Phillips 66

National Labor Relations Board - Administrative Judge Opinions

Apr 9, 2013

16-CA-087373 (N.L.R.B. Apr. 9, 2013)

JD(NY)–15–13
Old Ocean, TX
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
NEW YORK BRANCH OFFICE
PHILLIPS 66 (SWEENY REFINERY)
Case Nos. 16-CA-87373
and 16-CA-89250
16-CA-89036
INTERNATIONAL UNION OF OPERATING
ENGINEERS, LOCAL UNION NO. 564
Dean Owens, Esq., Counsel for the General Counsel.
Dan Dargene, Esq., Ogletree, Deakins, Nash, Smoak & Stewart, P.C., Counsel for the
Respondent.
DECISION
Statement of the Case
Joel P. Biblowitz, Administrative Law Judge: This case was heard by me on
February 21, 2013 in Houston, Texas. The Consolidated Complaint herein, which issued on
December 27, 20121 and was based upon unfair labor practice charges, and an amended
charge, that were filed between August 16 and September 12 by International Union of
Operating Engineers, Local Union No. 564, herein called the Union, alleges that Phillips 66,
herein called the Respondent, on August 14 and September 11, interrogated employees about
their Union activities and sympathies and on August 14, also threatened employees with loss of
benefits if they selected the Union as their bargaining representative. The Consolidated
Complaint further alleges that since about September 11, the Respondent has interfered with its
employees and the Union’s use of the Old Ocean Voluntary Fire Department property to
conduct a Union organizing event. It is alleged that by these actions the Respondent violated
Section 8(a)(1)(1) of the Act.
I. Jurisdiction and Labor Organization Status
Respondent admits, and I find, that it has been an employer engaged in commerce
within the meaning of Section 2(2), (6) and (7) of the Act, and that the Union has been a labor
organization within the meaning of Section 2(5) of the Act.
II. The Facts
The Respondent operates a petrochemical refinery in Old Ocean, Texas, a town
approximately sixty miles south of Houston. The Union presently represents a unit of
approximately twenty crane operators at the Respondent’s Sweeny Refinery, located in Old
Ocean, Texas, herein called the facility. On August 17, it filed a petition to represent all
operators and terminal operators employed by the Respondent the facility. The Acting Regional
Director issued a Decision and Direction of Election dated September 6 wherein he found that
the unit of operators and terminal operators was the appropriate unit and ordered that an
election be held in that unit. At the election conducted on October 4 and 5, there were 87 votes

1 Unless indicated otherwise, all dates referred to herein relate to the year 2012.
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cast in favor or the Union and 233 votes cast against the Union. No objections having been
filed, on October 15 the Regional Director issued a Certification of Results of Election finding
that a majority of the valid ballots were not cast for any labor organization.
There are three distinct incidents herein that are alleged to violate the Act: it is first
alleged that on August 14,Tynes Schroller, Training Supervisor, and an admitted supervisor and
agent of the Respondent, interrogated an employee about his Union activities and sympathies
and those of his fellow employees, and threatened him with the loss of benefits if the employees
selected the Union as their bargaining representative. It is next alleged that on September 11,
Desiree Cromwell, Team Leader and an admitted supervisor and agent of the Respondent,
interrogated an employee about his Union activities and sympathies, as well as those of his
fellow employees. Finally, it is alleged that the Respondent, by Mike Saiz, its Human Resources
Director, interfered with its employees and the Union’s use of the Old Ocean Volunteer Fire
Department property to conduct a Union organizing campaign. Respondent denies these
allegations.
A. August 14 Incident
The recipient of Schroller’s remarks on August 14 was Roger Bennett, who has been
employed by the Respondent for 33 years, and is presently classified as a lead operator at the
facility, a nonsupervisory position. He reports to Dale Thames, supervisor specialist, and Carlos
Sepulveda, the team leader. He has known Schroller for almost thirty years, had worked with
him for about ten years and considers him a friend; up to a few years ago, they used to play golf
together. Schroller is not his supervisor, he does not assign work to Bennett, give him
performance evaluations, or discipline him. Bennett testified that it is a known fact at the facility
that he is a Union supporter and he was an observer for the Union at the election. He testified
that on August 14, while he was making changes in the Respondent’s procedures in the
computer room in the administration building at the facility, he was approached by Schroller, the
highest ranking manager in the training department, who asked, “What’s going on with the
Union?” Bennett shrugged his shoulders, but did not respond. He testified:” I knew better than
to…I didn’t want to start a conversation about the Union.” Schroller said that if the Union came
in the odds are that the Respondent would make the lead operator position salaried. Bennett
responded that he didn’t want to be salaried, and that he would rather “bump back” and be an
operator rather than being salaried. Bennett told other employees about this incident.
Schroller has been employed at the facility for twenty seven years and has been a
training team leader for three years; he reports directly to Saiz. He has known Bennett for about
twenty seven years; during ten of those years, they worked side-by-side and he considers him a
friend. He and the six training team analysts that he oversees provide operational and
maintenance training for the hourly employees at the facility, some hands-on, but most through
the computer, in the training room. He has no supervisory authority over the unit of employees
that the Union was attempting to organize. He testified that on August 14, while he and Bennett
were working in the training computer laboratory, he commented that there was going to be
another vote, and he was not even aware that the Union was having cards signed. They
discussed the pros and cons of unions and how other refineries operate with a union. He told
Bennett that if the Union came in, everything would have to be renegotiated. He also told
Bennett that at the other refineries owned by the Respondent, the operators were salaried.
B. September 11 Incident
This situation involved Winston Bush, who has been employed by the Respondent for
fifteen years as a chemical plant operator. His lead operator is Alvin Johnson; Cromwell is his
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team leader. His department’s responsibility is to monitor environmental concerns pertaining to
the river water used at the facility. He testified that he had no involvement with the Union’s
organizational campaign. On September 7, he sent Cromwell an email setting forth his concerns
about some plants that had appeared in the water system that could cause a problem for the
water supply. On September 11, while he was making his rounds of the reservoir and the river
in his truck he received a call from Charlie Willbanks, his lead operator at the time, saying that
Cromwell wanted to speak to him. He drove back and saw her on the roadway and told her that
he could show her the problem areas and she agreed, and he said, “hop in.” He was getting
ready to show her the problem areas, when she said, “Let me ask you something, what’s your
opinion of this union thing?” He did not reply, testifying: “I tried to stay as close-mouthed on it as
I possibly could.” He told her that he didn’t have an opinion about it and she told him that the
facility was probably one of the better ones that she had worked at because they were close knit
and family oriented. She said that the employees have “a good thing here” and that she has
worked in other plants and knows how hectic it could be “working in a unionized environment.”
She mentioned that in one unionized plant nine hundred cases had to go to arbitration. When he
arrived at the location that Cromwell asked to be dropped off at, she stayed in the truck and
continued to talk about how the Union would not necessarily be beneficial to the employees. To
play the “Devil’s Advocate,” he asked her what would be the worst thing about having a union
for representation, and she said that the company already had an employee review board and
an open door policy. He asked her if he were her husband, brother or cousin, would she be
having this conversation with him and she said that she would. Before leaving the truck, she
gave him a printout of the pros and cons of a union. Shortly thereafter, a group of employees,
including Bush, invited her to join them for lunch.
Cromwell has been employed at the facility for four years and has been team leader for
a year and a month. On Monday, September 10, while she was speaking to Bush, he asked if
she had seen his September 7 email and when she did recollect it, he asked if she had time the
following day to drive with him to inspect the problem areas, and she said that she did, and on
September 11, she had him paged and he picked her up in his truck. She testified that after
about fifteen minutes and discussions of the water situation, she mentioned that she was
surprised that she received an email dated August 21 from the general manager of the facility
that the Union had filed a petition with the Board to represent the operators. She testified that
Bush responded that he was not surprised because of the issues the operators were having
with management. She told him that the Respondent had implemented a lot of new programs to
improve communications between the employees and management and had established a peer
review process and an employee excellence team, and he acknowledged that they were good
programs. He asked her to take off her manager’s hat and asked if he were her cousin, husband
or brother, would she be telling him the same things, and she said that she would. While in the
truck, they spent fifteen minutes or less speaking about the Union, and a majority of the time,
speaking about the water system.
C. The Union Party at the Firehouse
The Old Ocean Volunteer Fire Department, herein called the Fire Department, is located
directly across the road from the facility, on land owned by the Respondent. On September 18,
1980, the Respondent entered into a lease agreement with the Fire Department for one dollar a
year for a period of five years, but from year to year thereafter until either party gives the other
thirty days written notice of its intention to terminate the agreement. Apparently, neither party
has exercised its right to terminate the agreement. The building on the premises is small and
contains bays where the fire trucks are stored, and it is located on a third of an acre lot with
adjacent acreage containing a baseball field and a parking lot. Over the years the Union has
held regular monthly meetings of its membership composed of crane operators employed at the
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facility. Prior to arranging these meetings, the Union called Craig Peterson, the Fire Chief, for
permission to use the facility for the meeting, and he has always given his approval. Charles
Singletary, Business Manager of the Union, testified that other unions representing pipefitters,
boilermakers, welders, operating engineers and electricians employed at the facility also used
the building for their monthly meetings.
Singletary testified that in mid-August, he called Peterson to ask permission to use the
Fire Department property for either a pancake breakfast or another function and that they would
be using the property for the entire day. Peterson gave him permission, and told him that the
property had no kitchen, and Singletary said that they would bring everything that they needed.
Singletary asked if he could take the fire trucks out of the bays, and he said that if he were
available he could, and he also asked if the Union could use the meeting room if people wanted
to come inside out of the Summer heat, and Peterson said that they could. Singletary also said
that they were going to be setting up tents and that they would have everything that they
needed. About a week later, he called Peterson to confirm, and told him that they were either
going to have a barbecue, where they cooked the food elsewhere, and brought it to the site, or
would have the party catered, and the party was scheduled for September 13. Shortly thereafter
the Union distributed a flyer to all employees on the Excelsior list stating that the barbecue
would be at the Fire Department property on September 13 from Noon to 8:00 P.M. Eric Wells,
an organizer for the Union, testified that on about September 11 he received a telephone call
from Peterson saying that the Union would not be able to have their barbecue at the Fire
Department because he was contacted by Saiz stating that the barbecue would not be taking
place there.
Peterson testified that a number of years ago he began allowing in-house unions at the
facility to use his building for meetings, and prior to this situation, he never refused permission
for a union to use the building. When he received the call from Singletary asking if the Union
could use the property on September 13 he told him that they could do so. A few days prior to
September 13 he received a telephone call from Saiz asking about the Union’s barbecue: “And
he asked me if I was aware that our station sat on Phillips property, and I said yes, sir. And he
said, well the unions are really not supposed to have things on our property. And I said,
okay…he asked me if I would call and talk to the people and get them to move it, and I said,
sure.” Peterson then asked Saiz if he was wrong letting the other unions use the building for
their meetings, and he said that he didn’t have a problem with the in-house unions meeting at
the fire station: “he said he only had a problem with this event and not with the other meetings.”
Peterson then called the Union and told them that because the firehouse sat on Respondent’s
property they could not have their meeting there and they would have to move it to another
location, and mentioned the telephone call that he received from Saiz. The Union was able to
obtain the use of a VFW hall, approximately four miles away for the meeting on September 13.
Although they expected approximately one hundred people to attend, only about thirty attended
the event at the VFW hall2.

2 There was some testimony, principally on cross examination, about whether liquor would
be served at the event (it wouldn’t, but people could bring their own) and the size of, and
facilities at, the building compared the nature of the event and the number of people expected to
attend. I find that both subjects are irrelevant to the ultimate determination herein, the former
because Saiz’ objection was not to the fact that there might be liquor at the event (it wasn’t even
mentioned in his call to Peterson), and the latter because the Union’s event was going to be in
tents set up outside the building, and the food was going to be cooked elsewhere or catered so
that the size of the building, and the limited facilities in the building, were not relevant factors.
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III. Analysis
It is initially alleged that Schroller’s questioning of Bennett, on about August 14, violated
Section 8(a)(1) of the Act. As there are credibility issues involving the testimony of Bennett and
Schroller, and Bush and Cromwell, I found the testimony of Bennett and Bush to be totally
credible and believable, and credit their testimony over that of Schroller and Cromwell. Although
I did not find Schroller to be an incredible witness, I found Bennett to be clearly more credible. In
addition, I found Cromwell, at times, to be evasive and incapable or unwilling to answer directly,
and I credit his testimony over hers.
Rossmore House, 269 NLRB 1176 (1984) and some more recent cases such as John
W. Hancock, Jr., Inc., 337 NLRB 1223 (2002); Toma Metals, Inc., 342 NLRB 787, 789 (2004);
and Camaco Lorain Manufacturing, 356 NLRB No. 143 (2011) set forth the factors to be
considered in determining whether questioning of this nature violates the Act:
(1) The background, i.e., is there a history of employer hostility and discrimination?
(2) The nature of the information sought, e.g., did the questioner appear to be seeking
information on which to base taking action against individual employees?
(3) The identity of the questioner, i.e., how high was he/she in the company hierarchy?
(4) Place and method of interrogation, e.g., was employee called from work to the boss’s
office? Was there an atmosphere of unnatural formality?
(5) Truthfulness of the reply.
The Board also takes into consideration whether the supervisor and the questioned employee
had a friendly relationship and whether the employee was reluctant to respond. Gelita, USA,
Inc., 352 NLRB 406 (2008). Further, the Board stresses that these factors are not to be
mechanically applied. Sunnyvale Medical Clinic, 277 NLRB 1217, 1218 (1985).
Taking these factors into consideration, there is no history of hostility between the
Respondent and the Union, other than the allegations herein and, in fact, some of the
Respondent’s employees are organized; Schroller’s question to Bennett was a general,
nonspecific, question, rather than one that attempted to induce Bennett to incriminate himself.
Schroller and Bennett had worked together side by side for ten years, they have known each
other for almost thirty years and still consider the other a friend. Bennett is a known Union
supporter, was an observer for the Union at the election, and Schroller is not Bennett’s
supervisor, he is a training team leader, and the question was asked while they were in the
computer room of the administration building. On the other hand, rather than answer the
question, Bennett shrugged his shoulders because he didn’t want to discuss the subject. Other
than Bennett’s reluctance to answer Schroller’s inquiry, all of these factors are answered in
Respondent’s favor. I therefore find that there was no unlawful interrogation here, and
recommend that this allegation be dismissed. However, the Complaint also alleges that
Schroller threatened Bennett with the loss of benefits if the employees selected the Union as
their collective bargaining representative, and that is precisely what Schroller did; he told
Bennett that if the Union came in the odds were that the Respondent would make the lead
operator position (Bennett’s job) salaried, even though there was no record evidence to support
this conclusion. This statement by Schroller was “…no longer a reasonable prediction based on
available facts, but a threat of retaliation based on misrepresentation and coercion, and as such
without the protection of the First Amendment.” Gissel Packing Co. v. NLRB, 395 U.S. 575, 618
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(1969). By telling Bennett that the Respondent would probably do that in response to the
employees’ Union activities, the Respondent violated Section 8(a)(1) of the Act.
Employing the same factors for the September 11 situation involving Cromwell and
Bush, I find that her questions and comments violated Section 8(a)(1) of the Act. Unlike
Schroller’s general question: “What’s going on with the Union?” Cromwell’s question was
specific, asking him his opinion about the Union. In addition, Bush had no involvement, or open
involvement, with the Union, she was his supervisor and they were not on a friendly basis, as
Bennett and Cromwell were, and the conversation was one-on-one in the closer confine of the
Respondent’s truck. Further, his testimony that he tried to stay as closed mouthed as he could,
establishes that he was uncomfortable with the question. For all these reasons, I find that her
question about the Union, while they were in the truck, violated Section 8(a)(1) of the Act.
The final issue relates to the legality of the Respondent’s refusal to allow the Union to
have its September 13 party at the Fire Department. The evidence establishes that the
Respondent owns the land on which the Fire Department sits and that it leases the land to the
Fire Department for a dollar a year. The evidence also establishes that the Fire Department,
with no objection from the Respondent, has regularly granted Respondent’s in-house unions
permission to hold meetings on its premises. The first occasion when such permission was
denied was on about September 11 when Saiz overruled Peterson and told him that unions
were not really supposed to meet on its property, and asked him to call the Union to tell them to
move their meeting to another location, which he did. Unlike Counsel for the General Counsel’s
Brief, I find it unnecessary to differentiate between Respondent’s rights as the owner, or not the
owner, of the property on which the Fire Department is located. Rather, I find that the
appropriate inquiry is whether the denial of the use of the property was the result of disparate
treatment caused by the Union’s organizational purpose at the property.
D’Alessandro’s, Inc., 292 NLRB 81, 84 (1988) stated that an employer may prohibit
certain postings on its property as long as it does not discriminate against the union by allowing
other distributions. In Davis Supermarkets, 306 NLRB 426 (1992), the Board found that the
employer violated the Act because of its disparate treatment of denying access to the union
while permitting access to others. And in Columbia University, 225 NLRB 185 (1976), clearly
relevant to the facts herein, the Board found that the university violated the Act by denying
access to an organizing committee composed solely of its employees, while allowing recognized
union groups, and outside groups, to use the denied facility for a variety of purposes. Also on
point is Dow Jones and Company, 318 NLRB 574 (1995) where the union, which represented
about two thousand of the employer’s employees nationwide, proposed to its membership that
rather than being an independent union, they affiliate with the Communications Workers of
America, and the employer openly and actively opposed this affiliation. Although the employer
had allowed other groups (groups composed of minority employees and female employees,
smoke-ending programs and weight reduction programs) to meet on their premises, they
refused to allow the union and CWA representatives to use its facilities to solicit support for the
proposed affiliation. The Board affirmed the judge’s finding that the employer violated the Act
because of its disparate treatment of denying access to the union, while granting it to others.
Clearly, that is also the situation herein. The in-house unions regularly had meetings at the
firehouse; in fact, Peterson initially told Singletary that the Union could have their party there.
The first time that such a meeting was prohibited was when Saiz called Peterson on September
11 and told him not to allow the Union to have the party. Clearly, there was no reason for this
prohibition other than the fact that, in this situation, the Union was attempting to organize the
Respondent’s employees. Whitesell Corporation, 352 NLRB 1196 (2008). This obvious
disparate treatment violates Section 8(a)(1) of the Act.
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Conclusions of Law
1. Respondent has been an employer engaged in commerce within the meaning of
Section 2(2), (6) and (7) of the Act.
2. The Union has been a labor organization within the meaning of Section 2(5) of the
Act.
3. The Respondent violated Section 8(a)(1) of the Union when Cromwell interrogated
Bush on about September 11.
4. The Respondent violated Section 8(a)(1) of the Act when Schroller told Bennett that
the Respondent would probably make his position salaried if the Union were voted in.
5. The Respondent violated Section 8(a)(1) of the Act by denying the Union the use of
the Fire Department property for its organizational party on September 13, 2012.
6. The Respondent did not violate the Act as further alleged in the Complaint.
The Remedy
Having found that the Respondent has violated Section 8(a)(1) of the Act, I recommend
that it cease and desist therefrom and take certain affirmative action designed to effectuate the
policies of the Act. In that regard, Respondent shall notify the Union and the Fire Department, in
writing, that it has no objection to the Union, or any other labor organization, using the property
for any purpose that does not conflict with the Fire Department’s purpose.
Upon the foregoing findings of fact, conclusions of law, and on the entire record, I hereby
issue the following recommended3
ORDER
The Respondent, Phillips 66, its officers, agents, successors and assigns shall
1. Cease and desist from:
(a) Refusing to allow the Union, or any other labor organization, equal and
nondiscriminatory access to the Old Ocean Volunteer Fire Department property, or any other
property owned or maintained by the Respondent.
(b) Interrogating its employees regarding their Union activities, or threatening employees
with adverse working conditions if they chose the Union as their collective bargaining
representative.
(c) In any like or related manner interfering, restraining or coercing employees in the

3 If no exceptions are filed as provided by Sec. 102.46 of the Board’s Rules and
Regulations, the findings, conclusions, and recommended Order shall, as provided in Sec.
102.48 of the Rules, be adopted by the Board and all objections to them shall be deemed
waived for all purposes.
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exercise of their rights guaranteed them by Section 7 of the Act.
2. Take the following affirmative action designed to effectuate the policies of the Act.
(a) Notify the Union and the Fire Department, in writing, that it has no objection to its use
of the Old Ocean Volunteer Fire Department property for regular union meetings or for meetings
with an organizational purpose and that, it will allow the use of its facilities on a
nondiscriminatory basis.
(b) Within 14 days after service by the Region, post at its Sweeny Refinery, and all
refineries in the United States, copies of the attached notice marked “Appendix.”4 Copies of the
notice, on forms provided by the Regional Director for Region 16, after being signed by the
Respondent’s authorized representative, shall be posted by the Respondent and maintained for
60 consecutive days in conspicuous places including all places where notices to employees are
customarily posted. Reasonable steps shall be taken by the Respondent to ensure that the
notices are not altered, defaced, or covered by any other material. In the event that, during the
pendency of these proceedings, the Respondent has gone out of business or closed the facility
involved in these proceedings, the Respondent shall duplicate and mail, at its own expense, a
copy of the notice to all current employees and former employees employed by the Respondent
at any time since September 11, 2012.
(c) Within 21 days after service by the Region, file with the Regional Director a sworn
certification of a responsible official on a form provided by the Region attesting to the steps that
the Respondent has taken to comply.
(d) IT IS FURTHER ORDERED that the complaint is dismissed insofar as it alleges
violations of the Act not specifically found.
Dated, Washington, D.C. April 9, 2013
____________________________
Joel P. Biblowitz
Administrative Law Judge

4 If this Order is enforced by a judgment of a United States court of appeals, the words in the
notice reading “Posted by Order of the National Labor Relations Board” shall read “Posted
Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the
National Labor Relations Board.”
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APPENDIX
NOTICE TO EMPLOYEES
Posted by Order of the
National Labor Relations Board
An Agency of the United States Government
The National Labor Relations Board has found that we violated Federal labor law and has
ordered us to post and obey this Notice.
FEDERAL LAW GIVES YOU THE RIGHT TO
Form, join, or assist a union
Choose representatives to bargain with us on your behalf
Act together with other employees for your benefit and protection
Choose not to engage in any of these protected activities
WE WILL NOT threaten you with the loss of benefits if you choose International Union of
Operating Engineers, Local Union No. 564, (“the Union”), or any other labor organization to
represent you, and WE WILL NOT question you about your support for the Union, or for any
other labor organization.
WE WILL NOT refuse to allow the Union, or any other labor organization, equal and
nondiscriminatory access to the Old Ocean Volunteer Fire Department (“Fire Department”)
property, or any other property that we own or maintain and WE WILL NOT in any like or
related manner interfere with, restrain or coerce you in the exercise of the rights guaranteed you
by Section 7 of the Act.
WE WILL notify the Union and the Fire Department that it may use the Fire Department
property, or any other property that we own or maintain, for any function, on a nondiscriminatory
basis.
PHILLIPS 66
Dated_____________ By_____________________________________________________
(Representative) (Title)
The National Labor Relations Board is an independent Federal agency created in 1935 to enforce the National Labor
Relations Act. It conducts secret-ballot elections to determine whether employees want union representation and it
investigates and remedies unfair labor practices by employers and unions. To find out more about your rights under
the Act and how to file a charge or election petition, you may speak confidentially to any agent with the Board’s
Regional Office set forth below. You may also obtain information from the Board’s website: www.nlrb.gov.
1919 Smith Street, Suite 1545
Houston, TX 77002
Hours: 8:15 a.m. to 4:45 p.m.
713-209-4885
THIS IS AN OFFICIAL NOTICE AND MUST NOT BE DEFACED BY ANYONE
THIS NOTICE MUST REMAIN POSTED FOR 60 CONSECUTIVE DAYS FROM THE DATE OF POSTING AND MUST
NOT BE ALTERED, DEFACED, OR COVERED BY ANY OTHER MATERIAL. ANY QUESTIONS CONCERNING THIS
NOTICE OR COMPLIANCE WITH ITS PROVISIONS MAY BE DIRECTED TO THE ABOVE REGIONAL OFFICE’S
COMPLIANCE OFFICER, 817-978-2925.