While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The Project will have limited environmental and social impacts that can be managed through existing project design, and/ or readily available mitigation measures as defined in the management plans to be applied to the Project. Nonetheless and despite the limited E&S impact, the proposed IFC investment has been categorized as “A” to maintain consistency with the World Bank’s categorization procedures.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

The key environmental and social impacts include air quality, noise, employees’ and other onsite workers’ health and safety, traffic management, hazardous material and waste management, fuel transport, community health and safety. Tobene Power has presented information on its planned policies and practices that will seek to address environmental and social risks and impacts to ensure that the proposed Project will, upon implementation of specific additional agreed measures, comply with host country laws and regulations and IFC’s Performance Standards on Social and Environment Sustainability. Additional actions to be undertaken by the Company are listed in the attached Environmental and Social Action Plan (“ESAP”), which is complementary to the environmental and social management plan included in the ESIA.



Senegalese Law n° 2001-01 of January 2001 on the Environmental Code, and regulation applied to classified facilities require submission and approval of a detailed ESIA prior to construction of the type of activity of the proposed Project. Tobene Power has commissioned an ESIA from ERM, which has been subject to a technical review by the “Direction de l’Environnement et des Etablissements Classés” (DEEC), and input from both IFC and the World Bank. The ESIA addresses the potential risks and impacts from the Project and outlines proposed mitigation measures. In addition, stakeholder engagement was conducted (see Community Engagement section below).



The Company will develop and implement management programs to address ESIA-identified risks and impacts. The ESMP in the ESIA should be the basis of developing the thematic points of the management programs, key E&S issues to be addressed include management of: (i) local environmental, health and safety requirements; (ii) construction phase waste; (iii) occupational health and safety practices and training during construction and operation phases; (iv) labor and working conditions including hygiene and food safety; (v) air emissions; (vi) noise; (vii) emergency preparedness and response including first aid; (viii) drainage and storm water runoff; (ix) hazardous material storage and handling; (x) traffic safety (onsite and offsite) including transportation of fuel; (xi) solid and liquid waste handling, treatment, storage and disposal; (xii) equipment maintenance;( xiii) auditing of contractors implementation of the construction phase ESMP (included in the EIA); (xiv) community engagement with regards to labor, health/communicable diseases and safety; (xv) environmental and social performance monitoring and internal reporting including verification of monitoring data by a qualified third party consultant.The successful implementation of the actions outlined in the ESIA and IFC ESAP will require close collaboration between Tobene Power, the EPC and O&M contractors, and suppliers. The EPC contractor should have an Environment, Health and Safety (EHS) supervisor on the site. Tobene Power will
hire or designate an experienced EHS professional as well as community liaison person (if the role cannot be handled by the same person) to develop and implement Tobene Power’s E&S management programs and review those of the EPC Contractor for preconstruction, construction, operation and decommissioning phases ensuring compliance with the requirements of host country laws and IFC’s Performance Standards. The EPC contractor’s EHS site supervisor and the Company’s EHS team will ensure proper training of employees, contractors and subcontractors, ensure implementation of OHS standards on the construction site, have joint meetings on OHS and share lessons learned, and jointly investigate any incidents/accidents on the site.Storage, handling and use of HFO at the facility can present potential hazard in relation to accidental spills and fire. Both the EPC contractor and the Company will develop an emergency preparedness and response plan for the construction and operational phase respectively. The Plan should describe the procedures to follow when handling an emergency situation such as fire, hazardous material or waste spills, injuries, natural disasters. This will include establishment of a communication network between the EPC contractor, the O&M Contractor, the Company and emergency services such as fire departments, traffic police, local medical services, and the habitants in the vicinity. Furthermore, the system will be tested through a mock drill to confirm effectiveness of the system or rectify any identified oversight.

Tobene Power will monitor the indicators established in the ESIA and additional ones, as necessary, in conjunction with the EPC and O&M contractors. These indicators monitored during construction include: vehicles accidents, erosion control and water quality, noise and dust generation, waste disposal, employees health and safety practices including near misses, accidents, lost time incident, root cause analysis, and job creation within local communities. During operation, monitoring should include: point source and ambient air emissions, noise, occupational health and safety of employees and contractors, quality of effluent discharge, water and fuel consumption, sulfur content in fuel, greenhouse gas emissions, and job creation within the local communities. Specific parameters will be allocated to each of the activities above in order to track, monitor, analyze EHS and Social performance and ensure compliance with Senegalese laws and IFC Performance Standards.

Approximately 230 jobs will be created during the 18 months construction phase and 60 jobs during the operational phase with additional 20-25 temporary jobs during schedule maintenance. Tobene Power has committed to source at least 100 jobs from the local communities during the construction phase. Tobene Power will be required to develop a Human Resources (HR) policy that describes its approach to managing its workforce consistent with national labor requirements including its policies on equal opportunities, harassment, child labor, freedom of association; and a simple and clear manual which outlines the employees’ rights under national employment laws, any collective bargaining agreement as well as their rights with regards to working hours, wages, overtime compensation, benefits, company code of conduct and disciplinary action, grievance mechanism, and performance management ensuring compliance with this Performance Standard as well.

Occupational health and safety of the employees, workers engaged by third party, and potential visitors will be addressed in Tobene Power Management Programs. The EPC and O&M Contractors’ should have established health and safety management systems that are consistent with or certified to OHSAS 18001. Staff on the site (employees, contractors and subcontractors) will be required to wear relevant personal protective equipments such as hard hats, gloves, steel toe boots, goggles, ear plugs, and harness which will be supplied by Tobene Power, the EPC and O&M Contractors. Tobene Power EHS Officer will work closely with the EPC and O&M Contractors to ensure that both construction and operation follow good international industry practices, including World Bank Group General EHS Guidelines.



Prior to start of operation, designated staff will be trained in fire safety and spill response. Fire extinguishers, hydrants and pumps, first aid kits will be readily available at the Project site to ensure compliance with international best practices. An illustrated occupational health and safety manual will be provided to all personnel on the Project site and for those who are illiterate detailed explanation will be provided in the local language. As per the E&S performance monitoring requirements in PS1, the Company will track, investigate, analyze, and report on incidents and accident of its employees and subcontractors and use lessons learned as part of the training program.



Senegalese law requires that any institution, with staff of 50 people and over, must have in place a health and safety committee (HSC). As such, Tobene Power will ensure that the committee is in place and well functioning to meet legal requirement.



Tobene Power will take commercially reasonable steps and establish policies and procedures to comply with the requirements of workers engaged by third party under this Performance Standards.

The Project will use combined cycle system allowing heat recovery from the combustion engines to generate steam and power steam turbine generator enabling an efficiency gain of 4 to 6% of the total engine output.

During construction water will be supplied to the Project by tankers and during operations by the municipal water networks. No use of boreholes is anticipated. The Project will require approximately 200 m3 of water per day of which the steam turbine and cooling system will utilize 180.5m3. Approximately 1 800 m3 of water will be stored on site for fire response system.



The impact of the flue gas emissions on ambient air quality was assessed using result from diffusion tubes from 5 baseline sampling points and application of the US EPA adopted Air Emission model CALPUFF. Modeling assumed a 70m stack height and fuel with a sulfur content of 2%. The results indicate that, for the most part, ambient concentrations will be within both Senegalese limit values and European Standards of air quality. The only exception involves NO2 hourly average concentrations where the model predicts up to 5 non continuous excess a year during the rainy seasons (July to September) which represent less than 0.06% of the plant operating time. What is more, these potential non-compliances would be located in an area with no current dwellings. The Project’s contribution to ambient level of NOx will be less than 25% of the Senegalese applicable standards during 99.8% of the time. Notwithstanding, during the first two years of operation Tobene Power will conduct seasonal ambient air sampling to demonstrate air quality is within acceptable limits. Should actual monitoring indicate that the airshed ambient air quality exceeds Senegalese air quality standards, Tobene Power will implement additional pollution control measures to further reduce stack emissions. More specifically, in the case of exceedance in nitrogen oxides, Tobene Power will make the necessary capital and/or operating improvements to reduce the concentration of NOx in the engine exhaust.



The construction phase will likely have some impact on ambient noise mainly due to use of heavy equipments and influx of traffic on site. The ESIA predicted noise exceedance by 4 dB during construction phase at closest school located at 600m from the site. Noise will be mitigated during the construction phase by limiting activities to between 7am and 7pm. During operation phase, the proposed mitigation measures outlined in the ESIA will be implemented by Tobene Power to ensure compliance with national standards.



Sanitary effluents generated during construction are estimated at 40 m3 per month and will be stored in septic tanks that will be emptied by a third party licensed contractor periodically. Storm water drainage system will have an oil and water separator. It is currently planned that non contaminated effluent will be directed to a retention tank for evaporation; however, Tobene Power will look a
t opportunity to reuse this water. During operation all effluents and process waters susceptible of being contaminated will be drained toward tanks that will then be pumped and directed to the effluent treatment system. The Project will have a wastewater treatment facility consisting of flocculation -injection of sodium hydroxide (NaOH), and injection of coagulants. After treatment, the effluent will comply with the Senegalese standards and the World Bank Group guideline limits. In case of non compliance the effluent will be re-circulated to the treatment facility. The treatment facility will have a daily debit of 7 m3 and the treated effluent will be discharged in the same manner as the storm water. The remaining sludge will be transferred in BigBags to dry and handled as hazardous waste.



Waste generated during construction will include excavated soil, domestic waste, various packaging, containers, used oil, batteries, etc. The excavation will be limited given that the topography of the site is relatively flat, and that there will be no basement construction and as such excess soil could be used to level the site. Both Tobene Power’s and the contractors’ ESMP will include waste management procedures. Tobene Power will ensure that the EPC and O&M contractors appropriately minimize and control release of hazardous materials (e.g. used oils, chemicals for water treatment, fuel, and wastewater treatment). Waste will be segregated into construction, domestic, hazardous, and oily sludge and managed in a manner consistent with WBG EHS Guidelines and local regulatory requirements. Waste generated during construction phase is estimated at 20m3 daily (about a truck load). Total waste generated during operation is 3,900 m3 annually (1,800m3 of domestic waste and 2,100 from production of which two thirds are hydrocarbon sludge and used oil). Waste will be disposed-off by licensed contractors. Waste manifest will be required by Tobene Power as part of its waste management procedures.



The use of daily heavy fuel oil is estimated between 300 and 400 m3 per day and will be stored onsite in above ground storage tanks that will have secondary containment system that meet WBG EHS guidelines; the anticipated total amount of fuel onsite at any given time is estimated 9,560m3.



Greenhouse Gases: The ESIA estimated that the Project will produce 576 GWh of electricity per year, with carbon dioxide emissions of approximately 353,000 t CO2 per year while the Senegal national GHG emission level was estimated at 6788,93 GtCO2 in 2000 (source UNFCC3).

The power plant occupies 4.5 hectares within the larger 50 hectare site purchased by SENELEC. The closest residential area is Mbayene, 600m South-West of the site. To minimize health, safety and security impacts to surrounding communities from construction and operation phases, Tobene Power will develop and implement procedures to control the following:

- safety of delivery of raw materials;

- entry to the site from the main road;

- roadside incident management and spill response; and

- defensive driving, and drugs and alcohol testing for truck drivers.



To further minimize the fire risk to surrounding communities posed by storage of large quantities of fuel on the plant site, Tobene Power will secure a buffer zone that prevents future residential development within a defined distance from the storage areas. The buffer zone dimensions will be based on the hazard analysis included in the ESIA. Tobene Power as well as the EPC and O&M contractors will put in place an emergency preparedness and response system that will be tested for its integrity as described in PS1 above. Tobene Power will also ensure that security personnel have undertaken necessary screening and training in accordance with good industry practices. Tobene Power will put in place a system to investigate any credible allegations of unlawful or abusive acts of security personnel, take action or urge appropriate parties to take action to prevent recurrence, and report unlawful and abusive acts to public authorities when appropriate.

As part of the ESIA, a comprehensive stakeholder engagement was undertaken to meet the requirement of PS1 and included individual as well as group interviews to obtain views on the Project from the local communities, the local, regional, and national authorities; more specifically Rural Community of Taïba Ndiaye; village chiefs and notable of Mbayenne, Keur-Mallé, and Minam Diop; women and young girls; regional and national technical services departments, etc. These consultations took place in August and September 2012 as part of the ESIA process.

Key issues identified by stakeholders included priority to local community for unskilled employment, assistance with valorization of local products, extension of the electricity network and provision of electricity at a lower price, strengthening of water networks of the community, promotion of youth and cultural activities; in addition various concerns related to potential impacts on air quality, noise, and traffic congestion were expressed. Details of all the issues raised and interactions with the various stakeholders are included in the ESIA.

Electricity shortage is an issue in the country and power projects are generally welcomed. No objections to the Project have been raised during the ESIA stakeholder engagement process. However, further comments from these stakeholders could be forthcoming following the public consultation that will take place shortly and will be included in the final approved version of the ESIA.

A community grievance mechanism will be put in place to allow community to lodge their grievances. Tobene Power will maintain a register of complaints during construction and operation phases including actions taken to address such complaints

Tobene Power:
Address: Yoff Virage, Route de l’aéroport, Villa KP
Contact Person: Said JALKH
Email mailto:sjalkh@tobenepower.com
Website: http://www.tobenepower.com (under construction)

Broad Community Support is not applicable for this project

Task Description	Anticipated Completion Date
1. TOBENE Power will hire or designate an EHS and social Professional to develop and implement its management programs.	One month prior to start of construction
2. TOBENE Power will hire a third party qualified independent expert to verify its annual monitoring information prior to sending such information to IFC	Annually
3.    TOBENE Power will put together Health and Safety Committee and ensure that their terms of references are implemented as per legal requirements and that adequate budget is provided to implement the necessary corrective actions.	6 months after start of operation
4. TOBENE Power will conduct seasonal manual sampling to demonstrate at least 2 consecutive years of ambient air quality monitoring data at least 25% less than Senegalese Limits. TOBENE Power will make the necessary capital and/or operating improvements to reduce the concentration of NOx in the engine exhaust. Monitoring frequency will be reviewed and set by IFC based on results obtained.	During operation