PS5: Land Acquisition and Involuntary Resettlement is not applicable as the project expansion will be located within the permitted footprint of 4.5 hectares, requiring no additional land. The process and issues related to the land acquisition done by Senelec for the Tobene power plant are addressed under the previous Tobene project (#33841).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable to this Project as it is located in a modified habitat which has previously been utilized for agricultural activities and surrounded by other agricultural land, residential properties, and a SENELEC substation. In addition, the project site is not considered of high biodiversity value albeit three partially protected plant species will require specific authorization prior to land clearance activities and two protected bird species have been identified on the site noting that they are proportionately found within a 10km area. In order to limit potential impacts, land clearance activity will be avoided during the nesting period of July through September.

PS7: Indigenous People (IP) is not applicable as there are no IPs identified in area.

PS8: Cultural Heritage is not applicable as the area is not identified as archeological sensitive, nor have affected people indicated any cultural heritage of interest on the project site. However, as a precautionary measure, a chance find procedure will be required as part of the construction contractor ESMP.

According to IFC’s Policy on Environmental and Social Sustainability this is a category B project because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria as is described in the following sections. The original investment was categorized A, as is typically the case for greenfield thermal power projects. This difference in categorization can be explained by the difference in incremental E&S impacts associated with a greenfield thermal power plant vs a within-footprint expansion such as that under consideration. The key incremental impact is related to air emission and noise levels due to the installation of the additional MAN 18V48/60 combustion engine. More details on the additional impact and mitigation measures are discussed in the Performance Standard 3 section.

Key environmental and social issues reviewed during this appraisal include: (a) air emissions and impact on ambient air quality (involving NOx, SOx, CO and particulate matter); (b) occupational health & safety and labor practices of Tobene and contractors engaged during construction and operation; (c) water consumption and effluent treatment and disposal; (d) management of waste and hazardous materials; (e) prevention and response of emergencies such as those related to potential oil spills, fire, and explosions; (f)  management of impacts on communities from noise and air emissions; (g) engagement with communities; and (h) effectiveness of the company's management systems, including its internal capacity and staffing, to undertake the project in a manner that is consistent with IFC Performance Standards.

 IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

Tobene Power commissioned ERM consultants to provide an addendum (“Environmental note - March 2016) to the environmental and social impact assessment (ESIA) prepared in June 2013 (available at: http://tobenepower.com/EIES_Tobene_Final_14062013.pdf) to include additional impacts due to the 18 MW extension. This annex to the ESIA (March 2016) contains information to assess project related risks and potential impacts linked to the increase in air emissions and noise during operations, and proposes appropriate mitigation measures. These mitigation measures had already been identified in the first ESIA (June 2013) and include the utilization of HFO with a sulfur content of less than 2 percent, air quality monitoring of the airshed in terms of NO₂ and SO₂ concentration, and monthly stack emissions testing.

The appointed EPC contractor for the 18 MW extension is the same as for the initial phase, MPG Services S.A.L, also a subsidiary of the MATELEC Group. To ensure implementation of mitigation measures as outlined in the environmental and social management plan (ESMP), Tobene Power established an EHS organization on site, consisting of the QHSE coordinator of the EPC contractor and EHS supervisors of the four main subcontractors. MAN Diesel & Turbo (member of the EPC consortium) also mobilized its QHSE representative to ensure implementation of MAN’s procedures.  However, Tobene’s oversight of EHS aspects at the project site was not initially effective, with several gaps in implementation of the ESMP and one fatal accident recorded in December 15^th, 2015.  A second fatality was recorded in September 24^th, 2016. In January 2016, Tobene hired an EHS Officer to manage EHS aspects at the plant, and to coordinate and oversee EHS practices among construction contractors still on site.

Both the EPC contractor and Tobene Power are subsidiaries of the MATELEC Group and adhere to its EHS Policy. The policy is available at: http://www.matelecgroup.com/files/ESHP0.0-Environmental-Safety-Health-Policy.pdf.  

Tobene Power S.A. will ensure that it’s recently appointed EHS Officer has the authority and resources to guarantee implementation of the mitigation measures proposed in the ESMP and address the deficiencies identified during the construction of the initial phase, through strengthening the implementation of the E&S management system in line with the requirements of IFC Performance Standard 1. As part of the E&S management system, Tobene Power will periodically review and update its E&S procedures, and ensure that employees and contractors are adequately trained to perform their duties in accordance to up-to-date procedures. (ESAP action nr.1) 

Storage, handling and use of HFO at the facility can present potential hazards in relation to accidental spills and fire. Tobene will implement an emergency preparedness and response plan for the construction of the 18 MW extension and the operation phase, and ensure the EPC contractor and all sub-contractors implement the same procedures as for the first phase of the project. The emergency plan – including a fire safety plan – will be approved by the relevant authorities (i.e. Plan d’Operation Interne, POI) and will be in line with the requirements of IFC Performance Standard 1.  The plan will identify possible emergency settings – such as explosions, fire, accidental spills, injuries, natural disasters – and establish adequate response procedures.  A communication network between the EPC contractor, sub-contractors, the O&M contractor, Tobene Power, inhabitants in the vicinity, and emergency services such as fire departments, traffic police, and local medical services, will be established.  The system will be tested periodically through drills – with the participation of the local fire department – to confirm its effectiveness and any deficiency will be rectified.

Tobene Power S.A. monitors some of the indicators established in the ESMP, in conjunction with the EPC and sub-contractors. Given that some important parameters are not monitored on an on-going basis (for example noise and air quality), Tobene Power will strengthen its E&S monitoring program and ensure it includes the collection, record, and analysis of data, and that monitoring results are reported internally to TP’s senior management for review and used to identify and undertake any corrective action to improve E&S performance and ensure compliance with Senegalese laws and IFC Performance Standards (ESAP action nr.1). Sargent & Lundy was hired in October 2016 to act as the E&S independent consultant for the project with the task to verify that all environmental & social impacts are managed in accordance with IFC Performance Standards, and that data collected and methodologies used for monitoring are adequate.

Although this project expansion will not require additional land to be acquired, during the due diligence process it was observed that agricultural activities are still being performed in the project buffer zone adjacent to the fence. Tobene will hire a social expert, approved by IFC, to identify the number of people undertaking activities in the security perimeter zone outside of the project fence as specified in the ESIA (dated March 2013). These mapping of people and type of crops harvested will be updated regularly to ensure information is accurate. In addition, this social expert will develop and monitor a livelihood restoration plan for the people economically displaced (17) through Senelec’s  previous land acquisition process for the 4.5 ha of land originally provided for the Tobene power plant. This process is described in the ESRS for the Tobene project (#33841). This expert will also determine if additional mitigation measures are necessary (ESAP action nr.2 and 3).

The construction phase of the extension is expected to finalize in December 2016 and required up to 50 workers during peak time activities. During the operation phase, Tobene Power will employ around 45 permanent workers, and approximately 30 people contracted through third parties for security, cleaning, catering and some maintenance activities. There was no worker accommodation established for the construction phase and it’s not foreseen for the operation phase. Workers were responsible to find lodging in the nearby town of Tivaouane.

Human Resources Policies and Procedures: Tobene Power is in the process of developing all relevant policies and procedures to comply with the objectives of IFC Performance Standard 2, which include (a) the non-discrimination in terms of recruitment and hiring, compensation, terms of employment, access to training, job assignment, promotion, termination of employment, and disciplinary practices; (b) the respect of workers’ rights to form or to join workers’ organizations; and (c) the provision of a safe and healthy work environment for direct employees, contractors and/or sub-contractors (ESAP action nr.4). Tobene Power will ensure that these requirements are also incorporated into the contractual agreements with its main contractors and sub-contractors (i.e. EPC, O&M) (ESAP action nr.5).

Working Conditions and Terms of Employment: Tobene Power provides working conditions and terms of employment in accordance to the national Labor Code and IFC Performance Standard 2. Working conditions and terms of employment – including type of employment contract, working hours and overtime arrangements, wages and overtime pay, benefits, wage deductions, breaks, rest days, holidays, leave, workers’ organizations, access to training, performance evaluations, and disciplinary procedures– are documented in the Human Resources manual. To reinforce already established policies, Tobene will communicate to workers in a format and a language they can understand at the time of employment all provisions under the terms of employment. This is applicable to direct workers and all workers on site irrespective of the type of working contract (contractors/sub-contractors) (ESAP action nr.4). Tobene Power will ensure the aforementioned requirement is incorporated also into contractual agreements with its main contractors and sub-contractors. (ESAP action nr.5)

Workers’ organizations: At the moment, one employees’ representative has been appointed by Tobene’s management until elected officials are chosen. Employees are free to voice their opinions and concerns via this representative.

Grievance Mechanism: Tobene Power has developed and implemented a grievance mechanism for all direct employees and contracted workers that are regularly on site. The mechanism allows for timely feedback to those concerned and timely resolution, shields complainants from retribution, and allows for anonymous and confidential complaints to be raised and addressed. However, no grievances have been filled during the construction period and Tobene Power will communicate to all workers on site that this mechanism is available to raise any concern related to working conditions and terms of employment (ESAP action nr.4). Tobene will also maintain a grievances log and will report on trends to IFC as part of the AMR.

Occupational Health and Safety: The original ESIA (June 2013) performed an evaluation of professional risks for construction and operations phases. The highest risks identified during construction are linked to vehicle and machinery movements on the worksite. The highest risks identified during operations are electric, chemical, fire and explosions, and risks linked to the use of machines. 

Several gaps with regards to good OHS practices were identified during the due diligence process, including limited implementation of OHS procedures, and lack of oversight of OHS practices by both the contractors and Tobene; therefore, Tobene will review its’ OHS procedures, as presented below, and set up a joint management-worker health and safety committee. Tobene, will ensure the committee has the capacity and resources to perform its work effectively and monitor health & safety aspects throughout the lifecycle of the project.

As part of its E&S management system, Tobene Power will perform job hazard analyses by a qualified professional which will be reviewed and updated regularly and when changes to the work stations and processes occur. Safe work procedures will be developed based on these analyses, and an illustrated occupational health and safety manual will be available to workers at the time of hiring.  For workers that are illiterate, detailed explanation will be provided in the local language during induction. Tobene Power will also install all the necessary hazard warning signs, implement a safety training program, and continue to regularly conduct safety toolbox talks (ESAP action nr.6).

Unfortunately, during construction two fatalities occurred in the project site involving two different contractors. Tobene undertook an investigation for both accidents and mitigation measures where implemented. Tobene Power will continue requiring its contractors to ensure use of relevant personal protective equipment, implement safe work permits (e.g. excavations, working at height, confined space, electrical works), and tag-out/lockout systems, and implement an incident/accident recording/reporting system, to ensure a zero-accident objective can be achieved on site. Tobene Power will periodically review OHS performance of contractors during construction and operation phases.

Welfare facilities for workers: The company provides restaurant facilities, toilets and changing rooms for all workers on-site. Going forward, Tobene will ensure that access to drinking water is available for all workers.

GHG Emissions: The project is designed to have a net plant efficiency of about 46% in combined cycle mode.  The MAN 18V48/60 is a dual fuel engine and can be switched from liquid fuel to gas operation mode without retrofitting requirements.  Should Senegal succeed in introducing natural gas in the country's fuel mix, Tobene will undertake a cost-benefit analysis of operating the plant on natural gas and will assess the feasibility on doing so. In the previous ESIA, with a guaranteed capacity of 70 MW, the estimated annual GHG emissions were about 350,000 tons of CO2 equivalent. Therefore, the estimated GHG emissions of six 18 MW MAN 18V48/60 engines using HFO and operating at full installed capacity is 540,000 tons of CO2 equivalent. This represents a contribution of less than 3% of the country’s annual emissions.

Air Emissions and Ambient Air Quality:  The ESIA consultant monitored concentrations of NO₂ and SO₂ (using passive diffusion tubes) at five (5) monitoring sites from September 18 to October 12, 2012. As data were collected only during three weeks during the rainy season, they cannot be extrapolated to obtain the annual average concentration of pollutants and determine if the airshed is classified as degraded or non-degraded according to the relevant air quality standards. In addition, no data were collected for particulate matter.

Considering the limited data available, the average concentrations of NO₂ in the five locations, from September 18 to October 12, are well below the relevant air quality standards.  On the other hand, the average concentrations of SO₂ in the five locations, from September 18 to October 12, are below the Senegalese standards but above European standards. According to the ESIA, the high concentration in SO2 could be explained by the presence of a phosphate mine close to the study area.

Air dispersion modeling – using the US EPA approved CALPUFF modeling system – was performed to assess the potential impacts associated with the atmospheric emissions of the six MAN 18V48/60 engines running on HFO. Modeling assumed a fuel with a sulfur content of 2%, stack heights of 65 m, indicative flue gas emissions provided by MAN, and engines operating 24 hours/day.  The average sulfur content in the fuel received during 2015 was 0.4%, well below the assumed 2% used in the modelling, hence results indicate a worst-case scenario. Is important to note that flue gas emissions provided by MAN do not exceed Senegalese standards and IFC EHS Guidelines for thermal power plants in non-degraded airsheds. Also, a first stack emissions testing for NOx and SO₂ was carried out in March 2016 by an independent expert confirming that emissions by the power generating engines are within the relevant standards.

As no baseline air quality data is available, the air dispersion modelling only shows the project contribution to air quality, and not the predicted environmental concentrations.  As a general rule, in non-degraded airsheds, the IFC EHS General Guidelines suggests that a project should not contribute more than 25% of the applicable air quality standards. According to the air dispersion modelling, project contribution to the concentration of pollutants is within 25% of the applicable air quality standards. The only exception involves NO₂ hourly average concentrations where the model predicts up to 9 non-continuous excesses per year; these maximum NO₂ hourly average concentrations will occur close to the plant and outside residential areas and sensitive receptors.

Tobene Power will conduct monthly ambient air sampling during the first two years of operation to demonstrate air quality is within acceptable limits (ESAP action nr. 7). Should ambient air quality exceed relevant air quality standards, Tobene Power will implement additional pollution control measures to further reduce stack emissions to comply with relevant emissions guideline for degraded airsheds (ESAP action nr. 8). Tobene Power will engage a consultant, approved by the lenders, to confirm that there are no cumulative impacts on the quality of the airshed due to operations of a neighboring mine and associated power plant.  

Noise:Baseline noise levels for the existing plant (without extension) monitored at two receptor points located at the limit of the residential areas are within permissible national and IFC ambient noise limits during daytime post operations commencing. The ESIA addendum for the extension states that, based on the results of the modeling, the noise level increase due to the addition of the new engine should remain within the levels accepted by the IFC/WBG EHS guidelines. Noise levels were not measured at night, but as noise levels at daytime were 44 dB(A), it is expected that nighttime noise levels are also within permissible national and IFC ambient noise limits during nighttime. As the 96MW power plant is already in operation, noise levels were monitored in various workstations and at the plant boundary.  Average noise level in the machine room is 104.8 dB(A), thus Tobene Power shall implement appropriate hear protection systems for exposed workers.  Noise levels measured at the boundary of the site were 66.1 and 65.9 dB(A) and therefore within the relevant standards. Tobene will periodically monitor noise levels at the closest sensitive receptor points (not only at site boundary) outside of the plant boundaries to ensure these are within permissible national and IFC ambient noise limits (ESAP action nr. 9).

Dust: In relation to increase in dust due to increase in traffic and other activities, Tobene is watering access routes and routes inside the construction site to reduce the amount of nuisance dust.

Water consumption: Water comes from an underground pipeline which is part of the SDE (Sénégalaise des Eaux) distribution system. During operations an approximate volume of 210 m³/day will be required for the power plant’s industrial purposes, of which 30m³/day for the extension.

Wastewater Treatment:Industrial wastewater is collected, directed and treated by a de-oiling station. To ensure the correct operation of the de-oiler, Tobene will conduct monthly analysis of the water effluents of the project, including all parameters covered in the Senegalese legislation and IFC/WBG EHS guidelines (ESAP item nr 10). Sludge from the de-oiler is disposed by a qualified hazardous waste disposal operator. Tobene will also implement good practices in terms of run-off management and ensure that also potentially contaminated rain water is treated in the de-oiling station. The average volume of industrial wastewater is about 7 m³/day, and the treated industrial wastewater will be discharged into an evaporation pond which is under construction adjacent to the project site.  As this pond is outside the project site, Tobene Power will build a fence around the evaporation pond and install warning signs to prevent access from people and livestock. (ESAP action nr.13). Sanitary wastewater from temporary and permanent installations is collected in septic tanks and its contents are regularly disposed by a government approved service provider. No water course is located in the project’s area of influence, but soil is characterized by the presence of sand formations considered to be relatively permeable.  In conclusion, the project is considered to have a moderate impact on groundwater if the mitigation measures are not appropriately implemented. If groundwater shows contamination with oil or other hazardous constituents, Tobene Power will implement the necessary corrective actions to avoid contamination.

Solid Waste Management:  Waste generated during the operation phase will include domestic waste (e.g. offices, canteen), and hazardous waste, such as sludge from the de-oiler, oil and containers, used filters, oily rags, and waste from the laboratory and maintenance workshops. Contracts are already in place with licensed waste management and hazardous waste management companies for the collection, treatment, and disposal of waste. Tobene Power will implement a hazardous waste system to track hazardous waste – including contaminated media removed from the project site – from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat or dispose of the hazardous waste.

Hazardous Materials: Tobene Power will document a hazardous materials management plan and a waste management plan to describe the process of purchase, transport, storage, handling and disposal of hazardous materials and hazardous waste. These procedures and the content of material safety data sheets (MSDS) will be used to train employees about the safe handling of hazardous materials.  As part of Tobene Power’s spill prevention and control plan, secondary containment will be constructed wherever liquid hazardous materials or liquid wastes are stored, and emergency response equipment (e.g. spill response kits, self-contained breathing apparatus, safety showers and eye-wash fountains) will be located close to the areas where hazardous materials are stored (ESAP action nr.11). Construction of secondary containment around the 3,000 m³ HFO storage tank will finalized by September 2016.

Emergency Preparedness and Response:A hazard study was performed as part of the ESIA to determine safety distances from the power plant.  In the worst case scenarios (fireball following slow pressurization or boil-over from the 3,000 m³ HFO tank) irreversible effects could be felt at a distance of up to 473 m from the tank.  As the nearest settlement, the village of Miname, is located well beyond this safety distance (about 900 m), the risk to nearby communities is considered as very limited.  As of today, no residential development has been observed in the established 500 m security buffer zone. However, farming activities inside the buffer zone are still ongoing and Tobene will address any mitigation measures as presented in the PS1 section.  The control of the security buffer zone is the responsibility of the national authorities, but Tobene Power will support these authorities in the demarcation of the boundaries so as to facilitate the visibility and enforcement of the security buffer zone. Tobene Power’s emergency preparedness and response plan will include communication protocols with nearby communities to warn them in case of an emergency, and indicate if evacuation of the area is required (ESAP action nr.12). The plan will include coordination with local government agencies (i.e. fire department) to assist in the evacuation. Emergency numbers will be displayed at site at the site for use by responsible staff. 

Access to site and traffic management: To ensure the safety of local population and livestock, Tobene Power has constructed a wall around the site and installed hazard warning signs. During the due diligence process, it was noted that Tobene is digging the wastewater evaporation pond outside of the project fence, as referenced in the PS3 section. Tobene will ensure that all safety measures are implemented to avoid safety issues with nearby population and livestock (ESAP action nr.13). Also, speed limits are enforced among truck drivers, and speed limit signs have been installed along access routes. 

Security Personnel: Tobene hired an authorized private security contractor in 2014. This contractor provides unarmed security to the project and ensures protection of the site and assets. Tobene has assigned the Plant Manager as the responsible manager to ensure that security policies and procedures are adopted. These will include: (i) security personnel have been screened; (ii) security personnel has clear objectives and work orders; (iii) security personnel are trained in accordance with good industry practices; (iv) security incidents are recorded, investigated and corrective actions implemented; and (v) there is a grievance mechanism for community members and employees in the case of an incident. To date no significant security incidents have been reported at the project site (ESAP action nr.14).

The power plant is located within the rural community of Taïba Ndiaye; which includes 39 villages with an estimated population of 29,000 people and an area of 184 km², and depends administratively of the arrondissment of Meouane. The area close to the plant is scarcely populated. The closest villages to the plant are Keur-Mallé (911 inhabitants), Minam Diop (788 inhabitants) and Mbayène (1 300 inhabitants). Minam Diop, which is the closest village among the three, is located about 900 m from the plant.

As part of the ESIA, stakeholder engagement was undertaken to meet the requirement of PS1 and included: rural community of Taïba Ndiaye; village chiefs and notables of Mbayène, Keur-Mallé, and Minam; women and young girls; regional and national technical services departments. Key issues identified by stakeholders included: (i) priority to employment for local community, (ii) assistance with pricing of local products, (iii) extension of the electricity network and provision of electricity at a lower price, (iv) strengthening of water networks in the community, and (v) 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.

Tobene established a community grievance mechanism allowing community members to lodge their grievances through boxes at the entrance of the project site. Limited grievances are captured through this channel and community members prefer to discuss issues directly with project representatives. Throughout the construction process, Tobene has engaged with the Mayor of the Community of Taïba Ndiaye, supporting the improvement of school infrastructure in some of the villages, on-going maintenance of access routes to the closes villages, the collection of waste, and the construction of a football field to encourage sports within the local population youth. A hiring committee has been set up with the supervision of the Sous-Prefect of the arrondisement of Meouane to promote local recruitment and maximize positive social impacts.

Tobene will hire a skilled professional to undertake a more effective and on-going engagement with all relevant stakeholders. Tobene will also develop a stakeholder engagement plan (SEP) as a framework for effective and on-going engagement with relevant stakeholders in line with the IFC Performance Standards (ESAP action nr.2). The SEP involves: (i) stakeholder analysis and planning, (ii) disclosure and dissemination of information, (iii) community consultation and participation, (iv) grievance mechanism, and (v) ongoing reporting to affected communities. The SEP will be revised every 6 months based on lessons learned during the engagement process.

A web page has been established for the project: www.tobenepower.com. The ESIA can be downloaded from the website, and the contacts of Tobene Power’s representatives are made available.

Contact Person: Said JALKH

Company Name: Tobene Power SA

Address:  29545 Dakar Yoff - Senegal

Email: sjalkh@melecpowergen.com

Phone: +221 33 820 92 12

Facsimile: +221 33 820 46 76