the
waste management hierarchy; organisational structure; training; monitoring and reporting.
Waste disposal is regulated under Turkish legislation, with which TANAP complies. Waste contractors
are utilised to transfer waste to the nearest municipality landfill and disposed of. Recyclable material
will be segregated and disposed of at appropriate facilities licenced by the applicable Ministry.
Hazardous wastes are disposed of by a licenced waste disposal contractor with applicable permits
under Turkish legislation. Chain of custody records are held by TANAP confirming waste has been
disposed of at an appropriate facility.
As discussed in Section 5.1.6, EBRD PRs recommend that clients ascertain whether licenced disposal
sites are being operated to acceptable standards. Evidence has been supplied to validate that TANAP
has conducted site verification audits of licenced waste disposal facilities along the pipeline route to
ensure that Project generated waste is being disposed of appropriately by the contractor.
5.3.6 Hazardous Substances

The Project does not use or generate substantial hazardous waste volumes. The Project utilises a
formal chemical management system (ChemAlert) to manage and inform their use and selection of
chemicals that may be required during Project activities. This system preferentially selects chemicals
with the least ecological impact.
As per the requirements of both Turkish and EU legislation, TANAP utilises licenced contractors to
transport and dispose of hazardous waste. The EBRD PRs recommend that clients ascertain whether
licenced disposal sites are being operated to acceptable standards. TANAP has conducted site
verification audits of a sample of disposal facilities along the pipeline route to ensure that their waste
is being disposed of appropriately by the contractor.

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PR
Ref.
3 Resource Efficiency and Pollution Prevention
3.1 Resource Efficiency FC The principles of resource efficiency appear to have been suitability
identified during the ESIA process.
Supplementary evidence provided to the IESC is sufficient to

demonstrate appropriate consideration of energy efficient measures
during project planning.
3.2 Pollution Prevention and Control - FC A Pollution Prevention Management Plan has been developed by
Air emissions TANAP and its construction contractors to minimise and manage
pollution on the environment.
The ESIA states (in Chapter 2) that best practice technology has been
considered in reducing emissions from the Compressor Stations
(CSTs).
The maximum rated output of the CSTs is 157MW (for three of the
CSTs). EU Directive 2010/75 requires that facilities with power rating
greater than 100MW shall have their emissions monitored
continuously. It is not clear in the ESIA whether this will occur at the
CSTs as part of the commitment to best practice technology.
Emission limits are listed in Chapter 4 (Table 4.4-3) and discussed in

Chapter 8.1.14 of the ESIA. Modelled emissions for CST’s have been
provided and the maximum emission criteria for each unit is specified
in the design documentation.
3.3 Pollution Prevention and Control - FC A Pollution Prevention Management Plan has been developed by
Waste waters TANAP and its construction contractors to minimise and manage
pollution on the environment.
The Project generates two main streams of waste water from its
construction activities; these being effluent water generated from
Project camps/facilities and hydrotest waste water.

Page 44
PR
Ref.
The ESIA states that waste water from domestic requirements will be
captured and treated in water treatment facilities prior to being
discharged to the environment. Prior to discharge, testing would be
undertaken to ensure compliance with Project Standards.
Onshore hydrotest water will preferentially be taken from surface

water bodies. After use, it is intended that water be treated until it
meets the required Project Standards and discharged back to the
closest receiving environment (surface water). Where possible,
addition of chemical corrosion inhibitors will be avoided, although in
some cases they may be required.
Hydrostatic testing of offshore equipment and marine section of the

pipeline involves pressure testing with water (typically filtered
seawater, unless equipment specifications do not allow it) to verify
equipment and pipeline integrity. Chemical additives (corrosion
inhibitors, oxygen scavengers, and dyes) may be added to the water
to prevent internal corrosion or to identify leaks. A range of measures
have been proposed to minimise pollution to the marine environment
from hydrotesting.
During operation, the collection of process waste water in the Above

Ground Facilities is possible. It will be collected in impermeable
storage containers and either pumped to waste water treatment
plants if nearby or transferred by truck to an appropriate facility.
3.4 Greenhouse Gases7 FC The ESIA has assessed impacts related to GHG emissions, although it  Commit to annual reporting of GHG emissions
does not appear to contain consideration of technically and financially to the EBRD in line with their accepted
achievable options to minimise emissions of GHG in the assessment methodology.
process. Upon IESC request, supplementary evidence was provided in
the form of the BAT emissions inventory and relevant evaluation data
7Particular attention should be given to client demonstration of consideration of alternatives. Projects expected annually to produce more than 25,000 tonnes of Co2
equivalent should provide an emission inventory and plans for annual reporting.

Page 45
PR
Ref.
that demonstrates resource efficiency measures have been considered
during design (e.g. ability to limit venting of gas, alternative forms of
While this may have formed part of Project planning and assessment,
it has not been expressly stated in the ESIA documentation.
An assessment of GHG emissions has been conducted in Section 8.1.1

of the ESIA. Emissions were calculated using the guidance outlined in
INGAA, 2005. Greenhouse gas emission estimation guidelines for
natural gas transmission and storage – Volume 1 – GHG emission
estimation methodologies and procedures.
The EBRD requires that operations that produce more than 25,000
tonnes CO2-equivalent annually (which TANAP does) quantify and
report these emissions to the EBRD annually, in accordance with the
EBRD Methodology for Assessment of Greenhouse Gas Emissions.
3.5 Water FC Discussion is evident in the ESIA on the need to minimise and re-use
water where possible.
3.6 Wastes FC Detailed consideration of waste streams and their impact has been
provided in the ESIA.
3.7 Hazardous Substances and Materials FC As per the requirements of both Turkish and EU legislation, TANAP
utilises licenced contractors to transport and dispose of hazardous
waste.
The EBRD PRs recommend that clients ascertain whether licenced

disposal sites are being operated to acceptable standards. TANAP has
conducted site verification audits of a sample of disposal facilities
along the pipeline route to ensure that their waste is being disposed
of appropriately by the contractor.

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5.4 PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY
This PR recognises the importance of avoiding or mitigating adverse health and safety impacts and
issues associated with Project activities on workers, communities and consumers.
5.4.1 Occupational Health and Safety

TANAP implements a detailed Health and Safety Management System (HSMS) to manage the
Project’s Health and Safety (H&S) risks. The principles of the HSMS are documented in the TANAP
H&S Commitment (Policy) signed by the executive management team of TANAP.
Risk assessments form the basis of the management controls within the HSMS and apply the
mitigation hierarchy in their implementation. A dedicated organisational structure has been defined
to implement the TANAP HSMS.
H&S expectations for CCs were communicated during the tender process through the Health, Safety,
Social and Environmental Requirements for Suppliers and Vendors. CCs implement their own internal
HSMS which aligns with the TANAP HSMS.
High risk hazards are controlled through a Permit to Work (PTW) process, implemented by each Lot
CC and under supervision from TANAP personnel. Activities that require implementation of a PTW
include:
• Cold Work;
• Hot Work;
• Excavation;
• Confined Space;
• Lock Out / Tag Out; and
• Gas Measurement.
Lifting of pipeline on each Lot is managed under procedural guidance in the form of Safe Work
Method Statements (SWMS), as it was determined that due to the large amount of pipeline lifts on
the Project that control through a PTW system would be time consuming without providing additional
benefits to the task.
the work being conducted and the climatic conditions at the time (see also PR 2 on working
conditions). A lack of in-field amenities including toilets, shelters and heating were observed in a
range of separate locations in the field at Lot 1. Temperature in the field during the site visit was
approximately -5 to -10C. Remains of a campfire on bare ground were observed in the Erzurum
Wetland (Critical Habitat area). The IESC considers that the observed working conditions may pose
an occupational health and safety risk to construction workers on this Lot. TANAP has a NCR system
in place to manage CC performance. However, it is not clear when / if it has been used for OHS
breaches relating to environmental conditions experience in each Lot. The TANAP Assurance Review
process provides a detailed review of contractor management of HSE issues including site worker
facilities, fatigue management for drivers, high risk work procedures, work permit system

Page 47
implementation, worker training requirements and competency. The outcomes and corrective
actions of the assurance review process are tracked by TANAP.
5.4.1.1 Project H&S Incidents

TANAP monitors workplace H&S incidents and near misses. This process is outlined in the Incident
Management, Reporting and Action Tracking Procedure (TNP-SCD-HSM-GEN-006). Clear evidence
was available during the site visit that incidents are investigated in an appropriate manner and
measures to prevent reoccurrence implemented. TANAP monitors worker health through a Health
and Hygiene Monitoring process, also implemented by the CCs.
As of March 2017, the Project had recorded 1 fatality in the year to date and 6 fatalities for the period
of the Project. There have been 5 Lost Time Incidents in the year to date and 27 for the Project to
date. For road accidents attributable to the Project, there have been 2 recordable accidents in the
year to date and 14 over the life of Project. TANAP has recorded a Lost Time Injury frequency rate of
0.66 which is below its target of 0.82. The Project’s Total Recordable Injury Frequency Rate (TRIFR)
is 1.45 which is also below the Project target frequency rate of 2.
For each major safety incident, the IESC team reviewed the detailed incident reports to determine
whether the appropriate response measures had been investigated and implemented. Each incident
appeared to have been investigated in detail, with numerous corrective actions implemented.
Fatalities that occurred were on Lots managed by different CCs and involving a range of scenarios
(i.e. no pattern of occurrence) however a review of incident root cause analysis indicated that some
recurring trends were observed. These included insufficient training, infrequent audits and
evaluations and inadequate risk assessment of tasks. For personnel involved in or witnessing these
incidents, it is not clear if additional support in terms of counselling services has been offered to these
employees.
A review of the Project incident database identified that there were many incidents that involved near
misses and first aid / lost time injuries related to pipeline lifting activities. One of the recorded
fatalities was also a lifting incident. The detailed incident report related to the lifting fatality stated
that root causes of the incident were insufficient training and a lack of suitable procedures for the
tasks. Interviews with employees on the Lot indicated that it was normal practice for personnel to be
in the designated ‘danger zone’ during lifts, amongst other system failings. The fact that it was
considered normal working practice to be within the ‘danger zone’ during lifts also indicates that there
may have been a lack of appropriate supervision and conduct of workplace inspections of lifting
activities by TANAP in the field.
The IESC team has some concern that lifting activities in particular are leading to a relatively high
occurrence of reported incidents / near misses. Given that lifting of pipe is one of the most common
activities on the Project which has the potential for serious injury or fatalities, a certain level of
control and supervision of the tasks by TANAP would be expected, particularly given that lifts on the
Project are not controlled under the PTW system. TANAP reports that Lessons Learnt documents of
incidents are being shared with all lots and stations, and actions are being followed up by LOT and
Station Leads (Delivery Manager, Lot HS Lead, etc). Relevant procedures and official letters provided
and discussed with TANAP in meetings held on 12 May 2017 indicate that appropriate remedial
actions are being implemented by TANAP in relation to lifting activities.

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5.4.2 Community Health and Safety
Assessment of potential community health and safety impacts of the project on communities was
articulated in the ESIA (Chapter 8.3), along with the related Community Safety, Emergency Response
and Traffic Management Plans. TANAP, and third-party monitoring contractor, CINAR, undertake
periodic monitoring of delivery of ESIA commitments and MPs. Construction Contractor MPs and
procedures are aligned with those prepared by TANAP, and the documentation reflects a mitigation
hierarchy approach. Training for MP implementation includes awareness-raising within the workforce
of interactions with the community, interactions with emergency responders, and awareness for the
community of potential project hazards.
Site-based practices vary across CCs, with evidence of differing standards of security of Project site
access and protection of communities from potential hazards (e.g. fencing, signage, accessibility of
open trenches, engagement with affected communities). TANAP reports that trench registers are
being kept for the entire route, including the barricading status of open trenches, and are being
closely followed up by the Construction and HS Teams. Additionally, the Community Relations Team
is undertaking Community Safety Awareness meetings including access to open trenches, ROW, risks
related with unauthorised site access, and construction and traffic safety with communities
throughout the pipeline route.
However, in alignment with a key construction phase project risk, there was evidence of strong
management of potential road safety impacts to both workers and communities. These included
travel management tools, vehicle controls and monitoring, and community and worker training, and
specific training with women and children to minimise public health risks due to vehicle traffic.
Emergency Response Plans have additionally been developed and approved by TANAP, including
provision for engagement and training with external emergency responders by the Project, led by
TANAP’s Security and Emergency Response departments. These plans are supplemented by mapping
of available health services along the pipeline, and address potential for community conflicts that may
occur as a result of the Project. Regular walk-overs and fly-overs of the pipeline are in place for the
construction phase of the Project to monitor potential pipeline intrusion, while building intrusion
systems are being implemented during construction for all AGIs.
Transportation of explosives for blasting of some pipeline trenches in rocky terrain areas is done
under the supervision of Gendarmerie. Blasting is done by a series of controlled explosions, and any
excess explosives are collected by the Gendarmerie. No explosives are stored on-site.
5.4.3 Infrastructure, Building and Equipment Design and Safety

TANAP has considered GIP in the design and safe operation of its infrastructure required for operation
of the pipeline. Block valves will be operated from the CSTs manned by TANAP staff. Intelligent
pigging will be conducted regularly to monitor the mechanical integrity of the pipeline. The Project
will also install and operate a SCADA (Supervisory Control and Data Acquisition) System. The pipeline
will also have leak detection systems installed along its length, with data reviewed on the SCADA
system.
Process safety and equipment safety procedural guidance has yet to be developed and will be done
prior to operations commencing.

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5.4.4 Hazardous Materials Safety
The process and tools used to manage and monitor implementation of the environmental and social
compliance requirements relevant to construction Project are described within the ESMS. The ESMS
requires the development and implementation of a Pollution Prevention MP as part of the ESMPs,
which includes the management of hazardous materials and selection of chemicals required during
the Project construction to ensure compliance with ESIA commitments.
The ESMPs provide construction phase management controls to prevent impacts from Project related
activities resulting in harmful exposures or degradation of environmental values that are important in
maintaining community health. The construction phase plans include interface with stakeholder
engagement plans and recognise the need to communicate with local communities regarding
environmental performance and to respond to external stakeholder concerns. The Pollution
Prevention MP describes the control measures to be implemented by all Project delivery teams to
prevent contamination of soil and water, minimise spills risks and prevent impacts to livestock.
5.4.5 Traffic and Road Safety

Given the scale of the Project and the reliance on vehicles to access the pipeline route, vehicle and
road safety was identified as one of the biggest health and safety risks during Project construction
activities.
A specific Road Safety Management Unit was created to work within the overall HSMS. Detailed
ESMS documentation has been developed related to road safety, vehicle use and journey
management. Each driving route was risk assessed using a road risk analysis. Mitigation measures
on vehicles including GPS tracking and vehicle cameras were observed in all Project vehicles. Use of
mobile phones is prohibited when driving.
From a community perspective, evidence from community meetings concurs with Lender
requirements and GIP. This includes provision of training in project-affected communities on road and
traffic safety, commencing from the construction phase. Evidence has been sighted of training
programs with women and children, facilitated by CCs and TANAP social staff.
5.4.6 Natural Hazards

Detailed assessment and design studies were conducted for seismic risks along the pipeline route
during the ESIA. Where the pipeline crosses known active fault zones or is in high seismic risk areas,
specific designs are utilised to allow for potential shifts in the land surface to minimise stress on the
pipe and avoid tension in the case of surface displacement. Specialist international experts were
employed to design the seismic crossings. Specialised design drawings were observed during the site
inspection for these crossings. Section 8.1.3 of the ESIA also considers impacts associated with slope
instability in the design of the pipeline route.
5.4.7 Exposure to Disease

Community Safety MPs provide for communicable disease training to the workforce and engagement
with local health authorities to agree appropriate mitigation actions. Further, TANAP is conducting
Occupational Health Audits of CCs and sharing the actions officially with them. It is not clear if this
engagement on epidemiological studies has occurred to inform the CCs’ MPs, however in practice,

Page 50
third party contractors are available to assist in the event of any incidences of communicable diseases
as a last response with respect to the mitigation hierarchy.
Potential effects of population influx including community exposure to disease has been minimised by
local employment practices. A local hiring plan with associated KPIs, and communications with local
communities on potential hiring opportunities, have minimised population influx. Further, documented
engagement results demonstrate variation in the demand for unskilled jobs across different Lots,
which can also influence potential for influx.
5.4.8 Emergency Preparedness and Response

Appropriate Emergency Response Plans (ERPs) have been developed by TANAP and the CCs for
construction activities. Evidence of drills against the requirements of the plans was provided. TANAP
identifies that contractors operating the construction Lots are primarily responsible for emergency
response management. This includes development and testing of site specific emergency response
plans; maintaining adequate response resources and communicating with communities.
ERPs related to operation of the pipeline are currently in development and are stated to be ready six
months prior to operation. Offshore construction ERPs including an Oil Spill Emergency Response
Plan required to manage response to vessel interactions have been drafted and TANAP plan to
complete these prior to construction in the offshore package commencing in late June 2017. TANAP
are required to have these developed and disclose these plans prior to commencement of offshore
works.

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PR
Ref.
4 Health and Safety
4.1 Occupational Health and Safety FC The Project has recorded 6 fatalities since its commencement, with 4 of these
occurring in 2016. Detailed incident analysis of each event was undertaken. A
range of corrective and preventative actions were implemented as a result of these
detailed incident investigations.
Particular attention was given to lifting activities on the Project and whether
appropriate controls and supervision of lifting is occurring to ensure incidents are
minimised. The IESC team was provided with additional information following the
site audit that demonstrated that the actions resulting from major incident
investigations were being adequately applied and that the incident rates due to
construction activities had been reduced for the period from January to March 2017.
4.2 Community Health and Safety FC Potential impacts to Community health and safety was assessed in the ESIA chapter
8.3 (Social impact assessment – onshore) and the relevant SMPs subsequently
developed:
 Community Safety Management Plan (Appendix 5.2)
 Traffic Management Plan (Appendix 5.7).
TANAP conducts periodic monitoring of implementation by CCs’ of the MPs and third
party independent monitoring is additionally undertaken by CINAR.
Contractors are required to develop their own procedures (pursuant to Contracts

and consistent with the ESIA commitments and TANAP ESMPs), which have been
submitted to TANAP and approved. MPs are consistent with the mitigation hierarchy
approach and include awareness of communities to potential hazards (particularly at
the construction phase), as well as preparedness of Project staff in managing
potential risks. Management measures for key risks are documented in CC MPs,
including:
 Appropriate engagement with external emergency responders (CCs’ Emergency
Response Plans)
 Communicable disease mitigation measures (CCs’ Community Safety MPs)
 Reduction of potential community-traffic interactions (CCs’ Community Safety MPs
and Traffic MPs).
While TANAP provides support through its Construction, HS and CR Teams,

variation between site management practices was evident between different CCs,

Page 52
with varying standards of security of site access between different Lots visited.
Variations included: fencing, signage, accessibility of open pits/other potential
hazards, and engagement with local affected communities.
Evidence was provided in community meetings that TANAP/CCs have held

community safety meetings, including with women and children on trench access
and road safety. The community raised concerns about road safety in ESIA
consultation meetings, but no accidents involving communities were reported in
community meetings attended by the audit team. The project has dedicated
significant resources to minimising potential road/traffic related incidents and
accidents, including travel management tools, vehicle tracking and monitoring
equipment. See also s.4.6 below.
4.3 Infrastructure, Building, and FC TANAP has demonstrated that safety considerations relating to Project
Equipment Design and Safety infrastructure have been assessed appropriately.
4.4 Hazardous Materials Safety FC TANAP has considered safe use and transport of hazardous materials appropriately.
4.5 Product and Services Safety N/A Not applicable to this Project
4.6 Traffic and Road Safety FC Given the scale of the Project and the reliance on vehicles to access the pipeline
route, vehicle and road safety was identified as one of the biggest health and safety
risks.
Detailed ESMS documentation has been developed related to vehicle use and
journey management. Mitigation measures on vehicles including GPS tracking and
vehicle cameras were observed in all Project vehicles. Use of mobile phones is
prohibited when driving.
From a community perspective, evidence from community meetings concurs with

Lender requirements and GIP. This includes provision of training in project-affected
communities on road and traffic safety, commencing from the construction phase.
Evidence has been sighted of training programs with women and children,
facilitated by CC and TANAP social staff.
4.7 Natural Hazards FC Detailed assessment and design studies were conducted for seismic risks along the
pipeline route. Where the pipeline crosses known fault zones or is in high seismic
risk areas, specific designs are utilised to allow for potential shifts in the land
surface. Specialist international experts were employed to design the seismic
crossings. Design drawings were observed during the site inspection.
Section 8.1.3 of the ESIA also considers impacts associated with slope instability in
the design of the pipeline route.

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4.8 Exposure to Disease PC CCs’ Community Safety MPs make commitments to provide periodic communicable Develop a program on the prevention
disease training to workers and training on worker interactions with community and management of communicable
members. The Community Safety MP requires that the CCs will prepare studies on diseases in Project-affected
incidence of communicable diseases in affected Provinces, based on epidemiological communities:
information available, to ensure that all precautions are taken to prevent the  Develop the program Terms of
transmission of such diseases due to the presence of workers. Engagement is Reference for EBRD approval;
required by CCs with local health authorities to agree appropriate mitigation  Implement the program as agreed,
strategies as required. This is reflected in CCs’ MPs (e.g. SYA-PLN-SOC-GEN-001, including regular monitoring and
Table 4.2); it is not clear if such engagement/studies have been undertaken by all reporting;
CCs.  Share with EBRD for the Banks’
comment the plans for worker training
TANAP reports that it is conducting Occupational Health Audits throughout the on communicable diseases.
route. One of the audit items was to understand the status of providing training for 
communicable diseases among the employees. The findings are being shared via
official Audit Reports with related EPC/PCCs. Also, related community safety training
regarding communicable disease is to be undertaken from April to June 2017 in
camp affected settlements in liaison with local Health Authorities.
TANAP stated during the audit that 3rd party contractors are on call for any
incidences of communicable diseases, together with the Project Occupational Health
doctors, whose program of work is also periodically audited. Communicable disease
management is provided for occupational response, in the Medical Emergency
Response Plan (see PLK-PLN-HSM-PL4-011, 13.12.2016), however this Plan does
not extend to community health response to Project-induced communicable disease.
Any potential effects of population influx, with the consequent potential impact of
exposure to communicable diseases, were stated as being mitigated predominantly
through local employment practices. A study on manpower resources requirements
and availability was undertaken, in consultation with relevant stakeholders (local
authorities, chambers of commerce and others) (ref: HZR-REP-SOCGEN-001,
11.12.2015). This study indicated province-specific manpower context and informed
CCs’ local hiring plans, with associated roles, responsibilities and KPIs, developed by
each CC (e.g. FRN-PLN-SOC-PL1-001). Potential employment opportunities for local
labour are promoted at the village level near the current construction sites, based
on local hiring plans. Resulting levels of influx are low, as local potential hiring
opportunities are well understood and communicated to communities according to
the site-specific manpower resources.
4.9 Emergency Preparedness and PC Environmental Emergency Response Plans have been developed by construction  Develop offshore construction ERPs
Response contractors based on the requirements of the Guidelines for Contractors and disclose information in line with

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specification developed by TANAP. PR 10, allowing for EBRD review of
documentation prior to disclosure.
The Security and Emergency Response departments of TANAP have undertaken  Develop operational ERPs 6 months
training with relevant emergency response agencies and CCs on site, initiated by prior to operations commencing.
TANAP. Major incidents are to be prevented and contained by security systems
including pipeline intrusion inspection system, which can be operated on any station
or route (this will be moved to the Main Control Centre functions during the
operations phase), as documented in the Security Management Plan. Fence and
Building Intrusion Detection systems are in place on all AGIs, and regular walkovers
and flyovers are in place of the pipeline for the construction phase.
The Environmental Emergency Response Plan, which includes oils spill response,
has been drafted for the offshore construction package and is expected to be
finalised prior to the commencement of the offshore construction – late June 2017.

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5.5 PERFORMANCE REQUIREMENTS 5: LAND ACQUISITION,
INVOLUNTARY RESETTLEMENT, AND ECONOMIC DISPLACEMENT
The TANAP project passes through 20 provinces and 585 settlements across Turkey, with
construction of a pipeline with a 36m wide Right of Way (ROW), above ground installations (AGIs),
access roads, powerlines, some permanent operational facilities and temporary facilities during the
construction phase.
The project will cause no physical displacement, but will require permanent and temporary land
acquisition, on both public and private land. Livelihoods impacts will predominantly be from short-
term construction impacts but will cause loss of agricultural land and crops, and common natural
resources.
A number of documents regarding resettlement have been prepared for the TANAP Project. This
commenced with the Resettlement Action Plan (RAP), which was prepared at the time of the ESIA
(Golder, 2015, GLD-PLN-LAC-GEN-003-P3-1). Following this, an Implementation Audit (carried out by
ERM in 2016) and WB due diligence investigation have been undertaken on the TANAP land
acquisition, involuntary resettlement and economic displacement activities to identify gaps in
inventory studies and against World Bank E&S safeguards policies. These resulted in the development
of the RAP for Above Ground Installations (AGIs RAP) and a RAP for the Pipeline (Pipeline RAP).
These documents present a new suite of studies, commitments, processes and documents for
development and implementation by TANAP in fulfilling international standards in land acquisition and
livelihood restoration, including filling gaps in having not completed a full socio-economic survey and
census8, or livelihood restoration mechanism. The areas covered by the additional corrective actions
identified by TANAP address: Compensation and Entitlements; Livelihood Restoration; Vulnerable
Groups; Grievance Redress Mechanism; Community Engagement and Disclosure Policy; Monitoring
Process; and Local Employment9. TANAP has made an additional 16 commitments to be taken for the
remaining implementation period including preparation of a monitoring program to ensure delivery of
the commitments against international standards.
No material non-compliances were identified as the part of the review against land acquisition,
involuntary resettlement and economic displacement criteria. The RAPs present the overall impacts,
policy and legislative framework, land acquisition process, consultations and disclosure details and
implementation arrangements, indicative implementation schedules and budgets and significant
further work has been undertaken by TANAP and Lenders to develop additional commitments to meet
international requirements in LAR.
5.5.1 Physical and Economic Displacement

TANAP has avoided physical displacement through remote preferred route corridor investigation,
application of more selective selection criteria as more detailed planning progressed in assessing and
selecting the preferred corridor, and subsequent evaluation of alternative route corridors. The Route
8 A full census was not carried out for the pipeline. Instead, a representative socioeconomic survey was
conducted with 876 Project affected households, in-depth interviews with 132 village headmen and focus group
discussions with 16 different women’s groups.
9 The corrective actions are summarized in Table 24: Summary of Corrective Actions of the Pipeline RAP (pp. 48)

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has been frozen at Route H (i.e. ESMPs were developed according to this alignment). Additional
baseline studies have been undertaken to avoid key features (e.g. archaeological sites, homes, critical
habitat) with successive alignment changes, such that the current alignment is Route J. An E&S
checklist is used to determine whether desktop or field studies are required.
Four different land types are required: 49-year unrestricted and exclusive rights (16m pipeline
corridor); temporary (3year) easement rights (20m pipeline corridor); permanent ownership rights
(AGIs, access roads, poles); and 5-year contractual (rental agreement) rights for temporary facilities
such as camps. BOTAS as the land rights entity (LRE) is carrying out management and execution of
all land acquisition, in accordance to national requirements, project standards and international
policies, monitored by TANAP. The pipeline requires acquisition of 6,340ha (2,307ha of public land
and 4,032ha of private land), while 263ha of land was acquired permanently for AGIs, across 578
land parcels (79% privately owned) and impacting 936 Project Affected Persons (PAPs). AGIs for the
TANAP project include 7 compressor stations, 4 Metering stations, 11 Pig Launcher and receiver
facilities, 49 Block Valve Stations (BVS), and 2 Off-Take points.
Route realignment has been carried out during the construction phase in accordance with the re-
routing procedure to manage deviations that are required from the ESIA approved alignment. Site
surveys are undertaken by an assessment with TANAP, the CC and survey team for TANAP final
approval prior to route change implementation, including consultation with relevant stakeholders. The
process is described for community engagement in the Guide to Land Acquisition and Compensation
(currently being updated). A third-party consultant, consisting of three senior experts and one junior
expert has been engaged to conduct monitoring of PR 5 related issues (CINAR is the third-party
monitoring consultant for all other areas, excluding PR5 related issues).
TANAP has committed to follow international and national policies on LA, and in the event of a
conflict in interpretation, the international standards (World Bank OP4.12) will prevail.
5.5.2 Consultation
Consultation is required with the land owners, tenants, users, squatters, encroachers and those who
will/are experiencing loss of grazing, forest and community lands and severance/fragmentation of
lands. BOTAS is the government entity responsible for carrying out land acquisition and expropriation
on behalf of the TANAP project, including identifying, engaging with some 97,000 landowners, with
TANAP. Good working relationships were evident during the audit between BOTAS and TANAP.
Consultations commenced during Project planning phase activities, with 80 meetings with Project
affected settlements in September 2014 including distribution of the Guide to Land Access and
Resettlement (GLAC). Subsequent consultation has been undertaken by BOTAS, TANAP and CCs,
from 2014 to the present, including: Information meetings prior to negotiations/gathering sample
census data; 2 rounds of negotiation meetings; crop determination studies/meetings; preconstruction
information meetings; and land entry meetings. Advance notice/information is provided to PAPs prior
to discussions/negotiations and legal advisors present during negotiation meetings to advise on
procedural matters. Land entry meetings are held only after compensation has been paid to the
relevant landowner(s) or into an escrow account. CCs’ Community Liaison Officers (CLOs) maintain
continuous relations with PAPs and TANAP field staff maintain continuous relations with other

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stakeholders according to the RAP, and TANAP field staff providing monitoring and support in RAP
consultation and engagement to CLOs. Consultation processes provide for greater participation of
women and vulnerable groups through targeted meetings, in addition to wider village-level meetings.
Engagement as well as grievances is tracked through OSID, with data collected for TANAP and all
CCs. The Corrective Actions presented by TANAP in the Pipeline RAP additionally provides for
identification of and support to vulnerable groups.
TANAP acknowledges in the RAP for the Pipeline that the cut-off date identified in the initial RAP was
not applied in practice, as the construction commenced in advance of the original schedule and the
identification of PAPs and their assets inventory had not been completed, as is required by
international standards. However, in line with the concept of multiple cut-off dates across the
different provinces, BOTAS is applying the following approach in line with the Pipeline RAP
specifications:
• For land and other assets; the cut-off date was determined as “the day before negotiations”
(noting that BOTAS branch office representatives announced information regarding the cut
off dates and distributed the GLAC during the village consultations prior to negotiations); and
• For standing crops; the cut-off date was determined as “the day of the determination of
users” after Article 27 was put into force.
While the original approach was not in compliance with GIP, BOTAS has committed to evaluating and
compensating every additional claim and justified complaint (i.e. in line with eligibility requirements)
including those that fall after the cut-off date, which is considered a practicable approach to this
requirement (ref: Pipeline RAP s.2.34).
TANAP also acknowledges that a full socioeconomic census was not conducted (Ref: Pipeline RAP s.
2.102), rather, a sample survey was undertaken that did not allow for a full census or identification of
vulnerable households. TANAP has committed to carrying out a retrospective study to inform all
eligible PAPs and compensate these PAPs who have not yet been compensated under the new
Entitlements Matrix, to be undertaken with the development and disclosure of the public brochure
describing the RAP Fund and its management. Further, in absence of one to date, TANAP commits to
developing a Livelihood Restoration Plan to address livelihoods impacts of the Project. This should
address PAPs, and as per s.5.5.3 below, also specifically respond to whether undue hardship has
been caused through the expropriation process. Note this will allow for an additional layer of analysis
to the commitment to investigate and provide support for vulnerable groups, as identified in the
Corrective Actions summary (Table 24, RAP for Pipeline).
Consultation identified community concerns related to the themes:
• Limited access to agricultural land thus direct impact on agricultural production and livelihood
reduction
• Limited access to grazing land thus impacting livestock activities
• Damages to crops during construction
• Health risks due to leakages

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• Damage to land quality, poor reinstatement of previous projects,
• Perception of pipeline existence affecting the value of land; and
• Damages to existing infrastructure.
Consultation and information disclosure has been undertaken providing details of project activities,
timelines and responsibilities of various parties in land acquisition (LA), including distribution of the
Guide to Land Acquisition and Compensation (GLAC). The IESC notes that the corrective actions
identified in the RAP include additional engagement and disclosure actions to strengthen the Project’s
response and management of these identified issues. The RAP Fund Management Procedure has
been drafted and defines the process for implementing the RAP Fund to entitled PAPs (i.e. the
mechanism for ensuring those eligible under the revised Entitlements Matrix are identified and
compensated accordingly). Further, a new brochure is being prepared for those who are entitled to
RAP Fund compensation in line with the revised Entitlements Matrix for a widespread disclosure of
RAP Fund components and entitlements to facilitate information disclosure to PAPs in detail about
eligibility, entitlements and processes. This brochure is being delivered to eligible households and
affected communities, commencing April 2017. In parallel, internal training on international Lender
requirements has been scheduled or undertaken with all LOTS to ensure consultation and
engagement with PAPs is in line with the requirements. Lastly a stakeholder engagement plan specific
to the disclosure and engagement process on the revised entitlements matrix is yet to be complete.
This engagement plan should ensure that TANAP is proactively identifying potentially eligible
households. For disclosure of and engagement on RAP Implementation, TANAP advise that an Annex-
2 to the existing SEP is the preferred method, rather than developing a new plan of engagement
specific to RAP Implementation. This is intended to minimise confusion by making the documentation
as simple and user-friendly as possible.
5.5.3 Compensation
TANAP has described the LA process (including, broadly, identifying the corridor,
landowner/landowner shareholders, negotiation and agreement with landowners or expropriation
process). LA compensation is: (a) cash compensation for private land acquisition; (b) other assistance
through implementation of livelihood restoration plans (c) RAP Fund assistance for PAPs (informal
users or settlers not covered by Turkish legal requirements); (d) entry costs and leases for the
forestry lands. As at August 2016, approximately 5,450 formal land users have been identified (to be
compensated through BOTAS) and 324 informal users to be compensated through the RAP Fund,
administered by TANAP, as BOTAS cannot acquire land from or compensate these categories that fall
outside the Turkish legal framework. PAPs in categories eligible to receive compensation from the
RAP Fund are defined in the Entitlement Matrix in the AGIs and Pipeline RAPs. A RAP Fund
Management Procedure focusing on RAP Fund strategy and implementation principles has been
drafted and is currently being delivered to Project-affected settlements and PAPs, along with the new
GLAC (Guide to Land Acquisition). The RAP Fund Evaluation Committee has additionally been
established.
Permanent land acquisition is required for approximately 260ha for the AGIs, while approximately
6,600ha is required for a temporary period of 3 years (easement land for the construction corridor, or

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unrestricted access for the ROW). This land is to be returned to owners after construction, with some
restrictions on agriculture / buildings in easement areas.
Eligibility criteria for AGIs are defined and include provision for support to vulnerable groups. TANAP
has committed to provide additional support from this fund for economic losses of producers that
earn income from agricultural activities carried out on private or public lands affected by permanent
acquisition of land for AGIs, and to compensate such losses by allowing producers to benefit from
activities to be determined within the scope of Livelihood Restoration Program. Field studies for the
preparation of LRP for AGIs, focusing on AGI-based vulnerable groups, were completed in April 2017
and the following Livelihood Restoration Program is to be drafted by the end of June 2017. Types of
support will depend on the settlement impacted, but may include priority for employment during
Project construction, agricultural support, support to livestock production, intensive farming support,
irrigation support, alternative income generation, trainings and capacity building.
Payments to be made were initially developed to meet Turkish national expropriation requirements,
however additional entitlements have been included to meet WB OP 4.12 requirements (transaction
costs, transitional payments, support to vulnerable households, and compensation for unviable land
parcels). In some areas, this is to be applied retrospectively (for example, 100% of ROW activity has
been completed in Lot 1). A retrospective study is being undertaken (due for completion in July 2017)
to identify and compensate PAPs who have not been compensated yet under this change in
Entitlements Matrix (ref: Summary of Corrective Actions). Further, TANAP will explicitly allow for full
replacement cost for all assets and will ensure that lost income is fully restored through the
compensation process.
The Guide to Land Acquisition and Compensation (GLAC) was developed in 2014 to inform
landowners about the process for land acquisition, including the grievance mechanism, rights, and the
Land entry protocols in place to ensure land parcels are not able to be accessed by CCs without
compensation payments having been received by land owners. In addition, TANAP has developed a
brochure as a supplementary document to GLAC-2014 to explain new entitlements and eligibility
requirements as per the new Entitlements Matrix (as referenced in the above), as well as new
grievance mechanism information such as the Appeals Committee process (i.e. as per Pipeline RAP).
This new brochure developed for disclosure focuses on the frequently asked questions related to land
acquisition, and additional RAP Fund items, together with the revised / improved Entitlements Matrix.
The procedure for demonstrating avoidance of expropriation appears to be a gap. While TANAP’s LA
process allows for negotiation with landowners, 67% of agreements are not amicable and trigger the
expropriation process, which does not meet with GIP and suggests the process of determining and
compensating landowners is rushed, in addition to absentee owners or other factors, resulting in
significant expropriation by international standards. While acknowledging that the pipeline
component of the project is linear, temporary and land acquisition has been completed, it should be
clear to TANAP that the expropriation process has not caused undue hardship to those losing access
to their resources, and thus the interviews and community-level meetings planned with disclosure of
the new RAP Fund brochure are key to ensuring proactive identification of potentially eligible PAPs.

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5.5.4 Grievance Mechanism
The grievance mechanism in place for the land acquisition process is the same integrated system as
per the Stakeholder Engagement Plan (the Online Stakeholder Information Database, OSID).
Complaints and requests can be lodged online, by phone, in person or with CLOs/TANAP Social
Specialists and via Muhtars. Complaints can be lodged anonymously or complainants can identify
themselves.
All PAPs are provided with general information about the Project and specific information regarding
the LA activities, through meetings and engagement activities, as well as receiving disclosure
information such as the GLAC. The GLAC also describes the grievance process, including ways in
which grievances can be raised and the process and timelines for resolution. A quarter of all
complaints across all Lots received to date relate to damage to land (see also PR10).
Appeals Committees have been established for each Lot in January 2017 with notification at the
community level from February 2017. These will provide for third party consideration of grievances
that cannot be agreed between TANAP and the complainant. Appeals Committees were established in
January 2017 for each Lot and are being announced via posters at settlement level in addition to
public disclosure on the TANAP website and supported by documentation including the SEP,
Grievance Procedure and an Appeals Committee Application Form. Currently, no complaints have
been escalated to Appeals Committees. The SEP was updated to reflect their formation, and
disclosed via new brochure being prepared to announce RAP Fund and Appeals Committee as a part
of TANAP’s Grievance Mechanism as of April 2017. Further, incorporating additional grievance
categories into OSID will now to allow for deeper analysis and better responsiveness to issues raised
by PAPs.
CCs have a maintenance period of one year, which will include the period for testing success of
reinstatement of land. This is to be completed to the satisfaction of TANAP, and losses of income due
to the failure of reinstatement are anticipated in the payments to landowners. Landowners are
additionally able to raise a grievance following the Land Exit process. For example, if grievances
relate to satisfaction of reinstatement and this falls during the maintenance period, this will fall under
the jurisdiction of the CC to rectify, otherwise this will be responded to as per the grievance
mechanism. According to TANAP, post-maintenance period land reinstatement rectification for the 2
years after reinstatement is the responsibility of the associated construction contractors as per their
contracts. ; the guidance on the Fund’s operation is yet to be developed and is anticipated for
completion by June 2017. Depreciation of land value is factored in to the valuation of land parcels
during the negotiation process (payments are between 70-90% of easement value, depending on the
type of land, and productivity losses are calculated as 30% for year 1, 20% loss for year 2 and 10%
loss for year three, added to the land value.)
It can be anticipated that there may be issues regarding reinstatement success due to soil storage
practices (see PR 6) hence the need to ensure the guidance provides clarity that this reinstatement
will be provided for and grievances redress actions taken, whether financed through the RAP Fund or
elsewhere, and an assessment that the productivity loss factors are accurate and sufficient to cover
real losses experienced in practice. See also Section 5.5.6 and 5.5.7. It is noted that Reinstatement
has been included as a new category in OSID to enable tracking of this issue.

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5.5.5 RAP/LRP Documentation
The Project RAP (GLD-PLN-LAC-GEN-003-P3-1) was developed with a focus primarily on meeting
Turkish legal requirements and international standards, without IFI involvement. Additional
documentation has been developed and publicly disclosed, including the RAP for the Pipeline (relating
to temporary land acquisition, TNP-PLN-SOC-GEN-006-P3-0), and the RAP for AGIs (relating to
permanent land acquisition, TNP-PLN-SOC-GEN-008-P3-0). A Guide to Land Acquisition and
Compensation (GLAC) has been developed and disclosed that outlines the process of LA for owners
and non-legal land users and other stakeholders. These documents have all been publicly disclosed
on TANAP’s website.
Gaps in meeting international requirements have been identified and plans are in place to address
these, as publicly disclosed commitments in the Summary of Corrective Actions (Addendum to the
Pipeline RAP) for development and implementation of a Livelihood Restoration Plan (LRP) for the AGIs
,, focusing on AGI-affected vulnerable groups, and an LRP for Offshore Fishermen. Some of the
livelihood restoration activities are to be supported through the RAP Fund (e.g. squatters, informal
land users and vulnerable households). The LRP documentation reflects onshore and offshore
impacts; the Draft Fisheries LRP was disclosed to fishermen at two impacted settlements (Kemer &
Aksaz villages) from April 2017 and the LRP has been finalised with the inputs from disclosure and
other Lenders. The field studies for the preparation of the LRP for AGIs, focusing on AGI-based
vulnerable groups, were completed in April 2017, with the LRP to be drafted by the end of June 2017.
There have been some crop payments made from the RAP Fund already, in absence of the RAP Fund
guidance (e.g. small costs in transporting landowners to meetings during the land acquisition
process); these payments will need to be reconciled and audited by a third party (the RAP External
Monitoring Team).
5.5.6 RAP/LRP Implementation

The Pipeline RAP identifies measures to strengthen remaining implementation (RAP s.4). These
include conduct of additional studies are required to be undertaken by TANAP to fill gaps between
existing RAP implementation and as a result of expansion to the Entitlements Matrix. This includes
determining which categories of PAPs are now eligible for compensation, and confirms which have
and have not already been compensated. The AGI and Pipeline RAPs identify that some of this work
will be undertaken retrospectively as land acquisition is already finalised or commenced (i.e. only in
Lot 4 will these new RAP measures be possible to initiate from commencement of implementation in
that Lot).
TANAP commissioned a study to identify possible livelihood impacts on fishery communities near
Marmara Sea in order to develop a mitigation approach and Livelihood Restoration Plan appropriate
to the impact of the Project on fisher livelihoods. The IESC notes that completion and commencement
of implementation of this Plan is on track to commence in advance of early works and exclusion of
fisherfolk from the fishing areas. TANAP and the Offshore CC are, at May 2016, preparing for
stakeholder engagement and LRP implementation.
The Specification for Reinstatement (WRP–SPC-EGG-PLG-001) guides CCs on development,

management and implementation of reinstatement plans to ensure the ROW is restored to a form

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suitable for future use. This requires that method statements be prepared which consider the specific
environment in which reinstatement is to be undertaken, and that the CC undertakes monitoring, and
if necessary, repair, to achieve ecological and biological restoration as agreed with the landowner.
This includes for example; the land is to be made ready for re-planting with crops in arable areas and
there is a contract maintenance period during which biorestoration measures must be maintained by
the CC. The grievance management system is referenced, providing additional protections for PAPs.
Land acquisition for AGI has commenced for 349 of the 458 parcels impacted by the Project, and A
Socio-economic field study conducted during July-August 2016 with 182 PAPs impacted by
Compressor Stations and Metering Stations. Engagement identified the key findings that PAPs do not
clearly distinguish land acquisition between the pipeline compared to the AGIs, that most do not use
the grievance mechanism and that PAPs do not distinguish between TANAP, BOTAS or CCs on site,
rather, the Project is viewed as a single entity. IESC notes that TANAP is addressing these
shortcomings; AGI-specific disclosure to respond to all concerns raised by PAPs (including Project
information, grievance mechanism, compensation strategy, employment opportunities, subcontractors
and Project details regarding implementation) are currently being implemented. The AGIs land
census survey was completed with 1008 PAPs in 265 households, and according to PAP declaration,
almost half of the households lost less than 20 percent of their total land holdings due to permanent
land take resulted from MS and CS specific AGIs. The IESC notes that the LRP for PAPs whom have
been subjected to a loss of livelihood are to be compensated through the AGI LRP now under
development.
5.5.7 Monitoring
The AGI and pipeline RAPs specify monitoring and evaluation mechanisms including indicators,
implementation schedule, and budget. These RAPs will be subject to IESC/independent monitoring
and review throughout implementation in accordance with GIP and EBRD PR 5 requirements.
TANAP reports that the Final RAP Monitoring Plan has been prepared and approved by TANAP (and
the World Bank) and an independent expert contracted for RAP External Monitoring. This Team
commenced External Monitoring in April 2017 and their 1st Semi-Annual Report will be submitted in
June 2017. The 1st RAP Quarterly Internal Monitoring Report has been prepared, and is now also
available for input to the RAP External Monitoring Team review/assessment.
TANAP has committed that the monitoring process for the Project is to be immediately implemented,
and it is to be closely linked to the grievance mechanism to provide a feedback loop. Internal
monitoring processes, key indicators (input, output, process, outcome and impact, see RAP s8.8) are
to be monitored through regular internal progress reports. The IESC notes that specific indicators will
apply to BOTAS and TANAP. This RAP Monitoring plan has been reviewed by the IESC.
Internal and external monitoring activities will be further defined in line with RAP commitments, and
includes TANAP internal performance monitoring, external experts/consultants undertaking impact
monitoring, and TANAP and external consultants conducting the RAP Completion audit. Further,
TANAP has committed to undertaking an end term impact evaluation by an independent firm, one
year following substantial RAP implementation, to evaluate the outcomes of compensation and
assistance impact on project affected people to improve their living standards. This report is to be

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commissioned to document whether RAP/LRP provisions have been met, with a corrective action
identified to close out any outstanding TANAP obligations for compensation, livelihood restoration and
development benefits. The IESC notes that internal monitoring should inform the date of the
completion of the impact evaluation as the specification of one year following implementation may
not be appropriate to be able to see impacts on longer term livelihoods programs on PAPs.

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PR
Ref.
5 Land Acquisition, Involuntary Resettlement, and Economic Displacement
5.1 Avoid or minimise displacement FC Full compliance was observed in relation to avoidance or minimisation
of displacement, with no physical resettlement required over the
length of the pipeline or at AGIs. Route realignment has been carried
out during the construction phase to manage deviations from the
ESIA approved alignment, in accordance with Project procedures and
the Guide to Land Acquisition and Compensation (GLAC), developed
for stakeholders. The pipeline requires temporary (3-year) acquisition
of 6,340ha, while 263ha of land was acquired permanently for AGIs,
across 578 land parcels and 936 Project Affected Persons (PAPs).
5.2 Consultation PC Consultation with stakeholders is undertaken by TANAP as the Project RAP Fund Management:
owner, CCs’ through site-based community liaison officers, and (a) Provide EBRD the stakeholder engagement
BOTAS, as the entity responsible for land acquisition, requiring plan, Annex 2 on RAP Implementation),
identification and engagement with approximately 97,000 landowners. including specific provisions for engagement
Consultation commenced during the Project planning phase, and has with vulnerable households.
since additionally included engagement specifically on: Information
meetings prior to negotiations/census data gathering; 2 rounds of
negotiation meetings; crop determination studies/meetings;
preconstruction information meetings; and land entry meetings. Land
exit meetings will also be undertaken following reinstatement
(approximately 3 years after land entry). Consultation processes
provide for engagement with vulnerable groups including women, and
overall, the IESC notes that the corrective actions identified in the
RAP include additional engagement and disclosure actions to
strengthen the Project’s responsiveness to stakeholders’ issues.
The Cut-off date from the original RAP could not be met, and BOTAS
has developed a practicable approach to evaluate and compensate
every additional claim and justified complaint even after the cut-off
date. TANAP should ensure that this commitment is met through its
monitoring and auditing processes.
5.3 Compensation for displaced persons PC Permanent land acquisition is required for approximately 260ha for

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PR
Ref.
the AGIs, while approximately 6,600ha is required for a temporary
period of 3 years (easement land for the construction corridor, or
unrestricted access for the ROW). This land is to be returned to
owners after construction, with some restrictions on agriculture /
buildings in easement areas. TANAP is commissioning a retrospective
study (due for completion in July 2017) to identify and compensate
PAPs who have not been yet been compensated under the new
Entitlements Matrix framework (ref: Summary of Corrective Actions).
Further, TANAP has committed to providing for full replacement cost
for all assets and will ensure that lost income is fully restored through
the compensation process.
5.4 Grievance mechanism PC There is a grievance mechanism in place. The same system for  Disclosure to communities of summary
stakeholder engagement is also applied to grievance management grievance data and measures taken by TANAP
(the Online Stakeholder Information Database, OSID). TANAP has and CCs to address the common causes of
made commitments to strengthen this mechanism including through grievances, in line with recommendations made
establishment of an Appeals Committee and strengthened disclosure in 10.2.
of summary grievance information to stakeholders.  Provide a copy of Appeals Committee
documentation to EBRD including Terms of
Reference and publicly disclosed information
regarding the Committees
5.5 RAP/LRP documentation PC TANAP has committed to development of a range of new RAP Livelihood Restoration Program (LRP):
documents, documented in the Summary of Corrective Actions in the (a) Provide for EBRD comment the LRP for
Pipeline RAP. These include the Livelihood Restoration Plan (LRP), AGI-affected settlement prior to the
RAP Fund guidance and documentation. The RAP Fund intends to fill Plan’s disclosure;
the gap between payments that can be provided for by BOTAS (as the (b) Provide a copy of the completed
national responsible agency) and international requirements managed Offshore Fisheries LRP to EBRD.
and implemented by TANAP. Some payments are reported to have
already been made from the RAP Fund, and for transparency these
should be reconciled following approval of guidance on
implementation of the Fund. RAP Fund Management Procedure has
been drafted and disclosure with PAPs commenced.
LRPs are the AGI-affected resettlement (currently under development)

and the Offshore Fisheries LRP (completed).
5.6 RAP/LRP implementation PC The Pipeline RAP additionally identifies measures to strengthen  See 5.5.

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PR
Ref.
ongoing implementation of the RAP. This includes a study to
investigate potential impacts to fisherfolk in the Sea of Marmara and
thereafter develop an appropriate Livelihood Restoration Plan. The
study has been carried out, (i.e. with adequate time to investigate,
plan and respond, in advance of any impacts occurring). Similarly, the
AGI RAP provides for the development of an LRP to PAPs who have
experienced a permanent loss of livelihoods. Mitigation measures are
yet to be developed and will differ from those who experience
temporary loss, which should be clearly managed and communicated
to stakeholders.
5.7 Monitoring PC The AGI and pipeline RAPs specify monitoring and evaluation RAP Monitoring:
mechanisms including indicators, implementation schedule, and  Provide to EBRD a copy of the Internal
budget. These RAPs would be subject to IESC/independent Monitoring Report(which includes monitoring of
monitoring and review throughout implementation in accordance with the RAP Fund, and implementation of the
GIP. Both internal and external monitoring have commenced, with the Corrective Actions Register);
1st Quarterly Internal Monitoring Report (March 31, 2017) reviewed  Provide to EBRD the results of external regular
by the IESC in May 2017. TANAP has contracted independent experts monitoring of the RAP, including payments
for RAP External Monitoring and will produce their 1st Semi-Annual from the RAP Fund.
External Monitoring Report in June 2017.A site visit and investigation
by the RAP External Monitoring Team was completed as of May 5,
2017. This monitoring, will, in turn, inform the Impact Evaluation at
the conclusion of the LA and livelihood restoration program.

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5.6 PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING
NATURAL RESOURCES
The TANAP Project presents significant challenges to ensuring that potential biodiversity impacts are
effectively managed. The construction of the 1787 km underground pipeline and an 18km subsea
crossing through the Sea of Marmara, including all aboveground support facilities, involves direct
disturbance within the pipeline Right of Way (RoW) corridor through numerous ecological regions and
habitat types including terrestrial, fresh water and marine habitats. Linear construction projects of
this nature require extensive broad range data gathering to effectively characterise the biodiversity
values likely to be affected. Biodiversity management measures applied during construction are
required to be site specific to reflect the range of landscapes and habitat types encountered. These
biodiversity protection measures are therefore non-standard and require intensive management to
ensure effective outcomes.
The IESC recognise that the application of impact assessment methodology and various standards for
characterising the significance of biodiversity values for large scale linear projects requires some
modification from that which would be applied for projects that have limited geographical extent.
The consideration of area of influence and the temporal extent of likely impacts is significant in
assessment of biodiversity issues for the TANAP project and the extent to which the Project can
achieve its stated objectives for protection of biodiversity.
The TANAP Project has developed extensive documentation for baseline studies, impact assessment
and biodiversity management and monitoring. The extent of documentation reflects the diversity of
ecological regions and habitat types and the need for biodiversity management measures to be fit for
purpose. The Biodiversity Action Plan (BAP) has been developed and was being implemented at the
time of the IESC site visit and the effectiveness of these measures was observed at a sample of work
sites, including those where critical habitat had been identified.
The biodiversity assessments and studies have been completed in consideration of the IFC 2012
Performance Standards and with specific reference to Performance Standard 6: Biodiversity
Conservation and Sustainable Natural Resource Management of Living Natural Resources. In addition,
key international guidelines and standards referenced in the ESIA relevant to biodiversity
management include:
• International Union for Conservation of Nature (IUCN) Red Book (RDB) for protected species;
• Action Plan for the conservation of marine vegetation in the Mediterranean Sea (1999);
• Strategic Action Programme for the conservation of Biological Diversity (SAPO BIO) on the
Mediterranean Region (2003);
• Priority habitats according to the SAP/BIO Protocol (Barcelona Convention) (1999);
• Biodiversity in Impact Assessment Background Document to Decision VIII/28 of the

Convention on Biological Diversity – CBD Technical Series No. 26;
• The Action Plan for the conservation of Mediterranean Marine Turtles (UNEP-MAP);
• European Directive 2009/147/EEC The Birds Directive; and

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• 92/43/EEC Council Directive on the conservation of natural habitats and of wild fauna and
flora.
5.6.1 Assessment of Biodiversity and Living Natural Resources
Baseline Studies:
Baseline studies for the initial ESIA report were completed between February 2013 and March 2014.
The individual component studies did not extend throughout this period but were scheduled, for
various lengths of time, within this period. The studies were completed by Çinar Engineering who sub
contracted a range of specialist experts from various national academic and research institutions. The
baseline studies included desktop studies, aimed at collection and analysis of existing relevant
bibliographic data for all the valued environmental components (VEC’s), as identified through ESIA
scoping, and included field studies aimed at collection of field data for selected VECs, filling
knowledge gaps and verification of the desktop study results. Field surveys for the ESIA were
completed by Çinar using a defined survey methodology developed by Golder Associates who were
engaged by TANAP to assist in guiding the ESIA compliance with international standards including IFC
and EBRD requirements. A review of the baseline methodology found that the component field
studies had been undertaken using representative sampling that appears to be representative of the
project AoI. These field studies were undertaken selectively within the 500m wide Local Study Area
(LSA) for the ESIA followed by a more focussed field surveys within the 36-70m wide Right of Way
(RoW) to support the Biodiversity Action Plan (BAP). The IESC notes that the initial ESIA flora studies
were limited in duration to only one flowering season and that the flowering season in eastern and
western Turkey varies considerably. These deficiencies were somewhat addressed through the
further BAP studies undertaken between August and October 2014 that was focussed on identification
or priority species within the Pipeline Right of Way ROW (which ranges from 36 to 70 m in width).
A Baseline LSA was defined based on the likely AoI in which direct or indirect impacts to VECs could
occur. The LSA considers a 500m wide route corridor for the onshore pipeline and 100m wide for the
offshore component. A Regional Study Area (RSA) was also defined through the ESIA to allow impact
significance assessments, including identification of priority biodiversity features and critical habitat.
The RSA included terrestrial flora and fauna and habitats through Eco-regional data, and protected
areas within 5km of the TANAP route. There were 20 RSA provinces covered through the baseline
study that capture a vast array of ecoregions across the extent of Turkey. The RSA and LSA were
mainly assessed through desktop study while the AoI was assessed through field study.
The scale and linear nature of the Project presented some significant issues in collection of sufficient
baseline data required to undertake a comprehensive habitat assessment. The ESIA mapped the
EUNIS habitat types along the full pipeline route and identified 30 different Level 3 habitat types
along the route. The IESC notes that the ESIA did not establish a discrete management unit (DMU),
which is essential for the quantitative evaluation of the proportion of the global population occurring
within it. The ESIA concedes that the baseline data gathering was insufficient to delineate habitats
distribution around the LSA and the absence of population data from the baseline studies resulted in
the LSA being used as the spatial unit of analysis and critical habitat being only identified and mapped
at the LSA scale (500m from the Project footprint). The ESIA does recognise this deficiency and

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states that “it would be appropriate to conduct in-depth critical habitat assessments for the Project if
data become available for identifying the appropriate DMU’s”. The critical habitat assessment in the
ESIA was unable to assess against the quantitative thresholds set in Criteria 1 to 3 as a DMU was not
determined and therefore the assessment does not follow Guidance Note 65 of IFC PS6. As a result of
this, the ESIA applied conservative critical habitat assessment to define:
• Confirmed critical habitat – where species under Criteria 1 to 3 were observed and therefore
the entire patch of EUNIS Level 3 Habitat relevant to that species within the LSA was
determined to be critical habitat.
• Potential Critical habitat – where species under Criteria 1 to 3 were identified to be potentially
present and /or the habitats might contain unique evolutionary processes and/or high
biodiversity values (Criteria 4 and 5).
The baseline survey biodiversity studies included:
• Marine Fauna Baseline Report - containing data gathered from field observations, materials
collected, literature screening and personal interviews for a 2km wide buffer zone within the
local study area along the section of pipeline through the Sea of Marmara;
• Marine Flora Baseline Report – including data gathered form field observations, collected
materials and literature reviews for the local study area associated with the subsea pipeline
corridor;
• Marine Biodiversity Baseline Report – includes the findings and analysis obtained from the
marine flora and fauna reports along with literature review to characterise the biodiversity of
the local and regional study areas;
• Marine Habitats and Ecosystems Baseline Report – focussed on a 500m wide subsea pipeline
corridor route for the local study area and a 100m wide regional study area to identify habitat
types and assess the potential for critical and priority habitats;
• Terrestrial Fauna Baseline Report – includes both desktop and field studies (May and July
2013) with field studies prioritised to confirm presence and distribution of fauna within
natural and critical habitat areas of the LSA and to identify priority species and habitats.
• Terrestrial Flora Baseline Report - Terrestrial flora field data was collected in May to July of
2013, being only one flowering season, to confirm the presence and distribution of terrestrial
flora species particularly within Natural and Critical habitat areas of the LSA (500 m corridor),
and determine the presence of endemic, restricted-range, critically endangered and
endangered flora species in the LSA.
• Terrestrial Protected Areas Baseline Report - identified protected areas present in the LSA
(500m corridor) and Regional Survey Area (RSA) (within 5km of the LSA) and identify where
impacts may be predicted.

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• Terrestrial Biodiversity Baseline Report – collected field data and documented information on
the biodiversity characteristics of the RSA with respect to ecological values and characterised
the biodiversity values, including potential for critical habitats, within the LSA and relevant
nearby locations where impacts are predicted.
• Terrestrial Habitats and Ecosystems Baseline Report – included ground truthing of European
Nature Information System (EUNIS) level 3 habitat classification map and acquire data
regarding the status if habitats of conservation importance.
• Freshwater Fauna Baseline Report – included desktop and field studies, June-July 2013 and
September-November 2013) at 200 sampling stations to confirm the presence of fish species
within rivers subject to pipeline crossings and determine presence of endemic, restricted
range, critically endangered and endangered fish species for habitat assessments.
• Freshwater Flora Baseline Report – included desktop and field surveys conducted during key
flowering periods (May to June for the western sectors and July to August for the eastern
Turkey section), to determine distribution and presence of flora species in the LSA and to
determine priority species and allow the assessment of critical habitats.
• Freshwater Habitats and Ecosystems Baseline Report - was completed for freshwater habitats
within the LSA to confirm the distribution of habitats defined at a desktop level using the
EUNIS standardised habitat system, and also to acquire recent data regarding conservation
status and significance using National and international data and criteria.
• Ecosystem Assessment of TANAP corridor through Posof Wildlife Development Area – was
undertaken by a multi-disciplinary team of National scientific specialists in July 2013 to
undertake an ecological assessment of a range of protected areas within the WDA that are
likely to be affected by the TANAP LSA.
The baseline studies undertaken for the ESIA were sufficient to allow the scoping of critical habitat
(PR6 paragraph 6) but are not sufficiently detailed to allow for a critical habitat assessment in
accordance with PR6 paragraphs 7-9.
The European Nature Information System (EUNIS) habitat criteria appeared to provide a useful tool
for desktop studies and impact assessment of biodiversity values within the study areas (RSA, LOA
and AoI).
Community engagement undertaken for the ESIA included a range of surveys that include questions
regarding the presence of conservation significant species within the Project AoI and request for
information regarding community use of natural ecosystems including hunting, collection, bee
keeping and livestock grazing. This social data was used to supplement biodiversity baseline where
relevant.
Additional BAP Studies and Surveys

Further field and desktop biodiversity studies were undertaken by Cinar from August to October 2014
as part of the Biodiversity Action Plan (BAP) development. The BAP has been subject to a number of
revisions, the latest being the version Rev-P3-10 issued in May 2017. The BAP studies were required
to address data gaps identified in the ESIA studies, as described below, accommodate route changes

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that had occurred and to revise the critical habitat assessment completed for the ESIA. The BAP
ecological surveys were targeted towards the presence of ecological sensitive species and habitats
along the RoW, between 36m and 70 m in width.
BAP ecological field surveys focused on potential impacts within and along and immediately adjacent
to the ROW (36-70m) and used the ESIA as a macro perspective of the ROW surroundings.
The BAP objective is to protect and conserve the biodiversity within the 36m ROW during the
construction, operation and decommissioning phases of the project. The BAP identifies species and
habitats of significance with the aim of developing area specific actions. The BAP objectives include
the identification and management of critical habitat in line with IFC Performance Standard 6 and the
requirements of the Turkish National Biodiversity Strategy and Action Plan.
The BAP re-evaluated the baseline surveys carried out in the ESIA studies. This re-evaluation
included:
• The findings of the ESIA baseline studies within the 500m LSA were re-assessed for the 36 m
ROW;
• Verification and re-evaluation of Species of Conservation Concern;
• Field studies for considered species and habitats were planned; and
• Intersections between the ROW and protected areas or high biodiversity areas were
reviewed.
The BAP, including the re-evaluation of critical habitat, was undertaken by Çinar by relevant subject
matter national specialists. The Critical Habitat assessment methodology was developed in
consultation with other Project lenders and recognised the lack of identified Discrete Management
Unit and the species level data limitations for the 500m wide corridor.
Impact Assessment
The ESIA baseline data was used to define the sensitivity of the various VEC’s to identify likely
impacts associated with the project and to define the pre- project condition that will be used as a
benchmark to detect changes during monitoring. VECs were assigned sensitivity levels based on a
range of factors including current quality of the component and susceptibility to environmental
changes. Those impact factors most relevant to biodiversity impacts were identified as:
• Reduction in topsoil quality/availability;
• Site restoration;
• Sediment suspension;
• Removal of natural vegetation; and
• Introduction of alien species.
The impact assessment methodology for biodiversity assigned impact factor intensity based on
assumed standard mitigations being applied in accordance with good industry practice, so impact
factors are measured only after mitigation. The impact assessment methodology was based on that

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provided by Golder Associated which applies a GIS approach using a Driving Forces –Pressures-State-
Impacts-Response (DPSIR) framework.
Protection of terrestrial flora species in Turkey is a key issue as Turkey represents the richest flora in
the Palearctic (approximately 9700 species) and a very high rate of endemism (over 30%).
Priority Biodiversity Features

The TANAP BAP was developed with the specific objective to identify the species and habitats in
consideration of national and international significance and to consequently determine the applicable
area specific action to protect and conserve biodiversity within the 36 m RoW. The BAP has
identified the presence of natural habitats, intersections of the ROW with protected or conservation
areas and the presence of ecologically sensitive species within the ROW.
Flora studies included the sampling of 246 stations along the pipeline route. Species of conservation
significance were identified from assessments against the Red Book of Turkish Plants and IUCN 2001.
The studies identified 9 species considered critically endangered, 14 endangered, 35 vulnerable and
14 are near threatened. Moreover, 221 taxa were found to endemic and 62 of these are considered
restricted range. Of the 86 Species of Conservation Concern (SCC), 62 were found along the pipeline
ROW during field studies and one species was identified as new to science, bringing the total number
of SCC to 87.
The terrestrial fauna surveys identified five mammal SCC as a result of desktop and field studies
including 3 vulnerable and one near threatened. Bird studies identified 11 SCC including one critically
endangered, 4 endangered, 2 vulnerable and one near threatened species. There were 3 reptile SCC
identified including one critically engaged, on endangered and one near threatened. One vulnerable
amphibian species was identified. A total of 34 Arthropod species were identified as SCC including one
critically endangered, 7 endangered, 2 vulnerable and one near threatened.
The BAP includes a discussion of EUNIS habitat types encountered along the TANAP route including
30 different terrestrial habitat types classified as Level III and 6 level III freshwater habitats. Habitat
types classified as significant under the Turkish ‘National Biodiversity Strategy and Action Plan” were
also identified as priority habitats including steppe, coastal sand-dunes and mountainous forest
ecosystems.
Freshwater biological studies found no flora taxa that triggered SCC. The fish species were identified
from 189 river crossing sites sampled over two field campaigns in different seasons. These studies
identified 13 SCC fish species, 11 of which are highly endemic and two critically endangered. One
species of endangered aquatic invertebrate was identified as being potentially occurring at project
river crossings.
Protection status and endemism (for some species) have been determined by checking against BERN,
IUCN, CITES, Bird Directive, Habitat Directive, CHCD and RDBT. Protected and conservation areas in
the 10-km buffer around the Project have been determined.
Threatened flora and fauna species within the 500m corridor have been assessed. Freshwater critical
habitats (FCH) have been determined according to EUNIS Code with classification of confirmed versus
potential critical habitat.

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BAP Critical Habitat Assessment
The BAP states that it has identified critical habitat under five criteria outlined in the IFC PS6 (2012)
and GN6 and quantitative assessment for Tier 1 and 2 of Critical Habitat Criteria 1-3. Critical Habitat
was first identified during the baseline phase of the ESIA study and has been re-evaluated and
further defined in the BAP using the following approach:
• Information about the current status of the critical habitats (i.e. at the species, ecosystem
and landscape scales) was collected;
• The relationship between critical habitat with relevant conservation significant species was
identified;
• Intersects of the ROW with protected areas or high biodiversity areas were reviewed;
• Species and habitats were evaluated and prioritised as “low, medium and high” significance
scale in consideration of a range of factors including conservation status, distribution,
endemism, species/habitats and local conditions.
For critical habitat triggering flora species identified in the ESIA Studies, those that occurred within
the 36 m ROW were identified and included in the critical species list; those that were not observed in
the ROW were removed. For terrestrial fauna species identified as potentially critical habitat triggers
in the ESIA, the re-evaluation considered the potential for those species to use the 36m wide ROW
for reproduction, feeding, nesting or other habitat use was assessed on the basis of field investigation
and where no habitat use was identified then those species were removed from the critical species
list.
This process represents some limitations to the critical habitat determination as it is focussed on the
TANAP impact on species that trigger critical habitat rather than the critical habitat itself. PS6 GN 64
requires that critical habitat should be determined based on the biodiversity attributes particular to
the habitat in question and the ecological processes required to maintain them. It is recognised that
TANAP has applied the critical habitat assessment methodology using the available collected data
from the RoW, and more broadly in certain areas. However, TANAP’s critical habitat assessment was
limited due to the lack of regional species population and habitat data over the whole corridor.
TANAP has considered the broad scale EUNIS habitat scale data in determining critical habitat and
has also consulted with Project stakeholders in the critical habitat assessment methodology.
Where seasonal or other limitations to field investigations meant that the presence or of species or
habitat could not be assessed within the ROW then the BAP applied the precautionary principle and
included these in the critical habitat assessment and made recommendations for further field studies
to verify the assessment. TANAP does require construction contractors to undertake pre-construction
biological surveys of the RoW and uses this data to further verify the assessments.
The BAP provides a tabular summary of the critical habitat assessment outcomes including the criteria
triggers, the outcomes of the quantitative assessment to determine the appropriate tier for Criteria 1-
3 and area of critical habitat within the ROW. However, the BAP does provide limited information on
how the species data has been screened against the quantitative thresholds as described in the GN6
paragraph 69. As described above, there is no discussion or detail of the discrete management units

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for species and habitats that are identified as potentially critical. Quantitative assessments have been
applied by TANAP using the broad EUNIS habitat classifications.
The TANAP BAP includes a revision of the Critical Habitat determination made in the ESIA. The ESIA
assessment of critical habitat was limited to habitats within the LSA due to the limited area of
investigation and the lack of population data, as discussed above. This initial critical habitat
assessment identified that 10.8 % of the TANAP terrestrial LSA was confirmed as triggering critical
habitat and 81% of the LSA being identified as potential critical habitat. For rivers crossed through
the LSA, 41 rivers were confirmed as critical habitat and all the remaining rivers (1170 crossings)
were assessed as being potentially critical habitat. The ESIA identified further studies requiring to be
completed to further define critical habitat and these additional studies were completed during the
BAP surveys completed from August to October of 2014.
The re-assessment of critical habitat in the BAP identified 67 terrestrial and 27 freshwater critical
habitats. The terrestrial critical habitats cover only 0.39% of the 500m LSA corridor assessed in the
ESIA and 5.6% of the ROW (36m). This represents a significant decrease in terrestrial critical habitat
affected by the Project from that identified in the initial ESIA studies following the BAP re-assessment.
However, this reassessment of critical habitat area is based on the presence or absence of critical
habitat triggering species or values within the project’s direct impact area and removes critical habitat
areas where the triggering species or values were found to be undisturbed by direct impacts of the
ROW.
The IESC finds that the TANAP critical habitat assessment is not in full compliance with the IFC PS6
GN and is therefore in partial compliance with the requirements of PR6 to ensure net biodiversity gain
of critical habitat and no net loss of priority biodiversity features.
The BAP states that the impact assessment undertaken in the ESIA confirms a low degree of impact
expected on natural and critical habitat; states that significant permanent and long-term impacts are
not expected, and the defined mitigation measures are sufficient for the recovery of habitats. The
BAP also refers to the ESIA in confirming no long term or permanent significant impact to Species of
Conservation Concern. However, the BAP does recognise the threat of permanent impacts on SCCs
from alien invasive species, including the pathways for introduction of weed species, within the
pipeline ROW and reiterates the importance of the Alien Invasive Species Guidance Document.
Furthermore, the TANAP’s “Erosion, Reinstatement, and Landscaping Plan” and the “Specification for
Reinstatement” includes the range of actions for reinstatement and bio restoration of the project sites
to achieve pre-development biodiversity criteria. The performance of the bio restoration efforts in
achieving the stated biodiversity objectives is proposed to be monitored and reported through the
“Bio-Restoration Monitoring Plan (October, 2016).
The IESC review of the ESIA and BAP has found the impact assessment does recognises the potential
direct impacts to species of conservation concern including those that trigger critical habitat. For
example, high impacts are identified for two areas within the Ardahan and Kutahaya provinces for a
total of 4.8 hectares where SCC species are potentially present within the Project AoI. The mitigation
recommended in the ESIA for identified high impact includes measures to translocate individuals,
which is stated to be a “high risk option”. The mitigation measures also include seed collection from
SCC species for use in conservation projects and additional conservation measured where critically

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endangered species are impacted. The conservation measures include measures to re-introduce
populations in suitable habitats within the species range and includes the option to translocate to
suitable sites outside the RoW.
Section 3.2.1 of the most recent version of the BAP does include discussion on the application of the
mitigation hierarchy for critical habitats. The BAP describes how mitigation measures are applied for
each critical habitat that occurs along the Project and identifies where additional conservation actions
are required to ensure no net loss of priority species. Annex 9 of the BAP includes a range of
measures designed to ensure a net gain in critical habitat that is impacted by the Project. The net
gain measures include:
• Species specific action plans;
• Support for scientific research;
• Reducing grazing pressure on habitats; and
• A range of public awareness raising activities.
However, these net gain actions are not described in a way that demonstrate how a net gain would
be achieved. There is no quantification of the no net loss/ net gain objectives of the BAP to
demonstrate full compliance with PR6.
Neither the ESIA nor the BAP provide sufficient detail of the project related direct, indirect and
residual impacts on populations; species and ecosystems identified in the baseline studies. There is
insufficient assessment of the project impacts on critical habitat other than the direct impacts within
the ROW. The impact assessment on biodiversity values provides insufficient discussion on why
aspects such as habitat fragmentation, fauna avoidance and impacts from increased third party
access are not considered.
The BAP discussion of impacts to habitat includes reference to two other pipeline routes that passed
through some sections of the areas studied. One of these pipeline route corridors had restoration
work completed some years past and the BAP concluded that “there is no damage” evident after the
restoration has been completed. The other had no restoration work completed and damage to
biodiversity remains evident after long years being passed. This does demonstrate that good practice
remediation measures are an important mitigation necessary for biodiversity management. However,
there is no specific study cited or detailed evidence that supports the assertion that restoration work
on the TANAP ROW will result in net biodiversity gains in critical habitat and no net loss of priority
biodiversity features.
The project has not demonstrated full compliance with PS6 GN15 in its assessment of impacts to
critical habitat and has provided insufficient evidence that bio restoration works on the ROW will be
adequate to achieve the biodiversity outcomes required to demonstrate compliance with PR6.
The IESC has found that TANAP has relied heavily on the assumptions that mitigation of temporary
disturbance through bio-restoration and alien species control will be effective in ensuring no residual
impacts to priority biodiversity values and critical habitat. There is little discussion in the ESIA that
supports the assumption that bio-remediation will ensure no permanent or long-term impacts to
priority biodiversity values and critical habitat. The limitations of bio-reclamation are stated in various

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sections of the ESIA that refer to challenges in achieving propagation or translocate of some species,
and the inability to replace tree species over the ROW to ensure the integrity of the pipeline is
maintained (see Terrestrial Flora Baseline Report Section 2).
The effectiveness of the mitigation measures, including bio-restoration and alien species controls,
should be discussed in further detail and, where possible, refer to examples where these mitigation
measure have been effective in ensuring no loss of priority biodiversity values or critical habitat.
However, if relevant and geographic specific examples of successful bio-restoration are not available,
then the assumption that there will be no residual impact to priority features and critical habitat
In consideration of the limitations found with the TANAP critical habitat assessment and management
approach, and recognising the current status of Project construction. The IESC recommends that
TANAP develop and implement an Offset Management Strategy document that supplements the BAP.
The Offset Management Strategy should include:
• Quantification of the residual impacts to Priority Biodiversity Features and Critical Habitats, as
defined in the BAP;
• Identification of specific biodiversity measures in accordance with the mitigation hierarchy, to

achieve No Net Loss/ Net Gain outcomes of the species and habitats of conservation
importance;
• Quantifies No Net Loss/ Net Gains based on the successful implementation of the above
actions over a reasonable timeframe
Ecosystem Services
The ESIA assessed ecosystem services were assessed for TANAP in consideration of information
derived from both social and biological studies. Impacts and risks relating to ecosystem services were
measured through a range of component studies including:
• Employment and livelihoods;
• Land use and agriculture;
• Flora (terrestrial and freshwater);
• Fauna (terrestrial and freshwater)
The ESIA identified potential TANAP effects on ecosystem services and has considered these within
both environmental and social impact assessment and mitigation measures.
5.6.2 Conservation of Biodiversity
Application of the mitigation hierarchy

The TANAP route selection described in the ESIA Chapter 5 describes the process for defining the
TANAP route and included consideration of a range of factors included the presence of protected
areas, sensitive habitats, Scrublands, Meadows-pastures and wetlands. A number of route
alternatives were identified to avoid key biodiversity conservation areas including the Posof Ardahan
Wildlife Development Area, Kakgol-Sahara National Park, Sarikamis Allahaukber Mountains National

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Park, and the Akdagmadeni Forest (Important natural area). The range of constraints presented by
the TANAP project over the complete route presents challenges to avoidance of all priority
biodiversity features. However, ESIA Figures 5.10 and 5.11 demonstrate that route selection has been
successful in minimising impacts to protected areas and priority features.
The final TANAP route impacts are assessed in Annex 2 of the BAP (Rev P3-6) which shows 18
protected areas being intersected by the TANAP RoW. The ESIA baseline studies included detailed
assessment of the protected areas (Chapter 7.3.1.7 and Appendices) and a detailed assessment of
TANAP impacts to each protected area is provided in Chapter 8.2.2. The BAP assessment found all
intersections to be of a low impact level. The disturbance of protected areas from the TANAP RoW is
generally under 1% of the protected land area except for Bataklikduzi, Corakik Lake and Tuzlu lake
wetlands where the RoW disturbance area represents 1.26 %, 2% and 2.96 % of the protected area
respectively. Specific plans have been developed for each impacted protected area in consultation
with the relevant authorities that demonstrate compliance with Article 6 of the EU Habitats Directive.
Implementation of the BAP

The IESC site visit reviewed the implementation of the specific management measures outlined in the
Erosion, Reinstatement and Landscaping Management Plan (MP) for management of topsoil in
identified critical habitat and found that these measures are not realistically achievable in the field.
This MP states that topsoil shall be replaced onto the disturbed area as soon as the pipeline has been
placed into the ground and the surface reinstated. During the site visit it was found that this
commitment is not achievable in the field due to the need to conduct ongoing hydro-testing and
pressure testing activities that may require that the land surface be disturbed again after
reinstatement. Considering this, topsoil stockpiles in these areas may remain in place for up to 18 –
24 months before they are used in rehabilitation. As such, additional measures to ensure the topsoil
and seedbank remains viable should be considered. The delay in restoration is also likely to result in
biodiversity impact durations being extended and would require a re-evaluation of the biodiversity
impact assessment.
The observation of the critical habitat area (Erzurum Wetland) of ROW from the site visit confirms the
IESC’s concerns regarding the reliance on successful bio-restoration to ensure no long term or
permanent impacts to critical habitat. If topsoil management measures prescribed in the site-specific
restoration plans are not being followed, then it would suggest that alternative mitigation measures
or offset measures may be required.
The site visit to the pipeline construction sites noted the lack of implementation of specific measures
to minimise impacts top biodiversity including:
• Disturbance outside of the ROW corridor from vehicle and equipment movements;
• Presence of open trenches for extended periods without measures to prevent animal being
trapped in the excavation or means for trapped animals to egress;
• Lack of covers on open pipelines to prevent animals being accidently trapped during the
construction phase.

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The TANAP BAP implementation will require substantial level of effort and capability for both
implementation of the Erosion, Reinstatement and Landscape Management Plan by the relevant
construction contract teams and the monitoring efforts required for the Bio-Restoration Monitoring
Plan (October, 2016). The IESC has reviewed these plans and has some concern regarding the
resources available to fully implement both plans. For example, it is unclear how TANAP will ensure
the financial resources are available and planned for to ensure that failures in bio restoration
identified from monitoring are addressed up to 10 years following the completion of construction.

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Ref.
6 Biodiversity and Living Natural Resources
6.7 Assessment of Biodiversity and Living PC The BAP reassessment of critical habitat area is based on the The IESC recommends that TANAP quantify
Natural Resources, Baseline Studies presence or absence of critical habitat triggering species or the critical habitat/ priority biodiversity
values within the project’s direct impact area and removes Features to be impacted directly/indirectly by
Assessment process will characterise the critical habitat areas where the triggering species or values were the Project.
baseline conditions to a degree that is found to be undisturbed by direct impacts of the ROW. This
proportional and specific to the anticipated method is inconsistent with PS6 GN64. The results of the quantification of critical
risk and significance of impacts. habitat/ Priority Biodiversity Features should
The baseline assessment will consider: The IESC finds that the TANAP critical habitat assessment is not inform a Biodiversity Offset Strategy.
• loss of habitat, in full compliance with the IFC PS6 GN and is therefore unable
• degradation and fragmentation, to demonstrate compliance with the requirements of PR6 to
• invasive alien species, ensure net biodiversity gain of critical habitat and no net loss of
• overexploitation, priority biodiversity features.
• migratory corridors,
• hydrological changes,
• nutrient loading
• pollution,
• impacts relevant to climate
change and adaptation.
6.8 Identification of project related PC Impact assessment methodology is applied in accordance with  As per 6.7 above
opportunities, risks and impacts on accepted standards and is effective in identification of mitigation
biodiversity. Characterise impacts based on requirements.
likelihood, significance and severity and The ESIA baseline data was used to define the sensitivity of the
reflect concerns of communities and other various VEC’s to identify likely impacts associated with the
stakeholders. project and to define the pre- project condition that will be used
Consideration of direct, indirect and as a benchmark to detect changes during monitoring. VECs
cumulative impacts were assigned sensitivity levels based on a range of factors
including current quality of the component and susceptibility to
environmental changes. Those impact factors most relevant to
biodiversity impacts were identified as:
• Reduction in topsoil quality/availability
• Site restoration

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• Sediment suspension
• Removal of natural vegetation
• Introduction of alien species
The impact assessment methodology for biodiversity assigned
impact factor intensity based on assumed standard mitigations
being applied in accordance with good industry practice, so
impact factors are measured only after mitigation.
Neither the ESIA nor the BAP provide sufficient detail of the
project related direct, indirect and residual impacts on
populations; species and ecosystems identified in the baseline
studies. There is insufficient assessment of the project impacts
on critical habitat other than the direct impacts within the ROW .
The impact assessment on biodiversity values provides
insufficient discussion on why aspects such as habitat
fragmentation, fauna avoidance and impacts from increased
third party access are not considered.
6.9 Assessment to consider the use of FC The ESIA assessed ecosystem services were assessed for TANAP  No action required
ecosystems by potentially affected in consideration of information derived from both social and
communities and/or indigenous peoples. biological studies. Impacts and risks relating to ecosystem
Avoid impacts to those ecosystems used. services were measured through a range of component studies
Where avoidance in not possible – including:
minimise or implement appropriate • Employment and livelihoods;
mitigation measures to maintain overall • Land use and agriculture;
functionality. • Flora (terrestrial and freshwater);
• Fauna (terrestrial and freshwater)
The ESIA identified potential TANAP effects on ecosystem
services and has considered these within both environmental
and social impact assessment and mitigation measures.
6.10 For projects that could potentially have N/A Utilisation of living natural resources is not an aspect of this 
such impacts on Indigenous Peoples and Project
local communities, the client will provide
opportunities for fair and equitable sharing
of the benefits derived from the utilisation
of
living natural resources in accordance with:

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Ref.
(i) the requirements for addressing
economic displacement issues in
PR 5;
(ii) the specific requirements relating
to managing potential issues and
impacts on Indigenous Peoples in
PR 7; and
(iii) the stakeholder engagement
requirements provided in PR 10.
6.11 Conservation of Biodiversity PC A detailed Biodiversity Action Plan (BAP) has been developed by It is recommended that TANAP identifies the
TANAP contractor Cinar for implementation on the Project. The specific biodiversity management actions in
Project related impacts to biodiversity will most recent revision to this document occurred in October 2016 accordance with the mitigation hierarchy, to
be managed in accordance with the and included the addition of a Biorestoration Monitoring Plan as achieve No Net Loss/ Net Gain outcomes of
mitigation hierarchy and GIP. an Annex to the document. the species and habitats of conservation
Adopt precautionary approach and apply significance.
adaptive management practices The BAP has not adequately identified and addressed critical
habitat that is likely to be disturbed by the Project. The BAP The biodiversity management actions should
does not discuss how the species data has been screened inform a Biodiversity Offset Strategy.
against the quantitative thresholds as described in the GN6
paragraph 69. It appears that TANAP has applied a scale of
analysis to assess criticality of species and habitats of
conservation significance using project disturbance boundaries,
the ROW, and has not applied discrete management units in
accordance with the requirement of GN6 paragraph 64 and 65.
It is therefore very likely that critical habitat exists within the
ROW that has not been identified as such due to the absence of
critical habitat triggering species.
Specific management measures outlined in the Erosion,

Reinstatement and Landscaping Management Plan (MP) for
management of topsoil in identified critical habitat are not
realistically achievable in the field, as evidenced during the field
visit. The impact assessment on biodiversity values provides
insufficient discussion on why aspects such as habitat
fragmentation, fauna avoidance and impacts from increased

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Ref.
third party access are not considered.
Residual impacts to biodiversity will occur of bio restoration

works are not 100% effective. This has not been effectively
considered.
6.12 Maintain the viability of priority biodiversity PC TANAP has stated that no significant long term or permanent See 6.7 and 6.11 actions
6.13 features: impacts to priority biodiversity features due to effective
Threatened habitats; vulnerable species; mitigation using bio-restoration and alien species control.
significant biodiversity features; and, The IESC has found that TANAP has relied heavily on the
ecological structure and functions needed assumptions that mitigation of temporary disturbance through
to maintain the viability of priority bio-restoration and alien species control will be effective in
biodiversity features. ensuring no residual impacts to priority biodiversity values and
critical habitat. The limitation of bio-restoration is stated in
Where significant, adverse and irreversible various sections of the ESIA that refer to challenges in achieving
impacts to priority biodiversity features are propagation or translocate of some species, and the inability to
identified, activities should not be replace tree species over the ROW to ensure the integrity of the
implemented unless: there are no feasible pipeline is maintained (see Terrestrial Flora Baseline Report
alternatives; overall benefits outweigh Section 2). The latest version of the BAP (Rev P3-10) provides
project impacts; stakeholders are prescriptive detail of the post construction bio-restoration
consulted; permits are granted under monitoring requirements to ensure that residual impacts are
applicable laws; appropriate mitigation avoided or additional measures are implemented to offset these
measures are put in place. impacts .
The BAP has been subject to a number of revisions, the latest
being the version Rev-P3-10 issued in May 2017. The BAP
studies were required to address data gaps identified in the
ESIA studies, as described below, accommodate route changes
that had occurred and to revise the critical habitat assessment
completed for the ESIA. The BAP ecological surveys were
targeted towards the presence of ecological sensitive species
and habitats along the RoW, between 36m and 70 m in width.
The effectiveness of the mitigation measures, including bio-

restoration and alien species controls, should be discussed in
further detail and, where possible, refer to examples where
these mitigation measure have been effective in ensuring no

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loss of priority biodiversity values or critical habitat. However, if
relevant and geographic specific examples of successful bio-
restoration are not available, then the assumption that there will
be no residual impact to priority features and critical habitat
6.14, Impacts to critical habitat to be identified, PC See 6.12 and 6.13 above Develop and implement a Biodiversity Offset
6.15 including (i) highly threated or unique Strategy document that:
6.16 ecosystems; (ii) habitats of significant  Quantifies residual impacts to Priority
6.17 importance to engaged or critically Biodiversity Features and Critical Habitats, as
6.18 endangered species; (iii) habitats of defined in the BAP [Rev P3 – 10]
significant importance to endemic or  Identifies specific biodiversity management
geographically restricted species; (iv) areas actions, in accordance with the mitigation
associated with key evolutionary processes; hierarchy, to achieve No Net Loss / Net Gain
or (v) ecological functions that are vital to outcomes of these species and habitats of
maintaining the viability of these conservation importance
biodiversity features.  Quantifies No Net Loss / Net Gains based on
the successful implementation of the above
Where impacts to critical habitat have been actions over a reasonable timeframe
identified the client will retain experienced
external experts to conduct the assessment
of the potential adverse impacts on this
critical habitat.
Critical habitat must not be impacted to the

extent that ecological integrity is
compromised.
Activities in areas of critical habitat are not
to be implemented unless:
No viable alternative; stakeholders
consulted; project is permitted under
applicable law; no measurable adverse
impact on those biodiversity features that
trigger critical habitat; project is designed
to deliver net gains for impacted critical
habitat; no anticipated net reduction in

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Ref.
population of any endangered or critically
endangered species; long term biodiversity
monitoring and evaluation programme to
assess status of critical habitat is
implemented.
Where critical habitat requirements can be

met - mitigations strategy will be defined in
a BMP or BAP
Where offsets are proposed for priority

biodiversity features of critical habitat, the
Client must demonstrate through an
assessment that the significant residual
impacts on biodiversity will be adequately
mitigated and retain external expertise with
knowledge of offset design and
implementation.
6.19 Impacts to protected areas to be identified FC The TANAP route selection described in the ESIA Chapter 5
6.20 and mitigation hierarchy applied describes the process for defining the TANAP route and included
consideration of a range of factors included the presence of
Where impacts to priority biodiversity protected areas, sensitive habitats, Scrublands, Meadows-
features and /or critical habitat occur within pastures, and wetlands. A number of route alternatives were
protected areas, then these impacts will be identified to avoid key biodiversity conservation areas including
avoided and the client will: the Posof Ardahan Wildlife Development Area, Kakgol-Sahara
Show that the development is legally National Park, Sarikamis Allahaukber Mountains National Park,
permitted; act in a manner consistent with and the Akdagmadeni Forest (Important natural area). The
recognised management plans; consult range of constraints presented by the TANAP project over the
protected area managers; implement complete route presents challenges to avoidance of all priority
additional programmes to promote and biodiversity features. However, ESIA Figures 5.10 and 5.11
enhance the conservation objectives of the demonstrate that route selection has been successful in
project area. minimising impacts to protected areas and priority features.
6.21 Invasive Alien Species: avoid and FC The Alien Invasive Species Guidance Document provides a No Action Required
proactively prevent accidental or deliberate comprehensive process for mitigation of potential invasive
introduction of alien species that could species and this mitigation is critical in ensuring successful

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Ref.
have significant adverse impacts in mitigation of identified biodiversity impacts including the
biodiversity successful implementation of the Bio-restoration plan.
6.22 Sustainable Management of Living Natural N/A Not applicable to TANAP
- Resources – applicable for projects which
6.37 involve the primary production of living
natural resources or where such resources
are central to the project’s core function

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5.7 PERFORMANCE REQUIREMENT 7: INDIGENOUS PEOPLE
This Performance Requirement is not applicable to the TANAP Project.

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5.8 PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE
As defined by EBRD in PR 8, cultural heritage includes both tangible (physical) and intangible heritage
recognized at local, regional, national or international levels. The TANAP ESIA assessed cultural and
archaeological sites and intangible heritage along the pipeline route, including incorporation of
cultural heritage criteria in the route selection process.
5.8.1 Assessment and Management of Impacts on Cultural Heritage

The ESIA includes assessment of cultural and archaeological sites, and intangible cultural heritage.
Mitigation actions for the 161 sites identified included: Route change/Area change; Archaeological
Monitoring; Salvage excavation and test pits; or, No action.
Avoidance of cultural heritage (CH) sites has been achieved to date as far as practicable using the
corridor assessment process that included cultural heritage selection criteria.
A CHMP has been developed (TNP-PLN-ENV-GEN-006), which specifies actions required to identify
and mitigate potential impacts to intangible CH, through engagement and liaison by Contractors with
local authorities.
The CHMP further identifies identification of tangible heritage resources and definition of mitigation
measures at pre-construction phase, informed by baseline and survey results. At those sites identified
as unavoidable, engagement with statutory authorities was reported, as required in the CHMP. Of 161
sites identified during surveys, 55 were already registered with authorities, while 106 newly
discovered sites were revisited with the Ministry, and as a result, 20% of these sites were registered
as Protection Sites by the Ministry of Culture and Tourism.
Day to day management is the responsibility of the site-based Cultural Heritage Officer, formerly an
EPCM role now under TANAP (see also comments in PR1 on organisational implementation of ESMS).
Monitoring is required by the contractors’ archaeologist during ground disturbance, under a SOW that
complies with requirements of a Protocol between TANAP and the Ministry of Culture and Tourism. A
chance find process is in place (defined in Annex A of TNP-PCD-ENV-GEN-006, and replicated by each
of the CCs) to address avoidance of significant finds during construction and land preparation. Further
studies have been carried out on those sites that were unavoidable during routing studies, followed
by either permission to proceed by local authority, or, preferentially, to implement a route change.
Eleven sites were identified as unavoidable at pre-construction phase, of which five route changes
were implemented during construction. A contracted third party, operating under supervision of the
Ministry, carries out all test pits and salvage excavations.
Sites that were inspected by the audit team had completed cultural heritage site management.
Additional evidence (provided in meetings on 12 May 2017) requested by the IESC on chance finds
records, indicated that a total of 49 chance finds have occurred during construction, 46 of which have
been closed out, and actions for 3 remain open. Details of the corrective actions taken regarding
these chance finds have not been sighted by the IESC.

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5.8.2 Consultation
The CHMP identifies the Museum Directorate of the Ministry of Culture and Tourism as the
responsible agency for advice and direction on archaeological finds, under direction and decisions
from the Regional Board Directorate of Protection of Cultural Heritage.
TANAP and CCs stated and provided written evidence strong engagement with regulatory bodies on
cultural heritage, including assessment with museum specialists being undertaken at critical sites to
make a determination on any excavation, salvage or other mitigation requirements. The CC’s
archaeologist SOW includes consultation with the relevant state authorities on behalf of TANAP and
site-based CHOs provide additional support.
Stakeholder engagement with individuals or groups with specialist interests by the Project has been
limited; at the ESIA consultation phase, specialist NGOs were invited but did not participate (ESIA
Appendix 3.2d). Consultation with affected communities is carried out for intangible cultural heritage
and registered tangible cultural heritage elements. However, chance finds are managed differently
due to security reasons (due to the risk of illegal excavations).
TANAP is encouraged to continue to engage with CH specialist stakeholders for the duration of
construction in particular, in line with GIP. Museum specialists are the parties responsible for
informing stakeholders and making determinations on behalf of the Ministry of Culture, while TANAP
follows the expert advice in ensuring implementation requirements are followed by the CC.

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8 Cultural Heritage
8.1 Assessment and Management of FC A total of 161 sites were identified in this process, and mitigation actions 
Impacts on Cultural Heritage defined. Eleven sites were identified as unavoidable at preconstruction
phase. A Cultural Heritage Management Plan (CHMP) is in place, owned
by TANAP and requirements of which reflected in construction contractor
MPs. This includes a Chance Find Procedure. The CCs’ Archaeologist, who
liaises with the TANAP Cultural Heritage Officer and the Museum
Directorate, undertakes monitoring of ground clearance work. Third party
monitoring of implementation of the CHMP is also undertaken by CINAR. It
is noted that the former EPCM Chance Find requirements are still in place,
and are expected to be deleted from the TANAP ESMS by 31 January 2017
(see also Section 5.1 on PR1).
During the construction phase to date, five route changes have been
implemented at the eleven unavoidable sites, following engagement and
mitigation actions implemented under the direction of the with the
relevant authorities (Museum Directorate of the Ministry of Culture and
Tourism).
8.2 Consultation with affected FC Ongoing and close engagement has been undertaken with the Museum
communities and other stakeholders Directorate of the Ministry of Culture and Tourism, as the responsible
agency for advice and direction on archaeological finds and appears to
have been effective in managing and mitigating potential impacts to
tangible heritage in line with the mitigation hierarchy approach. However,
consultation with affected communities and other stakeholders has been
largely limited. Invitations to specialist interest groups at the ESIA
consultation phase has been recorded. IESC notes that consultation with
affected communities is carried out for intangible cultural heritage and
registered tangible cultural heritage elements. However, the chance finds
are managed differently due to security reasons (the risk of illegal
excavations).
8.3 Project use of Cultural Heritage FC Not applicable

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5.9 PERFORMANCE REQUIREMENT 10: INFORMATION DISCLOSURE AND
STAKEHOLDER ENGAGEMENT
Policies and standards are in place for the Project regarding Stakeholder engagement,
communications and social impact management and requirements. The Project Stakeholder
engagement approach was firstly outlined in the ESIA (Chapter 6), outlining engagement function
and approach across project phases and the Project’s grievance mechanism. Stakeholder
engagement past activities, current program and monitoring activities were also detailed, in line with
GIP. The total number of consultation meetings during the construction phase (as at November
2016) were 1,234, including meetings with women, safety awareness for children, and with local
authorities, across all Lots and stations. Comments raised during project disclosure were reflected
and analysed and incorporated into Project SMPs including the Stakeholder Engagement Plan (SEP)
and Resettlement Action Plan (RAP).
5.9.1 Stakeholder Engagement Plan

Policies and standards are in place for the Project regarding Stakeholder engagement,
communications and social impact management and requirements.
The SEP (Aug 2013) was prepared to meet international standards and was finalised reflecting public
participation and disclosure requirements. The SEP is aligned with an online Stakeholder Information
System for tracking ongoing engagement and issues of stakeholder interest.
Engagement activities during ESIA development and disclosure in line with GIP (including village-level
meetings, gender-segregated meetings/focus groups) and included stakeholder analysis of engaged
organisations (e.g. ERM-REP-ENV-GEN-003 Rev.P2-0, 17 January 2014). Engagement was
appropriate to the nature and the scale of the Project, at the pre-construction phase covering:
• 7 province and 56 District PPMs with the participation of local governors, local NGOs, media
and community representatives;
• 513 Village Questionnaires and 2,253 Household Questionnaires;
• 307 Focus Group Meetings with youth, women and fishermen;
• 151 in-depth interviews with Local Authorities, Sub-governors & Mayors;
• 83 Disclosure village meetings held; and
• 572 villages invited the village disclosure meetings.
Ongoing stakeholder engagement is undertaken by CCs with support of TANAP social specialists. The
last Lots/areas for construction phase engagement are Lot 4 and AGIs. A new SEP was developed
(2016 TNP-PLN-SOC-GEN-001-Rev3-2, 30/01/2017)), which provides for updated roles and
responsibilities.
Social induction training is provided to all workers thereby supporting culturally appropriate
behaviours by all workers on the Project, in line with GIP.

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The Social and Environmental Investment Program (SEIP) has been developed and approved by the
Board of Directors. The SEIP is TANAP’s CSR Program and intends to support wider project-affected
areas; it is not a fund for mitigating specific project impacts.
5.9.2 Operational Grievance Mechanism

The grievance mechanism is operational and is aligned with the CCs. All grievances are logged in an
online grievance recording and tracking system. CCs have access to and management of the same
system for Lots within their areas of responsibility only; TANAP has control of the system overall.
A total of 790 complaints have been received from 1/1/14 to 17/11/16 with 85% closed over an
average of 15d response time (30d is the time limit in the procedure for closure of complaints). The
most common grievances since project commencement relate to Damage to property/land; Land
acquisition and compensation process; damage to irrigation infrastructure; damage to roads; and
outstanding subcontractor payments (as per: Complaints issues – Top 20, 17.Nov. 2016). One quarter
of complaints related to damage to land.
An Appeals Committee has been established to provide third party review of unresolved grievances
between TANAP and the Complainant. Documentation on this committee has been developed and is
to be provided to the IESC.
Legal redress is possible regardless of establishment of the Appeals Committee with complainants
able to take matters to court independently. This has not occurred in the Project to date; a third-
party valuation had been sought to resolve land valuation, and a policy of resolution by mutual
agreement is in place by the project.
5.9.3 Information Disclosure

The ESIA documents were disclosed on the TANAP website in English and Turkish on 22 June 2015;
this included the ESIA, a Guide to Land Acquisition and Compensation, a RAP and a Stakeholder
Engagement Plan based on international good practices and standards, including the 2012 IFC
Performance Standards.
The current SEP specifies periodic review of the document in line with PR 10 requirements for
ongoing provision of information to stakeholders appropriate to the nature of the Project and its
adverse impacts. Material changes to the project included the revised approach to land acquisition
and resettlement, as documented in the AGIs and Pipeline RAPs. PR 10 requires at least annual
reporting to stakeholders for Category A projects; commitment on this aspect is included in the SEP.
The modality of disclosure of Project documents was described by TANAP. For RAP documentation,
the disclosure process was addressed adequately through provision of written summary information
in the local language, available to public disclosure meetings, which subsequently informed the final
RAPs prior to their disclosure. Additional engagement planning and disclosure material is required of
TANAP on the next phase of RAP activity (i.e. in identifying and appropriately compensating new
PAPs) and in the development and disclosure of the BAP

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PR
Ref.
10 Information Disclosure and Stakeholder Engagement
10.1 Stakeholder Engagement Plan FC A SEP was published (18 August 2013) on the TANAP website in 
Turkish and English, specifying objectives, legal context and project
standards, previous engagement, stakeholder identification and the
SE program. Roles and responsibilities, Grievance management
processes and monitoring, evaluation and reporting were all included,
in line with GIP and appropriate to the nature, scale and risks posed
by the Project. The SEP specified engagement approaches with
different stakeholder groups (e.g. community leaders, vulnerable
groups).
This SEP has been recently updated on 30/01/2017 (TNP-PLN-SOC-

GEN-001-Rev3-2) and includes additional guidance on SE
implementation for the construction phase (Annex 1_Stakeholder
Engagement Implementation Guidelines for Construction) to assist
CCs in achieving consistent, responsive and effective engagement
with the Project.
10.2 Operational Grievance Mechanism PC The Project’s grievance mechanism is in place to receive and respond Disclosure and actions to address common
to stakeholders’ concerns and grievances about the Project. The total grievances:
grievances received across all Lots as at November 2016 were 746, of (a) Conduct disclosure to communities of
which 88% were closed, and 87 (12%) were open. The main summary grievance data and measures
grievances received since project commencement relate to damage to taken by TANAP and CCs to address the
property and land, and the land acquisition process. A quarter of all common causes of grievances;
complaints registered related to damage to land. (b) include a specific section regarding
resettlement related grievances to be
TANAP has committed to providing grievance feedback and data to disclosed in summary form to relevant
communities during regular consultation meetings. An additional resettlement-affected stakeholders,
standing agenda item is to be added to consultation meetings, for with measures taken by TANAP to
follow up as appropriate; this will be reflected in the next SEP address the common causes of these
revision. grievances.
The grievance process provides for legal redress, and an Appeals

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Committee has additionally been established to provide third party
review of grievances between TANAP and complainants, to provide an
additional level of independent review of any unresolved complaints
or grievances.
10.3 Information Disclosure PC ESIA documents were disclosed on the TANAP website, with key Provide evidence to EBRD of the modality of
documents in English and Turkish. Supplementary reports prepared public disclosure of existing key project ESMPs,
included the RAP for Above-Ground Installations (AGIs) and the RAP including the BAP and RAP documents.
for the Pipeline, prepared and disclosed due to material changes in
the Project (i.e. approach to resettlement). The IESC recognizes that
disclosure has been achieved online, and the modality of disclosure
according to communities in a form and format readily understood by
stakeholders. The RAP for AGIs was finalised with inputs from priority
settlements; the revised Entitlements Matrix was disclosed in October
2016 and during this phase, informative leaflets were delivered to
meeting attendees, as well as to Muhtars (for non-attendees). Details
of these meetings were then incorporated into the RAP for AGIs. The
final Plan was finalized and disclosed by TANAP.
A RAP specific engagement plan (planned to be included as Annex 2
to existing SEP) is required as disclosure of the RAP Fund brochure is
critical in ensuring that all PAPs are identified as compensated as is
required.

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6. COMPLIANCE AGAINST TURKISH ENVIRONMENTAL,
HEALTH, SAFETY, AND SOCIAL LAWS, REGULATIONS,
AND PERMITS
A key objective of the TANAP ESIA is to ensure that applicable Turkish legal requirements and
expectations are addressed. Chapter 4 of the ESIA provides an overview of the agreements,
legislation, standards and guidelines, which are applicable to the TANAP Project including the
applicable national legislation, applicable requirements of international conventions ratified by the
national government, international petroleum industry standards and TANAP’s Health & Safety,
Environment and Social Policy. Chapter 3 of the ESIA describes the required EIA process within
Turkey which is also summarised below in Figure 6.1.
6.1 HOST GOVERNMENT AGREEMENTS

The following Host Government Agreements and Inter-Government Agreements have been signed by
TANAP in order to meet legal compliance with Turkish requirements and set the basis for the Projects
implementation.
“Memorandum of Understanding between the Government of the Republic of Turkey and the
Government of the Republic of Azerbaijan Concerning the Development of a Standalone Pipeline for
the Transportation of The Natural Gas Originating and Transiting from the Republic of Azerbaijan
across the Territory of the Republic of Turkey”, was signed on 24 December 2011 in Ankara, which
was approved by Law no 6342 dated 29 June 2012 and was published in the Official Gazette on 12
July 2012. Following approval by Council of Ministers, the Agreement was published in the Official
Gazette on 11 October 2012 and entered into force. Within the framework of this Memorandum of
Understanding, Trans Anatolian Gas Pipeline Company B.V was established.”
“The Host Agreement Between the Government of the Republic of Turkey and the Government of the
Republic of Azerbaijan Concerning the Trans-Anatolian Natural Gas Pipeline System", and its
attachment, "The Host Government Agreement (HGA) between the Government of the Republic of
Turkey and The Trans Anatolian Gas Pipeline Company B.V. Concerning Trans-Anatolian Natural Gas
Pipeline System", were signed on 26 June 2012 in Istanbul. These Agreements were approved by Law
no 6375 dated 02 January 2013, which was published in the Official Gazette on 17 January 2013.
Following approval by Council of Ministers, the Agreements were published in the Official Gazette on
19 March 2013 and entered into force.”
The Host Government Agreement requires Project Environmental and Social Standards complying
with National Laws and also taking due account of international standards and practices generally
prevailing in the Natural Gas pipeline industry, including relevant Performance Standards of the
International Finance Corporation.
6.2 EIA PROCESS IN TURKEY

The Turkish legal framework for environmental protection was developed in line with national and
international initiatives and standards, and some of them have been revised recently to be
harmonized with the EU Directives in the scope of pre-accession efforts of Turkey to the EU. The

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main legal basis for TANAP under Turkish environmental legislation is the Environment Law no. 2872,
which was published in the Official Gazette no. 18132 dated 11.08.1983 and amended by Law no.
5491 dated 26.04.2006. The objective of the Environment Law is to protect the environment in
accordance with the sustainable development principles.
The basic principles of EIA process applied in Turkey are defined by the Regulation on Environmental
Impact Assessment. As per the Turkish Regulation on EIA, whether a project requires an EIA study or
not is determined in relation to the scope and capacity of the project. The TANAP Project was
determined to require an EIA under Turkish legislation and was implemented following this regulation
appropriately. Legal approval through the MoEU for the ESIA Report of the Project was received on
24 July 2014.
The IESC team observes that the Project appears to be operated in full compliance with Turkish
legislation based upon the site visit and a review of provided documentation.

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Figure 6.1 Turkish EIA Process

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7. COMPLIANCE AGAINST OTHER APPLICABLE
STANDARDS / LAWS / CONVENTIONS
Chapter 4 of the ESIA discusses the legal, political and institutional framework under which the
Project is being implemented. This Chapter identifies the following major Standards / Laws /
Directives as being applicable to the Project:
• Equator Principles and IFC Standards and Guidelines;
• IFC Performance Standards (2012);
• IFC EHS Guidelines;
• World Health Organisation (WHO) Standards;
• Various International Conventions (refer to Section 3);
• EU EIA Directive - 85/337/EEC Council Directive on the assessment of the effects of certain
public and private projects on the environment (EIA Directive). The EIA Directive of 1985
has been amended three times, in 1997, in 2003 and in 2009 and is now codified by Directive
2011/92/EU of 13 December 2011.
• 2009/147/EEC The Birds Directive; and
• 92/43/EEC Council Directive on the conservation of natural habitats and of wild fauna and
flora (the Habitats Directive).
7.1 EU DIRECTIVES
Chapter 4 of the ESIA lists a raft of EU legislation as having been considered and applied during
Project scoping and ESIA development.
7.2 INTERNATIONAL LAWS / CONVENTIONS

Turkey is signatory to a range of applicable international treaties and conventions, as discussed in
Chapter 4 of the ESIA. The requirements of these laws and treaties were observed to be considered
during the ESIA process.
7.3 IFC EHS GUIDELINES

A high-level compliance assessment against the IFC EHS General Guidelines is included as Appendix B
to this ESDD. The IESC notes no particular issues of concern in this assessment.
7.4 TANAP PROJECT HSES STANDARDS

TANAP Project Standards have been defined in Chapter 4 of the ESIA, considering the requirements
of Turkish legislation, IFC Guidelines and EU Directives, applying the most stringent criteria from each
source as the adopted Project Standard.
The Project Standards are captured within TANAPs and the CCs respective ESMS and ESMPs and
compliance against them regularly monitored and assessed. Evidence of this was reviewed and
agreed to be of a satisfactory nature by the IESC team.

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8. HIGH LEVEL COMPLIANCE ASSESSMENT OF
ASSOCIATED INFRASTRUCTURE
The TANAP Project associated facilities include the SCPx; the SD2 Project and the TAP Project. Separate ESIA
reports were completed for these projects including three ESIA documents for the TAP Project: TAP Albania, TAP
Greece and TAP Italy. These associated facilities have been subject to a high-level review by the IC against
EBRD PRs. As the scope of the IC’s review of TANAP’s associated facilities called for a high-level assessment,
this section should be read within the following context and is subject to several limitations, as follows:
• Findings are based on a sample of the publicly available ESIA documentation for the
associated facilities. Whilst the IC has made all efforts to establish compliance, it is
recommended that further detailed assessment, specifically on-site verification, be conducted.
• Due to the limited scope of the high-level review, the findings produced are necessarily
general. The IC has not provided a definitive opinion on compliance, rather findings are
written as observations with the intent that further detailed review be undertaken to establish
compliance.
• The TAP ESIAs (Greece, Albania, and Italy) were all conducted by ERM, utilising a common
methodology and approach. The findings of the high-level review for the TAP ESIAs are
therefore highly consistent with each other with respect to compliance and gaps.
• Sustainability is contracted to conduct bi-annual ESDD review and monitoring of the SD2
Project, and therefore is able to present a high-level review of this associated facility with a
far greater level of detail and confidence than the other facilities assessed. Findings for SD2
are taken directly from the most recent ESDD conducted in July 2016.
The scope of the review includes the assessment of each project’s ESIA report, namely:
• South Caucasus Pipeline Expansion Project, Azerbaijan ESIA, June 2013.
• ESIA for the Shah Deniz 2 Project, November 2013.
• ESIA for Greece, Trans Adriatic Pipeline, June 2013.
• ESIA for Italy, Trans Adriatic Pipeline, September 2013.
• ESIA for Albania, Trans-Adriatic Pipeline, January 2013.
Findings are derived from a review of the following chapters of each ESIA report:
• Table of Contents;
• Executive summary; and
• Methodology.
The review found all the associated infrastructure ESIA reports to be completed in general alignment with the
requirements of the EBRD. The findings of the high-level desktop review of the associated facilities is provided
below.

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Table 8-1 High Level Compliance Evaluation – Associated Infrastructure
TAP
Performance TAP
SCPx SD2 TAP Albania Greec
Requirement Italy
e
PR 1. Assessment and Management of Environmental and Social Impacts and Issues
Environmental and An ESIA and ESMS have been prepared The environmental and social impacts High level review indicates that all See See
Social Assessment, for the SCPx by a third party. ESIA have been assessed through a systematic major components of an international TAP TAP
Environmental and appears comprehensive, having been process applied for all Project standard ESIA are present. ESIA was Albania Albania
Social Management produced in line with the requirements components as identified through the conducted by relevant local and
Systems, of the SCP Host Government Agreement ESIA scoping and through engagement international third parties, in
Environmental and (aligned with International Standards). with key Government stakeholders in consultation with local authorities and
Social Policy10, Several activities in the ESIA were Azerbaijan. appropriate engagement with
Environmental and deemed yet to be finalised, including: stakeholders.
Social Management Waste Disposal; sourcing of aggregates This is the latest assessment for the SD
Plan, Organisational and other construction materials; river Project that was initially subject to ESIA The ESMS framework is clearly
Capacity and crossing methodologies; temporary for Stage 1 in 2002. Baseline presented in the ESIA, as is the
Commitment, Supply access roads to the ROW. Documentary environmental and social data are framework for each ESMP (the
Chain Management, evidence as to progress / resolution of comprehensive, being developed from proposed contents for each ESMP is
Project Monitoring and these issues is required. There is a monitoring programmes refined over a summarised in Section 9).
Reporting11 comprehensive Guide to Land 10-year period. The impact assessment
Acquisition and Compensation that is methodology is sound and consistent with HSE policy framework is summarised,
stated to form the basis for the Land GIP. including basic objectives and content.
Acquisition and Compensation Physical policy is not provided in the
Framework. The IC notes that the Project has various ESIA.
management plans (MPs) in place for its
The emphasis of the ESIA is on the existing SD operations, and that these Process for identification of risks and
construction and less so on the plans include measurable targets and impacts appears robust, and
operational and decommissioning phase. indicators and assign clear roles and consistent with the principle of GIP.
responsibilities for time-bound Environmental and social baseline
An overarching Environmental and Social implementation. The social impact appears sufficient in all areas. The
10 Where the project represents a substantial extension to the client activities, confirm that Policy and supporting management systems and plans are appropriate for the new
activities.
11 At appraisal stage, there will be limited information. Compliance assessment should address specific plans for monitoring and reporting (against for example ESAP
requirements) and also consider whether there is evidence of weak monitoring/reporting by client on other relevant projects - which may reduce confidence in future
performance.

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Policy is provided, stipulating management planning for the Project risks and impacts identification
environmental and social objectives and relies on both SD2 process considers the emissions of
principles that guide the Project. The construction/contractor management greenhouse gases, relevant risks
Policy is broadly aligned with the key planning and BP’s Regional Community associated with a changing climate,
principles of the EBRD PRs. and External Affairs team who implement and potential trans-boundary and
on-going consultation with potentially cumulative effects. Environmental and
Management programs have been affected communities in the vicinity of the social risks and impacts are suitably
developed for the construction of the Sangachal Terminal. identified within the Project area of
Project (i.e. not for the operational . influence.
phase of the Project). The management
programs sufficiently describe mitigation The ESMS framework is clearly
and performance improvement presented in the ESIA, as is the
measures and actions that address the framework for each ESMP (the
identified environmental and social risks. proposed contents for each ESMP are
It is stated that operational phase summarised in Section 9). Review of
management plans will be based on completed ESMPs is required to assess
those developed for the construction adequacy.
phase and developed prior to operations
commencing. Environmental and social
Roles, responsibilities and authorities are organisational structure and
stipulated for the implementation of the management are defined in Section 9
construction phase ESMS. Clear lines of ESMP. Roles and responsibilities are
responsibilities are defined, including clearly outlined in Section 9 ESMP,
management representatives. Roles and including that of contractors with
responsibilities are also defined for regard to environmental and social
contractors. management.
Chapter 13: Management and Environmental, social, and cultural

Monitoring adequately describes monitoring procedures are proposed
monitoring and review of the in Section 9 ESMP, including for pre-
effectiveness of the management construction, construction, and
program, including legal compliance and operational phase monitoring.
contractual obligations.
PR 2. Labour and Working Conditions
Human Resource ESIA addresses the requirements for No substantial deficiencies were identified ESIA sufficiently addresses the

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Policies and Working working conditions and management of as a part of this review against labour requirements for working conditions
Relationships, worker relationships in the ESMMS and working conditions criteria. The SD2 and management of worker
Child and Forced Section 16: Local Recruitment and construction project had maintained an relationships in Section 9 ESMP,
Labour, Training Plan which details the measures excellent safety record for the period including outlined the proposed
Non-Discrimination and in place for recruitment and training from commencement of construction to content of the Workers MP. An
Equal Opportunity, management in line with PS2. Further the site visit in May 2016. The Project overview is provided in the Workers
Workers Organizations, verification through review and sighting had amassed a total of 20.5 million man- MP on the measures in place for
Wages, benefits, and of Labour, Health and Safety hours, including both BP direct hire and recruitment and training management
conditions of work and Management Plans, Programs, and HR contractors, and has achieved a very low in line with PR2 (including legal
accommodation, Policies documentation is required. accident frequency rate when compared framework, worker health and safety,
Retrenchment12, ESIA addresses the requirements for to relevant industry benchmarks. contractor management, worker
Grievance Mechanism, workers engaged by third parties in the grievance mechanism, and
Non-Employee Workers, ESMMS Section 16: Local Requirement At the time of the site visit there were a monitoring).
Supply Chain, and Training Plan which details the total of 18,976 contracted workers. The
Security Personnel measures in place for contractor's employment numbers had peaked for the Further verification through review
Requirements including hiring, training, etc., in line construction phase and de-manning had and sighting of the completed
with PS2. This review is unable to verify occurred at Project sites in response to Workers MP, and associated
whether monitoring is taking place, completed work packages. The changes procedures, as well as HR Policies
although it is stipulated in Section 16. to Project labour requirements have been documentation is required to conduct
implemented through a de-manning a full review of adequacy.
strategy aimed at minimising the impacts
of reduced employment as the Project Child labour, worker rights and forced
moves towards completion. A Labour labour are assessed in Section 8
Management Committee has been put in Assessment of Impacts and Mitigation
place to discuss and resolve key HR/IR Measures. In addition, these issues
issues relevant to contracts and BP are considered in the Human Rights
personnel working on the SD2 Impact Assessment. Section 9 ESMP
construction, including grievances, and indicates that provisions for protecting
meeting records of which indicate no the work force will be put in place
significant labour relations issues. The (including reference to specific
IESC notes that there is a potential for an documents such as tender
12Will not be applicable to many projects at appraisal stage. However, evidence, within the last 3 years of client approach to retrenchment which is not compatible with the
Policy should be taken into consideration.

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increase in grievances during the de- documentation, supplier contracts, HR
manning process, particularly given the policy, etc.). Further validation of
depressed Azeri economy and fewer these documents is required to assess
future employment opportunities for adequacy of measures.
particular skillsets. This will be followed
up during the next site visit. A framework H&S MP is provided in
Section 9 ESMP that outlines aspects
to be included in the Plan, including
HSE Policy, H&S Organisation, H&S
Standards, Accidents and Incidents,
H&S Auditing. Further validation of
the full Plan is required to assess
adequacy.
In addition, the Local Content Plan

also provides additional proposed
management measures for a
responsible supply chain in
compliance with GIP. The Local
Content Plan also provides additional
proposed management measures for
a responsible supply chain in
compliance with good international
industry practice.
PR 3. Resource Efficiency and Pollution Prevention and Control
Resource Efficiency, High level review indicates that Oil spills and spill prevention: A key High level review indicates that
Pollution Prevention and resources efficiency is sufficiently construction phase risk is the potential for resource efficiency is sufficiently
Control - Air emissions, addressed in the ESIA. spills to the environment resulting in soil addressed in the ESIA. Section 8
Greenhouse Gases13, The ESMMP Section 11 Resources MP and water contamination and discharge Assessment of Impacts and Mitigation
Pollution Prevention and provides detailed information on the to the marine environment. Two spills Measures is comprehensive, including
Control - Waste waters, management of aggregates, water, over 1 barrel in volume were recorded in detailed assessment of onshore and
13Particular attention should be given to client demonstration of consideration of alternatives. Projects expected annually to produce more than 25,000 tonnes of Co2
equivalent should provide an emission inventory and plans for annual reporting.

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Water, energy efficiency and timber to 2015, which were investigated and offshore aspects. Section 9 ESMP
Wastes, sufficiently address the requirements of corrective and preventative actions provides a detailed overview of the
Hazardous Substances PS2. Chapter 10 Environmental and identified and implemented. The proposed content for each MP,
and Materials Social Impacts and Mitigations (Planned operator has invested in improvement to including plans for waste, water,
Activities) also provides detailed energy oil spill response preparedness including hazardous material management,
consumption, water and other resources oil spill response planning with the watercourse crossings, pollution
and inputs, their impacts and mitigation Ministry of Emergency Situations and has prevention, landscape management,
measures. engaged the services of oil spill erosion and sediments control, and
Alternatives are considered in Chapter 4: responders for offshore and nearshore aggregates, among others, to
Project Development and Evaluation of construction works. sufficiently address the requirements
Alternatives, with options assessed of PR3. Alternatives are considered in
against environmental and social Waste Management: The ATA topsides Section 2 Project Justification.
sensitivity indicators. fabrication yard expansion included
installation of a sewage treatment plant
with a capacity of treating 300m3 per day.
Monitoring data indicates compliance with
discharge water quality criteria. However,
the SD2 temporary onshore construction
workforce sewage treatment plant at ST
was not operational at the time of the site
visit due to delays in obtaining permits.
Alternative wastewater removal to
licensed treatment facilities was in place
for the work site and accommodation
camp. The process to enable full
operation of the temporary wastewater
treatment facility by the construction
contractor is well understood and in
progress, and will be monitored by the IE
at the next site visit.
Wastes at the offshore fabrication yards

ATA and BDJF are segregated on site
prior to transport to a centralised waste
accumulation centre. At the centre, a BP

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managed waste contractor transfers
wastes to various waste treatment,
recycling and disposal facilities.
Approximately 500 tonnes of waste per
month is generated at the ATA Yard,
including hazardous wastes.
Noise and Vibration: Noise monitoring has
been undertaken at the four communities
near the ST, and shows regular noise
levels above the daytime criteria of 65dB
(LAeq). Elevated noise levels have been
attributed to a range of contributing
sources and have been reported back to
the communities by the construction
contractor. There have been no
instances where the action triggers
established in construction environmental
management plans has been reached. BP
advised the IESC that construction noise
from SD2 activities has generally not
been audible at monitoring locations
during the surveys and that no noise
complaints have been received in
Q1/2016.
PR 4. Health and Safety
Occupational Health and General OHS programs and procedures Occupational Health and Safety: In Socio-Economic Baseline appears to
Safety, are not included in the ESIA and general, the LESC observed a strong adequately assess the social context
Community Health and therefore a full assessment is unable to Project health and safety culture. H&S of the Project, including health and
Safety, be undertaken to determine compliance. management remains a priority at the safety.
Infrastructure, Building, Chapter 8 Socio-Economic Baseline does site, particularly the ST with very few
and Equipment Design not appear to include any assessment of incidents reported especially considering Section 8 Assessment of Impacts and
and Safety, security context of the Project. the number of man-hours worked, Mitigations Measures evaluates risks
Hazardous Materials The ESIA states that the existing SCPx compared to industry benchmarks. The and impacts to occupational health
Safety, Emergency Response Plan (ERP) will be project has achieved a commendable and safety and affected communities
Product and Services updated to integrate the SCPX and rolling 12-month Recordable Injury during all phases of the Project.

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Safety, refers to updates that will be included in Frequency Rate (RIF) of 0.04 and a total Section 9 ESMPs provides an outline
Traffic and Road Safety, the SCPX ERP. The ERP for the SCPX is RIF of 0.05, since the commencement of of the proposed content for the
Natural Hazards, insufficiently described in the ESIA to construction. Key statistics show that Community Health MP (including
Exposure to Disease, assess its adequacy. Chapter 12 Hazard there have been no fatalities on the Safety and Security).
Emergency Analysis and Risk Assessment Project to date; 3 high potential incidents,
Preparedness and (Unplanned Events) comprehensively 7 injuries requiring a day away from Security Personnel are addressed as
Response describes and assesses unplanned work, 18 recordable injuries, 193 first aid per the provisions of PR 4. Section 8
events and risks to public safety and incidents and 520 safety near misses Impacts Assessment and Mitigation
harm to the environment including recorded. The IC notes the effective Measures is comprehensive and
mitigation measures. health and safety management structures includes a detailed assessment
and framework established between the (including an HRIA). The Community
Project Operator and key contractors who Health MP includes provisions for due
have all had experience in working with diligence of security providers, and
BP in the Caspian region since the AGT training in Voluntary Principles on
Project construction. Security and Human Rights, and
Community Health, Safety and Security performance monitoring of security
The Operator has described the HSE providers.
leadership, planning and management,
legal and regulatory framework, as well Community Grievance Mechanism is
as management of contractor health and provided.
safety, security, environmental and social
responsibility, and self-verification in the An Emergency Response Plan
Programme HSE Management Plan, framework and proposed contents is
demonstrating an established system is in outlined in Section 9 ESMP. Further
place for addressing emergencies. As with review once the finalised plan is
other management plans, the specific available is required to assess
documented plans have not been publicly adequacy.
disclosed, which is inconsistent with the
requirements of the Lender Group
policies. However, records of community
engagement reviewed by the IC included
communications, via public meetings,
provided to potentially impacted
communities on the measures proposed
in response to emergencies and specific

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mitigations taken to ensure community
safety during construction and
operations.
Furthermore, the impact of population
influx to local communities was scoped
out at the ESIA Phase due to past Project
experience and proven labour
management practices. However, with a
reduced construction workforce labour
demand and fewer forward employment
opportunities available in the current
Azeri market, the mechanism for tracking
potential impacts of the de-mobilised
workforce on communities remains
unclear.
To enable independent verification of the
available project data the IC recommends
that the next site visit include
engagement with key external
stakeholders on their experience and
preparedness for emergencies and
potential for social impacts as a result of
demobilised workforce.
PR 5. Land Acquisition, Involuntary Resettlement and Economic Displacement
Avoid or minimise Project design is detailed in Chapter 4 The Project induced some temporary Social baseline report includes a
displacement, Project Development and Evaluation of economic displacement of fishing detailed section on Land Use and
Consultation, Alternatives - including consideration of households in the vicinity of the export Ownership. It is stated that a detailed
Compensation for physical and economic displacement gas pipeline and monoethylene glycol Resettlement Action Plan and
displaced persons, associated with options. (MEG) pipeline shore crossing during the associated Livelihoods Restoration
Grievance mechanism, Compensation and benefits appear to be construction period when a marine Framework and Plan will be
RAP/LRP compliant with PR 5 principles. The exclusion zone was in place. established and a detailed summary of
documentation, Project has developed a comprehensive Impact assessment on enforcement of the contents and objectives are
RAP/LRP Guide to Land Acquisition and the marine exclusion zone recognised the stipulated. In addition a Draft
implementation, Compensation that forms the basis of potential impact to small-scale fishermen, Entitlements Matrix is provided in the
Monitoring the Land Acquisition and Compensation resulting in a fishing livelihood baseline ESIA. Further assessment once the

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Framework. Further documentary survey being undertaken to gather Resettlement Action Plan is available
evidence of the framework is required to additional information on small-scale for review is required to ascertain
assess adequacy. fishing activities within Sangachal Bay compliance with the PS.
Community engagement on land issues and the nearshore environment. The The SEP outlines grievance
appears to be adequately detailed in the baseline determined that livelihood mechanism that is consistent with PS
Public Consultation and Disclosure Plan, restoration is required to compensate the 1.
including description of community fishermen’s temporary loss of access to
feedback and Project responses. natural resources of the Bay. The Project
Grievance mechanism appears has developed and implemented a Fishing
established and publicised. Resettlement Livelihoods Management Plan (FLMP)
and livelihood restoration baseline which describes the mechanisms to be
appears to adequately define potential used to engage with Project-affected
impacts on land users at specific fishing households, the validation of
locations, to determine eligibility for information underpinning the impact
compensation and assistance. The assessment and to define priorities in
ESMMP provides procedures for the relation to mitigation measures. Further,
monitoring and evaluation of the the Plan specifies measures to address
implementation of the Land MP and the the needs of vulnerable fishing
Land Acquisition and Compensation households (75% of, or 45 impacted
Framework (pending its development). fishing households).
Additionally, the Guide to Land The Project reached agreement with the
Acquisition and Compensation provides identified impacted fishing households,
comprehensive guidance in line with PR including support workers. The IC has
5 on land acquisition and resettlement. reviewed the details of compensation
The responsibilities of the Company and measures which have been made to
the Government in resettlement are affected households and further adjusted
clearly delineated, including that the agreements based on additional
State will take responsibility for land fishermen being deemed eligible and
acquisition within the framework of the increased payments made to
joint (i.e. State and Company) Land accommodate for a longer period of
Acquisition Teams. The Guide to Land marine exclusion. Evidence of effective
Acquisition and Compensation clearly engagement with affected fisherman has
outlines the process to be followed by all been reviewed including minutes of
parties for all types of acquisition. meetings, participant registers and two
household surveys of eligible fishermen.

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The grievance process outlined in the
FLMP remains active with ongoing
consideration of some issues. The IC will
continue to monitor the implementation
of the FLMP during the next site visit with
a focus on the resolution of residual
grievances. It is recommended that the
FLMP remain in place pending the
outcome of the next planned independent
FLMP monitoring report.
Further, the IC notes that although the
FLMP was disclosed by Lenders, on the
ADB website, the SD2 Operator has not
publicly disclosed the FLMP on the
Operator’s website in local language and
that such disclosure is necessary to fully
comply with Lender policies and
requirements. This disclosure of key
documentation is essential to verification
that potentially affected fishermen have
full access to the livelihood restoration
mechanism outlined in the FLMP including
the engagement and grievance process.
PR 6. Biodiversity and Living Natural Resources
Assessment of Chapter 7 Environmental Baseline ST environmental monitoring includes the Biodiversity risk and impacts appear
Biodiversity and Living appears to contain adequate detail. water quality and water levels of well documented for both offshore
Natural Resources, Chapter 10 Environmental and Social wetlands (or wadi) located to the east of and onshore, including modified,
Conservation of Impacts and Mitigations (Planned the SD2 expansion area, in the proximity natural and critical habitats. A
Biodiversity, Activities) also appears to address in of the beach pull site. Pre-existing soil Biodiversity Action Plan overview
Sustainable sufficient detail the provisions of PS6. and water contamination was identified including all elements proposed for
Management of Living as well as possible sources of the Plan is provided (including a
Natural Resources contamination from nearby pipelines and biodiversity offsets program).
neighbouring land use. Free phase oil on Ecosystem services are not explicitly
water has been observed in wetlands discussed in the ESIA.
near the neighbouring power station, and

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the SD2 Project now maintains a
monitoring programme to identify the
cause of contamination at the wetlands
area and monitor the ecological use of
these wetlands by birds and other fauna,
the results of which are reported annually
to the Ministry for Environment.
PR 7. Indigenous People
Not applicable to associated facility projects.
PR 8. Cultural Heritage
Assessment and Cultural heritage is comprehensively The SD2 construction at ST includes Cultural heritage baseline appears
Management of Impacts identified and documented in Chapter 7 provision of ongoing monitoring of comprehensive. The risks and impacts
on Cultural Heritage, Environmental Baseline Study. A potential impacts to Cultural Heritage and to Intangible cultural heritage are also
Consultation with thorough risk and impact assessment is a watching brief for works being assessed in a comprehensive manner.
affected communities conducted in Chapter 10 Environmental undertaken outside of past detailed A CHMP overview and proposed
and other stakeholders, and Social Impacts and Mitigations heritage surveys in line with the Project’s contents is defined (including a
Project use of Cultural (Planned Events), indicating the cultural heritage plan commitments. Local chance finds procedure).
Heritage application of mitigation measures that experts have been undertaking the
favour avoidance. monitoring in consultation with the
A Cultural Heritage Chance Finds Ministry for Culture and Tourism as
Process is provided in the ESMMP. cultural heritage observers, and initial
Baseline indicates that surveys and surveys were completed and submitted
consultation was conducted, and for approval to the Ministry of
additional consultation is delineated in Environment. A range of isolated
the ESMMP for the purposes of artefacts have been identified during the
identification and decision-making. watching brief of construction at ST but
no finds have been deemed to be of
significant heritage value.
Vibration monitoring at the Sand Cave
heritage site has been undertaken by the
SD2 Project to protect the site from
potential damage from Project related
activities in the vicinity of the shore
crossing and pipeline beach pull site. The

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action trigger was not reached during
monitoring, but the Project did amend the
piling technique to reduce vibration in
response to the monitoring results, and
no damage to the Sand Cave site was
observed throughout the works.
PR9. Financial Intermediaries
Not applicable.
PR10. Information Disclosure and Stakeholder Engagement
Stakeholder A Community Liaison Plan is defined The IC notes that the environmental and Extensive engagement (analysis,
Engagement Plan, within the ESIA that includes community social management plans documented for planning disclosure and consultation)
Operational Grievance relations training, establishment and the SD2 construction phase have not is documented in the ESIA in the
Mechanism, maintenance of good community been publicly disclosed during the SD2 following sections - Section 7
Information Disclosure relations, and a grievance procedure. In ESIA process and are not currently Stakeholder Engagement, Annex 7
addition, there is a Public Consultation available to the general public which Stakeholder Engagement Data, and
and Disclosure Plan that presents and indicates a deficiency in conformance to Annex E ESIA Disclosure indicating
describes the stakeholder disclosure and Lender Group requirements. It is that engagement was conducted in
consultation procedures as part of the recommended that the SD2 Operator accordance with IFC principles. The
ESIA process. In sum, the plans appear publicly disclose documented documentation indicates that
substantive. environmental and social management stakeholder analysis and engagement
Concerning disclosure, the ESIA plans where these plans contain the planning was conducted, that there
documentation was disseminated for details and commitments to manage or was adequate disclosure of Project
public review and comment for a period mitigate potentially significant information, and that the principles of
of 60 days, including public meetings. environmental and social impacts of the informed consultation and
The Community Liaison Plan and the Project. participation were adhered to. A
Public Consultation and Disclosure Plan In line with stakeholder engagement and grievance mechanism is documented
both adequately define procedures for grievance management requirements, Section 7 Stakeholder Engagement.
external communications and the responses to affected communities,
lodging and resolution of grievances. summary feedback and adjustment to
Periodic reporting is adequately management plans as a result of
documented in the ESIA (i.e. of the ESIA consultations and grievances received are
itself), including evidence of reporting recommended to be communicated back
notifications and materials. In addition, to interested stakeholders and affected
there is a commitment to periodic communities. Verification on

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reporting to affected communities as the effectiveness of engagement and
Project develops in both the Community grievance management with key
Liaison Plan and the Public Consultation stakeholders such as community
and Disclosure Plan. members and representatives,
commercial fishers, and local government
representatives is sought by the IESC for
the next site visit.

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APPENDIX A: DOCUMENT LIST
File Name Document Name Author / Company Rev / Date
/ Period
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\1.Topographical 001: Topographic map and crossing points002: TANAP 2014
Map and Crossing Points - CIN_MAP_GEN_001_01 to 001_85 and Topographic Map CINAR
CIN_MAP_GEN_002_1 to 002_6
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence 2017 year training activity schedule SICIM 2017
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 08 Spread-3 Drill Exercise Plan YUKSEL
New Data April 17 2017 \ EBRD Questionarie on Social due diligence 2017 year training activity schedule SICIM 2017
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 09 Spread-4 Drill Exercise Plan YUKSEL
Documents 21122016\6.5 Completed Quarterly Third Party Monitoring 9th QUARTERLY PROGRESS REPORT (English CINAR 2/12/2016
Reports by ЗINAR - CIN-PRQ-PRC-GEN-009_9th quarterly monitoring Version)ENVIRONMENTAL AND SOCIAL TANAP
report MONITORING STUDIES
2015-16 Action Status Report Action Status Report (ASR) – Environmental A. Selim KILIC / Tanap 1/1/2015 –
Monitoring 31/12/2015
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates AGGREGATE MANAGEMENT PLAN SICIM – YUKSEL – 04/04/2015
Man. Plan - SYA-PLN-ENV-GEN-012_P3-0 AKKORD JV
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates AGGREGATES MANAGEMENT PLAN FERNAS iNŞAAT A.S. 16/06/2015
Man. Plan - FRN-PLN-ENV-PL1-015-P4-0
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Aggregates Management Plan TANAP 13-03-17
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-009- Aggregates Management Plan-
P4-0
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates AGGREGATES MANAGEMENT PLAN – 48’’ PUNJ LLOYD-LİMAK- 22/06/2016
Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - PLK-PLN-ENV-PL4-008_P4-C ONSHORE PIPELINE CONSTRUCTION LOT 4 KALYON JV
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Agriculture and Livestock TANAP
7.3.1.6
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ AIR EMISSION INVENTORY TANAP 04.03.2014
BAT_emission inventory and relevant evaluation data \ BCH-CAL-ENV- iLF
CSG-001-Rev-P2-2-AIR EMISSION INVENTORY BEACHTEL
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence AIR EMISSION INVENTORY TANAP 04.03.2014
Report-02.03.2017 \ PR3(3.2) \ BCH-CAL-ENV-CSG-001-Rev-P2-2-AIR iLF
EMISSION INVENTORY Bechtel
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air AIR QUALITY (PM10&PM2.5)Baseline Report TANAP 24/7/2014
Quality (PM10&PM2.5) Baseline Report - Air Qual PM10&2_5 BL Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air AIR QUALITY (SO2, NOX, O3) Baseline Report TANAP 2/6/2014
Quality (SO2, NOX, O3) Baseline Report - CIN-REP-ENV-GEN-010-22
Rev-P2-F_EN

Documents 21122016\1.1 Host Gov. & Int Agreement - E&S specific Amendment to “the host government agreement 26/5/2014
Provisions - HGA [ENG] between the government of the republic of
turkey and trans Anatolian gas pipeline company
b.v. concerning the trans Anatolian natural gas
pipeline system”
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Amphibians TANAP
7.3.2.8
Documents 21122016\8.2 List & Analysis of Stakeholders & Records of Analysis of stakeholders and records of
Consultation - 8.2 Analysis of Stake Holder Consultation consultation with relevant regulation authorities
and stakeholders
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 ANNEX 1 CHECKLIST-WASTE MANAGEMENT 17.03.2017
\Waste Facility Inspection Report \ Annex 1_Inspection checklist
New Data May 4 2017 \ Annex 1_Stakeholder Engagement ANNEX 1 STAKEHOLDER ENGAGEMENT TANAP 30/01/2017
Implementation Guideline For Construction... (1) IMPLEMENTATION GUIDELINE FOR
CONSTRUCTION PHASE
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Annex 1 The Analysis Reports for Seawater CINAR 2/7/2013
Water and Sediment Quality BL Report - Annex 1 The Analysis Reports
for Seawater
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Annex 1 The Analysis Reports for Seawater CINAR 2/7/2013
Water Quality Baseline Report - Annex 1 The Analysis Reports for
Seawater
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Annex 1 The Analysis Reports for Sediment CINAR 18/6/2013
Water and Sediment Quality BL Report - Annex 1 The Analysis Reports
for Sediment
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Annex 1 The Analysis Reports for Sediment CINAR 18/6/2013
Water Quality Baseline Report - Annex 1The Analysis Reports for
Sediment
ESIA – RAP – ANNEXES - Chp 1 – Introduction - ANNEX 1.1 - Existing & ANNEX 1.1. EXISTING AND PLANNED PİPELİNE
Planned Pipeline Projects PROJECTS IN TURKEY
ESIA – RAP – ANNEXES - Chp 1 – Introduction - ANNEX 1.2 - Detailed ANNEX 1.2. DETAILED TABLES RELATED TO THE
Tables on Project Affected Settlements PROJECT AFFECTEDSETTLEMENTS
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\11_Marine Annex 1: Distribution Map of biocenosis in the
Habitat and Ecosystems Baseline Report - Biocenosis Annex- 1 to 3 local study area
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Annex 2 Field Forms for Seawater TANAP 31/5/2013
Water and Sediment Quality BL Report - Annex 2 Field Forms for
Seawater
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Annex 2 Field Forms for Seawater TANAP 31/5/2013
Water Quality Baseline Report - Annex 2 Field Forms for Seawater

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Annex 2 Field Forms for Sediment TANAP 30/5/2013
Water and Sediment Quality BL Report - Annex 2 Field Forms for
Sediment
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Annex 2 Field Forms for Sediment TANAP 30/5/2013
Water Quality Baseline Report - Annex 2 Field Forms for Sediment
ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX ANNEX 4.1 – SURVEY QUESTIONSTANAP TANAP
4.1 - Survey Questions Pipeline Project Socio-Economic Survey of
Affected Land Owners and Land Users
ESIA – RAP – ANNEXES - Chp 6 – Impact - ANNEX 6.2 - Valuation ANNEX 4.1 – Valuation Process According to Union of Chambers of 2012
Process According to Expropriation Law Expropriation Law Turkish Architects and
Engineers
ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX ANNEX 4.3 - Village Headmen In-Depth
4.3 - Village Headmen In-Depth Interview Summary Tables Interview Summary Tables
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Annex 4_Laboratory Competency Certificate CINAR
Water and Sediment Quality BL Report - Annex 4_Laboratory
Competency Certificate
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.10 - Land ANNEX 5.10 - Land Acquisition for Jointly Owned
Acquisition of Jointly Owned Land Land
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.11 - Land ANNEX 5.11 – Land Acquisition Process for
Acquisition for Deceased Owner Deceased Owner
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.12 - ANNEX 5.12 – Additional Information on Land
Additional Information on Land Consolidation Consolidation in Turkey
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.13 - Quality ANNEX 5.13 - Quality Control and Reporting
Control and Reporting
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.14 - Land ANNEX 5.14 - Land Exit Process
Exit Process
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.15 - ANNEX 5.15 - Transfer of Land Rights from LRE
Transfer of Land Rights (BOTAS) to TANAP
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.2 - Key ANNEX 5.2 - Key Steps in Land Acquisition
Steps in Land Acquisitionrev revP3-1
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.4 - Land ANNEX 5.4 - Acquisition Procedures of State
Acquisition of State Pasture and Forest Land revp3-1 Authority Land, Pasture Land and Forest Land
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.5 - Land ANNEX 5.5 – Land Acquisition under Customary
Acquisition Under Customary Rights revp3-1 Rights
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.6 - Land ANNEX 5.6 - Land Delivery (Possession of Site)
Delivery Process revp3-1 Process
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.7 - Land ANNEX 5.7 - Land Entry Process
Entry Processrevp3-1

ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.8 - Pipeline ANNEX 5.8 – Pipeline Route Deviation
Route Deviation
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.9 - Court ANNEX 5.9 - Court Process Based on Article 10
Process Based on Article 10 of Expropriation Law revp3-1 of the Expropriation Law
ESIA – RAP – ANNEXES - Chp 6 – Impact - ANNEX 6.1 - Additional ANNEX 6.1. Additional Tables and Figures of
Tables and Figures Chapter 6
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Annex 7 Business Partner risk approval form SICIM 13/06/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 06 SitePlus Security Due YUKSEL
Diligence Report AKKORD
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Annex 7 Business Partner risk approval form SICIM 4/06/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 07 Yuksel Guvenlik Due YUKSEL
Diligence Report AKKORD
Guide to Land Aquisition and Compensation ANNEX 7.1 – Guide to Land Acquisition and
Compensation (GLAC)LAND ACQUISITION
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Annex I The Analysis Reports for Soil CINAR 2/12/2013
Contamination Baseline Study Report - Annex I_The Analysis Reports
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Annex II_Field Forms for Soil TANAP 1/11/2013
Contamination Baseline Study Report - Annex II_Field Forms
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Annex IV Laboratory Competency Certificate
Water Quality Baseline Report - Annex IV_Laboratory Competency
Certificate
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Annex IV_Laboratory Competency Certificate
Contamination Baseline Study Report - Annex IV_Laboratory
Competency Certificate
BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ ANNOUNCEMENT
Appeals Committee \ APPEALS COMMITTEE_WEB ANNOUNCEMENTS
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence ANNUAL TRAINING PLAN AND TOPICS
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \
ANNUAL TRAINING PLAN AND TOPICS
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.16 - App 5.16 Application of Article 27
Application of Article 27revp31
BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ APPEALS COMMITTEE APPLICATION FORM
Appeals Committee \ TNP-SOC-FRM-006 Appeals Committee_Application
Form
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6 - Appendix Appendix – 2.6.1. Photographs of Project Area TANAP
%96 2.6.1. Photographs of Project Area
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX - 4.5 IMPACT REGISTERS TANAP
Appendix 4.5

ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX - 4.6. LEGISLATION REGISTERS TANAP
Appendix 4.6
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX - 4.7COMMITMENTS REGISTERS TANAP
Appendix 4.7
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence APPENDIX (4) RISK ANALYSIS AND
Report-02.03.2017 \ PR2(2.10) \ Stations \ Risk Rating Matrix ASSESSMENT RESULTS
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps - APPENDIX APPENDIX 1.3 MAPS AND PLANS TANAP
1.3_index
Ref Mat\Documents 21122016\1.1 Host Gov. & Int Agreement - E&S Appendix 1: Host government between the
specific Provisions - TANAP HGA English Final 25062012 government of the republic of turkey and trans
Anatolian gas pipeline company (attached to
and forms an integral part of the
Intergovernmental agreement)
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.1 APPENDIX 2.1. TECHNICAL STUDIES, FIELD TANAP
STUDIES, REPORTS, ANALYSES, MAPS AND
PHOTOGRAPHS
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.2 APPENDIX 2.2METEOROLOGICAL BULLETIN
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.3 APPENDIX 2.3. ANALYSES TANAP
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4 APPENDIX 2.4. REPORTS TANAP
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.5 APPENDIX 2.5. ECOLOGICAL FIELD SURVEYS TANAP
OBSERVATION POINTS
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6 - APPENDIX 2.6. PHOTOGRAPHY ARCHIVE AND TANAP
APPENDIX 2.6_index LOADED DATA BANK CATALOGUE
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.7 Appendix 2.7. “ModellingReport on Emission ALTOSENE 16/04/2014
ofCompressor Station” of ESIA REPORT
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Appendix 2.7. “ModellingReport on Emission TANAP 16.04.2014
Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_APPENDIX 2.7 ofCompressor Station” of ESIA REPORT CINAR
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2.8 Appendix 2.8 “Noise ModellingReport For OZMEALTOSENE 16/04/2014
CompressorStations ”of ESIA REPORT
Documents 21122016\1.4 Appendix 2 of ESIA - APPENDIX 2_index APPENDIX 2_index TANAP
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) - APPENDIX APPENDIX 3 TANAP
3_index
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.1. INFORMATION AND REGISTERS TANAP
APPENDIX 3.1 RELATED TO PUBLIC PARTICIPATION
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.2 STAKEHOLDER REGISTERS TANAP
APPENDIX 3.2_index
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.2d Invitee List for NGO Meeting TANAP 12/11/2013
APP 3.2d-Invitee List and Forms and FormsINVITEES AND PARTICIPANTS

FROMNATIONAL AND INTERNATIONAL
STAKEHOLDERS
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.2e List of NGOs which received Info TANAP
APP 3.2e-List of NGOs which received Info Packs Packs
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.2f Feedback Form TANAP
APP 3.2f-Feedback forms
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.3ANNOUNCEMENT RECORDS TANAP 12/02/2013
APPENDIX 3.3
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.4NOTIFICATION REGISTERS TANAP
APPENDIX 3.4
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - APPENDIX 3.5COMPLAINT REGISTERS TANAP
APPENDIX 3.5
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX 4.1. INFORMATION AND REGISTERS, TANAP
APPENDIX 4.1 AND AUTHORITY OPINIONS RELATED TO EIA
PROCESS
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX 4.2 SPECIAL FORMAT OF ESIA TANAP
APPENDIX 4.2 REPORT
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - Appendix 5.1. Construction Impacts TANAP
Appendix 5.1 Management Plan
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.10. Pollution Prevention Plan TANAP
Appendix 5.10
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.11. Waste Management Plan TANAP
Appendix 5.11
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.12. Emergency Response Plan TANAP
Appendix 5.12
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.2. Community Safety Management TANAP
Appendix 5.2 Plan
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.3. Community Relations Plan TANAP
Appendix 5.3
Documents 21122016\2.7 Local Hiring Plans - CIN-REP-ENV-GEN-010-45 Appendix 5.4. “Employment and Training Plan” CINAR 2/6/2014
Rev-P2-C_App. 5.4_EN of ESIA REPORT TANAP
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.4. Employment and Training Plan TANAP
Appendix 5.4
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.5. Procurement and Supply TANAP
Appendix 5.5 Management Plan
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.6. Aggregates Management Plan TANAP
Appendix 5.6
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.7. Traffic Management Plan TANAP

Appendix 5.7
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.8. Cultural Heritage Management TANAP
Appendix 5.8 Plan
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5.9. Erosion, Reinstatement and TANAP
Appendix 5.9 Landscaping Plan
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 5 - APPENDIX 5MANAGEMENT PLANS TANAP
APPENDIX 5_index
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates Appendix A - OFF ROW AGGREGATE
Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - Appendex A CONSUMPTION REGISTER
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX A LIST OF SLOPES AND RELATED
8_Biorestoration Monitoring Plan – Appendices - APPENDIX A LIST OF BIORESTORATION ACTIVITIES
SLOPES AND RELATED BIORESTORATION ACTIVITIES
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX A LIST OF SLOPES AND RELATED
Methodologies\BAP\Annex-8\Appendices - APPENDIX A LIST OF SLOPES BIORESTORATION ACTIVITIES
AND RELATED BIORESTORATION ACTIVITIES
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX A LIST OF SLOPES AND RELATED
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX A BIORESTORATION ACTIVITIES
LIST OF SLOPES AND RELATED BIORESTORATION ACTIVITIES
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX A LIST OF SLOPES AND RELATED
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX A LIST OF BIORESTORATION ACTIVITIES
SLOPES AND RELATED BIORESTORATION ACTIVITIES
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX A LIST OF SLOPES AND RELATED
APPENDIX A LIST OF SLOPES AND RELATED BIORESTORATION BIORESTORATION ACTIVITIES
ACTIVITIES
Documents 21122016\1.9 Pipe Supply Contract and Prequalication Appendix A: Schedule of requirementsHealth, Consulting Engineers 7/3/2014
Requirements - Extract from LЭne Pipe Supply Contract Safety, Social and Environmental Requirements TANAP
for Suppliers and Vendors
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX ATRAINING REGISTER
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN-
ENV-PL4-003_P4-1 - APPENDIX A TRAINING REGISTER
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX B FAUNA REGİSTER
ENV-PL4-003_P4-1 - APPENDIX B FAUNA REGİSTER
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX B.1 TERRESTRIAL FLORA
8_Biorestoration Monitoring Plan – Appendices - APPENDIX B.1 MONITORING TABLE
TERRESTRIAL FLORA MONITORING TABLE
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX B.1 TERRESTRIAL FLORA
Methodologies\BAP\Annex-8\Appendices - APPENDIX B.1 TERRESTRIAL MONITORING TABLE

FLORA MONITORING TABLE
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX B.1 TERRESTRIAL FLORA
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX MONITORING TABLE
B.1 TERRESTRIAL FLORA MONITORING TABLE
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX B.1 TERRESTRIAL FLORA
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX B.1 MONITORING TABLE
TERRESTRIAL FLORA MONITORING TABLE_clean/tc/pdf file
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.1 TERRESTRIAL FLORA
APPENDIX B.1 TERRESTRIAL FLORA MONITORING TABLE_tc/clean/pdf MONITORING TABLE
file
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX B.2 TERRESTRIAL FAUNA
TERRESTRIAL FAUNA MONITORING TABLE_clean
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX B.2 TERRESTRIAL FAUNA
Methodologies\BAP\Annex-8\Appendices - APPENDIX B.2 TERRESTRIAL MONITORING TABLE
FAUNA MONITORING TABLE_clean
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX B.2 TERRESTRIAL FAUNA
B.2 TERRESTRIAL FAUNA MONITORING TABLE
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX B.2 TERRESTRIAL FAUNA
TERRESTRIAL FAUNA MONITORING TABLE_clean/tc/pdf file
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.2 TERRESTRIAL FAUNA
APPENDIX B.2 TERRESTRIAL FAUNA MONITORING TABLE_tc/ clean / MONITORING TABLE
pdf file
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX B.3 FRESHWATER FAUNA
B.3 FRESHWATER FAUNA MONITORING TABLE
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX B.3 FRESHWATER FAUNA
FRESHWATER FAUNA MONITORING TABLE
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX B.3 FRESHWATER FAUNA
APPENDIX B.3 FRESHWATER FAUNA MONITORING TABLE MONITORING TABLE
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX B.3 TERRESTRIAL FAUNA
FRESHWATER FAUNA MONITORING TABLE
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX B.3 TERRESTRIAL FAUNA
Methodologies\BAP\Annex-8\Appendices - APPENDIX B.3 FRESHWATER MONITORING TABLE

FAUNA MONITORING TABLE
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates APPENDIX B-LIST OF QUARRIES ALONG THE
Man. Plan - PLK-PLN-ENV-PL4-008_P4-C - Appendex B LOT 4 PIPELINECORRIDOR (AS PROVIDED)
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX C SENSITIVE AREA REGİSTER
ENV-PL4-003_P4-1 - APPENDIX C SENSITIVE AREA REGİSTER
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX C.1 SAMPLE SITE SELECTION
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.1 SAMPLE METHODOLOGY
SITE SELECTION METHODOLOGY
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.1 SAMPLE SITE SELECTION
APPENDIX C.1 SAMPLE SITE SELECTION METHODOLOGY METHODOLOGY
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX C.1 SAMPLE SITE SELECTION
Methodologies\BAP\Annex-8\Appendices - APPENDIX C.1 SAMPLE SITE METHODOLOGY -ESTIMATION OF SAMPLE
SELECTION METHODOLOGY NUMBER AND SAMPLE LOCATION FOR SPECIES
COMPOSITIONASSESSMENT
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.1 SAMPLE SITE SELECTION
8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.1 SAMPLE METHODOLOGYESTIMATION OF SAMPLE
SITE SELECTION METHODOLOGY NUMBER AND SAMPLE LOCATION FOR SPECIES
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX C.1 SAMPLE SITE SELECTION
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX METHODOLOGYESTIMATION OF SAMPLE
C.1 SAMPLE SITE SELECTION METHODOLOGY NUMBER AND SAMPLE LOCATION FOR SPECIES
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX C.2: SITE RECORDS
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.2 SITE
RECORDS
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.2: SITE RECORDS
APPENDIX C.2 SITE RECORDS
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.2: SITE RECORDSSITE
8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.2 SITE ASSESSMENT PROFORMA
RECORDS
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX C.2: SITE RECORDSSITE
Methodologies\BAP\Annex-8\Appendices - APPENDIX C.2 SITE ASSESSMENT PROFORMA
RECORDS
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX C.2: SITE RECORDSSITE
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX ASSESSMENT PROFORMA
C.2 SITE RECORDS
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.3 SITE ASSESSMENT CHECKLIST

8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.3 SITE
ASSESSMENT CHECKLIST
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX C.3 SITE ASSESSMENT CHECKLIST
Methodologies\BAP\Annex-8\Appendices - APPENDIX C.3 SITE
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX C.3 SITE ASSESSMENT CHECKLIST
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX
C.3 SITE ASSESSMENT CHECKLIST
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX C.3 SITE ASSESSMENT CHECKLIST
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.3 SITE
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.3 SITE ASSESSMENT CHECKLIST
APPENDIX C.3 SITE ASSESSMENT CHECKLIST
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.4 ESTIMATING PERCENT COVER
8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.4
ESTIMATING PERCENT COVER
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX C.4 ESTIMATING PERCENT COVER
C.4 ESTIMATING PERCENT COVER
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX C.4 ESTIMATING PERCENT COVER
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.4
ESTIMATING PERCENT COVER
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.4 ESTIMATING PERCENT COVER
APPENDIX C.4 ESTIMATING PERCENT COVER
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX C.4 ESTIMATING PERCENT COVER –
Methodologies\BAP\Annex-8\Appendices - APPENDIX C.4 ESTIMATING VISUAL GUIDE TO ESTIMATING PERCENTAGE
PERCENT COVER COVER
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX C.5 CALCULATION OF NDVI VALUES
8_Biorestoration Monitoring Plan – Appendices - APPENDIX C.5
CALCULATION OF NDVI VALUES
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX C.5 CALCULATION OF NDVI VALUES
Methodologies\BAP\Annex-8\Appendices - APPENDIX C.5 CALCULATION
OF NDVI VALUES
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX C.5 CALCULATION OF NDVI VALUES
C.5 CALCULATION OF NDVI VALUES
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX C.5 CALCULATION OF NDVI VALUES
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX C.5

CALCULATION OF NDVI VALUES
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX C.5 CALCULATION OF NDVI VALUES
APPENDIX C.5 CALCULATION OF NDVI VALUES
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- APPENDIX D TERRESTRIAL FAUNA SURVEY
8_Biorestoration Monitoring Plan – Appendices - APPENDIX D FORMS
TERRESTRIAL FAUNA SURVEY FORMS
Documents 21122016\6.1 Description of Timing and Baseline Survey APPENDIX D TERRESTRIAL FAUNA SURVEY
Methodologies\BAP\Annex-8\Appendices - APPENDIX D TERRESTRIAL FORMS
FAUNA SURVEY FORMS
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ APPENDIX D TERRESTRIAL FAUNA SURVEY
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ Appendices \ APPENDIX D FORMS
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- APPENDIX D TERRESTRIAL FAUNA SURVEY
GEN-017-Rev-P3-10 \ Annex-8 \ Appendices \ APPENDIX D FORMS
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ APPENDIX D TERRESTRIAL FAUNA SURVEY
APPENDIX D TERRESTRIAL FAUNA SURVEY FORMS FORMS
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX D WATERCOURSE CROSSİNG
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN- REGISTER
ENV-PL4-003_P4-1 - APPENDIX D WATERCOURSE CROSSİNG
REGISTER
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX E REINSTATEMENT REGISTER
ENV-PL4-003_P4-1 - APPENDIX E REINSTATEMENT REGISTER
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX F TREE/SHRUB CUT & RELOCATED
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - PLK-PLN- REGISTER
ENV-PL4-003_P4-1 - APPENDIX F TREE_SHRUB CUT & RELOCATED REG
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - APPENDIX G MAJOR RIVER CROSSINGS
ENV-PL4-003_P4-1 - APPENDIX G MAJOR RIVER CROSSINGS
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Appendix M: Environmental and Social 22.04.2014
Report-02.03.2017 \ PR1(1.6) \ Appendix M Environmental and Social Management for 56” Onshore Pipeline
Construction
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 4 - APPENDIX-4 TANAP
APPENDIX 4_index
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Approval of subcontracts WorleyParson 14/04/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 03 TANAP-WRP-LET-SYA-0069
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Approval of subcontracts SICIMYUKSELAKKORD JV 24/03/2015

Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 02 TANAP-SYA-LET-WRP-0066
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Aquatic Invertebrates TANAP
7.3.2.11
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Aquatic Vegetation TANAP
7.3.2.4
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix- Archaeological Baseline Studies 25/5/2014
2.6.5. Archaeological Baseline Studies - 5. Archaeological Baseline
Studies
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\9.Archaeological Archaeological site map TANAP 2014
Areas Map - CIN_MAP_ARC_001_01 to 001_63 CINAR
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Archaeological Status Table 29/5/2014
2.4\22_Terrestrial Archaeology Baseline Report - Annex 1 Archaeological
Status Table 29052014
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Archaeological Survey Forms REGIO 29/5/2014
2.4\22_Terrestrial Archaeology Baseline Report - Annex 2 Archaeological
Survey Forms29052014
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Areas Under The Provision of Government TANAP
7.3.1.8 (Military Prohibited Zones, Areas Allocated to
State Institutions and Organizations with
Special Purposes, “Restricted Areas” by Cabinet
Decree no. 7/16349, etc.)
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Arthropoda Field Forms 1/05/2013
2.4\13_Terrestrial Fauna Baseline Report - Ek 7 -Arthropoda Field Forms
ESIA – ESMS Docs – ESIA – Chapter 9 ASSESSMENT OF AREAS TO BE GIVEN UP IN THE TANAP
PROJECT
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Assessment of Offshore Biological Environment TANAP
7.3.5
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Assessment of Offshore Socio-Economic TANAP
7.3.6 Environment
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.3 Assessment of On Shore Social Characteristics TANAP
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Assessment of Onshore Socio-Economic TANAP
7.3.3 Environment
Documents 21122016\11.1 Copies of All Presentations - EBRD Attendance sheet TANAP
Attendance Sheet Worley Parsons
Documents 21122016\6.9 BAP Monitoring Plans for Contractors - 6.9 BAP Monitoring Plans for Contractors (Read Me)
BAP Monitoring Plans for Contractors (Read Me)
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\7.Baseline Map - Baseline Map (Surveying Map) TANAP 2014
CIN_MAP_BAS_001_01 to 001_41 CINAR

Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Basis of Design: Pipeline Crossings of Active TANAP 14/10/2015
Stability,Surface Fault Rupture)\Basis of Design Pipeline Crossings of Tectonic Faults WorleyParsons
Active Tectonic Faults - WRP-REP-PPL-GEN-017
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ BAT Assessment Report TANAP 10.03.2014
BAT_emission inventory and relevant evaluation data \ BAT Assessment iLF
Report BEACHTEL
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Biodiversity TANAP
7.3.2.14A
Documents 21122016\6.1 Description of Timing and Baseline Survey BIODIVERSITY ACTION PLAN CINAR 12/10/2016
Methodologies\BAP - CIN-REP-ENV-GEN-017-Rev-P3-6 TANAP
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ BIODIVERSITY ACTION PLAN TANAP 31.01.2017
CIN-REP-ENV-GEN-017-Rev-P3-9 \ CIN-REP-ENV-GEN-017-Rev-P3-9 CINAR
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- BIODIVERSITY ACTION PLAN TANAP 02/05/2017
GEN-017-Rev-P3-10 \ CIN-REP-ENV-GEN-017-Rev-P3-10 CINAR
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ CIN-REP- BIODIVERSITY ACTION PLAN CINAR 02/05/2017
ENV-GEN-017-Rev-P3-10.pdf \ CIN-REP-ENV-GEN-017-Rev-P3-10 TANAP
Revised 12.10.2016 - Biodiverity action plan (BAP) - Modification BIODIVERSITY ACTION PLAN (BAP) CINAR
Register_12102016 MODIFICATION REGISTER
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- BIODIVERSITY ACTION PLAN (BAP) TANAP 20/04/2017
GEN-017-Rev-P3-10 \ Modification Register_clean MODIFICATION REGISTER CINAR
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \Modification BIODIVERSITY ACTION PLAN (BAP) CINAR 20/04/2017
Register_clean.docx \ Modification Register_clean MODIFICATION REGISTER TANAP
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ BAP_final BIODIVERSITY ACTION PLAN (BAP) TANAP 20/04/2017
draft \ Modification Register MODIFICATION REGISTER CINAR
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ BIODIVERSITY ACTION PLAN TANAP 31.01.2017
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Modification Register_31012017 (BAP)MODIFICATION REGISTER CINAR
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ BAP_final BIODIVERSITY ACTION PLAN (Review P3-11) TANAP 18/05/2017
draft \ CIN-REP-ENV-GEN-017-Rev-P3-11_tc CINAR
ESIA – ESMS Docs – BAP - BAP_CIN-REP-ENV-GEN-017_P3-4 Biodiversity Action Plan (The Trans-Anatolian CINAR 12/07/2016
Natural Gas Pipeline Project)
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / FRESHWATERFAUNA BASELINE OZEC 2/6/2014
2.4\12_Freshwater Fauna Baseline Report - Freshwater Fauna BL Rep REPORT 2
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / FRESHWATERFLORA BASELINE DUMH 13/2/2014
2.4\14_Freshwater Flora Baseline Report - Freshwater Flora BL Report REPORT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / FRESHWATERHABITATS AND DUMH 2/6/2014
2.4\18_Freshwater Habitat and Ecosystems Baseline Report - ECOSYSTEMSBASELINE REPORT
Freshwater Habitat and Ecosystems BLReport
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\10_Marine Biological / Marine BiodiversityBaseline Report KATT 27/1/2014

Biodiversity Baseline Report - Marine Biodiversity BL Rep CINM
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine BIOLOGICAL / MARINE FAUNABASELINE KATT 23/1/2014
Fauna BL Report - Marine Fauna BL Report REPORT CINM
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\8_Marine Biological / Marine FloraBaseline Report TASE 27/1/2014
Flora Baseline Report - Marine Flora BL Rep CINM
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\11_Marine Biological / Marine Habitats andEcosystems KATT 28/1/2014
Habitat and Ecosystems Baseline Report - Marine Habitat&Ecosystem BL Baseline Report CINM
Rep
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\9_Marine Biological / Marine ProtectedAreas Baseline CINM 30/1/2014
Protected Areas Baseline Report - Marine Protected Areas BL Rep Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / TERRESTRIALBIODIVERSITY HASA 2/6/2014
2.4\17_Terrestrial Biodiversity Baseline Report - 17_Terrestrial BASELINEREPORT
Biodiversity Baseline Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / TERRESTRIALFAUNA BASELINE HASA 2/6/2014
2.4\13_Terrestrial Fauna Baseline Report - Terrestrial Fauna BL Report REPORT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / TERRESTRIALFLORA BASELINE DUMH 2/6/2014
2.4\15_Terrestrial Flora Baseline Report - Terrestrial Flora Baseline REPORT
Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / TERRESTRIALHABITATS AND DUMH 7/2/2014
2.4\19_Terrestrial Habitat and Ecosystems Baseline Report - Terrestrial ECOSYSTEMSBASELINE REPORT
Habitat and Ecosystems BL Rep.
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX BIOLOGICAL / TERRESTRIALPROTECTED AREAS HASA 2/6/2014
2.4\16_Terrestrial Protected Areas Baseline Report - 16_Terrestrial BASELINEREPORT
Protected Areas Baseline Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix- Biological Baseline Studies CINAR
2.6.3. Biological Baseline Studies - 3. Biological Baseline Studies
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\6.Biological Biological Sampling Stations Map TANAP CINAR 2014
Sampling Stations Map - CIN_MAP_BIO_001_01 to 001_41
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex- BIORESTORATION MONITORING PLAN CINAR 10/2016
8_Biorestoration Monitoring Plan – CIN-PLN-ENV-GEN-014-Rev-P3-1
Documents 21122016\6.1 Description of Timing and Baseline Survey BIORESTORATION MONITORING PLAN TANAP 12/10/2016
Methodologies\BAP\Annex-8 - CIN-PLN-ENV-GEN-014-Rev-P3-1 CINAR
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ BIORESTORATION MONITORING PLAN TANAP 31.01.2017
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-8 \ CIN-PLN-ENV-GEN-014- CINAR
Rev-P3-2
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- BIORESTORATION MONITORING PLAN CINAR 31/01/2017
GEN-017-Rev-P3-10 \ Annex-8 \ CIN-PLN-ENV-GEN-014-Rev-P3-2 TANAP
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 8 \ BIORESTORATION MONITORING PLAN CINAR 1/2017

CIN-PLN-ENV-GEN-014-Rev-P3-2 TANAP
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Bird Field Forms TANAP 21/2/2013
2.4\13_Terrestrial Fauna Baseline Report - Ek 5- Bird Field Forms
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Birds TANAP
7.3.2.6
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring Log TANAP 4/10/2013
2.4\25_Geotechnical Survey Borelogs - BoreLog Rep5-TR SOCAR
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring log TANAP 17-
2.4\25_Geotechnical Survey Borelogs - BoreLog Rep2-TR SOCAR 26/9/2013
SEBAT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring log TANAP 30/10 –
SEBAT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring log TANAP 27-
SEBAT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring Log TANAP 4-7/10/2013
2.4\25_Geotechnical Survey Borelogs - BoreLog Rep6-TR SOCAR
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring log TANAP 29/8 –
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Boring log TANAP 5-20/2/2014
2.4\25_Geotechnical Survey Borelogs - BoreLog RepCS-TR SOCAR
SEBAT
Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Buoyancy Calculation TANAP 23/9/2015
Wetlands & Seismic Act\Buoyancy Calculation - WRP-CAL-PPL-PLG-006 WorleyParsons
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Calibration report Protos 30/10/2013
Vibration BL Report - A 4 SVAN CALIBRATOR new
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Calibration report Protos 6/6/2013
Vibration BL Report - A 4 SVAN CALIBRATOR
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence CAMP ID CARDS
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Access Control ID Check \
Sample ID Badges
Documents 21122016\3.6 Construction Camp Site Drainage CAMP MANAGEMENT PLAN (LOT 4) TANAP 4/8/2016
Management Process - PLK-PLN-ENV-PL4-004_Camp management WorleyParsons
plan_Lot 4
Documents 21122016\3.6 Construction Camp Site Drainage Camp Management Plan (LOT1) TANAP 11/5/2015
Management Process - FRN-PLN-ENV-PL1-002_Camp management WorleyParsons
plan_Lot 1 FERNAS

Documents 21122016\3.6 Construction Camp Site Drainage Camp Management System (LOT2) SYA ‐ 5/5/2015
Management Process - SYA-PLN-HSE-GEN-012_Camp management Sicim‐Yuksel‐Akkord JV
plan_Lot 2 TANAP
WorleyParsons
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Camp Security Plan For Spread-5 TANAPTEKFEN 15.12.2016
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-003-P4-2
(SEC. PLAN SPRD-5)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Camp Security Plan For Spread-6 TANAP 15.12.2016
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-004-P4-2 TEKFEN
SEC. PLAN SPRD-6
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Certificate of operating permit for private
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 4 Yuksel Guvenlik security company
Securty license
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Certificate of participation as trainer
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ certificate
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Chance Finds Procedure WorleyParsons 14/04/2015
Management Plan - Annex B - WRP-PCD-ENV-GEN-003
ESIA – ESMS Docs – ESIA – Chapter 2 Chapter 2 PROJECT DESCRIPTION TANAP
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence CHAPTER 2: TRANS ANATOLIAN NATURAL GAS TANAP
Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_CH-2 PIPELINE (TANAP) PROJECT ESIA REPORT
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Chapter 7.3.1.1 Meteorological and Climatic TANAP
7.3.1.1 Characteristics
Documents 21122016\3.1 Hydrotest Management Plan – Procedure - CHAPTER 8.1 Assessment Of Impacts On TANAP
TNP-REP-ENV-GEN-002_CH-8.1 Physical Components
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.1 Chapter 8.1 Assessment Of Impacts On Physical TANAP
Components
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ CHAPTER 8.1 Assessment Of Impacts On TANAP
BAT_emission inventory and relevant evaluation data \ TNP-REP-ENV- Physical Components
GEN-002_CH-8.1
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence CHAPTER 8.1: TRANS ANATOLIAN NATURAL GAS TANAP
Report-02.03.2017 \ PR3(3.2) \ TNP-REP-ENV-GEN-002_CH-8.1 PIPELINE (TANAP) PROJECT ESIA REPORT
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air ÇINAR ENVIRONMENTAL MEASUREMENT AND CINAR 21/12/2010
Quality (PM10&PM2.5) Baseline Report - A 2 Field Forms_PM10 ANALYSIS LABORATORY PM 10 SAMPLING
FORM
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air CINAR Laboratory Competency Certificate CINAR
Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex III_CINAR
Laboratory Competency Certificate
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY COMMUNITY RELATIONS MANAGEMENT PLAN FERNAS 19/06/2015

RELATIONS PLANS OF CCs - FRN-PLN-SOC-PL1-005_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY COMMUNITY RELATIONS MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 14/06/2016
RELATIONS PLANS OF CCs - PLK-PLN-SOC-PL4-002_P4-2
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY Community Relations Management Plan SYA ‐ 21/05/2015
RELATIONS PLANS OF CCs - SYA-PLN-SOC-GEN-002_P4-0 Sicim‐Yuksel‐Akkord JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Community Relations Management Plan TANAP 19.01.2017
Report-02.03.2017 \ PR2(2.7) \ FRN-PLN-SOC-PL1-005 FERNAS
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Community Relations Plan TANAP 16-02-17
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-002- Community Relations Plan-
P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY COMMUNITY SAFETY MANAGEMENT PLAN FERNAS 17/06/2015
SAFETY MANAGEMENT PLANS OF CCs - FRN-PLN-SOC-PL1-004_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY COMMUNITY SAFETY MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 15/06/2016
SAFETY MANAGEMENT PLANS OF CCs - PLK-PLN-SOC-PL4-005_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY Community Safety management plan SYA ‐ 07/05/2015
SAFETY MANAGEMENT PLANS OF CCs - SYA-PLN-SOC-GEN-001_P4-0 Sicim‐Yuksel‐Akkord JV
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Community Safety Management Plan TANAP 02-02-17
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-001- Community Safety
Management Plan- P4-0
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence COMPRESSOR STATION 1 - DESIGN CASE
Report-02.03.2017 \ PR3(3.2) \ WRP-REP-MEC-GEN-001-P3-2. Technical PERFORMANCE DETAIL
bid evaluation report.emission values
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\26_ENVID Compressor Station Environmental Impact 2013
Report - 26_ENVID Report Identification (ENVID) REPORT
ESIA – ESMS Docs – ESIA – Chapter 12 Conclusion TANAP
Documents 21122016\3.6 Construction Camp Site Drainage Construction Camp Management Plan (LOT 3) Tekfen 16/4/2015
Management Process - TKF-PLN-ENV-PL3-012_Camp management TANAP
plan_Lot 3
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACT MANAGEMENT PLAN PUNJ LLOYD – LİMAK JV 10/06/2016
ENV-PL4-003_P4-1 - PLK-PLN-ENV-PL4-003_P4-1
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACT MANAGEMENT PLAN FERNAS 15/06/2015
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - FRN-PLN-
ENV-PL1-003_P4-1
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Construction Impact Management Plan TANAP 07-03-17
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-002- Construction Impact
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - CONSTRUCTION IMPACTS MANAGEMENT PLAN SYA ‐ 28/05/2015

CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN- Sicim‐Yuksel‐Akkord JV
ENV-GEN-008_P4-0 - SYA-PLN-ENV-GEN-008_P4-0
Documents 21122016\6.7 Procedures Management Plan for Invasive CONSTRUCTION IMPACTS MANAGEMENT PLAN TANAP Worley Parsons 11/11/2016
Species - SYA-PLN-ENV-GEN-008_Construction impacts management SICM
plan(revised) YUKSEL
AKKORD JV
Documents 21122016\4.5 Country Industry Project Safety Zone Country Industry Project Safety Zone Distances
Distances from AGI's - 4.5 Country Industry Project Safety Zone
Distances
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence CRISIS MANAGEMENT PLAN TANAP 21.02.2017
Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-004 Crissis FERNAS
Management Plan
Documents 21122016\8.1 Criteria for Avoiding Salvage Excavation of Criteria for Avoiding Salvage Excavation of
Cultural Heritage - 8.1 Criteria for Avoiding Salvage Excavation of Cultural Heritage (Read me)
Cultural Heritage (Read me)
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Critical Habitats TANAP
7.3.2.17A
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Cultural Heritage Management Plan FERNAS 27/01/2016
Management Plan - Annex B - LOT 1- FRN-PLN-ENV-PL1-016
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Cultural Heritage Management Plan SYA ‐ Sicim ‐ 04/05/2015
Management Plan - Annex B - LOT 2- SYA-PLN-ENV-GEN-006 Yuksel‐Akkord JV
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage Cultural Heritage Management Plan Tekfen 14/05/2015
Management Plan - Annex B - LOT 3- TKF-PLN-ENV-PL3-018
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage CULTURAL HERITAGE MANAGEMENT PLAN PUNJ LLOYD – LİMAK JV 05/06/2016
Management Plan - Annex B - LOT 4- PLK-PLN-ENV-PL4-009
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage CULTURAL HERITAGE MANAGEMENT PLAN 19/07/2016
Management Plan - TNP-PLN-ENV-GEN-006
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Cultural Heritage Management Plan TANAP 15-10-16
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-007-Cultural Heritage Management
Plan-P4-C
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage CULTURAL HERITAGE MANAGEMENT PLAN - 19/07/2016
Management Plan - Annex B - Annex B_ Chance Finds Procedure of ANNEX B CHANCE FINDS PROCEDURE OF EPCM
EPCM and CHMP of CCs AND CHMP OF CCS
Documents 21122016\8.3 Cultural Heritage Management Plan - 8.3 Cultural Heritage Management Plan (Read me)
Cultural Heritage Management Plan (Read me)
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage CULTURAL HERITAGE MANAGEMENT 19/07/2016
Management Plan - Annex D PLANANNEX D SCOPE OF WORK ARCHAEOLOGY
CONSULTANT

ESIA – ESMS Docs – ESIA – Chapter 10 Cumulative and Global Impact Assessment TANAP
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Daily activities report form: Annex 5_Hard TANAP 2/9/2013
Fauna BL Report - Annex 5_Hard Bottom Macrobenthos Field Forms Bottom Macrobenthos Field forms
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Daily activities report form: Fish field forms TANAP 2/9/2013
Fauna BL Report - Annex 3_Fish Field Forms
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Daily activities report form: Soft Bottom TANAP 2/9/2013
Fauna BL Report - Annex 4_Soft Bottom Macrobenthos Field Forms Macrobenthos Field forms
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Determination of Baseline Pollutant Load in the TANAP
7.3.1.9 Project Area and in Impact Area (in terms of Air,
Water, Soil, Noise etc.)
Documents 21122016\2.1 Fatique Man. Guidelines & Man. Plan - TNP- Diver Manual DRIVING STANDARDS AND TANAP 21/8/2014
MAN-HSM-GEN-001-Rev-P2-0_EN APPLICATIONSFOR TANAP PROJECT
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ DRAFT-TANAP RAP FUND MANAGEMENT TANAP 23/05/2017
TNP-PCD-SOC-GEN-003-Draft RAP Fund Management Procedure PROCEDURE
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Drill / Execution TANAP 03/02/2017
ROW Security Training Dutluca Eskiюehir 2017 \ Security Drills in Gonen
- Karaorman 2017 \ Gonen Drill and Karaorman DrillL
Documents 21122016\2.1 Fatique Man. Guidelines & Man. Plan - HED- Driver and vehicle Management procedure HED Academy 8/8/2016
PCD-HSM-GEN-001-Rev-P2-2_EN TANAP
New Data 15 May 2017 \ BAP_Presentation_EBRD_11_05_2017_R1 ECOLOGICAL STUDIES TANAP 11/05/2017
CINAR
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLAN FERNAS 17/06/2015
EMPLOYMENT AND TRAINING PLANS OF CCs - FRN-PLN-SOC-PL1-
001_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - EMPLOYMENT AND TRAINING PLAN PUNJ LLOYD-LIMAK JV 14/06/2016
EMPLOYMENT AND TRAINING PLANS OF CCs - PLK-PLN-SOC-PL4-
003_P4-2
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Employment and Training Plan TANAP 15-03-17
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-003- Employment and Training
Plan-P4-D
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Employment and Training Plan TANAP 19.01.2017
Report-02.03.2017 \ PR2(2.7) \ FRN-PLN-SOC-PL1-001 FERNAS
Documents 21122016\2.7 Local Hiring Plans - FRN-PLN-SOC-PL1-001- Employment and training plan (Lot 1) Worley Parsons 17/6/2015
P4-0-C1 TANAPFERNAS
Documents 21122016\1.2 Process & Timeline for transfer of Org - ENV- Environment and social remaining document
SOC REMAINING DOCUMENT REVISION STATUS 16122016 revision status
Documents 21122016\1.2 Process & Timeline for transfer of Org - ENV- Environment and social remaining document

SOC REMAINING DOCUMENT REVISION STATUS 16122016 revision status
Documents 21122016\11.1 Copies of All Presentations - EBRD-_ENV Environment Department 29/11/2016 TANAP 29/11/2016
DEPT FERNAS
ESIA – ESMS Docs – ESMP - TNP-PLN-ENV-GEN-001_P3-1 ENVIRONMENTAL & SOCIAL MANAGEMENT TANAP 21/07/2016
PLAN
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Environmental & Social Monitoring Plan TANAP 27-02-17
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-008- Environmental & Social
Monitoring Plan- P4-0
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Environmental & Social Training Plan Sapura 12-01-17
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-008- Environmental & Social Kencana
Training Plan -P4-D
ESIA – ESMS Docs – ESMP – EAP - TNP-PLN-ENV-GEN-002_P3-2 Environmental Action Plan TANAP 20/07/2016
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan - TNP- Environmental Action Plan TANAP 24/11/2014
PLN-ENV-GEN-002
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN- Environmental Action Plan Annex 2-ESMP of TANAP 20/7/2016
ENV-GEN-002 P3-2 Annexes - Annex 2-ESMP of EPCM (WRP-PLN-ENV- EPCMEnvironmental and Social Management Worley Parsons
GEN-002_P4-2) system
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN- ENVIRONMENTAL ACTION PLAN ANNEX 5 TANAP 20/7/2016
ENV-GEN-002 P3-2 Annexes\Annex 5-Sensitive Biodiversity Areas - TNP- SENSITIVE BIODIVERSITY AREAS (MS. Word)
PLN-ENV-GEN-002-P3-2_Annex 5_clean
ESIA – ESMS Docs – ESMP – EAP - Annex 1-National and Internatiol ENVIRONMENTAL ACTION PLANANNEX 1 TANAP 20/07/2016
Standards NATIONAL AND INTERNATIONAL STANDARDS
OF TANAP PROJECT
ESIA – ESMS Docs – ESMP – EAP - Annex 2-ESMP of EPCM (WRP-PLN- ENVIRONMENTAL ACTION PLANANNEX 2 ESMP WorleyParsons 11/01/2016
ENV-GEN-002_P4-2) OF EPCM
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Annex 3-CC ENVIRONMENTAL ACTION PLANANNEX 3 CC 20/07/2016
Sub-Management Plans SUB-MANAGEMENT PLANS
ESIA – ESMS Docs – ESMP – EAP - Annex 4- Environmental ENVIRONMENTAL ACTION PLANANNEX 4 24/11/2014
Management Guidelines for Contractors ENVIRONMENTAL MANAGEMENT GUIDELINES
FOR CONTRACTORS
ESIA – ESMS Docs – ESMP – EAP - Annex 5-Sensitive Biodiversity Areas ENVIRONMENTAL ACTION PLANANNEX 5 20/07/2016
- TNP-PLN-ENV-GEN-002-P3-2_Annex 5 SENSITIVE BIODIVERSITY AREAS
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN- ENVIRONMENTAL ACTION PLANANNEX 5 TANAP 20/7/2016
ENV-GEN-002 P3-2 Annexes\Annex 5-Sensitive Biodiversity Areas - TNP- SENSITIVE BIODIVERSITY AREAS (PDF)
PLN-ENV-GEN-002-P3-2_Annex 5
ESIA – ESMS Docs – ESIA – Chapter 11 Environmental and Social Management TANAP
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Environmental and Social Management Plan TANAP 31/01/2017
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-001- Environmental & Social

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Environmental Emergency Response Plan TANAP 31-10-16
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-007- Environmental Emergency
Response Plan- P4-C
Documents 21122016\3.1 Hydrotest Management Plan – Procedure - ENVIRONMENTAL HYDROTEST MONITORING TANAP 18/11/2016
SYA-PLN-ENV-PL2-001.Environmental Hydrotest Monitoring Plan PLAN Worley Parsons
SICIM – YUKSEL –
AKKORD JV
ESIA – ESMS Docs – ESMP - Env Mon Plan - TNP-PLN-ENV-GEN-003_P3- ENVIRONMENTAL MONITORING PLAN TANAP 01/07/2016
2
ESIA – ESMS Docs – ESMP - Env Mon Plan - Annex 2 - TNP-PLN-ENV- ENVIRONMENTAL MONITORING PLANANNEX 2 TANAP 01/07/2016
GEN-003-Rev-P3-1 Annex 2 ENVIRONMENTAL STANDARDS FOR
MONITORING
Documents 21122016\6.6 Records of Seed Collection - TNP-REG-ENV- Environmental monthly registers summary TANAP 26/10/2016
GEN-008_Environmental Monthly Summary Registers report – September 2016
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental Environmental Plans (ARDAHAN) TANAP 2014
Master Plan and Legends - CIN_MAP_EMP_001_01 to 001_67 CINAR
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 1 EPCM Environment and Social Management WorleyParsons 11/01/2016
System
ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.3 Erosion, Erosion Control, Reinstatement & Landscaping SYA ‐ 25/05/2015
Reinstatement and Landscaping Plan for LOT-2 Plan Sicim‐Yuksel‐Akkord JV
ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.2 Erosion, EROSION, REINSTATEMENT AND LANDSCAPING FERNAS 11/12/2015
Reinstatement and Landscaping Plan for LOT-1 PLAN
ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.5 Erosion, EROSION, REINSTATEMENT AND LANDSCAPING PUNJ LLOYD – LİMAK 06/06/2016
Reinstatement and Landscaping Plan for LOT-4 PLAN Joint Venture
Revised 12.10.2016 - Biodiverity action plan (BAP) - Annex-6_Contractor EROSION, REINSTATEMENT AND LANDSCAPING PUNJ LLOYD – LİMAK - 01/07/2016
Documents - Annex-6.5 Erosion, Reinstatement and Landscaping Plan PLAN KALYON JV
for LOT-4
Documents 21122016\10.1 NGO & International NGO TANAP Meeting ESIA of TANAP ProjectSTAKEHOLDER TANA 17/1/2014
Minutes - ERM-REP-ENV-GEN-003-Rev-P2-0_NGO Meeting Report CONSULTATION MEETINGS REPORT PERM
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ ESIA Report Summary Evaluations for Off-shore
1.1 \ Off-shore ESIA summary Section
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Evacuation Plan TANAP 21.02.2017
Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-007 FERNAS
Evacuation PLan
RAP Executive Summary Executive Summary (Natural Gas Pipeline
Project)
Revised 12.10.2016 - Executive Summary_BAP - CIN-REP-ENV-GEN-022- EXECUTIVE SUMMARY OF BAP (English Version) CINAR 10/2016

Rev-P3-C_en
Documents 21122016\4.4 Explosives Management Plan - 4.4 Explosives Explosives Management Plan
Management Plan (Read Me)
ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.3 - Expropriation Law EXPROPRIATION LAW
(2942)
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Fault Crossing Engineering Critical Assessment TANAP 27/6/2016
Stability,Surface Fault Rupture)\Fault Crossing Engineering Critical Report WorleyParsons
Assessment Report - WRP-REP-PPL-PLG-056
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Fauna (Fish and Macroinvertebrate) Survey 7/7/2013
2.4\12_Freshwater Fauna Baseline Report - 1. Fieldwork Forms Form
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Fauna (Fish and Macroinvertebrate) Survey 29/10/2013
2.4\12_Freshwater Fauna Baseline Report - 2. Fieldwork Forms Form
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Field Forms CINAR
Vibration BL Report - Annex II_Field Forms
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Field Forms_PM2_5&PM10 TANAP
Quality (PM10&PM2.5) Baseline Report - A 2 Field Forms_PM2_5&PM10
RAP for Pipeline Final Addendum to RAP for TANAP Pipeline TANAP 21/10/2016
Route (The Trans-Anatolian Natural Gas Pipeline
Project)
Addendum to RAP for Pipeline FINAL ADDENDUM TORESETTLEMENT ACTION
PLAN (RAP) FOR TANAP PIPELINE ROUTE -
EXECUTIVE SUMMARY
RAP for AGIs Final RAP for AGIs – Final Resettlement Action 24/10/2016
Plan for Above Ground Installations (The Trans -
Anatolian Natural Gas Pipeline)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Final resettlement action plan (RAP) for above TANAP 24/10/2016
Report-02.03.2017 \ PR10(10.3) \TNP-PLN-SOC-GEN-008-RAP for ground installations
AGIs_smallsize
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR FISHERIES LIVELIHOOD RESTORATION PLAN TANAP 10/05/2017
5&10\CIN-PLN-SOC-GEN-002_Offshore Fisheries LRP CINER
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Flora Field Forms 1/5/2013
2.4\15_Terrestrial Flora Baseline Report - Annex IV_Flora Field Forms
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Forest Areas TANAP
7.3.2.1
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\4.Forestry Map - Forest Map TANAP CINAR 2014
CIN_MAP_FRS_001_01 to 001_85
Revised 12.10.2016 - Biodiverity action plan (BAP) - Critical Habitats Freshwater Critical Habitats
KMZ Files

ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Freshwater Fishes TANAP
7.3.2.10
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Freshwater Habitats and Ecosystems TANAP
7.3.2.13A
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Geohazard Assessment Report TANAP 12/7/2013
Stability,Surface Fault Rupture)\Geohazard Assessment Report - ILF-
REP-ROU-PLG-005-Rev-P1-0
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Geohazard Close Out Report 48 Section TANAP 9/11/2015
Stability,Surface Fault Rupture)\Geohazard Close Out Report 48 Section WorleyParsons
- WRP-REP-EGG-PLG-026
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Geohazard Close Out Report 56 Section TANAP 9/9/2015
Stability,Surface Fault Rupture)\Geohazard Close Out Report 56 Section WorleyParsons
- WRP-REP-EGG-PLG-025
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\2.Geological Map Geologic Map and Geohazards TANAP 2014
and Geohazards - CIN_MAP_GEO_001_01 to 001_85 CINAR
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Geological Characteristics TANAP
7.3.1.3
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Governorship of Erzincan Decision of the
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 1 - Decision of provincial private security commission
Erzincan Governerate
Documents 21122016\1.6 Routing Report - Feasibility Study - TNP-GUI- Guideline for route confirmation, centreline TANAP 15/08/2012
ROU-PLG-001 design and baseline field study SOCAR
New Data 15 May 2017 \ TNP-PCD-HSM-GEN-025_Incentive programme H&S incentive programme procedure TANAP 21/04/2017
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\5.Habitat Map - Habitant Map TANAP 2014
CIN_MAP_HAB_001_01 to 001_85 CINAR
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence HEALTH AND INDUSTRIAL HYGIENE TANAP 25.04.2015
Report-02.03.2017 \ PR2(2.5)&PR4(4.1) \ FRN-PCD-HSE-PL1-045 health PROCEDURES WorleyParsons
and industrial hygiene procedure FERNAS
ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.2 - HGA Host Government Agreement between the 26/06/2012
government of the republic of Turkey and Trans
Anatolian Gas Pipeline Company B.V. Concerning
the Trans Anatolian Natural Gas Pipeline System
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Hydrogeological Characteristics TANAP
7.3.1.5
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Hydrological Characteristics TANAP
7.3.1.4
Documents 21122016\3.1 Hydrotest Management Plan – Procedure - 3.1 Hydrotest MAnagement Plan (Read me)
Hydrotest MAnagement Plan (Read me)

ESIA – ESMS Docs – ESIA – Chapter 3 IMPACT ASSESSMENT APPROACH AND TANAP
METHODOLOGY
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Impact Assessment Forms 29/5/2014
2.4\22_Terrestrial Archaeology Baseline Report - Annex 5 Impact
Asessment Forms29052014
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence INFORMATION TABE AND MACHINERY & 28/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7- SECURITY PERSONS FOR ROW SPREAD 7
28.02.2017 ROW Securi
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence INFORMATION TABE AND MACHINERY & 28/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 2-SP- SECURITY PERSONS FOR ROW SPREAD 8
8 28.02.2017 ROW
Documents 21122016\5.1 Documented Evidence of RAP Communication INFORMATIVE LEAFLET FOR COMPENSATION OF TANAP 10/2016
Consultation Disclosure - 5.1 Tanap_AGI RAP Disclosure Leaflet- LOSS OF LAND AND ECONOMIC LOSSES DUE TO
ENG_Oct2016 LAND ACQUISITION ACTIVITIES FOR ABOVE
GROUND INSTALLATIONS
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Instructions On Ways of Conduct At Main
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Access Control ID Check \ Gates
Instructions On Ways of Conduct At Main Gates
Documents 21122016\1.1 Host Gov. & Int Agreement - E&S specific Intergovernmental agreement between the
Provisions - TANAP IGA English Final 25062012 (2) government of the republic of turkey and the
government of the republic of Azerbaijan
concerning “The trans Anatolian natural gas
pipeline system”
ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.1 - IGA Intergovernmental Agreement between the
government of the Republic of Turkey and The
Government of the republic of Azerbaijan
concerning the trans Anatolian Natural Gas
Pipeline System
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Introduction of Environmental Baseline Features TANAP
7.1&7.2
ESIA – ESMS Docs – ESIA – Chapter 1 Introduction of TRANS-ANATOLIAN NATURAL TANAP
GAS PIPELINE (TANAP) PROJECT ESIA REPORT
Documents 21122016\1.3 Contractor Man. Pro & Non-Conformance Sys Item 1.3 Contractor Management Procedures
- 1.3 Contractor Man Pro & Non-Conformance System and Non-Conformance system – details of how
used and financial penalty structure
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Laboratory Competency Certificate CINAR
Quality (PM10&PM2.5) Baseline Report - A IV_Laboratory Competency
Certificate

Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Laboratory Competency Certificate
Vibration BL Report - Annex IV_Laboratory Competency Certificate
Documents 21122016\2.2 Turkish Labour Law (in English) - Turkish LABOUR LAW 22/3/2003
Labor Law
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Land Acquisition Plan TANAP 14-11-16
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-003- Land Acquisition Plan- P4-C
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.1 - Land LAND ACQUISITION STRATEGY iLF 22/08/2013
Acquisition Strategy
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\3.Land Use Map - Land Use Map TANAP 2014
CIN_MAP_LND_001_01 to 001_85 CINAR
ESIA – RAP – ANNEXES - Chp 5-Land acquisition - ANNEX 5.3 - Land LAND VALUATION MANAGEMENT PROCEDURE TANAP 21/08/2014
Valuation Management Procedure
Documents 21122016\2.2 Turkish Labour Law (in English) - Turkish Law LAW ON TRADE UNIONS AND COLLECTIVE 7/11/2012
on Unions - see article 41 LABOUR AGREEMENTS
ESIA – ESMS Docs – ESIA – Chapter 4 LEGAL, POLITICAL AND INSTITUTIONAL TANAP
FRAMEWORK
Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Liquefaction Assessment Report - Priority 1 TANAP 23/11/2015
Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 1- WorleyParsons
WRP-REP-EGG-PLG-020
Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 2 - WorleyParsons
WRP-REP-EGG-PLG-021
Wetlands & Seismic Act\Liquefaction Assessment Report - Priority 3 - WorleyParsons
WRP-REP-EGG-PLG-022
Documents 21122016\3.6 Construction Camp Site Drainage List of Requirements for Main Camps and iLF 29/05/2014
Management Process - ILF-LST-CST-GEN-001-P2-1 List of Requirements StorageYards TANAP
for Main Camps and Storage Yards
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Mammal Field Forms 1/5/2013
2.4\13_Terrestrial Fauna Baseline Report - Ek 4-Mammal Field Forms
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Mammals TANAP
7.3.2.5
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\7_Marine Mammals and Turtles Questionnaire Survey 5-6/9/2013
Fauna BL Report - Annex 2_Mammals and Turtles Questionnaire Survey Forms
Forms
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\21_Marine Marine Archaeology DesktopStudy Baseline MUSG 17/2/2014
Archaeology Desktop Study Baseline Report - Marine Archaeology Report DAGH
Desktop Study Baseline Report

Documents 21122016\1.12 Preconstruction Survey Methodology - TKF- Method Statement and Risk Assessment for Pre- TEKFEN 25/6/2015
MST-PPL-PL3-023 Construction Survey TANAP
Documents 21122016\1.12 Preconstruction Survey Methodology - FRN- Method Statement for Pre construction Activities WorleyParsons 26/10/2015
MST-PPL-PL1-001 TANAP
FERNAS
Documents 21122016\1.12 Preconstruction Survey Methodology - SYA- Method Statement:Pipeline Pre construction SICIM 11/5/2015
MST-ROW-PL2-001 survey, survey and stake out YUKSEL
AKKORD JV
TANAP
Worley Parsons
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - Mitigation Measures – Lot 2 TANAP
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN-
ENV-GEN-008_P4-0 - Appendix-2_Lot2
Documents 21122016\6.5 Completed Quarterly Third Party Monitoring MONTHLY PROGRESS REPORT CINAR TANAP 2/8/2016
Reports by ЗINAR - CIN-PRM-PRC-GEN-046_monthly report FORENVIRONMENTAL AND SOCIAL
MONITORING WORKS
Documents 21122016\6.5 Completed Quarterly Third Party Monitoring MONTHLY PROGRESS REPORT CINAR 9/12/2016
Reports by ЗINAR - CIN-PRM-PRC-GEN-051_monthly report FORENVIRONMENTAL AND SOCIAL TANAP
MONITORING WORKS
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ MS2 Heating and Cooling System Concept TANAP 10/12/2014
BAT_emission inventory and relevant evaluation data \ WRP-REP-EGG- Study – Final Report WorleyParsons
MS2-100-Rev-P3-0_heating&cooling study
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope NARROW RIDGE ASSESSMENT - ÇADIRKAYA TANAP 21/10/2015
Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 (KP410) WorleyParsons
Зadirkaya (KP410) - WRP-TNO-PPL-GEN-001
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope NARROW RIDGE ASSESSMENT - Meryem Dag TANAP 27/10/2015
Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 Meryem (KP392) WorleyParsons
Dag (KP392) - WRP-TNO-PPL-GEN-002
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope NARROW RIDGE ASSESSMENT - POSOF (KP16) TANAP 22/9/2015
Stability,Surface Fault Rupture)\Narrow Ridge Assessment %96 Posof WorleyParsons
(KP16) - WRP-TNO-PPL-GEN-005
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence NCR Register 2017
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the
Contractors-TANAP NCR Register \ NCR Register 2017_Rev0_26.02.2
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Noise & Vibration BaselineReport TANAP 24/7/2014
Vibration BL Report - 6_Noise & Vibration BL Report
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Non conformance report – Berms with stones TANAP WorleyParsons 10/05/2016
Report-02.03.2017 \ PR2(2.5)\ WRP-QAC-FRM-001-00385-P3-2

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Non-Conformance Management System TANAP 7-12-2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Procedure Sapura
Contractors-TANAP NCR Register \ SPK \ SPK-PCD-QAC-DAR-002 Kencana
ESIA – ESMS Docs – ESIA – Non-Technical Summary - Non-Technical NON-TECHNICAL SUMMARY TANAP
Summary
New Data 15 May 2017 \ Content of Compulsory HS trainings Occupational Health and Safety basic Training KURAL
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.5 Offshore Biological Impact Assessment TANAP
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ OFFSHORE HAZID CLOSE OUT REPORT TANAP 5/12/2016
1.1 \ WRP-REP-TSF-GEN-005_Offshore HAZID Worley Parsons
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Offshore Physical Characteristics TANAP
7.3.4
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.4 Offshore Physical Impact Assessment TANAP
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence OFFSHORE PROJECT QUALITY PLAN (PQP) TANAP 10-10-2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Sapura
Contractors-TANAP NCR Register \ SPK \ SPK-PLN-QAC-DAR-001 Kencana
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH- Onshore Biological Characteristics - Biological TANAP
8.2.5-11 Features – Terrestrial Fauna
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH- Onshore Biological Characteristics - Biological TANAP
8.2.1-4 Features - Terrestrial Flora
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan - 1.7 Onshore Fuel & Chemical Spill Plan TANAP
Onshore Fuel & Chemical Spill Plan (Read me)
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ ONSHORE HAZID CLOSE OUT REPORT TANAP 29/11/2016
WRP-REP-TSF-GEN-030_Onshore HAZID WorleyParsons
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Onshore Pipeline: Hydrological Assessment TANAP 27/10/2015
Stability,Surface Fault Rupture)\Onshore Pipeline River Crossing Methodology WorleyParsons
Methodology - WRP-MAN-EGG-PLG-001
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Onshore Pipeline: Watercourse Crossing TANAP 26/3/2015
Stability,Surface Fault Rupture)\Onshore Pipeline Watercourse Crossing Philosophy WorleyParsons
Philosophy - WRP-PHL-EGG-PLG-001
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Onshore Route and Geohazard Assessment BECHTEL 2/4/2014
Stability,Surface Fault Rupture)\Onshore Route and Geohazard Report TANAP
Assessment Report - BCH-REP-EGG-PLG-008-Rev-P2-0 iLF
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Other Archaeological Sites List
2.4\22_Terrestrial Archaeology Baseline Report - Annex 4 Other
Archaeological Sites List
Documents 21122016\5.4 Identification of Land Parcels size and location Parcel size and locations for existing and future
for future Compressor - 5.4 Identification of Land Parcels Size and compressor stations and pig launching and
Location for future Compressor Station receiving pads.

Documents 21122016\6.1 Description of Timing and Baseline Survey PERFORMANCE REQUIREMENT 6
Methodologies - revision status regarding requested items
ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.5 - IFC Performance Performance Standard 5 Land Acquisition and International Finance 01/01/2012
Standard 5 Involuntary Resettlement Corporation
Documents 21122016\4.10 Permit to Work Descriptions - 4.10 Permit To PERMIT TO WORK PROCEDURE (LOT2) SICM 30/3/2016
Work YUKSEL
AKKORD JV
TANAP
Worley Parsons
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 Photos
\Waste Facility Inspection Report \ Annex3_photos
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ Security
Cabins placed (1) (2) and alo
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos - Gendarmerie Training Dutluca
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ Eskiюehir 2017
Gendarmerie Training Dutluca Eskiюehir 2017 \ E__T_M G_RSEL (1)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos - Doрankent 1, 2, 3
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ VPSHR TRAINING \ SPREAD 5 –
DOGANKENT \ Doрankent 1, 2, 3
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos - Polatlэ-1, 2, 3, 4
POLATLI \ Polatlэ-1, 2, 3, 4
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos - Training Dutluca Eskiюehir 2017
ROW Security Training Dutluca Eskiюehir 2017 \ IMAG4304 and
IMAG4308
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Photos - Trainings in Gцnen-Karaorman 2016
ROW Security Training Dutluca Eskiюehir 2017 \ Trainings in Gцnen-
Karaorman 2016 \ IMG-20161122-WA0000, 02, 05, 08, 16,22, 24
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix- Photos of first field survey 2013
2.6.3. Biological Baseline Studies\Freshwater Habitat and
Ecosystems\First field survey
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix- Physical Baseline Studies CINAR
2.6.2. Physical Baseline Studies - 2. Physical Baseline Studies
Documents 21122016\1.12 Preconstruction Survey Methodology - WRP- Pipeline Construction Specification TANAPWorley Parsons 20/5/2016
SPC-PPL-PLG-001 Pipeline Construction Specification P4-4

Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Pipeline Stress Analysis Report TANAP 26/11/2015
Wetlands & Seismic Act\Pipeline Stress Analysis Report - WRP-REP-PPL- WorleyParsons
PLG-003
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PLK -LOT 4-SPREAD 7 SİTE PLUS DAILY Punj Lioyd 28/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7- SECURITY REPORT (DSR) Limak
28.02.2017 Daily Secu Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PLK -LOT 4-SPREAD 8 SİTE PLUS DAILY Punj Lioyd 27/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 1 -SP - SECURITY REPORT (DSR) Limak
8 28.02.2017 Dai Kalyon
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Pollution Prevention Plan TANAP 15-03-17
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-005- Pollution Prevention Plan-P4-D
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\23_Eco- POSOF WDA ECOSYSTEM ASSESSMENTREPORT 2014
system Evaluation Report - Eco-system Evaluation Report
Documents 21122016\1.12 Preconstruction Survey Methodology - Pre- Preconstruction survey methodology
Construction Survey Note
Documents 21122016\1.12 Preconstruction Survey Methodology - Pre- Preconstruction survey methodology (PDF)
Construction Survey Note
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Probabilistic Seismic Hazard Assessment Report TANAP 14/9/2015
Stability,Surface Fault Rupture)\Probabilistic Seismic Hazard Assessment - Pipeline WorleyParsons
Report – Pipeline - WRP-REP-EGG-GEN-026
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Probabilistic Seismic Hazard Assessment Report TANAP 14/9/2015
Stability,Surface Fault Rupture)\Probabilistic Seismic Hazard Assessment - Stations WorleyParsons
Report – Stations - WRP-REP-EGG-GEN-028
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PROCEDURE FOR CONTROL OF NON TANAP WorleyParsons 08.07.15
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the CONFORMANCEPREVENTATIVE AND FERNAS
Contractors-TANAP NCR Register \ FRN \ FRN-PCD-QAC-PL1-004 CORRECTIVE ACTION
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PROCEDURE FOR CONTROL OF NON- TANAP 25.01.2017
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the CONFORMANCES, CORRECTIVE AND Punj Lioyd
Contractors-TANAP NCR Register \ PLK \ PLK-PCD-QAC-PL4-001 PREVENTIVEACTIONS Limark
Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Procedure for Corrective, Preventive Action TANAP 11/09/2015
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the andControl of Non-Conformance WorleyParsons
Contractors-TANAP NCR Register \ TKF \ TKF-PCD-QAC-PL3-010 Tekfen
Documents 21122016\5.6 Land Entry Exit Procedure Examples - 5.6 Procedure for Land Delivery, Entry and Exit TEKFEN 19/11/2015
SAMPLE LAND ENTRY - EXIT PROCEDURE_ TANAP
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PROCEDURE FOR MANAGEMENT OF NON TANAP 01/07/2015
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the CONFORMITYCORRECTIVE & PREVENTIVE WorleyParsons
Contractors-TANAP NCR Register \ SYA \ SYA-PCD-QAC-GEN-001 ACTIONS SICIM

YUKSEL
AKKORD JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Procedure for Non-Conformance Management TANAP 08.11.2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Tekfen
Contractors-TANAP NCR Register \ TKN \ TKN-PCD-QAC-GEN-075
Documents 21122016\3.8 Procedures for Physical & Final Procedures for Physical & Final reinstatement
Reinstatement - 3.8 Procedures for Physical & Final reinstatement (Read (Read me)
me)
Documents 21122016\3.7 Procedures for Testing of Excess Excavation Procedures for Testing of Excess Excavation
Dredging Spoil - 3.7 Procedures for Testing of Excess Excavation Dredging Spoil (Read me)
Dredging Spoil (Read me)
Documents 21122016\6.7 Procedures Management Plan for Invasive Procedures Management Plan for Invasive
Species - 6.7 Procedures Management Plan for Invasive Species (Read Species (Read me)
me)
Documents 21122016\1.2 Process & Timeline for transfer of Org - 1.2 Process & Timeline for Transfer of Organisation
Process & Timeline for Transfer of Organisation (Read Me)
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - Procurement & Supply Management Plan SYA ‐ 21/05/2015
PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - SYA-PLN- Sicim‐Yuksel‐Akkord JV
SOC-GEN-003_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - Procurement and Supply Management Tekfen 11/12/2015
PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - TKF-PLN-
ENV-PL3-017_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - PROCUREMENT AND SUPPLY MANAGEMENT FERNAS 17/06/2015
PROCUREMENT AND SUPPLY MANAGEMENT PLANS OF CCs - FRN-PLN- PLAN
SOC-PL1-002_P4-0
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Procurement and Supply Management Plan TANAP 21-11-16
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-004-Procurement and Supply
Management Plan- P4-C
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Project Basis of Design TANAP 4/5/2016
Stability,Surface Fault Rupture)\Project Basis of Design - WRP-REP-EGG- WorleyParsons
GEN-003
ESIA – ESMS Docs – ESMP - Env Mon Plan - Annex 1 - TNP-REG-ENV- Project Environment and Social Commitments TANAP 23/06/2016
GEN-003-Rev-P3-1 Register
Revised 12.10.2016 -Commitment Register - TNP-REG-ENV-GEN-003- Project Environmental and Social TANAP 12/10/2016
Rev-P3-3 CommitmentsRegister
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Environmental and Social TANAP 29.08.2016
Report-02.03.2017 \ PR1(1.7) \ TNP-PLN-ENV-GEN-003_Annex 1 CommitmentsRegister
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ PROJECT EXECUTION PLAN TANAP 9/2012

1.1 \ CC- ESMS \ CIN-PLN-ENV-GEN-001-Rev-P1-0_PEP_ESIA.Org. chart CINAR
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ PROJECT EXECUTION PLAN (PEP)THIRD PARTY TANAP 24/02/2017
1.4 \ CIN-PLN-ENV-GEN-002_Rev-P3-3_PEP_TPMC.Org.chart ENVIRONMENTAL AND SOCIAL MONITORING CINAR
SERVICES
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ PROJECT EXECUTIONPLAN TANAP 9/2012
1.4 \ CIN-PLN-ENV-GEN-001-Rev-P1-0_PEP_ESIA.Org. chart CINAR
SOCAR
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Nonconformity Management Procedure TANAP WorleyParsons 22.06.16
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the ABB
Contractors-TANAP NCR Register \ ABB \ ABB-PCD-QAC-GEN-003
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Quality Management Plan TANAP 20/04/2015
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the WorleyParsons
Contractors-TANAP NCR Register \ SYA \ SYA-PLN-QAC-GEN-001 SICIM
YUKSEL
AKKORD JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PROJECT QUALITY PLAN TANAP 07.05.2015
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the WorleyParsonsFERNAS
Contractors-TANAP NCR Register \ FRN \ FRN-PLN-QAC-PL1-001
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence PROJECT QUALITY PLAN TANAP 20/06/2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Punj Lioyd
Contractors-TANAP NCR Register \ PLK \ PLK-PLN-QAC-PL4-001 Limark
Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Quality Plan TANAP 07.11.2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the Tekfen
Contractors-TANAP NCR Register \ TKN \ TKN-PLN-QAC-GEN-001
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Quality Plan (PQP) TANAP WorleyParsons 22/11/2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the ABB
Contractors-TANAP NCR Register \ ABB \ ABB-PLN-QAC-GEN-001
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Project Specific Quality Plan (PSQP) TANAP 14.05.2016
Report-02.03.2017 \ PR1(1.6) \ Quality Plans & NCR Procedures of the WorleyParsons
Contractors-TANAP NCR Register \ TKF \ TKF-PLN-QAC-PL3-001 Tekfen
New Data 15 May 2017 \ 17.05.11 Project Status and Progress on ESIA TANAP 11/05/2017
TANAP_EBRD_Presentation_2017.05.09 Implementation EBRD - TANAP – TPMC
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Protected and Sensitive Habitats TANAP
7.3.2.2
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Protected areas TANAP
7.3.2.15A
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Protected Areas (In the scope of the list of TANAP

7.3.1.7 buffer regions in Annex V)
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\8.Protected Areas Protected Areas and high biodiversity area Map TANAP 2014
Map - CIN_MAP_PAR_001_01 to 001_08 CINAR
Documents 21122016\1.9 Pipe Supply Contract and Prequalication Questionnaires (Prequalification for Line Pipe)
Requirements - Annex 2 - Questionnaires
Documents 21122016\5.7 RAP Fund Strategy - 5.7 RAP Fund RAP Fund Strategy (Read Me )
Strategy (Read Me )
ESIA – RAP – ANNEXES - Chp 4 - Project Affected Population - ANNEX RAP of TANAP Project - METHODOLOGY FOR Golder Associates 19/02/2014
4.2 - Socioeconomic Survey Methodology SOCIOECONOMIC SURVEY
Documents 21122016\5.2 Initial Draft of the Livelihood Restoration Plan Read me - Initial Draft of the Livelihood
- 5.2 Initial Draft of the Livelihood Restoration Plan (Read me) Restoration Plan
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ Read me - Notepad
BAT_emission inventory and relevant evaluation data \ Read me
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Read Me 10.3 TANAP
Report-02.03.2017 \ PR10(10.3) \ Read Me 10.3
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Read Me 2.7 Social Management Plans
Report-02.03.2017 \ PR2(2.7) \ Read Me 2.7
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Read me 3.2
Report-02.03.2017 \ PR3(3.2) \ Read me 3.2
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Read Me 6.11
Report-02.03.2017 \ PR6(6.11) \ Read Me 6.11
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Read Me PR1
Report-02.03.2017 \ PR1(1.6) \ Read Me PR1 (1.6)
Documents 21122016\6.1 Description of Timing and Baseline Survey Read me: Description of Timing and Baseline
Methodologies - 6.1 Description of Timing and Baseline Survey Survey Methodolgies
Methodolgies (Read me)
Documents 21122016\8.4 Documented Evidence of Identified Disturbed Read me: Documented Evidence of Identified
Graveyards - 8.4 Documented Evidence of Identified Disturbed Disturbed Graveyards
Graveyards (Read me)
Documents 21122016\6.3 Meth. used for the App. Assessment of Read me: Meth. used for the App. Assessment of
Biodiversity Impacts - 6.3 Meth. used for the App. Assessment of Biodiversity Impacts
Biodiversity Impacts (Read me)
Documents 21122016\6.8 Method Statement for Tree Cutting and Read me: Method Statement for Tree Cutting
Replanting - 6.8 Method Statement for Tree Cutting and Replanting and Replanting
(Read me)
Documents 21122016\6.2 The Methodology for Assessment of the Read me: The Methodology for Assessment of
current status of the Habitats - 6.2 The Methodology for Assessment of the current status of the Habitats
the current status of the Habitats (Read me)

ESIA – ESMS Docs – ESIA – Chapter 5 REASONS FOR THE ROUTE SELECTION AND TANAP
EVALUATION OF ALTERNATIVES
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - RECRUITMENT AND WORKERS MANAGEMENT SYA ‐ 21/05/2015
EMPLOYMENT AND TRAINING PLANS OF CCs - SYA-PLN-SOC-GEN- PLAN Sicim‐Yuksel‐Akkord JV
004_P4-0
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope REINSTATEMENT AND EROSION CONTROL TANAP 25/9/2014
Stability,Surface Fault Rupture)\Reinstatement and Erosion Control REQUIREMENTS WorleyParsons
Requirements - WRP-REP-EGG-GEN-004-Rev-P3-0
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope REINSTATEMENT AND EROSION CONTROL TANAP 1/9/2015
Stability,Surface Fault Rupture)\Reinstatement and Erosion Control REQUIREMENTS FOR THE 48" PIPE WorleyParsons
Requirements for the 48 Pipe - WRP-REP-EGG-GEN-027
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence REPORT FOR ESIA DISCLOSURE MEETING TANAP 25/11/2014
Report-02.03.2017 \ PR10(10.3) \ REPORT FOR ESIA DISCLOSURE CINAR
MEETINGS
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Reptile and Amfibi Field Forms 1/5/2013
2.4\13_Terrestrial Fauna Baseline Report - Ek 6 -Reptile and Amfibi Field
Forms
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Reptiles TANAP
7.3.2.7
ESIA – RAP - GLD-PLN-LAC-GEN-003_P3-1 Resettlement Action Plan (RAP) for TANAP Golder Associates 05/10/2015
Project
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR Resettlement Action Plan (RAP) TANAP 12/05/2017
5&10\TNP-PLN-SOC-GEN-010 RAP Monitoring Plan Monitoring Plan
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- Revised Version of Biodiversity Action Plan TANAP 02/05/2017
GEN-017-Rev-P3-10 \ TANAP-CIN-TRA-TNP-0493 CINAR
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Row security personnel control schedule 07- 08
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ /02/2017
SPREAD 7 Night Push to Tal
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Row security personnel control schedule 26 – 27
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ /02/2017
SPREAD 7 Night Push to (1)
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Schedule of Accreditation UKAS 31/10/2011
Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex III_GRADKO
Laboratory Accreditation Certificate
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\1_Sea Sea Water and Sediment QualityBaseline Report TANAP 2/6/2014
Water and Sediment Quality BL Report - Sea Water&Sediment Quality
Report
New Data 15 May 2017 \ TNP-PRE-SEC-GEN-007-EBRD 11.05.2017 Security Department TANAP 11/05/2017

New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Security Licenses and permits SICIM 04/06/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 04 TANAP-SYA-LET-WRP-0172 YUKSEL
AKKORD JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Security Management Plan TANAP 21.02.2017
Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ FRN-PLN-SEC-PL1-001 Security FERNAS
Management Plan (Rev.2)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SECURITY MANAGEMENT PLAN TANAP 14/08/15
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ SYA-PLN-SEC-PL2-001 WorleyParsons
SYA ‐
Sicim‐Yuksel‐Akkord JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SECURITY MANAGEMENT PLAN TANAP 22.09.2016
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ PLK-PLN-SEC-PL4-002 Punj Lioyd
Limak
Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Security Management Plan WorleyParsons 07/06/2016
Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Management Plan TANAP
347 TAFFEN
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SECURITY RISK ASSESSMENT TANAP 25.02.2017
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 13 Security Risk Assessment SICIM
YUKSEL
AKKORD JV
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Security Training Plan
Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Training Plan
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Site Plus Security Exercises Plan
Report-02.03.2017 \ PR2(2.10) \ Stations \ Security Exercises Plan
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (CS - 5) TANAP 17/01/2017
TNP-HSM-FRM-015-00008 Site Safety Inspection Report for CS5
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (CS 1) TANAP 21/12/2016
TNP-HSM-FRM-015-00001 Site Safety Inspection Report for CS1
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Lot 1 / Spead TANAP 23/12/2016
TNP-HSM-FRM-015-00006 Site Safety Inspection Report for LOT1 - 2 IIica Camp)
Spread 2 - Ilэca Camp
TNP-HSM-FRM-015-00005 Site Safety Inspection Report for LOT1 - 2 Pasinler Camp)
Spread 2 - Pasinler Camp
TNP-HSM-FRM-015-00007 Site Safety Inspection Report for LOT1 - 9 Refahiye Camp)
Spread 9 - Refahiye Camp

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Lot 1 / TANAP 20/12/2016
TNP-HSM-FRM-015-00003 Site Safety Inspection Report for LOT1 - Spread 1 Posof region)
Spread 1 - Posof Camp
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Lot 1 / TANAP 19 -
TNP-HSM-FRM-015-00004 Site Safety Inspection Report for LOT1 - Spread 1 Selim Camp) 21/12/2016
Spread 1 - Selim Camp
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 Site safety inspection report form (MS - 1 Camp TANAP 19-
\TNP-HSM-FRM-015-00024 Site Safety Inspection Report for MS1 Camp Site) 20/03/2017
site
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (MS 1 Camp TANAP 20/12/2016
TNP-HSM-FRM-015-00002 Site Safety Inspection Report for MS1 Camp Site)
site
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 Site safety inspection report form (SP-7 Dutluca TANAP 29/03/2017
\TNP-HSM-FRM-015-00029 Site Safety Inspection Report for SP-7 Camp Site)
Dutluca Camp site
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (SP-8 Iiicak TANAP 28/03/2017
TNP-HSM-FRM-015-00027 Site Safety Inspection Report for SP-8 Ilэcak Camp Site)
Camp site
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 Site safety inspection report form (SP-8 TANAP 28/03/2017
\TNP-HSM-FRM-015-00028 Site Safety Inspection Report for SP-8 Karaorman Camp Site)
Karaorman Camp site
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Spread 3 - TANAP 24/01/2017
TNP-HSM-FRM-015-00012 Site Safety Inspection Report for Spread-3 Kelkit Fly Camp)
KELKЭT Fly Camp
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Spread 3) TANAP 23/01/2017
TNP-HSM-FRM-015-00011 Site Safety Inspection Report for Spread-3
ЗADIRKAYA Camp
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 Site safety inspection report form (Spread 4 - TANAP 25/01/2017
\TNP-HSM-FRM-015-00013 Site Safety Inspection Report for Spread-4 Hafik Camp)
HAFЭK Camp
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 Site safety inspection report form (Spread 5) TANAP 26/01/2017
\TNP-HSM-FRM-015-00010 Site Safety Inspection Report for LOT3 -
Spread 5 …
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ HS 4.1 \ Site safety inspection report form (Spread 6) TANAP 18/01/2017
TNP-HSM-FRM-015-00009 Site Safety Inspection Report for LOT3 -
Spread 6 …
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Slope Assessment Report - Priority 1 Areas TANAP 26/3/2015
Stability,Surface Fault Rupture)\Slope Assessment Report %96 Priority 1 WorleyParsons

Areas - WRP-REP-EGG-PLG-010
ESIA – ESMS Docs – ESMP - Social Action Plan - TNP-PLN-SOC-GEN- SOCIAL ACTION PLAN TANAP 15/07/2016
002_P3-1
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 3 SOCIAL ACTION PLANANNEX 3 SOCIAL 15/07/2016
MANAGEMENT GUIDELINES FOR CONTRACTORS
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social Social Baseline Report AYDSFIDG 24/3/2014
Baseline Report - Social Baseline Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\20_Social SOCIAL IMPACT ASSESSMENT TANAP 2013
Baseline Report - APPENDIX 1F HOUSEHOLD QUESTIONNAIRE_AGI STUDYHOUSEHOLD QUESTIONNAIRE (FOR
AGI’s)
Baseline Report - APPENDIX 1E HOUSEHOLD QUESTIONNAIRE_ROUTE STUDYHOUSEHOLD QUESTIONNAIRE(ROUTE
SURVEY)
Baseline Report - APPENDIX 1C SETTLEMENT QUESTIONNARE_AGI STUDYSETTLEMENT QUESTIONNAIRE (FOR
AGI’s)
Baseline Report - APPENDIX 1D SETTLEMENT STUDYSETTLEMENT QUESTIONNAIRE (FOR
QUESTIONNARE_ESKISEHIR OFF TAKE ESKISEHIR CONNECTION)
Baseline Report - APPENDIX 1B SETTLEMENT QUESTIONNAIRE_PHONE STUDYSETTLEMENT QUESTIONNAIRE (PHONE
INTERVIEW INTERVIEW)
Baseline Report - APPENDIX 1A SETTLEMENT QUESTIONNAIRE_ROUTE STUDYSETTLEMENT QUESTIONNAIRE(ROUTE
SURVEY)
ESIA – ESMS Docs – ESIA – Chapter 8 - TNP-REP-ENV-GEN-002_CH-8.6 Social Impact Assessment-Offshore TANAP
ESIA – ESMS Docs – ESMP - Social Monitoring Plan - TNP-PLN-SOC-GEN- SOCIAL MONITORING PLAN TANAP 18/07/2016
003_P3-1
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix- Socio-economic Baseline Studies
2.6.4. Socio-economic Baseline Studies - 4. Socio-economic Baseline
Studies
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Soil Characteristics TANAP

7.3.1.2
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\3_Soil Soil Contamination Baseline Study Report TANAP 24/7/2014
Contamination Baseline Study Report - Soil Contamination BL Rep.
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SOPs Standart Operating Procedures – Site
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 12 Standard Operating Security Likely scenarios & course of action
Procedures (Sample)
Documents 21122016\3.3 Specific Process Used to Calculate Sulphides SPECIFICATION FOR PHASE 3 SUBSURFACE TANAP 27/8/2015
in Soil - WRP-SPC-EGG-GEN-010 INVESTIGATION WORKS Worley Parson
ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.1 Specification for Specification for Reinstatement Worley Parsons 26/11/2015
Reinstatement
Documents 21122016\6.1 Description of Timing and Baseline Survey Specification for Reinstatement Worley Parsons 26/11/2015
Methodologies\BAP\Annex-6 - Annex-6.1 Specification for Reinstatement TANAP
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 6 \ Specification for Reinstatement TANAP 26-11-15
CIN-REP-ENV-GEN-017-Rev-P3-9 \ Annex-6 \ Annex-6.1 Specification for WorleyParsons
Reinstatement
New Data May 4 2017 \ 2 May 2017 Documentation \ CIN-REP-ENV- Specification for Reinstatement WorleyParsons 26/11/2015
GEN-017-Rev-P3-10 \ Annex-6 \ Annex-6.1 Specification for TANAP
Reinstatement
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ Annex 6 \ Specification for Reinstatement TANAP 26/11/2015
Annex-6.1 Specification for Reinstatement WorleyParsons
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SPREAD 5 DOРANKENT CAMP CCTV LAYOUT Bordoter
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ SPREAD 5 DOРANKENT CAMP PLAN
CCTV LAYOUT PLAN
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SPREAD 6 POLATLI CAMP CCTV LAYOUT PLAN Bordoter
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ SPREAD 6 POLATLI CAMP CCTV
LAYOUT PLAN
ESIA – ESMS Docs – ESIA – Chapter 6 STAKEHOLDER ENGAGEMENT TANAP
Documents 21122016\11.2 Updated SEP - TNP-PLN-SOC-GEN-001-Rev Stakeholder Engagement Plan TANAP 26/10/2016
P3-1
New Data May 4 2017 \ TNP-PLN-SOC-GEN-001-Rev P3-2 Stakeholder Engagement Plan TANAP 30/01/2017
Documents 21122016\11.2 Updated SEP - Annex 1_Stakeholder STAKEHOLDER ENGAGEMENT PLANANNEX 1 TANAP 26/10/2016
Engagement Implementation Guideline For Construction Phase STAKEHOLDER ENGAGEMENT
IMPLEMENTATIONGUIDELINE FOR
CONSTRUCTION PHASE
Stakeholder Engagement Plan StakeholderEngagement Plan Golder Associates 18/8/2013
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - StakeholderEngagement Plan Golder Associates 18/08/2013
APP 3.2a-Stakeholder Engagement Plan
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Statement of compliance

Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 5 Statement of
compliance SITE PLUS
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Station Report: Measurement results for SO2, 2010-2013
Quality (PM10&PM2.5) Baseline Report - A IV_2010-2013_Measurement PM10 and NOX
Results
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air Station Report: Measurement results for SO2, 2010 – 2013
Quality (SO2, NOX, O3) Baseline Report\ANNEXES - Annex PM10 and NOX
V_Measurement Results (Canakkale_Biga)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Station Risk Analysis and Assessment results TANAP 01/03/2017
Report-02.03.2017 \ PR2(2.10) \ Stations \ Risk Assessment-Feb 2017
Documents 21122016\1.8 Status of Current Emergency Response Plans Status of Current Emergency Response Plans
- 1.8 Status of Current Emergency Response Plans (Read me)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Stop Work Notice TANAP 23/09/2016
Report-02.03.2017 \ PR2(2.5)\ TANAP-TNP-LET-FRN-0055
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence SUBCONTRACTOR AGREEMENT 25/05/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ TANAP-FRN-LET-WRP-0116 -
Submission for Subcontractor Agreement
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Subcontractor list SICIM 06/03/2015
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 01 TANAP-SYA-LET-WRP-0048 YUKSEL
(1) AKKORD JV
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\2_Surface Surface Water Quality Baseline Report TANAP 2/6/2014
Water Quality Baseline Report - Surface Water BL Rep.
Documents 21122016\4.1 Detailed Incident Analysis Reports - SYA Fatal SYA FATAL CRASH INCIDENT EXECUTIVE 5/9/2016
Crash Executive Sum._Rev.0 REPORT
ESIA – ESMS Docs – ESIA - TOC Table of content TANAP
ESIA – ESMS Docs – ESIA – Chapter 7 - Index Table of content of Chapter 7: Environmental TANAP
Baseline Features
ESIA – ESMS Docs – ESIA – Chapter 8 – Chapter 8_Index Table of content of chapter 8 – Impact TANAP
Assessment
New Data 15 May 2017 \ TANAP-TNP-LET-SYA-0093_submission of TANAP Assurance Review Report Findings TANAP 14/11/2016
assurance review report_Lot 2
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage TANAP Change Find Requirements TANAP 19/07/2016
Management Plan - Annex A - TNP-PCD-ENV-GEN-006
Documents 21122016\2.4 Labour Data Breakdown - 2.4 TANAP TANAP Contractor Employees ( As of 01 TANAP 1/12/2016
Contractor Employment Status ( As of 01 December 2016) December 2016)
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ TANAP TANAP coomments 24052017 TANAP 24/05/2017
comments 24052017
Documents 21122016\2.6 TANAP HR Audit on Subcontractors - 2.6 TANAP HR Audit on Subcontractors

TANAP HR Audit on Subcontractors (Read me)
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence TANAP ISSUES REQUIRING ADDITIONAL TANAP
Report-02.03.2017 \ 17.01.03 EBRD TANAP ISSUES REQUIRING INFORMATION AND CLARIFICATION Latest
ADDITIONAL INFORMATION AND CLARIFICATION Latest
Documents 21122016\2.7 Local Hiring Plans - HZR-REP-SOC-GEN-001 TANAP Manpower Baseline report TANAP 11/12/2015
HAZAR STRA
TEJI
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - TANAP PROJECT APPENDIX 3.2b- STAKEHOLDER
APP 3.2b-Stakeholder Register LIST
Documents 21122016\4.1 Detailed Incident Analysis Reports - TANAP PROJECT INCIDENT EXECUTIVE REPORT 3/2016
Executive-OHPL 16.03.2016 (overhead powerline Arc)
Documents 21122016\4.1 Detailed Incident Analysis Reports - Executive TANAP PROJECT INCIDENT EXECUTIVE REPORT 3/2016
Summary-Tire Burst 09.03.2016 (rollover of machinery)
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ TANAP PROJECT RESETTLEMENT ACTION PLAN TANAP 30/03/2017
TNP-REP-SOC-GEN-001 RAP Q1 Internal Monitoring Report (RAP) 1ST QUARTERLY INTERNAL MONITORING
REPORT (MARCH 2017)
Documents 21122016\2.5 Procedures for Third Party Monitoring on TANAP PROJECT SITE CONTROL PROCEDURE 01/03/2016
Labour - TANAP PROJECT SITE AUDIT PROCEDURE
New Data 15 May 2017 \ SOC_Presentation Social_11052017 TANAP PROJECT SOCIAL IMPACT MANAGEMENT TANAP 11/05/2017
Documents 21122016\4.1 Detailed Incident Analysis Reports - Executive TANAP PROJECT TRAFFIC INCIDENT EXECUTIVE 2/2016
Summary-Railway 03.02.2016 REPORT
Documents 21122016\11.1 Copies of All Presentations - TANAP EBRD TANAP project update TANAP 11/2016
Presentation
EXECUTIVE-SUMMARY-ENG-No-Memo-07262016 TANAP Project’s Executive Summary of ESIA and TANAP 22/7/2016
Supporting Environmental and Social Safeguard
Documents
ESIA - Executive Summary - EXECUTIVE SUMMARY_ENG TANAP Project’s Executive Summary of ESIA and TANAP 22/07/2016
Supporting Environmental and Social Safeguard
Documents FOR SUBMISSION TO WORLD
BANK’S BOARD AS PER PELOSI REQUIREMENT
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ TANAP Response: TANAP 24/05/2017
EBRD.ESAP.TANAPresponse.24.05.2017 APPENDIX C: ENVIRONMENTAL AND SOCIAL
ACTION PLAN
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \ TANAP response: Final Report of the TANAP 24/05/2017
EBR014_TANAP ESDD Report_Rev2.TANAP.response.24.05.2017 Independent Environmental and social
consultant 24/05/2017
ESIA – ESMS Docs – ESIA – Chapter 13 (Appendices) – Appendix 3 - TANAP Trans Anatolian Natural Gas Pipeline – TANAP
APP 3.2c-Project Brochure The path of energy and cooperation

ESIA – RAP – ANNEXES - Chp 7 – Consultation - App 7.1 GLAC rev P3-1 TANAP TRANS ANATOLIAN NATURAL GAS 06/2014
PIPELINEGUIDE TO LAND ACQUİSİTİON AND
COMPENSATİON
Documents 21122016\11.1 Copies of All Presentations - TANAP: LOT 1 29/11/2016
Presentation_29.11.2016
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - TANAPTRANS ANATOLIAN NATURAL GAS TANAP
CONSTRUCTION IMPACTS MANAGEMENT PLANS OF CCs - SYA-PLN- PIPELINE PROJECT – LOT 2
ENV-GEN-008_P4-0 - Appendix-1_all_maps
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ Technical bid evaluation report emission values
BAT_emission inventory and relevant evaluation data \ WRP-REP-MEC-
GEN-001-P3-2. Technical bid evaluation report.emission values
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ Technical Note Compressor Stations Waste Heat TANAP 06/08/2015
BAT_emission inventory and relevant evaluation data \ WRP-TNO-PRS- Recovery WorleyParsons
CSG-002_waste heat recovery
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope TECHNICAL NOTE FOR DESIGN OF PIPELINES IN TANAP 24/6/2015
Stability,Surface Fault Rupture)\Technical Note for Design of Pipelines in KARST WorleyParsons
Karst - WRP-TNO-EGG-PLG-001
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Technical Specification for Seismic Trenches 4/2/2016
Stability,Surface Fault Rupture)\Technical Specification for Seismic
Trenches - WRP-SPC-PPL-PLG-005
ESIA – ESMS Docs – ESMP – EAP - Annex 3-CC Sub EMPs - Aggregates TEKFEN Aggregates Management Plan Tekfen 29/04/2015
Man. Plan - TKF-PLN-ENV-PL3-011_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY TEKFEN Community Relations Plan Tekfen 21/05/2015
RELATIONS PLANS OF CCs -TKF-PLN-ENV-PL3-015_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - COMMUNITY TEKFEN Community Safety Management Plan Tekfen 21/05/2015
SAFETY MANAGEMENT PLANS OF CCs - TKF-PLN-ENV-PL3-014_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - Tekfen Employment and Training Plan Tekfen 08/06/2015
EMPLOYMENT AND TRAINING PLANS OF CCs - TKF-PLN-ENV-PL3-
016_P4-0
ESIA – ESMS Docs – BAP – BAP- Annex 6 - Annex-6.4 Erosion, Tekfen Erosion, Reinstatement and Landscaping Tekfen 30/06/2015
Reinstatement and Landscaping Plan for LOT-3 Plan
Documents 21122016\6.1 Description of Timing and Baseline Survey TEKFEN Erosion, Reinstatement and TEKFEN 30/6/2015
Methodologies\BAP\Annex-6 - Annex-6.4 Tekfen Erosion Control and Landscaping Plan TANAP
Stabilisation Plan for LOT-3
Documents 21122016\3.1 Hydrotest Management Plan – Procedure - TEKFEN Hydrostatic Test Environmental TEKFEN 5/12/2016
TKF-PLN-ENV-PL3-022.Environmental Hydrotest Monitoring Plan Monitoring Plan TANAP
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence TEKFEN Project Security Management Plan TANAP 15.12.2016
Report-02.03.2017 \ PR2(2.10) \ Lot 3 \ TKF-PLN-SEC-PL3-001-P4-2 TEKFEN

(SECURITY MANAGEMENT PLAN)
BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\ Terms of Reference for Appeals Committee 1/01/2017
Appeals Committee \ToR_TANAP_Appeals Committee Experts Experts
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Terrestrial Archaeology BaselineReport SAVB 24/7/2014
2.4\22_Terrestrial Archaeology Baseline Report - Terrestrial Archaeology
Baseline Report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX Terrestrial Archaeology PHOTOs
2.4\22_Terrestrial Archaeology Baseline Report\PHOTO_29052014
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Terrestrial Habitats and Ecosystems TANAP
7.3.2.12A
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Terrestrial Invertebrates TANAP
7.3.2.9
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Terrestrial Vegetation TANAP
7.3.2.3
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Test results of Calibration AVL 19/6/2013
Vibration BL Report - A 4 SVAN 958
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Test results of Calibration Protos 30/10/2013
Vibration BL Report - A 4 SVAN 958 1
ESIA – RAP – ANNEXES - Chp 3 – Legal - ANNEX 3.4 - Equator Principles THE EQUATOR PRINCIPLES Equator Principles 06/2013
Financial Institutions
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence THEORETICALLY AND PRACTICALLY SECURITY Site Plus 22/11/2016
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ EDUCATION TANAP
Karaorman 2016 \ Inspection Notes
Documents 21122016\11.1 Copies of All Presentations - 3rd Party Third Party Environmental & Social Monitoring
Environmental and Social Monitoring
New Data 15 May 2017 \ 3rd Party Environmental Third Party Environmental Monitoring TANAP 11/05/2017
Monitoring_EBRD_11_05_2017_final CINAR
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 Third party facility E&S inspection checklist – TANAP 17-03-2017
\Waste Facility Inspection Report \ TNP-REP-ENV-GEN-009 Waste Management
New Data 15 May 2017 \ 3rd Party Social Third Party Social Monitoring TANAP 11/05/2017
Monitoring_EBRD_11_05_2017 CINAR
ESIA – ESMS Docs – ESIA – Chapter 7 - TNP-REP-ENV-GEN-002_CH- Threatened species TANAP
7.3.2.16A
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - TRAFFIC TRAFFIC MANAGEMENT PLAN FERNAS 24/06/2015
MANAGEMENT PLANS OF CCs - FRN-PLN-SOC-PL1-003_P4-0
ESIA – ESMS Docs – ESMP - Social Action Plan - ANNEX 2 - TRAFFIC TRAFFIC MANAGEMENT PLAN PUNJ LLOYD-LIMAK JV 27/05/2016
MANAGEMENT PLANS OF CCs - PLK-PLN-SOC-PL4-004_P4-1

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Traffic Management Plan TANAP 11-11-16
1.1 \ CC- ESMS \ SPK-PLN-SOC-DAR-006-Traffic Management Plan- P4-C
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training Attendance Form TANAP 17/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ Punj Lioyd
Gendarmerie Training Dutluca Eskiюehir 2017 \ E__T_M KATILIM BELGE Limak
Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training Attendance Form TANAP 08/02/2017
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Training and Drill Documents \ Punj Lioyd
ROW Security Training Dutluca Eskiюehir 2017 \ E__T_M KATILIM BELG Limak
Kalyon
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training attendance sheet
POLATLI \ POLATLI VPSHR TRAINING ATTENDANCE SHEET-1, 2, 3, 4
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training attendance sheet
DOGANKENT \ DOРANKENT VPSHR TRAINING ATTENDANCE SHEET-1,
2
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training Plan
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 11 Spread-4 Training Plan
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Training report: Class training TANAP 03/02/2017
ROW Security Training Dutluca Eskiюehir 2017 \ Security Drills in Gonen
- Karaorman 2017 \ Gonen Training and Karaorman Training
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Trans anatolian natural gas pipeline (TANAP) CINAR 13/8/2013
Vibration BL Report - A 1 Analysis Reports project environmental and social impact
assessment report baseline studies –
Environmental Noise and vibration
measurement report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\4_Air Trans anatolian natural gas pipeline (TANAP) CINAR 13/8/2013
Quality (PM10&PM2.5) Baseline Report - A 1 The Analysis Reports_PM10 project environmental and social impact
assessment report baseline studies – PM10
measurement report
Quality (PM10&PM2.5) Baseline Report - A 1 The Anlys project environmental and social impact
Rep_PM10_Addtnl Camp Sites assessment report baseline studies – PM10
measurement report
Quality (PM10&PM2.5) Baseline Report - A 1 The Anlys project environmental and social impact

Rep_PM2_5_Addtnl Camp Sites assessment report baseline studies - PM2.5
measurement report
Quality (PM10&PM2.5) Baseline Report - A 1 The Analysis project environmental and social impact
Reports_PM2_5 assessment report baseline studies - PM2.5
measurement report
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\6_Noise & Trans anatolian natural gas pipeline (TANAP) CINAR 29/5/2014
Vibration BL Report - A 1 Analysis Reports_Additional Camp Sites project report baseline studies – Environmental
Noise measurement report
Documents 21122016\2.3 Labour Union Agreements In Place Lot 2& Trans anatolian natural gas pipeline project – lot TEKFEN 1/2/2016
3\Lot 3 - TANAP-TKF-LET-WRP-0651 3 – World Bank due diligence
Documents 21122016\2.3 Labour Union Agreements In Place Lot 2& TRANS ANATOLIAN NATURAL GAS PIPELINE SICIM 3/2/2016
3\Lot 2 - TANAP-SYA-LET-WRP-0533 PROJECT - LOT2 YUKSEL
AKKORD JV
Documents 21122016\4.3 Transport of Dangerous Goods and Materials - Transport of Dangerous Goods & Materials
4.3 Transport of Dangerous Goods & Materials (Read Me)
Documents 21122016\2.2 Turkish Labour Law (in English) - 2.2 Turkish Turkish Labour Law
Labour Law (Read me)
Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Typical drawing concreate coated pipe TANAP
Wetlands & Seismic Act\Typical Drawing - Concrete Coated Pipe - WRP- WorleyParsons
DGA-PPL-PLG-030
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Typical drawing fault crossing 48’’ & 56’’ TANAP TANAP
Stability,Surface Fault Rupture)\Typical Drawing Fault Crossings 56%94 gas pipeline WorleyParsons
& 48%94 Tanap Gas Pipeline - WRP-DGA-PPL-PLG-042
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope Typical drawing karst drainage requirement TANAP
Stability,Surface Fault Rupture)\Typical Drawing - Karst Drainage WorleyParsons
Requirement - WRP-DGA-EGG-PLG-001
Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Typical drawing saddle bag for buoyancy control TANAP
Wetlands & Seismic Act\Typical Drawing - Saddle Bag for Buoyancy WorleyParsons
Control - WRP-DGA-PPL-PLG-031
Documents 21122016\3.4 Engin. & Design Sol. & Pro. Pipe Shifting Typical Drawing screw anchor detail TANAP
Wetlands & Seismic Act\Typical Drawing - Screw Anchor Detail - WRP- WorleyParsons
DGA-PPL-PLG-032
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\11.Typical Typical Drawings
Drawings
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Vehicle and Visitor Inspection Records Site Plus 11/2016
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Vehicle Inspection \ Vehicle and
Visitor Inspection Records 1 - 5

New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3 \ Vent and Blowdown Report TANAP 9/11/2015
BAT_emission inventory and relevant evaluation data \ WRP-REP-PRS- WorleyParsons
CSG-001-vent & blow down report
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence Vent and Blowdown Report TANAP 09/11/2015
Report-02.03.2017 \ PR3(3.2) \ WRP-REP-PRS-CSG-001-vent & blow WorleyParson
down report
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 1 \ Waste Management Plan TANAP 13-02-17
1.1 \ CC- ESMS \ SPK-PLN-ENV-DAR-006- Waste Management Plan- P4-
0
Documents 21122016\3.2 Water Intake Assessment & Allocation - 3.2 Water Intake Assessment & Allocation - 3.2
Water Intake Assessment & Allocation (Read me) Water Intake Assessment & Allocation (Read
me)
Documents 21122016\11.1 Copies of All Presentations - LOT-1 EBRD- WELCOMESEUROPEAN BANK FOR FERNAS
Presentation RECONSTRUCTION AND DEVELOPMENT TEAM TANAP
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence WINTERIZATION PLAN TANAP 31.08.2016
Report-02.03.2017 \ PR2(2.5)&PR4(4.1) \ FRN-PLN-HSE-PL1-025 FERNAS
Winterizaiton Plan p4-1
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX
2.4\22_Terrestrial Archaeology Baseline Report\Att.2_Ann 3 – Tm 27,
30,33,36,39,and 42
2.4\25_Geotechnical Survey Borelogs - BoreLog Rep1-TR
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.6\Appendix-
2.6.2. Physical Baseline Studies - Photographs
2.6.3. Biological Baseline Studies - Terrestrial
Documents 21122016\4.6 H&S Requirements for Camps &
Accommodations - 4.6 SYA-PLN-HSE-GEN-012-P4-0 - 4.6TKN-PLN-HSM-
GEN-003-P4-0
2.6.3. Biological Baseline Studies - Marine
2.6.4. Socio-economic Baseline Studies - Photographs
2.6.5. Archaeological Baseline Studies - Photographs
Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental
Master Plan and Legands\Plan Hьkьmleri Onaylэ\100.000
цlзekli_Mekansal

Documents 21122016\1.5 Appendix 1.3 of ESIA Maps\10.Environmental
Master Plan and Legands\Plan Hьkьmleri Onaylэ\Balэkesir
Documents 21122016\1.7 Onshore Fuel & Chemicals Spill Plan\TNP-PLN-
ENV-GEN-002 P3-2 Annexes - Annex 3-CC Sub-Management Plans
ENV-GEN-002 P3-2 Annexes – Annex 1 – National and International
standards of TANAP project
ENV-GEN-002 P3-2 Annexes – Annex 4 – Environmental Management
Guidelines for Contractors
ENV-GEN-002 P3-2 Annexes\Annex 6-Cultural Heritage Management
Plan
Documents 21122016\1.10 Quality Management System Procedure for
Contractors
Documents 21122016\1.11 Traning Programmes & Rules of Engagement
Code of Conduct - 01-5188 Sayэlэ Цzel Gьvenlik Hizmetlerine Dair
Kanun
Code of Conduct - 02-5188 Sayэlэ Цzel Gьvenlik Hizmetlerine Dair
Kanunun Uygulanmasэna Эl...
Code of Conduct - 03-Цzel Gьvenlik Hizmetlerinin Birleюtirilmiю
Genelgesi
Code of Conduct - FRM.54 R.01 EРЭTЭM TUTANAРI
Code of Conduct - FRM.061 R00 TEBLЭР-TEBELLЬР BELGESЭ
Code of Conduct - FRM.063 R.00 ORYANTASYON EРЭTЭM RAPORU
Code of Conduct - TLM.001 R00 GЦREV YERЭ ЦZEL TALЭMATI
Documents 21122016\2.3 Labour Union Agreements In Place Lot 2&
3\Lot 2 - sendika toplu sцzleюme
Documents 21122016\2.8 Example of Employment Contract - Sample FERNAS
employment contract-Fernas
Documents 21122016\2.8 Example of Employment Contract - Sample
employment contract-SYA

Documents 21122016\2.8 Example of Employment Contract - Sample
employment contract-Tekfen
Documents 21122016\2.8 Example of Employment Contract - TANAP
sample employee contract
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope
Stability,Surface Fault Rupture)\Engineering Design Validation Pipeline
Crossings of Active Tectonic Faults
Documents 21122016\3.5 Outline of Procedures ( Geohazards,Slope
Stability,Surface Fault Rupture)\Pipeline River Corssing Civil Protection
Works Specification
Documents 21122016\4.2 Communicable Disease Management Plan
Documents 21122016\4.6 H&S Requirements for Camps &
Accommodations - 4.6 SYA-PLN-HSE-GEN-012-P4-0
Documents 21122016\4.7 Security Risk Assessment for Use of Weapons
on the Project - Genel Devriye-Keюifзi Gцrevlisi Gцrev Esaslarэ Talimatэ
on the Project - Silah Depolama ve Bakэm Talimatэ
on the Project - Silah Devir Teslim Talimatэ
on the Project - Silah Emniyet ve Kaza Цnleme Talimatэ
on the Project - Silahlэ Gьvenlik Nцbetзisi Gцrev Talimatэ
on the Project - Silahlэ Ziyaretзi Kabul ve Silah Alma-Etme Esaslarэ
Talimatэ
Documents 21122016\4.8 Emergency Response Drill Examples
Documents 21122016\4.9 Procedures For UXO identifications - 20- 4536
Sayэlэ Denizlerde ve Yurt Yьzeyinde Gцrьlen Patlayэcэ Madde ve ...
Documents 21122016\4.9 Procedures For UXO identifications - 21-
Denizlerde ve Yurt Yьzeyinde Gцrьlen Patlayэcэ Madde ve Юьpheli
Cisim...
Documents 21122016\5.3 Long Term Lease Agreement and
Arrangements for the Forest Lands - 5.3 SAMPLE LONG TERM LEASE
AGREEMENT WITH FOREST AUTHORITIES
Documents 21122016\5.5 Access Road Register
Documents 21122016\5.8 Social Investment Fund (strategy)
Documents 21122016\6.4 Itn. Con. & Stand. And EU Directives

benchmark biodiversity impact assessment
New Data April 17 2017 \ E&S DD Report Review-05.04.2017 \ PR 3
\Waste Facility Inspection Report \ Annex2_Inspections docs
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence
Report-02.03.2017 \ PR2(2.5)\ WRP-QAC-FRM-001-00004-P3-2
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence 05.01.2017
Report-02.03.2017 \ PR2(2.10) \ Lot 1 \ SKM_C30817010614191
New Data April 17 2017 \ EBRD Questionarie on Social due dilligence TANAP WorleyParsons
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 05 TANAP-WRP-TRA-SYA-0307
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ 10 Spread-3 Training Plan
Report-02.03.2017 \ PR2(2.10) \ Lot 2 \ Enclosure 2, 3,6
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ 3-SP-
8 25.02.2017 Dut
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Daily Security Reports \ SP7-
26.02.2017 Daily Shif
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Material Removal \ Material
Removal Form 2 and 3 and old version form
Report-02.03.2017 \ PR2(2.10) \ Lot 4 \ Perimeter Patrol Activity \
perimeter foot patrol Feb 26 2017 TOM Reader
Perimeter Patrol Activity Records Book
Perimeter Patrol Activity Records NIZAMIYE 1 and 2 TOM Reader
Perimeter Patrol Feb 26-27 Motor TOM Readers
Karaorman 2016 \ Trainings in Gцnen-Karaorman 2016\ KARAORMAN

KAMP E__T_M 22.11.20 and KARAORMAN KAMP E__T_M 22.11.20
Report-02.03.2017 \ PR2(2.10) \ Stations \ Akasaklэ eрitim ve tatbikat
tutanak
New Data May 4 2017 \ CIN-REP-ENV-GEN-017-Rev-P3-10 \ TANAP-
CIN-TRA-TNP-0493.pdf \
ESIA – ESMS Docs – ESMP – EAP - Annex 6-Cultural Heritage
Management Plan - Annex C
Documents 21122016\1.4 Appendix 2 of ESIA\APPENDIX 2.4\5_Air
Quality (SO2, NOX, O3) Baseline Report\ANNEXES\Annex I_The Analysis
Reports
2.4\24_Hydro.,Ocean.,Geological and Geophysical S.R\Annexes - Annex-
3 Lab Results for Core Sample
4 SDigital Data
5 Information and Calibration for Equipmant
6 Education Documents
7 Photos
8 Mozaic Map
9 Seismic Profile
1 Bathymetric Map and Report
2 Lab Results

EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\
RAP Disclosure
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\
RAP Fund Announcement Brochure_TR_2017_GLAC-2
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR
5&10\RAP Fund Announcement Leaflet_TR_2017
EBRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR
5&10\RAP Fund Announcement Poster_TR_2017
BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\
Appeals Committee \ Lot 2_Poster Sample
BRD_ESAP_ESDD&relevant docs.share_dated_24.05.2017 \PR 5&10\
Appeals Committee \ Lot 4_Poster Sample

APPENDIX B: IFC EHS GUIDELINES COMPLIANCE ASSESSMENT TABLE
Item is considered in compliance with Local and/or International
Demonstrates Compliance
requirements/standards (based on IESC review of TANAP ESIA)
Item is considered in compliance with Local and/or International
requirements/standards (based on IESC site visit of construction
Compliance Anticipated
corridor and TANAP operational standards and existing construction
phase Environment, Social and OHS documentation)
Project’s progress and/or information/data available to date are
partially adequate to fulfil Local and/or International
Partial Compliance
requirements/standards, further work is needed to achieve
compliance
Not Applicable Item does not apply to this Project
Compliance
General IFC EHS Guidelines Requirements
Category
Environmental Protection
1. Air Emissions and Ambient Air Quality
Ambient Air Quality
1.1. Emissions do not result in pollutant concentrations that reach or exceed relevant
Demonstrates
ambient quality guidelines and standards by applying national legislated standards, or in
Compliance
their absence, the current WHO Air Quality Guidelines.
1.2. Projects with significant sources of air emissions, and potential for significant impacts to
ambient air quality, should prevent or minimize impacts by ensuring that: emissions do not
Demonstrates
contribute a significant portion to the attainment of relevant ambient air quality guidelines or
Compliance
standards. As a general rule, this Guideline suggests 25 percent of the applicable air quality
standards to allow additional, future sustainable development in the same airshed.
1.3. At facility level, impacts should be estimated through qualitative or quantitative
assessments by the use of baseline air quality assessments and atmospheric dispersion
models to assess potential ground level concentrations. Local atmospheric, climatic, and air Demonstrates
quality data should be applied when modeling dispersion, protection against atmospheric Compliance
downwash, wakes, or eddy effects of the source, nearby structures, and terrain features.
The dispersion model applied should be internationally recognised, or comparable.
1.4. Facilities or projects located within poor quality airsheds, and within or next to areas
established as ecologically sensitive (e.g. national parks), should ensure that any increase in
pollution levels is as small as feasible, and amounts to a fraction of the applicable short-term
and annual average air quality guidelines or standards as established in the project-specific
environmental assessment. Demonstrates
Suitable mitigation measures should also include the relocation of significant sources of Compliance
emissions outside the airshed in question, use of cleaner fuels or technologies, application of
comprehensive pollution control measures, offset activities at installations controlled by the
project sponsor or other facilities within the same airshed, and buy-down of emissions within
the same airshed.
Point Sources
1.5. The stack height for all point sources of emissions should be designed according to Compliance
good international industry practice (GIP). Anticipated
1.6. Emissions from small combustion process installations (3 MWth - 50 MWth), operated
more than 500 hours per year, and those with an annual capacity utilisation of more than 30
Not Applicable
percent should be in compliance with standards, recommended by General EHS guidelines of
IFC.
Fugitive Sources
1.7. Volatile Organic Compounds (VOC) emissions associated with equipment leaks should
be prevented and controlled by techniques including:
 Equipment modifications; Demonstrates
 Implementation a leak detection and repair (LDAR) program that controls fugitive Compliance
emissions by regularly monitoring to detect leaks, and implementing repairs within a
predefined time period;

 Substitution of less volatile substances;
 Collection of vapours through air extractors and subsequent;
 Treatment with destructive control devices;
 Use of floating roofs on storage tanks.
1.8. Dust control methods should be implemented to prevent particulate matter (dust)
emissions including the following: Demonstrates
 Covers, water suppression, or increased moisture content for open materials storage piles; Compliance
 Use of water suppression for control of loose materials on paved or unpaved road surfaces.
1.9. Open burning of solid wastes, whether hazardous or nonhazardous, is not considered Demonstrates
good practice and should be avoided. Compliance
1.10. No new systems or processes should be installed using CFCs, halons, 1,1,1- Demonstrates
trichloroethane, carbon tetrachloride, methyl bromide or HBFCs. Compliance
Mobile Sources – Land-based
1.11 Emissions from on-road and off-road vehicles should comply with national or regional
programs. In the absence of these, the following approach should be considered:
 Implementation of the manufacturer recommended engine maintenance programs;
 Drivers should be instructed on the benefits of driving practices that reduce both the risk of
accidents and fuel consumption, including measured acceleration and driving within safe
speed limits; Demonstrates
 Operators with fleets of 120 or more units of heavy duty vehicles, or 540 or more light duty Compliance
vehicles within an airshed should consider additional ways to reduce potential impacts
including replacing older vehicles with newer, more fuel efficient alternatives; Converting
high-use vehicles to cleaner fuels, where feasible;
 Installing and maintaining emissions control devices, such as catalytic converters;
Implementing a regular vehicle maintenance and repair program.
Greenhouse Gases (GHGs)
1.12. The following measures should be implemented to reduce and control greenhouse
gases:
 Carbon financing;
Compliance
 Protection and enhancement of sinks and reservoirs of greenhouse gases;
Anticipated
 Carbon capture and storage technologies;
 Limitation and / or reduction of methane emissions;
 Enhancement of energy efficiency.
Air quality monitoring
1.13. Air quality monitoring program should be developed. The monitoring parameters
selected should reflect the pollutants of concern associated with project processes.
The air quality monitoring program should consider the following elements:
 baseline calculations;
 monitoring type and frequency (data on emissions and ambient air quality generated Partial
through the monitoring program should be representative of the emissions discharged by Compliance
the project over time);
 monitoring locations;
 sampling and analysis methods (monitoring programs should apply national or international
methods for sample collection and analysis).
1.14. Annual Stack Emission Testing of boilers with capacities between =3 MWth and < 20
MWth should be carried out to control SO2, NOx and PM (for gaseous fuel- fired boilers, only
NOx). SO2 can be calculated based on fuel quality certification if no SO2 control equipment
is used.
If Annual Stack Emission Testing demonstrates results consistently and significantly better
than the required levels, frequency of Annual Stack Emission Testing can be reduced from
annual to every two or three years.
Partial
Annual Stack Emission Testing of boilers with capacities between =20 MWth and < 50 MWth
Compliance
should be carried out to control SO2, NOx and PM (for gaseous fuel-fired boilers, only NOx).
Emission Monitoring:
 SO2. Plants with SO2 control equipment: Continuous.
 NOx: Continuous monitoring of either NOx emissions or indicative NOx emissions using
combustion parameters.
 PM: Continuous monitoring of either PM emissions, opacity, or indicative PM emissions
using combustion parameters / visual monitoring.
1.14. Air quality monitoring for turbines should include: Partial

 Annual Stack Emission Testing: NOx, SO2 and PM (NOx only for gaseous fuel-fired diesel Compliance
engines).
 If Annual Stack Emission Testing results show constantly (3 consecutive years) and
significantly (e.g. less than 75 percent) better than the required levels, frequency of Annual
Stack Emission Testing can be reduced from annual to every two or three years.
 Emission Monitoring: NOx: Continuous monitoring of either NOx emissions or indicative
NOx emissions using combustion parameters. SO2: Continuous monitoring if SO2 control
equipment is used. PM: Continuous monitoring of either PM emissions or indicative PM
emissions using operating parameters.
2. Energy Conservation
Energy Management Programs
2.1. Energy management programs should include the following elements:
 Identification, and regular measurement and reporting of principal energy flows within a
facility at unit process level;
 Preparation of mass and energy balance;
 Definition and regular review of energy performance targets, which are adjusted to account Compliance
for changes in major influencing factors on energy use; Anticipated
 Regular comparison and monitoring of energy flows with performance targets to identify
where action should be taken to reduce energy use;
 Regular review of targets, which may include comparison with benchmark data, to confirm
that targets are set at appropriate levels.
Energy Efficiency
2.2. For any energy-using system, a systematic analysis of energy efficiency improvements Compliance
and cost reduction opportunities should include a hierarchical examination of opportunities Anticipated
to:
 Demand/Load Side Management by reducing loads on the energy system;
 Supply Side Management by reduce losses in energy distribution; improve energy
conversion efficiency; exploit energy purchasing opportunities; use lower- carbon fuels.
Compliance
2.3. In process heating systems, a system heat and mass balance should be developed for Anticipated
examination of savings opportunities.
2.4. Special measures for heating load reduction should be used including the following: Compliance
 Ensure adequate insulation to reduce heat losses through furnace/oven etc. structure; Anticipated
 Recover heat from hot process or exhaust streams to reduce system loads;
 In intermittently-heated systems, consider use of low thermal mass insulation to reduce
energy required to heat the system structure to operating temperature;
 Control process temperature and other parameters accurately to avoid, for example,
overheating or overdrying;
 Examine opportunities to use low weight and/or low thermal mass product carriers, such as
heated shapers, kiln cars etc.;
 Review opportunities to schedule work flow to limit the need for process reheating between
stages;
 Operate furnaces/ovens at slight positive pressure, and maintain air seals to reduce air in-
leakage into the heated system, thereby reducing the energy required to heat unnecessary
air to system operating temperature;
 Robust Scheduled maintenance programs.
2.5. Losses in heat distribution systems should be reduced through the following actions: Compliance
 Promptly repair distribution system leaks; Anticipated
 Regularly verify correct operation of steam traps in steam systems, and ensure that traps
are not bypassed;
 Insulate distribution system vessels, such as hot wells and de-aerators, in steam systems
and thermal fluid or hot water storage tanks;
 In steam systems, return condensate to the boiler house for re-use, since condensate is
expensive boiler-quality water and valuable beyond its heat content alone.
2.6. The following efficiency opportunities should be examined for process furnaces or Compliance
ovens, and utility systems, such as boilers and fluid heaters: Anticipated
 Regularly monitor CO, oxygen or CO2 content of flue gases to verify that combustion
systems are using the minimum practical excess air volumes;
 Consider combustion automation using oxygen-trim controls;
 Minimise the number of boilers or heaters used to meet loads;

 Use flue dampers to eliminate ventilation losses from hot boilers held at standby;
 Maintain clean heat transfer surfaces;
 In steam boiler systems, use economisers to recover heat from flue gases to pre-heat
boiler feed water or combustion air;
 Adopt automatic (continuous) boiler blowdown;
 Recover heat from blowdown systems through flash steam recovery or feed- water
preheat;
 With fired heaters, consider opportunities to recover heat to combustion air through the
use of recuperative or regenerative burner systems;
 Oxy Fuel burners;
 Fuel quality control/fuel blending and etc.
2.7. Special measures to improve process cooling efficiency should be used including the Compliance
following: Anticipated
 Ensure adequate insulation;
 Control process temperature;
 Operate cooling tunnels at slight positive pressure and maintain air seals to reduce air in-
leakage into the cooled system;
 Examine opportunities to pre-cool using heat recovery to a process stream requiring
heating, or by using a higher temperature cooling utility;
 In cold and chill stores, minimise heat gains to the cooled space by use of air curtains,
entrance vestibules, or rapidly opening/closing doors;
 Do not use refrigeration for auxiliary cooling duties, such as compressor cylinder head or oil
cooling;
 Use energy efficiency techniques in air conditioning applications.
2.8. The efficiency of cooling systems should be improved by effective refrigeration system Compliance
design and increased refrigerant compression efficiency, as well as minimisation of the Anticipated
temperature difference through which the system works and of auxiliary loads used to
operate the refrigeration system.
2.9. Refrigerant compression efficiency should be improved by avoiding operation of multiple Compliance
compressors at part-load conditions; considering turndown efficiency when specifying Anticipated
chillers.
2.10. Energy use of refrigeration system auxiliaries (e.g. evaporator fans and chilled water Compliance
pumps) should be reduced. Anticipated
Compressed Air Systems
2.11. Special energy conservation measures should be used including : Compliance
 examination of each true user of compressed air to identify the air volume needed and the Anticipated
pressure at which this should be delivered;
 air use reduction opportunities review.
2.12. Monitoring of pressure losses in filters should be provided. Adequately sized Compliance
distribution pipework designed to minimise pressure losses should be used. Anticipated
3. Wastewater and Ambient Water Quality
General applicability and approach
3.1. In the context of their overall ESHS management system, facilities should understand Demonstrates
the quality, quantity, frequency and sources of liquid effluents in its installations. Compliance
3.2. Segregation of liquid effluents principally along industrial, utility, sanitary, and rainwater Demonstrates
categories should be planed and implemented, in order to limit the volume of water Compliance
requiring specialised treatment.
3.3. Opportunities should be identified to prevent or reduce wastewater pollution through Demonstrates
such measures as recycle/reuse within their facility, input substitution, or process Compliance
modification.
3.4. Wastewater discharges should be compliant with the applicable: (i) discharge standard Demonstrates
(if the wastewater is discharged to a surface water or sewer), and (ii) water quality standard Compliance
for a specific reuse.
3.5. Water use efficiency should be provided to reduce the amount of wastewater Demonstrates
generation. Compliance
3.6. Process modification should be implemented, including waste minimisation, and Demonstrates
reducing the use of hazardous materials to reduce the load of pollutants requiring treatment. Compliance
3.7. When wastewater treatment is required prior to discharge, the level of treatment should Demonstrates
be based on: Compliance
 National and local standards as reflected in permit requirements and sewer system capacity

to convey and treat wastewater if discharge is to sanitary sewer;
 Assimilative capacity of the receiving water for the load of contaminant being discharged
wastewater if discharge is to surface water;
 Intended use of the receiving water body;
 Presence of sensitive receptors;
 GIP for the relevant industry sector.
Liquid Effluent Quality
3.8. Discharges of process wastewater, sewage, wastewater from utility operations or Demonstrates
rainwater to surface water should not result in contaminant concentrations in excess of local Compliance
ambient water quality criteria or, in the absence of local criteria, other sources of ambient
water quality.
Receiving water use and assimilative capacity, taking other sources of discharges to the
receiving water into consideration, should also influence the acceptable pollution loadings
and effluent discharge quality.
Temperature of wastewater prior to discharge should not result in an increase greater than
3°C of ambient temperature at the edge of a scientifically established mixing zone which
takes into account ambient water quality, receiving water use and assimilative capacity
among other considerations.
3.9. Discharges of industrial wastewater, sewage, wastewater from utility operations or Demonstrates
rainwater into public or private wastewater treatment systems should: Compliance
 Meet the pre-treatment and monitoring requirements of the sewer treatment system into
which it discharges;
 Not interfere, directly or indirectly, with the operation and maintenance of the collection
and treatment systems, or pose a risk to worker health and safety, or adversely impact
characteristics of residuals from wastewater treatment operations;
 Be discharged into municipal or centralised wastewater treatment systems that have
adequate capacity to meet local regulatory requirements for treatment of wastewater •
Generated from the project. Pre-treatment of wastewater to meet regulatory requirements
before discharge from the project site is required if the municipal or centralised wastewater
treatment system receiving wastewater from the project does not have adequate capacity
to maintain regulatory compliance.
3.10. The quality of treated process wastewater, wastewater from utility operations or Demonstrates
rainwater discharged on land, including wetlands, should be established based on local Compliance
regulatory requirements.
Where land is used as part of the treatment system and the ultimate receptor is surface
water, water quality guidelines for surface water discharges specific to the industry sector
process should apply.
Potential impact on soil, groundwater, and surface water, in the context of protection,
conservation and long term sustainability of water and land resources should be assessed
when land is used as part of any wastewater treatment system.
3.11. Septic systems should be used for treatment and disposal of domestic sanitary sewage Demonstrates
in areas with no sewerage collection networks. Compliance
When septic systems are the selected form of wastewater disposal and treatment, they
should be:
 Properly designed and installed in accordance with local regulations and guidance to
prevent any hazard to public health or contamination of land, surface or groundwater.
 Well maintained to allow effective operation.
 Installed in areas with sufficient soil percolation for the design wastewater loading rate.
 Installed in areas of stable soils that are nearly level, well drained, and permeable, with
enough separation between the drain field and the groundwater table or other receiving
waters.
3.12. Treatment technologies should be used to achieve the desired discharge quality for
process wastewater and to maintain consistent compliance with regulatory requirements.
The design and operation of the selected wastewater treatment technologies should avoid
uncontrolled air emissions of volatile chemicals from wastewaters. Residuals from industrial
wastewater treatment operations should be disposed in compliance with local regulatory Demonstrates
requirements. Recommended water management strategies for utility operations include: Compliance
 Adoption of water conservation opportunities for facility cooling systems;
 Use of heat recovery methods or other cooling methods to reduce the temperature of
heated water prior to discharge to ensure the discharge water temperature does not result
in an increase greater than 3°C of ambient temperature;

 Minimising use of antifouling and corrosion inhibiting chemicals by ensuring appropriate
depth of water intake and use of screens;
 Testing for residual biocides and other pollutants of concern should be conducted to
determine the need for dose adjustments or treatment of cooling water prior to discharge.
Rainwater should be separated from process and sewage streams. Surface runoff from
process areas or potential sources of contamination should be prevented. Runoff from
process and storage areas should be segregated from potentially less contaminated runoff.
Runoff from areas without potential sources of contamination should be minimised. Sludge
from rainwater catchments or collection and treatment systems should be disposed in
compliance with local regulatory requirements, in the absence of which disposal has to be
consistent with protection of public health and safety, and conservation and long term
sustainability of water and land resources.
3.13. Recommended sewage management strategies include: Demonstrates
 Segregation of wastewater streams to ensure compatibility with selected treatment option; Compliance
 Segregation and pre-treatment of oil and grease containing effluents prior to discharge into
sewer systems;
 If sewage from the industrial facility is to be discharged to surface water, treatment to
meet national or local standards for sewage discharges;
 If sewage from the industrial facility is to be discharged to either a septic system, or where
land is used as part of the treatment system, treatment to meet applicable national or local
standards for sewage discharges is required;
 Sludge from sewage treatment systems should be disposed in compliance with local
regulatory requirements.
3.14. A wastewater and water quality monitoring program with adequate resources and Demonstrates
management oversight should be developed and implemented. The wastewater and water Compliance
quality monitoring program should consider monitoring parameters, monitoring type and
frequency, monitoring locations, data quality.
4. Water Conservation
Water conservation program
4.1. Water conservation programs should be implemented commensurate with the Demonstrates
magnitude and cost of water use. Compliance
These programs should promote the continuous reduction in water consumption and achieve
savings in the water pumping, treatment and disposal costs.
4.2. The essential elements of a water management program should involve: Demonstrates
 Identification, regular measurement, and recording of principal flows within a facility. Compliance
 Definition and regular review of performance targets, which are adjusted to account for
changes in major factors affecting water use.
 Regular comparison of water flows with performance targets to identify where action
should be taken to reduce water use.
4.3. Water should be reused in multi-stage washing and rinsing processes or from one
process for another with less exacting water quality requirements.
4.4. Measures for water saving should be implemented to reduce consumption of building Demonstrates
and sanitary water, including: Compliance
 Regularly maintain plumbing, and identify and repair leaks;
 Install self-closing taps, automatic shut-off valves, spray nozzles, pressure reducing valves,
and water conserving fixtures;
 Operate dishwashers and laundries on full loads, and only when needed;
 Install water-saving equipment in lavatories, such as lowflow toilets.
4.5. Water conservation opportunities in cooling systems should include: Demonstrates
 Use of closed circuit cooling systems with cooling towers rather than once-through cooling Compliance
systems;
 Limiting condenser or cooling tower blowdown to the minimum required to prevent
unacceptable accumulation of dissolved solids;
 Use of air cooling rather than evaporative cooling;
 Use of treated waste water for cooling towers;
 Reusing/recycling cooling tower blowdown.
4.6. Large quantities of water may be used by steam systems, and this should be reduced
by the following measures:
Demonstrates
 Repair of steam and condensate leaks, and repair of all failed steam traps;
Compliance
 Return of condensate to the boilerhouse, and use of heat exchangers (with condensate
return) rather than direct steam injection where process permits;

 Flash steam recovery;
 Minimising boiler blowdown consistent with maintaining acceptably low dissolved solids in
boiler water;
 Minimising deaerator heating.
5. Hazardous Materials Management
General Hazardous Materials Management
5.1. The level of risk should be established through an on-going assessment process based
on:
 The types and amounts of hazardous materials present in the project.
 Analysis of potential spill and release scenarios using available industry statistics on spills
Demonstrates
and accidents where available.
Compliance
 Analysis of the potential for uncontrolled reactions such as fire and explosions.
 Analysis of potential consequences based on the physical geographical characteristics of
the project site, including aspects such as its distance to settlements, water resources, and
other environmentally sensitive areas.
5.2. The management actions to be included in a Hazardous Materials Management Plan Demonstrates
should be commensurate with the level of potential risks associated with the production, Compliance
handling, storage, and use of hazardous materials.
5.3. Where there is risk of a spill of uncontrolled hazardous materials, facilities should Demonstrates
prepare a spill control, prevention, and countermeasure plan as a specific component of their Compliance
Emergency Preparedness and Response Plan.
5.4. The plan should be tailored to the hazards associated with the project, and include: Demonstrates
 Training of Operators on release prevention, including drills specific to hazardous materials Compliance
as part of emergency preparedness response training;
 Implementation of inspection programs to maintain the mechanical integrity and operability
of pressure vessels, tanks, piping systems, relief and vent valve systems, containment
infrastructure, emergency shutdown systems, controls and pumps, and associated process
equipment;
 Preparation of written Standard Operating Procedures (SOPs) for filling USTs, ASTs or other
containers or equipment as well as for transfer operations by personnel trained in the safe
transfer and filling of the hazardous material, and in spill prevention and response;
 SOPs for the management of secondary containment structures;
 Identification of locations of hazardous materials and associated activities on an emergency
plan site map;
 Documentation of availability of specific personal protective equipment and training needed
to respond to an emergency;
 Documentation of availability of spill response equipment;
 Description of response activities in the event of a spill, release, or other chemical
emergency.
5.5. Recommended practices to prevent hazardous material releases from transfer processes Demonstrates
include: Compliance
 Use of transfer equipment that is compatible and suitable for the characteristics of the
materials transferred and designed to ensure safe transfer;
 Regular inspection, maintenance and repair of fittings, pipes and hoses;
 Provision of secondary containment, drip trays or other overflow and drip containment
measures, for hazardous materials containers at connection points or other possible
overflow points.
5.6. Special measures should be implemented to prevent overfills of vessels and tanks, Demonstrates
including: Compliance
 Prepare written procedures for transfer operations;
 Installation of gauges on tanks to measure volume inside;
 Use of dripless hose connections for vehicle tank and fixed connections with storage tanks;
 Provision of automatic fill shutoff valves on storage tanks to prevent overfilling;
 Use of a catch basin around the fill pipe to collect spills;
 Use of piping connections with automatic overfill protection;
 Pumping less volume than available capacity into the tank or vessel by ordering less
material than its available capacity;
 Provision of overfill or over pressure vents that allow controlled release to a capture point.
5.7. Special measures should be implemented to avoid uncontrolled reactions or conditions Demonstrates
resulting in fire or explosion, including: Compliance
 Storage of incompatible materials (acids, bases, flammables, oxidisers, reactive chemicals)

in separate areas, and with containment facilities separating material storage areas;
 Provision of material-specific storage for extremely hazardous or reactive materials;
 Use of flame arresting devices on vents from flammable storage containers;
 Provision of grounding and lightning protection for tank farms, transfer stations, and other
equipment that handles flammable materials;
 Selection of materials of construction compatible with products stored for all parts of
storage and delivery systems, and avoiding reuse of tanks for different products without
checking material compatibility;
 Storage of hazardous materials in an area of the facility separated from the main
production works. Where proximity is unavoidable, physical separation should be provided
using structures designed to prevent fire, explosion, spill, and other emergency situations
from affecting facility operations;
 Prohibition of all sources of ignition from areas near flammable storage tanks.
Control Measures
5.8. Secondary containment should be used to control accidental releases of liquid Demonstrates
hazardous materials during storage and transfer. Secondary containment design and Compliance
construction should hold released materials effectively until they can be detected and safely
recovered. Appropriate secondary containment structures consist of berms, dikes, or walls
capable of containing the larger of 110 percent of the largest tank or 25 percent of the
combined tank volumes in areas with above-ground tanks with a total storage volume equal
or greater than 1,000 liters.
5.9. Transfer of hazardous materials from vehicle tanks to storage should be affected in Demonstrates
areas with surfaces sufficiently impervious to avoid loss to the environment and sloped to a Compliance
collection or a containment structure not connected to municipal wastewater / rainwater
collection system.
5.10. Where it is not practical to provide permanent, dedicated containment structures for Demonstrates
transfer operations, one or more alternative forms of spill containment should be provided, Compliance
such as portable drain covers, automatic shut-off valves on storm water basins, or shut off
valves in drainage or sewer facilities, combined with oil-water separators.
5.11. Storage of drummed hazardous materials with a total volume equal or greater than Demonstrates
1,000 liters should be affected in areas with impervious surfaces that are sloped or bermed Compliance
to contain a minimum of 25 percent of the total storage volume.
5.12. Double-walled, composite, or specially coated storage and piping systems should be Demonstrates
used particularly for underground storage tanks (USTs) and underground piping. If double Compliance
walled systems are used, they should provide a means of detecting leaks between the two
walls.
5.13. Leak detection may be used in conjunction with secondary containment, particularly in Demonstrates
high-risk locations. Leak detection is especially important in situations where secondary Compliance
containment is not feasible or practicable, such as in long pipe runs. Acceptable leak
detection methods include:
 Use of automatic pressure loss detectors on pressurised or long distance piping;
 Use of approved or certified integrity testing methods on piping or tank systems, at regular
intervals;
 Considering the use of SCADA if financially feasible.
5.14. Special measures should be implemented for underground storage of hazardous Demonstrates
materials to manage the risks of fire or explosion, vapor losses into the atmosphere, leaks of Compliance
hazardous materials, including:
 Avoiding use of USTs for storage of highly soluble organic materials;
 Assessing local soil corrosion potential, and installing and maintaining cathodic protection
(or equivalent rust protection) for steel tanks;
 For new installations, installing impermeable liners or structures under and around tanks
and lines that direct any leaked product to monitoring ports at the lowest point of the liner
or structure;
 Monitoring the surface above any tank for indications of soil movement;
 Reconciling tank contents by measuring the volume in store with the expected volume,
given the stored quantity at last stocking, and deliveries to and withdrawals from the store;
 Testing integrity by volumetric, vacuum, acoustic, tracers, or other means on all tanks at
regular intervals;
 Evaluating the risk of existing UST in newly acquired facilities to determine if upgrades are
required for USTs that will be continued to be used, including replacement with new
systems or permanent closure of abandoned USTs.

5.15. Hazardous Materials Risk Management Plan should be prepared to prevent and control Demonstrates
of catastrophic releases of toxic, reactive, flammable, or explosive chemicals that may result Compliance
in toxic, fire, or explosion hazards.
5.16. An Emergency Preparedness and Response Plan incorporated into and consistent with, Demonstrates
the facility’s overall ES/OHS MS, should be prepared to cover the following: Compliance
 Planning Coordination: Procedures should be prepared for informing the public and
emergency response agencies; documenting first aid and emergency medical treatment;
taking emergency response actions; reviewing and updating the emergency response plan
to reflect changes, and ensuring that employees are informed of such changes;
 Procedures should be prepared for using, inspecting, testing, and maintaining the
emergency response equipment;
 Employees and contractors should be trained on emergency response procedures.
5.17. When hazardous materials are in use above threshold quantities, the management Demonstrates
plan should include a system for community awareness, notification and involvement that Compliance
should be commensurate with the potential risks identified for the project during the hazard
assessment studies (availability of general information to the potentially affected community
on the nature and extent of project operations, and the prevention and control measures in
place to ensure no effects to human health; the potential for off-site effects to human health
or the environment following an accident at planned or existing hazardous installations;
specific and timely information on appropriate behavior and safety measures to be adopted
in the event of an accident including practice drills in locations with higher risks).
6. Waste Management
General Waste Management
6.1. Facilities that generate and store wastes should practice the following: Demonstrates
 Establishing waste management priorities at the outset of activities based on an Compliance
understanding of potential Environmental, Health, and Safety (EHS) risks and impacts and
considering waste generation and its consequences;
 Establishing a waste management hierarchy that considers prevention, reduction, reuse,
recovery, recycling, removal and finally disposal of wastes;
 Avoiding or minimising the generation waste materials, as far as practicable;
 Where waste generation cannot be avoided but has been minimised, recovering and
reusing waste;
 Where waste cannot be recovered or reused, treating, destroying, and disposing of it in an
environmentally sound manner.
6.2. Effective planning and implementation of waste management strategies should include: Demonstrates
 Review of new waste sources during planning, siting, and design activities, including during Compliance
equipment modifications and process alterations, to identify expected waste generation,
pollution prevention opportunities, and necessary treatment, storage, and disposal
infrastructure;
 Definition of opportunities for source reduction, as well as reuse and recycling;
 Definition of procedures and operational controls for onsite storage;
 Definition of options / procedures / operational controls for treatment and final disposal.
6.3. Potential impacts and risks associated with the management of any generated Demonstrates
hazardous waste should be assessed during its complete life cycle. Compliance
6.4. It should be ensured that contractors handling, treating, and disposing of hazardous Compliance
waste are reputable and legitimate enterprises, licensed by the relevant regulatory agencies Anticipated
and following good international industry practice for the waste being handled.
6.5. Processes should be designed and operated to prevent, or minimise, the quantities of
wastes generated and hazards associated with the wastes generated in accordance with the
following strategy:
 Substituting raw materials or inputs with less hazardous or toxic materials, or with those
where processing generates lower waste volumes;
 Applying manufacturing process that convert materials efficiently;
Demonstrates
 Instituting good housekeeping and operating practices, including inventory control to
Compliance
reduce the amount of waste resulting from materials that are out-of- date, off-specification,
contaminated, damaged, or excess to plant needs;
 Instituting procurement measures that recognise opportunities to return usable materials
such as containers and which prevents the over ordering of materials;
 Minimising hazardous waste generation by implementing stringent waste segregation to
prevent the commingling of non-hazardous and hazardous waste to be managed.

6.6. Total amount of waste may be significantly reduced through the implementation of
recycling plans, which should consider the following elements:
 Identification and recycling of products that can be reintroduced into the manufacturing
Demonstrates
process or industry activity at the site;
Compliance
 Investigation of external markets for recycling by other industrial processing operations
located in the neighbourhood or region of the facility;
 Providing training and incentives to employees in order to meet objectives.
6.7. If waste materials are still generated after the implementation of feasible waste Compliance
prevention, reduction, reuse, recovery and recycling measures, waste materials should be Anticipated
treated and disposed of and all measures should be taken to avoid potential impacts to
human health and the environment. Such measures should include the following:
 On-site or off-site biological, chemical, or physical treatment of the waste material to
render it nonhazardous prior to final disposal;
 Treatment or disposal at permitted facilities specially designed to receive the waste.
6.8. In the absence of qualified commercial or government-owned waste vendors and
disposal Operators (taking into consideration proximity and transportation requirements),
facilities generating waste should consider using:
 Have the technical capability to manage the waste in a manner that reduces immediate
Demonstrates
and future impact to the environment;
Compliance
 Installing on-site waste treatment or recycling processes;
 As a final option, constructing facilities that will provide for the environmental sound long-
term storage of wastes on-site or at an alternative appropriate location up until external
commercial options become available.
Waste storage
6.9. Wastes should be stored in a manner that prevents the commingling or contact between Demonstrates
incompatible wastes. Compliance
6.10. Different type of wastes should be stored in different closed containers away from Demonstrates
direct sunlight, wind and rain. Compliance
6.11. Periodic inspections of waste storage areas should be conducted with documenting the Demonstrates
findings. Compliance
6.12. Secondary containment should be included wherever liquid wastes are stored in Demonstrates
volumes greater than 220 liters. The available volume of secondary containment should be Compliance
at least 110 percent of the largest storage container, or 25 percent of the total storage
capacity (whichever is greater), in that specific location.
Demonstrates
6.13. Adequate ventilation should be provided where volatile wastes are stored.
Compliance
6.14. Hazardous waste storage activities should also be subject to special management
actions, conducted by employees who have received specific training in handling and storage
of hazardous wastes:
 Provision of readily available information on chemical compatibility to employees, including
labelling each container to identify its contents;
Partial
 Clearly identifying (label) and demarcating the area, including documentation of its location
Compliance
on a facility map or site plan;
 Conducting periodic inspections of waste storage areas and documenting the findings;
 Preparing and implementing spill response and emergency plans to address their accidental
release;
 Avoiding underground storage tanks and underground piping of hazardous waste.
Transportation
6.15. On-site and Off-site transportation of waste should be conducted so as to prevent or
minimise spills, releases, and exposures to employees and the public.
All waste containers designated for off-site shipment should be secured and labeled with the Demonstrates
contents and associated hazards, be properly loaded on the transport vehicles before leaving Compliance
the site, and be accompanied by a shipping paper that describes the load and its associated
hazards.
Monitoring
6.16. Monitoring activities associated with the management of hazardous and non-
hazardous waste should include:
Partial
 Regular visual inspection of all waste storage collection and storage areas for evidence of
Compliance
accidental releases and to verify that wastes are properly labelled and stored.
 Regular audits of waste segregation and collection practices;

 Periodic auditing of third party treatment, and disposal services including re-use and
recycling facilities when significant quantities of hazardous wastes are managed by third
parties;
 Regular monitoring of groundwater quality in cases of Hazardous Waste on site storage
and/or pre-treatment and disposal.
7. Noise
Prevention and Control
7.1. Noise impacts should not exceed the following levels: Compliance
 55 One Hour LAeq (dBA) at daytime for residential; institutional; educational receptors; Anticipated
 45 One Hour LAeq (dBA) at night time for residential; institutional; educational receptors;
 70 One Hour LAeq (dBA) at daytime and night time for industrial; commercial receptors.
7.2. Noise prevention and mitigation measures should be applied where predicted or Compliance
measured noise impacts from a project facility or operations exceed the applicable noise Anticipated
level guideline at the most sensitive point of reception. Noise reduction options that should
be considered include:
 Selecting equipment with lower sound power levels;
 Installing silencers for fans;
 Installing suitable mufflers on engine exhausts and compressor components;
 Installing acoustic enclosures for equipment casing radiating noise;
 Improving the acoustic performance of constructed buildings, apply sound insulation;
 Limiting the hours of operation for specific pieces of equipment or operations, especially
mobile sources operating through community areas;
 Reducing project traffic routing through community areas wherever possible
 Developing a mechanism to record and respond to complaints.
Monitoring
7.3. Noise monitoring programs should be designed and conducted by trained specialists. Compliance
Typical monitoring periods should be sufficient for statistical analysis. Anticipated
8. Contaminated Land
Prevention of land contamination
8.1. Contamination of land should be avoided by preventing or controlling the release of Compliance
hazardous materials, hazardous wastes, or oil to the environment. Anticipated
8.2. When contamination of land is suspected or confirmed during any project phase, the Compliance
cause of the uncontrolled release should be identified and corrected to avoid further releases Anticipated
and associated adverse impacts.
8.3. Contaminated lands should be managed to avoid the risk to human health and Compliance
ecological receptors. Anticipated
8.4. The preferred strategy for land decontamination is to reduce the level of contamination Compliance
at the site while preventing the human exposure to contamination. Anticipated
Risk assessment
8.5. Where there is potential evidence of contamination at a site, the following steps should Compliance
be provided: Anticipated
 Identification of the location of suspected highest level of contamination through a
combination of visual and historical operational information;
 Sampling and testing of the contaminated media (soils or water);
 Evaluation of the analytical results against the local and national contaminated sites
regulations;
 Verification of the potential human and/or ecological receptors and exposure pathways
relevant to the site in question.
8.6. Interim risk management actions should be implemented at any phase of the project life Compliance
cycle if the presence of land contamination poses an “imminent hazard”, i.e., representing Anticipated
an immediate risk to human health and the environment if contamination were allowed to
continue, even a short period of time.
Appropriate risk reduction should be implemented as soon as practicable to remove the
condition posing the imminent hazard.
8.7. If the presence of land contamination poses an “imminent hazard”, a detailed site- Compliance
specific, environmental risk assessment should be used to develop strategies that yield Anticipated
acceptable health risks, while achieving low level contamination on-site.
8.8. The risk factors and conceptual site model within the contaminant risk approach Compliance
described should also provide a basis to manage and mitigate environmental contaminant Anticipated
health risks.

Occupational Health and Safety
9. General Facility Design and Operation
Integrity of Workplace Structures
9.1. Permanent and recurrent places of work should be designed and equipped to protect
OHS:
 Surfaces, structures and installations should be easy to clean and maintain, and not allow
for accumulation of hazardous compounds;
 Buildings should be structurally safe, provide appropriate protection against the climate,
Demonstrates
and have acceptable light and noise conditions;
Compliance
 Fire resistant, noise-absorbing materials should, to the extent feasible, be used for cladding
on ceilings and walls;
 Floors should be level, even, and non- skid;
 Heavy oscillating, rotating or alternating equipment should be located in dedicated
buildings or structurally isolated sections.
Severe Weather and Facility Shutdown
9.2. Work place structures should be designed and constructed to withstand the expected Demonstrates
elements for the region and have an area designated for safe refuge, if appropriate. Compliance
9.3. Standard Operating Procedures (SOPs) should be developed for project or process shut-
Compliance
down, including an evacuation plan. Drills to practice the procedure and plan should also be
Anticipated
undertaken annually.
Workspace and Exit
9.4. The space provided for each worker, and in total, should be adequate for safe execution
of all activities, including transport and interim storage of materials and products.
Passages to emergency exits should be unobstructed at all times. Exits should be clearly
marked to be visible in total darkness. The number and capacity of emergency exits should Demonstrates
be sufficient for safe and orderly evacuation of the greatest number of people present at any Compliance
time, and there should be a minimum two exits from any work area.
Facilities also should be designed and built taking into account the needs of disabled
persons.
Fire Precautions
9.5. The workplace should be designed to prevent the start of fires through the Demonstrates
implementation of fire codes applicable to industrial settings. Compliance
9.6. Facilities should be equipped with fire detectors, alarm systems, and fire-fighting Demonstrates
equipment. Compliance
The equipment should be maintained in good working order and be readily accessible. It
should be adequate for the dimensions and use of the premises, equipment installed,
physical and chemical properties of substances present, and the maximum number of people
present.
Demonstrates
9.7. Fire and emergency alarm systems that are both audible and visible.
Compliance
Lavatories and Showers
9.8. Adequate lavatory facilities (toilets and washing areas) should be provided for the Demonstrates
number of people expected to work in the facility and allowances made for segregated Compliance
facilities, or for indicating whether the toilet facility is “In Use” or “Vacant”. Toilet facilities
should also be provided with adequate supplies of hot and cold running water, soap, and
hand drying devices.
Where workers may be exposed to substances poisonous by ingestion and skin
contamination may occur, facilities for showering and changing into and out of street and
work clothes should be provided.
9.9. Adequate supplies of potable drinking water should be provided from a fountain with an Demonstrates
upward jet or with a sanitary means of collecting the water for the purposes of drinking. Compliance
Water supplied to areas of food preparation or for the purpose of personal hygiene (washing
or bathing) should meet drinking water quality standards.
9.10. Where there is potential for exposure to substances poisonous by ingestion, suitable Demonstrates
arrangements are to be made for provision of clean eating areas where workers are not Compliance
exposed to the hazardous or noxious substances.
Safe Access
9.11. Passageways for pedestrians and vehicles within and outside buildings should be Demonstrates
segregated and provide for easy, safe, and appropriate access. Compliance
9.12. Equipment and installations requiring servicing, inspection, and/or cleaning should Demonstrates

have unobstructed, unrestricted, and ready access. Compliance
9.13. Hand, knee and foot railings should be installed on stairs, fixed ladders, platforms, Demonstrates
permanent and interim floor openings, loading bays, ramps, etc. Compliance
Demonstrates
9.14. Openings should be sealed by gates or removable chains.
Compliance
Demonstrates
9.15. Covers should, if feasible, be installed to protect against falling items.
Compliance
Demonstrates
9.16. Measures to prevent unauthorised access to dangerous areas should be in place.
Compliance
First Aid
9.17. The employer should ensure that qualified first-aid can be provided at all times. Demonstrates
Appropriately equipped first-aid stations should be easily accessible throughout the place of Compliance
work.
9.18. Eye-wash stations and/or emergency showers should be provided close to all Demonstrates
workstations where immediate flushing with water is the recommended first-aid response. Compliance
9.19. Remote sites should have written emergency procedures in place for dealing with Demonstrates
cases of trauma or serious illness up to the point at which patient care can be transferred to Compliance
an appropriate medical facility.
Air Supply
9.20. Sufficient fresh air should be supplied for indoor and confined work spaces. Factors to Demonstrates
be considered in ventilation design include physical activity, substances in use, and process Compliance
related emissions. Air distribution systems should be designed so as not to expose workers
to draughts.
9.21. Mechanical ventilation systems should be maintained in good working order. Point- Demonstrates
source exhaust systems required for maintaining a safe ambient environment should have Compliance
local indicators of correct functioning.
9.22. Re-circulation of contaminated air is not acceptable. Air inlet filters should be kept Demonstrates
clean and free of dust and microorganisms. Heating, ventilation and air conditioning (HVAC) Compliance
and industrial evaporative cooling systems should be equipped, maintained and operated so
as to prevent growth and spreading of disease agents or breeding of vectors of public health
concern.
10. Communication and Training
OHS Training
Demonstrates
10.1. Provisions should be made to provide OHS orientation training to all new employees.
Compliance
10.2. Training should consist of basic hazard awareness, sites specific hazards, safe work Demonstrates
practices, and emergency procedures for fire, evacuation, and natural disaster, as Compliance
appropriate. Any site-specific hazard or color coding in use should be thoroughly reviewed as
part of orientation training.
10.3. If visitors to the site can gain access to areas where hazardous conditions or Demonstrates
substances may be present, a visitor orientation and control program should be established Compliance
to ensure visitors do not enter hazard areas unescorted.
10.4. The employer should ensure that workers and contractors, prior to commencement of Demonstrates
new assignments, have received adequate training and information enabling them to Compliance
understand work hazards and to protect their health from hazardous ambient factors that
may be present.
10.5. A basic occupational training program and specialty courses should be provided, as Demonstrates
needed, to ensure that workers are oriented. Compliance
Workers with rescue and first-aid duties should receive dedicated training so as not to
inadvertently aggravate exposures and health hazards to themselves or their coworkers.
Training would include the risks of becoming infected with blood–borne pathogens through
contact with bodily fluids and tissue. Through appropriate contract specifications and
monitoring, the employer should ensure that service providers, as well as contracted and
subcontracted labor, are trained adequately before assignments begin.
Area Signage, Labeling of Equipment, Communicate Hazard Codes
10.6. Hazardous areas (electrical rooms, compressor rooms, etc.), installations, materials, Demonstrates
safety measures, and emergency exits, etc. should be marked appropriately. Signage should Compliance
be in accordance with international standards and be well known to, and easily understood
by workers, visitors and the general public as appropriate.

10.7. All vessels that may contain substances that are hazardous as a result of chemical or Demonstrates
toxicological properties, or temperature or pressure, should be labeled as to the contents Compliance
and hazard, or appropriately color coded.
Similarly, piping systems that contain hazardous substances should be labeled with the
direction of flow and contents of the pipe, or color coded whenever the pipe passing through
a wall or floor is interrupted by a valve or junction device.
10.8. Copies of the hazard coding system should be posted outside the facility at emergency Demonstrates
entrance doors and fire emergency connection systems. Compliance
10.9. Information regarding the types of hazardous materials stored, handled or used at the Demonstrates
facility, including typical maximum inventories and storage locations, should be shared Compliance
proactively with emergency services and security personnel to expedite emergency response
when needed.
10.10. Representatives of local emergency and security services should be invited to Demonstrates
participate in periodic (annual) orientation tours and site inspections to ensure familiarity Compliance
with potential hazards present.
11. Physical Hazards
Rotating and Moving Equipment
11.1. Machines design should eliminate trap hazards and ensuring that extremities are kept Demonstrates
out of harm’s way under normal operating conditions. Compliance
Where a machine or equipment has an exposed moving part or exposed pinch point that
may endanger the safety of any worker, the machine or equipment should be equipped with,
and protected by, a guard or other device that prevents access to the moving part or pinch
point. Guards should be designed and installed in conformance with appropriate machine
safety standards.
11.2. Turning off, disconnecting, isolating, and de-energising machinery with exposed or Demonstrates
guarded moving parts, or in which energy can be stored (e.g. compressed air, electrical Compliance
components) during servicing or maintenance, in conformance with a standard such as c.
11.3. Designing and installing equipment, where feasible, to enable routine service, such as Demonstrates
lubrication, without removal of the guarding devices or mechanisms. Compliance
Noise
11.4. No employee should be exposed to a noise level greater than 85 dB(A) for a duration Demonstrates
of more than 8 hours per day without hearing protection. In addition, no unprotected ear Compliance
should be exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C).
11.5. The use of hearing protection should be enforced actively when the equivalent sound Demonstrates
level over 8 hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average Compliance
maximum sound level reaches 110dB(A). Hearing protective devices provided should be
capable of reducing sound levels at the ear to at least 85 dB(A).
11.6. For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or duration Demonstrates
should be reduced by 50 percent. Compliance
11.7. Prior to the issuance of hearing protective devices as the final control mechanism, use Demonstrates
of acoustic insulating materials, isolation of the noise source, and other engineering controls Compliance
should be investigated and implemented.
11.8. Periodic medical hearing checks should be performed on workers exposed to high Demonstrates
noise levels. Compliance
Vibration
11.9. Exposure to hand-arm vibration from equipment such as hand and power tools, or
whole-body vibrations from surfaces on which the worker stands or sits, should be controlled
Demonstrates
through choice of equipment, installation of vibration dampening pads or devices, and
Compliance
limiting the duration of exposure. Exposure levels should be checked on the basis of daily
exposure time and data provided by equipment manufacturers.
Electrical
Demonstrates
11.10. All energised electrical devices and lines should be marked with warning signs.
Compliance
11.11. Devices should be locked out (de- charging and leaving open with a controlled locking Demonstrates
device) and tagged-out (warning sign placed on the lock) during service or maintenance. Compliance
11.12. All electrical cords, cables, and hand power tools should be checked for frayed or Demonstrates
exposed cords. Manufacturer recommendations for maximum permitted operating voltage of Compliance
the portable hand tools should be followed.
11.13. Double insulating / grounding should be applied for all electrical equipment used in Demonstrates

environments that are, or may become, wet; using equipment with ground fault interrupter Compliance
(GFI) protected circuits.
11.14. Power cords and extension cords should be protected against damage from traffic by Demonstrates
shielding or suspending above traffic areas. Compliance
11.15. Use of appropriate labeling of service rooms housing high voltage equipment Demonstrates
(‘electrical hazard’) and where entry is controlled or prohibited. Compliance
Partial
11.16. “No Approach” zones should be established around or under high voltage power lines.
Compliance
11.17. Rubber tired construction or other vehicles that come into direct contact with, or Demonstrates
arcing between, high voltage wires may need to be taken out of service for periods of 48 Compliance
hours and have the tires replaced to prevent catastrophic tire and wheel assembly failure,
potentially causing serious injury or death.
11.18. Conduct detailed identification and marking of all buried electrical wiring prior to any Demonstrates
excavation work. Compliance
Eye Hazards
11.19. Use of machine guards or splash shields and/or face and eye protection devices, such Demonstrates
as safety glasses with side shields, goggles, and/or a full face shield. Machine and Compliance
equipment guarding should conform to standards published by organisations such as CSA,
ANSI and ISO.
11.20. Moving areas where the discharge of solid fragments, liquid, or gaseous emissions Demonstrates
can reasonably be predicted away from places expected to be occupied or transited by Compliance
workers or visitors. Where machine or work fragments could present a hazard to transient
workers or passers-by, extra area guarding or proximity restricting systems should be
implemented, or PPE required for transients and visitors.
11.21. Provisions should be made for persons who have to wear prescription glasses either Demonstrates
through the use over glasses or prescription hardened glasses. Compliance
Welding / Hot Work
11.22. Provision of proper eye protection such as welder goggles and/or a full-face eye Demonstrates
shield for all personnel involved in, or assisting, welding operations. Additional methods may Compliance
include the use of welding barrier screens around the specific work station (a solid piece of
light metal, canvas, or plywood designed to block welding light from others). Devices to
extract and remove noxious fumes at the source may also be required.
11.23. Special hot work and fire prevention precautions and Standard Operating Procedures Demonstrates
(SOPs) should be implemented if welding or hot cutting is undertaken outside established Compliance
welding work stations, including ‘Hot Work Permits, stand-by fire extinguishers, stand-by fire
watch, and maintaining the fire watch for up to one hour after welding or hot cutting has
terminated. Special procedures are required for hot work on tanks or vessels that have
contained flammable materials.
Industrial Vehicle Driving and Site Traffic
11.24. Provide training and licensing industrial vehicle Operators in the safe operation of Demonstrates
specialised vehicles such as forklifts, including safe loading/unloading, load limits. Compliance
11.25. Ensure moving equipment with restricted rear visibility is outfitted with audible back- Demonstrates
up alarms. Compliance
11.26. Establish rights-of-way, site speed limits, vehicle inspection requirements, operating Demonstrates
rules and procedures, and control of traffic patterns or direction. Compliance
Restrict the circulation of delivery and private vehicles to defined routes and areas, giving
preference to ‘one-way’ circulation, where appropriate.
Working Environment Temperature
11.27. Extreme temperatures in permanent work environments should be avoided through Compliance
implementation of engineering controls and ventilation. Anticipated
11.28. Monitor weather forecasts for outdoor work to provide advance warning of extreme
Partial
weather and scheduling work accordingly. Provide temporary shelters to protect against the
Compliance
elements during working activities or for use as rest areas.
11.29. Adjustment of work and rest periods should be regulated according to temperature Compliance
stress management procedures provided by ACGIH67, depending on the temperature and Anticipated
workloads.
11.30. Personnel should be provided with protective clothing and access to adequate Compliance
hydration such as drinking water or electrolyte drinks. Consumption of alcoholic beverages Anticipated
should be avoided.

Ergonomics, Repetitive Motion, Manual Handling
11.31. Use of mechanical assists to eliminate or reduce exertions required to lift materials, Demonstrates
hold tools and work objects, and requiring multi-person lifts if weights exceed thresholds. Compliance
11.32. Selecting and designing tools that reduce force requirements and holding times, and Demonstrates
improve postures. Compliance
Demonstrates
11.33. Provide user with adjustable work stations.
Compliance
11.34. Incorporating rest and stretch breaks into work processes, and conducting job Demonstrates
rotation. Compliance
11.35. Implement quality control and maintenance programs that reduce unnecessary forces Demonstrates
and exertions. Compliance
Demonstrates
11.36. Take into consideration additional special conditions such as left handed persons.
Compliance
Working at Heights
11.37. Provide installation of guardrails with mid-rails and toe boards at the edge of any fall Demonstrates
hazard area. Compliance
Demonstrates
11.38. Ladders and scaffolds should be properly used by trained employees.
Compliance
11.39. Use of fall prevention devices, including safety belt and lanyard travel limiting devices Demonstrates
to prevent access to fall hazard area, or fall protection devices such as full body harnesses Compliance
used in conjunction with shock absorbing lanyards or self-retracting inertial fall arrest
devices attached to fixed anchor point or horizontal life-lines.
11.40. Provide personnel with appropriate training in use, serviceability, and integrity of the Demonstrates
necessary PPE. Compliance
11.41. Inclusion of rescue and/or recovery plans, and equipment to respond to workers after Demonstrates
an arrested fall. Compliance
Illumination
11.42. Work area light intensity should be adequate for the general purpose of the location Demonstrates
and type of activity, and should be supplemented with dedicated work station illumination, Compliance
as needed.
Demonstrates
11.43. Emergency lightening should be provided in case of tripping the main light source.
Compliance
12. Chemical Hazards
Air Quality
12.1. Maintain levels of contaminant dusts, vapors and gases in the work environment at Demonstrates
concentrations below those recommended by the ACGIH as TWA-TLV’s (threshold limit Compliance
value)—concentrations to which most workers can be exposed repeatedly (8 hours/day, 40
hrs/week, week-after week), without sustaining adverse health effects.
12.2. Developing and implementing work practices to minimise release of contaminants into Demonstrates
the work environment. Compliance
12.3. Where ambient air contains several materials that have similar effects on the same Demonstrates
body organs (additive effects), taking into account combined exposures using calculations Compliance
recommended by the ACGIH.
Where work shifts extend beyond eight (8) hours, calculating adjusted workplace exposure
criteria recommended by the ACGIH.
Fire and Explosions
12.4. Flammables should be stored away from ignition sources and oxidising materials. Demonstrates
Further, flammables storage area should be: Compliance
 Remote from entry and exit points into buildings;
 Away from facility ventilation intakes or vents;
 Have natural or passive floor and ceiling level ventilation and explosion venting;
 Use spark-proof fixtures;
 Be equipped with fire extinguishing devices and self-closing doors.
12.5. Provide bonding and grounding of, and between, containers and additional mechanical Demonstrates
floor level ventilation if materials are being, or could be, dispensed in the storage area. Compliance
12.6. Where the flammable material is mainly comprised of dust, provide electrical Demonstrates
grounding, spark detection, and, if needed, quenching systems. Compliance
12.7. Define and label fire hazards areas to warn of special rules (e.g. prohibition in use of Demonstrates
smoking materials, cellular phones, or other potential spark generating equipment). Compliance

12.8. Provide specific worker training in handling of flammable materials, and in fire Demonstrates
prevention or suppression. Compliance
Corrosive, oxidising, and reactive chemicals
12.9. Corrosive, oxidising and reactive chemicals should be segregated from flammable
materials and from other chemicals of incompatible class (acids vs. bases, oxidisers vs.
reducers, water sensitive vs. water based, etc.), stored in ventilated areas and in containers
Demonstrates
with appropriate secondary containment to minimise intermixing during spills. Workers who
Compliance
are required to handle corrosive, oxidising, or reactive chemicals should be provided with
specialised training and provided with, and wear, appropriate PPE (gloves, apron, splash
suits, face shield or goggles, etc.).
Asbestos Containing Materials (ACM)
12.10. The use of asbestos containing materials (ACM) should be avoided in new buildings
or as a new material in remodeling or renovation activities. Existing facilities with ACM
should develop an asbestos management plan which clearly identifies the locations where
the ACM is present, its condition, procedures for monitoring its condition, procedures to
Demonstrates
access the locations where ACM is present to avoid damage, and training of staff who can
Compliance
potentially come into contact with the material. The plan should be made available to all
persons involved in operations and maintenance activities. Repair or removal and disposal of
existing ACM in buildings should only be performed by specially trained personnel following
host country requirements, or in their absence, internationally recognised procedures.
13. Biological Hazards
Measures to prevent biological hazards
13.1. If the nature of the activity permits, use of any harmful biological agents should be Demonstrates
avoided and replaced with an agent that, under normal conditions of use, is not dangerous Compliance
or less dangerous to workers. If use of harmful agents cannot be avoided, precautions
should be taken to keep the risk of exposure as low as possible and maintained below
internationally established and recognised exposure limits.
13.2. Work processes, engineering, and administrative controls should be designed, Demonstrates
maintained, and operated to avoid or minimise release of biological agents into the working Compliance
environment. The number of employees exposed or likely to become exposed should be kept
at a minimum.
13.3. The employer should review and assess known and suspected presence of biological Demonstrates
agents at the place of work and implement appropriate safety measures, monitoring, Compliance
training, and training verification programs.
13.4. Measures to eliminate and control hazards from known and suspected biological agents Demonstrates
at the place of work should be designed, implemented and maintained in close co-operation Compliance
with the local health authorities and according to recognised international standards.
13.5. Work involving agents in Groups 3 and 4 should be restricted only to those persons
who have received specific verifiable training in working with and controlling such materials.
Areas used for the handling of Groups 3 and 4 biological agents should be designed to Demonstrates
enable their full segregation and isolation in emergency circumstances, include independent Compliance
ventilation systems, and be subject to SOPs requiring routine disinfection and sterilisation of
the work surfaces.
14. Radiological Hazards
Acceptable effective dose limits for workplace radiological hazards
14.1. Places of work involving occupational and/or natural exposure to ionising radiation Demonstrates
should be established and operated in accordance with recognised international safety Compliance
standards and guidelines. The acceptable effective dose limits appear:
 Five consecutive year average – effective dose– 20 mSv/year for workers (min. 19 years of
age);
 Single year exposure– effective dose– 50 mSv/year for workers (min. 19 years of age);
6 mSv/year for apprentices and students (16-18 years of age);
 Equivalent dose to the lens of the eye –150 mSv/year for workers (min. 19 years of age);
50 mSv/year for apprentices and students (16-18 years of age);
 Equivalent dose to the extremities (hands, feet) or the skin – 500 mSv/year for workers
(min. 19 years of age); 150 mSv/year for apprentices and students (16-18 years of age).
14.2. Exposure to non-ionising radiation (including static magnetic fields; sub-radio Demonstrates
frequency magnetic fields; static electric fields; radio frequency and microwave radiation; Compliance
light and near-infrared radiation; and ultraviolet radiation) should be controlled to
internationally recommended limits.

14.3. In the case of both ionising and non- ionising radiation, the preferred method for Demonstrates
controlling exposure is shielding and limiting the radiation source. Personal protective Compliance
equipment is supplemental only or for emergency use. Personal protective equipment for
near-infrared, visible and ultraviolet range radiation can include appropriate sun block
creams, with or without appropriate screening clothing.
15. Personal Protective Equipment (PPE)
Providing Personal Protective Equipment (PPE) for workers additional protection
15.1. Worker, co-workers, and occasional visitors should be provided with appropriate PPE Demonstrates
that offers adequate protection. Compliance
15.2. Proper maintenance of PPE should include cleaning when dirty and replacement when Demonstrates
damaged or worn out. Proper use of PPE should be part of the recurrent training programs Compliance
for employees.
15.3. Selection of PPE should be based on the hazard and risk ranking and selected Demonstrates
according to criteria on performance and testing established. Compliance
16. Special Hazard Environments
Confined Space
16.1. Engineering measures should be implemented to eliminate, to the degree feasible, the Demonstrates
existence and adverse character of confined spaces. Compliance
16.2. Permit-required confined spaces should be provided with permanent safety measures Demonstrates
for venting, monitoring, and rescue operations, to the extent possible. The area adjoining an Compliance
access to a confined space should provide ample room for emergency and rescue
operations. 16.3. Access hatches should accommodate 90% of the worker population with
adjustments for tools and protective clothing.
16.4. Prior to entry into a permit-required confined space: Demonstrates
 Process or feed lines into the space should be disconnected or drained, and blanked and Compliance
locked-out;
 Mechanical equipment in the space should be disconnected, de-energised, locked-out, and
braced, as appropriate;
 The atmosphere within the confined space should be tested to assure the oxygen content
is between 19.5 percent and 23 percent, and that the presence of any flammable gas or
vapour does not exceed 25 percent of its respective Lower Explosive Limit (LEL);
 If the atmospheric conditions are not met, the confined space should be ventilated until the
target safe atmosphere is achieved, or entry is only to be undertaken with appropriate and
additional PPE.
16.5. Safety precautions should include Self Contained Breathing Apparatus (SCBA), life Demonstrates
lines, and safety watch workers stationed outside the confined space, with rescue and first Compliance
aid equipment readily available.
16.6. Before workers are required to enter a permit-required confined space, adequate and Demonstrates
appropriate training in confined space hazard control, atmospheric testing, use of the Compliance
necessary PPE, as well as the serviceability and integrity of the PPE should be verified.
Further, adequate and appropriate rescue and / or recovery plans and equipment should be
in place before the worker enters the confined space.
Lone and Isolated Workers
16.7. Where workers may be required to perform work under lone or isolated circumstances, Demonstrates
Standard Operating Procedures (SOPs) should be developed and implemented to ensure all Compliance
PPE and safety measures are in place before the worker starts work. SOPs should establish,
at a minimum, verbal contact with the worker at least once every hour, and ensure the
worker has a capability for summoning emergency aid.
16.8. If the worker is potentially exposed to highly toxic or corrosive chemicals, emergency Demonstrates
eye-wash and shower facilities should be equipped with audible and visible alarms to Compliance
summon aid whenever the eye- wash or shower is activated by the worker and without
intervention by the worker.
17. Monitoring
Occupational health and safety monitoring program
17.1. The occupational health and safety monitoring program should be developed. It should
include the following:
 regular inspection and testing of all safety features and hazard control measures; Demonstrates
 surveillance of the working environment: Employers should document compliance using an Compliance
appropriate combination of portable and stationary sampling and monitoring instruments;
 surveillance of workers health;

 training activities for employees and visitors should be adequately monitored and
documented.
Accidents and Diseases monitoring
17.2. The employer should establish procedures and systems for reporting and recording: Demonstrates
 Occupational accidents and diseases; Compliance
 Dangerous occurrences and incidents.
These systems should enable workers to report immediately to their immediate supervisor
any situation they believe presents a serious danger to life or health. The systems and the
employer should further enable and encourage workers to report to management all:
 Occupational injuries and near misses;
 Suspected cases of occupational disease;
 Dangerous occurrences and incidents.
17.3. All reported occupational accidents, occupational diseases, dangerous occurrences, and Demonstrates
incidents together with near misses should be investigated with the assistance of a person Compliance
knowledgeable/competent in occupational safety.
Community Health and Safety
18. Water Quality and Availability
18.1. Project activities involving wastewater discharges, water extraction, diversion or Demonstrates
impoundment should prevent adverse impacts to the quality and availability of groundwater Compliance
and surface water resources.
18.2. Drinking water sources, whether public or private, should at all times be protected so Demonstrates
that they meet or exceed applicable national acceptability standards or in their absence the Compliance
current edition of WHO Guidelines for Drinking-Water Quality.
18.3. The potential effect of groundwater or surface water abstraction for project activities Demonstrates
should be properly assessed through a combination of field testing and modeling techniques, Compliance
accounting for seasonal variability and projected changes in demand in the project area.
18.4. Project activities should not compromise the availability of water for personal hygiene Demonstrates
needs and should take account of potential future increases in demand. Compliance
19. Structural Safety of Project Infrastructure
19.1. The following issues should be considered and incorporated as appropriate into the
planning, siting, and design phases of a project:
 Inclusion of buffer strips or other methods of physical separation around project sites to
protect the public from major hazards associated with hazardous materials incidents or
process failure, as well as nuisance issues related to noise, odours, or other emissions; Demonstrates
 Incorporation of siting and safety engineering criteria to prevent failures due to natural Compliance
risks posed by earthquakes, tsunamis, wind, flooding, landslides and fire. To this end, all
project structures should be designed in accordance with engineering and design criteria
mandated by site-specific risks, including but not limited to seismic activity, slope stability,
wind loading, and other dynamic loads.
20. Life and Fire Safety
20.1. All new buildings should be designed, constructed, and operated in full compliance
Demonstrates
with local building codes, local fire department regulations, local legal/insurance
Compliance
requirements.
21. Traffic Safety
21.1. Traffic safety should be promoted by all project personnel during displacement to and Demonstrates
from the workplace, and during operation of project equipment on private or public roads. Compliance
21.2. Road safety initiatives proportional to the scope and nature of project activities should Demonstrates
include: Compliance
 Adoption of best transport safety practices across all aspects of project operations with the
goal of preventing traffic accidents and minimising injuries suffered by project personnel
and the public;
 Regular maintenance of vehicles and use of manufacturer approved parts to minimise
potentially serious accidents caused by equipment malfunction or premature failure.
Where the project may contribute to a significant increase in traffic along existing roads, or
where road transport is a significant component of a project, recommended measures
include:
 Minimising pedestrian interaction with construction vehicles;
 Collaboration with local communities and responsible authorities to improve signage,
visibility and overall safety of roads;
 Coordination with emergency responders to ensure that appropriate first aid is provided in

the event of accidents;
 Using locally sourced materials, whenever possible, to minimise transport distances;
 Employing safe traffic control measures.
22. Transport of Hazardous Materials
22.1. The procedures for transportation of hazardous materials (Hazmats) should include: Demonstrates
 Proper labelling of containers, including the identify and quantity of the contents, hazards, Compliance
and shipper contact information;
 Ensuring that the volume, nature, integrity and protection of packaging and containers
used for transport are appropriate for the type and quantity of hazardous material and
modes of transport involved;
 Ensuring adequate transport vehicle specifications;
 Training employees involved in the transportation of hazardous materials regarding proper
shipping procedures and emergency procedures;
 Providing the necessary means for emergency response on call 24 hours/day.
22.2. Guidance related to major transportation hazards should be implemented in addition to Demonstrates
measures presented in the preceding section for preventing or minimising the consequences Compliance
of catastrophic releases of hazardous materials, which may result in toxic, fire, explosion, or
other hazards during transportation.
Projects which transport hazardous materials at or above the threshold quantities should
prepare a Hazardous Materials Transportation Plan.
22.3. Procedures and practices for the handling of hazardous materials and Emergency Demonstrates
Preparedness and Response Plan should be developed for quick and efficient responses to Compliance
accidents that may result in injury or environmental damage.
23. Disease Prevention
Communicable Diseases
23.1. Recommended interventions at the project level include:
 Providing surveillance and active screening and treatment of workers;
 Undertaking health awareness and education initiatives, for example, by implementing an
information strategy to reinforce person-to-person counselling addressing systemic factors
that can influence individual behaviour as well as promoting individual protection, and
protecting others from infection, by encouraging condom use;
Demonstrates
 Training health workers in disease treatment;
Compliance
 Conducting immunisation programs for workers in local communities to improve health and
guard against infection;
 Providing treatment through standard case management in on-site or community health
care facilities;
 Promoting collaboration with local authorities to enhance access of workers families and
the community to public health services and promote immunisation.
Vector-Borne Diseases
23.2. Client in close collaboration with community health authorities, can implement an
integrated control strategy for mosquito and other arthropod-borne diseases that might
involve:
 Prevention of larval and adult propagation through sanitary improvements and elimination
of breeding habitats close to human settlements; Demonstrates
 Elimination of unusable impounded water; Compliance
 Increase in water velocity in natural and artificial channels;
 Considering the application of residual insecticide to dormitory walls;
 Promoting use of repellents, clothing, netting, and other barriers to prevent insect bites,
and other measures.
24. Emergency Preparedness and Response
Communication Systems
24.1. Alarm bells, visual alarms, or other forms of communication should be used to reliably Demonstrates
alert workers to an emergency. Compliance
24.2. Testing warning systems at least annually (fire alarms monthly), and more frequently if Demonstrates
required by local regulations, equipment, or other considerations. Compliance
24.3. Installing a back-up system for communications on-site with off-site resources, in the Demonstrates
event that normal communication methods may be inoperable during an emergency. Compliance
24.4. If a local community may be at risk from a potential emergency arising at the facility, Demonstrates
the company should implement communication measures to alert the community. Compliance

Demonstrates
24.5. Emergency information should be communicated to the media through:
Compliance
•
 A trained, local spokesperson able to interact with relevant stakeholders, and offer
guidance to the company for speaking to the media, government, and other agencies;
•
 Written press releases with accurate information, appropriate level of detail for the
emergency, and for which accuracy can be guaranteed.
Emergency Resources
Demonstrates
24.6. A mechanism should be provided for funding emergency activities.
Compliance
24.7. The company should consider the level of local fire fighting capacity and whether Demonstrates
equipment is available for use at the facility in the event of a major emergency or natural Compliance
disaster.
If insufficient capacity is available, firefighting capacity should be acquired that may include
pumps, water supplies, trucks, and training for personnel.
24.8. The company should provide first aid attendants for the facility as well as medical Demonstrates
equipment suitable for the personnel, type of operation, and the degree of treatment likely Compliance
to be required prior to transportation to hospital.
24.9. Appropriate measures for managing the availability of resources in case of an Demonstrates
emergency should include: Compliance
 Maintaining a list of external equipment, personnel, facilities, funding, expert knowledge,
and materials that may be required to respond to emergencies;
 Providing personnel who can readily call up resources, as required;
 Tracking and managing the costs associated with emergency resources;
 Considering the quantity, response time, capability, limitations, and cost of these
resources, for both site-specific emergencies, and community or regional emergencies;
 Considering if external resources are unable to provide sufficient capacity during a regional
emergency and whether additional resources may need to be maintained on-site.
24.10. Where appropriate, mutual aid agreements should be maintained with other Demonstrates
organisations to allow for sharing of personnel and specialised equipment. Compliance
24.11. The company should develop a list of contact information for all internal and external Demonstrates
resources and personnel. The list should be maintained annually. Compliance
25. Training and Updating
25.1. Training programs and practice exercises should be provided for testing systems to Demonstrates
ensure an adequate level of emergency preparedness. Compliance
25.2. Training should be conducted annually and perhaps more frequently, when the Demonstrates
response includes specialised equipment, procedures, or hazards, or when otherwise Compliance
mandated.
25.3. Provide training exercises to allow personnel the opportunity to test emergency Demonstrates
preparedness. Compliance
26. Business Continuity and Contingency
26.1. Measures to address business continuity and contingency should include the following:
 Identifying replacement supplies or facilities to allow business continuity following an
emergency;
Demonstrates
 Using redundant or duplicate supply systems as part of facility operations to increase the
Compliance
likelihood of business continuity;
 Maintaining back-ups of critical information in a secure location to expedite the return to
normal operations following an emergency.

APPENDIX C: ENVIRONMENTAL AND SOCIAL ACTION PLAN

APPENDIX C: ENVIRONMENTAL AND SOCIAL ACTION PLAN
Requirement Resources, Target and
Timetable / Frequency
Environmental & Social Risks (Legislative, Investment Evaluation Criteria
No.1 Action of Monitoring for Status
(Liability/Benefits) EBRD PR, Best Needs, for Successful
Action
Practice) Responsibility Implementation
Facilitate and coordinate the International Environmental and Social Monitoring of project performance. EBRD PR1-10 Resources: External 6 monthly prior to Phase Actions completed /
Consultant, as agreed between EBRD and TANAP, to conduct Investment: 0 operations status updated
monitoring of the project on 6 monthly intervals prior to operation Responsibility:
0.0 of Phase 0. The audits will review the project against project
commitments made in the ESIA and various Management Plans and
against this ESAP. Reports will be reviewed by the company and
released into the public domain.
Operations phase monitoring will be implemented based on a ToR Monitoring of project performance. EBRD PR1-10 Resources: External To be in place prior to Actions completed /
acceptable to EBRD using a consultant agreed by EBRD. The final Investment: beginning of operations status updated
0.1
scope of work for the monitoring will be provided to EBRD for Responsibility: phase
approval on a no objection basis.
PR1 Assessment and Management of Environmental and Social Impacts and Issues
1.1 Disclose Offshore ESMS documentation including the Emergency Offshore ESMPs and Emergency Management Plan have been EBRD PR1 (1.4) Resources: In- Disclose prior to ESMS documentation
Management Plan developed in draft form and being finalised but not yet disclosed. house commencing offshore complete & disclosed.
EIA EU Directive Investment: construction
2011/92/EU Responsibility:
1.2 Provide a cost estimate for operatonal phase Biorestoration Financial provisions for implementation of BAP & Biorestoration EBRD PR1 (1.7) Resources: In- Prior to operations phase Rationale behind costs
monitoring and maintenance sufficient for the length of the pipeline monitoring and maintenancerequirements may not be sufficient to house provided and deemed
corridor and ensure sufficient contingency budget allocations for adequately characterise biorestoration effectiveness. Investment: sufficient
any newly identified biodiversity remedial and offset activities. Responsibility:
PR2 Labour and Working Conditions
2.1 Develop strengthened documentation and key actions for Overtime work and fatigue management were raised on several EBRD PR2 (2.1) Resources: In- (a) Engagement program  Program rolled out to
agreement with TANAP and EBRD on overtime, to be incorporated separate occasions in the grievance mechanism. There is confusion at house / Contractors shared with EBRD by all workers.
into the ESMS, as follows: a site level as to the TANAP policy on overtime. ILO Core Labour Investment: Sept 2017.  Fewer grievances are
(a) Develop and conduct a program of engagement with CC TANAP is working to address overtime issues through a “Working Standards Responsibility: Ongoing engagement as lodged about
workers through appropriate mechanisms (e.g. HR Hours Action Plan”, but it is noted that emphasis is directed to legal per program. overtime/fatigue.
Managers) to clarify overtime policy at the site level and compliance around overtime, and it is not clear what fatigue  All documents are
strengthen worker understanding of policy; management measures are in place and how these measures are (b) Labour Audit Reports consistent.
(b) Continue to implement procedures, plans and employment linked with effective overtime management. completed by external  Fewer non-
contrcats consistent with working hour policies. TANAP to Further, contractors are financially incentivised for being on provider (Practical conformances by
share labour audit reports from external provider (Practical time/advance of deadlines, which may contribute to the issue of Solutions) during contractors
Solutions) with EBRD. overtime and fatigue. IESC recognises that the reduction of LTIs is a construction activities to
focus area for TANAP. be shared with EBRD.
2.2 Fatigue Management: EBRD PR2 Resources: In- Fatigue Management Plan developed and
(a) Develop a Fatigue Management Plan for TANAP and house / Consultant Plan to be developed by agreed
implement this across the project; Investment: TANAP prior to EBRD
(b) Agree the Plan and its timeframe for implementation with Responsibility: Board meeting Plan implemented as
the EBRD; agreed
(c) Implement the Plan as agreed.
2.3 Termination and retrenchment provisions: Interviews with short term labour suggests that not all CCs are EBRD PR2 (2.5) Resources: In- September 2017 for Engagement conducted
(a) Share with EBRD the Retrenchment Plans of each of the making clear what the working conditions (including house Retrenchment Plans and documented.
CCs; retrenchment/termination) are. TANAP requires provision of a ILO Core Labour Investment: Quarterly Monitoring Form amended.
(b) Share the first two quarterly monitoring reports of the document of resignation or notice of termination, in practice notice Standards Responsibility: Reports as these are
Retrenchment Plans, undertaken by TANAP of the CCs. periods for dismissal may be occurring inconsistently, particularly in available, by latest
relation to casual / short-term work. It is noted that the CCs are December 2017
required to prepare Retrenchment Plans.
PR3 Resource Efficiency and Pollution Prevention and Control
3.1 Provide annual reporting of GHG emissions to the EBRD in line with The EBRD requires that operations that produce more than 25,000 EBRD PR3 (3.4) Resources: In- 1st Quarter 2018 & Annual reporting
their accepted methodology. tonnes CO2-equivalent annually, (which TANAP does), quantify and house / Consultant annually thereafter conducted
report these emissions to the EBRD annually, in accordance with the Investment:
1 These numbers refer to the action item, and are not a reference to the relevant section of the Performance Requirements. Reference to Performance Requirements are provided in the column titled Requirement (Legislative, EBRD, PR, Best Practice).

Environmental and Social Action Plan June 2017
Page 1
Action
EBRD Methodology for Assessment of Greenhouse Gas Emissions. Responsibility:
PR4 Health and Safety
4.1 Develop a program on the prevention and management of CCs’ Community Safety MPs make commitments to provide periodic EBRD PR4 (4.8) Resources: August 2017 (ToRs and Epidemiological studies
communicable diseases in Project-affected communities: communicable disease training to workers and training on worker Contractors / the worker training conducted and findings
(a) Develop the program Terms of Reference for EBRD interactions with community members. The Community Safety MP Consultant plans) incorporated in
approval; requires that the CCs will prepare studies on incidence of Investment: management approach
(b) Implement the program as agreed, including regular communicable diseases in affected Provinces, based on Responsibility: September 2017 / community health
monitoring and reporting; epidemiological information available, to ensure that all precautions (commencement of programs
(c) Share with EBRD for the Banks’ comment the plans for are taken to prevent the transmission of such diseases due to the Program implementation)
worker training on communicable diseases. presence of workers. Engagement is required by CCs with local health
authorities to agree appropriate mitigation strategies as required.
This is reflected in CCs’ MPs, although it is not clear if such
engagement / studies have been undertaken by all CCs. It is noted
that TANAP has plans in place for worker training.
Communicable disease management is provided for occupational
response, in the Medical Emergency Response Plan, however this
Plan does not extend to community health response to Project-
induced communicable disease.
PR5 Land Acquisition, Involuntary Resettlement and Economic Displacement
5.1 RAP Fund Management: The Cut-off date from the original RAP could not be met, and BOTAS EBRD PR5 (5.2) Resources: In- August 2017 Process determined and
(a) Provide EBRD with a copy of the final RAP Fund has developed a practicable approach to evaluating and house / Consultant (implementation of implementation
Management Procedure and associated documents compensating every additional claim and justified complaint even Investment: engagement on the RAP commenced
(including brochure for information dissemination); after the cut-off date. TANAP should ensure that this commitment is Responsibility: Fund procedure)
(b) Provide for EBRD the stakeholder engagement plan, Annex met through the retrospective study to compensate all eligible PAPs
2 on RAP implementation, including specific provisions for (i.e. all members of households’ dependent on land income in
engagement with vulnerable households. addition to identified title holder, descendants of deceased land title
holders with no formal paper, people with no formal title to land;
customary users of land, disputed ownership, etc., as per the revised
Entitlements Matrix) and subsequent monitoring and auditing
processes.
5.2 Livelihood Restoration Program (LRP): TANAP is commissioning a retrospective study (due for completion in EBRD PR5 Resources: Prior to EBRD Board Livelihood Restoration
(a) Provide for EBRD comment the LRP for AGI-affected July 2017) to identify and compensate PAPs who have not been yet (5.5/5.6) Investment: meeting Program developed in
settlement prior to the Plan’s disclosure; been compensated under the new Entitlements Matrix framework. Responsibility: line with PR 5. EBRD to
(b) Proivde a copy of the completed Offshore Fisheries LRP to Further, TANAP has committed to providing for full replacement cost agree on contents of
EBRD. for all assets and will ensure that lost income is fully restored through Program.
the compensation process.
5.3 RAP Monitoring: Livelihood Restoration Plan (LRP), RAP Fund Guidance and EBRD PR5 (5.5) Resources: Prior to EBRD Board RAP External
(a) Provide to EBRD a copy of the Quarterly Internal documentation. Some payments are reported to have already been Consultant meeting and quarterly for Monitoring Team Audit
Monitoing Report (which includes monitoring of the RAP made from the RAP Fund, and for transparency these should be Investment: internal RAP monitoring completed and first
Fund, and implementation of the Corrective Actions reconciled following approval of guidance on implementation of the Responsibility: and semi-annually for Semi-annual external
Register); Fund. The new RAP documents should be developed according to the external RAP monitoring monitoring Report.
(b) Provide to EBRD the results of external regular monitoring identified timeline and publicly disclosed in a mode appropriate to the throughout construction Results submitted to
of the RAP, including payments from the RAP Fund. intended audience. period. EBRD / IESC for review.
The AGI and pipeline RAPs specify monitoring and evaluation Actions agreed and
mechanisms including indicators, implementation schedule, and Corrective Actions
budget. These RAPs would be subject to IESC/independent tracked and monitored.
monitoring and review throughout implementation in accordance with
GIP. Both internal and external monitoring have commenced, with
the 1st Quarterly Internal Monitoring Report (March 31, 2017)
reviewed by the IESC in May 2017. TANAP has contracted
independent experts for RAP External Monitoring and will produce
their 1st Semi-Annual External Monitoring Report in June 2017.A site
visit and investigation by the RAP External Monitoring Team was
completed as of May 5, 2017. This monitoring, in turn will, inform the
Impact Evaluation at the conclusion of the LA and livelihood
restoration program.
PR6 Biodiversity and Living Natural Resources

Page 2
Action
6.1 Develop and implement a Biodiversity Offset Strategy document The BAP [Rev P3 - 10] does not quantify how the project’s EBRD PR6 Resources: Third Submission of the draft Submission of the draft
that: biodiversity management actions will result in No Net Loss of Priority Party / Internal Biodiversity Offset Biodiversity Offset
(a) Quantifies residual impacts to Priority Biodiversity Features Biodiversty Features and/or Net Gain of Critical Habitats, as per Investment: Strategy Q3 2017 Strategy
and Critical Habitats, as defined in the BAP [Rev P3 – 10] EBRD’s Performance Requirement 6 Responsibility:
(b) Identifies specific biodiversity; management actions, in Final report to be Final report disclosed
accordance with the mitigation hierarchy, to achieve No disclosed by TANAP prior by TANAP prior to
Net Loss / Net Gain outcomes of these species and to EBRD Board Meeting EBRD Board Meeting
habitats of conservation importance;
(c) Quantifies No Net Loss / Net Gains based on the
successful implementation of the above actions over a
reasonable timeframe.
PR7 Indigenous People
7.1 Not applicable
PR8 Cultural Heritage
PR10 Information Disclosure and Stakeholder Engagement

10.1 Disclosure and actions to address common grievances: The main grievances received since project commencement relate to EBRD PR10 Resources: In- September 2017 & Disclosure completed.
(a) Conduct disclosure to communities of summary grievance damage to property and land, and the land acquisition process. A (10.2) house thereafter annually Records available
data and measures taken by TANAP and CCs to address quarter of all complaints registered related to damage to land. The Investment: demonstrating
the common causes of grievances; grievance process provides for legal redress, and Appeals Committees Responsibility: disclosure conducted.
(b) Include a specific section regarding resettlement related are additionally established to provide third party review of
grievances to be disclosed in summary form to relevant grievances between TANAP and complainants. This Committee
resettlement-affected stakeholders, with measures taken intends to provide an additional level of independent review of any
by TANAP to address the common causes of these unresolved complaints or grievances.
grievances.
10.2 Provide evidence to EBRD of the modality of public disclosure of ESIA documents were disclosed on the TANAP website, with key EBRD PR10 Resources: In- Prior to EBRD Board Information provided
existing key project ESMPs, including the BAP and RAP documents. documents in English and Turkish. Supplementary reports prepared (10.3) house meeting and issue resolved.
included the RAP for Above-Ground Installations (AGIs) and the RAP Investment: Information provided
for the Pipeline, prepared and disclosed due to material changes in Responsibility: and issue not resolved,
the Project. However, while the IESC recognizes that disclosure has additional actions
been achieved online, the modality of disclosure to communities in a agreed
form and format readily understood by stakeholders is ongoing with
the development of additional resettlement-related documents (i.e.
including the RAP Fund procedure and associated brochure).
The latest version of the BAP has yet to be disclosued and should be
undertaken in line with GIIP.

Page 3

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FINAL REPORT OF THE:

INDEPENDENT ENVIRONMENTAL & SOCIAL

ENVIRONMENTAL AND SOCIAL DUE DILIGENCE OF THE

ENVIRONMENTAL AND SOCIAL DUE DILIGENCE

TRANS ANATOLIAN NATURAL GAS PIPELINE PROJECT

Prepared for: European Bank for Reconstruction and Development

Prepared by: Sustainability Pty Ltd

Suite 3, 118 Flora Terrace

North Beach, Western Australia, 6020

+61 (0)8 9246 6666

Team Members: John Miragliotta Project Director

Marc Barendrecht Environmental Specialist

Amy Sexton Social/Cultural Heritage Specialist

Catherine Grant Social Advisor

Saniye Onur Local Environmental Specialist

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

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

• Commencement of offshore construction – July 2017;

• Mechanical Completion of Phase 0 pipeline – December 2017;

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

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

• Gas supply to Europe – June 2019.

PERFORMANCE REQUIREMENT 1: ASSESSMENT AND MANAGEMENT OF

Trans Anatolian Natural Gas Pipeline Project Rev 5

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

• Construction Impacts Management Plan (ESIA Appendix 5.1);

• Community Safety Management Plan (Appendix 5.2);

• Community Relations Plan (Appendix 5.3);

• Employment and Training Plan (Appendix 5.4);

• Procurement and Supply Management Plan (Appendix 5.5);

• Aggregate Management Plan (Appendix 5.6);

Trans Anatolian Natural Gas Pipeline Project Rev 5

• Cultural Heritage Management Plan (Appendix 5.8);

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

• Pollution Prevention Plan (Appendix 5.10);

• Waste Management Plan (Appendix 5.11);

• Emergency Response Plan (Appendix 5.12).

PERFORMANCE REQUIREMENT 2: LABOUR AND WORKING CONDITIONS

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

PERFORMANCE REQUIREMENT 3: RESOURCE EFFICIENCY

Trans Anatolian Natural Gas Pipeline Project Rev 5

PERFORMANCE REQUIREMENT 4: HEALTH AND SAFETY

Trans Anatolian Natural Gas Pipeline Project Rev 5

PERFORMANCE REQUIREMENT 5: LAND ACQUISITION, INVOLUNTARY

Trans Anatolian Natural Gas Pipeline Project Rev 5

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

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

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

PERFORMANCE REQUIREMENT 6: BIODIVERSITY AND LIVING NATURAL

Trans Anatolian Natural Gas Pipeline Project Rev 5

Trans Anatolian Natural Gas Pipeline Project Rev 5

PERFORMANCE REQUIREMENT 8: CULTURAL HERITAGE