DEPARTMENT OF THE NAVY
ENGINEERING FIELD ACTIVITY, NORTHWEST
NAVAL FACILITIES ENGINEERING COMMAND
1991 77TH AVENUE N.E.
POULSBO, WASHINGTON 98370-7570

16 Apr 98

The Honorable Patty Murray
United States Senate
Washington, D.C. 20510-4704

Dear Senator Murray,

Your letter dated 24 March 1998 to the Department of the Navy, Chief of Legislative Affairs, concerning Mr. Robert Farmer has been referred to this office for response.

Mr. Farmer's e-mail correspondence expressed his concern in regard to the health and safety of contractor employees, and the surrounding community, during the Puget Sound Naval Shipyard (PSNS) Hammerhead Crane repainting operations. He alleges contractor employee exposure during operations resulting in high blood lead levels. In addition, he describes tears in the containment system and purports that lead contaminated dust was released into the surrounding air and water.

The contract to paint the Hammerhead Crane was awarded to Weststar Engineering, Inc. in December 1995. The contract scope required the contractor to remove the old paint, known to contain lead, prior to preserving and repainting. Weststar chose to perform this paint removal by a steel grit blasting operation. The contract required Weststar to prepare and submit for approval a Lead Paint Removal Plan prior to commencing this activity. This Plan outlined Weststar's responsibilities for the protection of their employees and the surrounding environment in accordance with Occupational Safety and Health Standards during the course of their work. It also defined Weststar's paint removal methods, construction of the containment enclosure, auxiliary employee facilities, air monitoring, personal protective equipment and medical surveillance, and cleanup and disposal procedures. The Plan included baseline and periodic testing of employees' blood lead levels. The Plan was approved as meeting the requirements of current safety and health regulations.

The blasting operation commenced in July 1996 and was substantially completed in December 1997. In the fall of 1997, OSHA cited Weststar for failure to comply with personal protection elements of the removal plan. Weststar stopped work in the affected areas until all cited problems were corrected. Also, through periodic testing of employee's blood lead levels, there were several cases when an employee's test results exceeded action levels. In these cases, the contractor was required to provide work for the employee in areas with no lead exposure until their test results returned to acceptable levels.

Air monitoring was conducted in the general work area, PSNS Controlled Industrial Area, during the course of the blasting operation. Results of the monitoring demonstrate the effectiveness of the containment system. The size of the containment system and the effects of adverse weather conditions necessitated the repair of tears to the system. Weststar'swork was suspended until repairs were completed. Additionally, potential releases of lead containing dust were prevented by negative pressurization of the containment system. Exhaust air was filtered using a high efficiency particulate filter. Because of the negative air pressure, if a tear occurred in the containment system, air was drawn into the enclosure instead of being able to escape to the surrounding environment.

If I can be of further assistance, please contact me at (360) 396-0043.

C. J. NAVIN

Captain
Civil Engineer Corps, USN
Commanding Offficer

Copy to:
OLA
NAVSEA (OOD)
NAVSHIPYD Puget Sound (00)
NAVFACENGCOM
SOUTHWESTNAVFACENGCOM