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.

Health, Safety, Environmental and Security Requirements

for

Contractors and Subcontractors

1. Definitions: For purpose of interpretation and/or clarification, the following words shall have the meanings set forth.

a. Contractor shall mean the contractor hired by Owner to perform the construction, operations, security and control of the Site and assume overall management for the site health, safety, environmental programs and daily operations of all Contractor personnel and subcontractors working on-site;

b. Contract(s) shall mean the applicable agreement(s) entered into by and between the Owner and Contractor or the agreement(s) between Owner and Contractor(s);

c. Contractor(s) shall mean the contractor(s), the BOP Contractor, hired by Owner to perform work in connection with the Project;

d. Subcontractor(s) shall mean all subcontractors at every tier hired by Contractor and Contractor(s) to perform Work;

e. Owner shall mean the project as applicable, pursuant to the Contract(s).

f. Site shall mean the property or area upon which Contractor and Subcontractors shall perform the Work; and

g. Work or Services shall interchangeably mean the work performed by Contractor and Subcontractors pursuant to the Contract;

2. Health, Safety and Environment

Contractor with the cooperation of the Contractors shall implement and manage the Site Health, Safety and Environment (HSE) Program and establish the Site HSE Programs per Contract requirements. The HSE plans shall meet or exceed the requirements set forth in the Owner’s Site Safety Plan Exhibit L-2 during all phases of the Projects. The Contractor and Contractors shall also implement systems to comply with and maintain the requirements in the EPC Compliance Matrix, Exhibit H-2.

BOP Contractor is required to provide one (1) full-time HSE representative at all times that will act as the leader of the department.

BOP Contractor or Subcontractor (RES/Subcontractor) will provide a second HSE representative which scope may be covered by a working crew leader (with minimum OSHA 30 certification) until Contractor and Subcontractors combined reach 50 workers.

BOP Contractor or any of RES’s Subcontractors will increase 1 HSE representative per every additional 50 workers incorporated directly into the works which must exclude personnel at the office unless they are working onsite over 50% of the time.

For the avoidance of doubt:

· One (1) Full-time HSE Representative at all times. (Department Leader);

· One additional (1) HSE Representative (RES/Subcontractor) which position responsibilities can be covered by a crew leader with minimum OSHA 30 certification; (from 0 to 50 employees);

· One additional HSE Rep. (RES/Subcontractor) (From 51 to 100 workers);

· One additional HSE Rep. (RES/Subcontractor) (From 101 to 150 workers);

· One additional HSE Rep. (RES/Subcontractor) (From 151 to 200 workers);

· One additional HSE Rep. (RES/Subcontractor) (From 201 to 250 workers);

· The same logic will be applicable in the increment/reduction of workers in the frequency established accordingly.

The Owner shall be responsible for retaining Emergency Medical Technician (EMT) services once the overall number of persons assigned to the Site reaches twenty (20) personnel. The Owner shall retain the EMT until such time that substantial completion is reached and the overall number of persons assigned to the Site shall fall below and remain less than twenty (20) personnel.

The Contractor shall, in all cases where the Contractor, Contractor(s) or Subcontractor(s) perform any Work during extended or weekend hours, have a HSE representative on-Site while any such Work is conducted. The Owner shall maintain the EMT on-Site whenever the Contractor and/or Subcontractor(s) are performing Work during extended or weekend hours. Such Contractor(s) and Subcontractors shall afford the Owner with at least twenty-four (24) hours advance notice whenever the EMT is required to be present on-Site during extended or weekend work hours.

A dedicated safety trailer shall be provided by the Contractor. It shall be of sufficient size to accommodate office space for all required individuals, and an area suitable for conducting the training identified above.

The Contractor and the Owner will collaboratively evaluate the credentials of the safety personnel prior to their arrival to the Project in order to ensure they meet the HSE representative criteria set below.

Lead HSE representative shall meet the following criteria:

· Job function is fully dedicated to HSE with at least 70% of their time being field inspections to ensure adherence to safety standards. In the event that documentation or any other internal company duties prevents any HSE representative from achieving this requirement then another HSE representative or administrative assistant will be provided.

· Degree in HSE or relevant field that is acceptable to the Owner.

· Previous construction HSE experience related to the specific type of construction being performed.

· Working knowledge of OSHA regulations as well as other applicable agencies related to safe work practices.

· Supply Owner the weekly hours, number of orientations and incidents for the week by Monday for the previous week.

Contractor shall implement a site inspection and audit program that includes the following:

· Daily start of shift safety message and plan of the day meeting including a stretch program will occur at the office compound prior to dispatching to site work locations. This will include all Contractor(s’) employees and Owner’s representatives. Subcontractors will either join this meeting or by request of Contractor conduct their own in their own office area.

· Conduct a weekly all hands site safety meeting that includes all employees of each contractor for the entire site.

· Weekly documented Site HSE inspections with listed corrective actions.

· Proactive audit program with documented system audits frequency of once per quarter.

· Inspection program that includes review and monitoring of JHAs.

Meetings:

Contractor shall establish an HSE Safety Committee that is comprised from Contractor and Subcontractor’s employees other than management. The committee shall meet at least once per week with published meeting minutes and actions.

Contractors shall establish a Site Safety Managers Meeting with published meeting minutes and corrective actions which will be held weekly. This meeting will include the HSE representatives from each Contractor on site. This meeting shall occur at which time there are more than two site safety representatives on site. This group will also address identified issues raised by the HSE Site Safety Committee and provide them with corrective actions where necessary.

Incident Reporting and investigation:

Contractor and Subcontractors shall report accidents/incidents to Owner’s Site Safety Representative as soon as practically possible verbally and using the offline form. Contractor shall send an official notification to the Owner within twelve (12) hours of an incident - with basic information (“who, what, when, where”). The Contractor(s) or Subcontractor(s) involved shall perform follow-up written investigations that will include recommended corrective actions which shall within forty-eight (48) hours from incident occurrence be delivered to and discussed with the Owner’s Site Representative and Site Safety Representative before any final reports are concluded. Final reports are due to the Owner’s Safety Representative no later than ten (10) days after the incident unless there are pre-approved extenuating circumstances by the Owner.

Emergency Planning:

Contractor will develop a written Emergency Management Plan (EMP) that will be developed in coordination with local government and civil emergency preparedness agencies such as police, fire, National Guard, and hospital treatment facilities. The EMP shall include at a minimum injury response, environmental and weather risks. At least two drills shall be conducted, one during early works and another prior to the completion of ten (10) wind turbines. A summary of these drills shall be prepared and distributed to the Owner’s Site Safety Representative within 48 hours of completion. The summary will include, at a minimum, a timeline of events and areas that need improvement.

3. Security

Contractor shall participate with the site passports to all project personnel for identification and daily site population tracking purposes. All Site personnel will check in and out with Site Security daily using their passport and their passport will stay on their person will on site. . If a passport is lost or forgotten personnel will not be allowed to go to a work location until a new passport is issued or their existing passport is retrieved. All visitors shall check in with and receive a visitor pass from Security prior to entering the compound area. All visitor passes shall be returned to Security at the end of each day. A security office shall be located at the compound entrance and supplied with electricity and appropriate toilet facilities as required. The positioning of the Security Office shall allow for the Security Officer to view all persons entering and exiting vehicles without impeding traffic flow.

Owner, Contractor and Subcontractors shall ensure that their vehicles except for rentals on site temporarily (less than one week) have placards or company insignias. Any vehicle without permanent markings shall be provided temporary project signage visible from a distance of 100 feet. Signage shall be magnetic or provided with alternate means of attachment.

4. Environmental

Contractor and Subcontractors shall adhere to all applicable environmental laws and regulations including any conditions contained within Owner and Contractor Permits Exhibit H-1 and any other issued permits or approvals required for the Project. For the benefit of the Contractor and Subcontractors, the Owner has provided a compliance matrix that summarizes the permits and conditions required for the project; however, this matrix is a reference list and does not supersede any regulatory requirements.

All contractors are required to adhere to site development area construction corridors shown on the construction civil drawings. No vehicular traffic is allowed outside the identified corridors. Failure to comply with these restrictions could cause the violating contractor to be responsible for providing barriers or fencing to prevent recurrence of corridor violations at no cost to the Owner, therefore, Contractors and Subcontractors are encouraged to provide a plan for communicating with and monitoring their personnel and the Contractor.

Contractor shall provide an Environmental Coordinator/Monitor (ECM) who at a minimum will have a college degree or professional environmental coordination and monitoring experience commensurate with such responsibilities and will be well versed in generally accepted best management practices. The requirement for a degree may be substituted by at least two (2) years of relevant successful work experience as an environmental monitor. Each Contractor shall also provide one (1) ECM who will have substantially the same or similar credentials as described herein-above. The one (1) ECM retained by Contractor will be assigned to provide services throughout all phases of the Projects to which Contractor has entered a contract with Owner to Work. The Contractor’s ECM shall only be called upon on an as-needed-basis in relation to the below duties on an hourly rate specified in Contractors’ Unit Rate Ticket Exhibit B-3. For avoidance of any doubt, the Contractor(s) is required to provide one (1) individual only that will be assigned to provide ECM coverage for any additional Phases to the project until BOP Contractor reaches substantial completion.

Duties of the Contractor Environmental Coordinator shall include as a minimum:

· Management and oversight of the project environmental management system.

· Compile all information indicated as the contractor responsibility in the EPC compliance matrix.

· Conduct environmental orientation training.

· Maintenance, Inspection, Reporting and mapping of all installed BMP’s.

· Conducting frequent inspections and providing a weekly report documenting compliance to the Project Environmental Requirements, assessing identified weaknesses, and providing corrective action recommendations.

· Monitoring housekeeping, trash pickup, and dust control measures.

· Investigating and reporting spills.

· Monitoring re-vegetation and landscaping activities.

· Have documented program to monitor all equipment and vehicles coming on site for environmentally hazardous issues and invasive weeds.

· Implement a site wide recycling program.

· Track owner required environmental criteria for environmental reporting which shall consist of types and amounts of materials shipped from site and final destination of each.

Waste Management:

Each construction site shall follow Enel Green Power North Americas waste management program, document ENA-ENV-OP-WST-001. This waste management plan is designed to help ensure that used oil and universal waste generated at the Enel Green Power North Americas sites are handled, stored and disposed of properly in accordance with federal, state and local requirements.

5. Contractor Provided Safety Training Requirements

Onsite training requirements:

· The training requirements listed in this section are not intended to replace any contractor required training being scheduled or mandatory.

· A site training program for safety orientation and environmental awareness shall be implemented before site activities begin. This training shall be given to all members of the Contractor and their Subcontractors management and staff, Owner’s management and staff, delivery, sales representatives or maintenance personnel who may have intermittent work activities that require unescorted access to Site locations.

· Personnel who have not attended the site safety orientation and environmental awareness training will not be allowed unescorted access to the site.

· Contractor along with their Subcontractors, shall participate in safety meetings and training sessions that have been developed by the project team.

· Training records shall be retained by the contractor for the duration of construction. These records shall consist of course outline along with roster complete with course name, date, time, location, competent trainer with trainers’ signature, employee’s names and signature. These records shall be maintained and transmitted to the owner in a timely manner.

· HSEQ Orientation for the workers shall be a minimum of 3 hours in length. Visitors from corporate/non-site office personnel shall go through a separate HSEQ Orientation that will be no more than an one (1) hour in length and will be escorted by someone that has went through the full HSEQ Orientation. The HSEQ orientation for the workers shall contain the below requirements, at the minimum, the minimum for visitors will have a mark (*) next to the main HSEQ Orientation:

· Enel Green Power North America’s commitment to an incident free environment shall be presented with the mission statement slide and stop work policy. *

· Review of required site PPE along with guidelines on how to use and care for.

· Review of the site-specific rules. *

· SDS review. *

· Location of first aid equipment along with identification of EMS personal. *

· Job Hazard Assessment and tailboard meeting awareness training. *

· Event reporting requirements.

· Site evacuation and emergency awareness training. *

· Mobile equipment training program.

· Basic electricity safety.

· Fall prevention awareness training including ladders and scaffolds.

· Energy isolation training.

· Confined space training.

· Blood borne pathogens awareness training. *

· Hearing protection awareness training. *

· Forklift training program.

· Crane awareness training.

· Enel Safety Video.

· Environmental Orientation shall be 1 hour in length and contain the below requirements at the minimum:

· Overview of the environmental regulatory obligations, including relevant Site Permits.

· Review of the flora, fauna and archaeological restrictions associated with the survey reports and owner regulatory commitments specified in the H-2 compliance matrix.

· Reporting requirements and field actions for employees.

· Site Development Area construction corridor compliance.

· Housekeeping and recycling.

· Oil containment and spill requirements.

· Review and alignment with key topic concerning SPCC stipulations.

· Mobile equipment and operator training will have duration of 1 hour and be required for all personnel assigned to mobile equipment. It will include as a minimum:

· Construction compliance.

· Power line interaction training.

· Topsoil preservation requirement associated with best management practices.

· Storm water pollution prevention plan requirements.

· Discovery and reporting of archaeological artefacts or human remains.

· A training program that consists of formal training as well as an observed practical operation test in which both will be documented. The formal training and practical operation training

· All employees that operate mobile equipment will have an operators card on their persons at all times of operation.

· Crane operator and crew training will be required for all personnel assigned to mobile, all terrain and crawler crews prior to deployment on site. This training will be devolved in compliance with OSHA standards and other applicable regulations and include as a minimum:

· Proper entrance and exiting procedures.

· Power line interaction training.

· Safe backing techniques.

· Proper use of spotters.

· Tipping, jack knifing and operational awareness training.

· Provide training to familiarize O&M personnel and those involved with energization with the operation of the high voltage collection system and substation. The contractor shall accomplish by:

· Incorporating Owners O&M personnel into the project start up activities.

· Review all manuals.

· Review drawing and other educational material provided for the training of the O&M personnel.

· Electrical contractor splice training:

· Contractor must train all personnel performing the splicing on the projects. Under no circumstances will any individual perform splicing unless specifically trained by personnel from vendor of such splices.

o All individuals must accurately demonstrate splicing techniques and methods to a vendor’s trainer.

· All splice technicians must provide evidence of training to owner prior to actual field splicing.

· Electrical clearance training:

· Contractors shall provide electrical clearance training to all employees performing electrical works prior to initial substation energization.

· Documentation certifying this training shall be submitted to owner prior to substation energization.

· Contractor shall train all personnel to properly lock and tag all equipment that becomes energized during construction.

· Turbine supplier WTG installation training if applicable for the site.

· Contractor shall complete all WTG installation training being provided by the turbine supplier.

· Contractor shall provide WTG installation training to its personnel prior to actual filed installation activities.

· All other site-specific safety training shall be performed, documented and complete before the applicable activity begins.

Exhibit A.4

REV 4 18Mar16 Page 1 of 12

Exhibit A.4

REV 4 18Mar16 Page 1 of 12

Page 1 of 12

Rev. 7.1 - 12/01/17