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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The project site is located in a designated industrial area. The ESIA showed that about 1 ha of the 2.99 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 – Senegal’s national power utility - in collaboration with CG CdB 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, as discussed in the previous ESRS. No further displacement is required and PS5 Land Acquisition and Involuntary Resettlement 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 is a category B project according to IFC’s Policy on Environmental and Social Sustainability 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.

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 CG CdB 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 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.

ContourGlobal commissioned consultants ERM to update the environmental and social impact assessment (ESIA) prepared in March 2015 as to include additional impacts due to the 33 MW extension. Additional assessment was undertaken for the first time regarding particulate matter impacts on ambient air quality of the airshed.



The updated ESIA (March 2016) contains information to assess project related risks and potential impacts, and identifies appropriate avoidance, minimization, and compensation measures throughout the life-cycle of the project, in a manner consistent with IFC Performance Standards and good international industry practices (GIIP). The proposed mitigation measures are outlined in the environmental and social management plan (ESMP). Beyond these mitigation measures, the ESMP also outlines a framework for monitoring and reporting on E&S performance, assigns responsibilities, and estimates timing and required budget for implementation.



CG CdB will ensure adherence to IFC Performance Standards as applicable during its construction and operation phases by implementing the mitigation, monitoring, and management measures outlined in the ESMP. During the construction phase, this is done by including E&S provisions in the contractual agreements with the EPC contractor and sub-contractors, and setting up a robust oversight mechanism.



CG CdB has established an E&S organization on site, consisting of qualified EHS personnel from the EPC contractor and subcontractors, and CG CdB’s EHS Officer. The retained EPC contractor, which is the same contractor retained for the initial project, is an internationally recognized company with strong occupational health & safety culture and effective management of sub-contractors. Since beginning of the construction phase, the EPC contractor’s EHS Officer has been responsible for: (i) implementing mitigation measures, and conducting monitoring and reporting of EHS performance, as defined in the ESMP; (ii) developing an emergency preparedness and response plan; and (iii) regularly train all workers on safe working practices. CG CdB’s EHS Officer is responsible for overall EHS oversight.



During the operations phase, CG CdB will continue to employ a full-time EHS professional to implement CG CdB’s EHS management system in line with IFC Performance Standards. The EHS management system will ensure effective implementation of the ESMP and compliance with Senegalese requirements, IFC Performance Standards, and WBG EHS Guidelines. CG CdB will ensure that all applicable permits, authorizations and regulatory approvals are up to date.



CG CdB adheres to the policies and procedures of the Sponsor (Contour Global), including on environmental and social aspects. CG CdB has adopted Contour Global’s Health, Safety, and Environmental Policy, which includes the commitment to comply with WBG EHS Guidelines. The policy is available at: http://www.contourglobal.com/citizenship. CG CdB will periodically review
and update its EHS procedures, and ensure that employees and contractors are adequately trained to perform their duties in accordance to up-to-date procedures.



CG CdB has implemented an emergency preparedness and response plan, including a fire safety plan, approved by the relevant authorities (i.e. Plan d’Operation Interne, POI) and in line with the requirements of IFC Performance Standard 1, both for the construction and operations phases. The plan identifies possible emergency settings – such as explosions, fire, spills from hazardous materials and hazardous waste – and establishes adequate response procedures. Communication protocols are established between the company, contractors, inhabitants in the vicinity, and emergency services such as the fire department, police, and local medical services. Designated staff are regularly trained on the emergency response procedures. 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.



CG CdB will implement an emissions monitoring system (EMS) to monitor air emissions (i.e. NO2, SO2, and PM) from the engine stacks with portable equipment on a weekly basis. This information will be used to assess compliance with emission limits set by Senegalese laws or the World Bank Group EHS Guidelines. If the modelled concentrations of pollutants are above Senegalese and WHO air quality standards (AQS), CG CdB will analyze and implement economically feasible mitigation measures to reduce the concentration of pollutants (ESAP IFC project #35175). CG CdB will also collect, record and analyze data on the following aspects: (a) noise at two receptor points; (b) consumption of fuel and water; (c) sulfur content in HFO; (d) concentration of pollutants in effluents discharge; (e) environmental accidents such as spills or leakages of hazardous materials; (f) frequency and severity of accidents (i.e. lost time injury frequency and severity rates); (g) grievances presented by workers and external stakeholders. This information will be regularly presented to senior management for review and shall drive continual improvement. This information will be presented to IFC as part of the Annual Monitoring Report (AMR); CG CdB will hire a qualified independent expert to verify the information and methodologies used (ESAP IFC project #35175).

The construction phase of the Extension is expected to last for over 6 months (until September 2016) and will require up to 250 workers during peak time activities. During the operations phase, CG CdB will employ around 45 permanent workers, and approximately 40 people contracted through third parties for security, cleaning, catering and some maintenance activities.



Human Resources Policies and Procedures: CG CdB adheres to the human resource (HR) and occupational, health and safety (OHS) policies and procedures of the Sponsor (Contour Global). Furthermore, CG CDB has developed a HR handbook, which documents the procedures for hiring, compensation, and promotions. CG CdB reviewed and updated its HR handbook to ensure policies and procedures comply with the objectives of IFC Performance Standard 2. This update included: (a) strengthening non-discrimination provisions in terms of recruitment and hiring, compensation, terms of employment, access to training, job assignment, promotion, termination of employment, and disciplinary practices; (b) explicitly mentioning prevention of child and forced labor among contractors; (c) strengthening the provisions to respect workers’ rights to form or to join workers’ organizations; (d) and including requirements to prevent harassment and intimidation in the workplace.



Working Conditions and Terms of Employment: CG CdB 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 contracts, working hours and overtime arrangements, wages and overtime pay, benefits, wage deductions, breaks, rest days, holidays, leave, access to training, performance evaluations, disciplinary procedures, and OHS provisions – are documented and communicated to workers at the time of employment.



CG CdB has included HR and OHS provisions into the contractual agreements with the EPC contractor and subcontractors (ESAP IFC project #35175). CG CdB will ensure these requirements are incorporated into contractual agreements with contractors and subcontractors also during the operations phase. CG CDB will continue to provide training and capacity building support to contractors to understand and meet the aforesaid requirements. CG CdB will also contractually require contractors to report on OHS statistics, ESMP implementation, and worker grievances.



Workers’ organizations: As the hiring process for permanent employees has just been completed, employees’ representatives are in the process of being appointed by CG CdB’s management elected and the process is expected to be concluded by June, 2016. Employees are free to voice their opinions and concerns via their representatives.



Grievance Mechanism: Grievances can be presented directly by the employee or through the employee representatives. CG CdB will review its grievance mechanism to ensure it allows for timely feedback to those conce
rned and timely resolution, and shields complainants from retribution. The mechanism shall also be gender sensitive, and allow for anonymous and confidential complaints to be raised and addressed. CG CdB will also maintain a grievances log and will report on trends (ESAP IFC project #35175).



Occupational Health and Safety: Both the original and the updated ESIA 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, and to falling objects. The highest risks identified during operations are electric, chemical, fire and explosions, and risks linked to the use of machines.



In collaboration with the EPC contractor, CG CdB has develop a health, safety and security (HSS) plan, which describes HSS aspects during the construction, commissioning, and operation of the power plant, and how these will be managed. The EPC contractor is a reputable company with a strong safety culture and management systems in place (as described in section Performance Standard 1). As a result, no fatality and lost time accidents have occurred during the construction phase until today.



CG CdB has set up a joint management-worker health and safety committee, which performs its duties as defined per local regulations. CG CdB will ensure the committee has the capacity to perform its work effectively and monitor health & safety aspects throughout the lifecycle of the project (ESAP IFC project #35175). As part of the HSS plan, CG CdB has performed job hazard analyses, which will be reviewed and updated regularly and when changes to the work stations and processes occur. Safe work procedures have been 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. CG CdB will implement a safety training program and will regularly conduct safety toolbox talks.



CG CdB will continue requiring its contractors to ensure use of relevant personal protective equipment, implement safe work permit (e.g. working at height, confined space, electrical works), and tag-out/lockout systems, and implement an incident/accident recording/reporting system. CG CdB will periodically review OHS performance of contractors during construction and operation phases. Other relevant aspects to OHS are covered under section Performance Standard 1.

GHG Emissions: The project is designed to have a high thermal generating efficiency of about 47% on HFO (gross) with resulting GHG emissions of 700,000 tons of CO2 equivalent. This represents a contribution of about 3.45% of the country’s annual emissions.



Air Emissions and Ambient Air Quality: To determine the baseline air quality of the airshed, CG CdB monitored concentrations of (i) NO2 and SO2 (using passive diffusion tubes) at six (6) monitoring sites from November 2014 to November 2015, and (ii) PM10 and PM2.5 (using active samplers) at three (3) monitoring sites from September 2015 to December 2015.



Annual average concentration of NO2 and SO2 at the monitoring sites are below the national and WHO Air Quality Standards (AQS). Annual average concentrations of PM10 and PM2.5 are likely to be above WHO AQS. However, annual average concentrations of particulate matter (both PM10 and PM2.5) are based on four months of data collected during the dry season; as such, these are expected to be higher than the actual annual average concentrations which take into account both dry and wet months. In addition, a compositional analysis of the collected PM showed that more than 75% of PM is naturally occurring dust (or sand), with an additional 3 to 8% comprised of salt, while combustion products represent less than 15-20%. This indicates that the degradation of air quality in terms of PM is mostly due to regional phenomena. PM monitoring activities will continue until a one-year dataset is available to reassess the quality of the airshed (ESAP IFC project #35175). Depending on the results of the one-year PM monitoring, CG CdB will assess economically feasible mitigation measures to minimize the project contribution of pollutants to the airshed (ESAP IFC project #35175).



Air dispersion modeling – using the US EPA approved CALMET-CALPUFF modeling system – was performed to assess the potential impacts associated with the atmospheric emissions of the HFO engines. Modeling assumed a fuel with a sulfur content of 2%, stack heights of 40 m, indicative flue gas emissions provided by Wartsila, and engines operating 24 hours/day. Although the concentration of PM emissions from the diesel engines is 65mg/Nm3 (exceeding the PM emission limit of 30 mg/Nm3 set by the World Bank Group EHS Guidelines for thermal power plants in degraded airsheds), according to the air dispersion modeling, the project contribution is negligible, being less than 3 percent of the relevant air quality standard for daily average and less than 2 percent of the relevant air quality standard for the annual average. Project contribution of NO2 and SO2 is more significant, but predicted environmental concentrations at the monitoring sites located near sensitive receptors are still within the relevant standards.



Noise and dust: Baseline noise levels monitored at the closest residential areas and sensitive receptors are within permissible national and WBG ambient noise limits duri
ng day time, but above permissible limits at night time. Major sources of noise and dust during construction include, movement of construction machinery, excavation, and vehicular movement. Noise and dust levels increase during construction will be temporary and limited to the vicinity of the noise generating sources, except in case of movement of material through/near habitations or other sensitive receptors.



To reduce these impacts, CG CdB has implemented a traffic management plan and other mitigation measures like restriction on traffic movement during night hours, regular maintenance of vehicles, and watering and maintenance of access roads. To reduce noise levels from the power plant, CG CdB will enclose generators and steam turbines with anti-noise panels, and install silencers on exhaust stacks, air inlets, and output ventilators. With the implementation of these mitigation measures, the noise impact assessment for the operations phase indicates that the increment in noise level at sensitive receptors is expected to be within the WBG limit of 3 dB(A), and that noise levels both at the industrial site’s boundary and at sensitive receptors are largely expected to be within the WBG guideline limits. As from startup of the power plant extension, CG CdB will monitor noise at the site’s boundary and at the closest sensitive receptors every 6 months; additional measurements will be conducted to meet the WBG Guidelines.



Water consumption: During construction about 6,200m3 of water will be consumed, 1,000m3 of water for sanitation purposes and 100m3 of water for washing equipment and preventing dust generation. Water will come from the existing SDE (Sénégalaise des Eaux) distribution system. During operation an approximate volume of 40 m3/day will be required for the power plant’s industrial and domestic purposes, of which 20m3/day for the Extension.



Wastewater Treatment: The EPC contractor has implemented good practices in terms of run-off management by means of installing draining ditches and sediment traps, protecting heaps of materials from erosion, and ensuring products are properly stored onsite to avoid accidental spills and leakages. Rain water is separated from any possibly contaminated water by means of a drainage system connected to the canal used by the SENELEC power plants, which discharges into the ocean.



During the operations phase, industrial wastewater and potentially contaminated rain water will be collected, directed and treated by the effluent treatment station (i.e. de-oiling, flocculation, coagulation, and neutralization). To ensure the correct operation of the effluent treatment station, quality of treated effluent will be monitored monthly. Results of analysis will be presented to IFC as part of the Annual Monitoring Report (AMR).Treated water will be discharged into the aforementioned canal. Sanitary wastewater from temporary and permanent installations is collected in septic tanks and its contents are regul
arly disposed by a government approved service provider. Soil is characterized by the presence of clay and limestone-marl formations considered to be relatively impermeable. In conclusion, the project is considered to have a negligible impact on surface and groundwater.



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 industrial effluent treatment station and the hydrocarbon separator (residues from the centrifugation of HFO), oily waste 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. CG CdB will implement a hazardous waste system to track hazardous waste from the time it leaves the facility where it was produced, until it reaches the off-site waste management facility that will store, treat or dispose of the hazardous waste.



CG CdB will also monitor contaminated media removed from the project site and maintain records of its treatment and disposal at approved facilities. If groundwater shows contamination with oil or other hazardous constituents, CG CdB will monitor groundwater too.



Hazardous Materials: ContourGlobal has documented 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 CG CdB’s spill prevention and control plan (ESAP action #1), 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, in particular chemicals for effluent treatment, are stored. A new 3,000 m3 HFO storage tank has been built close to the new power plant, and the two 1,480 m3 HFO storage tanks located in the existing (now closed) power plant have been rehabilitated. Secondary containment has been built around all fuel storage tanks.

The site is located in an industrial area with the nearest settlement approximately 400m away.



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 scenario (boil over from the 3,000 m3 HFO tank) irreversible effects could be felt at a distance of up to 155 m from the tank. As residential areas are located well beyond this safety distance, and as the boil over is a slow phenomenon allowing neighboring population to be evacuated in such an event, the risk to nearby communities is considered as very limited. CG CdB’s emergency preparedness and response plan includes communication protocols with nearby communities to warn them in case of an emergency, and indicate if evacuation of the area is required (ESAP IFC project #35175). The plan includes coordination with local government agencies (i.e. fire department) to assist in the evacuation. Emergency numbers will be displayed at the site for use by responsible staff.



Traffic management: A Traffic Plan with traffic guidelines to control the risks associated with movement of personnel and various types of vehicles in the construction site is in place. The plan will be revised to ensure the safety of nearby communities including traffic management measures, such as limiting movement during night time and established during day hours, speed limits, restriction on honking, and driver training. (ESAP action # 2)



Security Personnel: CG CdB hired an authorized private security contractor in 2013. This contractor provides unarmed security to the project and ensures protection of the site and assets. CG CdB has assigned the EHS officer as the responsible manager to ensure that: (i) security personnel have been screened; (ii) security personnel have 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.

The power plant is located in the municipality of Rufisque West, and the closest residential area is the Darou Salum Azur district, located about 400 m to the East of the project area and with an estimated population of 4,000 people. Stakeholder identification and consultation was undertaken as part of the ESIA process for the initial 53 MW project. Interviews were held with district delegates and directors of public and private schools, and focus groups were organized with women, fishermen, shells’ gatherers, and swimmers. Limited consultations took place when updating the ESIA for the 33 MW extension; these focused on meetings with national and regional technical services, and the Mayor of Rufisque West along with other Rufisque community representatives. A summary of stakeholder consultations and community engagement is presented in the ESIA.

As result of this process, a stakeholder engagement plan (SEP) has been developed by CG CdB as a framework to have effective and on-going engagement with relevant stakeholders in line with the IFC Performance Standards. 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. With regards to community investments, CG CdB will focus in the following areas: (a) engagement with local government to improve health services, educational programs, and recreation in West Rufisque; (b) creating employment opportunities through local hiring; and (c) engagement with partners to support youth empowerment in West Rufisque. The SEP will be revised annually based on lessons learned during the engagement process. (ESAP IFC project #35175).

Contact Person: Yann Beutler
Company Name: ContourGlobal Cap des Biches
Address: Cap des biches| 2, place de l’indépendance
B.P.23607 Dakar-Ponty Sénégal
Email: mailto:yann.beutler@contourglobal.com
Phone: +221 78 378 72 72
Facsimile:

Broad Community Support is not applicable for this project

CG CdB II(38113) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
The Borrower will prepare a Spill Prevention and Control Plan ("SPCP") which shall comply with the requirements of the CTA and OPIC Loan Agreement and implement the SPCP during operations.	31-Jul-2016	Completed	Completed	1/10/2019
Transport Safety: Implement a Transport Safety Plan that will ensure the safety of the nearby communities and require its transport service providers to comply with the Transport Safety Plan.	31-Jul-2016	Completed	Completed	1/10/2019