Please review the Central requirements document located below. Please be prepared to discuss the differences in the central requirements document and our US requirements. There are many differences, so I’m expecting a lot of feedback.

INDEX

1. DOCUMENT SCOPE AND APPLICATION AREA 3

2. DEPARTMENT IN CHARGE OF THE DOCUMENT 3

3. REFERENCES 3

4. DEFINITIONS AND ACRONYMS 3

5. HEALTH, SAFETY and ENVIRONMENT 4

6. RESPONSIBILITIES 4

7. GENERAL 6

8. WORKSITE INSPECTIONS 9

9. JOB HAZARD ANALYSIS AND RISK ASSESSMENT (JHARA) 9

10. INCIDENT RESPONSE AND REPORTING 10

11. DRUGS / ALCOHOL / WEAPONS 11

12. SHORT SERVICE EMPLOYEES (SSE) 11

13. WARNING SIGNS / GUARDRAILS / PERMITS (KNOWN HAZARDS) 12

14. EMERGENCY RESPONSE / RESCUE AND EVACUATION 12

15. PERSONAL PROTECTIVE EQUIPMENT 13

16. ENVIRONMENTAL CONSERVATION / WASTE MANAGEMENT 16

17. INSPECTING AGENCIES 18

18. HAZARD COMMUNICATION / WHIMIS 18

19. MANAGEMENT OF CHANGE 19

20. WORK PERMITS 19

21. AUDITS AND INSPECTIONS 21

22. SITE SAFETY RULES 21

23. OFFSITE PERSONNEL AND VISITORS 21

24. DRONE POLICY 22

25. GENERAL OPERATIONS 22

26. ACKNOWLEDGEMENTS 32

27. CONTRACTOR SELECTION PROCEDURES 32

28. HAZARD INVENTORY / RISK ASSESSMENTS 32

29. GENERAL SITE LIST 32

30. FORMS / SITE HSE RECORDS 35

Attachment 1 - ENEL STOP WORK POLICY 36

Attachment 2 – ENEL GREEP POWER QUALITY SAFETY AND ENVIRONMENT POLICY 37

Attachment 3 - ENEL GREEN POWER NORTH AMERICA SITE RULES 38

Rev.

Date

Description

PREP.

CHKD.

APPR.

01

12/15/12

Initial Release

02

10/18/13

Updated for 14001 & 18001

03

01/04/17

Updated Incident Reporting Time, PPE Description, and overall alignment

DLG

04

01/20/17

Overall Updated Alignment

DLG

05

11/12/18

Updated for EGP NA Drone Policy

AB

06

11/28/18

Updated the ENEL Stop Work Policy, and Offsite personnel and Visitors

AB

1. DOCUMENT SCOPE AND APPLICATION AREA

This document is designed to ensure that visitors and hired contractors are working safely and in accordance to Enel Green Power North America (EGP NA) policies and procedures. The program identifies risks, the Environmental, Health & Safety (HSE) and training requirements, communicates those requirements to the contractors and verifies that the requirement are being met through training and worksite inspections.

In addition, contractors who have not been trained are prevented from accessing the facility minimizing the opportunities for untrained workers to put themselves or others at risk or to violate procedures.

This document must be followed by all non EGP NA personnel (i.e. Contractors and subcontractors) prior to and during work that is performed on premises owned, operated, or leased by or under the jurisdiction of EGP NA.

For new construction projects EGP NA may prepare an overall site HSE plan that will encompass the requirements in this document.

2. DEPARTMENT IN CHARGE OF THE DOCUMENT

The Health Safety Environment and Quality North America Area unit is responsible for drafting, updating and maintaining this document.

This document has been authorized by the Health Safety Environment and Quality department.

3. REFERENCES

· Group Enel Code of Ethics;

· Zero Corruption Tolerance (ZCT) Plan;

· Organization and Management Model according to Legislative Decree no. 231 dated 8 June, 2001 – Guidelines for non-Italian Subsidiaries

· List of reference documents issued by external organizations (laws, guidelines, regulations)

· OHSAS 18001

· ISO 14001

· EGP HSE Policy

· EGP NA Hot Work Program

· EGP NA Electrical Safety Program

· EGP NA Electrical Operating Procedures (EOP)

· EGP NA PPE Program

· EGP NA Hazard Communication Program

· EGP NA Waste Disposal Program

· EGP NA Lockout / Tagout Program

· EGP NA Confined Space Program

· EGP NA Fall Protection Program

· For additional programs please contact your EGP NA Host or HSEQ.

4. DEFINITIONS AND ACRONYMS EGP: Enel Green Power S.p.A.

EGPNA: Enel Green Power North America, Inc.

HSEQ: Health, Safety, Environment and Quality

5. HEALTH, SAFETY and ENVIRONMENT

Health and safety at work are part of our culture and they must be the distinctive trait of the conduct of every citizen of the Enel Group.

Enel Green Power aims at supporting environmental protection in the various phases of the development, construction and management of renewable plants, consistently with its Safety and Environmental Policy

All the initiatives that we carry out are aimed not only at ensuring the observance of regulations, but also at establishing top standards regarding safety at work and environmental protection in all the countries in which Enel Green Power operates, also by spreading a significant amount of resources devoted to Safety, Environment and Quality and by sharing the best global practices.

In fact, Enel Green Power has an Integrated Management System, in accordance with the international regulations ISO 9001:20015, ISO 14001:2015 and OHSAS 18001: 2007. We deal with Safety and Health management and environmental issues with a systemic vision and aiming at a continuous improvement, both directly and indirectly, therefore centering our attention not only on our staff, but also on everyone who operates for different reasons in our set up, as external coworkers, contractors or visitors.

Safety and Environmental Policy

In view of these principles, we commit to:

· integrate health and safety at work and environmental protection issues into our usual decision-making and managing activities;

· adopt technologies and practices that produce a continuous improvement of conditions regarding health and safety at work and the internal and external environment;

· take all the necessary action to eliminate risks in the field of health and safety at work that can cause incidents or injuries to people;

· take all the necessary action to avoid or reduce pollution by preventing incidents, controlling the materials that are used, the waste that is generated and the observance of the established operating practices;

· develop, through adequate information and training programs, the skills of the employees who perform different activities, under normal conditions and in situations of danger or emergency, in order to raise the awareness concerning their role and their potential, as regards both the prevention of risks in the field of health and safety, and the achievement of objectives and results of environmental performance;

· to promote and support an open dialogue with the citizens, the organizations and the administrations on the effects that the Group’s activities produce on the communities and the environment, in order to favor protecting and enhancing activities aimed at improving the internal and external health and safety.

· Specific and measurable objectives are defined annually, and their actual achievement is assessed by continuously monitoring the results that have been obtained. Subsequently, the Direction will carry out periodic revisions based on these studies.

6. RESPONSIBILITIES

6.1 Enel Green Power North America shall develop and implement company health and safety policies and procedures that comply with or exceed State, Federal and local laws and regulations; develop site health, safety and environmental plans for the workplace; analyze the workplace to identify,

eliminate, and minimize hazards through engineering, procedural, and/or PPE requirements; inform and provide training on job safety / health, incident prevention, and countermeasures for exposed personnel about the hazards they may face; monitor the work site for overall incident preventive measures; communicate and coordinate subcontractor services; assure compliance and accuracy in record keeping; and direct all incident investigations.

6.2 Enel Green Power North America

6.2.1 Enel Green Power North America management, supervisors, Health Safety, Environment and Quality unit and employees are the policy and procedure enforcement and are required to uphold and enforce company policies and procedures through the performance of their duties with a commitment to health and safety.

6.2.2 Compliance, through their role of supervision, inspections and audits shall stop work in progress and correct any condition considered unsafe. Work shall only be allowed to proceed when observed hazards have been eliminated or mitigated to the satisfaction of the authority. Enel Green Power North America shall impose disciplinary actions for non-compliance with the requirements of this document.

6.2.3 Enel Green Power North America shall insure emergency services and its equipment and protective devices are in place and operational.

6.2.4 Enel Green Power North America shall conduct and/or participate in incident investigations to determine root cause, corrective measures and closure.

6.3 All Employees

6.3.1 All employees on the job site, whether working for Enel Green Power North America or its contractors, shall;

6.3.1.1 Perform work duties in a safe and productive manner.

6.3.1.2 Obey company policies and procedures.

6.3.1.3 Stay alert to identify and report workplace hazards to your supervisor.

6.3.1.4 Participate and cooperate in incident investigations.

6.3.1.5 Protect themselves, their company, and customer assets.

6.3.1.6 Complete all required work related documents.

6.3.1.7 Maintain and exercise the right to intervene if they observe request for performance of unsafe work.

6.3.1.8 Immediately stop work when HSE issues are not being managed properly.

6.3.1.9 Be fit for duty including having proper rest and being in proper mental state.

6.4 Contractor / Subcontractor

6.4.1 Perform all work in a safe manner.

6.4.2 Establish / maintain policies and procedures and ensure employee compliance.

6.4.3 Follow applicable Federal, State and local regulations and ordinances while on Enel Green Power North America work site.

6.4.4 Provide and ensure current applicable employee training and provide proof of training on site.

6.4.5 Provide, inspect and maintain proper tools and equipment for the successful completion of the job.

6.4.6 Ensure that their employees have been and are trained in the appropriate use of required PPE.

6.4.7 Report and fully investigate all HSE incidents to determine Root Cause, corrective measures and closure.

6.4.8 Have programs in place that proactively ensure improvements to Environmental, Health, and Safety performance.

6.4.9 Provide Job Safety Analysis / Risk Assessments on all job tasks performed.

6.4.10 Provide a competent person (supervisor/foreman) to monitor employee performance.

6.4.11 Hold and document pre-job (daily) tailgate meetings to identify and discuss specific hazards pertaining to the job prior to beginning work.

6.4.12 Establish “Zero Tolerance” policy on site with specific details on items that will include disciplinary action up to removal from site.

6.4.13 Provide an Emergency Action Plan which includes muster points and tornado shelters on the site map prior to any construction commencing. Conduct a drill during first month of the in order to fix any gaps prior. Subsequent drills should be conducted at least every year or more frequently as needed.

7. GENERAL

7.1 It is the joint responsibility of EGP NA and the contractor to see that Contractors’ employees perform their work safely.

7.2 All contractors’ employees, even those working a day or less, shall receive an HSE orientation prior to working on an EGP NA project.

7.2.1 Depending on the project the orientation can be conducted by EGP NA, the contractor or both.

7.2.2 If the contractor is conducting the orientation it should be submitted to EGP NA for review.

7.2.3 Orientation shall include all job task that will be commencing on site during the project in order to educate all site personnel on potential hazards should they be around a different work area from what they work in daily.

7.3 The site safety orientation shall advise of the requirements and expectations set forth in this document and the contractor HSE program.

7.4 All Employees shall be issued an orientation sticker to be placed on hard hats upon compellation of the orientation. The sticker will include the date and location.

7.5 Some specifics that should be address during the orientation are:

7.5.1 Enel Green Power North America’s commitment to an incident-free environment, the contractors’ responsibilities and the protection of the environment including an overview of the EGP NA HSE Management System.

7.5.2 An overview of the identified hazards and risks on the site

7.5.3 The site emergency procedures

7.5.4 Designated parking areas

7.5.5 Restrictions on smoking

7.5.6 Housekeeping

7.5.7 Site Specific Rules

7.5.8 Reporting procedures

7.5.9 Waste Handling and disposal

7.6 Exclusions:

7.6.1 Individual contract/temporary workers reporting directly to an EGP NA Supervisor are excluded from this group, but they shall follow the same HSE policies as EGP NA employees

7.6.2 Contractors working in offices, or who are performing inspections/studies that do not require the use of tools or chemicals and will be escorted will be given a copy of the Contractor HSE Pamphlet by their EGP NA Host.

7.6.3 Contractors servicing garments, making pickups/deliveries or snow removal.

7.7 The HSEQ unit will maintain a prequalification process with the support of the Procurement Unit.

7.8 The contractors’ HSE plan should be reviewed, approved and on file prior to the start of work.

7.9 Contractors shall provide skilled employees capable of performing all work in a manner to prevent incidents.

7.10 Proof of current training shall be maintained on site for the following areas as required to perform their job:

7.10.1 Hazard Communication or WHIMS

7.10.2 Hearing Protection / Conservation

7.10.3 Personal Protective Equipment

7.10.4 Basic Electrical Safety (Non-Electrician)

7.10.5 Fall Prevention / Protection (incl: ladder, scaffolds)

7.10.6 Energy Isolation (Lockout / Tagout)

7.10.7 Confined Space (entry if required)

7.10.8 Fire Prevention / Portable Fire Extinguisher Use

7.10.9 Exposure Control (Blood borne Pathogens)

7.10.10 HAZWOPER First Responder (if required)

7.11 Depending on an contractor employee’s exposure to certain hazards other required training may include:

7.11.1 Respiratory Protection

7.11.2 Fall Protection

7.11.3 Personal Protective Equipment

7.11.4 Permit Required Confined Space Entry

7.11.5 Excavation Safety

7.11.6 Mechanical Lifting (including rigging, slings, etc.)

7.11.7 Manual Lifting

7.11.8 Arc Flash / Electrical Safety / NFPA 70E

7.11.9 Blasting Operations

7.11.10 Certifications in the operations of Cranes and Forklifts

7.11.11 Work at heights and rescue training (WTG Climb and Rescue-wind farm projects)

7.12 Monthly Site Safety Meetings

7.12.1 A Site Safety Meeting shall be conducted weekly to address known hazards, noncompliance issues, inspection deficiencies, and other related issues. All workers and supervisors are required to attend this meeting.

7.12.2 The contractor shall submit a copy of the safety meeting notes/minutes and attendee list to the EGP NA Host.

7.13 Pre-Job Planning Meetings

7.13.1 Each contractor shall hold a documented planning meeting prior to the work shift (daily) and/or prior to new job task implementation.

7.13.2 A competent person representing the contractor performing the work shall conduct and maintain documentation of the meeting.

7.13.3 Workers attending the meeting shall sign the attendance sheet and participate by reporting any known workplace hazards, equipment deficiencies, etc. Topics of discussion shall include workplace incidents and reviews of Job Safety Analysis (JSA‘s). This meeting should serve as the dispatch point for workers.

7.14 Emergency services for employees must be provided within five (5) minutes. Compliance with this regulation requires that contractors maintain First Aid kits and employees trained in administering First Aid and CPR.

7.14.1 Each contractor shall maintain a list of employees trained in First Aid and CPR.

8. WORKSITE INSPECTIONS

8.1 As work gets underway on a project, the HSEQ Unit and/or the EGP NA Host will conduct periodic audits of the site to certify that contractors are working safety and in accordance with EGP NA Procedures. If they are not the problems will be documented and either fixed immediately or a plan developed for corrective actions.

8.2 All inspection reports must be followed up in writing identifies the corrective measures implemented.

8.3 If the problems cannot be remedied the work will be stopped down until the problems are addressed.

8.4 Note: not all projects are audited

9. JOB HAZARD ANALYSIS AND RISK ASSESSMENT (JHARA)

9.1 Contractor / subcontractors shall undertake risk assessments of their work to identify the hazards present on the project site that have been identified by Enel Green Power North America or the contractor and other hazards that they observe prior to the start of work. These risk assessments will identify mitigation measures to reduce and control these risks.

9.2 Safety method statements will describe how these tasks will be performed implementing the necessary mitigation measures. The assessment of risk associated with performing work related operations should be performed by a competent person who is knowledgeable of the task being performed and who has the ability to identify the associated hazards. Identifying the hazards with risk to personal injury and/or property damage shall be the catalyst for providing controls and preventive measures.

9.3 Once a hazard has been identified, the competent person shall provide a means of eliminating or minimizing the hazard. Hazards shall be eliminated when possible and can be minimized

through awareness training, engineering controls, the use of personal protective equipment, and/or monitoring devices.

9.4 Competent persons (supervisors/foreman) shall utilize the JHARA report by comparing the hazards identified daily before the actual work begins and the mitigation plans developed to control these hazards. Competent persons shall monitor existing controls and preventive measures to insure accuracy and usage. The competent person shall continue to compare the actual work to the assessment allowing for changes in the assessment when change is warranted. Workers shall be familiar with the JHARA, use the existing controls and preventive measures while performing the tasks, and provide input to their supervisors to ensure JHARA procedure reflects all hazards identified.

9.5 A pre-task risk assessment must be completed prior to the start of a job/task by those involved in the task.

10. INCIDENT RESPONSE AND REPORTING

10.1 EGP NA requires that all accidents/incidents, regardless of severity, be reported, verbally, as soon as possible, to your immediate supervisor. Subcontractor’s competent persons (supervisors/foreman) shall report, verbally, all subcontractor accidents/incidents to Enel Green Power North America host or HSEQ as soon as possible.

10.2 An initial contactor accident/incident report shall be provided verbally and using the offline form to EGPNA HSEQ within twelve (12) hours.

10.3 Any incident that is “severe” or greater in severity requires the activation of the EGP NA Contingency Plan by contacting the EGP NA Host or Market Operations Call Center. They will determine additional notification and/or activation of the Emergency Management Plan.

10.4 Reportable Incidents

10.4.1 Any incident/ incident with injury / illness of any magnitude.

10.4.2 Incidents resulting in property or equipment damage of any magnitude.

10.4.3 Any near-miss incidents that could potentially have resulted in injury / illness or property or environmental damage must be reported.

10.4.4 Any chemical spills or released to water, soil or air regardless of quantity.

10.4.5 Any offsite incident that is related to the project (i.e. delivery truck traveling to the project is involved in an incident)

10.5 Incident Investigations

10.5.1 EGP NA management and supervisors will investigate all work related incidents involving company employees or company property to determine root cause, develop preventive measures and implement corrective actions following requirements in the EGP NA Incident Investigation Program

10.5.2 Contractors shall investigate all work related incidents involving their employees, subcontractors or company property to determine root cause, develop preventive measures and implement corrective actions. An EGPNA representative may participation or may oversee and direct the investigation.

10.5.3 All incidents resulting in lost time or greater severity shall be investigated by a joint team of representatives of contractor and EGP NA. Enel Green Power North America will prepare a final investigation report as outlined in REN Safety Document N1 and Enel Green Power North America Incident investigation program.

10.5.4 The final incident reports and supporting documents will be delivered or transferred to Enel Green Power North America offices within 10 days of the incident.

10.6 Injury Management

10.6.1 Prompt medical attention including First Aid services to injured employees. Enel Green Power North America shall pre-arrange for medical services in remote job sites.

10.6.2 A list of available medical services shall be maintained at the job site.

10.6.3 Contractor management / supervisor shall assure prompt medical attention including Medic First Aid services to injured employees and shall pre-arrange for medical services in remote job sites.

10.6.4 Contractors shall have a supervisor and/or site HSE representative accompany an injured employee to obtain medical services and represent the contractor’s interest to the injured employee.

10.6.5 EGP NA has a return to work program that incorporates light duty. All contractors and subcontractors must have a program that incorporates light duty.

11. DRUGS / ALCOHOL / WEAPONS

11.1 Enel Green Power North America prohibits the use, possession, manufacture, distribution, promotion, transportation or sale of alcoholic beverages, illegal drugs, inhalants, drug paraphernalia, controlled substances, firearms or weapons on the project site, whether owned or leased. Contractor personnel must not report for duty under the influence of any drug, alcoholic beverage, intoxicant or other substance including the use of over-the-counter medications which will in any way affect work ability, alertness, coordination, or response or risk the safety of others.

12. SHORT SERVICE EMPLOYEES (SSE)

12.1 Short Service Employees are employees who have less than six (6) months service or experience in the particular job they are tasked to perform. Employees that are new to the job or crew shall be accompanied by a job site mentor and shall be identified by a form of New-On- The-Job hardhat sticker or similar.

12.2 After the SSE has received the required training and the company has documented 3 months consistent safe work procedures, the SSE can remove the NOTJ sticker from his/her hard hat.

13. WARNING SIGNS / GUARDRAILS / PERMITS (KNOWN HAZARDS)

13.1 Guardrails are barriers erected to prevent workers from falling to lower levels and/or entering a hazardous area. Guardrails shall be secured when installed to prevent accidental displacement by wind, equipment, or workers, etc.

13.2 Warning signs for known hazards shall be posted near the hazard, i.e.: “Overhead Power Lines”, “Underground Pipelines”, and/or “Warning - Poison Gases May Be Present”.

13.3 Operational warnings may be posted to permit work and warn of hazards, i.e.: Lockout/Tagout, Permit Required Confined Space, Employees Working Overhead, etc.

13.4 All employees shall obey posted warning signs and be alert to the hazards they address as well as the potential hazards posed by wildlife and ranch animals.

13.5 Protection caps shall be utilized on rebar and/or T-Post to eliminate protrusion hazard.

13.6 Signage needs to be bilingual including substation and collection system labels.

14. EMERGENCY RESPONSE / RESCUE AND EVACUATION

14.1 Emergency Response

14.1.1 The Contractor shall be familiar with the EGP NA Emergency Response Plan for the project site.

14.1.2 Contractor/subcontractors shall provide for emergency response to ill or injured employees within five (5) minutes. This means there shall be at least two First Aid and CPR trained person for every crew that is more than five (5) minutes away from emergency services.

14.2 Emergency Equipment

14.2.1 Contractors/subcontractors shall maintain first aid kits, oil spill kits, fire extinguishers and means of emergency notification at every work area. Contractors/subcontractors shall provide training in the use of such equipment. Each company vehicle on site shall contain at a minimum a first aid kit.

14.3 Emergency Rescue Plans

14.3.1 When personal fall arrest systems are used, emergency rescue shall be planned to assure that workers can be promptly rescued or can rescue themselves should a fall occur. The availability of rescue personnel, ladders, or other rescue equipment must be evaluated. Contractors/subcontractors shall address rescue procedures in JHARAs, and the information shall be presented to affected employees during safety training and tailgate meetings. Contractors/subcontractors can provide their own rescue service provided appropriate training is conducted and documented. Contractor/subcontractors shall provide for emergency rescue services for employees who use personal fall arrest

systems when they do not have their own rescue teams. Rescue equipment shall be located in the immediate area where work is commencing. If project is a wind farm a mock tower rescue drill shall be conducted after first 5-10 turbines are erected.

14.4 Emergency Evacuation

14.4.1 When adverse weather conditions present a potential risk to personnel, a contractor/subcontractor competent person shall notify their workforce of required action up to and including site evacuation. Other emergency shutdown procedures may occur as a result from high wind warnings, thunderstorms and/or lightning, ice storm warnings and/or uncontrolled releases of a potentially hazardous substance. Project site lightning policy shall follow EGP NA’s policy.

15. PERSONAL PROTECTIVE EQUIPMENT

15.1 The Contractor shall supply its employees with all the proper Personal Protective Equipment

15.2 All contractors and visitors shall wear appropriate personal protective equipment (PPE). The minimum PPE for an EGP NA Project is as follows:

15.2.1 Hard Hat – Type I Class E Rated

15.2.2 Safety-toe footwear

15.2.3 Safety Glasses – ANSI Z87+

15.2.4 Long pants and shirt with sleeves Note: FR clothing may be required for access into EGP NA project. Consult with EGP NA Host.

15.3 Each contractor shall ensure that their employees wear PPE as required by the specific task being performed, the potential hazards that person will be exposed to, and the specifics of the job site. PPE requirements as recommended on Safety Data Sheets (SDS) for chemical handling and from NFPA 70E shall be strictly adhered to.

15.4 All employees shall wear a shirt with sleeves at a minimum of 4” and long pants at all times. Tank tops, sleeveless shirts, and short pants or cutoffs are not permitted. Loose or floppy clothing is prohibited around rotating or moving equipment. Rings, neck chains or loose jewelry shall be removed.

15.5 Head Protection

15.5.1 An approved ANSI Z89.1 Type I Class E or CSA equivalent hard hat shall be worn at all times except while in vehicles, living quarters, offices, and control rooms (after construction in control room is complete). Where high wind conditions are present, non- strangling chinstraps shall be worn. Hard hats shall not be worn backwards unless approved by the manufacture.

15.6 Eye Protection

15.6.1 Safety glasses with side shields shall be worn at all times except while in vehicles, living quarters, offices, and control rooms (after construction in control room is complete). During night or low light operations, only clear or amber colored glasses shall be worn. All eye protection must comply with ANSI Z87+ standard. When safety glasses do not provide adequate protection, safety goggles or face shields shall be the means of protection (i.e.: splash hazards when working with chemicals and in fueling operations, high-pressure washers, chipping, buffing or grinding operations). Welding hoods shall be used during all arc-welding operations. Goggles or other suitable eye protection with appropriate filter lenses shall be used during all gas welding, gas cutting or brazing operations. All filter lenses and plates used in welding hoods and goggles shall meet the test for transmission of radiant energy prescribed in ANSI Z87.1

15.7 Foot Protection

15.7.1 Safety-toe footwear with at least 6” ankle height shall be worn at all times except while in vehicles, living quarters, and offices. EGPNA requires visitors to the project to wear safety toe footwear unless other arrangements are made with Safety & Environment. Employees climbing ladders or scaffolding shall have safety-toe footwear with heals. All safety toe footwear must comply with ANSI Z41.1 or CSA equivalent standard.

15.8 Hand Protection

15.8.1 Appropriate gloves shall be worn when the hands are exposed to hazards such as cuts, punctures or abrasions (cloth, leather, leather palmed, kevlar); when handling chemicals (fueling operations) or hazardous materials where absorption is a concern (rubber gloves); and when performing electrical work.

15.9 Hearing Protection

15.9.1 Hearing protection shall be worn in all high noise areas or wherever a high-noise warning sign is posted.

15.10 Protective Clothing

15.10.1 Protective clothing shall be worn when handling chemicals and during fueling or in other hazardous situations as specified by the MSDS. Clothing worn while operating or interacting with live electrical equipment shall comply with NFPA 70E or CSA Z462 standards.

15.11 Respiratory Protection

15.11.1 Respiratory protection shall be worn when working in areas where respiratory hazards exist and are not controllable by other means. Employers providing respirators must implement a respiratory protection program. Employees using respirators must meet the following requirements:

15.11.1.1 Any medical requirements for using the equipment

15.11.1.2 Training on the use, fit and maintenance of the equipment

15.11.1.3 Not have any facial hair that will interfere with the seal of the face piece

15.11.1.4 Not wear eye glasses that interfere with the seal of the face piece

15.12 Fall Prevention / Protections Activities that expose workers to potential fall of six feet or more, or falls that are likely to result in death or serious injury shall employ suitable fall hazard control measures. Whenever possible, tasks should be planned so that elevated work will not occur. When this is not possible, fall hazards should be minimized by installing fixed platforms with railing, guarding openings, controlling access, or working from equipment designed for the job.

15.13 Suitable fall hazard control measures shall be taken to protect against the potential exposure of falling into floor openings, permanent or temporary, in elevated walking and working surfaces where a potential fall is likely to result in serious harm. Wall openings or excavated areas from which a potential fall is likely shall be guarded with a barrier or other effective system.

15.14 Stairs having four or more risers shall be equipped with stair railings or handrails to protect against the potential exposure to falling objects; walking or working surfaces above a work area shall be fitted with toe-boards, screens, nets or a guardrail system.

15.15 When fall hazards cannot be eliminated or prevented, personal fall arrest systems shall be used. Personal fall arrest systems (PFAS) consist of an anchoring point capable of supporting at least 5,000 pounds, double latching snap hooks, and a full body harness must include for wind turbine access a shock absorbing lanyard and lifeline or suitable combinations of these. PFAS shall conform to OSHA and ANSI Z 359 or CSA equivalent standard. PFAS components shall be configured so workers are within the free fall design of the system, nor contact any lower level.

15.16 Contractors/subcontractors employees are responsible and shall be trained to:

15.16.1 Identify when fall protection is required.

15.16.2 Maintain 100% tie off

15.16.3 Identify and select anchor points

15.16.4 Use proper personal protective equipment.

15.16.5 Visually inspect equipment prior to each use and follow manufacturers’ recommendation for inspection requirements.

15.16.6 Understand emergency rescue plans so that they can be implemented quickly if required.

15.16.6.1 If project is a wind farm, all personnel working inside a turbine shall be climb trained. At least two members of each crew that climbs shall be towerand rescue trained within the last year including a current FA/CPR/AED certificationmedical fit for duty approval and climb test.

15.16.7 Report unusual conditions and/or defective equipment to your supervisor and stop operations if unsafe conditions cannot be remedied.

16. ENVIRONMENTAL CONSERVATION / WASTE MANAGEMENT

16.1 Enel Green Power North America is committed to conducting operations in a safe and environmentally sound manner. All employees and contractors are required, at a minimum, to comply with all Federal (including EPA), State and local (including this document) requirements while performing operations.

16.2 All employees are required to report all environmental releases, including oil spills, chemical spills, etc. as soon as possible to your supervisor.

16.3 Prior to beginning any work activity, an environmental assessment should be completed to determine if adequate barriers are in place to prevent an environmental incident or permit violation. The environmental assessment should evaluate whether:

16.3.1 Activities generate any new discharges to the air, water or land

16.3.2 Activities require any new permits

16.3.3 Activities affect any existing discharges

16.3.4 Existing discharges exceed the permit limit

16.3.5 Activities lessen the effectiveness of existing barriers to protect for an oil, gasoline, diesel or chemical spill

16.4 Knowing your Workplace: All personnel shall be familiar with the work procedure to identify when something is not right. They shall be familiar with substances that could be present in the workplace. Consulting the Material Safety Data Sheet of these substances will provide the necessary information for personal protection, emergency response, and clean-up procedures. They shall be familiar with the customer requirements for safe work and environmental reporting requirements.

16.5 Spill Plans: When the spill or release of a substance(s) occurs during the work process, the spill or release should be stopped and/or contained until the proper cleanup procedure can be conducted. If the spill or release poses a reasonable risk to the health and/or safety of the employees, a safety risk to the completion of the process or an undue risk to the environment, the work process should be stopped and the release shall be cleaned up or minimized until the risk is reduced to an acceptable level. A competent person, familiar with the process, the released substance and the affects posed to personnel and the process, shall be responsible for determining the risk associated with a spill or release.

16.6 SPCC, Waste Management Plans and other project site requirements must be followed by the contractor.

16.7 Spill preventive measures shall be followed while handling or transferring substances that poses a health, safety and/or environmental hazard.

16.8 The following spill preventive procedures shall be used while transferring hazardous substances (e.g., refueling and/or servicing equipment on site):

16.8.1 Position spill pan with absorbents below entry port

16.8.2 Ground equipment when transferring flammable substances

16.8.3 Transfer fluid at a controllable rate

16.8.4 Man the control device (switch, valve, pump, etc.) until transfer is complete

16.8.5 Do not smoke while transferring flammable substances

16.8.6 Do not use cellular phone while transferring flammable substances

16.8.7 Do not allow distractions until the transfer is complete

16.9 A Spill Prevention Control and Countermeasure Plan is required for any facility which stores oil or petroleum products in a single above ground tank greater than 55 gallons or combination of tanks greater than 1320 gallons.

16.10 Secondary containment dikes must hold the contents of the largest single tank plus room for precipitation. When secondary containment is not practicable, a spill contingency plan is required.

16.11 If drain valves are present on dikes, they must be closed and plugged when not in use. Water accumulated within the dike must be inspected for contamination before draining. All draining operations must be witnessed and documented in the SPCC Plan.

16.12 Documented periodic inspections of tanks must be conducted and maintained with the SPCC Plan.

16.13 Facility personnel should be trained in the operation and maintenance of spill prevention equipment and regulations. Training shall be held at intervals frequent enough to assure understanding of the facility SPCC Plan.

16.14 Cleanup of spills may require personnel to be trained according to OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations.

16.15 A cleanup contractor shall be identified that is capable of responding to any chemical spill on site if the EGP NA site does not already have one selected.

16.16 Waste Management

16.16.1 Contractors are required to contain and to dispose of all waste generated by your operations unless other arrangements have been previously made with EGP NA. Contractors are responsible for taking the necessary steps, including employee training and job site monitoring, to prevent pollution and minimize the generation of waste.

16.16.2 Contractors that generate waste are required to :

16.16.2.1 Properly identify waste streams.

16.16.2.2 Segregate individual waste streams.

16.16.2.3 Provide proper labeling, markings, manifesting, storage and shipping of each waste stream.

16.16.2.4 Provide copies of all waste manifesting and disposal documents to EGP NA.

16.17 Crop Dusting

16.17.1 Contractor is required to have a program/procedure that addresses crop dusting if applicable to the project area.

17. INSPECTING AGENCIES

17.1 Various regulatory agencies are authorized to conduct inspections of regulated facilities during the course of the work. Inspectors are required to provide proper identification and explain the purpose of the inspection. If you are notified of an inspection:

17.1.1 Ask for proper identification.

17.1.2 Ask the nature of the inspection.

17.1.3 Politely inform the inspector that it is Enel Green Power North America’s policy to refer all agency inspectors to Enel Green Power North America management.

17.1.4 Immediately contact the EGP NA Host.

17.1.5 Only an Enel Green Power North America management or a Safety & Environmental representative is authorized to represent the Company.

18. HAZARD COMMUNICATION / WHIMIS

18.1 The purpose of this section is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to EGP NA and all exposed employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training.

18.2 Contractors and subcontractors shall maintain a written HAZCOM Program and insure implementation through:

18.2.1 Container labeling and providing information regarding hazards associated with unlabeled containers.

18.2.2 Maintain Material Safety Data Sheets (MSDS).

18.2.3 Maintain workplace chemical inventory lists.

18.2.4 Provide Enel Green Power North America a list of hazardous chemicals used or stored on site.

18.2.5 Provide employees with information and training including measures employees should take to protect themselves from these hazards including proper work practices, PPE and emergency procedures.

18.2.6 A chemical master list of all chemicals and MSDS sheets must be provided to Enel Green Power North America.

19. MANAGEMENT OF CHANGE

19.1 Enel Green Power North America requires that a Management of Change (MOC) process be used for all operations in which major changes are planned, both permanent and temporary, that can have a significant impact on operation. The purpose of the MOC process is to ensure hazards and risks associated with these changes are identified and managed. The MOC process provides for appropriate review, approval, implementation, and tracking. An Enel Green Power North America employee should review changes to contractor / subcontractor equipment, procedures, etc. to insure proper use of the MOC process and determine if any adverse effects to HSE could result from the change. Consult an Enel Green Power North America representative for those changes that will require use of the MOC process. Examples of “changes” may include:

19.1.1 Physical changes to equipment

19.1.2 Equipment and / or structural additions to a physical asset

19.1.3 Changes in software

19.1.4 Change in weather conditions

19.1.5 Changes in personnel (staff and/or management)

19.1.6 Changes in project scope

19.1.7 Procedural changes

20. WORK PERMITS

20.1 The Work Permit will generally be issued on a daily basis and re-issued at a shift/tour change or significant change in hazard classification of job assignment. The Work Permit document shall contain the following at a minimum:

20.1.1 When the specified work will begin (date/time) and end and/or when a new permit will be required (date/time). A formal hand-over procedure must be in place for when Work Permits are issued for periods longer than one shift/tour and/or when Work Permit authorization changes.

20.1.2 Who the permit is issued to (including company and individual’s name).

20.1.3 Where the specific work will take place.

20.1.4 Full description of what work will be performed including proposed tasks and objectives and description of equipment to be used.

20.1.5 Special considerations for safeguarding short service employees.

20.1.6 Description of all major hazards that could be encountered during the job, as well as documentation of appropriate controls for each hazard identified.

20.1.7 PPE necessary for specific work that will take place.

20.1.8 Specific standards/procedures/guidelines that are applicable to work that will take place.

20.1.9 Jobs involving Permit-required Confined Space Entry (PRCS), Lockout/Tagout (LOTO), Excavation and Trenching; or Hot Work will generally require additional documentation. All these permits should be issued by HSE on a daily/as needed basis.

20.1.10 Contingency plan if work does not proceed as planned.

20.1.11 Actions to be taken in the event of an incident including appropriate emergency response and notification phone numbers for EGP NA and contractor.

20.1.12 Reference to all other activities that may be impacted by work that will be performed (including other Work Permits) to ensure alignment and coordination.

20.1.13 Signatures of all workers who have reviewed the Work Permit and agree to meet all the operational and HSE requirements.

20.1.14 Final documentation and formal hand-over procedure declaring the work has been completed and the job site left with no HSE issues or problems and ready to return to service.

20.2 The contractor shall provide for the suitable display of Work permits.

20.3 Contractor / subcontractor operations may include regulated activities that require written permits, such as simultaneous operations (work being performed by various contractors in close proximity to each other). Subcontractors shall notify an EGP NA Host prior to the implementation of these activities. These specific activities shall be preempted by a tailgate meet and JHARA review.

20.4 The following activities require a written permit; however, all activities on site should be assessed according to risks, and all contractors and subcontractors should be prepared to seek a written permit if warranted by the risks of the task:

20.4.1 Permit Required Confined Space operations

20.4.2 Energy Isolation (Lockout / Tagout) and clearance operations

20.4.3 Excavation, Trenching and Blasting

20.4.4 Hot Work

20.4.5 Live work

20.4.6 Crane work that requires a lift plan

21. AUDITS AND INSPECTIONS

21.1 All personnel are required to perform visual inspections of tools; equipment and vehicles prior to the start of each shift (daily) and acknowledge these inspections.

21.2 All personnel are required to remain attentive to the hazards in their workplace and to stop work when new hazards develop or known hazards need to be readdressed.

21.3 Monthly documented (auditable) inspections of tools, equipment and vehicles shall be performed per manufacturer recommendations.

21.4 Contractor shall perform documented workplace HSE audits and safety inspections weekly of ongoing operations. Audit and inspection reports shall note deficiencies and corrective action verification.

22. SITE SAFETY RULES

22.1 All visitors and contractor personnel shall conduct themselves in a professional manner and are expected to follow the general site safety rules listed for the project location.

23. OFFSITE PERSONNEL AND VISITORS

23.1 Offsite personnel and all visitors shall obtain permission to enter the Enel Green Power North America site before entering the project site. A site visitor log shall be maintained.

23.2 AllOffsite personnel and all visitors shall conform to the minimum PPE requirements in this document or PPE requirements consistent with their presence on site, site safety plan, JSA, whichever is more stringent.

23.3 All visitors shall be notified of the potential hazards and the site safety rules and shall be accompanied by EGP NA or contractor / subcontractor supervisory personnel at all times while onsite. Offsite personnel and all visitors shall be notified of the potential hazards and the site safety rules, through the site orientation.

23.4 Offsite personnel and all visitors shall be accompanied by EGP NA or contractor / subcontractor supervisory personnel at all times while onsite.

23.5 If offsite personnel carry out temporary activities and tasks on site (ex. delivery and installation of equipment, troubleshooting, planned / unplanned maintenance on machines and equipment, repairs, etc.), those activities shall be communicated in advance to the EGP NA Site Management, then scheduled and executed under EGP NA permission.

23.6 Contractor / Subcontractor supervisory personnel shall safeguard that the offsite personnel activities and tasks are carried out according to the site safety plan, JHA, permit to work, and shall notify the completion to the EGP NA Site Management.

24. DRONE POLICY

24.1 All uses of unmanned aerial system on Enel sites must be safe and in full compliance of federal, state & local regulations.

24.2 *** Use of personal drones by EGP employees, contractors and affiliates is prohibited ***

24.3 *** All commercial uses of unmanned aerial systems must be approved by site supervisor ***

24.4 Pilots in Control of Unmanned Aerial Systems must:

24.4.1 Hold a current FAA Remote Pilot Certification

24.4.2 Carry proper insurance that explicitly covers aviation (Note: most general liability policies exclude the use of aircraft, including drones)

24.4.3 Use only FAA registered aircraft (Note: additional registration may also be required at the states and local level)

24.4.4 Obtain airspace authorization from the FAA if required

24.4.5 Follow a safety plan and wear appropriate PPE

24.5 Unmanned aircraft systems must be used in a manner that is compliant with FAA Part 107 regulations. Including but not limited to:

24.5.1 Stay within visual line of site of Pilot in Command

24.5.2 Stay below 400’ above ground or structure level

24.5.3 Not fly over people or moving vehicles

24.5.4 Yield the right of way to manned aircraft

25. GENERAL OPERATIONS

The following guidelines and procedures are required as a minimum and are not intended to be all- inclusive. If a contractor company has more stringent rules, if regulatory requirements previously not identified mandate a more stringent approach, or if risk analysis indicates a more stringent approach or different approach is necessary to mitigate the hazards, then the more stringent requirements shall apply.

25.1 Lifting of Loads by Personnel

25.1.1 Back injuries may result from improper lifting techniques. Lifting a load that is too heavy, or lifting in the wrong position, can cause an injury.

25.1.2 All lifting should be eliminated when possible. Use mechanical devices to eliminate the need to lift and reduce/eliminate the need to carry items any distance.

25.2 Lockout/Tagout (Energy Isolation)

25.2.1 Lockout/Tagout is a procedure required to isolate personnel from all potential energy sources when performing maintenance or service on equipment, especially when that maintenance or service requires the disabling or removal of normal guards and safety devices.

25.2.2 Potential energy sources include electrical, mechanical, pneumatic, hydraulic, thermal, and chemical and all forms of potential stored energy.

25.2.3 Contractors / sub-contractors shall have a written Lockout/Tagout program in effect. A logbook of Lockout/Tagout shall be maintained at the project site.

25.2.4 Lockout/tagout programs shall be reviewed with EGP NA Host to determine if the EGP NA or contractors’ program will be used.

25.3 Confined/Enclosed Space Entry

25.3.1 Confined space entry is defined as entry of personnel into a confined space such as a hub, vessel, foundation, earth pit, etc. A confined space is defined as a space that:

25.3.1.1 Has openings large enough and configured so that a person can physically enter the space and perform work;

25.3.1.2 Has limited or restricted means of entry or exit; and

25.3.1.3 Is not designed for continuous human occupancy.

25.4 All Confined and Permit Required Confined Spaces are labeled. Consult with the EGP NA host to determine the status of any spaces.

25.5 Permit required Confined Space Entry:

25.5.1 Entry in a confined space can expose personnel to one or more of the following hazards, in which case a Work Permit (per OSHA 29 CFR 1910.146) shall be required for personnel to enter the space:

25.5.1.1 Hazardous atmosphere such as toxic or flammable vapors.

25.5.1.2 Oxygen-deficient atmosphere.

25.5.1.3 Material, such as mud or sludge that has the potential for engulfing an entrant.

25.5.1.4 An internal configuration such that the entrant could be trapped or asphyxiated.

25.5.1.5 Inwardly converging walls or floors, which slope downward and tapers to a small cross section.

25.5.1.6 Other recognized serious health or safety hazards.

25.5.2 Under no circumstances shall an employee be allowed to enter a permit required confined space without a properly completed Work Permit approved by the contractor. The Work permit shall have a Sign-in/out sheet for entrants, and the hazards shall be discussed with the entrant prior to that person entering the space.

25.5.3 All confined spaces shall be identified.

25.5.4 Minimum requirements for entering confined spaces:

25.5.4.1 The air in a confined space shall be tested prior to a person entering the space using a 4 Gas Meter (Multi-Gas Detector) for oxygen (O2) content, Lower Explosive Limits (LEL), and hydrogen sulfide (H2S) in that order with an approved and calibrated device by a person trained and certified to use the device. During the construction of Wind Turbines, 3 Gas Meter will be sufficient on a wind project to monitor the following: Oxygen (O2) content, Lower Explosive Limits (LEL), and Carbon monoxide (CO). DANGER levels are as follows:

25.5.4.2 Oxygen (O2) content below 19.5% or above 23.5%

25.5.4.3 Lower Explosive Limit (LEL) 10% of LEL

25.5.4.4 Hydrogen sulfide (H2S) less than 10 parts per million (ppm)

25.5.4.5 Carbon monoxide (CO) 35 parts per million (ppm) Time Weighted Average (TWA)

25.5.5 If the air in a confined space is contaminated, the space shall be purged until an acceptable working atmosphere is achieved prior to a person entering the space.

25.5.6 When a person is in a confined space, ventilation into the space shall be provided at a rate of three (3) air volume changes per hour when ventilation is needed. Mechanical ventilation via blowers, etc. shall be required if natural ventilation is not sufficient.

25.5.7 One or more trained persons must act as an attendant whenever work is performed within a confined space. There shall be an effective means of communication established and maintained between personnel in the confined space and the attendants(s). Communication shall be verbal, voice or a signal line.

25.5.8 Any rotating, agitating or other equipment that can present a hazard to the entrant within a confined space shall be locked out/Tagged out prior to entry into the space.

25.5.9 A rescue plan to remove all entrants from the confined space must be established prior to entry into the space. This includes pre coordination of rescue services.

25.5.10 A permit confined space can be deregulated as allowed by the contractor or EGP NA plan.

25.6 Hot Work

25.6.1 Each contractor working on site must have a hot work program. In addition to the program the requirements below must be followed.

25.6.2 Hot work is defined as welding, flame cutting, burning, grinding or using a torch. When possible, hot work should be performed in a shop, outside the facility, or in a “Designated Welding Area”. A designated welding area shall be established on all locations where substantial welding or flame cutting is anticipated.

25.6.3 All welding and flame cutting operations shall be done in the established “Safe Welding Area” (SWA) unless otherwise authorized. Designated welding areas shall be located fifty (50) feet from heavily vegetated areas, thirty-five (35) feet from combustibles (stored oil, diesel, etc.), and on a non-combustible surface.

25.6.4 If hot work needs to be performed, especially inside a nacelle, all movable fire hazards in the vicinity shall be removed to a safe distance or guards used to confine the heat, sparks and slag and to protect the immovable fire hazards. A Work Permit shall be

issued for all hot work done outside of the designated welding area and approved by the contractor and EGP NA. Hazards and recommended special precautions should be documented in the Work permit.

25.6.5 The hot work equipment and work area shall be inspected prior to beginning any hot work operations to ensure safe working conditions. This includes checking for explosive atmospheric conditions in all vessels piping and confined spaces and documenting the results on the Work permit. Oxygen and acetylene cylinders shall be stored valve end up and properly secured. Only certified personal/welders shall be permitted to perform hot work.

25.6.6 Fire Protection during Hot Work Operations The following precautions shall be taken during Hot Work operations for fire protection:

25.6.6.1 Firewatchers with suitable fire extinguishing equipment shall be required whenever hot work operations are performed outside of the designated welding area. The fire watch shall be maintained for a minimum of a half-hour after completion of hot work operations so the danger of fire has passed.

25.6.6.2 Oxygen and acetylene cylinders shall be kept at a safe distance from the actual hot work operation so the sparks, hot slugs or flames do not reach the cylinder. If such safe distance cannot be maintained, fire resistant shields shall be used.

25.6.6.3 A jet of oxygen shall not be used to blow dirt out of bolt holes, sockets, nuts, etc. If objects such as these need to be cleaned, compressed air shall be used.

25.6.6.4 Wherever there are floor openings or cracks that cannot be closed, precautions shall be taken so the no readily combustible materials below will be exposed to sparks.

25.6.6.5 During hot work operations outside the designated welding area, combustible floors shall be kept wet, covered with damp sand, or protected by fire resistant shields.

25.6.7 Hot Work operations shall not be permitted in the following situations:

25.6.7.1 In areas not authorized by EGP NA.

25.6.7.2 In the presence of explosive atmosphere or where such atmospheres may develop.

25.6.7.3 Where ignition can be caused by heat conduction, such as on metal walls or pipes in contact with combustibles on the other side.

25.6.7.4 When wind conditions are such that sparks could be carried to combustible materials.

25.6.8 Prior to welding or cutting, all hollow spaces or containers shall be vented to permit the escape of air or gases. Purging with inert gas is recommended.

25.6.9 No cutting will be allowed on used drums or tanks.

25.6.10 Adequate ventilation shall be provided when hot work is done

25.7 Electrical Safety

The project site shall address and minimize personnel exposure to electrical hazards through effective equipment operation, design, specification, installation, and maintenance. All electrical contractors working onsite shall have an electrical safety program that meets or exceeds the requirements below.

25.7.1 Electrical Safe Work Practices: All electrical work shall be done in accordance with the latest codes, standards, and regulations including, but not limited to: National Electric Code (NEC), NFPA 70E, OSHA subpart S, National Electrical Safety Code (NESC) and

any federal, state, or local standards. PPE must comply with OSHA 29 CFR 1910.137 and NFPA 70E.

25.7.2 All live electrical work requires a live work permit. A qualified person shall discharge all stored electricity and shall verify the equipment is de-energized and proper Lockout/Tagout procedures implemented prior to beginning electrical work.

25.7.3 Power Lines: All power lines shall be considered energized unless proper measures have been taken to de-energize including instillation of grounds.

25.7.4 When work is performed near energized overhead power lines, equipment such as boom, mast, crane, or its load shall never be permitted within twenty (20) feet of power lines. Crane or other tower components shall clear all energized power lines by 25 feet during rig up, rig down, or while operating.

25.7.5 All overhead lines that cross project roadways shall be highlighted and identified when equipment is being used in the area.

25.7.6 All portable generators shall be grounded and have Ground Fault Circuit Interrupter.

25.7.7 Arc Flash Study shall be done during engineering phase of project and not post energization.

25.8 Operating Equipment

25.8.1 Operating equipment typically refers to rotating or reciprocating equipment such as generators, gate systems, yaw drivers, pitch systems, gearboxes, pumps, pumping units, etc.

25.8.2 The following are requirements to minimize the possibility of an incident during the repair, service, startup, etc. of the operating equipment:

25.8.2.1 Only trained operators shall start and stop operating equipment.

25.8.2.2 Jewelry such as rings, watches, wrist chains, key chains or loose clothing shall not be worn when working around operating equipment. Long hair shall be confined.

25.8.2.3 Repairs, service or alterations shall not be made on equipment in operation. All equipment shall be shut down and a Lockout/Tagout device used in such a manner that the equipment cannot be accidentally started while being worked on.

25.8.2.4 Guards and other safety devices shall be reinstalled before lockout is removed.

25.9 Crane and Rigging Safety

25.9.1 Any company operating a crane or rigging onsite shall have a program to address the hazards that includes the items below.

25.9.2 Only trained, qualified and certified personnel shall operate cranes and other such lifting equipment.

25.9.3 All project site work utilizing cranes shall be done in accordance with OSHA 29 CFR 1910 and 1926.

25.9.4 Only approved and certified personnel shall be allowed to operate cranes. The contractor shall provide to EGP NA written certification for each employee who might operate a crane.

25.9.5 All cranes shall be strictly maintained in accordance with the manufacturer’s recommendations.

25.9.6 The following are requirements to minimize the possibility of an incident during crane and rigging operations:

25.9.6.1 A lift plan is required for all heavy lifts, a critical lift is at 75% of the cranes capacity. All heavy/critical lifts should be identified prior to the start of work and be included in contractors’ method statements.

25.9.6.2 All personnel shall be clear of a load before it is picked up and shall remain clear at all times. Personnel should face the crane in full view of the crane operator and/or signalman. Personnel, including those holding tag line(s), shall never be under suspended loads or go between the load and other objects where they may be trapped or crushed.

25.9.6.3 The crane operator shall never leave the control while a load is suspended. This excludes the possibility of leaving a tower-top section erected without a nacelle. Cranes shall not be left connected to towers sections, whether erected or not, without an operator at the crane controls.

25.9.7 Non-conducting tag lines shall be used to control all suspended loads. Chains or steel cables are not acceptable. Tag lines shall be attached before a load is lifted.

25.9.8 A single designated signalman shall be used if the crane operator does not have full view of lifting operations. Where practical, the use of radios or other communication equipment is also recommended. The crane operator shall respond only to signals from the signalman, but shall obey a stop signal from anyone at any time.

25.9.9 The crane operator shall inspect lift lines, rigging, slings and crane fittings/fasteners daily when in use or prior to each lift and replace if necessary. This equipment shall be properly rated for the intended load and certification tags attached to all slings. For

U.S. based work, all wire rope clamps shall comply with OSHA 29 CFR 1920.251. Wire rope shall not be secured with knots.

25.9.10 The operator shall inspect all cranes prior to use. For U.S. based work, cranes should be loaded marked per OSHA 29 CFR 1910.179. In addition, cranes shall have the most recent inspection records posted in the cab.

25.9.11 A crane shall not be used to pull a load sideways.

25.9.12 A crane boom shall not be used as a ladder for walking, except for necessary maintenance of the boom and its components.

25.9.13 When not in use, the crane boom shall be kept in the cradle.

25.9.14 For rigging, chains shall never be used.

25.9.15 Determine the load weight before rigging it and do not exceed the safe working load of any equipment.

25.9.16 Before being unhooked, all loads shall be safely landed and properly blocked.

25.9.17 Wire rope slings shall never be shortened by tying knots in them or by wrapping them around the crane hook. Protruding ends of strands in splices on slings shall be covered or blunted. Chains shall not be used for anything but lashing.

25.9.18 Slings shall be protected from sharp edges by blocking or protective pads.

25.9.19 When multi-leg slings are used, each leg of the sling should be loaded evenly.

25.9.20 Kinked wire rope slings shall be removed from service. Wire rope shall be kept lubricated and free of corrosion.

25.9.21 Procedures for Using Tag Lines

25.9.21.1 If tag lines are impractical during final positioning of the load, caution should be taken to ensure that no part of the person’s body guiding the load is between the load and other objects where they may be wrapped or crushed.

25.9.21.2 No attempt to guide a load shall be made with the tag line wrapped around a hand or waist.

25.9.21.3 The tag line must be free of knots and never run over a tag line with vehicle or equipment.

25.9.21.4 A tag line shall be of sufficient length a minimum of 10 feet so that no part of the person guiding the load shall be under the load at any time.

25.9.21.5 Hard tag lines should always be used when lifting nacelles and rotors, and whenever else conditions call for additional control (determined by JSA’s for the specific task).

25.9.22 Use of a Crane to Hoist Personnel

25.9.22.1 Cranes used to lift personnel should be equipped with an “anti-two- blocking” device (OSHA 29 CFR 1926.550).

25.9.22.2 The personnel lift procedures shall be reviewed and approved by the EGPNA supervisor prior to any lifts.

25.10 Excavation and Trenching

25.10.1 An excavation is any man-made pit, trench, hole or cut into the ground formed by the removal of earth.

25.10.2 Prior to the start of work proper notification of the local dig safe program is required.

25.10.3 Potential hazards include, but are not limited to cave-ins, hazardous atmospheric conditions, and rupture or contact with live gas flow-line or utility installation.

25.10.4 The following are requirements to minimize the possibility of an incident during excavation and trenching operations:

25.10.5 A dig permit must be completed for all excavations

25.10.6 All excavation and trenching operations shall be performed under the supervision of a “competent” person and all requirements met. (For U.S. based work, as specified by OSHA 1926.652)

25.10.7 Personnel entering a trench or excavation exceeding four (4) feet in depth must follow confined space entry procedures and require a Work Permit approved by the contractor. A safe means for personnel to enter and exit shall be provided every 25 feet with in the working area.

25.10.8 Locations of cables, communication wires and other underground hazards such as pipelines shall be established and marked prior to beginning excavation or trenching operations.

25.10.9 Adequate protection from cave-ins shall be provided through appropriate sloping, shoring or shielding as determined by the “competent” person supervising the operation.

25.10.10 All unattended excavations and trenches shall have barricades and warning signs that are visible after dark. Barricades shall be located at least 6’ from the edge of the excavation.

25.11 Scaffolding Safety

25.11.1 Scaffolding shall be used when appropriate. Any contractor using or constructing scaffolding must have a safety program for scaffolding work that includes the items below and provide a competent person.

25.11.2 Climbing or working from the handrail, mid-rail, or brace members of the scaffolding is prohibited.

25.11.3 All scaffolding shall be erected according to OSHA scaffold requirements specified in 29 CFR 1910.28 and 1926.451.

25.12 Sandblasting

25.12.1 The potential hazards during sandblasting operations include, but are not limited to inhalation of dusts (including lead from the paint or silica from the blasting medium); high noise levels; high operating pressure of equipment; etc.

25.12.2 The following are requirements to minimize the possibility of an incident during sandblasting operations must be including in the contractors program:

25.12.3 Approved respiratory and hearing protection shall be worn.

25.12.4 Appropriate eye protection shall be worn.

25.12.5 The use of silica sand in the blasting medium is discouraged.

25.12.6 Paint coatings being removed by sandblasting operations shall be considered as lead containing until proven otherwise.

25.12.6.1 Contractors performing sandblasting operations for EGPNA shall have a medical surveillance program in place to monitor employee’s blood level exposure to lead.

25.12.7 Check all hoses every day for leaks and signs of wear.

25.12.8 Ventilation (either mechanical or natural) shall be adequate to keep the work atmosphere less than 10% Lower Explosive Limit (LEL) and oxygen (O2) content greater than 19.5%.

25.12.9 Disconnect and lock out all electrical power before sandblasting.

25.12.10 Blasting nozzles shall be equipped with a cut-off device (dead man’s switch).

25.12.11 Secure and hobble all high-pressure air hose connections.

25.12.12 All air hose connectors shall be pinned or wired to keep them from coming apart.

25.12.13 Warning signs shall be posted identifying potential hazards.

25.13 Painting

25.13.1 The potential hazards during painting operations include but are not limited to inhalation of toxic vapors or spray mist, fire hazard due to solvents in the paint, etc.

25.13.2 The following are requirements to minimize the possibility of an incident during painting operations and must be included in the contractors program:

25.13.3 Contractors performing painting operations for ENA shall have a medical surveillance program in place to monitor employee’s blood level exposure to lead.

25.13.4 Approved respiratory protection shall be worn.

25.13.5 Approved eye protection shall be worn.

25.13.6 Be aware of and eliminate ignition sources in the work area.

25.13.7 Ventilation (either mechanical or natural) shall be adequate to keep the work atmosphere less than 10% Lower Explosive Limit (LEL) and the oxygen (O2) content greater than 19.5%.

25.13.8 Bleed or de-pressure all lines before disconnecting.

25.13.9 Warning signs shall be posted identifying potential hazards.

25.14 Compressed Air Used for Cleaning

25.14.1 Compressed air used for drying or cleaning shall be limited to 30 psi (gauge) by a pressure regulator or pressure-reducing nozzle as specified in OSHA 29 CFR 1910.242.

25.14.2 Directing compressed air toward a person for any reason is prohibited.

25.14.3 When using compressed air for cleaning in a dry and dusty situation, protective eye goggles, gloves, and a dust filter for respiratory protection shall be worn at a minimum.

25.15 Powered industrial Trucks (including UTVs)

25.15.1 Only trained and qualified personnel shall operate forklifts.

25.15.2 Training shall be conducted as specified in OSHA 29 CFR 1910.178.

25.15.3 The contractor shall provide written certification to EGPNA for each employee who might operate a forklift.

25.15.4 All forklifts shall be strictly maintained in accordance with the manufacturer’s recommendations.

25.15.5 Personnel shall not ride on forklifts.

25.15.6 The forklift shall have warning lights, appropriate lights if used at night, and an alarm signaling when the vehicle is backing up.

25.15.7 When a forklift is left unattended, the forks shall be fully lowered, controls put in “off” or “neutral” position, the power shut-off, and the brakes set. Wheels shall be chocked if the forklift is parked on an incline. Ignition keys shall be removed and stored in a secure place.

25.15.8 The forklift operator shall ensure that the forklift’s wheels are properly chocked before unloading.

25.15.9 Seat belts shall be worn when operating equipment.

25.15.10 All equipment must have a rollover protection system.

25.15.11 Equipment traveling/operating on public roadways shall have an escort.

25.16 Use of Hand and Power Tools

25.16.1 Tools shall be maintained in good condition and defective tools repaired by qualified personnel or replaced.

25.16.2 Where potentially explosive atmospheres exist, explosion-proof and non-sparking tools and cords shall be used.

25.16.3 Hand tools shall always be used for their intended purpose. For example, wrenches shall not be used as a hammer; screwdrivers shall not be used as a chisel or pry bar; pipe wrenches shall not be used on hex nuts; grinder wheels shall be properly rated for the speed of the grinder; etc. Guards shall be in place and not modified. Power tools and extension cords shall have proper grounding.

25.17 Cowboy Gates

25.17.1 If cowboy gates are used a latching device must be installed to tension the gate to prevent workers from having to pull on the gate to tension and close.

25.17.2 The length of the gate shall be limited to prevent excessive tension when trying to close the gate.

25.17.3 All gates shall be marked for easy visibility in both light and dark conditions. If night work is planned reflective tape shall be used to identify gates as well.

26. ACKNOWLEDGEMENTS

26.1 This contractor’s site safety plan or safety program shall be used in contractor/ subcontractor orientation and shall be acknowledged by all personnel by a signoff indicating orientation.

26.2 Prior to the start of work the contractor shall review safety with EGP NA host to insure alignment of safety plans.

26.3 The project or safety and environment group shall maintain acknowledgments through the duration of the project.

27. CONTRACTOR SELECTION PROCEDURES

All contractors selected to work on the Project Site have been selected using criteria that evaluate competency, including HSE performance, company safety plans, and experience. We fully expect our subcontractors to utilize similar evaluative parameters when selecting subcontractors of a lower tier. After work completion EGPNA will conduct post-job safety performance.

28. HAZARD INVENTORY / RISK ASSESSMENTS

This list is to include the health, safety and environmental hazards identified on the project site, including plans of mitigation. This list is to be used by all contractors and subcontractors when they are developing their method statements detailing how they will perform their tasks relative to this list.

29. GENERAL SITE LIST

Hazards: This list is for use as a prompt and is not an exhaustive list by any means - each site will have its own set of unique hazards that need to be identified. Each item listed could provide a whole host of hazards in different situations.

29.1 Site History

29.1.1 Contamination (from producing operations on leased land, both active and abandoned)

29.1.2 Produced oil and gas (H2S, sour crude, etc.)

29.1.3 Land slip, crevices

29.1.4 Quarry work

29.1.5 Low flying aircraft (i.e., there is an abandoned air field on leased land)

29.1.6 Seismic Activity

29.2 Land present use

29.2.1 Producing Oil & Gas Units (sour crude and H2S)

29.2.2 Spraying (e.g., farming operations, crop dusting)

29.2.3 Set Aside – Economic rural designations/ status.

29.2.4 Ownership/ Land Title.

29.2.5 Footpaths, Right of Ways.

29.2.6 Low flying aircraft (i.e., there is an air field)

29.2.7 Hunting

29.3 Overhead Power-lines

29.3.1 Working adjacent to / underneath overhead cable lines

29.3.2 Mobile plant movement taking place in the vicinity of the overhead cable lines

29.3.3 Location of turbine to overhead line including toppling over, blade breaking, location of crane hard-standing

29.4 Services (Underground Pipelines / Aboveground Flow-lines)

29.4.1 Gas or Oil Pipe lines

29.4.2 Electric Cables Overhead / Underground

29.4.3 Plastic piping (sour crude or sour gas/active or inactive)

29.4.4 Springs, private water supplies

29.4.5 Fiber optic cables

29.4.6 Sewers – Foul

29.4.7 Sewers – Storm Water

29.4.8 Land drains, field irrigation systems.

29.4.9 Water Mains/ Services.

29.4.10 Service ducts/pipes – live / abandoned.

29.4.11 Penstocks.

29.5 On site Access/ Work area related hazards

29.5.1 Bridges /culverts

29.5.2 Existing structures buildings / barns etc.

29.5.3 Gradients

29.5.4 Topography (Loose rock, stones, tower locations close to mountain edges, precipices)

29.5.5 Ditches, watercourses (ponds, peak volume)

29.5.6 Wetlands, soft spots.

29.5.7 Weather patterns (i.e. Rainfall, high winds, altitude)

29.5.8 Livestock

29.5.9 Indigenous species (poisonous snakes, spiders, insects, turkeys, deer, bats, eagles, etc.)

29.5.10 Cacti, bushes with thorns

29.5.11 Existing met masts, guy wires

29.5.12 Fencing and gates (electric, barbed wire, etc.)

29.5.13 Plastic piping on the ground (live and abandoned oil & gas service)

29.5.14 Overhead power lines

29.6 Traffic management

29.6.1 Site Entrance (include visibility, local bye laws, class of road)

29.6.2 Vehicle passing areas (cut offs on roadside to allow passage of two way traffic without having to turn around)

29.6.3 Truck and/or trailer storage area(s)

29.6.4 Turning Heads (to avoid reversing)

29.6.5 Bushes, trees, meandering roads, hills, etc. (posing a vision problem in regards to s time to wild life, livestock roaming loose in area)

29.6.6 Pedestrians

29.7 Preservation orders, Archaeology

29.8 Flooding

29.9 Security and Vandalism

29.10 Surrounding Land use – see above.

29.11 Lightning

29.12 Site Access

30. FORMS / SITE HSE RECORDS

The forms and records below shall be maintained onsite by the contractor as required.

30.1 HSE plans and supporting documents/forms

30.2 Master Safety Registers (Orientations & Training)

30.3 Visitor sign in sheets

30.4 Hazard Analysis Worksheets

30.5 Task planning cards

30.6 Active and canceled permits (hot work, confined space, dig, etc.)

30.7 JSAs of tasks and activities carried out

30.8 Incident logs

30.9 Incident Reports

30.10 Emergency Contact lists

Attachment 1 - ENEL STOP WORK POLICY

Attachment 2 – ENEL GREEP POWER QUALITY SAFETY AND ENVIRONMENT POLICY

Attachment 3 - ENEL GREEN POWER NORTH AMERICA SITE RULES

Compliance with the following rules is a condition of continued access to this project site. Failure to follow these safety rules may result in your being removed from the site.

1. The minimum PPE requirements for individuals on the project site are: hard hat, safety toe footwear, and safety glasses with side shields.

2. Dress Code: Long pants and shirt shall be work at all times. NO cut-offs or tank top shirts will be allowed on site.

3. Report all near-miss, hazardous conditions and accident / incidents immediately.

4. All climbing and lifting equipment must be checked daily before use.

5. Report, replace, and / or repair defective equipment before use.

6. Maximum project speed limit is 25 miles per hour unless otherwise posted.

7. Unloaded trucks / equipment shall yield to loaded.

8. Seat belts must be worn in vehicles and equipment while moving.

9. No riding on / in equipment / vehicles unless there is a seat and seatbelt for you.

10. NO SMOKING on site unless in designated areas.

11. No Drugs, Alcohol, or Weapons allowed on site.

12. Obey all warning signs. Stay alert to potential hazards.

13. Pre task plans are required before starting work

14. Only certified or qualified personnel shall operate tools / equipment.

15. All underground cables and lines must be identified and turned off prior to excavations within three

(3) feet of that line.

16. Suitable barriers and signage must be erected / posted around all open excavations and trenches.

17. Traffic control measures must be used when working on or adjacent to the site roads especially when using cranes and excavators, digging trenches or blocking part of the road for any reason.

18. Attend all required safety meetings, trainings, tailgate meetings.

19. NO climbing turbines, masts, ladders, or scaffolds unless authorized and wearing proper PPE.

20. Never put any part of your body under a lifted load.

21. Check load ratings and rigging gear daily.

22. Be aware of poisonous snakes, spiders and plant life.

23. Report all environmental releases to your supervisor ASAP.

24. Mind your trash, take it home with you.

25. Communicate and cooperate with other workers / companies.

26. Be aware that we are not the only ones working in the area. Work without interfering with other operations or ranching operations.

27. Maintain training certificates for inspection at all times.

28. NO horseplay, running, or jumping at anytime.

29. Report suspicious behavior to your supervisor.

30. Refer all media and landowner interaction to the project office

31. Everone has the responsiblity to stop work or intervien if you see something unsafe.

Remain safety conscious, courteous to other workers, and professional in your behavior at all times.

OPERATIONAL PROCEDURE

ENA HSE OP GEN 010

Rev 0406 date 04/20/201711/28/2018

NORTH AMERICA AREA

RENEWABLE ENERGIES

Subject: EGP NA Contractor HSE Program

RENEWABLE ENERGIES

1 /4038

This document is the property of Enel Green Power North America, Inc. This document contains unpublished, non-binding, confidential and proprietary information of Enel Green Power North America, Inc. and its affiliates. No disclosure, duplication or use of any portions of the contents of these materials, for any purpose, may be made without the prior express written consent of Enel Green Power North America, Inc. or its affiliates.

Printed copies of this document are uncontrolled and may not be the current version.