DEPARTMENT OF THE NAVY PUGET SOUND NAVAL SHIPYARD AND INTERMEDIATE MAINTENANCE FACILITY 1400 AVENUE BREHKERTON, WASHINGTON 98314-6001 REPLYREFERTO 5100 Ser 106.22/0245 061112013 Occupational Safety and Health Administration US Department of Labor Attn: Mr. Dave Baker, Area Director 520 112e1Avenue NE, Suite 200 Bellevue, WA 98004 Dear Mr. Baker: This letter provides a response to the_Notice of Unsafe or Unhealthful Working Conditions, Inspection Number 905898, regarding industrial wastewater operatidns performed at the washington State permitted, Industrial Wastewater Pre?Treatment Facility (IWPF), Building 1109, Puget Sound Naval Shipyard and Intermediate Maintenance Facility (PSNS is the abatement certification requested by the notice. As previously noted during the Occupational Safety and Health Administration (OSHA) onsite inspection, PSNS a IMF halted operations in the pretreatment plant approximately one month before OSHA visited, when it self?identified the problems found during a routine worksite assessment of the cyanide destruction?process on electroplating wastewater on 10 April 2013. Both items 1 (pertaining to exposure) and 2 (pertaining to training) in the notice were abated a month before OSHA visited because the process was halted on 10 April 2013. The worksite assessment was being accompliShed by PSNS IMF personnel for purposes of updating the industrial hygiene (IH) survey for the cyanide destruction process to ensure engineering controls, administrative controls and personal protective equipment (PPE) were effective in keeping exposure to chemicals as far below the authorized permissible exposure limits as possible. Based on past IH surveys and existing controls, chlorine gas levels were not identified as presenting a respiratory hazard and respiratory protection was not issued. During the worksite assesSment, chlorine gas levels were being monitored with a handheld meter when the levels elevated more quickly than expected and above the Immediately Dangerous to Life or Health (IDLH) level within two minutes. An excess quantity of sulfuric acid was added to the electroplating. ?wastewater containing sodium hypochlorite. The cyanide destruction process was stopped and employees immediately evacuated the area when chlorine gas levels elevated. 5100 Ser 106.22/0245 Subsequent investigation determined a chemical reaction produced by the improperly controlled pH_resulted in the unexpected generation of high concentrations of chlorine gas. The prompt execution of the Building 1109 emergency action plan limited employee exposure to chlorine gas. Employees were sent to the PSNS IMF Branch Medical Clinic as a precautionary measure. No injuries occurred. -Inadequacies with training specified by Item 2 of the notice were alSo selfwidentified by PSNS IMF during the investigation "of the event which occurred on 10 April 2013 when the elevated chorine gas levels were detected by PSNS IMF personnel. On? .the~job training (OJT) had been provided to Building 1109 employees. Employees had also received hazard communication (HAZCOM) training for the chemicals added to the electroplating wastewater during the cyanide destruction process. Neither the OJT nor the HAZCOM training adequately covered the potential hazards associated with chemicals that are byproducts of the cyanide destruction process. Employees were aware of the potential to generate chlorine gas.based on their OJT and the presence of chlorine gas alarms but the chemistry behind the reaction and the properties and hazards associated with chlorine gas were not fully understood by the employees. In conjunction with suspending the cyanide destruction process on 10 April 2013, PSNS IMF began conducting a detailed "review of engineering controls, procedures, work practices, PPE, and monitoring to allow safe resumption of the process. This review is ongoing and the process will not be allowed to recommence until PSNS IMF experts are satisfied that it can be done safely under all conditions and that exposure to chemicals is kept as far below the authorized permissible expoSure limits- as possible. Procedures will be revised to specify safety and health precautions to mitigate chlorine exposure concerns, set stop points for chlorine gas hazards being monitored, and establish response actions if stop points are reached. Sulfuric acid and.sodiumihypochlorite will be added through a closed loop automated chemical injection system to mitigate dangers associated with the cyanide destruction process. The tanks in which the.cyanide destruction process is performed will be covered and have additional ventilation installed to remove any - potential chlorine gas from the worker's breathing zone. As an administrative control, procedures will not allow employees to be in close proximity to the tanks during the cyanide destruction process. Chlorine gas monitoring will be conducted at the tanks to improve the verification proceSs to ensure that procedures, controls and PPE are effective. PSNS IMF is. 2 5100 Ser 106.22/0245 bringing in an Architectural and Engineering contractor to assess all industrial wastewater processes at Building 1109. Additional procedure revisions, plant modifications, gas alarm relocation and training will be implemented based on the assessment. PSNS IMF will develop and implement an ?in house? continuing training program for employees assigned to Building 1109. Continuous training will be focused on the procedures contained within the revised Industrial Process Instruction and the new Industrial Engineering Instructions governing plant operations. PSNS IMF is bringing in an outside vendor to provide two days of training specifically focused on treating electroplating waste water. HAZCOM training will be_revised to cover the potential hazards associated with chemicals that are byproducts of the cyanide destruction process. Employees will -also be re~briefed on the HAZCOM training for the chemicals added to the electroplating wastewater during the cyanide destruction process. PSNS IMF is confident that its employees.have not been exposed to chlorine gas levels at or near the IDLE level prior to this incidents .Chlorine gas has strong olfactory properties and would produce a severe physical reaction at the IDLE level. No such reaction'has been reported by employees assigned to Building 1109. However, the steps outlined above will ensure exposure is reduced to the maximum extent possible and that protections for operator error will be maximized. If you have any further questions regarding this issue, please contact Ms. Cindy Sims, Head, Safety and Health Division (Code 106.2), at (360) 476?3671. . A. HEE CKER Director, Environmental, Safety, and Health Office By direction of the Shipyard Commander Enclosure: 1. Certificate of Corrective Action Worksheet After reviewing the response to the OSHA citation(s), There are numerous discrepancies in the statements made to OSHA. How can you say there wasn't any exposer with all the facts that came to light with the critiques. The response also stated that the lH survey was being done to update lH survey, but in fact there has never been one on the plant as built, the original survey stated that it was a closed loop system and there was no chance of exposer. But in fact that was not the case, the plant design changed at some point and no one caught it on the IH survey. It never was a closed loop system. The Fact that they did not install covers or ventilation to make it a closed loop system put the operators in a situation that they were being exposed daily to to a varity of toxic fumes and vapors from the transfer and treatment processes in bldg. 1109. Unfortunately, this major mistake was not realized until the plating shop sent us water that was not supposed to come to the IWPF but was to be shipped off site for treatment. But instead when we received it into Process tank 3A in bldg. 1109 it set off the chlorine alarms and forced the evacuation of the bldg. Code 106 was called and Craig Henderson(industria hygienist from 106) came down to investigate, the levels were very high and we shut down all operations until the plant finally cleared the fumes 24hrs later.(Craig told us that ?we should be ok? stating that the original survey stated it was a closed loop system) but no one ever looked at the plant to see that it was not built to the approved plans, but instead was built to a modified set of plans that did not include the required ventilation or the required tank lids on the process tanks that was specked out in the original MCON PROJECT On contract This project was started on May 1,2002 And conformed on Jan we have copies of all this It even states on the tanks id plaque that lids are required with ventilation on all the process tanks in bldg. 1109. And for the first 5+ years there was not even chlorine alarms installed in the plant until a prior critique CATS item made them install them. (see critique for details) They Started to install them in Feb 2012 but did not go on line until July 15 2012. However the contractor that installed them, and the contractor (E18) that was to maintain and test had problems testing them and had told us that they were not sure they were working. The other issue with the alarms in the building have to due to the fact that the cyanide alarms that had been installed during the original construction. it's my opinion, and blatantly obvious to others that they were not put in a location that will detect any problem until after it?s gone thru the breathing zone. You don?t have to be a rocket scientist to see the problem with the location but you should be knowledgeable about what type of gasses (chlorine, hydrogen cyanide, sulfur dioxide) and the properties ofall the other potential gasses being generated in the plant. Not to mention the fact that the physical properties of cyanide gas, and hydrogen cyanide gas is heavier than air and will sink to the basement following the outside of the tank. Unfortunately these details were not taken into consideration when they decided on the locations that were used. The only alarms installed originally were for cyanide gas. But these were not even on the cyanide tanks but in between the chrome tanks aprox 10? below the operators and 6+ away from the base of the cyanide tanks. This was brought up to upper management on several occasions and we were told that this is a state ofthe art design and we were safe. in addition to the fact that we have had several cyanide alarms trigger the low level set points and the hi?level causing evacuations in the past. The distance the alarms are from the source and still detected high levels would not have been accurate in the breathing zone, it would be much higher. The next issue with the alarms were going off whenever we would receive (fish glue tanks) ie Photo etch water . during these transfers there is a very strong oder that would set off our cyanide alarms, code 980 was asked what we could do and we were instructed to put large fans near the tank tops to blow the smell away from the operators but this was affecting the function of the ventilation system. Then we were told By our GF at the time that they were false alarms and to dis able the cyanide alarms whenever we needed to receive (fish glue tanks but it turned out that the fish glue was full of chemicals that should not come to 1109 but should have been shipped off site for treatment . And they were not false alarms after all (see critique 200-cr.13.98 for more details). Then let's get to the fact that we were also receiving waste from the chem lab on a regular basis, however the chem? lab was using a lab?exempt profile that had expired several years ago, this also fell thru the gaps. And it was discovered that these should also be shipped off site for treatment.(this was also discovered in critique for shop 17) Due to the fact it would react with the standard wastewater that is to be treated in bldg. 1109. After finding out these facts we no longer take these types of waste. In bldg. 1109. WHY because they produce dangerous gasses and the ventilation is not capable of protecting the operators. Other issues with the ventilation system include the fact that there are several locations in the plant that don?t clear when an odor is introduced. The ventilation system is supposed to exchange all the air every 6 min per the design specs. However our SOP states that if we smell something unknown to call 911 and evacuate, recently that happened we had the fire dept down to investigate, but the source was never located. No hazardous were detected and the bldging was release back to us but the smell was still detectable 24 later. Why if the air should have been changed out completely every 6 min that would be 10 times per hr times 24 would have changed all the air in the bldg. 240 times then why would the smell still be there if the ventilation system was working how it was supposed to? . I know that code 980 has tested the ratio, and we were told that it was correct, but something has to be wrong. We conducted our own test using mango air freshener and it too stayed for more than 20 hours in the area at the top of the stairs at the (human Machine interface) where we run the automated system. Next let's talk about OJT, I would like to see these records of the training we received. Let's look at the p?910 briefs and the dates that we received them. On all Operators in the plant since it opened 2003. I'm am perplexed by the stance 106.22 has stated in their response to this matter and hope that people will look at the evidence in this case. All of the facts will come out in the end. And it's in everybody best interest to know all the facts before commenting on these issues. Please remember that False or misleading statements made to OSHA can lead up to a $10,000.00 fine and up to 6 months in jail for that person or persons involved in the statement. Message From: Boyle, Kevin A, 5/99 Sent: Wednesday, October 16, 2013 7:08 AM To: Bressert, Matt 2 CW Shop Shop Albert, Kevi