November 2, 2017 Hello Susannah, JC Mathews, with whom you've been speaking, is out this afternoon and asked me to send you the answers to the questions you emailed him. V/r, Mary Anne Mascianica Public Affairs Officer Puget Sound Naval Shipyard & IMF (360) 476-7111 -----------------------------------------------------------------------1. What is the approximate date when shop 1109 stopped many of the chemical processes (and sent wastewater off site)? PSNS&IMF suspended industrial wastewater operations in Building 1109 on April 10, 2013, when an industrial hygienist performing a routine worksite assessment found elevated chlorine levels that were generated more quickly than expected. Although no injuries resulted and the Occupational Safety and Health Administration (OSHA) determined no one was exposed to chemicals above Permissible Exposure Levels (PELs) in the incident, out of an abundance of caution PSNS & IMF suspended operations at the facility and ordered a complete evaluation of the facility and its processes. 2. What is the approximate date when shop 1109 re-opened, able to reinstitute all the treatment processes? Following the suspension of operations on April 10, 2013, PSNS&IMF conducted an extensive evaluation of the treatment processes accomplished in Building 1109. Evaluations were performed to ensure that the procedures were safe for each treatment process and exposure to chemicals was verified to be below the applicable OSHA PELs. An assessment conducted by an engineering firm showed that further improvements to the facility were possible. As a result, PSNS & IMF invested an additional $2 million in plant upgrades. In the meantime, while PSNS & IMF made use of an existing off-site treatment process, new procedures were written to provide specific instructions for each process performed in the building. The treatment processes were brought back online incrementally beginning May 30, 2013, with the final treatment process recommencing March 10, 2017. 3. You stated in your previous email that "The facility is and has always been safe." What are you basing that on? Why do you believe it is and always has been safe? Building 1109 was constructed in 2006 using state-of-the-art systems which met industry standards. The plant was originally commissioned with open top tanks. General building ventilation systems were installed behind the tanks. These ventilation systems exhausted outdoors, achieving multiple (6 - 8) complete air changes in the building every hour to protect air quality and keep exposure to chemicals below OSHA PELs. In 2012, as a result of a concern raised by Building 1109 employees, PSNS&IMF tasked industrial hygienists and other safety, health, and environmental professionals to review operations, conduct worksite assessments, determine whether employees were being improperly exposed to chemicals and to evaluate the need for improvements. As part of this review, industrial hygienists from Naval Hospital Bremerton conducted monitoring during various treatment processes performed in the plant during its normal use. Sampling in various scenarios was conducted, and it was determined that the employees were not exposed above OSHA PELs. However, PSNS&IMF is committed to going beyond the legal requirement and minimizing exposure to the extent practicable. Despite the absence of employee injury and exposure, PSNS&IMF hired an engineering firm to review treatment processes and modify equipment design. Although the original monitoring and ventilation equipment were still found to be state-of-the-art, improvements to add more layers of protection were identified and installed. PSNS&IMF takes employee safety, training and feedback seriously and does what it can to mitigate risks beyond the level required by law wherever possible. The improvements to Building 1109 are evidence of this. 4. In general, what were the $2 million in upgrades for? The purpose of the $2 million project was to take advantage of engineering improvements to make the facility even safer and more efficient, based on our assessment at that time. Among the improvements were a new chemical feed injection system, localized ventilation at each tank, a reduction in noise within the plant, additional gas sensors and additional protective equipment. 5. Why was 1109 built and opened without a "closed loop system," (lids on tanks) as the original plans called for? The final design for the plant, considered state-of-the-art at the time, called for open-top tanks which did not require lids. Under this design, the only benefit to lids would be to prevent debris from falling into the tanks. a. Was this to save money? No. b. Was this to save time? No. 6. Given that you've said the plant has always been safe, does the Navy/PSNS believe that anyone has suffered adverse health effects from working in the plant? PSNS&IMF has no evidence of adverse health effects resulting from work in Building 1109, and no injuries have been identified. We are aware of workers' compensation claims that have been filed by employees who supported Building 1109, in addition to their other duties. Such claims are filed with the Office of Workers' Compensation Programs (OWCP), which is responsible for determining the outcome of those claims. 7. Was the Navy/PSNS aware that employees had concerns for their health and safety from the time the plant opened, to when many of the processes were shut down? Our in-depth review of plant operations beginning in 2012 was conducted in response to employee concerns and feedback. As part of this review, industrial hygienists conducted monitoring during various treatment processes performed in the plant during its normal use. Sampling in various scenarios was conducted, and it was determined that the employees were not exposed above OSHA PELs. 8. Why were warnings given to PSNS about the inadequacies of the plant not heeded prior to opening it? (IE: concerns about alarms, ventilation, chemical odors, leaking, spills, secondary containment, operator training). Concerns identified during the routine process of preparing a new facility for operation were addressed and corrections were made as needed. Once the facility opened, it operated safely and as designed. The plant operators were trained by a contractor to standards in the plant's operations and maintenance manual. The trainers remained in place during the initial start-up period to provide additional on-the-job training. 9. Does the Navy/PSNS believe that 1109 operators were exposed to toxins including cyanide gas, chlorine gas, and hexavalent chrome at levels exceeding PELs? No. An event did create concerns on April 10, 2013, during a routine worksite assessment, when an industrial hygienist found elevated chlorine levels that were generated more quickly than expected. All employees participating in the process moved quickly to a separately ventilated enclosed room. The prompt execution of the Building 1109 emergency action plan limited employee exposure to chlorine gas. As a precautionary measure, PSNS & IMF directed employees to the Naval Hospital Bremerton Branch Medical Clinic for evaluation. Based on that evaluation, no injuries were identified, and no further medical treatment was recommended. OSHA also investigated the incident and concluded there had not been any exposure above permissible levels. 10. Can you tell me how many square feet Building 1109 is? And I believe it is 3 stories high, is that right? Building 1109 is 10,375 square feet. It is a two-floor facility. 11. How many people work at PSNS & IMF? The workforce population of PSNS & IMF is approximately 13,500.