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 IFC's 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

The project site is located in a designated industrial area. The ESIA showed that about 1 ha of the 3 ha site was formerly used by one farmer for market gardening and the growing of fruit trees in the past. A land acquisition procedure was implemented by SENELEC in collaboration with CGCB resulting in compensation being paid and the matter being amicably settled. A detailed inventory of assets was carried out in May 2014 and compensation has been paid. No further displacement is required and PS 5 is thus not considered applicable. Impacts related to PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resource were not identified during the ESIA. In addition, PS7: Indigenous Peoples (IP’s) and PS8: Cultural Heritage do not apply to this project as IPs are not present in the area and the brownfield site does not contain any cultural heritage.

This investment is classified as a Category B project in accordance with IFC’s Policy on Environment and Social Sustainability. Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few in number, site specific, largely reversible and readily addressed through mitigation measures, as outlined in project E&S Management Plan and the Environmental and Social Action Plan (ESAP) attached to this Environmental and Social Review Summary document (ESRS).

The key environmental and social impacts for this project during the construction phase include: noise, employees’ and other onsite workers’ occupational health and safety, transport management, hazardous material and waste management, and community health and safety. Key E&S impacts during operations will include air emissions and ambient air quality impacts (involving NOx, SOx, CO and particulates); water consumption, effluent treatment and disposal; waste management; potential safety risks such as those related to a possible increase of oil spills and explosions and fuel transport, ; and occupational health and safety.

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.

Environmental and Social Impact and Risks Identification Process and proposed Management Program:

Senegalese law requires submission and approval of a detailed ESIA prior to construction of the proposed project. ContourGlobal commissioned consultants ERM to perform the ESIA, which has been subject to technical review and input from both IFC and OPIC. The ESIA addresses the potential risks and impacts from the project and outlines proposed mitigation measures. The ESIA was approved by the National Technical Committee on January 09th, 2014, and, as per the Environmental Assessment process in Senegal, was publicly disclosed by the Department de L’Environnement et des Etablissements Classés” (DEEC) for comments on January 10th, 2015 at Rufisque Ouest. The environmental permit is available on-line.



The company will develop and implement management programs to address ESIA-identified risks and impacts, based on the ESMP contained in the ESIA. Key E&S issues to be addressed include management of: (i) air emissions; (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) local environmental, health and safety requirements; (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) community engagement with regards to labor, health/communicable diseases and safety; and (xiv) environmental and social performance monitoring and internal reporting including verification of monitoring data by a qualified third party consultant.



Organizational Capacity:

The successful implementation of the actions outlined in the ESIA and IFC ESAP will require close collaboration between ContourGlobal Cap des Biches (CGCB), the EPC and other contractors, and suppliers. The EPC contractor will be required to have an Environment, Health and Safety (EHS) supervisor on site. CGCB will hire or designate an experienced EHS professional as well as community liaison officer (if the role cannot be handled by the same person) to develop and implement CGCB’s E&S management programs and review those of the EPC Contractor for design, construction, operation and decommissioning phases ensuring compliance with Senegalese requirements 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. Storage, handling and use of HFO at the facility can present potential hazard in relati
on 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 as captured in ESAP action 10. This plan will describe the procedures to follow when handling an emergency situation such as fire, hazardous material or waste spill, worker injury or natural disaster. This will include establishment of a communication network between the EPC contractor, the company and emergency services such as fire departments, traffic police, local medical services, and the inhabitants in the vicinity. Furthermore, the system will periodically be tested through mock drills to confirm effectiveness of the system or rectify any identified oversight.

Monitoring and Review:

CGCB is required contractually to execute the construction and operation phase in accordance with environmental protection regulations of the Government of Senegal and to implement an ESMP and monitoring program based on the mitigation measures identified in the ESIA. CGCB will monitor the following construction phase indicators, in conjunction with the EPC contractor: (i) ambient air quality; (ii) erosion control and water quality; (iii) vehicles accidents; (iv) noise and dust generation; (v) waste disposal; (vi) employee health and safety statistics including near misses, accidents, lost time incidents, root cause analysis; and (vii) job creation within local communities.



During operations, monitoring will include: (a) point source and ambient air emissions; (ii) noise; (iii) occupational health and safety of employees and contractors; (iv) quality of effluent discharge; (v) water and fuel consumption, sulphur content in fuel, greenhouse gas emissions; and (vi) job creation within local communities. Specific parameters will be allocated to each of the activities above in order to track, monitor, analyse E&S performance and ensure compliance with Senegalese laws and IFC Performance Standards. Once a year CGCB will send a monitoring report to IFC to evaluate the E&S performance of the project. In addition, environmental and social performance monitoring will include verification of monitoring data by a qualified third party consultant.

During the 18 month construction phase approximately temporary 200 jobs will be created. CGCB will give priority to hiring local people when skills match available jobs. During the operational phase CGCB will generate 45 permanent jobs with an additional 20 temporary jobs during scheduled maintenance. CGCB will develop a Human Resources (HR) policy and procedures in accordance with Senegalese labor laws and IFC’s PS2 requirements as captured in the ESAP actions 4 and 5, which will clearly define its approach to managing its workforce and outline the policies with regards to workers’ rights under national legislation or any collective bargaining agreement, including provisions regarding working hours, compensation and benefits, overtime compensation, health care, company code of conduct and disciplinary action, and a worker grievance mechanism.



The HR policy and procedures will also address equal opportunities, harassment, and freedom of association. According to local labor laws, all employees must receive copies of their contracts upon being hired. CBCG will ensure that the EPC and other contractors observe the same requirements, including labor and Occupational Health & Safety (OHS) provisions, by incorporating these into key contracts and monitoring contractor performance, as per the action item 7 in the ESAP.



Health and safety of employees, workers engaged by third parties and visitors will be addressed in CGCB Management Programs. The EPC contractor will establish a health and safety management system that is consistent with OHSAS 18001. The ESIA has a section describing the methodology and steps CGCB and the EPC contractor need to take to support planning of the appropriate preventive measures. High risk levels are those linked to vehicle and machinery movements on the worksite, those linked to extreme noise from machinery during the construction phase and those linked to contact with products and fires during the operational phases. CGCB’s EHS Officer will work closely with the EPC and other contractors to ensure that both construction and operation follow good international industry practices, including applicable 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, pumps and first aid kits will be available and accessible at the project site to ensure compliance with good international industry practice. 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 during induction, safety training and toolbox talks. As per the E&S performance monitoring requirements described above in PS1, the company will track, investigate, analyze, and report on the OHS performance of its employees and contractors and use lessons learned as part of the training program. Senegalese law requir
es that any institution with a staff of 50 people and over must have in place a health and safety committee (HSC). As such, CGCB will ensure that the committee is in place and functioning as captured in the ESAP action item 6.

A baseline air quality monitoring campaign (NOx, SO2, but not particulates) was undertaken between July and November 2014. This data was used to undertake atmospheric dispersal simulation modelling using the CALPUFF methodology recommended by the US-EPA. The results of modelling over the long term (annual cycle) did not show any exceedances of air quality standards at sensitive receptors identified. The closest residential receptors likely to be affected by emissions of fine particles and dust emitted by activities taking place during the construction phase are the first dwellings located at about 400m from the project area.



Modelling assumed a fuel with a maximum sulphur content of 2% and particulate matter (PM) concentration in dry fumes of 65mg/Nm3 (exceeding the PM emission limit set by the World Bank Group EHS Guidelines for thermal power plants at 50 mg/Nm3). The results indicate that, for the most part, ambient concentrations of key emissions parameters will be within both Senegalese and WBG EHS Guidelines air quality limit values, with the exception of hourly concentrations for NO2 and SO2. The ESIA states that over the long term, air quality readings in the project area will remain below limits. In order to have reliable air quality data that is the most representative of actual conditions, CGCB will monitor NOx, NO2, PM and SO2 before construction as captured in ESAP action item 8. During the first two years of operation CGCB will conduct seasonal ambient air sampling to demonstrate air quality is within acceptable limits.



The project site is part of a major existing energy production area that comprises two SENELAC thermal power units (CIII and CIV) located to the west. Air quality modelling included the impacts from these plants. Should the planned monitoring indicate that the airshed ambient air quality exceeds Senegalese air quality standards, CGCB will implement additional pollution control measures to further reduce stack emissions. More specifically, in the case of exceedance in NO2 and SO2, CGCB will make the necessary capital and/or operating improvements to reduce the concentration in the engine exhaust.



The construction phase will likely have some impact on ambient noise mainly due to use of heavy equipment and increase of traffic on site. The ESIA identifies an acoustic climate already affected by other major sources of noise, mainly from neighboring electricity power plants operated by SENELEC, and already exceeding Senegal’s and IFC’s limits, both for daytime and night-time, as confirmed by noise measurements taken in June 2014. The ESIA predicted a slight noise exceedance in some receptors during the construction phase, though this will be temporary. During operation, the ESIA indicates an increase above the background noise generated between 0.2 and 2.2 dB(A) during the night-time. Mitigation measures for the operation phase have been included in the design, and the use of silencers on stacks, air inlets and v
entilators on ventilation output, and the installation of anti-noise panels for the generators and steam turbine have been planned. The company will monitor noise in 7 sensitive receptors as identified in the ESIA.



During construction about 8,000m3 of water will be consumed, 1,000m3 of water for sanitation purposes and 100m3 of water for washing equipment and preventing dust rising. Water will come from the existing SDE (Sénégalaise des Eaux) pipe. As described in the ESIA, the company will implement good practices in terms of run-off management (by means of characterization of the site’s surface, draining ditches and sediment traps), and effluent discharge from temporary and permanent installations (collected and stored in a temporary septic tank during the construction phase). This septic tank will be emptied as often as necessary and its contents eliminated by an approved service provider. During operation an approximate volume of 125m3/day will be required for the power plant’s industrial and domestic purposes.



The effluent treatment unit will guarantee that wastewater is evacuated as required by Senegalese regulations. A buffer tank will be created in which to store liquid effluent after treatment and prior to discharge. Average volumes discharged will be about 4 m3/day. Discharge will be made into the sea via the SENELEC discharge canal and wastewater will be monitored quarterly on pH, TSS, BOD, COD, hydrocarbons, total ammonia, total phosphorus, coliform, and other parameters (e.g. heavy metals) relevant to the operational phase when HFO is used.



Wastes generated during operational phase will include waste oils, residues derived from the centrifugation of HFO, sludge from the wastewater treatment unit, laboratory waste, maintenance waste, containers and drums contaminated with oil or chemical substances, septic tank sludge, and office waste. Solid sludge and residues from treatments will be collected for treatment and/or disposal by an independent waste management company. Liquid waste will be stored with secondary containment to prevent risk of accident spillage. Waste management will include a procedure to monitor the performance of all sub-contractors involved.



Hazardous substances such as chemicals for water treatment will be stored with secondary containment. Near and outside areas where acid is stored and handled, safety equipment will be provided, e.g. autonomous breathing protection equipment, extinguisher, and a water station with abundant flow, safety showers and eye-wash fountains. Employees will be trained regarding chemical hazards.



The project is designed to have a high thermal generating efficiency of about 47 % on HFO (gross), with resulting CO2 emissions of 419, 932 tonCO2eq/year.

Based on the hazard study conducted as part of the ESIA, the key impacts and risks include: fire, spillages, and explosions. The company is planning to implement various emergency preparedness and response actions (see PS-3 on specific measures) to mitigate potential hazards from the use and storage of liquid fuel oil and hazardous materials.

Emergency preparedness and response actions involving project nearby communities include (i) warning signs on the in the boundary fences indicating the potential hazard and requirement to evacuate in the event of an alarm, (ii) coordination with the local fire department on the evacuation in the event of fire / explosion, (iii) preparation of emergency plans including evacuation of general public around the site boundaries where applicable, and (iv) provision of training for local people engaged in activities within the hazard study area.



CGCB hired SCORPION, a private security contractor, in 2010. This contractor will provide unarmed security to ensure protection of the site and assets. CGCB has assigned the HSE supervisor as responsible manager who will ensure that these security personnel have been screened and trained in accordance with good industry practices described in PS 4. The company 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 process, stakeholder identification and consultation was undertaken in the form of information meetings and discussions with national and regional technical services, local elected representatives and members of local associations, as well as with communities neighboring the CGCB power plant development project, located in the municipality of West Rufisque. The Darou Salam Azur district, which is the nearest inhabited zone, is located at around 400m to the east of the project area. This residential area was developed in 2004 and the population is estimated at 4,000 people living in a concession area. This population may be impacted mainly by noise, vibration and/or air pollution generated during construction and operation. Stakeholders engaged included national and regional technical services, local elected representatives and members of local associations, as well as communities neighboring the CGCB power plant development project.

A stakeholder consultation campaign took place between 25th and 27th June 2014, and another was held in October 2014, as part of the ESIA process. The consultation was carried out at three different levels: local level, which involved mainly the villages and rural communities potentially concerned by the project, whilst consultations at regional and national level were used to consult with the regional offices and national institutions concerned. The sponsor presented the following: (i) the impact assessment and management plan for the plant; and (ii) mitigation measures to be implemented. Some of the concerns raised by the communities were: (i) employment generation for young people from the district, (ii) health impacts due to noise and air pollution generation, and (iii) marine pollution from fuel oil being discharged into the sea. These concerns were raised by the head of the district of Diokoul, the Mayor and local representatives. The ESIA describes all mitigation measures the company will implement to avoid these impacts. CGCB will continue with the engagement and communication with the community about the plant’s environmental performance. The ESIA was approved by the National Technical Committee on January 09th, 2014, and, as per the Environmental Assessment process in Senegal, was publicly disclosed by the Department de L’Environnement et des Etablissements Classés (DEEC) for comments on January 10th, 2015 at Rufisque Ouest.

The company will develop and implement a Stakeholder Engagement Plan, as captured in the ESAP action item 4, to proactively and systematically engage with all relevant community actors to ensure environmental and social impacts and risks – and community concerns, are understood and managed accordingly and to help identify any future issues which could negatively affect the trust, credibility and local support which the company currently has. Proactive engagement with communities and other stakeholders also provides the opportunity to highlight the positive aspects of the company’s presence in the area. Specifically, the Group will strengthen its stakeholder engagement activities by mapping all relevant stakeholders, prioritizing them by any potential negative impacts that could be created, and developing a plan for how to further enhance engagement with them. As part of this engagement effort, the company will establish a formal community grievance mechanism, as captured in ESAP item 4; inform the community of this mechanism and the policies/procedures to address any community complaints going forward.

Ludovic PIERRE
ContourGlobal  Directeur Project Senegal
Bureau GTI - 2, Place de l'Indépendance, 3rd Floor - B.P. 23607 DAKAR | SENEGAL
Cell SN : +221 76 33 84 545
mailto:ludovic.pierre@contourglobal.com


Cheick-Oumar Sylla
CEO Africa & Solution Business
ContourGlobal
Centrale Thermique de Lomé, RN 2, Route d'Aného, 01BP 3662 Lomé – Togo
Office : +228 22 23 74 10
Email: cheickmailto:-oumar.sylla@contourglobal.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
EHS capacity: CGCB will hire or designate an EHS and social Professional to develop and implement its environmental & social management systems and programs as identified in the ESIA.	06/01/2015
Independent monitoring: CGCB will hire a third party qualified independent expert to verify its annual monitoring information prior to sending such information to IFC	06/01/2015
Stakeholder Engagement Plan: CGCB will develop and implement a plan to proactively and systematically engage with all relevant community actors. It will include the following items: i. mapping all relevant stakeholders; ii. prioritizing them by any potential negative impacts; iii. developing a plan for how to further enhance engagement with them; and iv. developing external communication and grievance mechanism: This will include but be not limited to: (i) type of communication and disclosure of information to communities, (ii) frequency of communication, and (iii) logging, tracking and feedback provided of complaints resolution to communities.	06/01/2015
Human Resources: Develop and implement a Human Resources (HR) policy and procedures which will be applied to direct employees and contractors.	06/01/2015
Worker Grievance Mechanism: The grievance mechanisms should be appropriate and include direct and contracted workers. Shield workers from retribution, allow for timely response and feedback, and be gender sensitive.	06/01/2015
OHS Committee: CGCB will put together a Health and Safety Committee and ensure their terms of references are implemented as per legal requirements and that adequate budget is provided to implement the necessary corrective actions.	07/01/2015
OHS provisions in contractors contracts: will ensure that the EPC and other contractors observe the same requirements, including labor and Occupational Health & Safety (OHS) provisions, by incorporating these into key contracts and monitoring contractor performance	06/01/2015
Air quality monitoring: CGCB will monitor ambient air quality levels to determine a baseline of current conditions. CGCB will monitor NOx, NO2, PM and SO2.	05/15/2015
CGCB 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. CGCB will make the necessary capital and/or operating improvements to reduce the concentration of PM in the engine exhaust. Monitoring frequency will be reviewed and set by IFC based on results obtained.	01/30/2016
Emergency preparedness and response: Both the EPC contractor and the company will develop an emergency preparedness and response plan for the construction and operational phase respectively – as described in ESIA	07/01/2015