J-13 Flow Down Of Fluor-BWXT Worker Health And Safety Program

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 6 of 41 FBP establishes the written policies, goals, and objectives for implementation of the Contractor WSHP through this document. In addition, the requirements of the following laws, regulations and standards are mandatory. NFPA 70E Standard for Electrical Safety in the Workplace and standards incorporated by reference 2015, NFPA 70 National Electric Code and standards incorporated by reference (2017) 10 CFR 850 Chronic Beryllium Disease Prevention Program 1904 Recording and Reporting Occupational Injuries and Illnesses 10 CFR 835 Occupational Radiation Protection 10 CFR 851 Worker Safety and Health Program 29 CFR 1910 Occupational Safety and Health Standards for General Industry and standards incorporated by reference 29 CFR 1926 Safety and Health Regulations for Construction and standards incorporated by reference American Conference of Governmental Industrial Hygienists, “Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices 2016” when the ACGIH Threshold Limit Values (TLVs) are lower (more protective) than permissible exposure limits in 29 CFR 1910. When the ACGIH TLVs are used as exposure limits, contractors must nonetheless comply with the other provisions of any applicable expanded health standard found in 29 CFR 1910. ANSI Z308.1 2009, Minimum Requirements for Workplace First Aid Kits and Supplies ANSI Z87.1 American National Standard for Occupational and Educational Eye and Face Protection Devices ANSI Z88.2 American National Standard for Respiratory Protection 2015 ANSI Z89.1 American National Standard Requirements for Protective Headwear for Industrial Workers ANSI Z136.1 Safe Use of Lasers 2014 ANSI Z49.1 Safety in Welding, Cutting and Allied Processes 2012 ASTM F 2412 Standard Test Methods for Foot Protection

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 8 of 43 J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 7 of 41 4.0 ASTM F 2413 Standard Specifications for Performance Requirements for Foot Protection RESPONSIBILITIES 4.1 Contractor Project Management Team Contractor Project Manager 4.1.1 The Contractor Project Manager (CPM) ensures that all personnel under his/her supervision, directly or indirectly, clearly understand their role, responsibilities, authorities, and accountabilities within assigned projects and activities. The CPM will maintain current knowledge of all safety policies and procedures, take responsibility for their own safety and the safety of managed personnel ensuring compliance with all applicable safety policies & procedures, and practice safe work habits. The CPM will provide identification of work activity types and the portions of the safety program applicable to the contracted work scope. The CPM will hold managerial responsibility for implementation of the agreed portion of the applicable WSHP as specified herein. Contractor Supervisor 4.1.2 The contractor supervisor ensures that all work on the project is performed safely and that activities are planned and performed in compliance with the PORTS Integrated Safety Management System principles and core functions. Remains knowledgeable of safety policies and procedures as well as performing assigned duties in a safe manner and, while supervising others, has the responsibility for their safety and ensures that they comply with established safety policies and procedures and practice safe work habits. The contractor supervisor maintains a current knowledge of all safety policies and procedures, take responsibility for their own safety and the safety of supervised personnel ensuring compliance with all applicable safety policies & procedures, and practice safe work habits. The contractor supervisor will serve as the field oversight point of contact for the contractor work force. Contractor OS&H 4.1.3 Contractor shall provide one or more full-time onsite (PORTS Reservation) qualified OS&H Representatives when field work is in progress. The OS&H Representative(s) must possess and demonstrate their Industrial/Occupational Safety knowledge, skills and ability in all arenas of the Ports. Complex as required. The OS&H Representative(s) must be approved by the Company and

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 8 of 41 poses, at a minimum, 30hr OSHA training in Construction and 2yrs. of verifiable field OSH oversight. Equivalent training/experience shall be determined by FBP OS&H. 4.1.4 When Contractor’s on site employee total is less than thirty individuals, the OS&H Representative may have other management responsibilities. 4.1.5 Additional qualified OS&H personnel may be required due to geographic location, specific hazards, Company requirements, or local regulatory requirements. This shall be determine based on the Contractors work plan and /or changes in work scope. 4.1.6 Contractor's OS&H Representative shall be responsible to oversee line management’s implementation of the Contractor’s Safety and Health Program. Contractor Industrial Hygiene 4.1.7 4.2 The Contractors Industrial Hygiene representative must possess the following qualifications: This person can be the Contractor’s OS&H Representative, if all of the following qualifications are met: A. Three (3) years (35% of time) verifiable experience in the field of industrial hygiene comprehensive practice, or one (1) year field experience. B. The IH representative can be an independent third party Industrial Hygiene consultant. 4.1.8 The qualifications of the person(s) developing, approving and performing any industrial hygiene monitoring/sampling shall be submitted to the Company for approval prior to the person(s) performing any industrial hygiene monitoring/sampling 4.1.9 This qualified person may train other personnel to perform monitoring as long as they ensure monitoring/sampling is done accurately when the task is performed. Training must be documented and approved by the Company. 4.1.10 Experience in the field of industrial hygiene shall include more than 1 year of dedicated asbestos work, if applicable to the work scope. 4.1.11 A Certified Industrial Hygienist (CIH) certification by the American Board of Industrial Hygiene (ABIH) is preferred, but not required. Training and Records [10 CFR 851.20 and 10 CFR 851.25] 4.2.1 Training A. Required training, site specific and specialty training, is identified in Appendix 1. In accordance with the contract submittal register, the Contractor shall submit Personnel Training Matrix (Appendix#14) prior to

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 9 of 41 mobilization and maintain it as current and up to date. By providing this submittal, the Contractor certifies that the contractor required training has been completed in compliance with the WHSP and applicable state and federal requirements. Contractor agrees that as personnel are added during the performance of the contract, the Personnel Training Matrix B. (Appendix#14) will be updated and resubmitted. Any required training records/matrix changes will be provided to FBP Project Manager prior to such personnel beginning field work at the PORTS facility. C. Any additional training required to perform the contracted task not identified in appendix#1 shall be added to the contractors training matrix for review and approval. Additional training received by employees shall also be submitted as part of the training records described below. D. The Contractor shall maintain auditable training records and/or certifications for each employee that will perform work at the Portsmouth Gaseous Diffusion Plant (PORTS). Employee training records shall be available and provided to the Company, upon request. Employee training records shall adequately document that each employee is properly trained (e.g. Appendix#1 and applicable state and federal required training) to safely and effectively perform work tasks to which they are specifically assigned. The Company will maintain a record of Company provided training which will be supplied to the Contractor upon request. E. The Contractor shall identify the OSHA Competent Person and submit a Competent Person Designation form (Appendix#7) along with the individual’s qualifications in accordance with OSHA regulations for approval by the Company OS&H. F. The Company may require the Contractor to participate in Periodic group safety meetings to discuss issues / lessons learned affecting the Contractor’s work and its employees. NOTE Recordkeeping for occupational injuries and illnesses complies with the requirements of OSHA 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses. Occupational Medical Records are retained confidentially by the contracted Medical Provider.

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 10 of 41 4.2.2 4.2.3 5.0 Records Generated [10 CFR 851.20] A. Safety inspections B. Completion of training C. Instrumentation and Calibration Logs D. Industrial Hygiene (IH) monitoring results E. Accident/Incident Investigation Reports F. Completed Permits G. Job Hazard Analyses (JHAs) H. Occupational Safety and Health Administration (OSHA) 300 Forms OSHA 300-A Logs and Experience Modification Rate A. In addition to the initial submission of the most current completed year and 2 previous years data; the Contractor shall submit annual updates to its OSHA 300-A Logs and Experience Modification Rate from their workers’ compensation insurance carrier to the Company Purchasing Representative for review; this is due no later than February 1 of the New Year. B. At the direction of the Company, Contractor may be required to submit a process improvement plan for approval by the Company Safety and Health, if it’s Experience Modification Rate is above 1.0 and /or its OSHA Total Recordable Case rate is above 1.0. C. The Contractor is to track the total hours worked on a weekly basis and submit them utilizing the Weekly Hour Usage Report (Appendix#13). PROGRAM DISCRIPTION 5.1 Integration with ISMS [10 CFR 851.10, 10 CFR 851.11 and 10 CFR 851.13] 5.1.1 The Company is committed to maintaining an Integrated Safety Management System (ISMS) that promotes the company’s core values of providing a safe and healthy workplace for all employees. The incorporation of the ISMS guiding principles and core functions during the planning and execution of work activities ensures that worker protection is afforded to all persons at the Company site. A key component to the successful implementation of the ISMS is integration of the Contractor WSHP during the planning, execution, and completion stages of work activities.

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 11 of 41 5.2 Zero Accident Program [10 CFR 851.10 and 10 CFR 851.11] 5.2.1 5.3 The Company adheres to a Zero Accident Philosophy and establishes a goal of zero accidents. This philosophy is based on the premise that all accidents are preventable. The Zero Accident Philosophy focuses on not only decreasing accidents, but also on eliminating them. The goal of the Zero Accident Philosophy is to create a safe working environment that empowers employees to “take charge” of their own safety. A critical element to achieving Zero Accidents is effectively implementing the Company approved Contractor WHSP. Stop Work Authority [10 CFR 851.10, 10 CFR 851.20 and 10 CFR 851.21] 5.3.1 Contractor/Subcontractor employees have the right, but also the obligation to stop work at any time to address reasonable belief that work involves imminent dangerous conditions or other serious hazards or concerns of an imminent safety risk that cannot be addressed using our normal work control or hazards reporting and controls processes. 5.3.2 A formal Work Stop requires documentation. A formal Work Stop must also be formally released.

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 12 of 41 5.3.3 5.4 All individuals involved in any aspect of the project have the authority and responsibility to suspend or stop work for any perceived threat to the safety and health of themselves, other personnel, or the environment. These concerns are brought to the attention of supervision and onsite OS&H personnel who will then assess the circumstances surrounding the perceived threat and take appropriate actions to resolve the reported concerns. Hazard Identification and Control [10 CFR 851.21 and 10 CFR 851.22] 5.4.1 A Hazard and Control Identification Checklist (HCIC), (Appendix #20) shall be completed to identify hazards applicable to the work scope. The Contractor shall perform a Job Hazard Analysis prior to work being performed evaluating the associated hazards including environmental hazards. Supplemental site information (the review safety data sheets, materials of construction, drawings and work documents, site characterization data, as-built drawings, etc.) should be reviewed as part of the hazard planning process. The Company (FBP) has developed a General Work JHA (J#26) that encompasses common hazardous activities performed by workers (FBP- JHA-13-1647). The General Work JHA contains hazards that are neither unique nor substantial and is part of the contractors required read catalog found in the STA. Contractors shall follow the controls in the Company’s General Work JHA as applicable to the job being performed. 5.4.2 The Contractor’s Job Specific JHA shall provide an agreed-upon set of S&H standards and requirements that are unique and substantial, outside of those found in the company’s General Work JHA unless those general hazards are in fact unique or substantial based on environmental conditions, that will be established which, when properly implemented, provide adequate assurance that employees, the public, and the environment are protected from adverse consequences based on each work step of the work plan. Any identified protective measures that OSHA requires to be prepared by a Professional Engineer or other qualified professional shall be accompanied by drawings or other appropriate documentation. It is expected that JHAs will be reviewed when the job scope changes and revised as needed to reflect changes. 5.4.3 The Contractor’s Line Management shall ensure that a hierarchy of controls is used for controlling task hazards: A. First through elimination or substitution of the hazards where feasible and appropriate; B. Through engineering controls where feasible and appropriate; C. Next through safe work procedures and administrative controls that are understood, followed, and reinforced where feasible and appropriate; and; D. Finally, by use of personal protective equipment (PPE).

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 13 of 41 5.4.4 The Contractor’s HCIC and JHA shall be submitted for review and approval by FBP Safety and Health (S&H) and acceptance by the Company prior to mobilization. All changes made to the JHA post-mobilization shall be submitted and approved by FBP S&H and the Company utilizing the redline change process prior to implementation. All redline changes are to be electronically updated and re- submitted within 5 work days. 5.4.5 Supervisory responsibilities shall include analyzing the work to identify hazards and implementing appropriate controls and assuring workers are qualified to perform their assigned tasks and follow the applicable work plan. 5.4.6 The Company WSHP provides for written, properly authorized, permits (e.g., electrical, hot work, confined space, chemical, lockout/tag out, environmental, radiological work, etc.) when required before associated work begins; The Company shall provide these permits (refer to Section C Statement of Work) and Contractor equivalent process substitutions will not normally be approved. Permits provide details on the type of activity to be performed and specific safety requirements necessary to perform the job. Permits shall be reviewed with applicable workers who have received necessary training on the associated program(s) and to assure understanding of the hazards and mitigations, posted in a designated area of the workplace and the instructions must be followed without exception. 5.4.7 Job Start-up Briefing and Post–Job Reviews NOTE Pre-mobilization equipment delivery and staging work is permitted following approval of the associated work plans and JHAs. A. Initial Site Briefing All Contractor field personnel shall attend an initial Job Start- up briefing prepared by the Contractor in coordination with the Company Contract Technical Representative or his/her designee prior to conducting any field activities (Appendix#8, Pre-Job Briefing Checklist, Appendix#10 Pre-Job Briefing and Post-Job Review Attendance Form) NOTE Personnel who perform contracted field work on the site must attend a Job Start-up Briefing. These briefings may be provided on an individual basis tailored to the specific scope of work the individual(s) will be performing, as well as the associated hazards and necessary interfaces with other site activities. At a minimum, the following shall be included in the Job Start-up Briefing.

J-13 TITLE: J-13 Flow down of Fluor-BWXT Worker Health and Safety Program REV. NO. 21 Page 14 of 41 B. Job Start-up Briefing 1) Contractor expectations for safety performance 2) General project scope and schedule 3) Project boundaries and requirements for entry 4) Emergency response and assembly areas 5) Job Hazard Analysis (JHA) 6) Safety Task Assignment (STA Appendix #11) 7) Security requirements C. The Safety Task Assignment (STA)/Daily Briefing The STA (Appendix#11) shall be utilized by individual work crews and individual tasks/jobs as a tool to identify hazards and controls associated with the work to be performed by the crew. The STA is performed prior to beginning work, when changing to a new work activity or when job conditions change, new personnel are assigned during the day (e.g. weather, surrounding activities, and unexpec

Appendix#10 Pre-Job Briefing and Post-Job Review Attendance Form Appendix#11 Safety Task Assignment (STA) Appendix#12 Physiological Monitoring for Heat Stress Appendix#13 Weekly Hour Usage Report Appendix#14 Project - Training Matrix A or B Appendix#15 Excavation Trench Inspection Form Appendix#16 Inbound Equipment Inspection Form