eqt ehs programs table of contents

EQT EHS Programs Table of Contents

1 Abrasive Blasting and Coating 2 All-Terrain Vehicle 3 Chainsaw and Tree Safety 4 Confined Space 5 Contractor and Subcontractor 6 Crane Operations 7 Electrical Safety – Grounding and Bonding 8 Emergency Planning and Response 9 Ergonomics 10 EQT Lockout- Tagout 11 Excavation 12 Explosives 13 Fatigue Management 14 Fire Safety 15 First Aid – Bloodborne Pathogens (BBP) 16 Fleet Safety 17 Gas Hazards 18 Hazard Assessment and Control 19 Hazard Communication 20 Hazardous Materials Management 21 Hearing Conservation 22 Hot-Work Permit 23 Incident Reporting and Investigation 24 Lone Worker 25 Mobile Equipment 26 Outdoor Safety 27 Personal Protective Equipment 28 Short-service Employee 29 Tools and Equipment 30 Working at Heights 31 EQT Security 32 Spill Response 33 Water Supply Protection 34 Air Permitting 35 Waste Handling and Disposal 36 Solids Control and Disposal – Drilling 37 WV AST Registration and Closure

EHS Management System

Title Abrasive Blasting and Coating

Number 01

Owner VP, EHS

Revision 0

EQT Corporation EHS-0101012021

Issue Date: 1/1/2021 Revision Date: 1/1/2021

Print Date: 11/2/2020 Valid on the Date Printed ONLY

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1 PURPOSE AND SCOPE

1.1 The purpose of this Abrasive Blasting and Coating Program is to define procedures and

precautions that must be followed during abrasive blasting and coating activities. This Program

applies to all personnel working on EQT locations.

2 GENERAL REQUIREMENTS

2.1 All equipment operated for abrasive blasting and coating activities must only be used for its

intended purpose in accordance with manufacturer recommendations.

2.2 The hazard assessment conducted shall meet the requirements established in the EQT Hazard

Assessment and Control Program. Based on the hazard assessment, appropriate controls will be

selected to mitigate employee exposure to acceptable levels.

2.3 Use a carbon monoxide and purification system when an oil-lubricated compressor is the air

source for blast hoods. Breathing air must meet OSHA Class D standards.

2.4 Never aim the blast nozzle at another person.

2.5 Provide safety cables and tie wire/pins at all connections.

2.6 Use a dead-man switch at the blast nozzle for abrasive blasters. Manually hold open switches and

valves.

2.7 Use only static-dissipating blast hose and ground the blast pot to prevent accumulation of static

electricity. Ensure the entire system is bonded and grounded.

2.8 Barricade or post “No Entry” signs in abrasive blasting area to protect others and limit access to

authorized personnel only.

2.9 Complete an EQT Hot Work Assessment form in accordance with the EQT Hot Work Program

prior to beginning work (when applicable).

2.10 Review the Safety Data Sheet for coating to ensure understanding of the hazards, safety

precautions and proper PPE.

2.11 All enclosures for blasting and coating operations will be designed in accordance with all federal

and state codes and standards.

3 TRAINING

3.1 Only trained personnel will be authorized to conduct abrasive blasting and coating operations.


Title Abrasive Blasting and Coating

Number 01

Owner VP, EHS

Revision 0




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4 ROLES AND RESPONSIBILITIES

4.1 EQT Supervisors

• Implement this Program; and

• Senior management will enforce actions related to violations of requirements.

4.2 EQT Employees

• Adhere to this Program, including attending all required training.

4.3 Business Partners

• Adhere to this Program, including providing and attending all training for business

partner personnel as required;

• Comply with all federal and state requirements to ensure exposure to their employees’

and subcontractors is below actionable levels;

• Have verified abrasive blasting and silica exposure control programs in ISNetworld; and

• Maintain and provide documentation upon request to EQT of industrial hygiene business

partner employee exposure assessments conducted on EQT locations. Refer to Hazards

Materials Management Program for more information.

4.4 EQT Corporate EHS Department

• Develops and delivers training for EQT personnel according to the requirements of this

Program;

• Conducts PPE risk assessments and industrial hygiene monitoring for abrasive blasting

and coating operations and develops controls to mitigate employee exposures to

acceptable levels; and

• Creates business partner safety qualifications and periodically audit business partners to

ensure they meet the requirements of this Program.

5 DEFINITIONS

Abrasive: a solid substance used in an abrasive blasting operation.

Abrasive Blasting: forcible application of an abrasive to a surface by pneumatic pressure, hydraulic

pressure, or centrifugal force.


Title All-Terrain Vehicle Safety

Number 02

Owner VP, EHS

Revision 0




Page 1 of 6

1 PURPOSE AND SCOPE 1.1 The purpose of this procedure is to define the requirements for the safe operation of All-Terrain

Vehicles (ATVs), Utility Terrain Vehicles (UTVs) and snowmobiles used in the course of EQT’s business.


2.1 EQT and Business partner ATVs/UTVs and snowmobiles are to be used exclusively for

company business unless specifically approved otherwise.

2.2 Operators of these units must adhere to all ATV, UTV, and snowmobile-related state laws. 2.3 All operators must follow the recommendations in OSHA’s Safety and Health Information

Bulletin 08-03-2006 – Hazards Associated with All Terrain Vehicles (ATV) in the Workplace.

2.4 All operators must be aware of site-specific hazards and wear required personal protective equipment (PPE) as defined in Section 3.

2.5 All operators must follow the owner’s manual specific for their ATV/UTV. 2.6 Only Authorized Operators — personnel approved by their supervisors and who have completed

the required training — will be permitted to operate an ATV, UTV, and/or snowmobile. 2.7 No family members, friends, or business partners are permitted to operate EQT vehicles.

2.8 Business partners must have an ATV/UTV operating policy and training program and provide a

copy to EQT prior to operating on EQT property.

2.9 When operating a snowmobile, a stop-engine safety cord must be used, as provided.

2.10 Unless specifically designed to carry more than one person, passengers are not permitted on an ATV. A UTV is not to be operated with more passengers than the vehicle is designed to accommodate. Passengers are not permitted in the bed of a UTV.

2.11 Vehicles must not be used on public roads while working on an EQT project, except to cross a roadway or ride on the roadway for short distances where permissible by state or local ordinances.



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3 EQUIPMENT

3.1 Every ATV, UTV, and snowmobile must be equipped with a Loggers first-aid kit.

3.2 All ATV, UTV, and snowmobile operators must wear a DOT-approved helmet with a properly fitted chinstrap.

3.3 All UTV operators and passengers must wear a seatbelt (if provided). Additionally, the UTV must be equipped with a Rollover Protective Structure (ROPS).

3.4 Eye protection consisting of either goggles, safety glasses with side-shields, or a face shield must be worn at all times while operating an ATV, UTV or snowmobile.

Snowmobile only: Wear goggles with colored lenses for bright days. Amber or yellow lenses are useful on dark days or late in the afternoon.

3.5 ATV and snowmobile operators are required to wear hand protection consisting of gloves at all times when the ATV or snowmobile is in operation.

Snowmobile operators: Wear gloves that safely permit hands and fingers to operate the controls.

3.6 Over-the-ankle boots, long-sleeved shirt and pants must be worn at all times when operating an ATV, UTV, or snowmobile.

3.7 Snowmobile operators should use the following clothing guidelines:

Wear layers and ensure they are not too loose or too tight; Ensure outer shell is windproof and waterproof; Consider thermal underwear, which adds an important layer of dead air to maximize proper insulation; and Avoid wearing long scarves or loose clothing that could get caught in moving parts.

4 PROCEDURE – ATVs AND UTVs

4.1 A pre-ride inspection must be completed prior to operating an ATV or UTV to ensure the vehicle

is in safe operating condition. EQT operators are required to perform a more thorough documented inspection conducted monthly (Appendix A).

Tires: Always maintain the manufacturer-recommended tire pressure and ensure all tires are inflated to equal pressure. Check tires for cuts or gouges that could leak or cause a blowout.



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Wheels: Ensure axle nuts are tight and secured with a cotter pin. Ensure all lug nuts are

in place and secured appropriately

Brakes: Always ensure brakes are working properly before riding. Check the cables and links to ensure they are moving smoothly. The controls should be positioned for easy reach and use.

Throttle: The throttle should operate smoothly and snap into the idle position when released. If the UTV has a throttle limiter, ensure it is adjusted appropriately for the rider.

Loose nuts or bolts: Riding on rough terrain may cause nuts and bolts to loosen. While the engine is off, check for loose nuts and bolts.

Lights and switches: The ignition switch and the kill switch must be functioning properly before placing the vehicle into operation. All lights must be working, particularly if riding at night.

Oil and fuel: While the engine is off, check to ensure sufficient oil and fuel levels. Also ensure there are no oil or fuel leaks.

Cargo: Ensure load is properly secured.

4.2 Loading and Towing

Attempt to use the terrain to minimize the angle of the ramp. Choose a site that

will provide the best option to keep the ATV as level as possible. Inspect the tailgate and tailgate straps. Ensure tailgate is secured to the truck at the

hinge point. Inspect tailgate straps for damage. Inspect the ramp and the ramp straps:

o Replace the straps on the ramp if they do not tighten or stay tight; o Secure ramp straps downward to help hold them tightly to the tailgate; o Never load or unload unless ramps are tightly secured to the truck; o Never walk up or down ramps; and o Never back the ATV into the bed of a truck.

Descend and ascend at a slow and steady speed:

o Stop and coast backward if there is not enough momentum to ascend the ramps; o Avoid increasing the throttle while ascending the ramps;



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o Ensure the parking brake has been disengaged and do not apply brakes suddenly; o Keep body weight toward the front of the ATV; and o Do not apply the throttle when descending ramps; let the ATV coast down the

ramp.

4.3 Transporting ATVs and UTVs

Secure UTVs with four tie-down straps. Leave ATVs and UTVs in gear with the brake set. Ensure the tailgate is latched. If the tailgate will not close, ensure there are no loose items in the bed of the truck or on the ATV/UTV.

5 PROCEDURE – SNOWMOBILES

5.1 A pre-ride inspection must be completed prior to operating a snowmobile to ensure the vehicle is in safe operating condition. EQT Operators are required to complete the monthly snowmobile

inspection (Appendix B).

Brakes: Always ensure brakes are working properly before riding. The controls should be positioned for easy reach and use.

Throttle: The throttle should operate smoothly and snap into the idle position when released. If the snowmobile has a throttle limiter, ensure it is adjusted appropriately for the rider.

Skis and track: Check for proper alignment. Ensure track tension is proper. Ensure that skis and track are not frozen down.

Lights and switches: The ignition switch and the kill switch must be functioning properly before placing the snowmobile into operation. All lights must be working, particularly if riding at night.

Oil and fuel: While the engine is off, check to ensure sufficient oil and fuel levels. Also ensure there are no oil or fuel leaks.

5.2 Controls

Throttle



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o Right hand controls the handlebar-mounted, spring-loaded throttle, which is designed to return automatically to the idling position when the operator is no longer holding it.

o Before each start, check the throttle before turning on the ignition. Ensure it moves freely without sticking in either a partially or fully open position. If trouble develops with the throttle control that prevents normal slowing or stopping, turn the ignition key or emergency switch to the off position.

Brakes

o Left hand controls a braking device to slow safely and rapidly. o Learn braking distances at various speeds for the many snow and ice conditions. o Check the smooth and free operation of the spring-loaded cable cord often.

Steering/Lights

o The snowmobile is running on snow and ice and relies on friction to turn. o The proper shifting of weight with both hands on the handlebars is required to

guide and turn it. Check your steering system to assure its movement is not restricted.

o Keep lights clear of road dirt, slush, or snow.

5.3 Maintenance/Fuel

Turn off snowmobile before adding fuel. Do not operate when the machine is faulty or if guards or components are missing. Follow recommended preventative maintenance schedule.

6 TRAINING

6.1 EQT New Authorized Operators will be required to complete an ATV/UTV training course. 6.2 EQT Authorized Operators of snowmobiles are required to complete Computer-based Training

(CBT) prior to operating the equipment and to attend a refresher course every three years. 6.3 EQT Operators must receive documented instruction and hands-on training on safe handling and

operation and be competent in operating their specific vehicle under the variety of conditions in which they will be driving.

6.4 Business partners must ensure their employees are competent in operating their specific ATV

under the variety of conditions which they will be driving. The ATV Safety Institute offers ATV classes that might be beneficial. Business partners must provide to EQT documentation of the



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employee’s training.

7 RECORD RETENTION 7.1 All documentation and equipment checklist associated with this program shall be maintained for

a period of one year. 8 ROLES AND RESPONSIBILITIES

8.1 Authorized Operators

Record and report all incidents and accidents; and Always operate an ATV, UTV or snowmobile in a safe and legal manner.

8.2 EQT Supervisors

Investigate and report all accidents involving an ATV, UTV, or snowmobile used in

performing company business; and Forward all incident reports to the EQT Fleet Safety Team for follow-up investigation.

9 DEFINITIONS

All-Terrain Vehicle (ATV): a motorized off-highway vehicle designed to travel on four low-pressure tires, having a seat designed to be straddled by the operator and handlebars for steering control.

UTV: an abbreviation for Utility Terrain Vehicle, a motorized off-highway vehicle equipped with a cargo or dump bed, seats for at least two occupants, and designed to travel on four low pressure tires.


Title Chainsaw and Tree Safety

Number 03

Owner VP, EHS

Revision 0




Page 1 of 8

1 PURPOSE AND SCOPE

1.1 The purpose of this Chainsaw and Tree Safety Program is to define procedures and precautions that must be followed for the safe use of a chainsaw, cutting of a tree, limbing, or clearing brush.


2.1 Felling trees as a lone worker is not permitted.

2.2 All business partners that are performing tree felling, trimming, or clearing; regardless of status as a prime business partner or subcontractor, must have a 100% verified and compliant logging program in ISNetworld. If a prime business partner is delegating all tree-related work to a subcontractor partner (and not performing any tree-related activities themselves), only the subcontractor partner is required to have a verified logging program. At a minimum, the written logging/tree safety program must meet the requirements of this Program and business partners are required to use the three established tree safety forms (Appendix A, B and C) described in sections 4.4 – 4.6.

2.3 EQT chainsaw safety-trained employees are permitted to perform tree limbing (removing limbs) and bucking (cutting sections into logs) of fallen trees where an essential business need has been identified, such as where a fallen tree has blocked access to a lease road, well site, pipeline right-of-way, or compressor station.

2.4 Tree felling, limbing, and bucking must be conducted in accordance with:

• Personal Protective Equipment (PPE) requirements; • Proper body positioning, such as conducting limbing and bucking on the uphill side of a tree or log or where rolling/sliding might be expected; • Proper cutting precautions to ensure safe limb pressure/tension relief; and • Safety training requirements.

2.5 EQT employees are not permitted to fell trees greater than four inches in diameter at breast height without first completing a chainsaw and tree felling safety training program and contacting their supervisor before tree felling begins. The maximum size tree to be felled by EQT employees is 10 inches in diameter at breast height. Trees larger than 10 inches are not be felled by EQT employees. If a tree larger than 10 inches needs to be felled the employee shall contact their supervisor to arrange for a certified business partner to fell and clear the tree.

2.6 Domino tree felling is prohibited. 2.7 Initiate Stop Work Authority (SWA) action if there is any doubt about the safety of the task.



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3 EQUIPMENT

3.1 All required PPE must be inspected and worn prior to starting a chainsaw. PPE includes:

• Hard hat meeting ANSI Z89.1 (Class E if within proximity of utilities) with mesh face

screen; • Hearing protection; • Cut resistant hard-toe boots (e.g. ASTM F1818 or EN ISO 17249); • Cut-resistant gloves (ANSI / ISEA 105 minimum level 3); • Long-sleeved shirt; • UL-labeled chainsaw leg protection meeting ASTM F1897 (e.g., cut-resistant chaps or

pants) that covers the entire leg (from the foot top to upper thigh, including the entire calf);

• Eye protection that meets ANSI / ISEA Z87+ safety standards; and • A minimum of ANSI / ISEA 107 Class 2 high-visibility clothing – tree felling only.

3.2 In the area in which a chainsaw is to be operated for tree felling, the below safety equipment is

required:

• Logger’s first-aid kit (adequate for the number of employees) and a personal blood-clotting bandage for each chainsaw operator;

• Wedges and hammer/small axe; • Chainsaw maintenance tools, including file guides and saw wrench; • Spill kit; • Working air horn, whistle or other non-audible means of communication; and • Two-way radio.

3.3 Equipment maintenance

• Chainsaws and felling equipment must be maintained according to the manufacturer’s

specifications. • EQT employees are not authorized to sharpen chainsaw blades. Replacement blades must be used when the blade becomes dull.

4 PROCEDURE

4.1 All chainsaws shall comply with ANSI B175 and must be equipped with an anti-kickback device; bucking spikes; an anti-vibration system; a trigger with safety interlock; spark arrestor; chain catch pin; inertia chain brake; and a hand/wrist guard.



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4.2 Prior to use, the chainsaw must be inspected to ensure all major safety features are in place and

in working order. In addition to the equipment’s safety features, the chainsaw must be inspected for:

• Proper chain sharpness and tension; • Proper engine revving speeds and idle positioning in accordance with manufacturer specifications. • No leaking fuel; and • Operating without the user providing continuous gas flow.

If the chainsaw does not pass the safety inspection, it must be tagged as “not in service” until repairs are made.

4.3 Personnel are to follow the below chainsaw operational procedures:

• Proper chainsaw starting practices must be performed. Drop-starting (arms in motion) chainsaw is prohibited. Chainsaws must be activated using the approved ground-start method and with the chain brake engaged.

• Chainsaw always must be operated with the right hand on the trigger and the left hand on the front handle.

• During cutting, both hands are to remain on the chainsaw at all times, with hands and thumbs firmly wrapped around the handles of the chainsaw.

• Footing must be secure before cutting. • Chainsaw must be operated close to the body between the chest and the knees, elbows

bent. • When not actively cutting, the chainsaw brake must be engaged. • Never operate a chainsaw above the shoulders or with a bent back; take a knee if

necessary. • Never operate a chainsaw from a ladder. • Chainsaw is to be carried in the left hand with the chain pointing backward, away from

the body. • Ensure chainsaw operators maintain a 10-foot buffer from other workers or a distance of

at least 2 times the length of the tree if felling trees. • Meet EQT’s Hot Work Permit Program requirements as applicable; and protect the

ground from unintentional spills. • Never fuel a hot engine. Wait at least 10 minutes before fueling. Start the chainsaw at

least 10 feet from the fueling area. • Shut off the chainsaw when moving it at a distance extending beyond tree to tree or in

hazardous conditions, such as slippery surfaces or heavy underbrush.



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4.4 All tree felling work zones must be assessed by the crew daily for hazards using the Tree Safety Work Permit (Appendix A); all identified hazards must be eliminated or mitigated before tree work begins. If hazards are unable to be mitigated and/or eliminated (e.g., danger tree), work is not to proceed until the employee contacts his/her supervisor and a Danger Tree Felling Plan (Appendix C) is developed.

4.5 A Tree Safety Work Permit (Appendix A) must be completed before felling or cutting takes place each day and applies to both mechanical and manual tree felling operations. Felling operations must include a Danger Tree Felling Plan (Appendix C) for identified danger trees or a six-step felling plan for normal felling operations which includes the following:

• Determination of a clear fall path that considers, at a minimum, overhead hazards, ground slope and ease of removal;

• Evaluation of hazards due to the height and lean of the tree; • Determination of necessary equipment. If all necessary equipment is unavailable or

tree work cannot be performed in a safe manner, work must stop and the Corporate EHS Department and EQT management contacted for guidance;

• Establishment of an escape route at 45o from intended direction of the tree fall; • Determination of the notch type to be used; and • Confirmation that a bore or back-cut will be made to cut and release the tree.

4.6 Additionally, the work location supervisor must complete a Daily Tree Safety Inspection

(Appendix B) after work has started to verify that the requirements of this Program are being met and that the required documentation is completed and available. Any issues found to be unsatisfactory during the daily inspection must be mitigated and the action documented.

4.7 Trees larger than five inches in diameter at breast height are to be notched using a 70o-90o angle

with the back-cut meeting the apex of the notch. There must be an appropriate-sized hinge to provide control of the tree through at least 50 percent of its fall.

4.8 Prior to tree cutting, all tension and compression points will be identified within the tree. (This applies to both mechanical and manual tree felling operations)

• If mechanical cutting is used to remove trees, ensure machine stability and safe equipment operation according to the equipment manufacturer’s operator’s manual.

• Chainsaw operator must ensure secure footing prior to making any cut. • Chainsaw operator must stand on the uphill side of the tree at all times. • Branches above the chainsaw operator are to be removed first to lessen the forces of

tension and compression, as well as prevent the chainsaw operator from being struck by a limb.



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• The tip or kickback zone of the chainsaw bar must be clear at all times. The chainsaw operator must identify all potential obstacles in the path of the bar prior to cutting.

4.9 Prior to limbing, loggers should evaluate overhead hazards, as well as the following: • Spring poles; • Butt movement forward (creates back pressure on limbs); • Butt twist (creates sideways pressure on limbs); • Butt off the ground (creates tension and compression on the tree stem); and • Cut principle/compression and tension.

4.10 Business partners performing tree climbing must be qualified in arboricultural safety, tree

climbing, aerial chainsaw use, arborist rigging, and aerial rescue. Business partners must also show competent understanding of ANSI Z 133 as well as OSHA 1910.269 regulations as they pertain to tree climbing.

• Climbers working within 10 feet of utilities (of 50kv or less or minimum approach distances shall be greater for voltages above 50kv) must provide proof of training as an Incidental Qualified Line Clearance Arborist (IQLCA). There must be one other IQLCA or QLCA trained business partner within visual and voice communication distance at all times.

• Prior to ascent, a pre-climb inspection including a pull and load test of the tree, and thorough inspection of any anchor point to be used for personal lift support must be completed and documented. A designated Competent Person must assess any tree deemed to be a danger tree and ensure a written plan is developed and implemented. All workers involved in the tree-felling operation must agree to the plan before climbing begins.

• All ropes must meet the minimum requirements listed in ANSI Z133. • All climbing harnesses and tree gaffs must meet the requirements listed in ANSI Z133, as

well as all other applicable standards (e.g., ANSI Z 359 and/or marked ASTM F887 if manufactured after January 1, 2018).

• Do not ascend a tree unless a qualified rescue climber is present. The rescue climber’s gear must be inspected daily and be available to facilitate an efficient rescue.

• Prior to climbing, ensure clearly designated work and fell zones. Ensure all crew members agree to verbal command and response signals.

• Climbers: o Must have at all times a climbing line long enough to repel to the ground no

matter where they are secured in the tree and a separate means of life support attached to the tree while cutting and working aloft;

o Must utilize safe fall protection methods and equipment to remain attached to the tree from the time the climber leaves the ground until returning to the ground; and

o Must use at least one choking/cinching system and have a means of egress to the ground while working on a tree where all the branches have been removed.



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• At all times while working aloft, climbers must have a handsaw. All chainsaws must be attached to the climbing harness by a breakaway lanyard.

• Never hand a chainsaw to someone while in a tree. 4.11 Personnel must have a clean and established escape route prior to beginning tree felling per the

six-step felling plan and must use the escape route as the tree begins to fall.

• All personnel must be at least two tree lengths away during felling operations. • The felling crew must have an established communication tool (e.g., horn, whistle, radio)

to communicate during tree felling operations. • An audible alarm must be given and understood by the entire crew before the tree is

felled. • If mechanically assisted tree felling will take place, a thorough review and

discussion of the tree safety work permit by both the machine operator and cutter (chainsaw operator) must be performed.

• The chainsaw operator must not be under the machine or tree while it is falling. • The chainsaw operator also must not stand downhill of the machine. • There must be radio communication and clear line of sight between the chainsaw

operator and the equipment operator.

4.12 If a hung tree/limb occurs, the area will be marked and barricaded until a documented Danger Tree Felling Plan (Appendix C) can be conducted and an action plan initiated to clear the obstruction safely.

4.13 Burning Requirements

• Ensure adequate fire suppression is on sight to extinguish any fires burning outside their designated area is mandatory prior to ignition of any fires.

• If burning is used, a burning permit may be required and obtained from the proper authority prior to any burning operations taking place.

• Comply with EQT Hot Work Permit Program, when conducting burning operations. • Ensure no fueling of equipment within the designated burn area, and remove all equipment

prior to ignition of fire. • Ensure log piles are no taller or wider than 14 feet. • Personnel are prohibited from walking atop piles for any reason. • Fires must be beyond 100 yards of a structure or roadway.

5 TRAINING

5.1 EQT employees must have current first-aid and CPR certifications prior to participating in

chainsaw activities.



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5.2 EQT Employees are not permitted to fell trees greater than four-inches in diameter without completing EQT Tree Felling Safety Training. The tree felling safety training must include a hands-on competency evaluation.

5.3 EQT Employees are not permitted to perform limbing and bucking operations if they have not completed EQT chainsaw training.

5.4 Retraining is required for EQT employees when new equipment is introduced and differs from the equipment on which employees originally were trained and if the employee is observed participating in unsafe job behavior.


6.1 EQT Supervisors

• Implementation of this Program; and • Senior management will enforce actions related to violations of any requirements.

6.2 EQT Employees/Business partners

• Adhere to this Program during all work operations. • Business partners who perform tree-related activities (e.g. trimming, mechanical or manual

felling, clearing) are required to have a verified and compliant logging/tree safety program in ISNetworld.

• Business partners must comply with OSHA 29 CFR 1910.266 Logging Standard or ANSI Z133 Arboricultural Operations Safety Requirements, as it applies to the work performed. Tree trimming, brush clearing, or logging operations performed within proximity to electric lines shall comply with OSHA 1910.333 and ANSI Z133 or 1910/269 and must have all documentation and training as a Qualified Line Clearance Arborist or Incidental Qualified Line Clearance Arborist (QLCA or IQLCA according ANSI Z133) when working within proximity of electrical conductors.

• Business partners must demonstrate the proper training and knowledge of the applicable OSHA standards, safe tree-cutting techniques, and proper equipment usage.


• Provides technical information and assists departments in implementing an effective Chainsaw and Tree Safety Program;

• Provides and/or coordinates chainsaw training; • Investigates and documents all reported incidents related to chainsaw use and tree cutting and

recommends corrective action; and



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• Reviews and revises the Chainsaw and Tree Safety Program to ensure compliance with applicable regulations.

7 DEFINITIONS

Bucking: process of cutting a felled and de-limbed tree into logs.

Danger Tree: one that poses an imminent threat of whole or partial failure within striking distance of a person or other hazards such as buildings, roads or utility lines, a tree that has significant cracks or burns, a tree with broken limbs or a tree impacted by vines. Escape Route: path of egress that is 45o from the notch in the tree that is pre-determined by the operator for escape.

Limbing: process of removing limbs from a tree

Tree Felling Work Zone: any area 360 o around the tree to be felled equal to two times the tree height.


Title Confined Space

Number 04

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Page 1 of 10

1 PURPOSE AND SCOPE

1.1 The purpose of this Confined Space Program is to define procedures and precautions that must be followed for safe entry into confined spaces and the operations performed within them. This program applies to all personnel working on EQT locations.


2.1 If the workplace contains permit-required confined spaces, affected personnel will be notified by

the posting of danger signs or other equally effective means that clearly indicate the existence, location of, and hazards posed by the permit-required confined spaces.

2.2 EQT personnel are not permitted to enter permit-required confined spaces unless all hazards have been removed and the location reclassified as non-permit required confined space.

2.3 Business partner personnel must follow all OSHA confined-space requirements and their

established company procedures. 2.4 Initiate a Stop Work Authority (SWA) action if there is any doubt about the safety of entering a

confined space.

3 CONFINED SPACE EVALUATION

3.1 Trained personnel shall evaluate equipment and areas at the site to identify confined spaces prior to entry. Trained EQT employees will use Section 2 of the Confined Space Pre-Entry Assessment form (Appendix A) to evaluate and classify the space prior to entry. Business partner personnel will evaluate and classify the space per the OSHA guidelines prior to entry.

3.2 A confined space is a space that meets all three of the following criteria:

The space is large enough and configured for a person to bodily enter and perform assigned work.

The space has limited means of entry or exit. The space is not designed for continuous personnel occupancy.

For Confined Spaces determined to be Permit-Required Confined Spaces, a sign/label is required with “DANGER PERMIT REQUIRED CONFINED

SPACE DO NOT ENTER” or other similar language. NOTE



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3.3 If a space is determined to be a confined space as outlined in 3.2, it must be further evaluated to

determine if it is a permit-required confined space.

3.4 Answering “yes” to any one of the below questions would classify the confined space as a permit-required confined space.

Does the space contain, or have potential to contain, an atmosphere that is toxic, flammable, asphyxiating, or immediately dangerous to life or health (IDLH)?

Does the space contain a material (e.g., liquid or finely divided solids) that can engulf the confined-space entrant?

Does the space have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section?

Does the space contain any other recognized serious safety or health hazards?

3.5 Document the confined space determination and classification on a documented pre-entry assessment.

3.6 The completed form for the confined space evaluation will be maintained by the Corporate EHS

Department and be readily available. 3.7 For permit-required confined spaces readily accessible (e.g., doors to valve vaults, chain across

ladder opening descending to compressor vault, cover over a wellhead cellar) for entry, identification of the permit-required confined space will be accomplished with a label or sign conveying “Danger Permit-Required Confined Space, Do Not Enter” or similar language. This label or sign will be in the traditional red, black and white colors and will be placed on or as close as possible to each entrance of the permit-required confined space.

3.8 All confined spaces will be identified and reviewed through the hazard assessment and control

process if the confined space is part of work operations.

4 CONFINED SPACE PRE-ENTRY PROCEDURE

Examples of a typical confined space can be a valve vault, wellhead cellar or below-grade sump in which a person would enter for maintenance or repair

activities. Examples of spaces not considered to be confined spaces are piping less than 24 inches in diameter, filter housings with screens preventing entry

and/or other spaces that have a barrier to bodily entry.

NOTE



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4.1 The EQT Confined Space Trained or Business Partner Entry Supervisor will review the confined space evaluation, supervise the entry and ensure safe work practices are followed. Before opening an access to a confined space, the EQT Confined Space Trained or Business Partner Entry Supervisor shall follow these procedures:

Review the completed pre-entry assessment to become familiar with any hazards associated with that space and the classification of that space.

Use normal safe work practices if the space is a non-permit required confined space. (See Section 5.)

Attempt to reclassify the permit-required confined space (Section 6.2) to a non-permit space or determine if the Alternate Procedure (Section 6.3) can be used.

Use a qualified business partner to complete the permit-required confined space entry if a permit-required confined space cannot be reclassified to a non-permit space or the Alternate Procedure cannot be used. (See Section 7 for an overview of requirements.)

5 NON-PERMIT REQUIRED CONFINED SPACE ENTRY PROCEDURE

5.1 If the confined space is not a permit-required confined space or a permit-required confined space

that has been reclassified, normal safe work practices will be observed before and during entry. 5.2 A review of the work will be conducted through the hazard assessment and control process prior

to entering the confined space to determine if any additional safety practices are required.

6 PERMIT-REQUIRED CONFINED SPACES

6.1 A permit-required confined space may be entered under three options:

Reclassify the permit-required confined space to a non-permit space; Use the Alternate Procedure for a permit-required confined space (qualified business

partners only); or Enter the space as a permit-required confined space (qualified business partners only).

6.2 A space classified as a permit-required confined space may be reclassified as a non-permit confined space with adherence to the following conditions:

The space poses no actual or potential atmospheric hazards. All hazards, including non-atmospheric hazards, are eliminated; The pre-entry assessment is used to document reclassification by documenting that all the

hazards in Part 2 have been eliminated. (Note: Control of atmospheric hazards through constant forced air ventilation does not constitute elimination of the hazard);



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Entry will be performed in compliance with the permit-required confined space requirements if initial entry of the permit-required confined space is required to obtain monitoring and inspection data; (Any permit-required confined space entry must be conducted by a qualified business partner.)

All personnel are obligated to initiate a SWA action and immediately exit the space if hazards arise within a permit-required confined space that has been reclassified to a non-permit space. The EQT Confined Space Trained or Business Partner Entry Supervisor then will re-evaluate the space to determine whether it must be reclassified as a permit-required confined space; and

Document reclassification for entry or the alternate procedure on the pre-entry assessment prior to entry related to each work shift.

6.3 An Alternate Procedure for entering a permit-required confined space may be used by qualified

business partners with adherence to all the following conditions:

Demonstration that the only hazard posed by the permit space is an actual or potential hazardous atmosphere;

Demonstrate that continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry;

Monitoring and inspection data is developed that supports these required demonstrations; If initial entry of the permit-required confined space is required to obtain monitoring and

inspection data, the entry will be performed in compliance with the permit-required confined space entry requirements; and

The determinations and supporting data are documented and made available to each worker who enters the permit space under the terms of this Procedure.

6.4 If the conditions required in 6.3 are met, entry may be made into the permit-required confined space by meeting the following requirements:

Any conditions making it unsafe to remove an entrance cover are eliminated before the cover is removed.

o Eliminate all hazards associated with establishing access. This could include but is not limited to de-pressuring; isolating the confined space through the EQT Control of Hazardous Energy Program (LOTO); draining liquids; flushing; rinsing; clearing the area of ignition sources if flammable vapors might be present; and placing barriers to limit unauthorized access to the area.

When covers are removed, the opening shall be promptly guarded by a railing, temporary cover or other temporary barrier that will prevent an accidental fall through the opening



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and protect employees working in the space from foreign objects entering it. (Refer to the EQT Working at Heights Program for additional information.)

The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any potential or actual hazardous atmospheres, so that appropriate permit procedures can be developed, and acceptable entry conditions stipulated for that space.

Before personnel enters the space, the internal atmosphere must be tested with a properly calibrated direct-reading instrument for oxygen content (O2), flammable gases and vapors (LEL/LFL), and for potential toxic air contaminants (H2S and CO).

o The testing results will be recorded on the pre-entry assessment form. If the space cannot be tested without entering, the space will be treated as a permit-required confined space and entry will be made in accordance with Permit-Required Confined Space Entry requirements.

Table 1 Atmospheric Test Permissible Concentration

Oxygen >19.5% but <23.5% LEL/LFL 0.00 Recommended; Not to Equal

or Exceed 10% H2S <10ppm CO <25ppm

Table 1 represents the maximum allowable level of atmospheric concentrations for

alternate procedures to be used, but personnel will attempt to achieve a zero concentration of H2S and CO whenever possible.

In a confined space, it is important to take samples at the top, middle and bottom to locate varying concentrations of gases and vapors. Highly concentrated gases can accumulate at the top or bottom of a confined space depending on whether they are less or denser than air.

Dilute gases and vapors in the ppm range distribute evenly throughout a confined space. It is especially important to sample at a distance from the opening, because air intrusion near the entrance can give a false sense of adequate oxygen presence.

Personnel shall not enter any space containing a hazardous atmosphere. Continuous monitoring is required, and gas detection equipment must have an internal or

attached pump, be calibrated properly, and bump tested per the manufacturer’s recommendation.

Continuous forced air ventilation shall be used as follows:



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o Mount sufficient forced air ventilation equipment on openings to the confined space to eliminate the hazardous atmosphere. Supply fans must be located outside of the potential hazardous area. Intrinsically safe fans should be used to prevent sending a spark down the duct;

o Forced air ventilation shall be directed as to ventilate the immediate areas where an entrant is or will be present within the space and shall continue until all entrants have left the space;

o The air supply for the forced air ventilation shall be from a clean source and may not increase the hazards in the space; and

o The atmosphere within the space shall be monitored continuously to ensure forced air ventilation is preventing the accumulation of a hazardous atmosphere. Workers entering the space shall be provided with an opportunity to observe the monitoring results. The test results will be recorded.

If a hazardous atmosphere is detected during entry, all personnel must leave immediately.

o The space will be evaluated to determine how the hazardous atmosphere developed.

o Measures will be implemented to protect entrants from the hazardous atmosphere before any subsequent entry takes place.

o Re-entry to the confined space will be prohibited until the hazardous atmosphere has been eliminated and the conditions of this Section are met. Before permitting re-entry, the Entry Supervisor will complete a new documented pre-entry assessment.

Any worker entering the space will be provided an opportunity to review the completed pre-entry assessment.

7 PROCEDURES FOR ENTRY OF PERMIT-REQUIRED CONFINED SPACES

7.1 Permit-required Spaces (Business Partner Requirements)

Only qualified business partners may perform the permit-required confined space

activities. The business partner must have a Confined Space Program approved in ISNetworld and a

Confined Space Entry Permit. At a minimum, the business partners permit must contain:

General Information: date, time, space location, purpose for entry, additional permits needed for work, and emergency contacts;



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Evaluation: confined space and permit-required determination, classification and reclassification;

Hazard assessment with control actions; Preparation of the confined space; Atmospheric testing results; and Authorization.

Inform the business partner of the permit-required confined spaces to be entered, the

known hazards associated with the spaces, and any EQT required procedures or precautions applicable to the area near the spaces.

The business partner will be responsible for all permit-required confined space entry activities, including development of a Hazard Assessment, Confined Space Entry Permit or pre-entry assessment, entry supervision, training, satisfaction of entry conditions, isolation of space, and provision of barriers and rescue services.

Business partners must use their own properly calibrated monitoring equipment and train their employees on the manufacturer’s use and requirements of the equipment.

If entry or associated activity will be conducted by personnel of more than one employer (multi-employer worksite), the hazard assessment will address coordination of the operation.

The business partner will be responsible for all equipment related to testing, monitoring, communications, ventilation, lighting, and rescue and emergency.

Business partners must maintain completed or canceled confined space entry permits for a minimum of one year and provide them to EQT upon request.

The business partner shall develop and implement procedures for summoning rescue and emergency services, rescuing entrants from permit spaces, providing necessary emergency services to rescued employees, and preventing unauthorized personnel from attempting a rescue.

Any site alarm or emergencies on location will immediately cancel the permit.

8 TRAINING

8.1 EQT employees who might encounter confined spaces will be trained to ensure familiarity with the EQT Confined Space Program.

Employees shall be trained to evaluate equipment and areas at the site to identify confined spaces prior to entry. Employees will use a documented pre-entry assessment to evaluate and classify the space prior to entry.

Employees must understand the characteristics of the various classifications of a confined space and be able to recognize hazards associated with confined spaces.



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Employees should understand the criteria for determining a confined space and permit-required confined space, the reclassification of a permit-required confined space, use of the Alternate Procedure and requirements for the entry into a confined space. This includes understanding the use and proper completion of the respective forms.

For employees, whose assigned duties will be that of Entry Supervisor during a confined space entry, additional training appropriate to their role is required.

8.2 Business partners must be trained and have a documented confined-space program in accordance

with OSHA 29 CFR 1910.146, OSHA 29 CFR 1926.1204, and EQT’s Confined Space Program.

8.3 Entry Supervisor

Entry Supervisors must understand how to conduct and review confined space evaluations.

Entry Supervisors must understand all requirements for conducting permit-required confined space entry on EQT locations.

Entry Supervisors shall understand the responsibilities associated with authorizing declassification and alternate procedure entries and must know what conditions would prohibit or stop a confined space entry.

8.4 EQT employees shall receive retraining when there is a change in their job assignments, as well

as under the following circumstances:

An entry operation imposes hazards for which an employee has not been trained; There is a change in the EQT Confined Space Program or regulatory requirements; or Inadequacies in an employee's knowledge or deviations from the EQT Confined Space

Program are observed. The retraining shall re-establish employee proficiency and introduce new or revised methods and procedures as necessary.

9 RECORD RETENTION

9.1 All cancelled and completed Confined Space forms shall be maintained for a period of 1 year. 10 ROLES AND RESPONSIBILITIES

10.1 All Personnel

Must familiarize themselves with the safe work practices identified in this Program and

apply these practices to their work site; Must be able to recognize confined spaces and the hazards associated with them; and



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Adhere to all provisions of this Program.

10.2 EQT Supervisors

Assure EQT employees receive and understand the training related to confined spaces; Assure specialty business partner qualifications for permit-required confined space entry

and review the issues of the permit-required confined space with them; Maintain documentation associated with confined spaces; Assure only trained EQT personnel participate in confined space operations and verify

equipment is in working order; Ensure required safety guidelines, including frequency of inspections and testing of the

confined space atmosphere, are followed and documented for EQT operations; and Ensure all involved EQT employees are aware of emergency rescue guidelines.


Survey facilities, identifying confined spaces and labeling of confined spaces; and May perform an annual review of completed confined-space forms to ensure participating

employees are protected from confined space hazards.

11 DEFINITIONS

Acceptable Entry Conditions: those that must exist in a permit-required space to allow entry and ensure individuals involved safely can enter and work within the space.

Entrant: individual approved by the employer to enter a permit space. Authorized Entrants are involved in permit-required confined space entry operations under a permit that only business partners will perform. Confined Space: one large enough and configured to enable a worker to enter and perform assigned tasks; has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins); and are not designed for continuous occupancy.

Hazardous Atmosphere: one with potential to expose workers to the risk of death, incapacitation, impairment to self-rescue (escape unaided from a permit space), injury, or acute illness from one or more of the following causes:

Atmospheric oxygen at a concentration below 19.5 percent or above 23.5 percent; Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL);



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Airborne combustible dust at a concentration that meets or exceeds its LFL. This concentration might be approximated as a condition in which the dust obscures vision at a distance of five feet or less; and

Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published that could result in employee exposure in excess of its dose or permissible exposure limit or other atmospheric condition that poses immediate danger to life or health.

Immediately Dangerous to Life or Health (IDLH): any condition that poses an immediate or delayed threat to life, causes irreversible adverse health effects or interferes with an individual's ability to escape unaided from a permit space. Isolation: process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lock out or tag out of all sources of energy; or blocking or disconnecting all mechanical linkages. Non-permit Confined Space: one that does not contain, or with respect to atmospheric hazards have potential to contain, any hazard capable of causing death or serious physical harm.

Permit System: employer's written procedure for preparing and issuing permits for entry and for returning the permit space to service following termination of entry.

Rescue Service: personnel designated to rescue employees from permit spaces.

An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute

illness due to its health effects, is not covered by this provision.

For air contaminants for which OSHA has not determined a dose or permissible exposure limit, other sources of information such, as Safety Data

Sheets that comply with the Hazard Communication Standard, 1910.1200, published information and internal documents can provide guidance

related to establishing acceptable atmospheric conditions.

NOTE

NOTE


Title Contractor and Subcontractor Safety

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1 PURPOSE AND SCOPE

1.1 The purpose of the Contractor and Subcontractor Safety program is to define procedures and precautions that must be followed for the safety qualification and safe management of contractors and subcontractors at EQT locations.

1.2 The scope of this program applies to all work performed by contractors, as well as their

subcontractors, throughout EQT’s operations and/or locations. Contractors are entities or individuals who perform contractual services, including but not limited to: the areas of drilling, completions, construction, maintenance and operation of EQT facilities and field operations. Subcontractors include companies that perform work (e.g., contract service providers, third-party providers, workforce supplement) on an EQT locations that are under the contractual agreement of an EQT prime or general contractor, not EQT.

1.3 EQT field operations include non-EQT property when EQT has contracted to acquire seismic

data through use of seismic blasting, use of vibroseis trucks or hauling of EQT natural gas liquids.

1.4 The term contractor is used interchangeably with the term business partner throughout EQT’s

EHS Programs.


2.1 Contractors and their subcontractors must follow all EQT Safety Policies and Programs. They also must complete EQT EHS Safety Training before working at an EQT field location and develop their own site-specific hazard assessment prior to entering any EQT location. Violation of EQT’s Safety Policies and Programs and/or EQT’s contractor safety agreement language could result in corrective actions, including termination.

2.2 Contractors and subcontractors also must follow all federal, state and local statutory and

regulatory requirements, as well as their company safety policies. 2.3 Contractors will develop and implement safety policies and procedures for their employees and

subcontractors. The policies and procedures must establish the Contractor’s method of compliance with all applicable regulations, laws, industry standards, and EQT requirements. All Contractor policies and procedures must be available for EQT review upon request.

2.4 Contractors and subcontractors shall conduct all necessary inquiries and inspections of their

worksites and relevant premises as often as needed, but not less than daily, to ascertain whether any conditions or hazards have been created by work performed by them or others that could pose any hazards.



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2.5 Contractors and subcontractors must immediately notify EQT Corporate EHS Department if

contacted by a government agency. 2.6 Contractors and subcontractors must have verified First Aid and Emergency Action Plan

programs in ISNetworld that can be implemented on location when work is being performed. 2.7 As defined and required by OSHA, all contractors must provide a Competent Person who

possesses the ability to recognize hazards on the job site and also has the authority to correct those hazards. Each contractor is required to designate, at every work location, a Competent Person familiar with the site-specific hazards. If subcontractors are the only entity at a given location they must provide a designated competent person.

2.8 Contractors and subcontractors must document and be able to verify via a card, that their

employees received EQT’s Annual Contractor Safety Training. 2.9 Prior to beginning work, the Contractor’s Competent Person or designee must conduct and

document on a daily basis a hazard assessment, in accordance with the EQT Hazard Assessment and Control program, when two or more personnel of a contractor or subcontractor are present. Completed hazard assessments must be kept on site.

2.10 The EQT Corporate EHS Department will perform formal safety auditing and inspections of contractors. Serious or repeat violations observed during auditing and inspections could affect a contractor’s qualification status.

2.11 An auditor/inspector will communicate issues of non-compliance to the Contractor and EQT. Audit results will be documented and sent to the Contractor. Contractors are required to certify completion of corrective actions.

2.12 Contractors are required to communicate hazards, as well as changes in scope of work and

procedures, to their employees, subcontractors and EQT. 2.13 Contractors and subcontractors must notify EQT immediately of any injuries and incidents by

calling EQT’s Emergency Dispatch Center (1-833-990-1534) and assist with related investigations, as well as perform their own. Contractors are required to provide EQT with a summary incident report within 24 hours and a completed incident investigation within seven days of the incident. They also could be required to meet and review the results of incident investigations with the EQT Corporate EHS Department and business unit senior management.



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3 EQUIPMENT REQUIREMENTS

3.1 Contractor and subcontractor equipment used at EQT locations must be inspected prior to use, used for its intended purpose, and maintained according to the manufacturer’s recommendations.

4 CONTRACTOR QUALIFICATION PROCEDURE

4.1 All contractors, as defined in Section 1.2 of this program, must meet EQT’s safety qualification

requirements. 4.2 When a contractor need is identified, an EQT representative will review the scope of work to

determine if the contractor requires safety qualification based on this program. Contractors requiring safety qualification are to submit required information and documentation to a third-party provider (ISNetworld) for evaluation on behalf of EQT.

• Contractors are required to submit and maintain verified safety programs and information in ISNetworld in accordance with their EQT statement of work. Contractors working with trees (i.e., trimming, felling and clearing) as defined by the EQT statement of work, must have a verified logging program in ISNetworld and meet EQT’s defined project-specific requirements.

• Contractors working with live electrical systems (more than 50 volts) must have a verified NFPA 70E program in ISNetworld and meet EQT’s project-specific requirements.

• Contractors working with asbestos containing material (ACM) must have a verified asbestos management/maintenance program in ISNetworld and meet EQT’s project-specific requirements.

• Contractors must develop and implement a drug and alcohol program and provide EQT with test results upon request.

4.3 Contractors who receive a total score of less than 70 percent will be classified as a “Non-

qualified Contractor.” Any contractor classified as a “Non-qualified Contractor” will not be permitted to perform work for EQT.

• Contractors failing to maintain in ISNetworld verified safety programs aligned with their

EQT statement of work could be designated by the EQT Corporate EHS Department as “non-qualified” for specific work activities.

• A non-qualified contractor may be granted a variance to continue work activities at the approval of the EQT Vice President of EHS.

• Depending on the circumstances, additional safety controls could be required of a non-qualified contractor for whom a variance is granted.



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4.4 Contractors and subcontractors must document and be able to verify via a card, that their

employees received EQT’s Annual Contractor Safety Training.

5 SUBCONTRACTOR QUALIFICATION PROCEDURE

5.1 All prime or general contractors are required to pre-qualify their subcontractors prior to having them perform work on EQT locations. One of the following methods must be used for subcontractor safety pre-qualification:

• Subcontractors submit information and documentation to a third-party provider

(ISNetworld) for evaluation, allowing the general contractor to view the subcontractor’s overall company grade.

• General contractor performs subcontractor pre-qualification and ongoing safety performance monitoring using an alternate procedure. Alternate procedures must be submitted to EQT for approval.

a. Depending on the circumstances, additional safety controls could be required if an alternate procedure is approved.

b. Subcontractors performing work with trees (e.g., trimming, felling, clearing, bucking) are not eligible for pre-qualification through alternate procedures.

4.5 All prime or general contractors, whether using ISNetworld or an approved alternate procedure

are expected to use subcontractors that have achieved a minimum grade of “C” or above or equivalent. Failure to pre-qualify a subcontractor may result in an impact to the general contractor’s qualified status.

5 TRAINING

5.1 EQT’s Contractor Safety Training must be completed and training renewed annually before

contractor and subcontractor employees are authorized to work on an EQT field location. 5.2 Contractors must ensure their employees and subcontractors have appropriate training relevant to

their job tasks. Contractors shall ensure their employees or subcontractors are competent and trained according to applicable regulations.

5.3 All personnel will be trained in the requirements of this program.



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6.1 EQT Responsible Person

• Ensures only contractors meeting the EQT contractor safety qualification requirements of

this program are permitted to work for EQT.

6.2 EQT Procurement Department

• Ensures contractors safety qualified in accordance with this program are issued a contract or agreement.


• Reviews, evaluates and communicates safety qualification information required by this program;

• Assists the EQT Responsible Person as needed, including investigating contractor-related incidents; and

• Develops and implements an audit/inspection program of contractors.

6.4 Prime/General Contractors

• Incorporate safety into their subcontractor selection process; • Ensure only subcontractors that have been properly qualified through an approved safety

qualification process are awarded work on EQT locations; • Develop and implement subcontractor safety qualification process (as approved by EQT)

if ISNetworld verification is not used; • Ensure subcontractors follow the internal company requirements of the general

contractor.


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1 PURPOSE AND SCOPE

1.1 The purpose of this Crane Operations Program is to define procedures for controlling the hazards associated with crane operations on EQT locations.

2 CRANE OPERATIONS

2.1 Business partners must have a Crane program (verified in ISNetworld) available to EQT upon request.

2.2 Accreditation from the National Commission for the Certification of Crane Operators (NCCCO)

is required for OSHA compliant operation of mobile telescopic cranes and non-telescoping crawler cranes above one-ton capacity.

2.3 All crane operations must follow federal and appropriate state requirements. For example, a

Crane Operator’s License is required in Pennsylvania when operating a mobile crane with a capacity above 15 tons. In West Virginia, all crane operators must obtain an NCCCO designation if the crane has a maximum rated capacity above 2,000 pounds, as well as a state license. Ohio does not have state-specific licensing requirements and adopts certification standards under 29 CFR 1926 Subpart CC.

2.4 Only certified (i.e., licensed) persons may operate the equipment. Documentation of training for

personnel must be available upon request. 2.5 Cranes must be inspected by a certified inspector in accordance with all federal, state and local

requirements, including 29 CFR 1926 Subpart CC. Documentation of inspections must be available prior to the lift.

2.6 Lifting of personnel via crane is not allowed at EQT locations. 2.7 Prior to the lift at each new work location, the crane operator, signal person (if necessary) and an

EQT representative must attend a meeting to ensure requirements of this Program will be followed.

2.8 The load-line hoist drum must have a system or device on the power train, other than the hoist

brake, which regulates the lowering rate of speed (controlled load lowering). Free fall is prohibited.

2.9 The crane must be level within one percent of grade. 2.10 Cranes with variable angle booms must be equipped with a boom-angle indicator readily visible

to the operator.



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2.11 Cranes with telescoping booms must be equipped with a device to indicate to the operator the boom’s extended length.

2.12 In the event of a two-blocking situation, a device or system that deactivates the hoisting action

before damage occurs must be used. 2.13 The crane must be equipped with a load line capable of lifting seven times the maximum

intended load weight. 2.14 Pre-lift plans that show boom angle, maximum intended load and radius to lift must be prepared

for all critical lifts. 2.15 Never stand under any lift. If guiding is required, ensure a tag line is used for the operation. 2.16 Manufacturer’s restrictions for operating in wind speeds below 30 mph shall be followed. 2.17 For wind speeds of 30 mph or greater, crane operations shall cease.

3 CRITICAL LIFTS

3.1 Critical lifts are those that exceed 75 percent of the rated capacity of the crane/derrick or those

that require the use of more than one crane/derrick. Critical lifts are also those that have been deemed as critical by EQT. These lifts could include:

• Those within 20 feet of a power line under 350kV or within 50 feet of a power line over 350kV;

• Those that require modification or design of lifting equipment or special rigging configurations;

• Lifts where the load crosses over active or process equipment or pipelines; and • Blind lifts.

3.2 All critical lifts must be planned, permitted and made by personnel in accordance with applicable

federal and state regulations. Critical Lifts also must be documented on the Hazard Assessment form.

3.3 All critical lifts require the completion of a Critical Lift Permit. A Pre-critical Lift Checklist must

be completed to verify the condition and requirements set forth in the permit. 3.4 Critical lifts must have a qualified rigger authorizing the rigging process prior to the lift being

completed. 3.5 Spotters shall be designated for the duration of the critical lift.



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3.6 Radios may be used for heavy/critical lifts. These radios must use designated channels determined in the pre-lift meeting. The designated channels are walkie-talkie capable and good for a range of one mile. The radios must be set on frequencies that no other radios are using.

3.7 When wind speeds reach 15 miles per hour critical lifts are to be postponed, unless the

competent person on site establishes an alternative standard in accordance with the equipment manufacturer’s guidance.

4 RIGGING EQUIPMENT

4.1 All rigging equipment must be designed for overhead lifting and marked with identification tags that state the size, grade, rated capacity, and manufacturer.

4.2 Rigging equipment must be inspected prior to each use and as necessary during its use. Defective

rigging equipment must be removed from service. 4.3 Rigging equipment must not be loaded in excess of its recommended safe working load. Sling

angles must be taken into consideration.

4.4 All new rigging will be inspected prior to use to verify compliance. 4.5 Padding or blocking shall be placed between rigging and the load to prevent damage from sharp

edges.

5 ALLOY STEEL CHAINS

5.1 Welded alloy steel chains must have affixed, permanent identification that states size, grade, rated capacity, and manufacturer.

5.2 Visual inspections shall be completed prior to use. Periodic inspections shall be complete,

inspecting each link and components individually. 5.3 Each link will be inspected for twists; excessive wear at bearing points; stretch; and cracks, nicks

and other deformities.

5.4 Job- or shop-made hooks and links, as well as makeshift fasteners formed from bolts, rods or other such attachments, shall not be used.

5.5 Any chain found defective must be removed from service.

6 WIRE ROPE



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6.1 Wire rope must have affixed, permanent identification that states the diameter of size, rated capacity and manufacturer.

6.2 Visual inspections shall be completed prior to use. Periodic inspections shall be complete,

inspecting entire length and components individually. 6.3 Wire rope attachments will not be secured with knots. 6.4 Wire rope will be inspected for the following:

• Cuts and kinking; • Birdcaging (separation of rope lays); • Excessive wear, corrosion or dryness; • Evidence of shock loading; • Heat damage from any source; • One or more broken wires in the end attachment(s); and • To ensure the number of visible broken wires in any 8 inch-diameter does not exceed 10

percent of the total number of wires.

7 MANILA AND NYLON ROPE

7.1 Manila and nylon ropes are not to be used for hoisting or overhead lifting.

8 SYNTHETIC SLINGS

8.1 Synthetic slings must have affixed, permanent identification that states the type of synthetic material, rated capacity and manufacturer.

8.2 Visual inspections shall be completed prior to use. Periodic inspections shall be completed

inspecting entire length and components individually. 8.3 Slings will not be shortened with knots. 8.4 Synthetic slings will be removed from service for the following defects:

• Cuts, tears or punctures; worn, frayed or broken stitching; • Heat damage from any source; and • Missing or unreadable load rating tag.

8.5 Synthetic slings will be stored in a dry place, unexposed to direct sunlight.



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9 TRAINING 9.1 EQT Employees will receive training on the Crane Operations Program.

9.2 EQT Employees’ training will include the requirements of 29 CFR 1926 Subpart CC applicable to

their respective roles (e.g., signal persons, operators and operators-in-training).

10 EQT RECORD RETENTION 10.1 Monthly and periodic hoist alloy chain/hook inspection forms shall be maintained. 10.2 Sling repair and test records shall be maintained for the life of the sling. 10.3 Crane and Hoist inspections and certifications shall be maintained for five years. 11 ROLES AND RESPONSIBILITIES


• Implement this Program. Senior management will enforce actions related to violations of any requirements; and

• Review of a Critical Lift Permit with crane operator prior to making a critical lift.

11.2 All Personnel

• Adhere to this Program during all work operations.

11.3 Crane Operator

• Inspects all rigging devices with rigger before use and adheres to all manufacturer’s use recommendations and capacity limitations;

• Practice sound operating procedures according to all accredited trade and professional organizations (e.g., API, SAE, ANSI, ASME) regarding crane rigging and lifting work;

• Maintains proof of qualification, including the size and/or type of equipment certified to operate and the date/expiration date of qualification. Copies of this certification must be available prior to lift; and

• Assists in the joint completion and planning of all critical lifts, including the completion of a Pre-critical Lift Checklist and Critical Lift Permit.

11.4 Qualified Rigger

• Assists in site preparation; • Inspects all rigging devices with crane operator and adheres to all manufacture’s use

recommendations and capacity limitations; and • Meets the criteria outlined in 1926 Subpart CC.



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11.5 Competent Person and Signal Person

• Perform all duties as described in 1926 Subpart CC.

11.6 Corporate EHS Department

• Assists in critical lifts; • Inspects crane inspection program; and • Inspects lifting equipment inspection records.

11.7 Crane Company

• Ensures the crane is inspected completely per the manufacturer’s specifications listed in the service manual and meets all applicable federal, state and local regulations;

• Maintains a record of all prior inspections, tests, repairs, maintenance, modifications, and deficiencies. A crane company will make these records available for review upon request by EQT; and

• Maintains records of the identification, capability, training and competence of all crane operators and site support personnel.

12 DEFINITIONS

Boom (equipment other than tower crane): an inclined spar, strut or other long structural component that supports the upper hoisting tackle on a crane or derrick. Competent Person: one capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Designated Channel: a line of communication assigned by the employer that controls the communication system to only one signal person and crane/derrick or to a coordinated group of cranes/derricks/signal persons. Free Fall (of the load line): only the brake is used to regulate the descent of the load line; the drive mechanism is not used to drive down the load faster or retard its lowering.

Hoist: a mechanical device for lifting and lowering loads by winding a line onto or off a drum. Mobile Crane: a lifting device incorporating a cable suspended latticed boom or hydraulic telescopic boom designed to be moved between operating locations by transport over the road.

Rated Capacity: the maximum working load permitted by the manufacturer under specified working conditions. Such working conditions typically include a specific combination of factors, such as equipment configuration, radii, boom length, and other parameters of use.


Title Electrical Safety, Grounding and Bonding

Number 07 Owner VP, EHS

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1 PURPOSE AND SCOPE

1.1 The purpose of the Electrical Safety Program is relative to the hazards arising from the use of electricity. This Program addresses operations that involve working with or near electricity, including grounding and bonding, electrical systems, and energized equipment, on all EQT locations.

1.2 All personnel exposed to potential contact with an electrical system must conduct work in accordance with this Program. Only Qualified Persons, who are authorized, are allowed to work on electrical equipment, which includes troubleshooting and repair.

2 WORK PRACTICES

2.1 Work on electrical equipment greater than 50 volts must be performed only by Qualified

Persons.

2.2 Qualified Electrical Contractors working on 50 volts or greater must have verified and compliant NFPA 70E and Electrical Safety Awareness programs in ISNetworld.

2.3 Personnel who perform work on electrical equipment less than 50 Volts must be trained on the

contents of this program and competent to work on electrical equipment. Competent Persons must be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools.

2.4 When any worker is exposed to contact with parts of fixed electric equipment or circuits that

have been de-energized, the circuits energizing the parts must be locked out/tagged out (LOTO) or locked and tagged.

2.5 All exposed circuits or live parts operating at greater than 50 Volts must be enclosed or guarded to prevent inadvertent contact.

2.6 In locations where electric equipment is likely to be exposed to physical damage, enclosures or guards must be arranged to prevent such damage.

2.7 Electric equipment may not be used unless the following markings have been placed on the

equipment:

• The manufacturer's name, trademark, or other descriptive marking by which the organization responsible for the product may be identified; and

• Other markings giving voltage, current, wattage, or other ratings as necessary.




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2.8 Conductive materials and equipment that are in contact with any part of a person’s body must be prevented from contacting exposed energized conductors or circuit parts.

2.9 Hands, shoes, and clothing should be dry when any energized electrical equipment is handled. 2.10 When opening and closing circuit breakers and switches, personnel must stand to the side of the

equipment and use a non-conductive object to throw the switch. All switch handles must be made of non-conductive material.

2.11 Personnel should avoid being near switch boxes, pumping units, electric motors or other

electrically operated equipment during an electrical storm.

2.12 Over-current protection of circuits and conductors must not be modified, even on a temporary basis, beyond the installation design (load requirements).

2.13 Each disconnecting means for equipment or circuits must be legibly marked to indicate the

equipment or circuit to which it is connected. In addition, ON and OFF shall be clearly distinguishable.

2.14 Electrical equipment must be inspected prior to use. Defective appliances, electrical equipment,

etc., must be repaired by a Qualified Person or taken out of service, tagged, and reported to a Supervisor.

2.15 Extension cords must be rated if used in highly conductive work locations such as those inundated with water or other conductive liquids, or in job locations where personnel are likely to contact water or conductive liquids. Personnel are prohibited from using extension cords for raising or lowering equipment; fastening cords with staples; hanging them in such a fashion that could damage the outer jacket or insulation; and connecting a series of extension cords or "daisy chaining".

2.16 The use of metal ladders is prohibited in areas where the ladder or the person using the ladder could come in contact with energized parts of equipment, fixtures, or circuit conductors.

2.17 When working near exposed energized conductors or circuit parts, personnel must use insulated

tools or handling equipment if the tools or handling equipment might make contact with such conductors or parts.

2.18 An Energized Electrical Work Permit, per NFPA 70E, is required when personnel are working

within the restricted approach boundary or when personnel interact with equipment with an increased likelihood of injury from an exposure to an arc flash hazard. Exemptions must meet the criteria outlined in NFPA 70E.




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3 PERSONAL PROTECTIVE EQUIPMENT

3.1 PPE selection should be based on a completed hazard assessment. The assessment shall

determine PPE required for electrical work tasks based on the electrical energy and hazards present.

3.2 Personnel working in areas where there are potential electrical hazards must use:

• Electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed; and

• Tools, shields, barriers, and other appropriate equipment as needed. 3.3 Protective equipment must be maintained in a safe, reliable condition and periodically inspected

or tested as per manufacturer specifications.

4 WARNINGS

4.1 The following alerting techniques must be used to warn and protect personnel from hazards, which could cause injury due to electric shock, burns, or failure of electric equipment parts:

• Safety signs, safety symbols, or accident prevention tags; • Barricades in conjunction with safety signs where it is necessary to prevent or limit

access to work areas exposing personnel to un-insulated energized conductors or circuit parts; and

• Attendants stationed to warn personnel if signs and barricades do not provide sufficient warning.

5 TRAINING AND CERTIFICATION PROCESS – EQT ONLY

5.1 EQT Employees must complete the EQT Electrical Training and Certification Process prior to

working on electrical equipment greater than 50 volts. The process includes:

• Taking the NFPA 70E training course; • Training on equipment and PPE for the voltages that will be encountered (e.g., voltage

meter, insulated gloves, arc rated clothing); and • Completing on-the-job training (OJT) verified by an evaluator and supervisor. (See

Appendix A, Electrical OJT Form)

5.2 Once the employee finishes the certification process and demonstrates competency related to applicable electrical tasks, the Corporate EHS Department will verify completion and add the employee to the list of electrically qualified employees for all tasks identified on the OJT Form.




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6 EQUIPMENT GROUNDING AND BONDING

6.1 This section focuses on the electrical grounding requirements of equipment to promote

dissipation of current to prevent electrical shock, lightning protection, and ground fault interruption. (Bonding and grounding requirements for fluid transfers can be found in the EQT Fluid Transfer Program.)

6.2 Measuring the resistance to ground at the grounding rod is important. EQT locations shall attempt to achieve a ground resistance of 25 ohms or less.

• If a single grounding rod does not have a resistance to ground of 25 ohms or less, it can be augmented by an additional ground rod.

• Where multiple rods are installed, they should be separated by at least six feet. • Grounding rods are to be kept free from non-conductive coatings, such as paint or

enamel; and, as practical, embedded below permanent moisture level. 6.3 General grounding installation requirements

• At a minimum no less than 6 gauge, insulated or non‐insulated copper wire must be used;

do not use any other material besides copper. • If the permanent production facility is in place, bond equipment into the production

equipment. • If installation of additional ground rods is required, use at least three-quarter inch by

eight feet copper ground rods. The number of rods required will vary based on soil quality, soil moisture content and the amount of equipment to be grounded.

o A One Call is required and Excavation safety requirements are to be met for driving ground rods. Using a certified electrician, electrical contractor or properly trained personnel is required. Protection caps (rebar caps) should be placed on the ground rods to protect personnel from impalement hazards.

• When wire runs do not vary, consider purchasing pre-made insulated cables with clamps on each end to be re-used for each location or operation.

• Corrosion adds resistance. Ensure the grounding system is free of excessive rust and the surface where equipment is grounded is not corroded. Use an oxide inhibitor, such as CUAL Gel, to prevent corrosion of mechanical grounding connections.

• Paint is an insulator. Scratch off paint prior to installing grounding lugs or bolts.

o Use oxide inhibitor to prevent corrosion of the scratched surface. When equipment is sent for re‐coating, ensure the lugs either are protected or removed and then reinstalled.




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6.4 The owner of the equipment must perform testing and verification of the grounding.

6.5 Portable Electrical Equipment (e.g., light towers, electric motors, generators, heaters, electrical panels)

• All portable generators, except vehicle-mounted welding generators, must be grounded unless the following conditions are met:

o The generator supplies only equipment mounted on the generator and/or cord and

plug-connected equipment through receptacles mounted on the generator; and o The noncurrent carrying metal parts of equipment (such as the fuel tank, the

internal combustion engine, and the generators housing) are bonded to the generator frame, and the equipment grounding conductor terminals are bonded to the generator frame;

o Thus, rather than connect to a grounding electrode system, such as a driven ground rod, the generators frame replaces the grounding electrode.

• Buildings containing electrical equipment, need to be grounded by an equipment-grounding conductor or bonded to grounded equipment.

o If the portable generating equipment is providing electric power to a building or structure, it must be connected to a grounding electrode system.

• If bonding conductors are used to assure electrical continuity, ensure they have the capacity to conduct fault current that might be imposed.

• If equipment (e.g., lights, tools, heaters) being powered by the generator is bonded to the generator through the grounding conductor in the cord or connection, it does not need to have additional grounding.

• Grounding is not required for vehicle-mounted welding generators, provided adherence to all the following conditions:

o The generator is mounted to a truck or trailer; o Auxiliary power is taken from receptacles on the generator using a cord and plug

and the receptacles have a grounding pin; and o The frame of the generator is bonded or electrically connected to the truck or

trailer frame.

Portable electric arc welders are not required to be grounded, though take special care when placing the negative lead of the welder. Stray current can travel through bonded

metal equipment, creating danger if a spark is released in a hazardous atmosphere.

6.6 Other Equipment

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To prevent accumulation of a static charge, equipment must be grounded. Equipment would include frac tanks, half rounds, rig substructures, derricks and masts.

• For wireline operations involving explosives, one electrical ground circuit is needed between the wellhead, service unit, rig structure, crane, gun loading trailer, and anything else with which the wireline may come in contact with prior to handling explosives.

• One ground lead must be connected directly to the well where operations are to be performed (do not assume flowback iron is properly grounded).

• For zipper operations, wireline companies can either move primary ground prior to each run or connect multiple legs of the same circuit to each well.

• Verify grounds are in place prior to every run in the hole.

7 RECORD RETENTION – EQT Only

7.1 Electrical safety training records and qualified electrical worker qualifications shall be retained for the duration of employment.


8.1 EQT Supervisors

• Ensure requirements of this Program are followed, understanding the scope and hazards associated with the work they are approving;

• Verify the need to perform electrical work; • Ensure reasonable efforts have been made to perform the work in a de-energized state; • Authorize the performance of hot electrical work (may sign permit); • Ensure business installing, using or maintaining electrical equipment/systems adhere to

appropriate electrical safety procedures; • Ensure availability, maintenance, calibration, testing, and use of applicable PPE; and • Ensure all employees have current training and the skills necessary to perform the work.


• Facilitates development, review and revision of this Program; • Ensures the quality content of training; • Maintains list of qualified employees; • Defines an audit process; and • Assists in training and management.

8.3 EQT Employees and Business Partners

• Adhere to the requirements of this Program;




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• Complete successfully required training; and • Report any incidents related to electrical work or unsafe electrical conditions. • Adhere to the electrical safety requirements as specified in OSHA 29 CFR Subpart K and

Subpart S. • Comply with all state-specific electrician license and certification requirements.

8.4 Electrical Qualified Person(s)

• Adhere to the requirements of this Program; • Work on electrical systems of 50 Volt or greater; • Complete successfully required training and maintain qualifications; • Communicate identified safety hazards; • Conduct pre-job hazard assessment or RHA; • Maintain equipment insulation and enclosure integrity; • Use the correct tools and equipment for the job; • Use and maintain appropriate PPE; and • Report any incidents related to electrical work.

8.5 Competent Person(s)

• Adhere to the requirements of this Program; • Complete successfully required training; • Use and maintain appropriate PPE and tools; • Ensure they do not work on electrical systems greater than 50 Volts; and • Report any incidents related to electrical work.

9 DEFINITIONS

Competent Person: One who has knowledge, training or experience to work on electrical systems less than 50 Volts. Ground-fault Circuit Interrupter (GFCI): a device intended for the protection of personnel that functions to de-energize a circuit or portion of it within an established period of time when current-to -ground exceeds values established for a Class A device.

Qualified Person: one who by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience, successfully demonstrates the ability to resolve problems relating to the subject matter, the work or the project. Only qualified persons are allowed to work on electrical systems greater than 50 Volts.


Title Emergency Planning and Response

Number 08

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1 PURPOSE AND SCOPE 1.1 The purpose of this Emergency Planning and Response Program is to define procedures and

precautions that must be followed for the prevention of, and response to, emergencies at EQT locations.


2.1 All EQT locations must have a site-specific Emergency Action Plan containing actions related to possible medical emergencies, fires, explosions, and spills based on Federal, State, and Local requirements. The emergency action plan must cover:

Emergency escape procedures and routes; Procedures for essential employees to manage critical operations before evacuation; Rescue and medical duties of employees as applicable; Procedures to account for all employees after evacuation; Means to report fires and other emergencies; and Contacts for additional information.

2.2 Everyone working at EQT locations must be knowledgeable of evacuation procedures, muster points, alarms, emergency shutdown devices (ESD), emergency contacts, and Safety Data Sheets (SDS). All Incidents, Emergencies, Security Issues or Spills must be reported immediately to the EQT Emergency Dispatch Center at 1.883.990.1534.

2.3 All EQT locations must have an emergency notification system meeting the requirements

outlined in 29 CFR 1910.165(b). Additionally, all outdoor and remote locations must have a plan in place to warn employees, business partners and visitors of necessary emergency action and allow for proper reaction time for a safe evacuation.

2.4 All EQT locations must evaluate potential hazards, and the appropriate emergency response

times for first-responder agencies nearest the work location. If response times are inadequate for the location, alternate plans must be made to provide lifesaving response.

2.5 Emergency Action Plans must include a section outlining state and federal notification processes to ensure proper agencies receive communication about the various events that surpass the reporting thresholds of the specified types of events outlined in the regulations.

3 MEANS OF EGRESS



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3.1 Exit Routes must:

Be free from explosive or highly flammable materials; Arranged to ensure employees do not have to travel toward any high hazard areas unless

the path of travel is shielded effectively; Provide stairs, ladders, or a ramp where the exit route is not level; and Ensure safeguards, such as alarms, fire doors and exit lighting are in proper working

order at all times.

3.2 Exit Marking and Lighting For buildings, all exits and access to exits must be marked by a readily visible sign. Any door or passageway that is not an exit but could be mistaken for an exit must be

identified or marked as “NOT AN EXIT.” Every exit sign must be distinctive in color and suitably illuminated by a reliable light

source. Every exit sign must have the word “EXIT” in plainly legible letters not less than six

inches high with the principal strokes of the letters in the word "EXIT" not less than three-fourths of an inch wide.

3.3 Aisles

All aisles must be free of obstructions. The minimum width of any exit access must be a minimum of 28 inches. The ceiling of an exit route must be at least 7’6” high.

o Any projection from the ceiling or any other overhead obstruction must not

extend to less than 6’8” from the floor.

4 SPILL MANAGEMENT

4.1 Incidental spills must be handled by employees or business partners adequately trained in the means to protect themselves and mitigate the spill based upon its hazards.

4.2 Each EQT location must determine how it will handle large (non-incidental) spills that exceed

the training requirements of personnel on site. Spill response should be coordinated with the EQT Corporate EHS Department.


5.1 All EQT locations must be evaluated regarding the need for life-saving equipment.

Locations must evaluate the hazards and be equipped with the required life-saving equipment, including fire extinguishers and first-aid kits.



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6 PROCEDURE

6.1 All required EQT locations will maintain a location-specific Emergency Action Plan. It is the

responsibilities of the location’s authorized operating entity — whether EQT or a business partner — to keep the Emergency Action Plan current with changing operations and conditions. Such procedures will be revised, as appropriate, particularly after a response to an incident or emergency.

6.2 Where practical, the authorized operating entity — whether EQT or a business partner — will

periodically test the procedures contained within the established emergency preparedness and response plans. The frequency of these tests will be determined based on the risks associated with the operations of the locations.

6.3 EQT will review and update annually all required EQT Emergency Action Plans.

7 TRAINING

7.1 All personnel shall be trained on the applicable Emergency Action Plan and role. 7.2 Retraining will be conducted when there is a change in the Emergency Action Plan or an

employee’s role related to the Plan is changed.


8.1 EQT Supervisors

Create, maintain, disseminate, and as appropriate, update procedures within emergency preparedness and response plans for all personnel working on or visiting the location.

8.2 EQT Employees/Business Partners

Adhere to this Program during all work activities.


Assesses location’s emergency preparedness and response plans to ensure they are current and meet the necessary requirements;

Supports location’s regulatory requirements associated with emergency preparedness and response plans; and

Ensures qualified emergency preparedness and response specialists are involved in the initial development and maintenance of plans for all EQT locations.



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9 DEFINITIONS

Exit route: a continuous and unobstructed path from any point within a workplace to a place of safety (including refuge areas). An exit route consists of three parts: 1) Access; 2) Exit and 3) Discharge. An exit route includes all vertical and horizontal areas along the route. Incidental Spill: a release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the workers cleaning it, nor does it have the potential to become an emergency.


Title Ergonomics Program

Number 09

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1 PURPOSE & SCOPE

1.1 The purpose of this Ergonomics Program is to define procedures and precautions that must be followed during all work activities that have the potential for personnel to develop ergonomic disorders.

2 OVERVIEW

2.1 High-risk job activities with the potential for ergonomic risks include; lifting heavy items, bending, reaching, pushing and pulling loads, awkward body postures, overextending, or repetitively performing tasks, including those performed in an office environment.

2.2 Through risk identification, adoption of safe work practices and encouraging personnel to report

early signs and symptoms of Musculoskeletal Disorders (MSD) can help reduce chronic ergonomic injuries.

3 ERGONOMIC RISK ASSESSMENT AND IDENTIFICATION – EQT ONLY

3.1 An assessment of required physical demands and essential functions will be completed for all EQT field jobs when the EQT EHS Department determine that there is a potential risk of MSD or chronic ergonomic injuries. Work location design should consider ergonomics and the end user prior to implementation.

3.2 Documented risk assessments should include:

Job title and description; Potential high-risk ergonomic activities; Current controls for mitigating risks; and Corrective action plan.

3.3 Safe lifting practices should be followed and include:

Plan the job in advance and use mechanical devices whenever possible and practical; Size up the load before trying to lift it. Test the weight by lifting at one of the corners. Lifting should not exceed 50 pounds. Get help or use a device if load is too heavy; Ensure individuals are in satisfactory physical condition to handle the weight they will

lift, carry, push or pull; lifting with leg muscles – not with back muscles; Start a lift as close to the load as possible; and Do not twist or turn the body once a lift is made. If you must turn the body, do so by

changing foot positions. Keep the load steady and close to the body. Do not carry a load above your head or on your side.



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3.4 Personnel should avoid awkward positions, such as:

Working with your hands over your head for more than 2 hours/day; Working with your back bent forward more than 30 degrees for more than 2 hours/day; Working with your neck bent more than 30 degrees for more than 2 hours/day; Twisting; Excessive reaching (over 26 inches); Working with your wrist bent more than 30 degrees when combined with repetitive

motions or high hand forces; or Kneeling or squatting more than 2 hours/day.

3.5 Personnel can avoid repetitive motion injuries by changing or rotating job tasks, stretching or

taking periodic breaks.

4 COMMUNICATION

4.1 Communication is paramount, particularly when identifying risks associated with early MSD stressors. Personnel are expected to communicate ergonomic concerns to their supervisors. Supervisors are expected to communicate concerns to the EQT Corporate EHS Department. By communicating early identified symptoms of potentially work-related MSD, a corrective action plan can be developed to implement controls to reduce ergonomic stressors.

4.2 The results from the ergonomic risk assessments and corrective action plans will be

communicated to affected personnel. Corrective actions can be evaluated for continued effectiveness in reducing ergonomic stressors.

5 TRAINING

5.1 All EQT employees covered under this Program must receive ergonomics training, which

includes:

Health hazards associated with ergonomic risks; Signs and symptoms of common types of MSD and ergonomic injuries; and Communication and reporting procedures related to potential ergonomic injuries.

6 EQT RECORD RETENTION

6.1 The EQT EHS Department will keep training records on file for the duration of employment. Records will include a roster of attendees, dates and a summary of the content and the



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instructor’s name. Employee medical records generated from activities associated with this Program will be maintained for the period of employment plus 30 years.


7.1 EQT Supervisors

Implement this Program; Address communications from employees regarding ergonomic concerns, as well as

related corrective actions; and Senior management will enforce actions related to violations of requirements.


Adhere to all provisions of this Program, including communicating potential ergonomic risks or symptoms of potential work-related MSD.

Business partners must maintain procedures and precautions during all work activities that have the potential for workers to develop ergonomic and musculoskeletal disorders (MSD).


Assists supervisors in identifying, evaluating and reporting ergonomic incidents, as well as developing and implementing corrective action plan;

Develop and administer training; Perform review of this Program for ongoing effectiveness; and Perform Program audits.

8 DEFINITIONS

Ergonomics: the science of designing a job fit to the worker rather than the worker to the job. Ergonomic Incident: one that shows early or late signs of a potential work-related MSD. Musculoskeletal Disorders (MSD): condition related to certain tasks that can affect the muscles, nerves, blood vessels, and ligaments/tendons. Lifting heavy items, bending, reaching over head, pushing and pulling loads, awkward body postures, overextending, or performing tasks repetitively are high-risk job activities that have potential to cause MSD if not monitored.


Title EQT Lockout Tagout


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1 PURPOSE AND SCOPE

This Program Sections 1-12 apply to EQT employees and designees. Program Section 13 applies to business partners that are not designees.

1.1 This Lockout Tagout (LOTO) Program specifically outlines the purpose, responsibilities,

authorization, rules and techniques to be used by authorized personnel to guard against the unexpected energizing or start-up of machines or equipment, or release of stored energy that could cause injury to workers.

1.2 This Program requires authorized personnel to lock out equipment or piping systems to isolate

them from all potential hazardous energy sources prior to service and/or maintenance activities where the unexpected energizing, start-up or release of stored energy could cause injury.

2 EXCEPTIONS 2.1 This Program does not apply to:

• Minor tool changes, adjustments and other minor servicing activities that take place during

normal production operations, if they are routine, repetitive, and integral to the use of the equipment for production, provided the work is being performed using alternative measures that provide effective protection.

• Troubleshooting or diagnostic work where the machine or equipment must be energized to test or position the machine, equipment or component; however, the following steps must be taken:

o Ensure guarding is installed, if applicable, providing the testing can be conducted with guarding in place. Clear the machine or equipment of tools and materials;

o Remove workers from the machine or equipment area; o Remove (LOTO) devices; o Energize and proceed with testing or positioning; and o De-energize all systems and re-apply energy control measures.

• In applications where electrical energy is needed for troubleshooting or diagnostic work,

employees working on the equipment must follow the requirements outlined in the EQT Electrical Safety - Grounding and Bonding Program.

3 WRITTEN ENERGY SOURCE ISOLATION PROCEDURES




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3.1 Written, equipment-specific LOTO procedures related to energy source isolation must be developed and maintained for equipment that does not meet the exceptions outlined in Section 3.4. If an equipment-specific procedure has not been developed, a procedure must be developed and documented using EQT LOTO form (Appendix A).

3.2 Operations must ensure LOTO equipment procedures remain current. Any changes to equipment

require a review and update of affected energy isolation and equipment-specific LOTO procedures.

3.3 The procedures will cover the steps to ensure equipment being serviced is isolated and secured from applicable energy sources (including stored or residual) that could injure personnel working on the equipment. A zero-energy state MUST be achieved.

• Procedures must identify and provide information on:

o Type of machinery, equipment and energy being isolated; o Method and location of LOTO; o Location where verification will take place; and o Type or method of verification that will be used to assure the LOTO was

successful.

3.4 Written LOTO procedures are not required for equipment or piping that meets all of the following criteria:

• Equipment has a single energy source that readily can be identified and isolated; • Isolation of that energy source will completely de-energize and deactivate the equipment; • Equipment is isolated from that energy source and locked out during servicing or

maintenance; • A single lockout device will achieve a zero-energy state; and • Lockout device is under the exclusive control of the authorized personnel performing the

servicing or maintenance.

4 EQT UNIQUE LOTO LOCK AND LOCK IDENTIFICATION

4.1 Red locks will be used exclusively for LOTO activities, and black locks will be used as control locks. The specified red and black locks will be unique and different from locks used for any other purpose.

4.2 For equipment being placed out-of-service for business or production purposes (e.g., poor

efficiency, recycled, sold) and unrelated to servicing and maintenance, the EQT employee must use a separate, distinct lock and tag to communicate the equipment’s energy state.




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• ORANGE Out-of-Service (OOS) Locks must be used for locking out a system for business or production reasons. These locks must be keyed alike, though the keys will be issued to specific and qualified individuals with strict accountability for the keys issued.

4.3 LOTO tag(s), identification label(s), or an engraved identification marking must accompany every lock that is applied. The tag(s), identification label(s), or engraved marking must have the name of the person for a personal LOTO lock or operations-specific lock identification for the operational control lock.

4.4 The designated LOTO locks must be used only to secure hazardous energy sources and must not

be used for any other purpose.

4.5 Duplicate keys for the removal of designated LOTO locks may be used only when the duplicate key is under the direct control of the area/location supervisor. The area/location supervisor is authorized to use a duplicate key removal system only if the supervisor has been trained and follows the process outlined in Section 9 and on the EQT Lock Removal form (Appendix B) of this Program.

4.6 LOTO locks keyed alike may have four duplicate keys per set of locks. Keys and locks must be controlled and used following the requirements set forth in the equipment-specific LOTO procedures.

5 PROCEDURE

5.1 Obtain, as applicable, the equipment-specific LOTO procedure.

5.2 Locate and identify all energy sources to determine which energy-isolating devices will establish a

zero-energy state in the equipment to be locked out, remembering that more than one energy source might be involved (e.g. stored, mechanical, electrical, radiation, fluid).

5.3 Notify all affected personnel that a lockout system will be used and the reason for its use. The authorized person must know the type and magnitude of energy the machine or equipment uses and understand associated hazards.

5.4 Shut down operating equipment by using the established shutdown procedure(s).

5.5 Operate the switch(es), valve(s), or other applicable device(s) to isolate the equipment from its energy source(s).

5.6 Stored energy (e.g., hydraulic systems, air, gas, steam, water pressure, gravity) must be dissipated or restrained by methods such as repositioning, bleeding down and blocking.




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NOTE: Bleeding down of pressurized lines must be accomplished at controllable points, such as needle valves or other types of valves. Bleed points can never be hammer unions, piping plugs or caps where the pressure cannot be controlled or properly vented. In the event that adequate bleed points are not available between two isolation points, then different isolation points must be identified where adequate bleed points are available.

5.7 Restraining, blocking, chains, and pinning devices are not to be "tried out" when equipment is

powered or active. Over time, this might compromise the integrity of the restraining device and damage the equipment. Visually verify the restraining device is in its correct position. NOTE: If an Authorized Employee identifies a discrepancy between the procedure and a zero-energy state, the employee must STOP the lockout activity and notify the supervisor. A review must be completed, and procedures updated if necessary, before work can proceed.

5.8 Document on the EQT LOTO form (Appendix A) the lockout activity, including date, location,

work, energy sources, isolation steps and personnel involved.

5.9 Lockout the energy-isolating devices with locking equipment. If an energy-isolating device is not capable of accepting a lock, a tag may be used to identify that a lockout activity is in progress. (This must be documented as a step on the EQT LOTO form.) When a tag is applied as the sole LOTO device, all employees must understand that a single tag is the same as a lock-and-tag combination (i.e., the tag by itself offers the same level of protection).

5.10 Prior to starting work on machines or equipment that have been locked out or tagged out, the

authorized employee(s) must verify isolation and de-energization of the machine or equipment has been accomplished. Verification must include that all energy sources are drained or isolated, no personnel exposed and equipment tested through the normal operating procedure to ascertain that it will not operate. Additionally, tests might need to be conducted to assure a zero-energy state. This could include verification of valve position, reading pressure gauges only if specified by the manufacturer, or testing electrical equipment. When possible, follow the manufacturer’s direction on how to achieve a zero-energy state.

NOTE: Return the controls to the “neutral” or “off” position after the testing is complete.

• Prior to starting the job activity, at least one of the authorized employees must initial the

column labeled “Initial Isolation Verification” on the EQT LOTO form (Appendix A).

NOTE: Lone workers must initial the isolation steps and verification section of the EQT LOTO form (Appendix A).

6 LOCK OUT OF PIPING SYSTEMS




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6.1 Before working on any piping system, actions must be followed to ensure employees are protected from a sudden release of energy. 6.2 The proper method for isolating a piping system is to identify, isolate, blow down, and lock and tag

applicable valves or controls.

• Additional piping systems connected to the section of pipe being isolated, such as third- party connections, syphons and drains, must be locked out.

• When blowing down natural gas pipelines, use proper venting techniques, identify and control potential ignition sources, be aware of wind direction and proximity to equipment/structures, and stay alert for potential release of fluids. Follow the applicable operating procedure.

6.3 If it is not feasible to lockout the valves on pipelines, use the following alternative:

• Plating (skillets) may be used to isolate a system. Attention must be paid to the grade and thickness of plate to be used. Contact EQT Engineering for proper specifications.

6.4 Prior to performing hot work activity within 35 feet of a parted pipe, air monitoring must be in place to ensure there is not an explosive atmosphere and the isolation mechanism (e.g., valve, stopple, plate or bag) in the pipe is effective. (See the EQT Hot Work Program.)

• If the isolating device is experiencing bleed-through, identify and isolate the next valve in

the line or eliminate escaping natural gas by following the applicable operating procedure.

6.5 Document on the EQT LOTO form (Appendix A) the lockout activity, including date, location, job activity, energy sources, isolation steps, and authorized personnel involved. The form also should be used to document isolation steps related to an emergency, such as a pipeline failure.

7 MULTIPLE LOCK DEVICES AND LOCK BOXES

7.1 When more than one person is working on equipment with single or multiple energy sources, each person is required to place a red personal lock on the established multiple lockout device, such as a hasp or lock box.

7.2 In some cases, it might be practical to use lock boxes rather than multiple personal locks. When lock boxes are needed, the following requirements must be met:

• Every worker involved in the group lockout activity must be afforded the same level of protection as if the worker isolated all of the energy sources individually;




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• Primary responsibility of the energy isolation will be vested in a PIC, who will be the authorized employee in charge of the group lockout operation and in control of the lock box. The PIC also could be the authorized employee trained to isolate and secure energy sources according to established equipment-specific LOTO procedures, prior to performing maintenance activities for a one-person operation.

• The name of the PIC/authorized employee in charge of isolating energy sources must be added to the PIC section of the EQT LOTO form (Appendix A). All participating authorized employee(s)/business partners must be added in the section labeled “Authorized Employee(s) and Business partners performing servicing or maintenance.” The applicable PIC must initial the isolation step.

• When more than one crew, craft, or department is involved, an authorized employee must be designated to coordinate affected work forces and ensure continuity of protection.

• After the equipment is properly isolated, de-energized, secured, and verified to be in a zero- energy state, each authorized employee involved in the lockout activity shall affix his or her personal lock with tag, identification label, or an engraving to the group lockbox when he or she begins work. Each employee shall remove the lock when he or she stops working on the machine or equipment being serviced or maintained.

• When a Lock Box System is used and operations are being conducted, it is the worker’s responsibility to assure that he or she places the red personal lock on the correct Lock Box.

• The EQT LOTO form (Appendix A) must be attached or located near each appropriate lock box, enabling authorized employee(s) to view the secured energy sources and readily be able to sign in/out of the job activity.

• During personnel changes, the lock box must remain secure to ensure all appropriate energy sources remain in a zero-energy state. This may be accomplished by transferring a key to a black-colored control lock between authorized employees. The placement of the control lock must be documented on the EQT LOTO form (Appendix A). If the lock box is left unsecured for any length of time, an authorized employee must verify all of the isolating devices remain in place, energy is dissipated and all appropriate keys are secured in the lock box.

8 STARTING EQUIPMENT

8.1 After the servicing or maintenance is complete and equipment or piping is ready for operation, the

area around the equipment must be checked to ensure no individual is exposed. This inspection will include looking for tools, loose parts or other devices that might have been left in the equipment; all guards have been re-installed and secured and that all workers are clear. Only after this inspection can lockout devices be removed and energy restored to the machine or equipment. When LOTO devices are removed and equipment is to be started, the LOTO checklist section on the EQT LOTO form (Appendix A) must be completed.




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8.2 Either the individual who placed the energy-isolating devices in single-person lockout activities or the authorized employee in group lockout activities will be responsible for coordinating inspection of the equipment.

9 LOCK REMOVAL

9.1 The authorized employee placing the lock on the energy-isolation device is responsible for removing the lock. The employee is allowed to maintain a personal lock on a piece of equipment for the duration of the job and for multi-day jobs as long as the employee re-verifies energy isolation upon returning to the job site.

9.2 When an authorized employee who places a lock is not available to remove it, that lock may be cut only upon the approval of the supervisor or the supervisor’s designee. A reasonable effort will be made to assure the authorized employee is not at the work site. A reasonable effort consists of attempting to make phone contact, a physical inspection of the work site, a check of the work schedule, and when possible, clock out records.

9.3 Prior to the authorized employee resuming any work activity, the employee must be informed that

the lock was cut. 9.4 The lock removal must be documented on the EQT Lock Removal form (Appendix B), with one

copy retained in the Department/District and one copy sent to the EQT Corporate EHS Department.

10 FORMAL EMPLOYEE TRAINING/RETRAINING

10.1 All affected and authorized EQT employees will receive general awareness training on the EQT LOTO Program. LOTO general awareness training will be conducted annually and include:

• Recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace and the methods and means necessary for energy isolation and control;

• Purpose and use of the energy controls; • Application, usage and removal of energy controls; • Prohibition relating to attempts to restart or reenergize LOTO machines or equipment; • Limitations of tags; • Roles and responsibilities of authorized and affected employees; and • Results of annual procedure reviews, audits and inspection activities;




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10.2 Employees authorized to perform LOTO for servicing and maintenance on equipment and piping will receive training and must demonstrate competency on the EQT LOTO Program, applicable procedures, recognition of energy sources and methods for isolation and energy control.

10.3 Employee retraining is required routinely, and when:

• There is a change in the location of an employee's job assignment; • A new hazard is introduced due to a change in machines, equipment, piping or process; • There is a change in LOTO procedures; and • A periodic inspection reveals inadequacies in procedures or in the knowledge of an

employee.

10.4 Operations is responsible for ensuring that training is completed. Retraining records will be documented and kept on file at the local operations office.

11 PERIODIC INSPECTIONS

11.1 A periodic inspection of each energy control procedure must be performed at least annually.

• The periodic inspection will ensure:

o Energy control procedures continue to be implemented properly; o Employees are familiar with their responsibilities under those procedures; and o The procedure is adequate and will provide effective protection during servicing

and maintenance operations.

• Periodic Inspections must be completed by an authorized employee other than the individuals using the energy control procedures being inspected.

• Similar equipment procedures may be grouped together for inspection purposes. Grouped equipment requires a minimum of one periodic inspection for that grouping. At least one of each grouped piece of equipment will be reviewed annually with applicable authorized employees.

• Operations will develop an annual schedule for completion of the periodic inspection.

11.2 The periodic inspection consists of two requirements:

• First, the inspector must observe a representative sample of authorized employees performing the servicing and maintenance operation using the LOTO procedure; and

• Second, the inspector must perform a review with each authorized employee of the employee's responsibilities under the energy control procedure being inspected.




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OSHA Directive: CPL 02-00-147 The Control of Hazardous Energy Enforcement Policy & Inspection

An employer who exceeds the minimum requirements of the standard and develops distinct energy-control procedures for individual pieces of machinery is not subjected to more extensive inspection and review obligations than an employer who groups a set of same or similar machines and develops a single, compliant energy-control procedure for the set of machines. A grouping of individual procedures meeting the criteria contained in this section would be considered one procedure for periodic inspection purposes.

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12 RECORD RETENTION

12.1 All activity within the scope of this Program must be documented appropriately:

• EQT LOTO form (Appendix A) • EQT Lock Removal form (Appendix B) • EQT Periodic LOTO Inspection Checklist (Appendix C)

Completed forms will be retained on file either at the work location or at the nearest operating Business Unit’s office for a period of 2 years.

12.2 Operations is responsible for ensuring that training is completed. Retraining records will be documented and kept on file at the local operations office.

13 BUSINESS PARTNER

13.1 Business partners will be required to conform to OSHA 1910.147, Control of Hazardous Energy. Business partners performing LOTO must have a verified LOTO program in ISNetworld and ensure training records readily are available upon request.

13.2 Business partners must ensure each employee and subcontractor employee has individual protection from all applicable energy sources with their personal LOTO lock. Group lock out can be accomplished by using multiple hasps or lock boxes.

13.3 Business partner locks used for LOTO will be different from locks used for any other purpose.

They must be unique and consistent.

• Business partners must assess the work area, equipment, piping, and systems to determine if the job task involves exposing employees to a potential release of hazardous energy.

• Business partners performing LOTO activities must have a written LOTO program and

training records readily available.

• Business partners working on EQT’s equipment will be provided an equipment-specific LOTO procedure to use as a guide for their LOTO activities. Business partners must perform their own evaluation to ensure stored or residual energy is de-energized of all necessary energy sources. Examples of energy sources include:

o Stored: pressure in vessels and piping, spring-loaded equipment; o Mechanical: equipment movement, flywheels, rotating shafts and chippers; o Electrical: systems and components, as well as capacitors; o Radiation: ionizing radiation in the form of radioactive sources;




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o Fluid: hydraulic or pneumatic systems; and o Atmosphere: hazardous and flammable.

• Personal LOTO locks also must identify the name of the person who applied the lock and

the name of their company. Personal LOTO locks will only have one key. • LOTO tags may be used only when it is infeasible to apply a LOTO lock or locking

device.

• Business partners must not shut down equipment unless they have been authorized by EQT.

13.4 Before working on a piping system, applicable operating procedures must be followed to ensure

business partners are protected from a sudden release of energy.

• For EQT piping systems, coordination with an EQT representative must take place prior to work.

• For business partner’s leased equipment, business partners must follow their applicable operating procedures.

13.5 When a business partner who places, a lock is not available to remove it, the Business partner

must complete a Forcible Lock Removal form per its company’s program. The lock may be cut by the Business partner only after obtaining approval from his or her supervisor or designee. A reasonable effort (attempting to make phone contact and a physical inspection of the worksite) must be made to ensure the business partner is not at the worksite.

• If the lock is on EQT equipment, the business partner must contact EQT to decide if the lock can be removed.

13.6 Business partners must adhere to applicable elements of EQT’s LOTO Program.

14 ROLES AND RESPONSIBILITES

14.1 EQT Business Units Supervisors (or designee)

• Ensure all requirements and procedures of the LOTO Program are developed and implemented fully.

14.2 EQT Supervisors (or designee)




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• Ensure that responsible employees are trained and follow the requirements of this program. • Maintain the necessary information required in this program for the safe LOTO of

equipment under their responsibility. • Communicate and inform personnel working on their responsible location/s of the

requirements of this program. 14.3 EQT Employees

• Adhere to all provisions of the EQT LOTO Program; and • Initiate Stop Work Authority action if an unsafe condition exists.


• Reviews and modifies as warranted this Program; • Works with supervisors to implement applicable training; and • Maintains general awareness training records. • Provide technical guidance per the requirements of this program. • Audit and evaluate compliance with the requirements of this program.

15 DEFINITIONS

Affected Employee: one whose job requires operating or using a piece of equipment or piping on which servicing or maintenance is being performed under LOTO or whose job requires working in an area in which such servicing or maintenance is being performed. Authorized Employee: a person who locks out equipment or piping in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance. Change: represents any modification to equipment that might affect LOTO procedures. These changes include technical, physical, procedural, and organizational.

• Significant Change: one that might impact the accuracy or clarity of the existing LOTO

procedure for the affected equipment. • Like-Size and Kind Change –one that is a replacement in kind. A “Like Size and Kind

Change” does not alter the technical, physical or procedural nature of the system; therefore, it does not impact the existing LOTO procedure.

Energy-isolating Device: a mechanical element that physically prevents the transmission or release of energy. Examples include: a manually operated electrical circuit breaker; disconnect switch; a manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and no pole can be operated independently; a line valve, blank or blind; and a block. Push




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buttons, selector switches and other control circuit-type devices are NOT to be used as sole isolating devices. Energy Source: any source of stored, mechanical, electric, radiation, gas or fluid energy.

Equipment Specific LOTO Procedure: one specific for a piece of equipment that defines the type of equipment being isolated, applicable energy sources, method and location of isolating the sources, and how to “try out” the equipment to verify everything is in a zero energy state. Lockout: placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed. Lockout Device: one that uses a positive means, such as a keyed lock, to hold an energy-isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds. Multiple Energy Source Equipment: piece of equipment that has more than one specific type of energy source or isolation of the equipment. Types of energy sources are stored, mechanical, electric, radiation, gas or fluid energy. Out-of-Service (OOS) Locks: Are orange locks that must be used for locking out a system for business or production reasons. These locks must be keyed alike, though the keys will be issued to specific and qualified individuals with strict accountability for the keys issued. LOTO Lock: a lock that is placed on a piece of equipment or lockbox. Types of LOTO locks are:

• Personal – A red lock applied by an individual to an energy-isolating device or lock bock.

Personal locks must be affixed with a tag, label or engraved with the name of the individual who placed the lock.

• Control – A black lock used for the sole purpose of ensuring a lock box remains secured during pauses in work or personnel changes. Control locks must be affixed with a tag, label or engraved with the words “Control Lock” and the name of the department who placed the lock.

• Operation or Group – A red lock used by personnel to lock out energy isolating devices for the purposes of group lock out. Operation locks must be affixed with a tag, label or engraved with the name of the unit, station or department.


Title Excavation Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Excavation Program is to outline requirements for controlling the hazards associated with excavation activities at EQT work locations.

2 SURFACE ENCUMBRANCES

2.1 All surface encumbrances that create a hazard to workers will be removed or supported, as

necessary, to safeguard workers. 2.2 A hazard assessment shall be completed prior to excavation activities taking place that meet the

requirements of the EQT Hazard Assessment and Control Program. The hazard assessment shall also evaluate the area specifically for power cables, pylons, and/or additional utilities.

3 UNDERGROUND UTILITIES

3.1 Prior to any groundbreaking or excavation activities, EQT personnel and business partners will

determine the location of any potential underground area utilities, including the following:

Sewer lines Telephone lines Fuel lines Water lines Electrical Fire suppression Underground tanks Storm sewer Pressurized lines

3.2 EQT personnel or the designated business partner must call 811 prior to excavating and per state regulations and contact the utility companies or owners to notify them of the proposed work in the area to establish the location of the underground utility installations.

If the utility companies/owners cannot respond to the request within 24 hours (unless a longer period is required by state or local law) or cannot establish the exact location of the installations, EQT or its contactors may proceed, provided all proper precautions are in place and detection equipment or other acceptable means to locate utility installations are used.



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3.3 EQT and their business partners may periodically call upon a private utility locator, such as one that uses ground penetrating radar (GPR), to assist in identifying any potentially unknown utilities.

3.4 Underground installations and utilities will be protected, supported or removed as necessary to

safeguard personnel while the excavation is open. 3.5 All excavating equipment used for excavation near existing facilities or equipment must have a

safety bar across the teeth to prevent line snagging that could damage the line and/or coatings. Side cutters might also need to be removed from the bucket.

3.6 When installing new piping, adequate markers must be set above it to indicate a natural gas line

is below it (when applicable).

4 ACCESS AND EGRESS

4.1 A competent person qualified in structural design must develop any structural ramps used solely as a means of access or egress from excavations and equipment.

4.2 When a trench or excavation is greater than four feet in depth, a stairway, ladder, ramp, or other safe means of egress will be placed in the trench/excavation at intervals no greater than 25 feet of lateral travel to personnel.

4.3 Walkways will be provided where workers or equipment are required or permitted to cross excavations. Guardrails that comply with §1926.502(b) will be provided where walkways are four feet or more above lower levels.

5 FALLING LOADS AND VEHICULAR TRAFFIC

5.1 EQT personnel and business partners will not be permitted under loads handled by lifting or

digging equipment. A safe distance must be maintained by all personnel to avoid being struck by any spillage or falling materials. Stop work authority must be used if violations of this requirement are observed.

5.2 When mobile equipment is operated adjacent to an excavation, or when equipment is required to

approach the edge of an excavation with no clear view from the operator’s perspective, a warning system, such as barricade, signaling or stop logs, must be used.

5.3 Personnel who have a potential to be exposed to vehicular traffic on location are required to wear

high-visibility vests or other approved garments in accordance with ANSI / ISEA 107.



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6 HAZARDOUS ATMOSPHERES

6.1 Atmospheric testing must be conducted prior to workers entering excavations greater than four feet in depth for any excavations that have potential for a hazardous atmosphere (e.g., toxic gas, flammable gas, oxygen deficiency).

6.2 When hazardous atmospheres are identified in a space, the space must be handled as a permit-required confined space, where no EQT employee is authorized to enter. If a space must be entered, a qualified permit required confined space business partner must complete the entry following all OSHA requirements or the hazardous atmosphere must be eliminated and verified prior to entry. Please reference the EQT Confined Space Program for additional requirements.

6.3 When controls are used to reduce the level of atmospheric contaminants to acceptable levels,

continuous monitoring of atmospheric testing will be conducted to ensure the atmosphere remains safe for personnel.

7 EMERGENCY RESCUE EQUIPMENT

7.1 When workers have the potential to enter excavations, emergency rescue equipment (e.g.,

breathing apparatus, safety harness and line or basket stretcher) must be readily available when hazardous atmosphere conditions exist.

8 WATER ACCUMULATION

8.1 If water has accumulated or is accumulating in the excavation or trench, no personnel are

authorized to enter unless adequate precautions have been taken to protect workers from the hazard associated by water accumulation.

8.2 If water removal equipment is used, the equipment and operations will be monitored by a competent person to ensure proper operation.

8.3 If excavation work at any EQT work site interrupts the natural drainage of surface water, suitable means will be used to prevent the surface water from entering the excavation and to provide adequate draining of the area adjacent to the excavation. If the excavation is subject to runoff from heavy rains, an inspection will be required by a competent person prior to entry.

9 ADJACENT STRUCTURE STABILITY

9.1 If excavation activities might impact stability of adjoining buildings, walls or other structures, support systems — such as shoring, bracing, or underpinning — will be provided to safeguard



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workers and ensure the stability of such structures.

9.2 Excavations below the level of the base or footing of any foundation or retaining wall that reasonably could be expected to pose a hazard to workers will not be permitted except when:

A support system, such as underpinning, is provided to ensure the safety of workers and the stability of the structure;

The excavation is in stable rock; A registered professional engineer has approved the determination that the structure

sufficiently is removed from the excavation so as to be unaffected by the excavation activity; or

A registered professional engineer has approved the determination that such excavation work will not pose a hazard to workers.

9.3 Sidewalks, pavements, and appurtenant structure will not be disturbed unless a support system or

another method of protection is provided to protect workers from the possible collapse of such structures.

10 LOOSE ROCK AND SOIL

10.1 Adequate protection will be provided to protect personnel from loose rock or soil that could pose

a hazard by falling or rolling from an excavation face. Protection will consist of:

Scaling to remove loose material; Installing protective barricades at intervals as necessary; and Other means that provide equivalent protection.

10.2 All materials and equipment must be kept at least two feet from the edge of excavations;

maintained by use of retaining devices sufficient to prevent materials or equipment from falling or rolling into excavations; or by a combination of the two.

11 INSPECTIONS

11.1 The Competent Person will conduct the inspection prior to the start of work and as needed

throughout the shift. Inspections are required regardless of depth, though must be documented for all excavations of four feet or greater. Inspections must also be made after every rainstorm or other hazard-increasing occurrence. Daily inspections of excavations, the adjacent areas and protective systems will be made by a competent person and documented (Excavation Checklist Appendix A for EQT Employees only) for evidence of a situation that could result in cave-ins, failure of protective systems, hazardous atmospheres, or other hazardous conditions.



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11.2 Where the competent person finds evidence of a situation that could result in a possible cave or cave-in incident, failure of protective systems, hazardous atmospheres, or other hazardous conditions, exposed personnel will be removed from the hazardous area until the necessary precautions have been taken to ensure their safety.

12 REQUIREMENTS FOR PROTECTIVE SYSTEMS

12.1 Protective systems (e.g., trench boxes) shall be used in accordance with this Program and follow all requirements outlined in 29 CFR 1926.652 Excavations: Requirements for Protective Systems.

Trench boxes must extend 18 inches above the surface and be no more than two feet from the bottom of the trench. If the trench depth exceeds 20 feet, a certified, professional engineer must design the trench box, according to OSHA requirements.

The employee can use contemporary shoring equipment or approved sloping methods to provide additional support for the trench box.

The employee must provide a safe access and egress with the trench box. Ladders, steps, and ramps are to be situated within 25 feet of workers to allow a quick exit if the soil collapse.

Design of support systems, shield systems, or other protective systems that are drawn from manufacturer's tabulated data shall be in accordance with all specifications, recommendations, and limitations issued or made by the manufacturer.

13 FALL PROTECTION

13.1 Where personnel or equipment are required or permitted to cross excavations, walkways or

bridges, standard guardrails shall be provided. 13.2 Applicable barriers, physical protection, or appropriate warnings shall be provided at all remote

excavation locations. All wells, pits, and shafts shall be barricaded or covered. Upon completion of exploration and similar operations, temporary wells, pits, and shafts will be backfilled.

13.3 Adequate precautions will be taken to protect the general public from unattended open excavations.

14 TRAINING – EQT Only

14.1 EQT Employees



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All field employees will receive an annual awareness-level excavation training.

14.2 Competent Person

All employees involved in excavation operations will participate in the EQT Excavation Competent Person training.

15 RECORD RETENTION – EQT Only

15.1 Completed Excavation Checklists shall be maintained for a period of 2 years. 15.2 Periodic review of completed Excavation Checklists (Appendix A) shall occur by the Corporate EHS Department to ensure compliance with this program.



Implement this Program; and Senior management will enforce actions related to violations of any requirements.


Adhere to this Program during all work operations; and Business partners must have a written, verified excavation safety program in ISNetworld

and must follow the excavation, trenching, and shoring requirements as specified in OSHA 29 CFR 1926.650.


Provides technical information and assists departments in implementing an effective

excavation safety program; Provides and/or coordinates excavation safety awareness training and competent person

training; Investigates and documents all reported incidents related to excavations and recommends

corrective action; and Reviews and revises the Excavation Program to ensure compliance with applicable

regulations.



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17 DEFINITIONS

Competent Person: one capable of identifying existing and predictable hazards in the surroundings or work conditions that are unsanitary, hazardous, or dangerous to workers and who has authorization to take prompt, corrective measures to eliminate them.

Faces (sides): the vertical or inclined earth surfaces formed as a result of excavation work.

Protective System: a method of protecting employees from cave-ins from material that could fall or

roll from an excavation face or into an excavation from the collapse of adjacent structures. Protective systems include support systems, sloping and benching systems, shield systems, and other systems that provide the necessary protection.

Shield: a structure able to withstand forces imposed on it by a caving incident, thereby protecting employees within the structure. Shields can be permanent or portable.

Shoring (Shoring System): a structure, such as a metal hydraulic, mechanical or timber shoring that

supports the sides of an excavation and which is designed to prevent cave-ins.

Stable Rock: a natural solid mineral material that can be excavated with vertical sides and remain intact while exposed. Unstable rock is considered stable when the rock material on the sides of the excavation is secured against caving or movement by rock bolts or by another protective system.

Support System: a structure such as underpinning, bracing, or shoring that provides support to adjacent structure, underground installation, or the sides of an excavation.

Surcharge: an excessive vertical load or weight caused by spoil, overburden, vehicles, equipment, or

activities that may affect stability. Surface Encumbrance: include utilities, foundations, streams, water tables, transformer vaults,

walkways, bridges, roads, and geologic anomalies.


Title Explosives Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Explosives Safety Program is to establish minimum requirements for the

safety of personnel working near blasting activities on EQT locations.


2.1 EQT employees are not permitted to handle explosives.

2.2 Only licensed contractors certified in the state in which they are operating can be authorized to

handle explosives at an EQT location. It is the contractor's responsibility to transport, store, and

handle explosive material in compliance with applicable federal, state, and local laws and

regulations.

3 INITIAL BLASTING PLANNING

3.1 For surface blasting and well perforating operations, the contractor must have their license on

site and a documented surface blasting plan available to EQT upon request. EQT must be

notified 24 hours prior to blasting.

3.2 EQT requires each surface blasting plan include, at a minimum, the following:

• Project scope;

• Safety and environmental concerns;

• Contractor qualifications;

• Materials required;

• Transportation and storage;

• Drilling and blast signals;

• Loading and initiating explosives;

• Misfire procedures; and

• Blasting area map.

3.3 All contractors must comply with EQT’s Hot-work Program and OSHA rules, as well as

minimize potential for fire or explosion by taking appropriate preventive measures for surface

blasting as outlined in EQT’s Fire Safety and Hot-work programs.



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4 SAFE WORK PRACTICES

4.1 Operations involving explosives will be conducted under the direct supervision of the licensed

explosives contractor. Devices (e.g., perforating guns, line cutters) containing explosives will be

handled only by or at the direction of personnel of the licensed service contractor.

4.2 Blasting operations cannot be conducted under Simultaneous Operations (SIMOPS). Perforating

(downhole blasting) can be conducted under SIMOPS.

• Prior to blasting operations EQT will conduct and document a pre-job meeting with the

explosives contractor and EQT personnel. All participating personnel must also review

responsibilities in accordance with the blasting plan.

4.3 All participating personnel must follow the direction and guidance of the certified blaster during

blasting operations.

4.4 Power off all two-way radios, cell phones, and other electronic communication devices while

surface or rock blasting is conducted.

4.5 Service company personnel utilizing explosives must follow the practices of API RP 67,

Recommended Practice for Oilfield Explosives Safety.

4.6 Unneeded personnel must clear the area when loading, unloading, or running perforating guns

into and out of the wellbore.

4.7 Contractor must have and follow safe work practices for managing misfires.

4.8 Blasting personnel will verify detonation to ensure there are no unexploded charges and remove

all explosive materials and waste from the location upon completion of blasting.

4.9 Immediately report any suspected remnants of explosives to the blasting contractor.

5 TRAINING

5.1 Only trained and licensed personnel will be authorized to conduct operations involving

explosives and blasting.




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6.1 EQT Supervisors

• Define compliance needs at their locations;

• Ensure blasting plan is received prior to starting any blasting; and

• Ensure proper implementation and adherence to this program.

6.2 EQT Contractors

• Follow provisions of this Program and related procedures;

• Prepare blasting plan prior to beginning operations;

• Adhere to all blast-area restrictions and warning instructions prior to, during and after

blasting activities; and

• Notify EQT management of the planned blasting operations within 24 hours of scheduled

operations.

6.3 EQT Employees

• Follow provisions of this Program and related procedures;

• Adhere to all blast-area restrictions and warning instructions prior to, during and after

blasting activities; and

• Report incidents immediately.


• Audit certified blasting contractors and blasting operations to ensure adherence to

requirements of this Program;

• Establish contractor safety qualification requirements.

7 DEFINITIONS

Blast area: one near operations in which flying material or debris might cause injury.

Blaster’s license: a license to detonate explosives and supervise blasting activities.

Perforating: act of blasting holes through steel casing, cement and rock formations. The technique

involves carrying explosive charges downhole, where they are detonated to create tunnels that act as

conduits through which reservoir fluids flow from the formation into the wellbore and to the surface.

Rock blasting: controlled use of explosives and other methods, such as gas pressure blasting,

pyrotechnics, or plasma processes, to excavate, break, or remove rock.


Title Fatigue Management Program

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1 PURPOSE AND SCOPE

1.1 The purpose of the Fatigue Management Program is to define procedures and precautions that must be followed while working on EQT locations.

1.2 This Program does not apply to operations based on locations with living quarters present, allowing personnel to take adequate breaks (e.g. drilling operations where employees are living at the location for extended periods).

2 REPORTING FOR WORK

2.1 Personnel are required to be present for work in a fit state, free from the adverse effects of sleep deprivation or fatigue. Workers must notify their supervisor immediately if they feel they are unfit to work or feel they no longer are fit (e.g., due to medications or any other product that might impair their ability) to perform the tasks associated with the required work.

3 HOURS OF WORK

3.1 Shifts generally will not exceed 16 hours in a 24-hour period. The maximum number of

consecutive hours of work on any single shift is 16 hours. Appropriate rest and meal breaks must be provided during shifts. Employees cannot perform as a lone worker over 16 hours.

3.2 Working beyond a 16-hour shift is permitted only in unusual situations and can proceed based

only on compliance with:

Obtaining pre-approval from the employee’s supervisor and documentation of the approval. The supervisor will make the decision following an assessment that will include a face-to-face discussion with the employee(s) to determine working beyond a 16-hour shift will not create an unacceptable level of risk for the employee or others.

A break of at least 10 hours is provided before work resumes. On-site supervision provided to monitor fatigue and performance. If the supervisor

determines fatigue is contributing to a reduction in safety or job performance, the supervisor shall stop the job and release the employee to return home or to another accommodation.

Supervisors maintaining contact with employees working past the 16-hour threshold for the completion of their shift.

3.3 Breaks during shifts should be coordinated to maximize work safety and efficiency.



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3.4 Personnel who work a 16-hour shift must have an absence from work of at least 10 hours before beginning their next shift. The respective supervisor can approve exceptions to the 10-hour break rule, but must address and document the assessment requirements as described in section 3.2.

3.5 Driving time to and from the location of work activities should be included when calculating the

16-hour threshold.

4 CONSECUTIVE DAYS WORKED

4.1 Generally, the maximum number of consecutive days worked, including travel, is six followed by a minimum of one day absent from work.

Generally, based on two weeks on/two weeks off, the maximum number of consecutive days for hitches should not exceed 16.

Generally, based on three weeks on/one week off, the maximum number of consecutive days for hitches is 23.

4.2 In times of shut down or periodic maintenance, the entire work schedule requires a fatigue

management assessment to determine optimum safe work rosters. In this case, the maximum number of consecutive 16-hour shifts should not exceed 23 before a 24-hour break is taken.

5 TRAINING

5.1 Personnel must be trained on how to identify symptoms of fatigue and proper management of the

associated risks. 6 ROLES AND RESPONSIBILITIES

6.1 EQT Supervisors

Implement this Program. Senior management will be responsible for enforcement actions

related to violations of any requirements of this Program.


Adhere to the provisions of this Program during all work operations; and Business partners must have a verified and compliant Fatigue Management Program in

ISNetworld.




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Evaluates occurrence and trends related to this procedure to determine effectiveness of this Program; and

Provides guidance and support to operations to identify fatigue management and develop solutions.

7 DEFINITIONS

Fatigue: a feeling of tiredness or exhaustion or a need to rest because of lack of energy or strength. Hitch: a blocked amount of time an employee is expected to work in the field. Sleep Deprivation: a situation or condition of suffering from a lack of sleep.


Title Fire Safety Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Fire Safety Program is to outline the requirements for preventing, identifying, and controlling the risks associated with fires at EQT locations.

2 FIRE PREVENTION PLANS

2.1 Fire prevention plans will be developed for each EQT location, as required.

2.2 A fire prevention plan will be updated as necessary to reflect changes. The location may develop

independent fire prevention plans or embed the required material into the location’s established Emergency Action Plan (EAP).

3 IGNITION HAZARDS

3.1 Electrical wiring and equipment for light, heat, or power will be installed in accordance with all applicable regulatory requirements and EQT program requirements.

3.2 Due to the nature of potential ignitable atmospheres at drilling operations, compressor stations

and well sites, all electrical and other equipment must be approved for the type of hazardous locations (i.e., Class I, Division I) where it will be used. Equipment examples include, but are not limited to:

Power and hand tools; Heaters; Lighting; Electronics; and Any spark-producing equipment.

3.3 Smoking and grilling must have designated areas that meet the requirements of all EQT programs.

3.4 Internal engine-powered combustion equipment must be located to ensure exhausts do not affect

combustible materials and employee living quarters.

Adequate clearance must be maintained between piping and combustible material when the exhausts are piped outside the building under construction.

An evaluation also must be completed considering distance, terrain, wind, and airflow for the installation of internal combustion engines to ensure exhaust is installed in a safe location to protect employee living quarters and gathering areas.



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3.5 Business partners must take appropriate steps and preventive measures to minimize the potential

for a fire or explosion. These steps include:

1. No smoking beyond designated smoking areas; 2. Not allowing accumulation of trash or flammable materials; 3. Protecting or eliminating potential sources of fuel; 4. Eliminating potential ignition sources, including static electricity; 5. Keeping flammable liquids in approved, self-closing containers; and 6. Learning the location of firefighting equipment, ESDs and alarms.

3.6 Ensure the nozzle of air, inert gas, and steam lines or hoses are bonded to the tank or vessel shell

when used in the cleaning or ventilation of tanks and vessels that contain hazardous concentrations of flammable gases or vapors.

4 MATERIAL STORAGE

4.1 All hazardous and flammable/combustible materials (including pallets) must be stored in a

manner to ensure they do not present a hazard to EQT personnel or business partners. Examples of unsafe practices include, but are not limited to:

Storing hazardous chemicals near emergency exit paths or doorways; Exceeding height or threshold quantity storage limits for hazardous materials; Obstruction of fire-suppression equipment; Storing incompatible chemicals within proximity of each other; and Storing flammable/combustible liquids near potential ignition sources.

4.2 Materials with specific storage requirements for Safety Data Sheets (SDS) must be labeled

properly and in appropriate containers for the contents. Damaged containers or illegible labels must be reported timely.

5 FIRE DETECTION/SUPPRESSION SYSTEMS

5.1 Fire detection and fire suppression systems will be designed, installed, and maintained in

accordance with all federal, state, and local codes and regulations. Example codes and regulations include:

29 CFR 1910 Subpart L – Fire Protection; 29 CFR 1926 Subpart F – Fire Protection and Prevention; National Fire Protection Association Standards; and International Fire Code Standards.



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5.2 Personnel who will inspect or perform maintenance activities on fire detection and suppression systems must be trained and receive authorization by EQT management prior to beginning work on these systems.

5.3 Design and construction of on-site living quarters must adhere to the current NFPA 101 Life

Safety Code.

6 PORTABLE FIRE EXTINGUISHERS

6.1 Portable fire extinguishers will be distributed, inspected, and maintained in accordance with local fire code and OSHA regulations. Fire extinguishers must be unobstructed and accessible for use.

6.2 Fire extinguisher requirements may vary based on the risks associated with a location’s material

storage and operations; therefore, variances in the fire extinguisher requirements will be outlined in the site-specific fire prevention plan.

7 OPEN BURNING

7.1 Any open burning of trees, brush, etc. must be done in accordance with state and local laws, and

EQT Hot Work Permit Program. Burn permits must be obtained and complied with where required.

7.2 Open burning is not allowed when burn bans are in effect, there are air pollution episodes/air

quality alerts, or when adverse weather impacts the ability to contain a fire. 7.3 Air curtain destructors must be used where required. 7.4 Burns must be attended by trained personnel equipped with appropriate communication and fire

suppression equipment.

8 TRAINING 8.1 All personnel will be trained on this program. 8.2 Requirements for all EQT field employees include:

New-hire safety orientation that includes fire extinguisher training; Annual (computer-based or instructor-led) refresher training; and Hands-on training for employees who perform essential task functions for this Program

based on their job classification and the EQT Hot-work Program. Every three years, employees must demonstrate their competency in fire extinguisher use.



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9 RECORD RETENTION

9.1 Fire extinguisher inspection records will be maintained for one year after the last inspection entry or life of the shell. Fire extinguisher training records will be maintained for the duration of employment.




10.2 EQT Employees and Business partners

Adhere to this Program during all work operations. Business partners must comply with OSHA 29 CFR 1910.39, Fire Prevention Plans,

1926.151, Fire Prevention and any applicable state requirements. 10.3 EQT Corporate EHS Department

Coordinates and maintains the fire safety training program; and Supports EQT Operations and Engineering departments with fire safety regulatory

guidance and development of Fire Prevention Plans.


Title First Aid and Bloodborne Pathogens (BBP)

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PURPOSE AND SCOPE

1.1 The purpose of this First Aid and Bloodborne Pathogens (BBP) Program is to define procedures and requirements for the planning, training, and application of first aid and BBP for all EQT locations.

GENERAL REQUIREMENTS

2.1 Only those who have received appropriate training may render first aid and/or CPR. 2.2 Risk of exposure to bloodborne pathogens is normally low at EQT locations, because typical job

assignments do not require occupational exposure to blood, body fluids, tissues, or the performance of emergency medical procedures. Employees might be exposed, however, when administering basic first aid. Because of the serious possible consequences (e.g., Hepatitis B and HIV) of exposure to BBP, employees must be instructed on the hazards of exposure to blood and other potentially infectious materials, how to minimize exposures and necessary medical follow-up procedures for isolated exposure incidents.

2.3 OSHA requires a person with a valid first-aid certificate be available to render care at

construction sites not reasonably accessible to a medical facility. Phone numbers of emergency medical services must be communicated during the daily hazard assessment if 911 is not available.

2.4 First-aid kits must be available at all EQT locations. Eye flushing kits must be available where

corrosives are used. Safety showers may be required based on quantity and type of corrosives used and based on OSHA Standards.

2.5 Business partners must have verified First Aid and BBP programs in ISNetworld before

conducting work at any EQT location. Business partners are responsible for providing first-aid care and for arranging transportation for their injured employees (including their subcontractor employees). Business partners must also have trained personnel on site to be able to administer first aid and CPR as needed, and as defined by OSHA standards.


3.1 All Company vehicles, EQT and Business partners, (including ATV and UTVs) are required to

have a First Aid Kit. The kit must be kept clean, stocked, and inspected to ensure supplies are readily available.

The Loggers First Aid Kit is the minimum requirement of first-aid supplies for small work sites consisting of approximately three employees. When larger operations or multiple operations are conducted at the same location, additional first-aid kits should be provided or additional quantities of supplies included in the first aid kits.



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SITE-SPECIFIC EXPOSURE CONTROL PLAN

4.1 Since certain field employee job categories are required to be able to administer first aid, and as

such, could be exposed to BBP, EQT will implement an EQT Exposure Control Plan (ECP). 4.2 Business partners should review and establish an ECP plan where applicable. 4.3 The EQT ECP must be reviewed and recorded annually, and at a minimum, include the following:

Exposure determination; Engineering controls, administrative controls and personal protective equipment required

to minimize exposure to BBP; Information on the Hepatitis B vaccination and post-exposure evaluation and follow-up; Communication of hazards to employees (labeling); Records maintenance; and Procedure for evaluating circumstances surrounding exposure incidents.

PROCEDURES

5.1 If a first aid or potential BBP incident occurs, only trained and certified first-aid responders who

have received BBP training and are included in the BBP program may respond. Those responding must follow their training and proper medical protocol.

EXPOSURE INCIDENT / POST EXPOSURE EVALUATION – EQT ONLY

6.1 Any EQT employee who has suffered a cut or needlestick or who has been exposed to human

blood and blood products must report the incident immediately and contact the EQT Medical Department.

6.2 An employee covered under this Program or acting as a “Good Samaritan” who has been

exposed, will be tested within 24 hours of exposure. The employee will be re-tested at six weeks, 12 weeks and six months after exposure. All testing will be performed at the expense of EQT. Results from the testing will be provided within five days.

TRAINING

7.1 All personnel must participate in any required first-aid/CPR/BBP courses to maintain their

qualifications.

RECORDS RETENTION – EQT ONLY



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8.1 EQT will retain on file the following:

All medical records in accordance with 29 CFR 1910.1020 and the EQT Medical Records Requirements;

Training records that include:

o Date(s) and content or summary of training sessions; o Names and qualifications of persons conducting the training; and o Names and job titles of all persons attending the training sessions.

Declination/acceptance forms for hepatitis B vaccinations.

8.2 Training records must be maintained for three years from the date on which the training

occurred. BBP training records, blood test consent forms and Hepatitis B vaccination status, including declination, will be maintained for the duration of employment plus 30 years.

ROLES AND RESPONSIBILITIES

9.1 EQT Supervisors and Business Partners

Define compliance needs at their locations; Ensure proper implementation and adherence to this Program; Ensure first-aid kits are maintained with adequate supplies; and Direct, as appropriate, first-aid response during an incident.

9.2 All Personnel

Follow provisions of this Program and related procedures; Attend all required training and report incidents immediately; and Respond to first-aid incidents if trained appropriately.


Provide technical guidance and support, training, ECP risk assessment, and development; Review and update at least annually the ECP and maintains first-aid training; and Audit the Program and related procedures.

9.4 EQT Medical Department

Maintain BBP employee medical records and schedule vaccines and medical

examinations, as warranted.



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DEFINITIONS

Bloodborne Pathogens (BBP): pathogenic microorganisms present in human blood that can cause disease in humans. Engineering Controls: self-sheathing needles, Sharps disposal containers, or other medical devices and injury protections that isolate or remove the BBP hazard from the workplace.


Title Fleet Vehicle Safety

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1 PURPOSE AND SCOPE

1.1 The Fleet Vehicle Safety Program provides clarity and application to the operation of EQT fleet vehicles used for company business at EQT Corporation and all its subsidiaries. This Program provides policies for all personnel having any interaction with, or interest in, the operation of EQT’s motor vehicle fleet.


2.1 General Prohibitions

Employees are prohibited from:

Operating a vehicle while impaired or influenced by alcohol, illegal drugs, prescribed or over-the-counter medication, a medical condition, illness, fatigue or injury;

Possessing or using illegal drugs or alcohol while using EQT vehicles or while conducting EQT business;

Carrying weapons in vehicles; Picking up hitchhikers; Pushing or pulling another vehicle where non-company vehicles are involved. (The only

exception is towing trailers rented on behalf of EQT); Transporting flammable liquids or gases unless using an approved container for the

specific material and only then in limited quantities within legal parameters; Performing any task that distracts driving: Using laptops, smartphones, smoking,

reading, eating, etc. while the vehicle is in motion. Modifying or adding after-market equipment to company vehicles without approval of

Corporate EHS Department. Driving motorcycles on EQT access roads.

2.2 Vehicle use authorizations

Employees authorized by their supervisors will be permitted to operate a passenger car, SUV or light truck;

Only employees with an appropriate commercial driver’s license (when required by the state) who receive authorization from their supervisors are permitted to operate commercial vans and trucks. These employees must be qualified by federal and state departments of transportation, where applicable;

Authorized drivers with a minimum of a field supervisor-level approval will be permitted to use a company vehicle for commuting to work or any other specific situation necessitating having the vehicle available to perform assignments of the position. Personal use will be limited to the commute to and from the normal place of work with “de minimis” privileges.



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o No family members, friends or business partners are permitted to operate company vehicles except if the Authorized Driver is unable to drive due to illness, fatigue or other circumstances that would make operation of the vehicle by the Authorized Driver unsafe. In any such case, another licensed driver may drive the Company vehicle, but only as far as the employee's residence, nearest company or medical facility.

o No family members, friends or other non-employees are permitted to travel as a passenger in a company vehicle unless in compliance with items above noted or in the case of emergency or specifically authorized by the Authorized Driver’s immediate supervisor.

2.3 Unauthorized personal use

Company vehicles may not be used for any form of commercial activity unrelated directly to EQT.

Except for incidentals related to daily commuting and required for company business, company vehicles may not be used for transporting personal property or any other goods, unless approved by a supervisor.

A company vehicle is not to be driven outside the Authorized Driver’s normal operating territory for personal reasons or on family vacations or other excursions under any circumstance.

2.4 Accidents and Other Incidents

It is the Authorized Driver’s responsibility to record and report all accidents and other incidents.

The Authorized Driver must immediately report any vehicle accident to his or her supervisor and to Emergency Dispatch Hotline at 1.833.990.1534.

The Authorized Driver must immediately report to their supervisor and the Corporate EHS Department all traffic citations (except parking tickets), all DOT inspections, and the suspension or revocation of his or her driver’s license;

2.5 Accident Procedure

Upon occurrence of an accident, the Authorized Driver will stop immediately in a safe manner and place emergency reflectors or flares as applicable;

Get help for injured persons. Render first aid to the extent the Authorized Driver is trained or qualified;

Notify the police if the Authorized Driver believes a motor vehicle violation has occurred and/or someone has been injured;

Obtain necessary information, including:

o Names, address, telephone number, and driver’s license number of those involved;

o Make, model, description, and license plate numbers of each vehicle involved;



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o Insurance carriers and insurance policy numbers of those involved; o Names of responding law enforcement agencies and names and badge numbers of

responding personnel; and o Names, address, and telephone number of all witnesses. o Takes photos of the scene and any damage.

2.6 Accident Classification

Each vehicular accident will be reviewed by a member of the EQT Corporate EHS Department to determine classification.

2.7 Pre-assignment

EQT supervisors must complete the New Employee Supervisor Driver Observation Training presentation and hands on activity prior to the employee operating a company vehicle. Along with the training, the EQT New Employee Vehicle Assignment Review Form must be completed and returned to the Corporate EHS Department.

2.8 An Authorized Driver must possess basic skills and credentials necessary to operate a company vehicle for company business as determined by the Driver Selection Process and complete

required training as assigned.

2.9 For safe vehicle operation, employees also must:

Ensure all occupants are wearing seatbelts when the vehicle is in motion. No one is permitted to ride in the back of pick-up trucks or vans unless the vehicles are equipped with approved restraints;

Abide by all federal, state and local motor vehicle regulations, laws and ordinances and be personally responsible for payment of any fines, traffic and parking violations;

Ensure the vehicle load is adequately secured and adhere to the manufacturer, federal, state, and load capacities requirements;

Ensure the driver’s floor is kept free of all loose objects and non-standard floor coverings that might obstruct pedal operation;

Carry all fuel for miscellaneous equipment in steel containers conforming to ASTM standards;

Park in such a way that the vehicle can pull forward to depart unless parking in a one-way, herringbone pattern or it is otherwise unsafe to use the reverse method;

o All company vehicles must display a 360° walk around decal. Immediately prior to driving vehicle, the driver must conduct a 360° walk-around safety check.

Use a spotter (when available) before reversing any vehicle weighing over 26,000 lbs. or any vehicle towing a trailer.



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Turn off the vehicle’s engine, ensure the transmission is in park, and apply the parking brake before leaving a vehicle unoccupied.

If an employee believes an engine must idle to power equipment for a specific job, the employee first should talk with his or her supervisor who will determine if the task requires the engine to idle and then take the following steps:

o Ensure the vehicle is parked at a safe location and will not create an ignition source for a planned or unplanned release of flammable gas. If the vehicle will be operating within a Class 1 Division 1 or 2 area, the EQT Hot Work Permit Program must be followed.

o Put the vehicle in park (if automatic) or neutral (if standard); o Turn off the vehicle and set the parking brake; o Exit the vehicle and place two wheel chocks on one rear wheel (one in each

direction); o Restart the vehicle and complete the task; o After the task is completed, turn off the vehicle and ensure the parking brake is set

prior to removing the wheel chocks; and o Remove keys from parked vehicle (except on active job sites) and close all doors.

Chock the rear wheels when parking any one-ton or larger truck. Manual transmissions

must be left in first gear and automatic transmissions in park when the engine is in the off mode;

Chock the wheels of other mobile equipment, such as trailers; When parking on an upgrade, turn steering wheel from the curb; and When parking on a down grade, turn steering wheel toward the curb. It is required that employees use the mobile Do Not Disturb (DND) function on their

mobile device, if available, to prevent possible distractions.

2.10 Rental Vehicles

All safety rules and procedures apply to rental vehicles driven for business purposes on behalf of the Company.

2.11 Federal, State, Intrastate, and Interstate Licensing

EQT’s Fleet Manager manages all licensing and reporting, including for state and apportioned registrations; Federal Motor Carriers Safety Administration/USDOT; International Fuel Tax Agreement (IFTA); WV Motor Carrier Road Tax (MCRT); and all requirements related to the Department of Energy Alternative Fuel Vehicle.

It is the driver’s responsibility, with support from Corporate EHS Department, to ensure the vehicle complies with all federal, state, interstate and intrastate licensing regulations, including those of the USDOT, IFTA and MCRT. Drivers must maintain appropriate documentation in the vehicle and ensure all required decals are displayed appropriately.



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Summary of Primary Compliance Requirements for USDOT: All company-owned motor vehicles with a Gross Vehicle Weight (GVW) or Gross Combined Weight (GCW) if towing a trailer over 10,000 lbs., are classified as commercial, subject to USDOT regulations and required to display EQT’s USDOT number. All drivers of these vehicles must:

o Obtain and carry a medical certificate; o Have a Driver’s Qualification File maintained on their behalf; o Follow hours of service regulations unless otherwise exempt; o Complete a vehicle inspection at the beginning of each work day; o Complete the required vehicle inspection at the end of each day’s work;

o The Driver’s Vehicle Inspections Form must be completed if defects are noted during the vehicle inspection.

If used to tow a trailer, the Gross Combination Weight Rating (GCWR), which is the vehicle plus trailer, must be used to register that combination and drivers must have received trailer towing training prior to conducting a journey with a trailer. Additionally, drivers who are towing a trailer shall complete the Pre-Use Utility Trailer Inspection prior to use.

2.12 Additionally the Fleet Administrator is responsible for ensuring compliance with:

IFTA requirements: All vehicles over 26,000 lbs. GVW and registered under the International Registration Plan (IRP) must display the required IFTA sticker and ensure that vehicle operators have the required Commercial Driver’s License (CDL).

MCRT requirements: All vehicles over 26,000 lbs. GVW and not registered under the IRP must display the required state MCRT sticker and ensure that vehicle operators have the required CDL.

For details on USDOT compliance, please follow this link: http://www.fmcsa.dot.gov/rules-regulations/rules-regulations.htm

2.13 Insurance

The valid and applicable insurance card is to be kept in the vehicle and produced on demand as evidence of insurance.

2.14 Drivers’ Licenses

Employees required to drive automotive equipment in connection with their work are responsible for obtaining and maintaining a valid driver’s license appropriate to the type and weight of the equipment being driven and provide to EQT upon request.

EQT will review each CDL driver’s state MVR annually, and reserves the right to obtain and review any Authorized Driver’s motor vehicle record and obtain a state Motor



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Vehicle Record (MVR) at any time.

2.15 Revocation of Driving Privileges

Revocation of driving privileges may be implemented for reasons as deemed by EQT.

2.16 Authorized Driver’s responsibility for monthly vehicle inspections using the EQT Monthly Vehicle Inspection Form

All drivable vehicles are required to have a monthly vehicle inspection. Where vehicles are not assigned to a particular driver, the supervisor must ensure the

inspection is completed and documented.

2.17 Maintenance and Care

Company vehicles require periodic maintenance to ensure safety and longevity. Each Authorized Driver must maintain the Company vehicle in accordance with the manufacturer’s specifications and EQT.

2.18 Fueling

All company vehicles will be fueled with the correct grade of diesel, standard unleaded gasoline, or Compressed Natural Gas, whichever is appropriate. Premium fuels are not to be used. Fuel, only for EQT business purposes, will be purchased using an approved fuel card. A commercial card should only be used in case of an emergency for fuel.

3 EQUIPMENT

3.1 Communications Equipment Operation

A driver must use hands-free communication equipment with a single touch to the headset or voice activation technology.

Restrict all cell-phone use to brief conversations and avoid unnecessary calls. Suspend conversations when driving conditions become hazardous, especially in adverse

weather, heavy traffic, or other difficult driving conditions. Comply with all federal, state and local laws regarding cell-phone usage.

3.2 Fire Extinguisher

Fire extinguishers will be provided as part of the fleet ordering process and be equipped with the appropriate size and type based on the EQT employee’s job functions.

Immediately replace any defective or discharged unit with a properly functioning, inspected unit.

3.3 Tire Chains



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Tire Chains should be considered as a device to get safely home or to another safe location.

Follow the manufacturer’s instructions when installing or removing tire chains. Wear proper PPE, keep yourself in a safe location when adjusting tire chains; ensure the vehicle is in park; the parking brake used; and turn off vehicle before installing, adjusting or removing tire chains.

4 RECORD RETENTION

4.1 All completed vehicle inspection checklists and DOT Required documentation shall be maintained for a period of 3 years.


5.1 EQT Authorized Drivers

Always operate a motor vehicle in a safe and legal manner; Walk around the vehicle and complete required daily checks for safe operation; Maintain company vehicle in accordance with EQT and the manufacturer’s

specifications; Complete inspection or maintenance is necessary; Ensure, with support from the Fleet Administrator, vehicle complies with all federal,

state, interstate and intrastate licensing regulations, with all USDOT, IFTA and MCRT regulations and displays required decals; and

Maintain appropriate documentation in the vehicle. Report all EQT vehicle incidents, accidents and near misses to the Emergency Dispatch

Hotline at 1.833.990.1534

5.2 EQT Supervisors

Participate in the evaluation of driver performance during annual performance reviews and after vehicle accidents; and

Support organization of driver training for Authorized Drivers. Notify Corporate EHS Department of the location of the vehicle and keys when an

assigned driver is no longer with EQT, or no longer drives an EQT vehicle.

5.3 EQT Human Resources

Maintains driver information for each employee who operates vehicles regulated under USDOT; a medical certificate for Authorized Drivers; a driver’s qualification file, and appropriate driving safety records.

5.4 EQT Corporate EHS



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Investigates all accidents involving a motor vehicle used in performing company business.


Maintain a valid driver’s license rated for the class of vehicle being operated; Obey all federal, state and local traffic laws; Maintain a verified Driving Safety program in ISNetworld and if regulated by DOT,

maintain a satisfactory DOT motor carrier safety rating; Ensure safety checks before beginning each shift to ensure parts, equipment and

accessories specified in 29 CFR 1926.601(b)(14) are in safe operating condition and free of apparent damage that could cause failure while in use; and

Comply with inspection procedures outlined in 49 CFR Parts 393 & 396 for commercial motor vehicles regulated under the Federal Motor Carrier Safety Administration (FMCSA).

Prohibited from operating motorcycles on EQT field locations including access roads. Report all Vehicle incidents to EQT Emergency Hotline at 1.833.990.1534 Obey all traffic control plans, All EQT posted signs, speed limits, and school bus

curfews. 6 DEFINITIONS

Authorized Driver: an individual whose job includes operating a fleet vehicle to conduct company business and who has been authorized by supervisor to operate vehicle. Personal Use: miles not driven by an Authorized Driver for the business of the Company. (Commuting between home and office is considered to be personal use.)

Qualified Non-Personal Use Vehicle: an EQT vehicle that meets all of the following criteria:

Is marked clearly with approved company decals; Is fitted with added provisions in accordance with federal income tax law regarding company provided vehicles; and Has been assigned to an employee as an essential work tool to enable the employee to perform normal daily work.

Preventable Vehicle Accident: one that results in injury and/or property damage where the Authorized Driver’s actions either caused or contributed to an accident that reasonably could have been foreseen or avoided. Non-preventable Vehicle Accident: one that results in injury and/or property damage, though the Authorized Driver did everything within his or her control to avoid the accident and the circumstances causing it reasonably could not have been foreseen or avoided.


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1 PURPOSE AND SCOPE

1.1 The purpose of the Gas Hazards Program is to outline procedures related to production of natural gas and associated hazards at EQT locations.

1.2 The procedures do not apply to atmospheric monitoring related to confined-space entry. For gas

monitoring in confined spaces, refer to the EQT Confined-Space Entry Program.

2 MONITORING REQUIREMENTS

2.1 All EQT locations where the potential for oxygen deficiency or hazardous gases could be present must have adequate monitoring and detection systems or devices to detect potential hazardous environments to employees and business partners. Hazardous gases include, but are not limited to:

Oxygen deficient/enriched atmospheres Flammable or Combustible gases Hydrogen Sulfide Carbon Monoxide Methane Natural Gas

2.2 A gas detection device is required when workers are performing tasks or activities in a known or

likely gaseous environment. Regardless of the location, such tasks or activities requiring use of a gas detection device include:

Excavations with potential for an oxygen-deficient and/or hazardous atmosphere; Confined space (permit and non-permit); Hot work and tank work (e.g., manual tank gauging, maintenance/service); Pigging operations and work with venting or leaking gas; Filter Changes; Working around the gas buster and flowback storage tanks (cold venting perimeter); Installing anodes, coupon retrieval or other corrosion-related work; Hot Oiling Pipeline tie-ins and parting pipe; Operational procedures that require a monitor be worn; and Other tasks as determined by operations as noted on the RHA.

Note: This is not an all-inclusive list and is provided only for guidance.



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2.3 Gas detection devices are required to remain on and be worn within 1 foot of the breathing zone, unobstructed by outer garments, while personnel are performing tasks in areas that have the potential for a hazardous atmosphere.

2.4 If performing area monitoring, it is acceptable for the monitor to be placed in the work area

where the space can be actively monitored and all alarms are within range of the user.

2.5 Gas detection devices shall be calibrated and bump tested in accordance with manufacturer recommendations or company policy.

2.6 Employees are not permitted to alter the gas detection device in any manner that limits the

capabilities of the device. 2.7 Gas detection devices must be selected and only used for the chemicals they are designed to

detect. These devices must have an appropriate detectable range for the chemicals they are trying to sample to provide adequate warning to employees if they are at risk of exceeding established occupational exposure limits.

2.8 If used in a potentially explosive environment, such as Class 1, Division 1 or 2 locations as

defined by API 505 and/or NFPA 497, the monitoring devices must be designed to be used in these areas without presenting a potential ignition source.

2.9 The gas detection device shall be designed to sense the following within the noted limits:

Oxygen – 19.5 percent low, 23 percent high; Lower Explosive Limit (LEL) – 10 percent low, 20 percent high; Hydrogen Sulfide – 10 ppm low, 15 ppm high; and Carbon Monoxide – 25 ppm low, 100 ppm high.

2.10 Personal monitoring systems must alert personnel of elevated concentrations of hazardous

atmospheres with a combination of visual and audible alarms. Area monitors will alert employees with an audible alarm.

3 ALARM RESPONSE PROCEDURES

3.1 When an alarm sounds, personnel must view the monitor screen to identify which alarm has been

activated. If an oxygen, carbon monoxide or hydrogen sulfide alarm sounds, employees must: Stop work immediately; Exit the work area safely; Re-assess the area to identify and mitigate risks; and Exit the area completely and notify supervision if the alarm continues to sound.



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3.2 If the LEL alarm sounds during activities that have the potential to cause a fire due to elevated temperatures, sparking tools or non-intrinsically rated tooling or equipment, or others that might pose immediate danger to life and health, employees must follow the bulleted directions listed in Section 3.1. Examples of such activities include hot work, working with non-sparking tools, working near high-temperature equipment, and working in confined spaces.

3.3 If the LEL alarm sounds during activities where the risk of fire or an Immediately Dangerous to

Life or Health (IDLH) atmosphere does not exist, employees must:

Stop Work; Reassess the area to identify and mitigate risk; and Continue to monitor the area.

4 GAS CONDENSATE AND NATURAL GAS LIQUIDS (NGLS)

4.1 Gas condensate and NGL may be expected in any formation where natural gas is being extracted. 4.2 EQT employees and business partners must highlight any work to be done on a condensate

producing location using the Hazard Assessment Form. Electronic equipment, cellular phones and other devices not rated for use in flammable atmospheres must be used only in accordance with the EQT Hot Work Program.

4.3 All associated temporary or portable holding tanks and pits must be labeled properly with an

EQT-approved sticker, magnet, or sign. 4.4 Personnel working on condensate producing locations must be familiar with the SDS for gas

condensates. 4.5 When the presence of gas condensate or NGL is suspected in any temporary pit, tank or

container, appropriately trained personnel on location may use a water or hydrocarbon-finding paste (e.g., KOLOR KUT®) to determine the amount of product in the container.

4.6 Only approved and rated tools and equipment (marked as being acceptable for use in Class I

areas) shall be used in the presence of gas condensate and NGL unless used in accordance with a hot work permit.

4.7 Handling flowback/impaired water during completions work:

The layout of flowback/completions tanks must be agreed upon by operations

management and adhere to the spacing guidelines for fixed facilities. Notify completions operations managers as soon as condensate is detected. Store condensate in tanks in a designated flammable zone.



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Place appropriate signage on condensate tanks to designate them clearly. Ensure trucks loading condensate are grounded and a minimum of 50 feet from tanks and

wellheads within the containment area. Trucks must be DOT-approved vacuum trucks. Drivers also must be DOT-certified.

4.8 Handling flowback/impaired water during water transfer:

At all times, attendants monitoring operations must wear a gas monitor equipped with an

LEL sensor. Monitor for condensate and use KOLOR KUT® according to manufacturer’s directions.

o Immediately cease operations in the affected area if LEL monitor readings reach 10 percent or higher. Evacuate the area until the source is determined and mitigated.

o Workers also must continually evaluate LEL monitor readings between one percent and nine percent for any change in conditions and to determine if there are hazards or health concerns.

5 FLUID TRANSFER

5.1 All flammable and/or combustible liquid storage tanks must have the appropriate labeling,

including flammability hazard identification. 5.2 EQT Employees and business partners handling flammable and combustible liquids must be

trained properly. Truck transfer operations must be conducted under the control of the DOT-trained truck driver.

5.3 Atmospheric testing for flammable vapor levels around the transfer area must be performed

continuously during pumping of the tank using properly calibrated monitoring equipment or 4 gas monitors to ensure flammable vapors are being managed adequately.

5.4 During Fluid Transfer, the operator must leave the truck cab and stay within 25 feet of the truck

(between the truck and the storage tank) throughout the operation. The operator must be ready to quickly close the product valve and/or stop the pump in the event of an unexpected situation (line blockage/material release, etc.) The truck operator must stand upwind when possible and within the line of sight of the transfer operation at all times while monitoring transfer operations and wind direction. All potential ignition sources, including cell phones, electronic equipment, lighters, smoking (no smoke breaks are allowed), e-cigarettes, and other spark-inducing items must be removed.

5.5 Use of trigger locks is prohibited on all fueling nozzles. In addition, no fluid transfers may be left

unattended. 5.6 A fire extinguisher rated not less than 20B must be provided within 50 feet of Fluid Transfer



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operations. 5.7 All fluid transfer trucks must be grounded prior to beginning the transfer. Only conductive hoses

shall be used for all fluid transfer operations. If location is equipped with a truck vent for vapor recovery, it must be used by the operator.

5.8 All equipment used for fluid transfer must meet all applicable regulatory requirements and use

NFPA 30 best practices where applicable. 5.9 Flammable liquid transfer must not begin until all hazards associated with the operations are

controlled. 5.10 Transfer operations must stop immediately if any items, including valves, vapor recovery

systems, hoses, wiring, grounding rods, or bonding wires are found to be in poor condition or working improperly. The transfer cannot resume until corrections are made.

6 TANK GAUGING

6.1 Tank gauging should not be performed by lone workers if possible. If gauging is to be done by a

lone worker, they must check in with their supervisor immediately before and after gauging. If possible, sources filling the tanks should be isolated prior to gauging.

6.2 Wear, in the breathing zone, a properly calibrated and bump tested 4-gas monitor for the task. 6.3 Use only rated and approved equipment, including explosion-proof lights, gauging and level

equipment capable of being bonded to the tank and designed to be spark and explosion proof. 6.4 Cellular phones and other electronic devices; smoking, lighters or other open-flame or spark-

producing equipment and unauthorized personnel are prohibited within the containment walls of any EQT tank battery.

6.5 Prior to gauging any tank, open a hatch on the furthest tank (commingled tank battery) or hatch

on a single tank and bleed the pressure slowly before completely opening the hatch. All of the hatches to the tanks to be gauged can be opened to alleviate the pressure and balance the atmospheres of the desired tanks. Allow gas to vent a minimum of 15 seconds prior to conducting work upwind of tank hatches.

6.6 Gauging should be done with wooden probes, when possible. If metal tape or rods must be used,

prior to gauging any tank, the operator must connect the bonding strap on the gauging tape to a clean metal surface before dropping the tape into the tank.

7 PYROPHORIC HAZARDS



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7.1 Pyrophoric iron sulfide may exist in gas processing equipment. A Pyrophoric reaction, spontaneous combustion of the material, can occur when exposed to air. It is infrequently seen in filter changes and pigging operations. Once it exists in a given location, it is likely to occur more frequently.

7.2 When changing filters or pigging, a 20BC fire extinguisher must be available within 50 feet. 7.3 If combustion begins to occur, typically smoking at the onset, a fire extinguisher can be used to

slow the reaction. Flammables and combustibles must be removed from the immediate area and additional fire extinguishing equipment brought in. Water and/or water and dish soap can also be used if available to smother the pyrophoric media. An air tight container should then be used to transport the pyrophoric media.

7.4 If a known pyrophoric hazard exists in an area, the area needs evaluated to determine a plan for

future filter changes and/or pigging operations.

8 TRAINING 8.1 All personnel using personal gas monitors must be trained in the calibration, use, storage, and

maintenance procedures for each type of device that will be used. 8.2 All personnel will be trained on the hazards associated with this gas hazards program to which

they could be exposed, and the measures they can use to protect themselves.


9.1 EQT Supervisors

Implement this Program and ensure an appropriate quantity of gas monitors are available to complete operations.

Senior management will enforce actions related to violations of any requirements.

9.2 All Personnel

Adhere to this Program during all work operations.


Orders and completes the initial equipment set-up; Provides technical information and assists in implementing an effective Gas Hazards

Program; and



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Reviews and revises the Gas Hazards Program to ensure compliance with applicable regulations.


Business partners must have a verified Gas Hazards Program in ISNetworld if they could work in a gas hazard environment.

10 DEFINITIONS

Bump Test: a response to an expected or detectable concentration of gas to ensure the detector and sensors respond to the gas. Gas Condensate or Natural Gas Liquids (NGL): dissolves in saturated natural gas that come from the solution when the pressure drops below the dew point. Synonyms: Condensate, Y-grade, raw product, produced water, pipeline drip, drip gas, formation water, oily water, high-pressure inlet liquids, and retrograde. Hydrocarbons include ethane, propane, butane, isobutene, and pentanes. Typically, pentanes and heavy hydrocarbons are recovered at the well site while light hydrocarbons are recovered at inlet scrubbers or separators of processing plants.

Hazardous chemical: any classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. Hazardous atmosphere: one that could expose employees to the risk of death, incapacitation, impairment of ability to self-rescue (escape unaided from a permit space), injury, or acute illness from one or more of the following:

Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; Flammable gas, vapor, or mist in excess of 10 percent of its lower explosive limit (LEL); Airborne combustible dust at a concentration that meets or exceeds its LEL; Atmospheric concentration of any substance for which a dose or a permissible exposure

limit is published in 29 CFR 1910 Subpart G, Occupational Health and Environmental Control, or in 29 CFR 1910 Subpart Z, Toxic and Hazardous Substances, and that could result in employee exposure in excess of its dose or permissible exposure limit; and

Any other atmospheric condition that immediately is dangerous to life or health.

Lower Explosive Limit (LEL): the lowest concentration of a gas or vapor in the air capable of producing a flashfire in the presence of an ignition source. Occupational Exposure Limit: one established by an agency, such as OSHA or NIOSH, which sets the maximum concentrations of a chemical to which employees can be exposed over a specified period of time.


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1 PURPOSE AND SCOPE

1.1 The purpose of this Hazard Assessment and Control Program is to outline a systematic process to identify and mitigate hazards associated with work tasks for EQT employees. EQT follows a Risk and Hazard Assessment (RHA) process to allow an inclusive approach to hazard identification, assessment, control, and communication.

2 PRE-TASK ASSESSMENT

2.1 For all work tasks completed on any EQT location, a hazard assessment must be completed prior

to beginning work. The risk and complexity of the planned work task shall dictate the level and detail of the hazard assessment.

2.2 Business partners must develop their own hazard assessment process to allow an inclusive

approach to hazard identification, assessment, control, and communication. 2.3 For lone-worker and routine tasks performed on a consistent or recurring basis, EQT employees

must perform a pre-task assessment. The pre-task assessment is a formal, undocumented review of the work area and evaluation of the anticipated task steps. The pre-task assessment must be completed at the work location and include five critical questions:

What hazards or risks are in the area? How could I get hurt? Are the necessary personnel, equipment, and controls in place? What else could go wrong? Do we need to, or have we, changed our plan?

3 HAZARD ASSESSMENT

3.1 Additionally, EQT requires its employees to complete a formal Risk and Hazard Assessment

(RHA) for non-routine tasks (those performed infrequently or for the first time) or tasks with two or more people.

3.2 An RHA leader must be selected to gather all EQT employees and business partners directly

assisting EQT employees on a proposed work task. Collectively, they will facilitate completion of the RHA.

3.3 Business partners must develop and follow their own hazard assessment process to allow an

inclusive approach to hazard identification, assessment, control and communication, when



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completing work tasks on EQT locations. Business partners must coordinate with all other operations on EQT locations to ensure hazards are identified and mitigated.

3.4 The individual completing the Hazard Assessment must:

Identify all the job tasks on the Hazard Assessment Form (Appendix A for EQT

Employees); Identify hazards and risks associated with each job task; and Use the Hierarchy of Controls, if warranted, to determine mitigation measures.

3.5 Identify on the Hazard Assessment Form and discuss all applicable safety programs, work

permits and work procedures. Discuss how these apply and the steps necessary to take before work begins.

3.6 If a hazard cannot be adequately mitigated, contact the EQT Corporate EHS Department for assistance.

3.7 The Hazard Assessment shall be revisited any time there is a change to personnel, equipment,

processes, or standard operating procedures to determine if the controls identified still apply. If they do not apply, the Hazard Assessment must be revised and the change communicated to all involved workers.

4 RECORD RETENTION

4.1 All completed EQT RHA Forms (Appendix A) shall be kept on file for two years.

5 TRAINING

5.1 All EQT employees will be trained in the requirements and use of the Hazard Assessment

process and appropriate completion of the EQT RHA Form (Appendix A). Refresher training will be provided annually.

5.2 The EQT supervisor or designee will instruct business partners working alongside EQT

employees on this Program. 5.3 If business partners are working on EQT locations independent of EQT employees, they must

follow their own Hazard Assessment and Control Program that must include some form of job hazard analysis that meets the minimum requirements of this program. The form must be completed for all business partner tasks and must be available to EQT upon request.



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6.1 EQT Supervisors

Ensure RHA are conducted and properly documented by employees in accordance with the requirements of this policy; and

Retain for two years a record of completed RHA Forms (Appendix A).

6.2 EQT Employees

Adhere to this Program during all work operations; Conduct and document an RHA before starting work that requires two or more people to

perform the assigned task(s); Participate in the RHA and implementing controls; and Look for hazards and immediately communicate changes or concerns.


Provides technical support and training to EQT supervisors and employees for

completing the requirements of the Hazard Assessment and Control Program; Documents and maintains all training records; and Audits and evaluates completed RHA Forms (Appendix A) to evaluate the effectiveness

of this Program.


Adhere to this Program during all EQT work operations. Complete a Hazard Assessment prior to beginning work on all EQT locations. Identify hazards, controls, and communicate changes or issues.

7 DEFINITIONS

Hazard: is any source of potential damage, harm or adverse health effects on something or someone.

Risk: probability or threat of damage, injury, liability, loss, or any other negative occurrence that is caused by external or internal vulnerabilities.



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Title Hazard Communication Program

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1 PURPOSE AND SCOPE

1.1 The purpose of the Hazard Communication (HazCom) Program is to ensure EQT employees and business partners have access to information about the hazardous properties of the chemicals they use or might be exposed to at work. Consumer products used by EQT for the purpose intended by the chemical manufacturer of the product are exempt from this Program.


2.1 All personnel who use or handle hazardous chemicals must conduct work in accordance with this Program. All personnel must be familiar with the contents of the HazCom Program, properties of hazardous chemicals in their work area and measures to protect themselves from those chemicals.

2.2 EQT and business partners will communicate about hazardous chemicals that could be

encountered in the normal course of their work at EQT locations. 2.3 Activities will be reviewed prior to starting tasks to identify hazardous chemicals, using the

hierarchy of controls to address them. 2.4 Where non-routine tasks are to be performed (e.g., confined space entry, spill clean-up, welding),

the supervisor will determine if specific procedures need to be developed due to the presence of hazardous chemicals.

3 MULTI-EMPLOYER WORKSITES

3.1 At multi-employer worksites, EQT requires each business partner to comply with applicable

hazardous chemical regulations.

Business partners are responsible for training their personnel and maintaining their training records.

Each business partner must also notify EQT and other employers on the worksite as to where the business partner’s Safety Data Sheets are located and provide access to them if requested.

EQT will inform business partners of the location of the EQT HazCom Program and the Safety Data Sheets that EQT has on each site. At the request of the business partner, EQT will provide copies of them.



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4 SAFETY DATA SHEETS (SDS)

4.1 Safety Data Sheets provide information about the hazards of chemicals and protective measures when using such chemicals. Safety Data Sheets are prepared and issued by chemical manufacturers and distributors.

4.2 Manufacturers and distributors are required to provide Safety Data Sheets with the initial

shipment of any product that contains hazardous chemicals. If a product is received without Safety Data Sheets, the supervisor must ensure the manufacturer or distributor is notified in order to provide the applicable Safety Data Sheets.

4.3 Safety Data Sheets for chemicals handled or stored on site are maintained in an electronic

database.

When using electronic means to supply Safety Data Sheets to employees, the supervisor must ensure that reliable devices are readily accessible in the workplace at all times.

If the online database is inaccessible, hard copies of the Safety Data Sheets must be present at the worksite.

4.4 Company vehicles that transport hazardous materials will be equipped with an emergency guidebook and/or Safety Data Sheets. They must be kept in a place (e.g., driver side door pocket or next to the driver’s seat) safely and immediately accessible to the driver.

5 HAZARDOUS CHEMICAL INVENTORY LIST

5.1 The EQT inventory of hazardous chemicals will be located in the Safety Data Sheets electronic

database. 5.2 The product identifier referenced on the supplier Safety Data Sheets will also serve as the

identifier for the chemical inventory.

5.3 The EQT Corporate EHS Department will assure the Hazardous Chemical Inventory List is updated in the electronic database.

6 LABELING REQUIREMENTS

6.1 All employees are responsible for ensuring containers of hazardous chemicals coming into,

within, or leaving the worksite are adequately labeled. If there are questions about a hazardous chemical not answered by the label, then the SDS can be referenced for additional information.



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6.2 Every container of hazardous chemicals, including secondary containers into which portions of another container have been transferred, must be labeled. The only exception is if a worker transfers a small amount into a container for that worker’s immediate use.

6.3 No personnel may remove or deface existing labels on containers unless the label is immediately replaced with a new label containing the required information.

6.4 If a label is missing or illegible, the supervisor is responsible for assuring that a replacement label is obtained and affixed to the container.

7 IDENTIFICATION OF PIPELINE CONTENTS

7.1 The contents of pipelines may be identified using any of the following methods: Color coding or labeling; Unlabeled piping traceable to a stationary vessel; and Process flow diagrams.

7.2 Once the contents of the pipeline have been identified, the hazards of the pipeline contents can

be obtained by reviewing the appropriate Safety Data Sheets.

7.3 In accordance with provisions of the Globally Harmonized System (GHS), SDS must also be developed for EQT-introduced content or unique product.

8 TRAINING

8.1 EQT Employees who work directly with hazardous chemicals or might otherwise be exposed to

them must be given training at the time of initial assignment and when a new hazardous chemical is introduced. Training will address:

Requirements of the OSHA Hazard Communication Standard; Operations in employees’ work areas where hazardous chemicals are present; The EQT Hazard Communication Program and SDS; Methods of detection and identification of hazards in the workplace and work practices to

avoid potential hazardous situations when working with hazardous chemicals; Measures employees can take to protect themselves from chemical hazards; Explanation of labels received on shipped containers (GHS labeling classification); Workplace labeling system used by EQT (e.g., NFPA and HMIS); and



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Using hazardous materials for non-routine tasks (e.g., cleaning tanks, entering confined space, welding).

9 RECORD RETENTION

9.1 The EQT Corporate EHS Department will keep training records on file 5 years. Records will include a roster of attendees, dates, summary of content, and the instructor’s name. SDS must be retained in the chemical inventory for the duration of use on EQT locations and archived in compliance with regulatory requirements.


10.1 EQT Supervisor

Implements this Program and develops site-specific applications; Ensures workplace labels are legible and prominently displayed on all hazardous

chemical containers and that containers are relabeled if labels have been removed or defaced;

Ensures EQT employees maintain their HazCom training at the time of initial assignment; and

Ensures SDS readily are accessible to employees for all hazardous chemicals in their workplace.

10.2 EQT Employees

Adhere to the provisions of this Program and attend required HazCom training; and Ensure labels are legible and prominently displayed on all hazardous chemical containers.


Follow all federal, state and local regulations for requirements regarding HazCom, along

with provisions of this Program; and Maintain a verified ISNetworld Hazard Communication Program. Provide training related to this Program.

10.4 EQT EHS Department

Monitors and reviews annually this Program to assure compliance; Trains EQT employees and conducts audits related to this program;



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Maintains oversight of the SDS information system; and provides program-related technical assistance.

11 DEFINITIONS

Globally Harmonized System (GHS): a structure under which chemicals are classified and labeled, including criteria for classifying health, physical, and environmental hazards, as well as specifying the information to include on labels for hazardous chemicals and Safety Data Sheets.

Hazardous Chemical: any chemical classified as a physical or a health hazard; a simple asphyxiant, combustible, dust, pyrophoric gas, or hazard not otherwise classified. Health Hazard: a chemical classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific-target organ toxicity (single or repeated exposure); or aspiration. Hazardous Materials Identification System (HMIS): designed for individual product containers that do not have a manufacturer’s label or same color/numerical rating system as the National Fire Protection Agency (NFPA) Fire Diamond. NFPA Fire Diamond: a color-coded, numerical system for indicating health, flammability and reactivity hazards of chemicals.

Pictogram: a composition that could include a symbol and other graphic elements, such as a border, background pattern or color, intended to convey specific information about the hazards of a chemical. Nine pictograms are designated under this standard for application to a hazard category. Precautionary Statement: phrase that describes recommended measures to take to minimize or prevent adverse effects resulting from exposure to hazardous chemical or improper storage or handling.

Signal Word: one used on the label to indicate the relative level of hazard severity and alert the reader to a potential hazard. Signal words used in this section are “danger” and “warning.”


Title Hazardous Material Management

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1 PURPOSE AND SCOPE

1.1 The purpose of this Hazardous Materials Management Program is to define procedures and precautions that must be followed for safely managing hazardous materials on EQT locations.

2 FLAMMABLE AND COMBUSTIBLE MATERIALS

2.1 Transportation and Storage General Requirements

• Store and transport flammable liquids only in shipping containers or applicable

color-coded cans designated for this purpose.

o Red: color-code for safety cans containing flammable liquids, such as gasoline, with a flashpoint below 100°F.

o Yellow: color-code for safety cans containing combustible liquids.

• Contents of safety cans must be identified with a label specifying the hazardous chemical and the appropriate hazard warning.

• Flammable or combustible liquids must not be stored in areas, such as exits and stairways, normally used for the safe passage of people.

• Storage of flammable or combustible liquids in a room outside an approved storage cabinet is restricted to no more than 25 gallons.

• Company-approved metal storage cabinets are acceptable if:

o Cabinets area labeled in conspicuous lettering, such as “Flammable, Keep Away From Fire.”

o Storage of flammable liquids is restricted to 60 gallons in one approved storage cabinet.

o Storage of combustible liquids is restricted to 120 gallons in one approved storage cabinet.

• Maintain cans in safe operating condition and ensure legible identification at all times. • Cans containing flammable liquids must not be transported in motor vehicle trunks or

compartments containing two-way radios. • Approved cans for flammable liquid storage or transportation must be constructed by

welding and equipped with the following safety features:

o Pressure relief; o Spring action, automatic closing cover; o Perforated sheet metal flame arrester with a machine thread connection; and o Flexible metal dispensing hose.



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2.2 Gasoline

• Store gasoline in a red-colored safety can with a maximum five-gallon capacity, spring-closing lid and spout cover designed to relieve internal pressure if can is subjected to fire exposure.

• Ensure ventilation is provided for all rooms, buildings or enclosures in which gasoline is handled.

• Clearly label gasoline storage areas with either of the following:

o “Gasoline Storage Keep Fire Away” o “Flammable Keep Fire Away”

• Immediately remove leaking containers and ensure combustible materials are not stored

near gasoline. • Contain any spillage and recover product as safely feasible. • Use absorbents to clean residual gasoline. • Remove immediately any gasoline-soaked clothing, and wash with soap and water the part

of the body that had been exposed to the gasoline. • Never use compressed air for emptying gasoline. • Avoid static discharge by using appropriate bonding between containers. • Ensure all gasoline mixers, filters, pumps, and engines are grounded electrically in an

effective manner. • Proper and adequate firefighting equipment must be provided at accessible locations. • Leaking gas tanks must be repaired and replaced by the supplier. • Gasoline pumping or refueling:

o Smoking, matches or open lights are prohibited near gasoline pumps; o Ignition and mobile radio systems must be off during refueling; o Vehicles and other engine-driven equipment with fuel tanks near the engine must

not be refueled while the engine is hot; and o Do not refuel within 25 feet of an operating engine.

2.3 Supplemental Chemicals, such as chromate compounds, methanol, acids, alcohols, and ethylene

glycols, can be hazardous to personnel due to their corrosive action, toxicity, flammability, and/or caustic characteristics. Improper handling and storage of these chemicals could result in burns, ulcers, fires, or explosions.

• Label clearly all chemical containers to ensure contents are marked. • Wear company-approved goggles and rubber gloves when handling chromate

compounds, acids, alcohols, and ethylene glycols. • Store containers in cool areas. • Clean spills immediately, flushing with water to prevent possible fire and toxic fumes. • Wash hands thoroughly after using chemicals and before eating and/or smoking.



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• Reseal the package before storing any unused content.

o Chromate compounds must remain in the manufacturer’s package or container until ready for use.

o Ensure chromate solution cylinders are labeled as “Chromate Solution.”

• Pour acid into water, never water into acid and mix in a well-ventilated area. • Use alcohol compounds in an open, well-ventilated area. • Ensure proper firefighting equipment is accessible when handling alcohol.

2.4 Liquefied Petroleum Gas (LP-Gas)

• All persons employed in handling LP-Gas must be trained in proper handling. • Ensure containers of LP-Gas are identified and labeled properly. • Place LP-Gas containers upright and in a stable position for transportation and use. • Weed burners must be equipped with a functioning dead man switch.

2.5 Painting Coating and Spraying

• Obtain Safety Data Sheets (SDS) for all paints that will be used. • Review the SDS for paint flashpoint, storage guidelines, hazardous ingredients,

spontaneous combustion hazards, and spill cleaning information prior to painting. • Wear PPE during all painting applications. • Adhere to non-smoking policy during operations using flammable or combustible paint. • Ensure paint containers either have the manufacturer’s label or an EQT-approved label

(e.g., National Fire Protection Agency Diamond). • Store flammable and combustible paints in a manner that isolates the product from

ignition sources. Open flames or other ignition sources are prohibited in storage areas. • Follow Section 5.0 for requirements associated with airborne lead if painting requires

removing existing paint as part of surface preparation. • Obtain supervisory approval for the application of any paint that has isocyanates,

formaldehyde, lead, cadmium, or chromium listed in the ingredient section of the SDS. • Ensure adequate ventilation is provided to control solvent vapors while painting indoors. • Follow policy for obtaining permit to paint in confined spaces. • Use only installation approved by supervisor for spray finishing that uses flammable and

combustible liquids (29 CFR 1910.107).

o Applying paint with a spray gun is a respirator-required task that must comply with the EQT PPE Program Section 3.9 respiratory protection.

• Ensure areas where spray guns are used have adequate ventilation to remove flammable vapors, mists or powders to a safe location and control combustible residues.



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• Consult with your supervisor or the EQT Environmental Department for appropriate response to all spills of more than one gallon.

• Consult with the SDS and your supervisor for proper disposal of remaining liquid paint. • Label and store in safety cans paint thinners, lacquers and other flammable and

combustible paint materials not in their original containers. • Transfer flammable liquids from one container to another by adhering to the EQT Fluid

Transfer Program. • Properly dispose of towels, rags, booth filters, paint scrapings, steel wool, masking and

other materials wetted or saturated with linseed oil, alkyd enamel resins and drying oils from paint to avoid spontaneous combustion of such materials.

o Thoroughly wet the contaminated materials with water. o Place them in a non-combustible container with a tight-fitting lid or in a water-

filled metal container. o Consult with your supervisor for other proper disposal methods.

3 ASBESTOS

3.1 All personnel with potential for exposure to asbestos will require asbestos awareness training. Personnel performing or supervising Class I through Class IV asbestos operations will require additional training.

3.2 Pipe and boiler wraps, fireproofing, acoustical plaster and ceiling tiles, drywall tape and

spackling, flooring, and roofing are examples of asbestos-containing material (ACM). 3.3 In buildings constructed before 1981, presumed asbestos-containing material (PACM) includes

thermal system insulation, spray fireproofing, trawled acoustic plaster, and asphalt or vinyl flooring and must be treated as such unless analytical testing shows it is free of asbestos.

3.4 Personnel must inform EQT of areas where they have found ACM or PACM. 3.5 OSHA regulations require a Competent Person be designated for all worksites where PACM or

ACM will be disturbed. The Competent Person must be trained in the aspects of handling asbestos and ensure appropriate notifications are made, as well as ensure compliance with training requirements and adherence to PPE.

• The Competent Person also must be capable of identifying existing asbestos hazards at the worksite and have the authority to take prompt corrective measures to eliminate them.

• OSHA regulations require a minimum of two hours of asbestos training per year for the Competent Person.

• Training may be accomplished with a combination of video presentation, policy review and classroom instruction.



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3.6 EQT Employees exposed to asbestos at or above the permissible exposure limits (PEL) also must be included in a medical surveillance program.

3.7 EQT will retain the following:

• Asbestos training records for one year beyond the last year of employment; • Respirator training and fit-testing records until the next fit test; • Medical records for the duration of employment plus 30 years; and • Air sampling results for at least 30 years from air sampling conducted to determine

airborne asbestos concentrations.

3.8 Medical examinations will be provided for EQT employees performing asbestos work for a combined total of 30 days per year or those exposed at or above PEL for 30 or more days per year.

3.9 Air monitoring generally will be performed by an independent business partner in accordance

with best practices and OSHA asbestos handling guidelines. 3.10 All PACM or ACM must be disposed properly according to federal, state and local regulations.

3.11 Establish area with red and black tape or “DANGER ASBESTOS” barrier tape if there is an

emergency and notify supervisor immediately.

4 POLYCHLORINATED BIPHENYLS (PCBs) 4.1 PCBs are industrial chemicals synthesized and commercialized in North America starting in 1929. They were used in the manufacturing of electrical equipment, heat exchangers, hydraulic systems, and several other specialized applications until the late 1970s. At EQT locations, they also

can be found in coal tar wrap.

4.2 Regulations require transformers and capacitors containing three pounds or more of dielectric be identified by PCB labels or marks placed on equipment by the owner or user. If they contain 500 ppm (0.05 percent) PCBs, they are designated PCB transformers or PCB capacitors. Mineral oil transformers containing 50 ppm (0.005 percent) PCBs are designated PCB-

contaminated transformers.

• All of the above are regulated for use and disposal. This does not necessarily mean that PCBs of lower concentrations or PCBs in small capacitors are not hazardous to human



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health and the environment. For purposes of this Program, “PCB-containing” means dielectrics containing any detectable quantity of PCBs.

4.3 It is important to be able to identify the potential sources of PCB-contaminated materials likely to

be encountered at EQT locations. Historically, the major source of PCB waste at EQT locations has been created when coal tar wrap was removed or PCB equipment decommissioned.

4.4 EQT shall identify and inventory potential and actual PCB-containing electrical equipment and

materials. Equipment and areas were PCB materials are located shall be marked clearly to ensure they easily are recognizable and not disposed inadvertently. Labeling also alerts individuals to the presence of PCB related to in-service equipment, thus assisting with inventory control, as well as during handling, storage and disposal.

4.5 Written records identifying PCB equipment and their locations are essential. Records should

include a serial number from the manufacturer nameplate or a company assigned number that has been placed on the equipment; dielectric identification from the nameplate; dielectric quantity, and PCB concentrations from lab analyses.

4.6 Additionally, PCB waste records for disposal shall include:

• Description of the PCB waste, including quantity and concentration of PCBs, and nameplate description where applicable;

• Method and dates that all PCB waste was transferred to the storage site; • Unique identification number for the PCB waste; • Date and name of individual who transported the material to the site; • Location of the waste; and • Methods for storage.

4.7 When equipment or material is suspected of containing PCBs, a test will be performed to indicate

the presence or absence of PCBs. If a laboratory sample through an accredited laboratory does not verify the equipment or material is PCB free, another sample should be sent for additional analysis to determine the extent of PCB contamination.

4.8 If PCBs are identified in areas of active EQT operations, employees working in that area will be

notified of the presence of PCBs. Employees will receive general awareness training on the potential health hazards associated with PCBs and how to locate the marks or labels that identify the material in the workplace.

4.9 PCB-containing materials are to be managed only by individuals trained to handle liquids. The

protective clothing to be worn will vary with individual circumstances, including concentration,



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quantity and form. Gloves (neoprene, nitrile rubber or vitron), boots, disposable coveralls, aprons, and eye protection should be worn as necessary.

4.10 Wastes contaminated with PCBs greater than 50 ppm require extra precautions for handling and

storage related to disposal. The EQT Corporate EHS Department must be notified prior to starting the removal process from a generating location to safe disposal.

5 AIRBORNE LEAD AWARENESS

5.1 Activities where the potential for a lead exposure are present will require initial air monitoring by EQT to quantify the level of exposure.

5.2 The Lead Exposure Assessment Report will list a range of exposure calculated as an eight-hour,

time weighted average (TWA).

5.3 Any activity or task where exposure levels have not been quantified will be presumed to be in excess of the PEL, 50 µg/m3 of air for an eight-hour TWA for general industry operations and 30 µg/m3 for construction activities.

5.4 Painted work surfaces involved in any welding, burning, scraping, or grinding and either are

unknown or suspected of lead will be tested for the presence of lead prior to beginning work. If unknown or impractical to test for lead, the paint will be treated as a presumed lead-containing material.

5.5 Exposure when working on lead-based painted surfaces must be controlled so that the eight-hour

TWA does not exceed the PEL of 50 µg/m3 for general industry operations and 30 µg/m3 for construction activities. Control methods will be developed depending on exposure levels.

6 MERCURY

6.1 Handling mercury improperly can expose employees to potential poisoning by inhalation, consumption or absorption.

6.2 Personnel will be trained on the methods of detecting mercury in the work area; its physical and

health hazards; measures necessary for protection from such hazards; and the use of labeling and SDS information.

6.3 EQT will provide applicable PPE, other equipment and materials for use by employees who will

be working with mercury.

6.4 Ensure food is not stored or eaten in areas where mercury is handled or used. Employees working with mercury should their wash hands before eating or touching any part of their skin, including the face and lips.



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6.5 Mercury that has potential for spillage should be handled over tables or containers with non-absorbent surfaces and a center drain. Collect and return safely to applicable container mercury that spills.

6.6 Immediately report spills to your supervisor. 6.7 Clean and coat with an HgX solution any area where mercury spills accidentally.

6.8 Store mercury in approved containers labeled “MERCURY,” and ensure label contains

appropriate hazard warnings. 6.9 Ensure container is upright in a locked storage cabinet posted: “WARNING – MERCURY

STORAGE AREA – AUTHORIZED PERSONNEL ONLY.” 6.10 SDS must be maintained and readily accessible to personnel handling mercury or working in

areas where it is handled.

7 RADIATION SAFETY

7.1 Personnel working with ionizing radiation and/or naturally occurring radioactive material (NORM) must follow a radiation safety plan that meets federal, state and local requirements.

7.2 Business partners must have a verified and compliant NORM and/or ionizing radiation program in ISNetworld based on their scope of work.

7.3 Personnel performing radiation work must have training documentation that meets their NORM and/or Ionizing Radiation Safety Program Requirements.

7.4 A hazard assessment must be used to determine the required PPE for tasks and operations that

have potential of radioactive exposure.

7.5 Except in designated areas, the following is prohibited; eating, drinking, smoking, and storage of food/beverages.

7.6 Transportation of radioactive materials must be in compliance with federal, state and local requirements.

7.7 Prior to conducting x-rays, properly isolate and barricade the radiation area to limit unauthorized

individuals and post appropriate warning signage at area perimeters. Notify all site personnel prior to starting x-rays.

7.8 Ensure other personnel, vehicles and equipment remain clear of the area where an x-ray

inspection is being conducted and wait for the inspection to conclude.



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7.9 Label all containers of radioactive materials in accordance with federal, state and local regulations.

7.10 Place all stored material in a designated, posted and secure location.

7.11 NORM Safe Work Practices

• Naturally Occurring Radioactive Materials (NORM) represent a wide range of

radioactive isotopes. The main radioactive elements of concern in oil and gas production are those found throughout the earth’s crust, and specifically present in formations from which oil and gas are produced. These elements include uranium and thorium and their respective related products, including radon gas.

• Personnel performing NORM measurement surveys may test all tri-axles, roll-off trucks and vacuum trucks leaving EQT locations before they are released from location to ensure there are no “hot” loads leaving the site without the knowledge of EQT.

8 SILICA

8.1 Business partners must maintain a verified and compliant program in ISNetworld on silica

exposure control.

8.2 Safety policies and procedures must be developed and implemented in compliance with OSHA 29 CFR 1910.1053 and all other applicable regulations.

8.3 Personnel overseeing and conducting work activities with a risk of silica exposure must be trained

on how to recognize exposure routes and how to protect themselves from overexposure. 8.4 Proactive measures must be implemented to ensure dust containing silica is maintained properly to

reduce exposure below the OSHA PEL of 50µg/m3, including engineering and work practice controls.

8.5 PPE may be used when all other means to control the silica hazard have been deemed infeasible.

Respirators used to control exposure to respirable dust must meet the applicable ANSI/OSHA requirements under 29 CFR 1910.134.

8.6 Areas where personnel could be exposed to respirable dust over the OSHA PEL must be

demarcated to alert personnel that they must be trained, authorized and properly protected with the appropriate PPE prior to entering the area. Signage must be posted throughout the areas and communicated to all personnel.

8.7 If exposures for a work task exceed the OSHA Action Limit (AL) of 25µg/m3 or the OSHA PEL

of 50µg/m3, then a periodic monitoring procedure must be established. Results of testing must be available to EQT upon request.



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9 HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (HAZWOPER)

9.1 The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard applies to five distinct groups of personnel. This includes personnel exposed or potentially exposed to hazardous substances, as defined by 1910.120(a)(1)(i-v) and 1926.65(a)(1)(i-v) and engaged in one of the following:

• Clean-up operations required by a governmental body, whether federal, state, local or other, involving hazardous substances at uncontrolled hazardous waste sites;

• Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);

• Voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;

• Operations involving hazardous wastes at treatment, storage and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations.

9.2 Personnel who must perform duties at a hazardous waste site that has not been characterized yet but where contamination is expected, fall under the scope of 29 CFR 1910.120. These workers must work under the direction of an on-site supervisor and a site-specific safety and health plan, and must be protected and trained fully pursuant to the HAZWOPER standard.

• When additional information through site characterization verifies minimal or no risk of employee exposure to hazardous substances, a lesser degree of PPE and worker training might be acceptable.

9.3 When site characterization shows the area to be serviced is free of potential exposure or the proposed work assignments would not expose any of the workers to hazardous substances, the activity may be implemented as a normal maintenance or construction operation.

10 INDUSTRIAL HYGIENE (IH) ASSESSMENTS

10.1 Industrial Hygiene Risk Assessment

• A qualitative IH risk assessment will be conducted by the EQT EHS Department for operations determined to have a reasonable potential for EQT employee exposure.

• Based upon the results of the qualitative assessment, a quantitative IH assessment may be conducted to collect baseline data to compare to the occupational exposure limits.



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• Business partners are responsible for developing their IH program and conducting IH risk assessments to evaluate levels of exposure to their employees. The business partner IH program, risk assessment and sampling must be available to EQT upon request.

10.2 Industrial Hygiene Assessment – EQT ONLY

• The quantitative IH assessment should be conducted by a Certified Industrial Hygienist or individual with knowledge of sampling methodology.

• All quantitative assessments must be conducted in accordance with their respective sampling methodology (i.e. NIOSH, OSHA).

• All collected samples must be sent using a chain of custody for analysis to a laboratory accredited by the American Industrial Hygiene Association (AIHA).

• Results will be compared to the occupational exposure limits. All results will be communicated to affected personnel. If an occupational exposure limit is exceeded, EQT will communicate to personnel on the controls that will be implemented to reduce the exposure to within established limits.

• All EQT records will be kept in accordance with 29 CFR 1910.1020 and the EQT Medical Records Program. EQT Employees will be notified of the availability of these records upon initial hire, thereafter, on an annual basis.

11 TRAINING

11.1 All EQT personnel exposed to hazardous materials covered under this Program must receive training, which includes:

• Health hazards associated with exposure to the hazardous material; • Workplace tasks that could result in exposure; • Measures, including engineering controls, work practices and PPE, that must be

implemented to safeguard from exposure; and • Any identified regulatory requirements associated with the hazardous material.



• Define compliance needs at their locations; • Ensure proper implementation and adherence to this Program; • Ensure asbestos training is implemented annually for employees who work in areas

where asbestos exposure could occur.




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• Implements this Program and delivers training; • Conducts risk assessments and schedules sampling; • Communicates employee exposure results to affected EQT employees and EQT Medical

Department;

12.3 EQT Corporate Environmental Department

• Conducts assessments, including waste characterization sampling and analysis, of waste streams as needed;

• Communicates disposal/inspection requirements to EQT supervisor; • Delivers training associated with waste management practices and recordkeeping; and • Completes required regulatory reporting.


• Adhere to this Program, including following controls to eliminate or minimize employee exposure.


• Develops and maintains EQT employee exposure records; and • Determines if EQT employee exposure results of IH testing exceed thresholds that trigger

medical protocols. 13 DEFINITIONS

Competent Person: one capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Combustible Liquid: one with a flashpoint that exceeds 100°F when assessed using closed-cup test methods. Flammable Liquid: one with a flashpoint that does not exceed 100°F when assessed using closed-cup test methods. Qualitative Industrial Hygiene Assessment: an evaluation of potential personal exposure to workplace chemicals and physical, radiological or biological agents based on personal experience and professional judgement. Quantitative Industrial Hygiene Assessment: an evaluation of actual personal workplace exposure to chemicals and physical, radiological or biological agents using accredited mathematical and numerical analysis.


Title Hearing Conservation Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Hearing Conservation Program is to establish requirements and responsibilities to protect employees exposed to excessive levels of noise at work. This Program applies to all EQT employees exposed to noise levels at or above an 8-hour time weighted average (TWA) of 85 dBA.

1.2 Business partners are required to have a hearing conservation program as applicable to their

scope of work and regulation. All other requirements of this program apply to EQT Employees only.


2.1 An employee’s daily noise exposure is dependent upon the sound levels and the duration of

exposure that exist in the work area on a typical day. A field employee might experience intermittent exposures to loud noise interrupted by periods of relative quiet (e.g., in office areas, outdoors, or in a company vehicle).

2.2 The reliable method of measuring intermittent noise exposure is with a noise dosimeter, or less

ideally, a sound meter. When noise exposure monitoring is not done with instrumentation, an employee’s noise exposure reasonably can be assumed to be in excess of the 85 dBA action level (as an 8-hour TWA) if the employee works most of the day in an environment where normal conversation is difficult without raised voices. Employees must be informed of noise monitoring results that indicate noise exposure above the action level of 85 dBA.

2.3 A copy of the OSHA Noise Exposure Standard must be made available to the employee.

3 MONITORING

3.1 EQT may conduct area and personal monitoring using a sound level meter and a noise dosimeter

survey, respectively.

3.2 Area monitoring may be conducted to determine noise levels on location. A sound survey map or diagram may be developed to indicate high-noise areas.

3.3 Monitoring may be conducted or repeated when there is a change in production, process

equipment or controls that might increase noise exposures and potentially expose employees to noise above the action level of 85 dBA.

3.4 All equipment used for sound level surveys will undergo a pre- and post-calibration test to

ensure it is operating efficiently. Equipment also shall be “factory calibrated” according to the manufacturer’s recommendation.



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3.5 Each employee shall be notified of monitoring results. The notification will be documented and posted in the work area without employee names.

3.6 EQT will determine whether to include an employee in the hearing conservation program based on risk, job classification, and results of area and personal dosimeter testing.

3.7 A copy of the OSHA Noise Exposure Standard must be made available to the employee.

4 HEARING PROTECTION DEVICES

4.1 Hearing protection devices, such as earplugs or earmuffs, must be provided to employees within

this Program at no cost to the employee. Hearing protection devices must be inspected and replaced as necessary.

4.2 Hearing protection must be used and maintained as originally intended and in accordance with

provided instructions. 4.3 Selected hearing protection must be compatible with other personal protective equipment (PPE). 4.4 Hearing protection should be kept clean and stored on a clean, dry surface. If reusable, cleaning

should follow manufacturer’s recommendations.

4.5 Hearing protection must offset employee exposure to at least an 8-hour TWA of 90 dBA.

For employees who experience a Standard Threshold Shift (STS), hearing protection must offset exposure at or below the action level of 85 dBA-TWA.

4.6 Hearing Protection Labeling (Signage)

Signage must be posted at the entrance to all high-noise work areas to identify the noise hazard and designate the required use of hearing protection.



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5 EMPLOYEE HEARING TESTING

5.1 Audiometric testing will be provided during the pre-employment medical examination to employees working in a designated hearing protection area and when employees’ 8-hour TWA noise exposures equal or exceed 85 dBA.

5.2 Audiometric tests must be performed by a licensed or certified audiologist or otolaryngologist or

other physician; or by a technician certified by the Council of Accreditation in Occupational Hearing Conservation (CAOHC) who has demonstrated competence in administering audiometric examinations. A technician who performs audiometric tests must be responsible to an audiologist or otolaryngologist or another physician. The testing will be in accordance with 29 CFR 1910.95(h).

5.3 Within six months of an employee’s initial exposure to or above the TWA, a baseline audiogram

against which subsequent audiograms can be compared shall be established by notifying the EQT Medical Department. If a mobile test van is used to perform audiometric testing, EQT shall obtain a valid baseline audiogram within one year of an employee’s first exposure to or above 85 dBA-TWA.

5.4 If an employee’s baseline audiogram is not obtained within six months after the first exposure to 85 dBA, the employee shall wear hearing protectors for any period exceeding six months.

5.5 Re-testing shall be performed annually for all employees enrolled in the Hearing Conservation

Medical Surveillance Program.

5.6 An audiologist or otolaryngologist shall review problem audiograms and determine if there is a need for evaluation. The review shall be performed in accordance with 29 CFR 1910.95.

6 TRAINING

6.1 Training will be conducted initially upon enrollment in this Program and then annually. All employees exposed to a TWA of 85 dBA or above shall receive training that will consist of at least:

The effects of noise on hearing; The purpose, advantages and disadvantages of hearing protection; attenuation of various

types; and instruction on selection, fitting, use, and care; The purpose of audiometric testing and an explanation of the test procedures; The proper methods to care for, use, and maintenance hearing protection; and Hearing Conservation Program requirements.

7 RECORD RETENTION



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7.1 The employee audiometric test record will include:

Name and job classification of the employee; Date of the audiogram and examiner’s name; Date of the last acoustic or exhaustive calibration of the audiometer; and Employee’s most recent noise exposure assessment.

7.2 A record containing the measurements of the background sound pressure levels in the

audiometric test room or booth will be retained.

7.3 EQT will maintain records that contain each employee’s name and date of training. 7.4 Audiometric tests and medical evaluations related to hearing conservation shall be recorded as a

permanent part of the employee’s occupational health record. The noise record will be retained for the duration of EQT employment plus 30 years. Annual program assessment documents shall be retained for a period of no less than three

years. Area and personal noise exposure measurement records shall be retained for five years or

until new measurements are completed.

7.5 All records shall be provided upon request to employees in accordance with 29 CFR 1910.1020. 7.6 Employers who cease to do business must transfer to the successor employer all records required

by the noise standard. The successor employer must retain these records for the remainder of the periods as above described.


8.1 EQT Supervisors

Define compliance needs at their locations; Ensure proper implementation and adherence to this Program; Ensure employees maintain their hearing conservation training annually; and Ensure appropriate hearing protection is available and worn by employees.

8.2 EQT Employees

Adhere to this Program, including attending all required training.



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Implements this Program; develops site-specific applications; annually reviews procedures; and monitors application to assure compliance;

Provides technical guidance and training for this Program; Maintains and revises the EQT Hearing Conservation Program; Conducts any area or individual testing of EQT operations; and


Schedules tests; missed tests, retests and medical evaluations; and Maintains employee records for audiometric test and medical evaluations; and records

occupational STS in OSHA Log.


Maintain a hearing conservation program when required per 29 CFR 1910.95.

9 DEFINITIONS Age Correction: allowance made for the contributing of aging to the change in hearing level. Area Monitoring: activity conducted to determine the noise level in a particular area or location. Audiogram: a chart, graph, or table resulting from an audiometric test showing an individual’s hearing threshold levels as a function of frequency.

Noise Dosimeter: a specialized instrument that measures the noise exposure to which an individual is integrated over time. Personal Monitoring: activity conducted to determine if an individual’s noise exceeds a given period of time.

Time-weighted Average (TWA): sound level that represents the length of exposure to noise averaged over a stated period of time, such as an eight-hour workday.



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Appendix A Hearing Conservation Program Permissible Noise Exposure Table

Permissible Noise Exposure Table

29 CFR 1910.95 Table G-16 (a) A-weighted sound level, L (decibel) Duration, T (hour)

80 32 81 27.9 82 24.3 83 21.1 84 18.4 85 16.0 86 13.9 87 12.1 88 10.6 89 9.2 90 8.0 91 7.0 92 6.1 93 5.3 94 4.6 95 4 96 3.5 97 3.0 98 2.6 99 2.3 100 2.0 101 1.7 102 1.5 103 1.3 104 1.1 105 1.0 106 0.87 107 0.76 108 0.66 109 0.57 110 0.5



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Appendix B Hearing Conservation Program Sample Standard Threshold Shift (STS) Letter

Your hearing health is important, personally and professionally. On [INSERT DATE], you received an audiometer test and a follow-up test on [DATE]. The most recent audiometrical test result was compared to your baseline audiogram. This comparison indicates that your hearing has deteriorated to the point where your hearing impairment, with age correction factors applied, constitutes a standard threshold shift (STS). An STS is defined by the Occupational Safety and Health Administration (OSHA) as a change in hearing relative to the baseline audiogram of an average of 10 decibels in either ear. (It is measured in frequencies of 2000, 3000, and 4000 Hz.) There are many possible reasons that contribute to hearing loss. Ear infections, wax buildup, allergies and occupational noise exposure all can be factors. While an audiogram cannot define why you have a hearing loss, prompt action now could help stop it from worsening. Hearing protection must be used when you are in a work environment that could result in noise exposure that equals or exceeds an eight-hour Time Weight Average (TWA) of 85 decibels. Loss of hearing will affect your life, so it is important to take measures to preserve it while you still can. By signing this letter you agree that:

o You have been trained in 1) the effects of noise on hearing; 2) the purpose of the hearing test; and 3) the purpose of hearing protectors, the type available, and their attenuation, fit and care.

o You have been trained and fitted with hearing protectors (Demonstration Only). o You have received a copy of this report.

_________________________________ ___________________ Employee Signature Date _________________________________ ___________________ Supervisor Signature Date _________________________________ ___________________ Safety or Medical Department Date



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Appendix C Hearing Conservation

Sample Field Monitoring Noise Data Sheet

SAMPLE FIELD MONITORING NOISE DATA SHEET

Date: Shift: Collect By:

EE Name: EE ID: Title:

Hearing Protection: NRR:

Test Duration (min): Dosimeter #: Pre-calibration Post-calibration

Timeframe Location/Remarks

Results

Lmax: Lavg:

Lavg1: Lpeak:

% Dose 80 Threshold: Equivalent dBA 90 Threshold:

% Dose 90 Threshold Equivalent dBA 90 Threshold



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Appendix D Hearing Conservation Program Sample Posting Tables

SUMMARY TABLE 1

OCCUPATIONAL EXPOSURES THAT EQUAL OF EXCEED THE OSHA PEL 90 dBA – TWA (80 THRESHOLD)

Date Name and Shift Occupation 80 Threshold 8-hour TWA dBAa

90 Threshold 8-hour TWA

dBAb 4/30/18 Joe Employee

(7:30 am - 4:00 pm) Well Operator

87.8

87.4

a Based upon an eight-hour Time Weighted Average (TWA) noise exposure, the OSHA Action Level (AL) and

Permissible Exposure Limit (PEL) is 85 decibels (dBA) and 90 decibels (dBA), respectively (80 Threshold). b At levels equal to or greater than 90 dBA, TWA (90 Threshold) employers are required under 29 CFR 1910.95 (b)(1) to

investigate the feasibility of engineering and administrative controls, and when feasible, implement these engineering controls to reduce noise levels. If engineering and/or administrative controls are not feasible, documentation of this investigation must be maintained.



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SUMMARY TABLE II OCCUPATIONAL EXPOSURES THAT EQUALED OR EXCEEDED OSHA AL 85 dBA – TWA

BUT FELL BELOW THE OSHA PEL 90 dBA-TWA (80 THRESHOLD)





88

87.2






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SUMMARY TABLE III OCCUPATIONAL EXPOSURES THAT WERE LESS THAN THE OSHA AL 85 dBA-TWA (80

THRESHOLD)





59.5

52.9





Title Hot Work

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1 PURPOSE AND SCOPE

1.1 The purpose of the Hot Work Permit Program is to delineate procedures and precautions that must be followed for hot work at all EQT locations. For the purposes of this Program, “Hot work” is defined as a condition where a fire, flash fire, or explosion could result from an ignition source or other flame-producing activity, such as welding, cutting, or grinding.


2.1 The Hot Work Permit Program applies to any hot work being performed in an area where natural gas or other flammable or combustible materials are present. Requirements of this Program apply to EQT employees and all business partners working on EQT locations. All personnel, including EQT business partners must use the EQT Hot Work Assessment/Permit.

All applicable safety precautions, such as proper purging, blocking, the use of air-moving or siphoning equipment, must be in place prior to beginning any hot work. A completed Hot Work Assessment/Permit Form (Appendix A) is required for all hot work operations.

2.2 There are also additional safety requirements for hot tapping, thermite welding, or polyplastic pipe fusion. Where specific standard operating procedures (SOP) are available, personnel must follow the outlined requirements. If an SOP has not been developed, the Hot work Assessment/Permit form must be used.

2.3 Hot work permits are not required for the use of electronic equipment outside Class 1 Division 1 or 2 areas generally considered to be safe. This exemption also applies to electronic equipment used within a Class 1 or 2 area with stationary monitors isolating the process in the event of a gas release. Examples of such equipment include a timing light or the use of cameras, computers or other equipment for operating, testing and/or troubleshooting electrical circuitry, lighting appliances and operating pneumatic tools, provided the determination has been made that the atmosphere is not flammable, combustible, or explosive.

Such a determination can be obtained through the use of stationary monitors within a compressor station or gas production units, handheld portable monitors or personal monitors. All monitoring equipment must remain on and functioning for the duration of the activity and be used in accordance with the manufacturer’s instructions.

2.4 Vehicles, generators and internal combustion heaters do not require hot work permit unless they will be operated within a Class 1 Division 1 or 2 area.

2.5 A documented assessment of new construction areas involving pipelines, compressor stations and meter stations where natural gas has not been introduced into the system and is not present must be performed within 35 feet of any flammables and combustibles prior to all hot work.

The hot work assessment must be documented using the EQT Hot Work Assessment/Permit form, Appendix A (Sections A, B & C).


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2.6 In the event it is impossible or impractical to follow all safety measures outlined in this Program, or a special condition not covered in this Program develops, the EQT Corporate EHS Department must be contacted to determine under what conditions a Hot Work Permit will be issued.

3 GENERAL PROCEDURE

3.1 The EQT Hot Work Assessment/Permit form (Appendix A) must be used to evaluate and

document hot work activities.

The requesting party and the EQT supervisor or designee will complete Section A of the Hot Work Assessment/Permit.

Prior to beginning work, Section B of the Hot Work Assessment/Permit form must be used to perform required inspections to determine if flammable or combustible materials could be present.

Once Section B is completed, the requestor must complete Section C. Information from Sections B and C will be used to determine if a hot work permit is required.

3.2 A valid Hot Work permit requires authorization from a person with specific knowledge of the EQT Hot Work Program, engaged in the work and conducting on-site monitoring of the hot work operations. An EQT supervisor or designee engaged in the work at the location will issue the Hot Work permit and also assign duties, such as clearing, notification, and fire watch. The knowledgeable person also will ensure the correct information has been entered on the Hot Work Permit (sections D and E), and will inspect the work area to verify:

Hot work will not begin before the permit has been issued. The permit shows the date for which the permit is valid. (The permit will be good only for

the shift/12 hours from which it is issued. A new permit must be issued after 12 hours or if there is a change in personnel and/or scope of work.)

A minimum of two signatures are obtained on a hot work permit for internal work where an EQT supervisor or designee is engaged in the work but not present. For example, signatures can be acquired by operations and a fire watch for a permit to be valid.

Permits are signed at the site of the hot work and not in areas isolated from the work site. Permits are to be issued to a specific person(s) who will actually perform the work. The

permits must be available upon request at the work area for the duration of the permit. All completed and cancelled hot work permits are maintained and available to the EQT

Corporate EHS Department upon request for one year.

3.3 The intended hot work area must be monitored for the presence of flammable vapors before a permit will be issued and work can begin. Verify that readings are all in the normal range. Hot work is not allowed when the LEL exceeds zero. Continuous monitoring is required for all hot work activities.


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Protect all cracks and openings through which hot sparks or slag may enter. Sweep the floor of all loose combustible debris. Before cutting or welding is permitted, the

area must be inspected by the individual responsible for authorizing cutting and welding. Eliminate accumulated combustible dust and verify there is no combustible dust suspended

in the air. Consider the placement of welding blankets and /or welding curtains to protect personnel in

adjacent work areas. Wet combustible floors during hot work. A permit is required for the temporary use of any space-heating device (e.g., oil, gas or

electric heaters) in a compressor building, except in those locations where such heaters are permanently installed or routinely used (e.g., electric heaters in shops, rest rooms and offices).

Machinery and facilities must be shut down and locked out/tagged out as necessary to ensure a safe work area.

Vent natural gas lines and siphons if necessary. Purge lines and tanks with an inert gas as practical or when a purge plan is required by

EQT Operations or EQT Engineering.

o At a minimum, purge plans must include purge points and isolation points; purging gas specifications and safety information; safety plans for discharge; and information on sampling device(s).

3.4 All direct reading instrumentation must be calibrated and bump tested per manufacturer’s

instructions. An instrument must not be used if it has not been calibrated properly.

3.5 Business partners must provide their own direct reading instrumentation and perform their own readings.

Where flammable or explosive gases or vapors might be present, tests must be conducted at least every 60 minutes within at least 35 feet in all directions, including sub-flooring, floor openings and excavations. Continuous monitoring equipment calibrated and bump tested per manufacturer’s recommendation is required.

Readings are to be obtained and recorded on the Hot Work permit immediately prior to beginning work and in intervals not to exceed 60 minutes. HOT WORK IS NOT PERMITTED in any area where explosive gases or vapors have been detected above zero LEL.

In a confined space, it is important to take samples at the top, middle and bottom to locate varying concentrations of gases and vapors. Highly concentrated gases can accumulate at the top or bottom of a confined space depending on whether they are less or more dense than air.

Dilute gases and vapors in the ppm range distribute evenly throughout a confined space. It is especially important to sample at a distance from the opening, because air intrusion near the entrance can give a false sense of adequate oxygen presence.


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Flammable and combustible materials must be moved a minimum of 35 feet from the work area to eliminate the danger of fire. This includes all portable containers of flammable and combustible liquids and other combustible materials. If it is impractical to remove such materials, they must be covered with fire-resistant blankets or isolated with a non-combustible enclosure.

Discontinue any operations that could capture and transport burning embers. Wall and floor openings in the immediate area should be covered if welding or cutting

inside a building. It also might be necessary to wet the area or hang or tie non-combustible covers in place to keep unwanted sparks from area.

A dry-chemical fire extinguisher (minimum 20 lbs.) must be kept at each location where hot work is being performed. These extinguishers must be inspected to ensure they are in proper working order.

Work must not be done in a confined space without following the EQT Confined Space Program.

3.6 A qualified person must be assigned as a Fire Watch for the duration of the hot work permit. This person(s) must have knowledge in the use of the direct reading instrumentation and the ability to recognize and react to a potential ignition situation. Additionally, a Fire Watch must be trained in the proper use and operation of portable fire extinguishers. Fire Watches may move within the work area as long as their ability to perform their duties is not compromised.

When the job is complete, the Fire Watch will check the site for a minimum of 30 minutes to ensure there is no possibility for fires to ignite. Only after the Fire Watch has deemed the area safe, can the hot work permit be closed.

Hot work permits must remain on file either on site or at the local office for at least one year.

3.7 Business partners working in an area that requires a Hot Work permit must contact EQT. The EQT supervisor or designee will convey the requirements of the EQT Hot Work Permit Program. It is the responsibility of the business partner to implement the Hot Work Permit Program.

3.8 Business partners performing hot work must certify in ISNetworld as having received the EQT Hot Work Program and acknowledge that they understand and will follow the requirements of the Program. Business partners must have a verified hot work program in ISNetworld.

4 TRAINING

4.1 All personnel working in hot work permit areas will be trained in the requirements and use of the

hot work permit program. Refresher training will be provided annually.

4.2 Prior to performing any work at EQT locations, all personnel must have knowledge and understanding of this Program.

5 RECORD RETENTION


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5.1 Hot Work permits will remain on file for at least one year.



The EQT supervisor is responsible for ensuring that any designee is competent in the

EQT Hot Work program and Hot Work practices; Develop and implement fully all requirements and procedures of the Hot Work Permit

Program; and Senior management will enforce actions related to violations of any requirements.

6.2 EQT Employees and Business Partners:

Adhere to the requirements of this Program; Wear, at a minimum, required PPE, including but not limited to: hard hats; safety eyewear;

hard-toed boots; fire-resistant outer clothing; and appropriate respiratory protection if necessary. Suitable hearing protection in noise areas and applicable hand protection also is required;

Initiate a Stop Work Authority action if any task is unsafe, has the potential to create an environmental incident or could create an unwanted operational event;

Evaluate the potential fire hazards in the work area and obtain necessary fire protection equipment;

Obtain necessary protective equipment such as welding shields, barricades, fire blankets, welding helmets, gloves, jackets, purging, blocking and/or air moving or siphoning equipment;

Verify unnecessary flammable and combustible materials are moved at least 35 feet from the area where the hot work will be performed;

Verify all equipment is inspected and in proper working condition for the work to be performed;

Ensure conditions are safe before beginning hot work and that the area is inspected by an individual responsible for authorizing cutting and welding operations; and

Coordinate hot work with EQT supervision to ensure operating facilities do not present unknown hazards, such as unexpected releases of natural gas.

6.3 Fire Watch

Engages solely in firewatch duties with no distraction from other duties during hot work; Remains on site through breaks unless relieved properly by another Fire Watch; Initiates a Stop Work Authority action if any task is unsafe; Has the appropriate fire protection equipment on location and is trained properly in its use; Knows and can implement approved method to alert personnel of an emergency;


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Verifies safe conditions by being vigilant regarding potential fire hazards with the area; Inspects hot work and surrounding area upon completion of the hot work; Remains on site for a minimum of 30 minutes after completion of the hot work to ensure all

smoldering materials have been located and extinguished; Uses appropriate PPE and atmospheric monitoring devices for the work being performed; Gives special attention to the following conditions:

o Combustible material or contents 35 feet or closer to the point of operation; o Combustibles more than 35 feet from point of operation though easily ignited; o Walls, floor openings and excavations within a 35-foot radius and exposed

combustible materials in adjacent areas (e.g., concealed spaces in walls and under floors); and

o Combustible materials adjacent to the opposite side of partitions, walls, ceilings, or roofs likely to be ignited.


Annually reviews the program and maintains it with up to date compliance obligations. Develops and delivers training associated with this program. Periodically reviews personnel working under the requirements of this program to evaluate

effectiveness. Provides technical guidance on the requirements of this program as requested.

7 DEFINITIONS

Clearing: a procedure to remove flammable, combustible and ignitable materials.

Fire Watch: a qualified person in constant attendance and alertness who is available to monitor the area when permit-required hot work is performed. This person must be trained in the use of firefighting equipment and gas monitoring equipment. Hot Work: the use of any tool, which when applied to a piece of equipment, could produce high enough temperatures by heat, friction, flame, spark or compression, to cause fire or explosion. Examples of hot work include open flame, gas or electric cutting, welding, burning, soldering, sweating operations, or hot spark-producing tasks, such as grinding. It also includes opening energized-rated electrical equipment or using non-rated electrical equipment.


Title Incident Reporting and Investigation

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1 PURPOSE AND SCOPE

1.1 The purpose of this Incident Reporting and Investigation Program is to define procedures that must be followed for the prompt reporting and investigation of all incidents on EQT locations.


2.1 All personnel are required to immediately report all work-related incidents, including

environmental incidents, injuries, near misses, and non-injury occurrences. Call 911 immediately if necessary. Report all incidents to the EQT Emergency Dispatch Center (1-833-990-1534).

2.2 If an EQT employee is injured, EQT Medical must be contacted after first aid care is rendered

and incident notifications made.

2.3 Business partners are required to immediately report to EQT all incidents by calling the EQT Emergency Dispatch Center (1-833-990-1534).

• Business partners must submit an initial report to EQT within 24 hours of the incident, including incident description and preliminary findings. The finalized investigation report is due to EQT within seven days.

• If the classification of the injury changes at any time, the business partner must make an immediate notification to EQT.

2.4 No Personally Identifiable Information shall be reported during the course of any incident

investigation.

3 RESPONSE

3.1 When an incident occurs, the first priority is to care for the injured and make the site safe or contain the environmental incident from escalation if possible. Call 911 Immediately if necessary. The next step must be to protect property and assets, but only when it is safe.

3.2 When applicable, initiate the appropriate Emergency Action Plan (EAP), emergency response, or

EQT Crisis Communication Plan. 3.3 Evaluate the area for additional safety hazards (e.g., escaping gas, hazardous materials and

contamination, sudden release of energy, or electrical issues) before taking action. 3.4 Focus on preventing additional injury, damage, or environmental release before continuing.

4 PROCEDURE



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4.1 For all incidents, document and photograph the incident site, including the position of persons, equipment, vehicles, and all related items.

4.2 Retain all documents relative to an incident, including witness statements and work permits. 4.3 Note the weather; driving conditions; walking surfaces; position of valves, dials and operating

controls; functions of vehicle and equipment controls; length of skid marks, and other important elements, as applicable.

4.4 Preserve for analysis any equipment, tools and materials that might have created or contributed

to the incident.

4.5 Root-Cause Analysis (RCA)

• A Root Cause Analysis will be completed on all EHS incidents that meet the criteria of Severity Level 4 or greater. See Appendix A.

• A Root Cause Analysis will be completed on the following Severity Level 3 Incidents: Near Miss Major, Fire Department Support Needed, and OSHA Recordable Injuries.

• A Root Cause Analysis shall be completed within 7 days of the incident date where feasible. The EQT Corporate EHS Department will make the determination if addition days are needed.

• For incidents involving only EQT personnel or equipment: o The EQT EHS Department will facilitate the Root Cause Analysis with the assistance

of the EQT Operations Department. o For incidents involving both the Safety and Environmental, one Root Cause Analysis

will be completed jointly. o The RCA method utilized will be a 5 WHY Analysis and include a timeline of events

and a WHY tree for complex incidents. • Incidents involving Business Partner’s personnel or equipment.

o The Business Partner will facilitate the Root Cause Analysis. The Business Partner may use the 5 WHY Analysis or another formally recognized method (with approval from EQT’s EHS Department.)

4.6 Corrective Actions

• Corrective actions can be formulated after the root-cause and contributing factors have been determined.

• The Incident Investigation Team will develop a corrective action plan to implement the corrective actions in a timely manner.

• Corrective actions must include timeline, assigned owners of action, and verification of action implementation.



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4.7 Follow-Up

• Periodically, the EQT Corporate EHS Department will review the corrective actions to ensure they have been implemented and are effective. Physical changes to procedures, equipment and/or processes to ensure adherence and effectiveness also will be reviewed.

4.8 Incident Review

• Incidents that meet the Root Cause Analysis guidelines will have an incident review meeting completed within 14 days of the incident date where feasible. The EQT Corporate EHS Department will make the determination if additional days are needed.

• The incident review meeting will cover the incident description, root cause analysis, causes identified, and corrective actions.

• For business partner incidents, the incident review will be facilitated by the business partner.

5 GOVERNMENT AGENCY

5.1 If a Government Agency responds (DEP, OSHA, etc.) to an EQT location, EQT Corporate EHS Department must be notified IMMEDIATELY.

5.2 All personnel shall limit conversation about the incident or other purpose for the Government

Agency’s presence, discussing it only with authorized EQT representatives. 5.3 No business partner shall speak on behalf of EQT, which includes saying “no comment.” 5.4 Depending on the type and severity of the incident, the incident might need to be reported to a

Government agency. The EQT Corporate EHS Department or business partner will make the determination on whether notification to any regulatory agency is required. The business partner is required to make this notification if it involves their personnel or their company.

6 RECORD RETENTION

6.1 Incident Investigation reports will be maintained for 5 years. 6.2 Maintain all information in accordance with EQT legal and Personable Identifiable Information (PII) standards.


7.1 EQT Supervisors



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• Participate in incident investigation involving their operations; and • Ensure completion of assigned corrective actions.


• Adhere to this Program during all work operations; and • Report immediately to their supervisor and EQT all injury and non-injury incidents. • Business Partners: Failure to comply with incident reporting requirements may result in

suspension or termination with EQT.

7.3 EQT Corporate EHS Department:

• Provides technical support and training to EQT supervisors and employees for completing initial incident investigations;

• Completes root-cause analysis with the information available within the safety management system for incident investigations;

• Communicates the requirements of this Program at least annually to EQT employees; • Operates and maintains the safety management system to track incident investigation and

corrective actions; • Communicates investigation outcomes and data to senior management team; • Provides lessons learned and actions to the rest of EQT, as applicable; • Verifies effectiveness of corrective actions; and • Notifies regulatory agencies of incident, if required.

8 DEFINITIONS

Incident: an event resulting in personal injury, property damage, equipment damage, impact to environmental resources, loss of production or product, or an event that has the potential to cause significant injury, damage, loss or impact to environmental resources.

Near-miss: unplanned event that has the potential to cause, but did not result in, injury, environmental damage, equipment damage, or an interruption to normal operations. Near-miss Major: unplanned event that has the potential to cause severe injury, major environmental damage, significant equipment damage, or an extended interruption to normal operations. OSHA-recordable: a work-related injury or illness requiring medical treatment beyond first aid that is included on OSHA 300 reporting logs in accordance with 29 CFR 1904.7.



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Appendix A


Title Lone Worker Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Lone Worker Program is to establish the minimum safety requirements for lone-worker operations at EQT locations.


2.1 All lone workers are required to have an approved means of communication at all times during lone-working activities (e.g. phone or radio communication, lone worker device, lone worker monitoring app).

3 HAZARD ASSESSMENT

3.1 The supervisor will make the determination with input from the worker as to whether or not the

tasks can be performed safely by a lone worker on a specific job site. If the tasks or work areas are not determined to be safe for a lone worker, the supervisor will make the changes to the job site or tasks necessary for the lone worker to work safely or provide other measures to ensure the safety of the lone worker. This could include having two workers perform the task.

3.2 Some tasks require at least two workers be present and are not permitted to be performed as a lone worker. The prohibited lone worker tasks include wearing a breathing apparatus; line breaking; confined space entry; excavating greater than four-feet in depth; hot work; using personal fall protection; tree trimming; clearing; felling and working on live electrical conductors or equipment that is not shut down, locked out and de-energized.

3.3 Workers in a Short-service Employee program must be approved to work as a lone worker.

4 PROCEDURES

4.1 The lone worker will have discretion to initiate a Stop Work Authority (SWA) action if the lone

worker feels it is unsafe or could be unsafe. The lone worker immediately will contact the supervisor on how to proceed safely to perform the task.

4.2 The supervisor is responsible for the safety and health of the lone worker even without constant

or direct supervision. The supervisor and lone worker must evaluate the tasks and establish “go-no-go” criteria for the trip/assignment.

4.3 All personnel must be trained in hazard identification and use the appropriate standard operating

procedures prior to completing any tasks as a lone worker.



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4.4 When the supervisor visits a work site of a lone worker, the supervisor will discuss the safety of the tasks at hand.

5 COMMUNICATIONS AND TRACKING

5.1 All personnel performing lone worker activities are required to check-in at intervals as predetermined by their supervisor or designee. If employees cannot check-in at the predesignated interval as determined by their supervisor or designate, the employee must travel to a location where service is available to check-in. Failure to check-in will result in a supervisor or designee traveling to the location or, when appropriate, notification being sent to local emergency response personnel.

5.2 It is recommended that the department or operations group have multiple methods to communicate with lone workers with at least two of these methods being available when the lone worker is traveling or performing task. Appropriate communication methods may include: Cell phones, radio communication, GPS, lone worker device.

5.3 The Supervisor has the option available of requiring that two-persons are on every jobsite.

6 TRAINING

6.1 The Supervisor is responsible to provide the necessary training to the workers, so they can work safely as a lone worker. The Supervisor will ensure the lone worker is sufficiently experienced in the job tasks and understands the risks of the tasks performed as a lone worker.

6.2 Training will include, yet is not limited to: Conducting non-routine tasks; Handling of unusual situations that may be encountered as a lone worker; Emergency procedures as a lone worker; Identifying the risks associated with the specific tasks and work areas; and Necessary precautions and measures to take to work safely as a lone worker.


7.1 EQT Corporate EHS Department Provide safety technical support and training for this program.

7.2 Management Personnel / Supervisors Ensure proper implementation and adherence to this program; Review work tasks with lone worker before work begins; Provide and maintain communication with lone worker throughout shift;



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Approve of lone worker devices for use.

7.3 EQT Employees Follow provisions of this program and related procedures; Attend all required training and report incidents immediately.

7.4 Business Partners Maintain Lone Worker Programs in ISNetworld as directed by the EQT Corporate EHS

Department; Provide safety technical support and training for this program.

8 DEFINITIONS

The following definitions are provided to clarify language used throughout this Lone Worker Program document: Global Positioning System (GPS): is a radio navigation system that allows land, sea, and airborne users to determine their exact location, velocity, and time 24 hours a day, in all weather conditions, anywhere in the world. Lone Worker: An employee or business partner whose work activities involve working in situations without the benefit of interaction with other workers, or without any kind of close or direct supervision. Groups of employees or business partners that are working in isolated locations without adequate communication capabilities are also considered lone workers.


Title Mobile Equipment Safety Program

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1 PURPOSE AND SCOPE

1.1 The objective of this Program is to establish procedures for the safe use of all mobile equipment on EQT locations, including but not limited to powered industrial trucks (PITs), earth moving/heavy equipment, and aerial lifts.

2 GENERAL REQUIREMENTS - ALL MOBILE EQUIPMENT

2.1 Horseplay and stunt driving is not permitted while operating mobile equipment.

2.2 Read the operators manual and operate the machine only if trained and competent in how to

operate it.

2.3 Any modifications or adaptations to lifting devices, including aerial lifts, must be certified in writing by the manufacturer.

2.4 No one may go beneath elevated equipment, such as booms, lifts, and forks.

2.5 Operators will not place any part of their bodies outside the mobile equipment or between uprights on the equipment where shear or crushing hazards exist.

2.6 Do not climb on the machine where hand and foot holds have not been provided. Use a three-point climbing technique whenever entering, exiting, or servicing the machine.

2.7 Unattended equipment shall have the keys removed.

2.8 Equipment must be powered off while being fueled.

2.9 Never walk alongside heavy equipment or approach operators until eye contact has been made with the equipment operator. Never assume you have the right of way and ensure the operator can see you.

2.10 Equipment operators and nearby workers must not use cell phones, wear a headset, headphones, or similar electronic devices while working on or near heavy equipment unless using for site communication purposes.

2.11 Wear appropriate clothing and personal protective equipment (PPE) as outlined in the PPE hazard assessment for the job.

2.12 Free rigging is prohibited on EQT locations.

3 POWERED INDUSTRIAL TRUCKS (PIT) PROCEDURE



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3.1 The operator must complete a documented daily and pre-shift inspection prior to operation to ensure the machine is in good working order and load rating capacities are not exceeded.

3.2 A qualified individual must complete repair and maintenance operations and ensure compliance with LOTO procedures.

3.3 Before returning equipment into service, ensure all associated guards and safety devices are operational.

3.4 A spotter must be used when there is limited visibility.

3.5 PIT’s will be operated with the load upgrade when traveling grades in excess of 10 percent.

3.6 Forklifts will be operated with the forks as low as possible whether loaded or unloaded.

3.7 All lifts should be assessed prior to the lift being performed and appropriate lifting attachments must be used.

3.8 Powered industrial trucks must be operated by trained, qualified and authorized operators only.

3.9 Ensure no person or objects are under or passing the elevated portion of any truck, whether loaded or empty.

3.10 When a powered industrial truck is left unattended, ensure load-engaging means are lowered fully, controls neutralized, brakes set and power off. Wheels must be chocked if the truck is parked on an incline.

A powered industrial truck is unattended when the operator is 25 feet or more away from the vehicle, regardless of whether the vehicle is in view or not in view.

3.11 Use a load backrest extension as necessary to minimize the possibility of any of the load falling rearward.

3.12 The use, care and charging of all batteries must conform to the following:

Ventilation will be provided to ensure diffusion of the gases from the battery and prevent accumulation of an explosive mixture;

Face shields, aprons and rubber gloves will be provided for workers handling acids or batteries; Facilities for quick drenching of the eyes and body will be provided within 25 feet of battery handling areas; and Facilities will be provided for flushing and neutralizing spilled electrolyte and for fire protection.



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4 PIT EQUIPMENT REQUIREMENTS

4.1 All powered industrial trucks acquired and used by EQT must meet the design and construction requirements for powered industrial trucks established in the “American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969,” and must bear a label or some other identifying mark indicating approval by a nationally recognized testing laboratory.

4.2 Modifications and additions that affect capacity and safe operation must not be performed without manufacturer’s prior written approval. Capacity, operation and maintenance instruction plates, tags, or decals must be changed accordingly.

4.3 Equipment will be kept clean and free of oil and grease as best as possible.

4.4 Non-combustible solvents/agents will be used to clean the equipment.

4.5 PIT’s will have an overhead guard to help protect the operator from falling objects. 5 PIT MAINTENANCE AND INSPECTIONS

5.1 Prior to use and before each shift, powered industrial trucks must be inspected to ensure safe operation. The completed inspection form must be placed in the powered industrial truck before use on each shift.

5.2 If a powered industrial truck is found to be in need of repair, defective or in any way unsafe, the truck must be removed from service until it has been restored to safe operating condition. Only authorized personnel may make any repairs.

6 EARTH MOVING/HEAVY EQUIPMENT OPERATING REQUIREMENTS

6.1 Below are specific requirements that apply to the following types of earth moving/heavy

equipment: scrapers, loaders, crawler (track) or wheel tractors, bulldozers, off-highway trucks, graders, agricultural and industrial tractors, and similar equipment.

6.2 Establish clear communication channels with the signal person. Operator and signal person should identify each other and agree on the communications to be used. 6.3 Operators must maintain three points of contact during access and egress of heavy equipment. 6.4 Restrict access to the heavy equipment counterweight swing areas to prevent people from entering this danger zone. 6.5 Equipment will not be driven to anyone standing in front of an excavation or a fixed object. 6.6 No person will be allowed to stand or pass under the elevated portion of any equipment, whether



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the equipment is loaded or empty. 6.7 Unauthorized personnel will not be permitted to ride on heavy equipment/mobile equipment. A safe place to ride will be provided where riding of equipment is authorized.

6.8 Arms or legs are prohibited from being placed between the moving parts of the equipment or outside the running lines of the vehicle.

6.9 A safe distance will be maintained from the edge of ramps or platforms while on any elevated surface and from the edge of any excavation.

6.10 Only approved heavy equipment/mobile equipment will be used in hazardous locations. 6.11 Only employees trained in safe winching operations may perform such work.

6.12 Prior to winching, ensure the cable is in safe condition and the hook-up secure. Brakes will be applied, and the blade will be lowered onto the ground during winching. Winch only at the proper speed that the machine being winched is able to move. Winch in a straight line, not on angle.

6.13 General Winching Precautions

Always keep hands clear of rope, hook loop, hook, and fairlead opening when spooling in or out, and during installation and operation;

Always use extreme caution when handling hook and rope during spooling operations; Always wear heavy leather gloves when handling rope; Never use winch to lift or move persons; Never use a winch as a hoist or to suspend a load; Never operate a winch with less than five wraps of rope around the drum; Always inspect rope, hook and slings before operating winch. Frayed, kinked or damaged rope must be replaced immediately. Damaged components must be replaced before operation. Protect parts from damage; Always remove any element that might interfere with safe operation of the winch; Always take time to use appropriate rigging techniques for a winch pull; Always be certain the anchor you select will withstand the load and the strap or chain will not slip; Never touch rope or hook while in tension or under load; Always stand clear of rope and load and keep others away while winching; and Always be aware of stability of vehicle and load during winching, keep others away from operations and alert all bystanders of any unstable condition.

7 EARTH MOVING/HEAVY EQUIPMENT REQUIREMENTS



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7.1 All vehicles must have a service, emergency and parking brake system. These systems may use common components and must be maintained in operable condition.

7.2 Whenever visibility conditions warrant additional light, all vehicles in use must be equipped with at least two headlights and two tail lights in operable condition. 7.3 All vehicles, or combination of vehicles, must have brake lights in operable condition, regardless of light conditions. 7.4 All vehicles must be equipped with an adequate, functioning, audible warning device (e.g., horn)

safely and easily accessible to the vehicle operator.

7.5 No employer may use any motor vehicle that obstructs the rear view unless it has a reverse vehicle signal audible above surrounding noise level.

7.6 All vehicles with cabs must be equipped with windshields and powered wipers. Cracked and broken glass must be replaced. Vehicles operating in areas or under conditions that cause fogging or frosting of the windshields must be equipped with operable defrosting devices. 7.7 All haulage vehicles in which payload is completed with cranes, power shovels, loaders, or similar equipment must have a cab shield and/or canopy adequate to protect the operator from shifting or falling materials. 7.8 Tools and material will be secured to prevent movement when transported in the same compartment with employees. 7.9 Vehicles used to transport employees must have seats firmly secured and adequate for the number of employees to be carried. 7.10 Seatbelts and anchors meeting the requirements of 49 CFR Part 571 (Department of Transportation Federal Motor Vehicle Safety Standards) must be installed in all motor vehicles and used by the operator. 7.11 Trucks with dump bodies must be equipped with permanently attached positive means of support

capable of being locked in position to prevent accidental lowering of the body while maintenance or inspection work is being done.

7.12 Operating levers controlling hoisting or dumping devices on haulage bodies must be equipped with a latch or other device that will prevent accidental starting or tripping of the mechanism. 7.13 Trip handles for tailgates of dump trucks will be arranged to ensure that the operator will be in

the clear when performing dumping work.



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7.14 All vehicles must be checked to ensure that parts, equipment and accessories are in safe operating condition and free of apparent damage that could cause failure while in use. Before each shift, check the following:

Horn; Service brakes (including any trailer brake connections); Emergency stopping system and brakes; Parking system (hand brake); Tires, seatbelts and coupling devices; and Steering mechanism and operating controls.

7.15 Prior to using equipment, operators must complete a Daily Pre-shift Inspection for each piece of equipment they intend to use.

7.16 All defects will be corrected before the vehicle is placed in service. The requirements also apply to equipment, such as lights, reflectors, windshield wipers, defrosters, and fire extinguishers.

7.17 Heavy/mobile equipment machines are required to have a seatbelt and rollover protection system (ROPS). Always use the seatbelt.

8 GENERAL PROCEDURE REQUIREMENTS FOR HEAVY EQUIPMENT USE

8.1 All equipment left unattended at night that is adjacent to a highway in normal use or adjacent to construction areas where work is in progress must have appropriate lights or reflectors or barricades equipped with appropriate lights or reflectors to identify the equipment location. 8.2 A safety tire rack, cage, or equivalent protection will be provided and used when inflating, mounting or dismounting tires installed on split rims or rims equipped with locking rings or similar devices. 8.3 Heavy machinery, equipment or parts that are suspended or held aloft by use of slings, hoists or

jacks, must be blocked or cribbed substantially to prevent falling or shifting before employees are permitted to work under or between them.

8.4 Bulldozer and scraper blades, end-loader buckets and dump bodies either will be lowered fully or blocked when being repaired or when not in use. All controls will be in a neutral position, with motors stopped and brakes set unless work being performed requires otherwise. 8.5 When the equipment is parked, the parking brake will be set. Equipment parked on inclines will have the wheels chocked and the parking brake set. 8.6 When working or being moved in the vicinity of power lines or energized transmitters, all

equipment must comply with OSHA requirements. Requirements include:



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For lines rated 50KV or below, a minimum clearance between the lines and any part of the equipment must be 10 feet. If there is a doubt on rating of the lines notify the local power company.

For lines rated over 50 KV, a minimum clearance between the lines and any part of the equipment or load must be 10 feet plus 0.4 inch per each KV over 50KV or twice the length of the line insulator, but never less than 10 feet. If there is a doubt on rating of the lines notify the local power company.

If equipment or machinery capable of breaching the safety clearance distance and has to pass underneath the overhead line, employees shall:

o Keep the number of passageways to a minimum. o Define the route of the passageway using fences and erect goalposts at each end to

act as gateways using a rigid, non-conducting material. o Ensure the surface of the passageway is levelled, formed-up and maintained to

prevent undue tilting or bouncing of the equipment. o Erect warning notices at either side of the passageway, on or near the goalposts

and on approaches to the crossing giving the crossbar clearance height and instructing drivers to lower jibs, booms, tipper bodies etc. to keep below this height while crossing.

o Illumination of the notices and crossbar at night or in poor weather conditions may be required, to ensure they are visible supplemented by the use of white or fluorescent paint or attaching reflective strips.

o Ensure barriers and goalposts are maintained.

9 OPERATING REQUIREMENTS AERIAL LIFTS

9.1 Test the lift controls each day prior to use to ensure they are in safe working condition.

9.2 Inspect the aerial lift vehicle to ensure that the boom is cradled properly and the outriggers stowed prior to moving the vehicle.

9.3 The intended weight (persons, tools, material) must not exceed the boom and basket load limits

specified by the manufacturer. Check the load ratings before use.

9.4 Always inspect the area and travel route and remove hazards prior to traveling the route. Avoid driving over loose objects on the roadway. Ascend and descend grades slowly and ensure speed will be slow enough to negotiate turns and stops safely.

9.5 Stand firmly on the floor of the basket. Do not sit or climb on the edge of the basket, the mid-rail, or use planks, ladders, or other devices to establish a work position.

9.6 Before lowering the basket check the area below to ensure it is clear of people.



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9.7 If operating near overhead electrical lines, follow all applicable electrical safety procedures. The safe working distance changes depending on the voltage, vehicle type and other factors. 9.8 Set the vehicle brakes. If using the outriggers, position the pads on a solid surface. If the aerial lift is positioned on an incline, install wheel chocks. 9.9 Do not move the aerial lift vehicle when the boom is elevated in a working position with persons in the basket unless the equipment is specifically designed for this type of operation. 9.10 Wear a harness with a self-retracting lanyard attached to an approved anchor point when working

from an aerial lift. Belting to adjacent structures or equipment is not permitted.

9.11 Aerial lifts will have platform (upper) and lower controls. Upper controls will be in or beside the platform within easy reach of the operator. Lower controls will provide for overriding the upper controls. Except in case of emergency, do not operate the lower-level controls without the permission of persons in the basket.

9.12 Equipment will be kept in a clean condition, free of oil and grease as best as practical. 9.13 Non-combustible solvents/agents will be used to clean the equipment. 9.14 Reference Section 8 of the Working at Heights Program for aerial lift operator requirements.

10 WORK ZONE SAFETY

10.1 A traffic-control plan might be required for an EQT location based on operation, site configuration and level of risk; however, a plan is required for return to pad operations; new pad construction; pipeline construction; and current hydraulic fracturing sites; and any other location as required by EQT.

10.2 Business partners must adhere to local requirements for work involving the use of temporary

traffic control in roadway work zones. Specific requirements include: Ensuring maximum protection for the employees in the street. Providing maximum safety for passing motorists and pedestrians in the vicinity; and Maintaining a safe, free flow of traffic around and consistent with the work area.

10.3 All personnel exposed to risks of moving traffic or construction equipment must wear required

high-visibility safety apparel meeting ANSI 107 for Class 1, 2, or 3 risk exposures.

10.4 All flaggers and traffic control signs or devices must conform to Part VI of the Manual on Uniform Traffic Control Devices (MUTCD).

11 TRAINING



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11.1 PIT and Aerial Lift Operators

Prior to operating a powered industrial truck, all operators must be trained and certified as outlined in 29 CFR §1910.178.

Refresher training is required when the operator has been observed driving unsafely, involved in an accident or near miss, received an evaluation that indicates unsafe operation, is assigned to drive a different type truck, or a there is a workplace condition affecting safe operation changes. An operator evaluation is required after refresher training.

All operators must be able to present their record of training and certification upon request prior to the use of mobile equipment on EQT sites.

Certifications will include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing the training or evaluation.

After three years, PIT operators shall receive detailed evaluation as required by 29 CFR §1910.178.

11.2 Earth Moving/Heavy Equipment Operators

EQT and Business partners must ensure that Earth Moving/Heavy Equipment operators are competent to operate their issued equipment safely. This can be done through the hiring process, applicable experience, training and/or certification information.

12 RECORD RETENTION 12.1 Documentation and records associated with the requirements established in this program,

particularly the completed equipment checklist, shall be maintained for a period of 1 year. 13 ROLES AND RESPONSIBILITIES

13.1 All Employees/Business Partners

Adhere to this Program; and Use extreme caution and keep a safe distance when walking or working around mobile

equipment.

13.2 Mobile Equipment Operators

Operate only the powered industrial trucks for which they have been trained and certified;

Read and comply with owner’s manuals, manufacturer-provided safety information and the requirements of this Program;

Follow all training and universal precautions when operating a powered industrial truck; Ensure nameplates and markings are in place and maintained in a legible condition;



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Use all appropriate safety equipment and devices, including but not limited to seatbelts; Report immediately to supervisor all unsafe practices, work-related accidents, fuel spills,

fires, and injuries; and Obey traffic signs and signals and audible or visual warning devices.


Ensure all powered industrial trucks acquired and used by EQT meet the design and construction requirements for powered industrial trucks established in the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969;

Ensure the proper designated powered industrial truck (e.g., forklift) or mobile equipment is used in the production areas per 29 CFR 1910.178 standard;

Identify all heavy equipment/mobile equipment in their department; Assure operator’s manuals and manufacturer’s safety information is available for all

applicable equipment and vehicles.


Maintains training records and ensures refresher training is delivered as required per 29 CFR 1910.178 standard; Reviews training qualification criteria to ensure effectiveness; and Identifies specific jobs or individuals to whom this Program applies, ensuring employees selected have the necessary experience and training.

14 DEFINITIONS

Free Rigging: the direct attachment to or placement of rigging equipment (e.g., slings, shackles, rings) onto the tines of a powered industrial truck for a below-the-tines lift. EQT prohibits this.

Industrial Tractor/Tractor: a high-power, low-speed industrial vehicle designed primarily to tow non-powered trucks, trailers or other mobile loads. Mobile Equipment: free-moving equipment powered by gasoline, propane, natural gas, diesel or electricity used to haul, transport, excavate, move, maneuver, or hoist materials, equipment, products or personnel. Rollover Protection System (ROPS): a structure that covers the machine operator to minimize the possibility of injury from falling objects or equipment roll over. Winching: process of pulling an item with the winch on a piece of equipment such as a dozer.


Title Outdoor Safety Program

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1 PURPOSE AND SCOPE

1.1 The purpose of this Outdoor Safety Program is to define procedures and precautions that must be followed for the safe completion of outdoor work at all EQT locations.


2.1 All personnel must evaluate and assess their environment according to the EQT Hazard Assessment and Control Program. At a minimum, all personnel should consider the nature of the work and the area where it is done, including remoteness, terrain, likely weather conditions, weather extremes, and the possibility of encountering dangerous animals, plants, or insects.

2.2 All personnel will be trained in hazard recognition and the unique physical and biological

hazards associated with working outdoors.

2.3 Controls must be in place to mitigate all identified potential hazards prior to starting work. 2.4 Initiate a Stop Work Authority (SWA) action if there is any doubt about the safety of the task.

3 SEVERE WEATHER

3.1 All personnel are required to use sound judgment in regard to their personal safety during

inclement weather. In state-declared emergencies, all personnel must follow the instructions of civil authorities.

3.2 Depending on the nature and seriousness of the impending severe weather, preparations might need to be made to reduce potential damage and adverse business impacts. EQT will determine the need for curtailing operations and evacuating the location if necessary.

3.3 In the event of a pending storm with electrical potential, loading and off-loading activities are

prohibited. Ensure all tanks are closed.

3.4 All aboveground work must stop and seek shelter when a lightning strike is detected within 10 miles of the worksite. Work shall not resume until 30 minutes after the last visible flash of lightning or last clap of thunder.

3.5 During severe weather events, all non-critical and non-essential equipment must be shut down.

3.6 In the event of an unexpected and severe winter storm during the workday, all personnel must ensure equipment and emergency supplies are available and ready for potential unexpected winter weather events. This includes first-aid kits, rock salt or ice melt, water, emergency lighting, batteries, and blankets.



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Due to the risk of carbon monoxide poisoning, do not use an electric generator indoors or near building air intakes if back-up power supplies are needed.

4 HEAT AND COLD STRESS

4.1 All personnel who work outdoors must be trained in the signs, symptoms, and control measures

for heat and cold stress.

5 BIOLOGICAL HAZARDS

5.1 All personnel who work outdoors must be trained in the signs, symptoms, and control measures for insect bites and stings. Prior to working outdoors, EQT employees are to notify the EQT Medical Department of known allergies to bees or venomous insects.

5.2 Medical treatment is required immediately if the victim experiences: breathing difficulties; facial

swelling; rapid pulse; and/or loss of consciousness.

Precautions to avoid stings and bites include:

Wearing light-colored clothing that enhances ability to see ticks and other insects; Wearing a long-sleeved shirt, long pants and a hat; and Using an insect repellant according to directions specified on label. Do not place insect

repellant on fire-resistant clothing.

5.3 All personnel who have been bitten (snake, spider, insects, dogs, etc.) must seek treatment immediately and report the incident.

6 TRAINING

6.1 All personnel must adhere to this program and understand the hazards associated with their location, operations and specific hazards posed by extreme weather, environmental and biological hazards.

7 RECORD RETENTION – EQT ONLY

7.1 Any medical records associated with EQT employee exposure shall be maintained by the EQT

Medical Department for the duration of the employee’s employment plus thirty years.


8.1 EQT Supervisors/Business Partners

Monitor the weather for the EQT work locations under their responsibility;



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Communicate weather warnings and weather-related issues; Ensure employees receive the necessary training for outdoor work; and Implement lone-worker precautions as needed.


Adhere to this Program; Monitor the forecast and use sound judgment during inclement weather; Communicate outdoor safety concerns to their supervisor; and Initiate an SWA action if an operation is deemed hazardous due to outdoor and

environmental factors.


Maintains and reviews this Program’s content; Provides technical support for EQT management, supervisors and employees; and Provides training for this Program.


Maintains medical records involved with the response to this Program; and Advises of appropriate medical protocol in the event of an incident.

9 DEFINITIONS

Biological Hazards: also known as biohazards, refer to substances that pose a threat to the health of living organisms, primarily that of humans. This can include a microorganism, virus, or toxin from a source plant, insect, or animal, that can affect human health.

Cold Stress: a serious condition that occurs when the body can no longer maintain a normal temperature. The results can be cold-related illnesses and injuries, permanent tissue damage or death. Heat Stress: a situation where too much heat is absorbed that can cause serious illness or even death. It can also cause heat cramps, heat exhaustion, and heat stroke. Physical Hazard: a factor within the environment that can harm the body without necessarily touching it.


Title Personal Protective Equipment

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1 PURPOSE AND SCOPE 1.1 The purpose of this program is to outline the requirements for Personal Protective Equipment

(PPE) at all EQT locations.


2.1 EQT requires appropriate PPE be worn at all work locations based on the hazards identified through the PPE hazard assessment. All field locations must adhere to the EQT minimum PPE requirements, which include:

Hard-toed boots (ASTM F2413); Safety glasses with side shields (ANSI Z87.1); Hard hat (ANSI Z89.1)

2.2 Most EQT locations and activities require the use of flame-resistant (FR) long pants or coveralls

and long-sleeved shirt (NFPA 2112) for flash-fire hazards or NFPA 70E for electrical arc-flash hazards. See Section 3.8 for detailed FR requirements.

2.3 Personnel near waterways must wear a properly fitted and correctly adjusted US Coast Guard-

approved PFD when working near flowing water or standing water of at least three feet. For entry into any impoundment or AST, refer to EQT’s Confined Space Program.

3 PPE

3.1 The minimum PPE requirements include flame-resistant (FR) long pants or coveralls and long-sleeved shirt, safety-toed boots, safety glasses, hard hats, and gloves available.

Minimum PPE is required when:

o Working on equipment or facilities, construction sites, maintenance areas, drilling locations, compressor stations and yards, gas wells, excavations, vaults, meter houses, and similar locations.

Exceptions include office and parking areas or inside enclosed cabs of mobile equipment, trucks and cars. Other exceptions must be approved by EQT.

High-visibility long-sleeved shirts or high-visibility vests overtop of long-sleeved shirts are required in high traffic areas, congested areas, or low visibility with vehicle and equipment.



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3.2 Hard Hats

Wear only approved hard hats that meet the requirements defined in ANSI Z89.1. Hard hats must be kept clean. They are not to be marked in any way except for the

appropriate company emblem. Stickers might be acceptable if applied per the manufacturer’s instructions. Prior to use, hard hats must be inspected for cracks, defective suspension, or other

impairments. Hard hats are to be worn as designed and prescribed by the manufacturer, with the bill of

the hat facing forward. Only approved hardhat liners and sweatbands may be worn; hairnets, bandanas, and ball

caps may not be worn under hard hats.

3.3 Eye Protection

Eye protection must be equipped with side shields and meet the current specifications contained in the ANSI Standard Z87.1.

Prior to use, safety glasses must be inspected for cracked or damaged lenses, missing or damaged side shields, or other impairments.

In addition to safety glasses, many operations require a special type or a combination of types of eye protection. A welding hood or goggles for welding and burning operations, and face shields for grinding, as well as face shields or goggles for chemical splash, are among combination examples.

Eye protection from potentially injurious light radiation must be equipped with filter lenses that have a shade number appropriate for the work being performed.

o Welders must wear eye protection appropriate for the type of welding being conducted.

3.4 Hard-toed Boots

Boots must meet the requirements as defined in ASTM F2413. Boots will be selected based on an evaluation of the potential hazards associated with the

worker tasks.

Additionally, specific PPE requirements are outlined in the EQT Electrical Safety and Grounding and Bonding Program and in the EQT

Chainsaw and Tree Safety Program for specialized operations.

NOTE



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3.5 Hearing Protection

Hearing protection must consist of approved earplugs, earmuffs, or a combination of the two.

All hearing protection equipment must have the appropriate Noise Reduction Rating (NRR) associated with containing the worker’s 8-hour TWA below 90 dBA.

Hearing protection must be worn while performing job tasks with an 8-hour TWA of 85 dBA and higher or in areas where such work is being performed.

Signage, as feasible, will be posted in areas where hearing protection is required. Hearing protection is also required while operating or working in close proximity to

equipment that generates noise in excess of 85 dBA. Compressors, lawnmowers, weed eaters, chainsaws, impact wrenches, and grinders are examples of such equipment.

Hearing protection also is applicable to drilling operations and other areas where natural gas is being vented or otherwise released.

3.6 Face Protection

All face protection (e.g., face shield, hood) must comply with ANSI Z87.1. Face protection must fit properly and be kept clean and in good repair. Face protection must be worn in addition to approved safety glasses or goggles when the

work activity includes one or more of the following hazards:

o Handling metal or other materials that can whip or spring, striking the face; o Exposure to flame, sparks or radiant heat; o Exposure to chemical splash, drips or spray; o Pressure spraying or cleaning; o Grinding, chipping, or cutting operations that cause flying sparks, chips, or

particles; and o Exposure to potential electrical arc flash.

3.7 Hand Protection

All personnel must wear hand protection appropriate for the hazards associated with the task. Selection of the appropriate hand protection will be determined by the chemical and physical nature of the materials handled.

Examples of tasks when gloves are required include, but isn’t limited to:

o Welding, cutting, and burning. o Handling steel, cables, piping, and sharp-edged material. o Working with corrosive or caustic chemicals. o Cold or hot temperature extremes. o Exposure to chemical splash, drips, or spray.



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o Pressure spraying or cleaning. o Using Hammers and Wrenches.

Gloves are required to be available at all field locations.

3.8 FR Clothing

EQT locations and activities require the use of FR long pants or coveralls and long-sleeved shirt (NFPA 2112) for flashfire hazards or NFPA 70E for electrical arc-flash hazards.

FR clothing is to be worn as the outermost layer of clothing. FR shirts must be tucked into pants, and sleeves and shirts must be buttoned or coveralls zipped.

FR garments must not be soiled with flammable substances. Clothing underneath the FR clothing must be made from cotton or other natural fibers

that will not melt to the body in the event of a flash fire. Exceptions to when FR clothing must be worn include: new site/pipeline construction

where no hydrocarbons or risk of flash fire is present, and other general tasks that occur offsite and away from flash fire risk areas.

Welders must wear non-synthetic clothing and hand, eye, and face protection that will guard against burns and UV radiation.

FR clothing must be free from damage or defects that will compromise coverage or protection. Damaged or defective clothing should be replaced immediately.

Clean and maintain FR clothing according to the manufacturer’s instructions. Electricians working on or near energized circuitry equipment must have FR clothing

with a sufficient Arc Thermal Performance Value (ATPV) to provide adequate protection from voltages and currents. For specific requirements, see the EQT Electrical Safety, Grounding and Bonding Program.

3.9 Respiratory Protection

Respiratory protection must be worn when working in potentially harmful environments

due to displaced oxygen, the presence of toxic and other harmful gases, or while performing operations that generate dusts, fibers, or fumes above OSHA’s Permissible Exposure Limits (PEL).

Only Qualified Personnel may use respiratory protection. This requires a physical examination, training, and fit testing.

Respirators may not be worn by personnel with facial hair that comes between the sealing surface of the face piece and the face. Glasses and goggles must not compromise the seal of the face piece.

At least one additional person must be present in areas where the wearer, with failure of the respirator, could be overcome by a toxic or oxygen-deficient atmosphere. Communication (visual, voice, or signal line) must be maintained among all individuals present.



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Respirators must be maintained through regular cleaning and disinfecting. Respirators used by more than one person will be cleaned and disinfected thoroughly after each use. Cartridges must be changed according to their prescribed frequency.

Respirators must be stored appropriately to protect them against dust, sunlight, heat, extreme cold, excessive moisture, and damaging chemicals.

3.10 Fall Protection

Personal fall protection must be worn when working at unprotected heights of four feet or

greater. For specific requirements, see the EQT Working at Heights Program.

3.11 High-visibility Clothing

High-visibility clothing is required in high traffic areas, congested areas, or low visibility with vehicles and equipment.

At a minimum, garments must be rated for for Class 2 performance. Class 2 high-visibility clothing must have a minimum of 775 square inches of

background fabric for roadway environments and 450 square inches of background fabric for public safety environments.

If working in an area where FR clothing is required, high-visibility clothing must be FR rated.

4 PROCEDURE

4.1 Personnel must inspect PPE before each use. Damaged or defective PPE must not be used.

Implement a Stop Work Authority (SWA) action if proper PPE is not worn. 4.2 PPE requirements for a specific task will be identified and communicated through:

Hazard Assessment and Control Process; Postings at job locations; and On-site supervisors and safety representatives.

5 TRAINING

5.1 All personnel required to wear PPE must receive training in the proper use and care of PPE

before being allowed to perform work requiring its use. Re-training shall be offered periodically to PPE users as needed.

6 RECORD RETENTION – EQT ONLY 6.1 PPE training records and completed PPE Hazard Assessments (Appendix A) shall be maintained

permanently.



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6.2 Respirator use training records shall be maintained for the duration of the employment and the completed respirator use questionnaire shall be maintained for the duration of employment plus thirty years.


7.1 EQT Supervisors



Adhere to this Program during all work operations. Business partners must have a

verified PPE Program in ISNetworld.


Defines the minimum PPE requirements for employees and business partners on EQT locations;

Completes PPE hazard assessments for the various EQT operations; Trains employees on job-specific PPE requirements and the EQT Safety Program; and Evaluates requests for non-standard PPE.

8 DEFINITIONS

American National Standard Institute (ANSI): a nonprofit organization that oversees development of voluntary consensus standards for products, services, processes, systems, and personnel. American Society for Testing and Materials (ASTM): a nonprofit organization that develops and publishes technical standards for the testing and classification of materials. National Fire Protection Association (NFPA): a trade association that creates and maintains copyrighted standards and codes to help eliminate death, injury, property and economic loss due to fire, electrical and related hazards. PPE Assessment: act of evaluating job tasks for hazards that cannot be controlled by engineering or administrative countermeasures. United States Coast Guard (USCG) Approved Personal Floatation Device (PFD): a USCG- sanctioned piece of equipment (e.g., life jacket, vest, preserver, belt, or buoyancy aid or flotation suit) designed to assist keeping the wearer afloat in water.


Title Short-Service Employee

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PURPOSE AND SCOPE

1.1 The purpose of the Short-Service Employee (SSE) Program is to define procedures and precautions that must be followed on EQT locations where newly hired employees are working.


2.1 This program has been established to provide short-service employees with specific safety,

supervisory, and supplemental job-site support during the first six months of employment. 2.2 A competency evaluation can be conducted at any time prior to six months, and if deemed

qualified to perform their job functions, the worker can be removed from the SSE program. 2.3 A short-service employee shall not be assigned a job or task without being trained adequately

and provided specific job instruction during the task.

3 APPLICABILITY

3.1 For purposes of this Program, “short service” applies to: 1) all field personnel who have performed less than six months of service (consecutive or non-consecutive) from the date of initial employment; and 2) field personnel with less than six months of experience with a new, significantly different, job function.

3.2 Short-service employees must not be left to work alone unless prior approval has been given by a

supervisor, the employee has been trained adequately, and provided specific job instruction for the task.

3.3 Mentoring

As part of this Program, a mentor must be assigned to short-service employees. Under this Program, a mentor will have sufficient experience and understanding of all policies and procedures.

The mentor will be available to answer the short-service employee’s questions, offer guidance and advice and generally provide the benefit of the mentor’s experience, support, and encouragement.

3.4 Business Partner SSE Requirements

All business partners are required to maintain, at a minimum, an SSE program that meets

the requirements of the EQT SSE Program. Business partners must have a verified SSE program in ISNetworld and provide documentation to EQT upon request.


Title Short-Service Employee

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Business partners must provide short-service employees with specific safety, supervisory, and supplemental job site support during the first six months of employment. This support includes but is not limited to:

o A method of visual recognition on a job site or work location, (e.g. a green hard hat)

o A process of mentoring these individuals to help gain experience and familiarity in work assignments and job-site environment

3.5 Training

All personnel must receive all required safety related orientations prior to working on EQT locations.

3.6 Visual Recognition

EQT will use a light green hard hat to signify their Short Service Employees. Business partners can use their own form of SSE recognition, provided it’s in their

policy, it’s easy to recognize in the field, and it’s on their hardhat.


4.1 Supervisors

Implement this Program


Adhere to this Program during all work operations.


Evaluates adequacy of the Program; Provides new hire orientation safety training


Title Tools and Equipment

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1 PURPOSE AND SCOPE

1.1 The purpose of the Tools and Equipment Program is to define requirements for the proper use, inspection, and maintenance of tools and equipment by all personnel on EQT locations.


2.1 Personnel will use only safe, undamaged tools and equipment and strictly for the purposes intended by the manufacturer.

2.2 Field-manufactured (homemade) and/or field-modified tools must not be used without first being inspected, rated, and approved.

2.3 Personnel must use appropriate personal protective equipment (PPE) when using tools and equipment.

2.4 Tool and equipment guards must not be removed or altered.

2.5 Personnel must perform visual inspections before, during, and after use of tools and equipment, including personal tools and equipment used in the scope of employee’s work.

2.6 Never use a portable electrical tool in areas where flammable gases or vapors are, or could be,

present unless it is designed for such use. 2.7 Avoid wearing loose clothing.

2.8 Electrical components must conform to the National Electrical Code. 2.9 All electrical tools must be connected to a ground fault circuit interrupter (GFCI).

2.10 Never carry tools by their cord.

2.11 Avoid standing in water when using electric tools. When standing in water is unavoidable, use rubber boots and gloves, and properly elevate the cord.

2.12 Remove all damaged portable electric tools from use and tag "Do Not Use."

3 GRINDING WHEEL EQUIPMENT

3.1 Safety Procedures

All operations must follow manufacturer requirements. Use the correct size and type wheel. Ensure guards and hoods are positioned to deflect flying particles away from operator

and ignitable materials. The work rest must be rigid and properly adjusted and tightened.



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Inspect all wheels for flaws immediately prior to mounting. Tap wheels gently with a light tool to determine if the wheel might be cracked.

Ensure required 1/8-inch maximum clearance between the wheel and the work rest. Never operate wheels at speeds above the manufacturer’s recommendations. Ensure required 1/4-inch maximum clearance between the wheel and the tongue guard.

3.2 Portable Grinders

All operations must follow manufacturer requirements. Guarding must be appropriate to the task. Do not use a portable grinder that is improperly

guarded.

4 HAND TOOLS

4.1 General Safety Requirements

Select proper tool for the specific job. Inspect each tool before and after use. Ensure hand tools are clean and maintained appropriately. Discard or repair worn or defective hand tools. Ensure wooden handles of tools are free of splinters and secured tightly to the tool. Place tools in boxes, racks, or trays to ensure they are stored appropriately. Sheath sharp-edged tools when they are not in use. Ensure co-workers are in the clear when using swinging hand tools. Tools are not to be used for purposes for which they were not designed or beyond their

capacity

4.2 Hammer Safety Requirements

Use non-sparking hammers if metal-to-metal striking operations are necessary in atmospheres containing flammable materials or explosive dust and vapors. Hammers made of copper, brass, rawhide, rubber, wood, or similar types of materials are suitable for this purpose.

4.3 Wrench Safety Requirements

Use the proper size wrench for the task; never use a wrench beyond its capacity. Never use an improvised extension (e.g., a “cheater”) on a wrench handle to gain

leverage unless it has been approved by the EQT Corporate EHS Department. Always pull on a wrench, if possible.

o Ask for assistance when either you have tried to complete the task safely without

success or determined it requires more than one person and/or mechanical assistance to complete.

Never strike a wrench with a hammer unless the tool is designed for that purpose.



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Ensure stable footing before using a wrench, adjusting your stance to prevent a fall if a sudden release were to occur.

5 PNEUMATIC TOOLS

5.1 General Safety Requirements

Safety clips or retainers must be installed securely and maintained on pneumatic tools to prevent attachment from being expelled.

Install whip-check safety cables in all high-pressurized hose applications to help prevent injury if a hose connection separates.

Never use oxygen to power pneumatic tools.

6 TRAINING

6.1 EQT employees and business partners shall be trained to operate tools and equipment in accordance with manufacturer specifications.


7.1 EQT Supervisors

Pre-approve purchases of hand and portable power tools.

7.2 EQT Employees

Adhere to this Program, as well as inspect and appropriately store hand and power tools.


Conduct PPE hazard assessments and assess tool variances or modifications.


Adhere to this Program, as well as inspect, use, and appropriately store hand and power tools in accordance with 29 CFR 1910.242

8 DEFINITIONS

Ground Fault Circuit Interrupter (GFCI): a device that reduces the risk of electric shock. Guard: a safety feature consisting of a shield or other device that covers a machine’s hazardous aspects, like chips or sparks, to prevent body contact.

Pneumatic Tool: air-powered device driven by compressed air, supplied by an air compressor.


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1 PURPOSE AND SCOPE

1.1 The EQT Working at Heights Program establishes procedures applicable to working on ladders, aerial lifts, scaffolds, elevated surfaces, wells, near cellars, and in any other areas where personnel are exposed to fall hazards of at least four feet. The requirements of this Program apply to all EQT employees and business partners working on EQT locations.


2.1 Personnel must be trained in fall hazards, safe ladder practices, and fall protection equipment required for the task prior to beginning elevated work. Training must be delivered by a Competent Person.

2.2 A hazard assessment must be completed to identify and evaluate hazards when personal fall protection is required for a task.

2.3 When a fall hazard has been identified in an area where employees are exposed to hazards greater than four feet, it must be evaluated by a Competent Person to determine the feasible means of protecting personnel who will be performing the work.

2.4 The hierarchy of controls for working at heights listed below should be followed when evaluating tasks to be performed at greater than 4’ above a lower level.

Eliminate the fall hazard (complete work from ground, etc.) Prevent falls (guardrails, etc.) Control the fall (personal fall arrest system, etc.)

2.5 Questions about fall protection should be addressed by a competent person.

2.6 Employees must be accompanied by another person whenever they are required to use personal fall arrest systems for working on elevated surfaces of at least four feet.

2.7 Appropriate rescue procedures and equipment must be in place prior to starting elevated work. Elevated work must not be performed where an emergency cannot be observed immediately and prompt rescue assistance summoned. Prompt rescue efforts of personnel who have fallen must be available by contacting 911 or radioing for help. Rescue procedures should be detailed on the pre-job hazard assessment.

2.8 Personnel are required to use a personal fall arrest system and be connected to an anchor point 100 percent of the time unless a guardrail is in place.

2.9 Multiple lanyards may not be connected to reach an anchor point.

2.10 Do not use anchor points that will cause a load to be applied to the snap hook keeper (gate) or snap lock (side loading).

2.11 Use anchor points designed to accommodate multiple workers if more than one worker is tied to

the same anchor point.



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3.1 The following is an overview of fall protection options that must be used. Proper selection and implementation for any given situation is critical. Fall protection throughout EQT operations uses the following three options:

Guardrail Systems Fall Restraint Systems Personal Fall Arrest Systems

3.2 Guardrail systems may be installed for temporary or permanent control and must meet regulatory

requirements.

3.3 A fall restraint system uses a line attached between the employee and an anchor point to prevent the employee from walking or falling off an elevated surface. A fall restraint system is composed of:

An anchor; Connective means (lanyard or rope); and Full Body Harness (no body belts).

3.4 Fall arrest personal protective equipment (PPE) must be used to minimize fall hazards either where engineering controls do not eliminate the hazard or in conjunction with engineering controls.

3.5 An individual personal fall arrest system can consist of many different components, such as a full body harness, anchor point, lanyard, lifeline, and deceleration/grabbing device. It is important to understand the use and application of each component and how it works with other components. All fall protection equipment must:

Meet or exceed the appropriate OSHA and American National Standards Institute (ANSI) criteria. All personnel must use only commercially manufactured equipment specifically designed for fall protection and certified by a nationally accredited and recognized testing laboratory.

Have the appropriate labels indicating manufacturer and approvals for specific use.

3.6 Those working in situations in which they could be exposed to flames or electric arcs must select fall arrest equipment that meets the requirements of ASTM F887.

3.7 During the hazard assessment prior to beginning work, the assigned Competent Person will evaluate the elevated work to be completed and select the appropriate deceleration device needed. Deceleration device options include:

A self-retracting lanyard/lifeline that contains a drum-wound line that can be extracted or retracted slowly.



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A rip-stitch lanyard, which has extra webbing incorporated into the lanyard. A shock-absorbing lanyard has webbing designed to stretch as it receives the worker's

falling weight.

3.8 All fall protection equipment must be inspected, used, stored, maintained and disposed of according to the manufacturer’s directions.

3.9 Any fall arrest system or component used to arrest a fall (impact loading) must be immediately removed from service.

3.10 Personnel must conduct visual inspections of fall protection equipment prior to each use. Detailed inspection requirements are included in Section 6. If a piece of equipment shows any signs of wear, it must be immediately removed from service and the supervisor notified.

3.11 Stow equipment in a clean area, removed from sunlight and extreme temperatures that could degrade materials. Follow the manufacturer’s recommendations for cleaning, maintenance, and storage.

3.12 Lanyards and lifelines must have a minimum breaking strength of 5,000 pounds.

Lanyards may not exceed six feet in length. Lanyards must be the appropriate length for the work height and anchorage point

location. Connecting assemblies must have a minimum tensile strength of 5,000 pounds. Self-retracting lifelines and lanyards must have a tensile strength of at least 3,000 pounds

(5,000 pounds for rip-stich, as well as tearing and deforming lanyards) and limit free fall to two feet or less.

All personnel must use a self-retractable lanyard/lifeline when working at elevations of 18.5 feet or less. This is also required when working in an aerial lift. Fall Restraint can also be used in lieu of an SRL.

Shock-absorbing lanyards not exceeding six feet in length can be used for fall protection above 18.5 feet.

3.13 Personal fall arrest systems must limit the maximum arresting forces to 1,800 pounds with a full-body harness and must have sufficient strength to withstand twice the potential impact energy of the falling employee.

3.14 Lifelines must be protected against cutting and abrasions.

3.15 Under the supervision of a qualified person, horizontal lifelines must be designed, installed, and used as part of a complete personal fall arrest system that maintains a safety factor of two. On suspended scaffolds or similar work platforms with horizontal lifelines that could become vertical lifelines, the devices used to connect to a horizontal lifeline must be capable of locking both directions on the lifeline.

3.16 Each employee must be attached to a separate lifeline when vertical lifelines are used.



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3.17 Where a positioning device is used, it must be:

Designed to ensure a free fall cannot be more than two feet; and Secured to an anchor point capable of supporting at least twice the potential impact load

of an employee’s fall or 3,000 lbs.

3.18 Any fixed ladders over 24 feet must have a fall protection system installed.

4 ATTACHMENT REQUIREMENTS

4.1 When using a full-body harness for fall protection, connecting devices must be attached to the "D" ring on the back. Side "D" rings are only for travel limiting or work positioning and must not be used for fall arrest connections.

4.2 When using a cross-arm strap as a point of attachment, do not allow the strap slack to extend the free-fall distance of the lanyard.

4.3 Anchorage Point

An anchorage point is where the lanyard or the lifeline is attached to a structural support. o For each worker using an anchorage point, this support must have a 5,000-pound

capacity. o Workers must tie off overhead, or at or above the D-ring point of the harness as

feasible.

5 FALL HAZARD PROCEDURES

5.1 All personnel are responsible for inspecting for potential fall hazards and having each potential fall hazard evaluated by a Competent Person.

If personnel are not equipped to eliminate a hazard, personnel must contact the appropriate supervisor or site contact to correct the problem.

Personnel should alert their supervisors to potential fall hazards newly identified and not controlled. Fall hazards requiring protection include but are not limited to:

o Open-sided floors, platforms, and runways with a fall hazard more than four feet or near dangerous operations regardless of height;

o Wall openings where there is a drop of more than four feet; o Any opening more than four feet where a significant portion of the body would be

required to lean over or through to perform work.

5.2 Dropped Objects and Overhead Protection

All Personnel must be trained properly to secure tools at height and understand correct procedures that will minimize dropping of objects and the injuries and damage that can result from them.

Use the hazard assessment to evaluate where objects most often are dropped, including:



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Rig derricks/drill floor; Areas below lifting operations; Cranes, forklifts, and other elevated work areas or platforms; Work spaces where equipment is mounted overhead; Temporary/portable equipment; Remotely operated vehicles (ROV); Pipe racks; and Ladders and scaffolding.

The appropriate controls and prevention system (primary and/or secondary) must be selected based on the risks identified in the hazard assessment. Use primary prevention when possible.

The primary drop prevention while working at heights include use of the following:

Tool Attachment Points: Prior to selecting a tool lanyard, a proper attachment point must be established on the tool;

Tool Lanyards/Tethers: After establishing an adequate attachment point on a tool, select a proper tool tether that has an appropriate load rating for the tool to be tethered;

Tool Holsters and Pouches: For some tools and objects, a tool holster or tool pouch might be appropriate;

Tool Belts: Upon choosing a proper method for tethering, select an appropriate anchor point for the remaining end of the tethering device;

Wristbands: Never use wristbands with tools weighing more than five pounds; and Tool Buckets: Use only if they are manufactured with a closure system that allows

contents of the bucket to be secured.

Secondary Drop Prevention

Design control options for the secondary containment of drops while working at heights include:

o Safety Netting: Nets should be designed with specific-sized webbing approved by the manufacturer for use based on the task, location and type of tools/materials being used. Safety nets must be hung, tested and maintained in accordance with the manufacturer’s instructions, as well as the requirements of OSHA CFR 1926.502;

o Toe Boards: Toe boards must be erected along the edge of overhead work in order to protect employees below the overhead work area;

o Dropped Object Zones: Zones are marked clearly with barricades or warning (“caution” or “danger”) tape to control access; and

o Guardrail Systems: Guardrail systems will need to be designed, installed, and inspected by a Qualified Person to ensure they comply with requirements.



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If an incident occurs, a dropped object calculator must be used to inform EQT of actual and potential severity.

5.3 A Competent Person must be designated to determine if engineering controls can eliminate or lessen the hazard of the work area or job site. Engineering controls must be provided where possible to minimize fall hazards.

Guardrails, parapets, and toe boards:

o A standard railing consists of a top rail, mid-rail and posts and is approximately 42 inches (plus or minus three inches) high from the top rail to the floor, platform, runway or ramp. Nominal height of the mid-rail is 21 inches.

o Standard toe boards must be a minimum of four inches high, with no more than 1/4-inch clearance to the floor. If a mesh material is used, the opening must be less than one inch.

o Anchoring of posts and framing of members for all railings must be constructed to ensure the completed structure is capable of withstanding a load of 200 pounds applied in any direction at any point on the top rail.

o Guardrail systems must have a surface that prevents injuries, such as punctures and lacerations, and prevents snagging of clothing.

o When guardrail systems are in hoisting areas, a chain gate or removable guardrail must be in place when not being used.

Covers:

o Covers for holes, including grates, must be able to support without failure at least twice the employee’s weight, equipment, and materials that could be imposed on the cover at any one time.

o Covers located on roadways and vehicular aisles must be capable of supporting without failure at least twice the maximum axle load of the largest vehicle expected to cross over it.

o All covers must be secured when installed to prevent accidental displacement by the wind, equipment, or personnel.

o Covers must be marked with the word “HOLE” or “COVER” to provide warning of the hazard when not readily apparent.

o If cover is removed, someone must monitor the hazard continuously while a cover is not in place.

5.4 A Competent Person must determine all required anchor points — temporary and permanent —

during preparation and completion of elevated work. Only Qualified Persons are authorized to design anchor points used in specific fall arrest systems.

5.5 Personal fall arrest systems must not be attached to guardrail systems or hoists except as specified in other regulations.



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6 HARNESS/LANYARD INSPECTION AND MAINTENANCE

6.1 The Competent Person must inspect the fall protection equipment at least annually and document inspection results.

6.2 All personnel must inspect fall protection equipment daily prior to use per manufacturer’s recommendations.

EQT employees may reference Appendix A for inspection requirements.

7 FIXED AND PORTABLE LADDERS

7.1 Only authorized EQT employees who have completed required ladder safety training are permitted to use fixed and portable ladders at EQT work locations. Business partners must have a verified Ladder Safety program in ISNetworld and train personnel on its requirements. Wooden ladders are prohibited.

7.2 Ladders must be inspected prior to each use. If a ladder has any defects, damage or other potential safety hazards, it must be tagged and labeled “Do Not Use” (or similar language) that readily identifies it as unsafe. Unsafe ladders must be removed from service until repaired.

7.3 When handling or using ladders on EQT locations, all personnel must adhere to the following safe work practices:

Never use the top 2 steps of any ladder; Maintain at least three points of contact while ascending/descending a ladder; Face the ladder when ascending or descending it; Use non-self-supporting ladders at an angle where the horizontal distance from the top

support to the foot is approximately one-quarter of the working length of the ladder (4-1 Rule);

Personal Fall Arrest Systems must be used if working from a ladder greater than 4’ high and 3 points of contact cannot be maintained.

Use only on stable and level surfaces unless secured to prevent accidental displacement; Ensure the area around the top and bottom of the ladder is kept clear; Do not move a ladder while it is occupied; When accessing an upper level, the ladder side rails must extend at least three feet above

the upper landing; Only approved ladders must be used when working around electrical equipment; Never exceed the weight limit for a ladder or use in adverse weather conditions that

would put personnel in danger; and Use only according to manufacturer’s requirements and the purposes for which it is

designed.

7.4 If a task requires the employee to leave the confines of the ladder, then the ladder must be secured and additional personal fall protection may be required.



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7.5 All portable ladders must be designed and maintained in accordance with manufacturers’ recommendations. All fixed ladders must meet the OSHA design requirements outlined in 29 CFR 1926.1053 and 29 CFR 1910.23.

8 AERIAL LIFTS

8.1 Only authorized and trained personnel are allowed to operate the equipment.

8.2 Aerial lift training must include a classroom portion that covers principles and safe work practices, as well as a practical (field) exam to demonstrate competence specific for each type of aerial lift. The class will be delivered by designated competent personnel familiar with the equipment.

8.3 Prior to each use, each aerial lift will be inspected by a competent person. The inspection must ensure the ground level and the elevating platform controls are functional, there is no equipment damage, and check any other items covered in the equipment safety manual. Inspections must be documented, maintained on file, and available upon request.

8.4 Check the weather forecast prior to using an aerial lift to determine if conditions are safe per the manufacturer’s instructions. During operation of an aerial lift, employees must also adhere to the following safe practices:

Ensure aerial lifts are rated appropriately for the atmosphere in which they will be used; Use only on grades/slopes that are safe for operation of the equipment; Never exceed the maximum weight load; Maintain proper distance between electrical equipment and overhead hazards; Maintain safe distances from on-the-ground obstacles, such as holes and excavations; Maintain a safe view of the path of travel; Wear appropriate PPE, including a hard hat and safety harness with self-retracting

lanyard attached to a designated point on the lift; and Keep feet firmly on the lift at all times.

9 SCAFFOLDING

9.1 All scaffolding must be designed and constructed in accordance with OSHA Standards. Only qualified business partners must be employed to construct scaffolding.

9.2 Business partners must designate competent personnel who will conduct daily inspections on all scaffolding at all EQT locations. Any deficiencies must be repaired prior to any workers using the scaffolding.

9.3 EQT employees are not anticipated to climb scaffolding; however, if the need arises, a hazard assessment must be completed and the EQT employees must be trained properly on how to use the scaffolding prior to use. Additionally, the scaffolding must have received its daily inspection by competent personnel prior to EQT employees climbing the scaffolding.

10 TRAINING



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10.1 All personnel must be trained to ensure familiarity with the EQT Working at Heights Program. All personnel must understand the purpose, function, and restrictions of the Working at Heights Program. This includes the hazards of working at elevations, around floor openings and cellars, ladders, aerial lifts, and scaffolding. All personnel must receive training prior to using a Personal Fall Arrest system and anytime there is a change in equipment. Training must be documented and made available.

10.2 EQT Employees will also receive annually refresher training in this Program in accordance with their assigned responsibilities.

11 RECORD RETENTION – EQT EMPLOYEES ONLY

11.1 Ladder training records for EQT employees using ladders shall be maintained for 1 year.

11.2 The documented EQT Competent Person’s annual fall protection equipment inspections referenced in section 6 of this program shall be maintained for a period of two years.



Ensure employees are informed, trained, and provided with the appropriate fall protection systems and equipment; and Coordinate the correction of fall hazards brought to their attention.


Use guardrails or personal fall arrest/restraint system for all work from heights greater than four feet; and Initiate a Stop Work Authority action and alert their supervisors when requested to work from heights without a means of fall protection; Business Partners are required to have a verified Fall Protection Program in ISNetworld.


Provides technical information and assists departments in implementing an effective fall

protection safety program; Provides technical information and assists in designing controls for fall protection; Provides and/or coordinates fall protection instruction as needed; Investigates and documents all reported incidents related to fall hazards and recommends

corrective actions; and Reviews and revises the Working at Heights Program to ensure compliance with

applicable regulations.

12.4 Designated Competent Persons



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Implement all aspects of the Program for areas under their control; Receive Competent Person training as defined by OSHA for fall protection; Serve as the Competent Person for job sites under their control that contain fall hazards; Evaluate fall hazards in work areas under their control; and Ensure personnel are informed, trained and provided with the appropriate fall protection

systems and equipment.

12.5 Designated Qualified Persons

Maintain professional certification or other requirements in their subject field; Provide design, analysis, evaluation, and specification in their subject field; and Maintain records of their designs, analyses, evaluations, and specifications according to the requirements of this Program.

13 DEFINITIONS

Competent Person: one certified as capable of identifying existing and predictable hazards in the surroundings or working conditions and who has the authority to take prompt corrective measures to eliminate them Connecting Device: the critical link that joins the body wear to the anchor/anchor connector, such as shock-absorbing lanyard, fall limiter, self-retracting lifeline, rope grab, etc. D-Ring: an integral component or provision commonly found on body wear and some anchor connectors that allows for attaching a connecting device Deceleration Device: any mechanism that serves to dissipate energy during a fall arrest, limiting the forces imposed on a person

Lifeline: provided for direct or indirect attachment to a body belt, body harness, lanyard, or deceleration device. Such lifelines may be horizontal or vertical in application

Personal Fall Arrest System: an arrangement of components that together will arrest a person in a fall from a working level Qualified Person: one with a recognized degree or professional certificate and extensive knowledge and experience in the subject field who is capable of design, analysis, evaluation, and specifications in the subject work, project, or product

Snap Hook: a connector with a hook-shaped member, keeper, latch, or other similar arrangement that may be opened to receive an object, and when released, automatically closes to retain the object


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1 PURPOSE AND SCOPE

1.1 EQT is committed to providing a safe and secure environment for all employees, business partners and visitors. These guidelines are intended to create a consistent approach to protect people, assets, and information while mitigating risks to EQT. The guidelines are not intended to supersede government statutes or regulations and will be updated as needed to better support the business.

1.2 These guidelines apply to all EQT locations, employees and business partners.

2 REPORTING AND INVESTIGATIONS 2.1 All personnel are required to immediately report all security related incidents to the Emergency

Hotline 1.833.990.1534.

2.2 The following types of incidents must be reported immediately:

• Any act or threat of violence. • Any crime or suspected criminal activity reported to law enforcement. • Any tampering with or loss of property during shipment (e.g. breach of warehouse, shipping

containers, trucks, etc.). • Any theft or any incident that causes business interruption. • Protests or demonstrations at EQT locations.

2.3 Depending on the incident, the first action may be to contact 911, law enforcement, your

supervisor, and Corporate EHS. Employees or business partners will not initiate any security investigations or surveillance – any investigation must be authorized by the Corporate EHS Department.

3 EQT IDENTIFICATION BADGE PROCEDURES

3.1 These procedures are the foundation of physical security and access control system (ACS)

procedures. ID badges are the only method to recognize the presence of unauthorized persons.

3.2 Identification badges will be issued to employees, business partners, and visitors in accordance with the EQT ID Badge Procedures. In certain circumstances the EQT Corporate EHS Department may grant an exception.

2.2 All EQT personnel must have a standard issued EQT personnel identification badge. The badge

must be worn and visible at all times while at an EQT Fixed Facility location unless it creates a safety hazard while the employee is performing work.

4 EQT ID BADGE PROCESS


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4.1 EQT locations may establish a more restrictive access control process as required to meet safety or regulatory requirements. At a minimum, EQT locations’ ID badge process must include the following:

• All EQT employees and business partners must wear their EQT identification badge where it is visible at all times while on the site.

• EQT identification badges may not be used by anyone other than the assignee. • Lost badges must be immediately reported to a supervisor and corporate security. • Found badges must be immediately returned to corporate security. • EQT employees and business partners who have lost or forgotten their identification badge

must wear a visitor badge until their badge is replaced or found. • Any person not displaying his or her identification badge may be asked to present his / her

identification badge. • “Tailgating” or “piggy-backing” is not permitted for unauthorized person (s) (e.g. non EQT

employee or business partner). • Visitors must be provided a visitor badge which must be visible while on location. • Visitor badges must be tracked, and a process must be in place to return the badges to the

reception area following the completion of the visit. • Visitor badges must be accounted for at the end of each day.

4.2 Any Fixed Facility that produces ID badges must issue ID badges consistent with the format set forth in Figure 2 below.

4.3 The Facilities Department can provide specifications (e.g. dimensions, color scheme and cardstock.) (see Figure 2)

Figure 2 – EQT Identification Badges

4.4 To prevent unauthorized access, Human Resources or managers / supervisors are responsible for collecting EQT identification badges from employees and business partners at the time of resignation / termination. All badges must be returned to the Facilities Department. The


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person responsible for issuing EQT identification badges will make final disposition of the badge once it has been returned. The terminated badges must be turned-in, do not discard.

4.5 EQT Facilities Department is responsible for the overall implementation and compliance of this procedure.

4.6 Each Fixed Facility producing ID badges must keep a record of all ID badges issued and account for all ID badges of departing individuals.

5 EQT SITE CHECK IN PROCEDURES AND FOCUS SAFETY BADGE

5.1 All EQT personnel, business partners, and other companies accessing an EQT field location must sign in with Security (when present). EQT contracts security guards on all active Drilling, Completion, and Flowback locations, and any location deemed necessary by Corporate EHS.

5.2 To gain access to EQT sites all personnel must present photo ID/ photo drivers’ licenses, and FOCUS Safety Badge to security guard. (see figure 3) Anyone who fails to comply with this request will be denied access to EQT field locations.

Figure 3- FOCUS Safety Badge

5.3 The check-in procedure goes as follows:

• Present Photo ID/Photo Driver’s License, along with FOCUS safety badge every time you sign in. The security guard will verify credentials and the company you represent.

• If present, report directly to the OSR (On Site Representative) trailer to notify them that you are onsite and why you are there. The OSR will then grant you permission to work on that site.

• Government agencies such as, DEP, ODNR, OSHA, etc. and emergency response teams such as police, EMS, fire fighters, etc. are the only personnel exempt from presenting a FOCUS Safety Badge.

Spiker, Chanc

I’ve made minor changes to this statement.


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6.0 VISITOR ACCESS PROCEDURES

6.1 The responsibilities listed in the Visitor Access Procedures, apply to any EQT location that receives visitors e.g., individuals not issued an EQT ID badge. Any visitor to an EQT site must have a designated sponsor and escort prior to being granted access to the site.

6.2 Requests for exceptions to this procedure must be submitted to the Corporate EHS Department. 6.3 All visitors that enter an EQT location should, if time permits, have a sponsor pre-register the

visitor(s) prior to arrival. The pre-registration process will be developed at each site – at a minimum the process will capture the following information:

• Full name • Company representing • Sponsor’s name • Date and time of arrival

6.4 All visitors must be escorted at all times

7 VISITOR RECEPTION PROCESS

7.1 Visitor logs must be maintained for a minimum of 3 months. If possible, the log in process should be of such a design that visitors, or others standing at the reception desk, are unable to see who has previously signed into or out of the site.

7.2 The Visitor Reception Process is outline below:

• Ask visitors to sign in using the site visitor log book or other registration system. (see Figure 4)

• Ask to see photo identification (e.g. driver’s license, passport). • View the sign in log or registration system to ensure it is complete. • Contact the sponsor to notify him/her that his/her visitor is waiting for them at the reception

desk. • Once the sponsor has arrived, issue the visitor a “Visitor Escort Required” badge with

instructions to the sponsor that the visitor badge must be returned at the end of the visit.

8 RESPONSIBILITIES

All EQT employees:

• Fulfill sponsor and / or escort requirements in accordance with this procedure. • Ensure that visitors enter only those areas of a fixed facility necessary for fulfilling

business requirements.


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• Report potential or suspected violations of this procedure to the visitor’s sponsor, the sponsor manager or corporate security.

Sponsors of Visitors:

• Properly register any visitor to the site in accordance with this procedure. • Designate a person to be the visitor’s escort. • Ensure that visitors properly display their visitors badge during the entire visit. • Report to your manager or Corporate EHS any violation of this procedure. • Ensure visitors only go into areas of the site that they are specifically permitted to visit. • Visitors may not use cameras or audio/visual recording devices unless specifically

authorized by EQT Legal Department or the Vice President of EHS. • Ensure that any badge issued to their visitor is returned to the reception desk at the

completion of the visit.

Figure 4 – Visitor Log


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1 PURPOSE AND SCOPE

1.1 The purpose of this policy is to define a standard procedure for Spill Management for all personnel on all EQT locations. All findings of any amount whether on or off containment are to be reported to EQT’s Emergency Response Hotline 1-833-990-1534.

2 SPILL RESPONSE

2.1 Conduct a visual inspection of your work area upon arrival and prior to departure (360 Walk) 2.2 If a spill or stain is observed:

• Stop the spill from continuing (ex: leaking pipe) if applicable and can be done in a safe manner. Contain spill to best of your ability if needed or able.

• Immediately report to EQT’s Emergency Response Hotline 1-833-990-1534 • If the situation is dangerous or unsafe: STOP, remove yourself from the situation, then

immediately report to the EQT Emergency Response Hotline 1-833-990-1534 • Provide a detailed description of findings and events to include:

1. Site Name 2. County & State 3. Time of Incident 4. Contact Information 5. Type of Work/Activity 6. Estimated Quantity or Size of Area 7. Type of Spill 8. On/Off Containment 9. Waterways Impacted (Yes/No) 10. Company Responsible 11. Photos of the scene

• Once properly reported, EQT EHS will handle the documentation and dispatch a remediation

team for the event. • Do not remove waste from location: All waste generated from spills and remediation will be

disposed of by an EQT approved business partner.

3 TRAINING

All field personnel are required to be trained on Spill Response.



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4.1 All Personnel

• Use of properly sized secondary containment for storage of all materials including, but not limited to, fuel cans, generators, pumps, lubricants, hoses and fittings, pipe racks/pipe ends, etc.

• Monitoring of containments for punctures or tears, and replacement if necessary. • Stormwater management within containment and well cellars to prevent commingling of

contaminants and stormwater. • Frequent inspections/monitoring and maintenance of equipment. At a minimum - daily,

during shift changes, prior to moving to new work areas or tasks, and at every stream crossing.

• Report all spills and/or staining of any amount on or off containment to the EQT Emergency Response Hotline 1-833-990-1534.

4.2 EQT Supervisors

• Ensures their direct reports and business partners are reporting all spills. • Participate in investigations as necessary.


• Coordinate Spill Response • Make proper notifications to Regulatory agencies • Develop training for this program • Ensure all spills are remediated properly and closed out accordingly.

5 DEFINITIONS

Spill – Any unauthorized discharging, leaking, releasing, pumping, pouring, emitting, emptying, injecting, leaching, escaping, dumping or disposing of any material into the natural environment – on the ground, surface waters, ground water, or air. This includes, but is not limited to, any spill of oil, lubricant, grease, sediment to water, chemicals, gases, condensate, and sand. (Incidents involving releases into containment must also be reported.) Spill Kit – A collection of absorbent items (pads, booms, oil-dri), to be used in rapid response typically for small spills, leak or other discharge of fluids. Spill Shed – A larger collection of items (pads, booms, oil-dri), to be used in case of a spill, leak or other discharge of fluids.



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Containment – Barriers/containers (impermeable liners, berms, drums, totes, buckets, portable duck ponds, etc.) used to prevent the release of fluids into the natural environment Contain – To keep within a certain area or boundary Remediation – The removal of pollutants or contaminants from environmental media such as soil, groundwater, sediment, or surface water


Title Water Supply Protection

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1 PURPOSE AND SCOPE

1.1 EQT is committed to conducting all operations in an environmentally responsible manner and is aware of the importance of private water supplies to the rural communities where our work occurs. The Water Supply Protection Program is the process for locating water supplies and documenting the conditions before EQT operations and activities commence, and the response protocols for complaint resolution, should a complaint occur.

1.2 This procedure applies to all EQT locations and all personnel involved in any work that may

involve potential impacts to private water supplies, including wells, springs, ponds, streams, etc. For the purposes of the Water Supply Protection Program, EQT operations and activities include, but are not limited to well pads, well pad access roads, and plugging locations.

2 BACKGROUND

2.1 EQT identifies and collects background information on all water supplies within 3,000 feet of

well pad locations. Property owners are interviewed to provide the locations and uses (potable, husbandry) for water supplies as well as details (if known) relative to the age, depth, size, quality, quantity, and general history of the supply. Water quality samples are collected by an independent business partner and analyzed for constituents indicative of the overall water quality as well as specific parameters relative to EQT operations. Per state regulation, pre-drill results are issued to the respective State reporting agency and to the landowner(s) for their record. The pre-drill sampling process may be repeated if 1) the well is re-stimulated or 2) if new wells are proposed on an existing well pad and pre-drill sampling occurred more than one year earlier.

3 RESPONSE TO WATER SUPPLY IMPACTS

2.1 When EQT (or business partners) becomes aware of a potential impact to a water supply, such as

the result of a confirmed spill or release or is informed that a perceived impact has occurred (from property owner), immediate notification to the Emergency Dispatch Center (1-833-990-1534) is required. The dispatch will route the information to EQT EHS. An ‘impact’ to a water supply is considered either quantity (diminution) or quality (degradation) issues. Quality issues could include taste, odor, turbidity, as well as water chemistry changes.

2.2 Methane occurs naturally in water supply wells in some areas and occurs naturally in shallow

formations typically related to coal. However, methane (or stray gas) can indicate mechanical integrity issues with gas wells (both conventional and unconventional) resulting in migration of methane into water wells, structures, etc. Any reports regarding methane, increases in methane, gas-like odors, bubbling in water supplies, etc. should immediately be reported to EQT


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Emergency Dispatch Center (1-833-990-1534). The dispatch will route the information to EQT EHS.

2.3 EQT EHS must report the complaint to the appropriate State regulatory agency within 24 hours

of discovery or notification of the impact (or perceived impact) to a water supply or violations from the agency could be issued.

2.4 EQT will initiate a complaint response which is an investigation initiated to gather additional

information regarding the validity and nature of the issue. This could include one or more of the following steps:

• Landowner interview and historical information review • Establish timeline of event • Mechanical/electrical system inspection • Re-sampling the supply to determine through chemical analysis the relative amounts

of constituents that are present that could impact aesthetics (taste, odor, color) and/or overall biological/chemical characteristics of the water supply

• Yield testing the water supply. Yield testing is the process to determine the water producing capability of a water well or spring.

• Conducting a thorough hydrogeologic review, which is a detailed evaluation of the topography, drainage, geology, precipitation, well depths, well construction and other site features as they may relate to actual or perceived changes in the quality or quantity of a water supply.

• A summary of the investigation will be prepared for the property owner detailing the results of the investigation.

• Where detrimental impacts to a water supply are proven to be caused by EQT operations, EQT would be responsible for restoring or replacing the water supply to the satisfaction of the state regulatory agency or the property owner.


3.1 All Personnel

• Ensure that this policy is understood and followed by all parties involved where water supplies are present or claims of water supply impacts have been reported or discovered.


Title Air Permitting

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1 PURPOSE AND SCOPE

EQT is committed to be a good steward of all our natural resources including protecting the air quality surrounding our operations. Ensuring that air quality regulations are met or exceeded is just one of the ways that EQT demonstrates commitment to employees, land owners and the community in which we operate. The purpose of this Air Permitting Procedure is to define the process to maintain air quality compliance at EQT in support of the Mission and Vision to be the operator of choice for all stakeholders. At EQT, all emission units shall be operated in compliance with applicable air quality regulations and permit conditions. This program applies to all EQT locations.

2 BACKGROUND

The foundation of air permitting in the United States is the Clean Air Act (CAA). The CAA was created in 1963, expanded in 1970, amended in 1977 and strengthened in 1990. The CAA requires the Environmental Protection Agency (EPA) to develop and enforce regulations designed to protect the public from airborne contaminants known to be harmful to people. Air permitting laws are also found in the Code of Federal Regulations, the Federal Register and Federal Register Notices. While EPA is ultimately responsible, EPA may approve and delegate State and local agencies to do the actual permit administration using laws that are codified in State Law and, in certain instances, may be stricter than Federal regulations.

3 APPLICABILITY

The Federal CAA sets emission limits to protect ambient air quality and overall human health and welfare. Certain oil and gas operations activities may trigger the need for air permitting and/or reporting. This procedure applies to all EQT locations.

An air permit will generally contain information on all regulated pollutants it releases, including how much it is permitted to release and what measures will be taken to ensure that the source won’t release more than its allowed amount of pollutants. The air permit may also require the facility to routinely report on compliance status based on routine inspections and emissions volumes calculated via simulations and EPA approved test methods. Activities that could require a new air permit or modification to an existing air permit include constructing a new emission source, or reconstructing, modifying or relocating an existing emission source.



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Emission units that typically require air permits or have emission limits include the following:

• Diesel or natural gas-fired engines; • Smaller combustion units (GPU’s, in-line heaters); • Vapor recovery units; • Natural gas dehydration units; • Storage tanks; • Flares/incinerators; • Blowdowns/venting processes; • Fugitive emissions and equipment leaks; • Open burning.

4 CONSTRUCTION AND OPERATING PERMITS

Some types of air permits can take 270 days or more to receive after submittal of a complete application. Construction and startup of emissions units that require permits shall not commence until applicable permits have been obtained. Ohio may allow certain activities to occur onsite prior to final issuance of an air permit. See below for details on Ohio-specific allowances. During the initial planning stages of an emission unit installation, modification, replacement or relocation, the EQT operations employee(s) responsible for the change shall notify the Environmental Department of such change. This will ensure timely receipt of applicable permits, as required.

Air permits may need to be modified when changes are planned such as a new, modified, relocated or like-kind engine replacement; a new dehydration system; an increase in horsepower or throughput; installation or removal of a catalyst, flare, or other control device; replacing a flare with a thermal oxidizer; increasing produced fluids production; changes in gas quality/analysis; storage tank changes (size or addition/removal); demolition activities; open burning; installing additional wells/GPUs on a pad; name changes/ownership changes; responsible official and contact changes.

If you are unsure if a planned activity needs an air permit, please contact your Environmental Coordinator or the Air Permitting Department.

NOTE



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Operations shall provide relevant data related to the equipment such as fuel usage, throughput, horsepower, hours of operation and other information as requested by the Environmental Department. The Environmental Department has created a Request for Information (RFI) document to ensure all equipment is included in the consideration of the air permit determination. Contact the Environmental Department for a copy of the most recent RFI template. Upon receipt of the RFI document, the Environmental Department will conduct an Internal Permit Determination Assessment to determine regulatory applicability related to the change. This assessment will include the development of emissions calculations, review of current source status (existing permits, emission units, etc.), and an evaluation of the impact of this change on the site and the effect on any nearby existing installations regarding aggregation.

As part of the regulatory applicability determination, the Environmental Department shall consider Federal, State and local regulations including a detailed evaluation of the following pollutants:

• (CO) Carbon Monoxide • (NOx) Nitrogen Oxides • (SO2) Sulfur Dioxide • (PM) Particulate Matter (includes PM10 and PM2.5; coarse and fine particulates) • (VOC) Volatile Organic Compounds • (Pb) Lead • (HAPs) Hazardous Air Pollutants including, but not limited to:

o Benzene o Toluene o Ethylbenzene o Xylenes o Formaldehyde

Based on the determination of the Environmental Department, either a formal Request for Determination will be submitted to the relevant agency, an air permit application will be prepared and submitted, or no permit will be required.

The Environmental Department shall document the Internal Permit Determination Assessment and maintain this documentation.

Installation, modification, or relocation of an emission unit shall not occur without approval from the Environmental Department. Pre-Construction Activities Allowed IN OHIO ONLY



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Some construction activities are allowed prior to receipt of the final air permit, however, implementation of these activities are at the entire risk of the owner or operator and any such activities must comply with applicable fugitive dust requirements.

• Clearing the site of existing vegetation, old buildings, or old equipment • Grading and clearing of land, stripping and stockpiling topsoil, earthwork cut and

fill for foundations in preparation for construction • Installing temporary site access roadways and parking areas • Installing temporary construction equipment areas • Storing of construction equipment including temporary building and trailers for

equipment storage and for construction offices • Exploratory excavation and borings to assess the suitability of a site for the intended

building or installation activities • Excavating building footers, pilings, foundations, pads, and platforms, etc. (note –

no pouring of concrete is allowed) • Installing concrete forms, and reinforcing bar for any concrete footers, pilings,

foundations, pads and platforms, etc. (note – no pouring of concrete is allowed) • Installing temporary utilities for site construction including electricity, water, gas,

communication and sanitary • Removing old equipment from existing buildings • Installation of any temporary construction dust control systems (sprinklers, etc.) • Installation of any signage or traffic control signs • Installation of any utility poles by a utility company • Installation of temporary erosion and sedimentation control systems including hay

bales, silt fences, rip-raps and sandbags • Installation of new landscaping including trees, bushes and seeding of disturbed

earthwork • Installation of landscaping fencing • Installation of temporary fences and signs around the construction site • Stockpiling of stone, soil and other materials for future construction

Additionally, in Ohio, some construction/installation activities are allowed prior to receiving the air permit and may only be undertaken if the owner/operator has filed a complete application:

• Installing electrical service for any air contaminant source up to the service panel for the new equipment. Final connections to the equipment cannot be made until the permit is issued and effective.

• Installing piping and sewers up to the point of connection to any air contaminant source or air pollution control equipment. Final connections to the equipment cannot be made until the permit is issued and effective.



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• Installing inlet air and exhaust duct work with the exception of final connections to the air contaminant source or air pollution control equipment.

• Installing site drainage systems including ditches, culverts, earthwork for underground storm drains, headwalls and catch basins. This is authorized only if any necessary storm water permits have been obtained.

• Installing concrete footers, foundations, pads and platforms for the building or for equipment.

• Installing any permanent roadways and parking areas not required to obtain a permit.

• Storing parts and equipment of the air contaminant source or air pollution control equipment.

• Construction of new or expanding buildings or the renovation or upgrading of existing buildings, in preparation for the installation of new or modified air contaminant source(s) or air pollution control equipment.

• Equipment that constitutes a component of an air contaminant source (including air pollution control equipment) may be delivered to the site prior to obtaining a final permit if the following criteria are met:

o If the equipment is to be installed in an existing building, then it may be placed in its final location and secured. No utilities, piping, or duct work may be connected to the equipment. The equipment shall not be operated.

o If the equipment is to be installed in a building that has not yet been built, then it can either be secured on the foundation of its final site or may be located anywhere on the property. No utilities, piping, or duct work may be connected to the equipment. The equipment shall not be operated.

The following flow charts provide basic overviews of this assessment for changes in Ohio, Pennsylvania, and West Virginia:



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5 FUGITIVE EMISSIONS

Air contaminants are emitted as either point sources or fugitive emissions. Point source emissions occur through engine stacks, boiler flues, chimneys, and vent pipes. Fugitive emissions enter the air by a means other than point sources and include emissions from process losses, construction activities, excavation, storage piles and roadways.

General Fugitive Dust Best Management Practices

Unless specifically allowed by regulation, no fugitive emissions are allowed beyond the property line and some construction activities may be pursued only after obtaining a permit to construct an air contaminant source.

Owners and operators should take all reasonable actions to prevent particulate matter from becoming airborne. These actions include but are not limited to:

• Use of water where possible for the control of dust. This specifically applies to

well roads, pipeline renewal/maintenance projects and spoil piles; • Prompt removal of dirt on paved streets; • Covering of material in transport vehicles; • Where a fugitive particulate matter suppression system utilizes water in its

operation, the equipment must be designed for all weather use. Open Burning If open burning is required, EQT expects the business partner to obtain any open burning permits or authorizations. The business partner will forward those approvals to EQT. EQT Safety Department should review any burning plans. If woody debris will be hauled offsite, a solid waste permit may be necessary to be obtained by the business partner. As a courtesy, open burning should be coordinated with local fire departments and/or emergency services as they may have additional requirements.

Pennsylvania Open Burning

PADEP may require a permit to burn and the use of an air curtain destructor. This permit may be rescinded if an air pollution problem exists.

West Virginia Open Burning

In West Virginia, open burning is only permitted upon written approval by West Virginia DAQ. Additionally, a permit must be obtained from the West Virginia Division of



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Forestry during forest fire season (March 1 – May 31 and October 1 – December 31) to burn between 7am and 5pm. Pitburners should be used whenever practical and may be required in non-rural areas.

WVDEP Guidelines for open burning of vegetative and land-clearing debris:

• It must be thoroughly dried at least 10 days and piled to promote combustion • No trunks, limbs or stumps over eight (8) inches in diameter (before splitting) are

allowed • It must be conducted during daylight hours, which requires the size of piles to be

small enough to burn out before dark • Fires must be completely extinguished and not allowed to smolder at night • All fires must be surrounded by a 10-foot clearing to prevent escape to potential

combustible materials • Never leave fires unattended, and keep a shovel and water source nearby • Health, safety, comfort and property of neighbors must be protected from the

effects of such burning.

In West Virginia, open burning is only permitted upon written approval by West Virginia DAQ.

Ohio Open Burning OEPA allows the burning of land clearing debris with proper approval (see note below for link to Permission Request Form). Open burning is restricted within city limits and there may be additional restrictions on times (not allowed during air pollution warning, alerts or emergencies). Additionally, Ohio Division of Forestry has some restrictions on open burning. Outdoor burning in rural areas is prohibited between 6am and 6pm during the typically dry months of March, April, May, October and November.

Diesel Truck Idling

Useful links:

PA Best Management Practices (BMP) for the Management of Waste From Land Clearing, Grubbing, and Excavation (LCGE)

WV Forestry Burn Permits

WV Compliance & Enforcement Open Burning Brochure

Ohio EPA Open Burning Regulations

NOTE



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Idling of diesel-powered vehicles results in emissions of nitrogen oxide and carbon dioxide and the consumption of diesel fuel. In order to reduce these emissions and to conserve energy, EQT employees and business partners should enforce and obey these laws. PA Requirement – Pennsylvania Act 124

The restrictions apply to the owner or operator of any diesel-powered motor vehicle with a gross vehicle weight greater than 10,000 pounds that is engaged in commerce in Pennsylvania. The law also applies to any owner or operator of a facility where an affected diesel-powered vehicle loads, unloads or parks. There are many exclusions, exemptions and exceptions to the law. Requirements: Diesel trucks are not permitted to idle for more than 5 minutes in any continuous 60-minute period Signage: The law requires at least one permanent sign at locations where the facility has:

a) Vehicles subject to this law load or unload; or b) 15 or more parking spaces for vehicles subject to this law.



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WV Requirement – WV Code Chapter 17C Article 13A Requirements: No driver or owner of a diesel-powered motor vehicle with a gross vehicle weight of ten thousand one pounds or more engaged in commerce may cause, and no owner or operator of the location where the vehicle loads, unloads or parks, may allow the engine of the vehicle to idle for more than fifteen minutes in any continuous sixty-minute period, except as provided under section three of WV Code Chapter 17C Article 13A. Signage: The owner or operator of a location where vehicles load or unload or a location that provides fifteen or more parking spaces subject to this article shall erect and maintain a permanent sign informing drivers that idling is restricted.

Leak Detection and Repair (LDAR)

Leaking equipment at a well site or compressor station can be a significant source of

emissions of volatile organic compounds (VOCs) and methane emissions. VOCs contribute to the formation of ground-level ozone and methane is a potent greenhouse gas. LDAR is required by 40 CFR Part 60 Subpart OOOO (OOOO or Quad Oh) the New Source Performance Standard (NSPS) for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced after 8/23/2011 and on or before 9/18/2015. LDAR is also required under the subsequent 40 CFR Part 60 Subpart OOOOa (OOOOa or Quad Oh Ay) Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction commenced after 9/18/2015. Many state and local air agencies incorporate federal standards for LDAR and some are more stringent than EPA’s LDAR requirements.

In general, OOOO/OOOOa requires operators to develop and implement a leak detection

monitoring plan with minimum elements including a sitemap with defined walking path, list of key personnel and their defined role, plan for any difficult-to-monitor components, survey procedures, survey equipment specifications, leak identification procedures and repair/resurvey procedures and list of monitoring records to be maintained. A summary of LDAR requirements for well sites and other operations sites are listed in the table below. If in doubt, please contact someone in the Environmental Department for assistance in determining the compliance requirements. State and Federal LDAR Requirements

There are many exclusions, exemptions, and exceptions to these idling restrictions. The Environmental Department can provide more information

on the exemptions. NOTE



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Well Sites OH PA WV USEPA Initial Within 90 days

of startup of production

Within 60 days of startup of production



Ongoing Quarterly* Ex 38b – annual Ex 38c – semi-annual

Quarterly Semi-annual (at least 4 months apart)

Repair Requirements

First attempt – 5 days Final repair – 15 days

Within 15 days First attempt – 5 days Final repair – 15 days

No later than 30 days, must tag each leak with lat/long and photo leak if not repaired immediately

*After 4 consecutive quarters < 2.0% leakers are discovered during most recent survey, frequency can be reduced to semi-annually. If after 2 consecutive semi-annual inspections <2.0% leakers are discovered during the most recent survey, frequency can be reduced to annually. If >2.0% leakers are discovered during a semi-annual or annual survey, frequency must return to quarterly.

Other PA – GP5/5A ± WV – G70/G35 USEPA – Compressor Stations

Initial Within 30 days of startup of production

Same as USEPA Within 60 days of startup of production

Ongoing Quarterly** Same as USEPA Quarterly (at least 60 days apart)

Repair Requirements

First attempt – 5 days Final repair – 15 days

Same as USEPA No later than 30 days, must tag each leak with lat/long and photo leak if not repaired immediately

± Auditory, Visual, Olfactory (AVO) inspections are required within 30 days of source operation and must be repeated monthly.

** May decrease the LDAR inspection interval from quarterly to semi-annually if the

percentage of leaking components is less than 2.0% for two consecutive quarterly LDAR inspections. If the percentage of leaking components is higher than 2.0% in any inspection, a quarterly LDAR inspection interval must be resumed or maintained.

6 Additional Considerations



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Dehydration Units – Hazardous air pollutants may be emitted in significant quantities depending on the dehydration unit size and operating parameters, the gas composition, and whether a control device (BTEX condenser/VDU) is used.

Desiccant Air Dryers – Some packing materials contain hazardous components that must be used in accordance with proper hygiene and safety practices addressed in the applicable SDS and the HAZCOM program.

Methanol/Alcohol Tanks – Air permits may be required for these sources depending on their respective emission rates. VOC storage tanks may be subject to various New Source Performance Standards (40 C.F.R Part 60). However, certain storage vessels are exempt from NSPS requirements based upon capacity, use and vapor pressure of the tanks. The applicable NSPS subpart should be consulted to determine whether such an exemption applies.

Parts Cleaners – Cleaning solvents typically contain VOCs, which are regulated under other federal and state requirements. However, some cleaning solvents may contain listed hazardous air pollutants. For cleaning solvents containing listed hazardous air pollutants, ensure these emissions are accounted for in reporting and applicability assessments. Pigging Operations – Air permits may be required for on-site or nearby sources depending on the emission rates from these operations. Gas Driven Pneumatic Controllers (valve actuators, level controllers, etc.) – Use of no-bleed or low-bleed pneumatic controllers are preferred. Continuous high bleed (>6 scf/hr) pneumatic controllers will be subject to additional onerous requirements under subpart OOOO/OOOOa. Condensate Storage Tanks – VOC and hazardous air pollutants may be emitted in significant quantities from uncontrolled condensate storage tanks and may trigger additional requirements under subpart OOOO/OOOOa and major source designations. Controls (BTEX condenser, flare/combustor) should be considered when designing facilities where condensate storage is needed. Engines - Diesel and natural gas-fired engines that are used for compression and/or power generation are subject to various New Source Performance Standards (NSPS) and installation or modification of these sources can trigger air permitting requirements. The NSPS requirements can also apply to regulated engines even when an air permit is not required. The applicable NSPS regulations (40 CFR 60 subpart JJJJ, 40 CFR subpart ZZZZ, subpart IIII) depends on the engine type, size and date of manufacture. NSPS can contain emission control requirements (i.e. catalyst), emission limitations, stack testing requirements, and maintenance and recordkeeping requirements. Any engine installations, replacements or modifications should be reviewed by the environmental department to determine applicable requirements and air permitting needs.



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Asbestos

The asbestos NESHAP (National Emission Standard for Hazardous Air Pollutants) specifies EPA notification, emission control and waste disposal requirements for buildings/structures being demolished or renovated that contain asbestos. In July of 2004, the EPA revised Table 1 of the NESHAP for asbestos to include a cross reference to the OSHA Permissible Exposure Level (PEL).

The following activities are subject to the asbestos NESHAP:

• Demolition and renovation activities where 160 square feet or more of regulated

asbestos containing material, 260 linear feet or more of regulated asbestos containing materials of 35 cubic feet of asbestos containing material will be disturbed. This includes non-friable asbestos that will be subject to cutting, sanding, etc. or that has a high probability of becoming crushed or pulverized.

• Regardless of the amount of asbestos containing material to be disturbed, notification to EPA is required 10 days in advance of all demolition activities.

The company will contract the services of a licensed asbestos abatement company for any removal or other work involving asbestos. Additionally, State and Local governments may require demolition permits and asbestos removal permits. Waste disposal permits may be required for landfill authorization. Asbestos containing material should never be burned. Consult the Environmental Department if you will be disturbing any buildings or pipe where you suspect asbestos may be present for additional guidance.

Failure to comply with the elements of an air permit can lead to serious penalties and/or corrective actions, not to mention unwanted citizen complaints

that can lead to media attention. Non-compliance can damage a company’s reputation, not only with permitting agencies, but also with the communities in which we operate. A history of non-compliance may draw opposition during

public meetings if we lose the public trust and may lead to permit denials.

NOTE



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Steps

Environmental

Department

Operations Mgr/Supv,

Facility Mgr, Project Mgr

Employee

1.

Assess whether an air permit is necessary for your facility.

L

P

P

2.

If the facility has a permit, ensure compliance with all permit requirements.

A L

P

3 Notify the Environmental Department of any proposed changes to equipment and/or operations that may impact emissions at the facility

A L P

4.

Look out for and report malfunctioning or damaged equipment including leaking gas (visual, auditory, odor) and anything out of the ordinary

A L P

5.

Ensure that asbestos standards are followed by asbestos contractors for any renovation or construction activities involving asbestos.

L P P

A = Audit L = Lead P = Participate

8 DEFINITIONS

Aggregation is commonly referred to the process of determining whether emissions from production activities should be aggregated, or combined, to determine if multiple stationary sources constitute a ‘major source’ for purposes of Prevention of Significant Deterioration (PSD), New Source Review (NSR) or Title V. The accepted method for determining aggregation is a 3-prong analysis: (1) Does each facility belong to the same industrial grouping (SIC code)? (2) Are they both located on one or more contiguous or adjacent properties? (3) Are they under the control of the same person? Hundreds of pages of legal text are written on interpreting source aggregation. Consult the Environmental Department for assistance if Aggregation is a concern. Catalyst – device that causes a chemical reaction to break down chemicals into less harmful by-products. Commenced, with respect to the definition of new source, means that an owner or operator has undertaken a continuous program of construction or modification or that an owner or operator has entered into a contractual obligation to undertake and complete, within a reasonable time, a continuous program of construction or modification.



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Emission unit includes, but are not limited to, combustion units, compressor engines, diesel or natural gas-fired engines, vapor recovery units, heaters, dehydration units (glycol, dry bed, molecular sieve, etc.), turbines, flares/incinerators, generators, storage tanks and fugitive sources including open burning that emit regulated pollutants. Facility is what we call a group of emission units regulated as one entity Major Source is a classification given to a source of air pollutants that produces enough air pollutants to require an air permit. The threshold to be considered a major source depends on the type of pollutants involved, the status of the area where the source is located, and the type of permit involved. Modification means any physical change in, or change in the method of operation of, an existing facility which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by that facility or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted. New Source Review is designed to protect air quality when a facility is newly built or modified. Referred to as NSR Permitting, it assures that new or modified facilities are as clean as possible and advances in pollution control are installed concurrently with expansions and modifications. Pollutants can be gases, vapors or tiny particles that can damage the health or people, animals and plants. PSD or Prevention of Significant Deterioration – is a classification of permit designed to prevent an emissions unit from changing an area’s attainment status. Stationary source means any building, structure, facility, or installation which emits or may emit any air pollutant. Title V of the CAA requires ‘major sources’ of air pollutants, and certain other sources, to obtain and operate in compliance with a Title V Operating Permit. Generally, the first step in determining if a facility is a Major Source is to determine the Potential-to-Emit (PTE) from all equipment. The PTE demonstrates the maximum air pollutants, including Hazardous Air Pollutants (HAPs) a facility may emit. If the PTE for any air pollutant is over major source thresholds for any air pollutant, the facility would be considered a Major Source and generally be required to obtain a Title V Operating Permit. Lower thresholds apply in non-attainment areas, but only for the pollutant that is non-attainment. Consult the Environmental Department for additional information on current attainment and non-attainment designations and thresholds.


Title Waste Handling and Disposal

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1 PURPOSE AND SCOPE

1.1 To regulate waste handling and disposal procedures for all waste streams generated on EQT locations.

1.2 This procedure applies to all EQT locations and all personnel involved in any waste generating

or disposal operations.

2 WASTE HANDLING REQUIREMENTS

2.1 The operational requirements outlined below are expected to be followed without exception.

2.2 The EQT Waste Management Department must be contacted immediately if there are any on-site issues or clarifications relating to waste generation or disposal.

2.3 Any necessary changes or improvements to the processes outlined below must be communicated

to the EQT Waste Management Department.

3 PLANNED AND UNPLANNED WASTE HANDLING REQUIREMENTS

3.1 Planned waste is any waste stream that was preemptively determined to be generated in a controlled manner with storage and a disposal plan already in place. The disposal plan will include final waste destination as well as all approvals and manifesting.

3.2 Examples of Planned Waste include:

• Drill cuttings • Plant trash • Liner/containment • Produced sands • Tank, GPU, and AST cleaning sludges • Cellar Cleanouts

3.3 Unplanned waste is any waste stream that was NOT preemptively determined to be generated in

a controlled manner with storage and a disposal plan already in place. Unplanned waste should be stored on location in an approved container, until transportation and disposal can be scheduled by the EQT Waste Management Department. All individual waste streams shall be labelled as accurately as possible with: contents, pad (location), operation, contact information, and date generated.

3.4 Examples of Unplanned Waste include:



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• Spills • Tires • Batteries • PCB’s • Hydrocarbon cleanup material • Filter socks • Universal waste

3.5 Universal Waste is a category of waste materials designated as "hazardous waste", but containing

materials that are very common. While Universal Wastes are not subject to the vast majority of Resource Conservation and Recovery Act (RCRA) requirements, they still must be managed in such a way as to prevent toxic releases to the environment. Proper labeling and transport to a facility that is designated for receiving hazardous waste will be organized by the Waste Management Department once notified. Universal Waste can only be stored for one year, the containers must be closed when stored, and the containers must be properly labeled.

3.6 Examples of Universal Waste include:

• Batteries • Light bulbs • Pesticides • Mercury containing equipment

4 TENORM WASTE HANDLING

TENORM is Technologically Enhanced Naturally Occurring Radioactive Materials that are produced by activities such as natural gas exploration or water treatment. 4.1 TENORM shipped from EQT facilities and sites shall be packaged, surveyed, and labeled in

accordance with local requirements and United States Department of Transportation (DOT), 49 CFR 173.

4.2 Pennsylvania Department of Environmental Protection (DEP) may exempt a carrier from DOT

regulations under certain conditions. 4.3 A DOT Special Permit (DOT-SP 11406) may be required for transportation when:

• During or at the conclusion of transportation, or during inspection of the shipment following

its receipt; the waste has been found to contain unexpected and unidentified radioactive material or contamination.



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• The waste is transported to a location determined by the authorizing state official to be more appropriate for characterization and/or disposition of the discovered radioactivity.

4.4 Waste stored on site shall comply with local, state and federal regulations.

4.5 Manifests, Certificates of Disposal or other documentation to confirm transfer/disposal shall be

generated and maintained by the EQT Environmental Department. 4.6 Transfer to an authorized recipient only as provided by applicable state or federal requirements. 4.7 Classification of all TENORM waste haul for disposal prior to ANY box leaving location:

• If any 8-point scan is >65 uR/hr; Hazardous (placard for Class 7; LSA-I is required) • If all 8-point scans are <65 uR/hr; Non-Hazardous

5 RESPONSIBILITIES EQT Operations

• Ensure that these procedures and regulations are understood and followed by all personnel involved in the waste generating or disposal process.

Business Partners

• Perform all work in compliance with these guidelines set forth by EQT.


Title Solids Control and Disposal - Drilling

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1 PURPOSE AND SCOPE

1.1 This procedure applies to all EQT locations where personnel are involved in solids control and disposal operations related to drilling operations. This procedure standardizes solids control and disposal for all waste streams throughout the drilling process.

2 COMMUNICATION REQUIREMENTS

2.1 Contact the EQT Waste Management Team immediately if any clarifications are needed.

2.2 The Waste Management Team must be contacted immediately if there are any on-site issues

relating to solids control or disposal. The team will then contact the appropriate parties in order to resolve the issues.

3 STANDARD TRIAXLE OPERATING PROCEDURE

3.1 EQT standard protocol is to utilize 100% triaxle trucks for all cuttings hauling. The Waste

Management Team must be notified immediately if roll-offs are requested on location (see section 2.3.1 for proper procedure).

3.1 It is expected that the on-site EQT representative, backyard company, and hauler communicate effectively in order to maximize the number of triaxle loads that can be disposed of during normal landfill operating hours. • Landfill Opening – Work to clear half rounds at the opening of the landfill each day (except

Sunday). • Landfill Closing – Ensure empty half rounds at the close of the landfill each day (except

Sunday). • Saturday Operations – Ensure half rounds are completely emptied prior to the landfill

closing for the weekend. • Sunday Operations – Plan to store all cuttings throughout day and prepare for landfill

opening first thing Monday morning. • Ensure staggered truck dispatching in an effort to minimize demurrage time.

4 LATE LOADS / PRE-LOADS / ROLL-OFF PROCEDURES

4.1 All requests for roll off boxes, late loading, or pre-loading need to be approved by an on-site EQT representative, and the Waste Management Team MUST be notified. If the on-site EQT representative is unavailable, the team lead will give primary approval for these decisions.

5 CEMENTING PROCEDURES

5.1 In preparation of a cement job, ensure there is an EMPTY half round available to store cement returns.



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• Allow returns to set up and send free water that has separated from the solids to an impaired tank.

• Move remaining solids into mixing half round to be solidified with dry cuttings that will be generated in the next hole section or the next well.

• If the last hole section of the last well on pad was just completed, solidification material can be used as needed to dry these solids.

6 PROCESSING FREE WATER

6.1 All free water (cellar water, containment water, etc.) must be sent to an EMPTY half round to allow for solids and water to separate. • Any water with an oil sheen must be processed in accordance with section 2.10 below. • Once water is processed and clean, send to an impaired tank for EQT’s impaired water group

to collect (on-site EQT representative will handle water group callouts). 7 SOLIDIFICATION MATERIAL USAGE

Water-based Mud (WBM) or Air Drilling • Lime is the primary mix-off agent for these drilling systems. • Lime has an exothermic reaction with these cuttings, and this process takes 20-30 minutes. • Minimize lime usage by allowing adequate time for the lime to react and properly dry

cuttings. • Maximize usage of dry cuttings as mix-off agent before using any lime. • Business partners or EQT employees working directly with lime must wear eye protection, a

disposable mask, and gloves to prevent irritation. Synthetic-based Mud (SYN) or Diesel-based Mud (DBM) Drilling

• Natural Organic hulls + Corncob are the two-primary mix-off agents for these drilling systems.

• These are absorbent materials that do not require a specific amount of time to effectively dry cuttings, however proper mixing is required.

• Minimize material usage by ensuring proper mixing of each sack with cuttings. • Maximize usage of dry cuttings as mix-off agent before using the hulls/or corncob. • All personnel working directly with these materials must wear eye protection to prevent

irritation. 8 TARPING HALF ROUNDS

8.1 Half rounds MUST be tarped when not actively in use to reduce unnecessary waste mixing with cuttings (e.g. rainwater, trash, debris, etc.)

9 PROPER LOADING OF TRUCKS



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9.1 It is important to optimize truckloads leaving location and every truck must be filled with >18 tons of cuttings. • When a truck is knowingly light-loaded, the Waste Management Team or On-site

representative must be notified immediately with an appropriate justification. 10 CLEAN BACKYARD

10.1 The backyard should remain clean, organized, and free of hazards at all times. 10.2 ANY hazard or potential environmental issue must be reported to the on-site EQT representative

immediately. 11 OIL-WATER SEPARATOR USAGE (if available)

11.1 All free water (cellar water, containment water, etc.) with an oily sheen MUST be sent from the

half round to the oil-water separator. 11.2 Processed water (once free of oil) is to be sent to an impaired tank.

• On-site EQT representative will coordinate all water hauling with EQT’s impaired water group.

11.3 Recovered oil will be drained from the oil-water separator is to be sent to a mixing half round with drill cuttings.

12 HAULER AND LANDFILL END OF WELL REPORTING

12.1 The hauler and landfill are expected to deliver end of well reports to the Waste Management

Team or Salesforce immediately following a well. These reports include, but are not limited to the following information: • All costs associated with the transportation and disposal of drill cuttings • Total tons disposed • Number of preloads, wet loads, roll-off loads, triaxle loads, etc. • Manifesting/BOL paperwork

12.2 Please contact the Waste Management Team immediately if any clarifications are needed.


13.1 EQT Operations

• Ensure that these procedures & regulations are understood and followed by all parties involved in the solids control and disposal process.


• Perform all work in compliance with these guidelines set forth by EQT.



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14 STANDARD BACKYARD LAYOUT AND FLOW STREAMS

The following diagrams outline the standard backyard layout and flow streams. If this standard package needs to be slightly modified due to space restrictions, needing to maximize cuttings, storage, or for any other reason, this decision will be made and effectively communicated to all parties.

14.1 Backyard Layout (Overhead View) – Generic



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14.2 Flow Streams

14.2.1 Bottom hole Closed Loop System



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14.2.2 Other Solids/Waste



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14.2.3 Drill Site Waste Water



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14.2.4 Cementing Operations



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15 RESIDUAL WASTE CODES (Applicable to Drilling Operations)

Code Description 710 Plant Trash. 803 Drilling Fluid Waste – oil and gas drilling mud, other drilling fluids other than fracturing fluid and

spent lubricant. 806 Synthetic Liner Materials – includes well site liners, liners used in pits or other approved storage

structures, freshwater impoundments, centralized impoundments, or used in conjunction with primary containers.

810 Drill Cuttings – oil and gas drill cuttings. 811 Soil Contaminated by Oil and Gas-related Spills – soil contaminated by spills of RWCs 803, 810.

Soils contaminated by spills of RWC 812 will be coded using RWC 812. 812 Filter Socks – Filters, filter socks, and other media used to filter any oil and gas-related

wastewater


Title WV AST Registration & Closure Procedure

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1 PURPOSE AND SCOPE

1.1 EQT is committed to being a good steward of all our natural resources including protecting the water quality surrounding our operations. Ensuring that water quality regulations are met or exceeded is just one of the ways that EQT demonstrates commitment to employees, landowners and the community in which we operate. The purpose of this West Virginia (WV) Aboveground Storage Tank (AST) Registration & Closure Procedure is to define the process to maintain WV AST compliance at EQT in support of the Mission and Vision to be the operator of choice for all stakeholders. At EQT, all WV ASTs shall be operated in compliance with applicable AST regulations. This program applies to all WV EQT locations.

2 BACKGROUND

2.1 WV’s AST Act (WV Code Chapter 22 Article 30) was originally established in 2014 in response to the Freedom Industries Spill. In that incident, 7,500 gallons of chemical foam and glycol ethers used to wash coal leaked from a tank into the Elk River upstream from a water intake treatment center that supplies water to several counties. Following the spill, up to 300,000 residents within nine counties in the Charleston, WV metropolitan area were without access to potable water for 5 days.

2.2 In 2016, the state legislature passed a rule (47CSR63) that established a regulatory program for

ASTs within the state of WV. The program requires that tanks with a storage capacity of 1,320 gallons or greater must be registered in WV’s Electronic Submission System, or ESS, and be labeled. Mobile tanks onsite for less than 365 days are not required to be registered. Under House Bill (HB) 2811, the rule was revised in 2017 to exempt devices from regulated AST requirements that have a capacity of 210 barrels or less, contain brine water or other fluids produced in connection with hydrocarbon production activities, and that are not located in a zone of critical concern. However, they must still be registered and labeled.

3 APPLICABILITY

3.1 This procedure applies to all EQT WV locations. The following are excluded from the requirements of the WV AST Act and its rules because it has been determined by WV that they do not represent a substantial threat of contamination or because they are equipment whose storage of substances is incidental to their predominant usage as equipment:

• Surface impoundments, pits, ponds, or lagoons; • Process vessels; • Devices containing drinking water for human or animal consumption, surface water or

groundwater, demineralized water, noncontact cooling water or water stored for fire or emergency purposes;

• Empty tanks held in inventory or offered for sale; • Pipeline facilities, including gathering lines, regulated under the Natural Gas Pipeline Safety

Act or the Hazardous Liquid Pipeline Safety Act, or an interstate pipeline facility regulated



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by the WV Public Service Commission or otherwise regulated under any state law comparable to the previously mentioned Acts;

• Liquid traps, atmospheric and pressure vessels, or associated gathering lines related to oil and gas production and gathering operations;

• Electrical equipment such as transformers, circuit breakers, and voltage regulator transformers; and

• Devices having a capacity of two hundred ten barrels or less, containing brine water or other fluids produced in connection with hydrocarbon production activities, that are not in a zone of critical concern. (These are still subject to registration and labelling requirements.)

4 REGISTRATION

4.1 Except as specifically excluded in the AST Rule, tank owners shall register each aboveground storage tank in the WV ESS within thirty (30) days after installation or acquisition of an ownership interest in the storage tank. All ASTs shall be registered prior to being placed into active service. It is unlawful for any owner or operator to operate, use or store substances in an AST that has not been properly registered or for which any applicable registration fee has not been paid.

4.2 Tank owners shall submit an amended registration form in the WV ESS within thirty (30) days of a change in the previously submitted information, except to amend registration for change in the substance stored in the tank or relocation of a tank to a Zone of Critical Concern, in which case the amended registration must be submitted within three (3) days. Amended registrations shall be made for the following:

• Removal or relocation of a storage tank to a new facility; • Change in operating status of the AST; • Change in use of a storage tank to or from the statutory definition of an AST; • Change in substance or substances stored in the tank; • Change of ownership or change of operator; and • Change of contact, mailing address or telephone number.

4.3 During the initial planning stages of an aboveground storage tank installation, modification,

replacement, relocation or closure, the operations employee(s) responsible for the change shall notify the Environmental Department of such change. This will ensure timely submittal of applicable registrations or amendment/ closure notifications, as required.

4.4 Operations shall provide relevant data related to the AST system such as: • Tank – volume, location, substance stored, manufacturer, construction material/ corrosion

protection, fabrication/ installation date;

If you are unsure if an aboveground storage tank needs to be registered, please contact your Environmental Coordinator or the Environmental Department. NOTE



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• Piping – construction material/ corrosion protection, installation date; • Secondary containment – volume, type, material, installation date; and • Other information as requested by the Environmental Department.

Installation, modification, replacement, relocation or closure of an aboveground storage tank

shall not occur without approval from the Environmental Department.

5 CLOSURE

5.1 To place a RL or RL/MN AST system in permanent closure, the owner or operator must empty and clean the AST, piping, and associated equipment by removing all liquids and accumulated residues. All RL and RL/MN tanks permanently taken out of service must be either dismantled and removed from the site or, if left onsite, rendered unusable for the storage of any substance and marked in a readily visible location with the name of the last substance stored in the AST, the date of the closure, and the words “Permanently Closed” or “Permanently Out of Service”.

5.2 To place a regulated (Level 1 or Level 2) AST system in permanent closure, the process is as

follows: • At least thirty (30) days before beginning a permanent closure, the owner or operator shall

notify WV Department of Environmental Protection (DEP) in writing of its intent to permanently close the regulated AST system, unless the action is in response to a corrective action ordered by WV DEP. A waiver of the thirty (30) day notice may be granted by WV DEP upon request of the owner or operator and for good cause shown.

• To place a regulated AST system in permanent closure, the owner or operator must empty and clean the AST, piping, and associated equipment by removing all liquids and accumulated residues. All regulated tanks permanently taken out of service must be either dismantled and removed from the site or rendered unusable for the storage of any substance.

• Closure activities must be performed in accordance with industry standards (such as API, NFPA, and STI) and closure guidance documents developed by WV DEP.

• Closure activities must be performed by a professional engineer, a person certified by API or STI or a person holding certification under another program approved by WV DEP.

• The owner or operator shall submit a closure plan for review and approval by WV DEP at least thirty (30) days prior to closure. The owner or operator must measure for the presence of a release where contamination is most likely to be present at the AST site and consider the method of closure, the nature of the stored substance, the analytical methods to be performed, the type of backfill, the depth to ground water, and other factors appropriate for identifying the presence of a release.

• The tank owner or operator shall submit a closure report to WV DEP no later than sixty (60) days after the closure has been completed. The closure report shall describe the regulated AST system closure procedures, including findings of any closure sampling required as part of the closure. The owner or operator shall retain a copy of the closure report for a minimum of three (3) years.



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• If contaminated soil, sediment, surface water or groundwater or free product is discovered outside of the secondary containment or confirmed by either direct observation or indicated by the analytical results of the closure sampling, the owner or operator shall report the release immediately and comply with section 7 of the AST rule.

• Tanks that undergo permanent closure and left onsite shall be rendered unusable for the storage of any substance and shall be secured against unauthorized entry. The regulated AST is to be legibly marked by placing a stencil in a readily visible location that states the name of the last substance stored in the AST, the date of closure, and the words “Permanently Closed” or “Permanently Out of Service”.

5.3 During the initial planning stages of an aboveground storage tank closure, the operations

employee(s) responsible for the change shall notify the Environmental Department of such change. This will ensure timely submittal of applicable closure notifications, as required.

The Environmental Department shall oversee all closure activities of all regulated ASTs.

Closure of an aboveground storage tank shall not occur without approval from the Environmental

Department.

Failure to comply with the requirements of the WV AST Rule can lead to serious penalties and/or corrective actions. Non-compliance can damage a company’s reputation, not only with regulatory agencies, but also with the communities in which we operate. A history of

non-compliance may lead to increased scrutiny from regulatory agencies.

References: Overview of Aboveground Storage Tank Act

WV Aboveground Storage Tank Act (WV Code Chapter 22 Article 30)(2014) WV AST Rule (47CSR63) (2016)

House Bill (HB) 2811 (2017)

NOTE

NOTE



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Steps

Environmental

Department

Operations Mgr/Supv,

Facility Mgr, Project Mgr

Employee

1.

Determine whether an aboveground storage tank needs registered.

L

P

P

2.

Notify the Environmental Department of any proposed changes to existing aboveground storage tanks or proposed installation of new aboveground storage tanks

P L P

3.

Oversee closure of regulated ASTs L P P

L = Lead P = Participate

7 DEFINITIONS

Aboveground storage tank (AST) – a device made to contain an accumulation of more than one thousand three hundred twenty (1,320) gallons of fluids that are liquid at standard temperature and pressure, which is constructed primarily of nonearthen materials, including concrete, steel, plastic, or fiberglass reinforced plastic, which provide structural support, more than ninety (90) percent of the capacity of which is above the surface of the ground, and includes all ancillary pipes and dispensing systems up to the first point of isolation. The term includes stationary devices which are permanently affixed, and mobile devices which remain in one location on a continuous basis for three hundred sixty-five (365) or more days. Aboveground storage tank system – an aboveground storage tank, its piping, and all its ancillary equipment, including spill containment devices, overfill protection devices, secondary containment systems, and any associated release detection equipment, up to the first point of isolation. Owner – a person who holds title to, controls or owns an inherent interest in an AST, including owners of tanks immediately preceding the discontinuation of a tank’s use. An “owner” does not mean a person who holds an interest in a tank for financial security unless the holder has taken possession of and operated the tank. Operator – any person in control of, or having responsibility for, the daily operation of an AST. Process vessel – a tank that forms an integral part of a production process through which there is a steady, variable, recurring or intermittent flow of materials during the operation of the process or in which a biological, chemical or physical change in the material occurs. This does not include tanks used for storage of materials prior to their introduction into the production process or for the storage of finished products or by-products of the production process.



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Registered and Labeled (RL) tank – An AST that is subject to only the registration and labelling requirements of the AST Act and its rules. Registered and Labeled (RL/MN) tank – An AST having a capacity of two hundred ten barrels or less, containing brine water or other fluids produced in connection with hydrocarbon production activities, that are not in a zone of critical concern. HB 2811 made these ASTs exempt from the provisions of the AST Act and its rules except for the registration and labelling requirements. Regulated AST or regulated tank – an AST that meets the definition of a level 1 or level 2 regulated tank. Regulated level 1 AST or level 1 regulated tank (A) An AST located within a ZCC, source water protection area, public surface water influenced groundwater supply source area, or any AST system designated by the secretary as a level 1 regulated tank; or (B) An AST that contains substances defined in section 101(14) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as a “hazardous substance” (42 U. S. C. § 9601(14)); or is on EPA’s “Consolidated List of Chemicals Subject to the Emergency Planning and Community Right to Know Act (EPCRA), CERCLA, and §112(r) of the Clean Air Act (CAA)” (known as “the List of Lists”) as provided by 40 C. F. R. §§ 355, 372, 302, and 68) in a concentration of one percent or greater regardless of the AST’s location, except ASTs containing petroleum are not “level 1 regulated tanks” based solely upon containing constituents recorded on the CERCLA lists; or, (C) An AST with a capacity of 50,000 gallons or more, regardless of its contents or location. Regulated level 2 AST or level 2 regulated tank – An AST that is located within a ZPC that is not a level 1 regulated tank. Secondary containment – a safeguard applied to one or more tanks that prevents the discharge into the waters of the state of the entire capacity of the largest single tank and sufficient freeboard to contain precipitation. In order to qualify as secondary containment, the barrier and containment field must be sufficiently impervious to contain fluids in the event of a release, and may include double-walled tanks, dikes, containment curbs, pits or drainage trench enclosures that safely confine the release from a tank in a facility catchment basin or holding pond. Earthen dikes and similar containment structures must be designed and constructed to contain, for a minimum of seventy-two (72) hours, fluid that escapes from a tank. Source water protection area – For a public groundwater supply source, it is the area within an aquifer that supplies water to a public water supply well within a five-year time-of-travel and is determined by the mathematical calculation of the locations from which a drop of water placed at the edge of the protection area would theoretically take five years to reach the well.



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Zone of Critical Concern (ZCC) – ZCC for a public surface water supply source and for a public surface water influenced groundwater supply source is a corridor along streams within a watershed that warrants detailed scrutiny due to its proximity to the surface water intake and the intake’s susceptibility to potential contaminants within that corridor. The ZCC is determined using a mathematical model that accounts for stream flows, gradient and area topography. The length of the ZCC is based on a five-hour time-of-travel of water in the streams to the water intake. The width of the ZCC is one thousand (1,000) feet measured horizontally from each bank of the principal stream and five hundred (500) feet measured horizontally from each bank of the tributaries draining into the principal stream. Zone of Peripheral Concern (ZPC) – ZPC for a public surface water supply source and for a public surface water influenced groundwater supply source is a corridor along streams within a watershed that warrants scrutiny due to its proximity to the surface water intake and the intake’s susceptibility to potential contaminants within that corridor. The ZPC is determined using a mathematical model that accounts for stream flows, gradient and area topography. The length of the ZPC is based on an additional five-hour time-of-travel of water in the streams beyond the perimeter of the ZCC, which creates a protection zone of ten (10) hours above the water intake. The width of the ZPC is one thousand (1,000) feet measured horizontally from each bank of the principal stream and five hundred (500) feet measured horizontally from each bank of the tributaries draining into the principal stream.