United States
        Environmental Protection
        Agency
United States
Occupational Safety and
Health Administration
EPA550-R-97-002
October 1997
        EPA/OSHA JOINT
        CHEMICAL
        ACCIDENT
        INVESTIGATION
        REPORT
        Napp Technologies, Inc.
        Lodi, New Jersey
EPA and OSHA
       ^Printed on recycled paper

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                      The EPA/OSHA Accident Investigation Program

       Under a  Memorandum  of Understanding,.  EPA and  OSHA have jointly assumed the
responsibilities to conduct chemical accident investigations. The fundamental  objective of the
EPA/OSHA chemical accident investigation program is to determine and report to the public the
facts, conditions, circumstances, and cause or probable cause of any chemical accident that results
in a fatality, serious injury, substantial property damage, or serious off-site impact, including a large
scale  evacuation  of the general public. The  ultimate goal of the accident -investigation is to determine
the root cause  in  order to reduce the likelihood  of recurrence, minimize  the  consequences associated
with accidental releases, and to make chemical production, processing, handling, and storage safer.
This report is an outgrowth of a joint EPA/OSHA investigation to describe the accident, determine
root causes and contributing factors, and identify findings and recommendations.

                 Basis of Decision to Investigate and for Involvement of EPA

       An explosion and fire took place at the Napp  Technologies facility at Lodi, New Jersey, on
April 21, 1995, resulting in deaths, injuries, public evacuations, and serious damage both on and off
site. The accident involved a commercial chemical mixture, a gold precipitating agent identified as
ACR 9031 GPA, owned by Technic  Inc. (Technic)  of Cranston, Rhode Island and comprised of
sodium hydrosulfite,  aluminum powder,  potassium carbonate and  benzaldehyde (hereinafter  "GPA").
EPA and OSHA undertook  an  investigation  of this accident because of the serious consequences and
the characteristics of the substances involved. This  investigation  was conducted in  conjunction  with
OSHA' s enforcement investigation.

       At the time  of the accident at  the Napp facility,  Napp  was performing a toll  blending
operation. Under  a toll  arrangement, a company  performs chemical manufacturing, blending,  or other
operations  for  other companies.  Those other companies may not have the equipment or capacity for
these  operations or may have other reasons  for outsourcing these tasks.  One of the purposes of this
investigation was to  identify hazards specific to the toll manufacturing industry that might lead to
chemical accidents, and develop recommendations to prevent  accidents and improve  safety in  the toll
manufacturing industry.

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                               Executive  Summary/Overview

        On April 21, 1995, at approximately 7:45 a.m., a violent explosion and fire occurred at the
Napp Technologies, Inc. (Napp) specialty chemical plant in Lodi, New Jersey.  Five employees of
Napp ultimately  died (four employees were fatally injured at the site, the fifth  employee  died several
days later due to injuries related to the event). A majority of the facility was destroyed as a result of
the  fire,  and other  businesses  near the  facility  were  destroyed or  significantly  damaged.
Approximately 300 residents in the area were  evacuated from their homes and a  school.  Additionally,
firefighting efforts generated chemically contaminated water that ran off into the streets and nearby
Saddle River.

       At the time of the explosion and fire, Napp was conducting a blending operation involving
water-reactive  chemicals.  The chemical mixing portion of the operation, which should have been
completed in less than an hour, continued for nearly 24 hours.  Operators noticed an  unexpected
reaction taking place in the blender, producing increasing heat and release of foul-smelling gas over
time.

       The joint chemical  accident  investigation  team (JCAIT) formed by  OSHA and  EPA
determined that the most likely cause of the  accident was the inadvertent introduction of water/heat
into water-reactive materials (aluminum powder and sodium hydrosulfite) during the mixing
operation. The water  caused  sodium hydrosulfite  in the blender to  decompose,  generating heat, sulfur
dioxide,  and additional water. The decomposition process, once started, was self-sustaining. The
reaction  generated sufficient heat to cause  the aluminum powder to rapidly react with the other
ingredients and generate more heat. During an emergency operation to off-load the blender of its
reacting contents, the material ignited and a deflagration occurred which resulted in the deaths of the
Napp employees and destruction of the facility.

       The JCAIT identified the following root causes and contributing factors of the event:

  •    An inadequate process hazards analysis was  conducted and appropriate preventive actions
       were not taken.. Napp's  process  hazard analysis identified the water reactivity  of the
       substances involved, but was inadequate to  identify and address other factors, including
       sources  of  water/heat,  mitigation measures, recognition of  deviations,  consequences  of
       failures of controls, and steps necessary to stop a reaction inside the blender. Consequently,
       appropriate prevention actions were  not taken.

  •    Standard operating  procedures and training were less than adequate.  Napp's  standard
       operating procedures (SOPs) and related training did not adequately address  emergency
       shutdown including  conditions  requiring  shutdown  and  assignment  of shutdown
       responsibility, and  operating limits, including the consequences of deviations, abnormal
       situations, and corrective steps required.

  •    The  decision to re-enter the facility and off-load the  blender was based on  inadequate
       information. Although Napp  was aware of, and concerned for, the strong possibility of a fire,

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       there was a lack of knowledge or understanding whether off-loading the  blender would have
       made the situation worse or the potential for violent deflagration.

  •     The  equipment  selected for the GPA blending process  was inappropriate. The  blender used
       by Napp for the process was inappropriate for the materials blended.

  •     Communications Between Napp and Technic were inadequate. Napp was carrying out a
       blending  operation  for another company. Inadequate communication of hazard information
       between the companies led to an inadequate process hazard review.

  •     The training of tire brigade members and emergency responders was inadequate.  Napp fire
       brigade members were not trained to respond to the type of emergency that occurred.

       The  JCAIT developed recommendations that address the root causes and contributing  factors
to prevent a  reoccurrence or similar event at other facilities:

  •     Facilities  need to fully  understand chemical and process  hazards,  failure modes and
       safeguards, deviations from normal and  their consequences,  and ensure that all relevant
       personnel know the proper actions to take to operate the process safely, recognize and
       address deviations, return to normal operations, or  safely shutdown. This is best achieved
       though process hazards analyses, standard operating procedures, and training;

  •    Guidance is needed to address the unique circumstances   surrounding  tolling  arrangements  and
      the responsibilities for hazards assessments and  communication  of  process safety information;

  •     Facilities should ensure that equipment manufacturers' recommendations  for proper  use of
       equipment are followed;

  •     OSHA and EPA  should review the lists of substances subject to the Process  Safety
       Management standard and Risk Management Program regulations to  determine whether
       reactive substances should be added;

  •     OSHA needs to review the role of MSDSs in conjunction with HazCom, HazWoper, and
       PSM Standards to clarify that MSDSs should not  be  used beyond their  intended design.
       Industry  should consider additional consensus standards or guidelines to address MSDS
       consistency and use; and

       OSHA and EPA should consider whether additional guidance or outreach  is needed for users
       to understand the limitations of MSDSs and industry awareness that more than the MSDS is
       needed to conduct full process hazards analyses.

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                                          -IV-

                                   Tabie of Contents
                                                                                 Page
1.0   Background	1

       1.1    Facility Information	I

       1.2    Process Information	3

       1.3    Chemical Information	   ... 5

2.0   Description of the Accident 	  -9

      2.1    Events Preceding the Blending Operation	9

      2.2    Preparations for Blending	9

      2.3    Blending Operation	   12

      2.4    The Explosion and Fire	  ... 15

      2.5    Emergency Response 	   ..16

      2.6    Napp Fire Brigade Members and Emergency Responders  	 17

3.0   Analyses and Significant Facts  	   18

      3.1    Analyses ...............	18

      3.2    Significant Facts	18

4.0   Causes of the Accident	21

      4.1    Possible Causes  of Chemical Reaction  	21

      4.2    Most Likely Causes of Chemical Reaction  	24

      4.3    Root Causes and Contributing Factors  	26

5.0   Recommendations   	   - - -	29

6.0   Outcomes of OSHA/Napp Technologies Settlement	32

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                                          -V-
                                      Appendices




A     Results of Analysis of the Accident  	34




B      Chemical  Reactions	37




C      Accidents Involving Sodium Hydrosulfite and Aluminum	41




D      References  	45




E      Photographs of Napp Technologies (Figures 4-24)	47






                              List of Figures and Exhibits




Figure  1      NappLayout  	2




Figure  2      P-K Blender	  4




Figure  3      IntensifierBar	6




Exhibit 1      Timeline of Events  	11




Figure  3A    Vacuum System	14

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  1.0     Background

         1.1     Facility Information

         The Napp Technologies, Inc. (Napp) facility in Lodi, New Jersey, was located on Main Street
  in a mixed  industrial/residential  section  of  Lodi. Napp shared a block with other businesses and was
  directly across the street from homes and retail businesses (see Figure 24).

         Operations

        Napp's  primary business is pharmaceutical manufacturing. However,  in  limited  cases, it  also
  performs  toll blending operations.  In a  tolling arrangement a company contracts  with another
  company  to perform a specific operation.  Typically, the company letting the toll contract lacks the
  equipment or capacity to manufacture the chemical product.  The raw material is  delivered to the toll
  manufacturer, who processes it according to customer specifications, and delivers it to the original
  company  for a fee or toll.

        At the time of the explosion, Napp was performing a blending operation to produce
  ACR 9031,  a gold precipitating agent (GPA) under a toll blending arrangement with  Technic Inc.
  (Technic)  of Cranston RI. Lacking the necessary equipment to  blend the ingredients, Technic entered
  into  a  contract with Napp whereby Technic  purchased the  components  of  GPA and had them
  delivered  to Napp to be blended.

        The Patterson-Kelley (PK) 125 blender used in the GPA blending operation was located in
 the PK-125 Blending Room, located in the Pulverizing and Blending Department on the South side
  of the facility, near the main warehouse area (see Figure 1).

        Facility Chemical Review Procedures

        Consistent with Napp's "New Product Review" standard operating procedure (SOP), new
 products that potentially will be used or manufactured at the  Napp Lodi facility are subject to an
 evaluation of employee health and safety, permit requirements, regulatory compliance (FDA, EPA,
 NJDEP, etc.), equipment  suitability, process  limitations  and product characteristics.  The New
 Process Review is an internal procedure in which management officials,  the  Regulatory Affairs
 Manager,  Chemical  Manufacturing  and Engineering Manager,  Operations  Director,  and Vice
 President of Regulatory and R&D participate.

        The  objective of the "New Product Review" procedure was  "to establish a uniform policy
for evaluating potential products before their use or manufacture on this site.  "

        The Regulatory Affairs Manager initially reviews the job request which may be rejected  due
 to regulatory concerns or company policies,  If accepted, the Regulatory Affairs Manager will

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                                  NAPP CHEMICALS. INC LAYOUT
    	MOLNA.R  Pl<.	
FIGURE 1

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 complete the New Product Review form assemble relevant documentation, and circulate the  package
 to other Napp management for further review.  As part of that management review, the Chemical
 Manufacturing and Engineering  Manager, the Operations Director, and the Vice President  of
 Regulatory  Affairs individually review (i.e., no concurrent team  review) the package for safety
 permitting,  and process requirements.  The last person to review the package returns  it to the
 Regulatory Affairs  Manager. Each  participant in the review indicates his approval or rejection of the
 proposal on the New Product Review Form.  All of the managers involved in the New Product
 Review approved of the processing of the GPA.

        According to Napp's accident report: "Material Safety Data Sheets and other information
provided by Technic formed the primary basis for this review. Instrumental in Napp's acceptance
 of the project was the Company's review of its prior successful processing of approximately the
 same volume of these materials in the same blender and the absence of any &closurefrom Technic
 o prior explosion, uncontrolled reactions or other accidents that had previously occurred during
 the blending of these materials. "

        1.2   Process  Information

        GPA Blending Process

        The GPA that Napp was blending is used to recover precious metals, such as gold, from
 aqueous cyanide solutions. The primary ingredients of the precipitating agent are aluminum powder
 and a  reducing agent, sodium  hydrosulfite.  The  precipitating  agent also contains potassium
 carbonate, an alkali metal, as an activator.  The ingredients were mixed in the following approximate
 proportions, by weight: 66% sodium hydrosulfite,  22% aluminum powder,  and 11% potassium
 carbonate.  A small amount (8 liters) of benzaldehyde was also to be added to the mixture for odor
 control.

        To prepare the GPA, according to patent information, the three powdered components are
 mixed prior to use.  The ingredients may  be mixed in  a  simple cone blender or other mixing device.
 The intended  blending time,  from the time  when all dry powders are charged until the time  of
 unloading, is approximately 45 minutes.

       Napp had once previously, in July 1992, blended a batch of ACR 9031 GPA for Technic, Inc.,
 in its PK-125 blender.  Before this operation, Napp technical personnel conducted a new product
 review.  No  formal record of this  review was  made,  although production records were retained  along
 with the Material Safety Data Sheet  (MSDS) for each of the components of the GPA. The  1995
 blending ingredients were virtually the  same as in 1992. The 1995 blending operation was intended
 to be the same as in 1992; however, because of operation deviations, the 1995 batch operation was
 significantly   different.

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TYPICAL PATTERSON-KELLEY  DRY SOLIDS BLENDER
      LOBE A
                                  LOBE B
                                          GEAR DRIVE/COVER
                    FIGURE 2

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                                              -5-

        Patterson-Kelley 125 Blender

        Figure 2 shows a typical Patterson-Kelley V-shaped blender. Patterson-Kelley builds each
 blender with options and features as specified by the  purchaser.  The blender at Napp had a working
 capacity of 6 cubic meters (125 cubic feet).  It was approximately 6 meters wide (19 feet), including
 supports, and 3 meters (10 feet) high.  The blender is a  double-lobed  stainless steel shell  shaped like
 a heart.  It is supported on its widest dimension by a horizontal trunnion attached to support tubes
 set in cement footings.  It is insulated with a rigid foam material and encased in a steel jacket
 containing a water/glycol mixture for cooling and heating.  The two access covers on top of the
 blender are used for loading raw materials, and one port is located at the bottom for off-loading
 product.  A gear to one side of the blender (right side of Figure 2) rotates the shell of the blender
 through a  360-degree arc.  Several water lines enter the jacket on this side. On the other side (left
 side of Figure 2) of the blender, a vacuum tube housing enters the blender.   A graphite seal located
 inside the vacuum tube separates the seal's cooling water from the internal area of the vacuum tube
 and the blender.  The purpose of the vacuum tube housing is to: (1) act as a conduit for establishing
 vacuum conditions when the blender is used for drying and other operations; and (2) contain other
 concentric lines,  shafts, etc., including a liquid feed line (added by Napp) and the shaft used to rotate
 an intensifier bar (I-bar).  The purpose of the I-bar is to enhance  the mixing of materials being
 blended.   The purpose of the feed line is to allow the  controlled introduction of liquids to the
 materials being blended. The PK-125 blender can be used with or without the I-bar in service.  The
 I-bar, Figure 3, transverses the  inner walls of the blender connecting the inner sides of the blender on
 the same plane as the trunnion.  See Figures 4-8 showing a larger but similar blender and associated
 equipment.

        1.3     Chemical Information

        The chemicals  involved in the explosion were sodium hydrosulfite, aluminum powder,
 potassium carbonate, and benzaldehyde. The properties and hazards of these  chemicals are discussed
 below.

        Sodium  Hydrosulfite

        Sodium  hydrosulfite (sodium dithionite), Na2S2O4, is  a  whitish,  crystalline solid, with
 moderately strong reducing properties.  It is principally used in dying and  bleaching operations.

       The National Fire Protection Association (NFPA) (NFPA 49, Hazardous Chemical Data.,
 1994) rates chemical hazards on a scale of 0 (lowest degree of hazard)  to 4 (highest degree of
hazard).  NFPA rates  sodium  hydrosulfite as 2  for  health  hazards  (moderate)  and  notes that
 combustion byproducts may  include sulfur  dioxide.  Sodium hydrosulfite is  rated  1 for flammability
and described as a combustible  solid. NFPA rates it as 2 for reactivity  and notes that exposure to
moisture  from humid air or small amounts  of water can result in  spontaneous chemical reactions that
may   generate  sufficient  heat to initiate  thermal  decomposition.   The U.S. Department  of
Transportation (DOT) lists sodium hydrosulfite (49 CFR Part 172) in Hazard Class 4.2

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                       INTENS1FIER  BAR/VACUUM HEAD ASSEMBLY
                                     SPRAY HEAD
  VACUUM TUBE ASSEMBLY
GRAPHITE SEAL
APPROXIMATE LOCATION
                    APPROXIMATE LOCATION
                    OF INTENSIFIER BAR
                    PACKING GLAND
                                           INTENSIFIER BAR
FIGURE  3

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                                            -7-

 (spontaneously  combustible material), Packing Group II. Packing Group II is assigned to materials
that  present  a  "medium degree of danger."   The shipping  label  "SPONTANEOUSLY
COMBUSTIBLE" is required for sodium hydrosulfite.

        Sodium hydrosulfite is unstable in the presence of water, heat or humid air, giving off sulfur
dioxide gas and other sulfur products in an exothermic reaction.  Once initiated, the decomposition
process of sodium hydrosulfite supports continued decomposition due to the generation of heat in
the exothermic  reaction.  Therefore, once the decomposition  has  been initiated, it cannot be
extinguished with smothering agents. To quench the decomposition, the temperature of the material
must be lowered below the decomposition temperature.

       The material  safety  data sheet (MSDS) for sodium hydrosulfite supplied by  Technic notes in
the event a container feels hot or begins to smoke it should be removed to an open area and "flood
with water."

       The decomposition temperature of sodium  hydrosulfite is identified on the MSDS as 130 C.
Under Reactivity Data, the material is described as "stable" although moisture and heat in excess of
50 C are identified as conditions  to avoid.

       Aluminum Powder

     Aluminum powder is light grey or silvery colored  Air dispersions (dust clouds) of aluminum
particles, when mixed in proper proportions and exposed to a small amount of ignition  energy,  will
burn with such rapidity that if contained an explosion may occur  Aluminum powder has a number
of uses related to its  flammability and explosivity when  dispersed  in air, including use in explosives,
propellants, and  pyrotechnics.  As a component of explosives, aluminum powder is used to increase
explosive  power.

       NFPA (NFPA 49, 1994)  rates aluminum  powder as 0 for health hazards, indicating health
hazards are minor. Under "Fire and Explosive Hazards," NFPA 49 describes aluminum powder as
a "[fjlammable solid if finely divided. Forms explosive mixtures in a dust cloud in air. Bulk dust
when damp with water may heat spontaneously. Hazard greater as fineness increases." The rating
for flammability hazard is 3, the rating that applies to liquids and solids that can be ignited under
almost all ambient temperatures.  Aluminum powder has a rating of 1 for reactivity hazards. DOT
lists aluminum powder, uncoated, on its Hazardous Materials Table in Hazard Class 4.3 (dangerous
when wet material), Packing  Group  II ("medium"  degree of danger). The shipping  label
"DANGEROUS WHEN WET" is required for uncoated aluminum powder.

       Sax's "Dangerous Properties of Industrial Materials" fifth edition, (page 352) indicates  that
aluminum powder is a moderate  explosion hazard when finely divided as dust and dispersed with
gaseous SO,, under appropriate conditions.

       Water will react with aluminum dust to produce hydrogen gas,  especially under  alkaline
conditions.  Aluminum is normally  protected by an  oxide coating, but the coating  is  readily dissolved

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by alkaline agents such as bicarbonate.  Once the oxide coating is removed, the aluminum becomes
very reactive.  The oxide coating normally reforms rapidly and exothermically on contact with air.
The  uncoated condition is ideal for aluminum to  become pyrophoric, i.e., burst  into  fire spontaneously
under appropriate conditions.
       The MSDS for aluminum powder, uncoated (atomized), as written by Valimet, Inc., and
supplied by Technic to Napp states:

       Under Section IV: Fire and Explosive Data:
               "Special Fire Fighting Procedures: Avoid water"

       Under Section VI: Reactivity Data:
               "Incompatibility (Materials to Avoid):  Water, acids, alkalis.
             Hazardous Decomposition Products: Exothermic reaction with water, acids,  alkalis
              to generate  hydrogen and heat."

       Benzaldehyde

       Benzaldehyde  is a colorless liquid. Benzaldehyde readily oxidizes to benzoic  acid.  To prevent
contact with air, an inert gas blanket over the material is required.

       Benzoic acid is a white crystalline material. When benzoic acid is heated above its melting
point, some formation of benzoic anhydride and  water takes place. When heated above 370C, it
decomposes to benzene and carbon dioxide, with small amount decomposing to phenol and carbon
monoxide.

       Potassium Carbonate

       Potassium carbonate is usually in the form of white crystalline granules.  Because of its
alkaline chemical nature, it is commonly used to raise the pH of mixtures and solutions.  Potassium
carbonate has some  acute health hazards (irritant to all body tissue, possibly leading to tissue
destruction), giving it an NFPA health hazard rating of 2.  NFPA fire and reactivity ratings for the
material are 0, indicating that it is a stable compound.

       Gold Precipitating Agent

       The MSDS for the gold precipitating agent supplied by Technic, Inc. notes:

       "Flammability Data: Contact with small  amounts  of water or humid atmosphere will  cause
                            a chemical reaction.   The heat generated from  this reaction is
                            sufficient enough to ignite  combustible material. .  . Flood the
                            material with water to ensure complete wetting, as this procedure will
                            control the auto-ignition of the material.

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                                            -9-

       Extinguishing Media: Water spray should be used to extinguish fire

       Usual Fire Fighting Procedures:  Use water to keep fire exposed containers cool."

       Unusual tire righting techniques are asserted not to be applicable. Hazardous  decomposition
products specified are limited to oxides of sulfur, carbon dioxide and carbon monoxide.
Incompatibles identified by Technic are limited to "oxidizing agents or materials, strong acids and
moisture.

2.0    Description of the Accident

       2.1    Events Preceding the Blending Operation

       In January of 1995, Technic contacted Napp to inquire about the timing of an order of GPA.
In February 1995, Napp informed  Technic that the next available date to make  GPA would be March
23, 1995. In preparation for that job, Napp decided to perform a new product review. The
Regulatory Affairs Manager, Chemical  Manufacturing and Engineering Manager, Operations
Director, and the Vice President for Regulatory and R&D participated in the review which included
the evaluation of the processing information available from 1992, the MSDS  prepared  by Technic for
its GPA, the MSDSs of the components of the mix, as well as other information.   They noted the
water-reactive nature of the components of the GPA

       In March of 1995, in preparation for the blending of one batch of GPA, Technic began
procurement of the various raw materials and made arrangements for their shipment to Napp.  A
slight, delay in the scheduled blending of the GPA pushed the production date into April.  On April
7, Technic sent Napp a  purchase order, a duplicate of the GPA MSDS already in Napp's possession,
and a sign-off by Technic's Director of Operations on the formulation sheet (batch recipe ticket)
indicating that it was "OK to blend." The delivery  of materials to Lodi commenced in March and was
completed with the delivery of aluminum powder on or about April 4,  1995.  The  components of the
blend included 1,800 pounds of  powdered aluminum 900 pounds of potassium carbonate, 5,400
pounds of sodium hydrosulfite, and eight liters of benzaldehyde.  The blended GPA was to be
packaged into 18 plastic-lined 55-gallon drums, supplied by Technic.

       2.2    Preparations for  Blending

       Preparations for the processing to be performed commenced on Monday, April 17,  1995 when
the PK-125 blender was rinsed with deionized water. Thereafter, the rinsewater was  discharged. The
intensifier bar was removed from  the vessel, dismantled by mechanics, and cleaned.

       The maintenance foreman instructed a maintenance employee to remove and change the
packing gland associated with the  intensifier bar on the PK-125 blender.  This  activity was standard
procedure whenever there was a scheduled  product change for one of the Napp P-K blenders.  After
removing the old packing gland and its housing, the maintenance employee observed water next to
a bearing. Based on this observation, the maintenance foreman instructed the maintenance employee

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                                             -10-

to drain the water out of the area, replace the packing,  and seal the blender.  As part of the procedure
to check the integrity of the seal and packing gland, the maintenance employee ran the blender and
its intensifier bar for 15 minutes and visually inspected the interior of the blender to assure that the
water-cooled seal  and packing  gland  were  not leaking. The mechanic found no evidence of leakage.

       The blender was given a final rinse, and the rinsate was checked for the presence of
contamination.  Quality  Control personnel "released" the blender  and the room in which it was housed
to Operations personnel and the cleaning log was signed signifying completion of the cleaning
process, approving both for use in preparing the next product, the GPA.

       On April  19, prior to charging the materials,  the first shift supervisor conducted a  process
review with operators on duty.  It was a Standard Operating Procedure that any operator engaged
in materials processing must complete a detailed review with the shift supervisor of the process and
its hazards  prior to  commencing  work. The review, which typically  takes 45 minutes to an hour, was
done for each  operator involved in the Technic  process,  and included a discussion  and review  of the
equipment set-up, the steps to be undertaken in the process, and a complete review of the MSDSs
for GPA and each component of the  mixture. The shift supervisor and two operators found  a minor
water leak from a water pipe in the back of the PK-125 room (not associated with the blender). The
shift supervisor stopped the leak, dried up any water that remained, and covered the floor drains in
the room to prevent contact of GPA with water in the sewer system in the event of a spill.   A sign
informing workers that water reactive chemicals  were being processed in  the PK-125 room was
placed at the entry to the room.

       At approximately  10:30 p.m. on April  19, the shift supervisor conducted a process review
with the night shift crew. Exhibit 1 shows the timeline of events beginning  at this point

       The process review with  the operators concluded at approximately  11:15 p.m. The operators
and leadmen then pre-weighed the GPA components, placing the unopened drums of sodium
hydrosulfite and aluminum powder and bags of potassium carbonate on a digital scale and recorded
the weight of the material  and its  container on a  log. In the  course of this activity, it was  discovered
that one of the bags of potassium carbonate had been broken and taped over and it weighed less than
the others.  To assure proper proportions for the GPA, a calculation was performed and the  volume
of the other raw materials was adjusted for the batch  to be mixed.

       At 3:30 am. on  April 20, as part of the  precharging  verification,  operators made  a final  check
to assure the blender  was  ready (i.e., clean and dry) to be loaded. The two operators and a foreman
discovered that the vacuum head area, inside the  blender, was wet.  They also observed water on the
internal walls of the blender. Another employee saw a wet spot also described as "droplets of water
on the stainless steel" at the intensifier bar shaft seal  (connection).  They believed this moisture was

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                                                                             -11-
                                                                     Exhibit  1
                                                            Timeline  of  Events
                                             April  21,  1995  Explosion  of  Blender
                                            at  Napp Technologies, Inc. -  Lodi,  NJ
 April 19,10:30 pm
    April 20,3:30 am
Shift supervisor
conducts process
review


Two operators
dry blender of
drops or moisture
on top of Intenelfler
bar assembly.
Vessel dry before
loading


Operators Inert
blender and start
loading
components of
GPA


New shift
operators arrive,
given a process
hazard review by
supervisor. They
recommence
loading of the
blender at
approximately
8:00am


Operators smelted
"vanilla-like" odor
and observed
water In liquid
feed tank, line, and
filter


Operators
removed water
from liquid feed
system except
portion Inside
blender. Replaced
In-line filter


Operators began
adding
Benzaldehyde
through liquid
feed line. Flow
rate was low -
most found
In vacuum line
separator bowl
Operators
Informed shift
supervisor of
problem
Operator reports
"rotten eggs" odor
from residue In
drums
Hatchway to
blender open,
operators
continue Nitrogen
purge
While
troubleshooting
feed line system.
maintenance
person eplaahed
with "slinky"
liquid, which
causes minor
chemical burns
Another
maintenance
person took over
and cleaned
liquid feed line
and noted "awful"
smell from liquid
In separator bowl
Maintenance
person Informs
shift supervisor of
smells and
finishes Installing
vacuum line.
Hatchway closed
                                                                                                                             April 21, 4:30 am
Operators
attempted, but
failed to add
Benzaldehyde
twice. During each
attempt, the
Intenslfier bar Is
running
Reportedly at 4:30,
shift supervisor
notes bubbling on
mixture surface
With no more
Benzaldehyde,
blender Is locked
and tagged out.
Pressure gauge
on blender
replaced with
open nipple
and Nitrogen purge
rate Increased
Vice President for
Regulatory Affairs
directs shift
supervisor to
unload the
blender ASAP
3rd shift
supervisor, several
employees, and
Members of Napp
Fire Brigade enter
building to begin
to unload blender
                     Blender and two
                     10-ton footings
                     propelled SO feet
                     5 employees
                     killed; 4
                     employees Injured;
                     area evacuated;
                     Fluorescein In
                     flrefightlng runoff
                     into Saddle River
                     and sanitary
                     sewars
                     Fire extinguished
                     by firemen
                                                                                                                                                 April 22, 8:30 pm
                     Residents allowed
                     to return
                                                                                                                                                        C78018-1-3

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                                             -12-

 caused by condensation.

        Knowing that water reactive materials were to be loaded into the blender, the night shift
 foreman directed an operator to wipe off the portions where moisture was found.  The blender was
 then heated using the water-glycol jacket on the PK-125 to further dry the interior surfaces.  The
 blender was allowed to cool and was checked to ensure it was ready to be charged with the raw
 materials and found to be dry.

        2.3    Blending  Operation

        Prior to the  commencement of loading operations, the operators implemented a standard
 operating procedure that  required  that a  vacuum  twice be created within  the blender and then broken
 with inert nitrogen gas.   Thereafter, a slight nitrogen pressure was maintained to assure inert
 conditions  within the blender.  At approximately 5:00 a.m. on April 20, operators began to load the
 components of the GPA into the blender, but did not finish the work.  At 6:00 a.m., a shift change
 occurred, and the first-shift day crew arrived to continue blending operations.

        A process review of the GPA blend had been conducted for the new operators, and the
 hazardous nature of the raw materials was discussed. At approximately 8:00 a.m., the first shift
 operators recommenced loading of the blender alternating proportionately from one component to
 the next as had the previous operators. Because  loading occurred only through one port of the "V-
 shaped blender, and to  distribute the materials evenly across the blender, the intensifier bar was
 rotated  briefly.  The loading of the blender concluded at approximately 11:00  to  11:30 am. Thursday
 morning. During the final charging, the blender was rotated to level (settle) the powders to allow all
 of the  material to be  loaded.  An operator noted that the charge was not dusty when the blender was
 opened for the final addition.  After charging was complete, the level of the powdered components
 completely covered the intensifier  bar and was almost up  to the middle of the vacuum head.
 Thereafter, the operators commenced the blending operation according to Napp's procedure, which
 called for blending the dry  powders as follows: rotate the blender for ten  minutes without the
 intensifier bar, five minutes  with the intensifier bar; and ten minutes again without the intensifier bar.
 The dry blending was completed by mid-day.

        The operators then made preparations to spray charge  the benzaldehyde, a procedure
 requiring the use of a separate liquid feed tank connected by hoses to a spray nozzle atop the vacuum
 head within the blender. Operators noted a "vanilla-like" odor  from a liquid feed  tank for the blender,
 and water was observed  inside the tank. Additionally, the operators found water in an internal filter
 located on the liquid, feed line near the point of entry  into the blender. However, because the
 components of the GPA, with the exception of the benzaldehyde, were already in the blender, the
 portion of the feed spray line  located inside the blender could not be cleaned without contaminating
the materials in the blender.  The operators did not consider the liquid feed line to be functioning
 properly. The liquid spray head and spray system had not been completely dried prior to the charging
 of the  blender. The operators placed a gallon of  isopropyl alcohol (IPA) into the  liquid feed tank and
blew inert nitrogen through the tanks and lines into  a bucket forcing the IPA through the system, with
the exception of that portion  of the line entering the blender  and  terminating at the spray nozzle.

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                                            -13-

 They then blew nitrogen through the liquid feed system for 45 minutes to one hour to make certain
 the feed tank and lines were dry.

        At approximately 2:30 p.m., the operators  attempted to charge the benzaldehyde into the
 blender. In doing so, the operators placed the benzaldehyde in the liquid feed tank, charged the tank
 with nitrogen pressure, commenced rotation of the blender and intensifier bar, and relieved the
 pressure into the blender. The operators noted the feed rate was unusually low, and upon inspection,
 they noticed that most of the benzaldehyde had ended up in a vacuum line separator bowl and not in
 the blender (Figure 3A). Upon consideration of the failure of the  liquid feed system to correctly spray
 the benzaldehyde into the blender, it  was determined to examine the compression fitting to the liquid
 feed line to see if it was leaking.

        An operator noted that the liquid in the bowl had a few drops of water or IPA on top of the
 benzaldehyde. No further analysis was performed on the liquid.

        At 7:00 p.m. an employee entered the PK-125 room and  smelled an odor described as "rotten
 eggs." The employee observed 18 drums which previously contained the raw materials. These drums
 sat uncovered.. Assuming the residue inside the drums was the cause of the odor, he put the tops
 back on the drums.

        At 7:30 pm., a maintenance employee was instructed to troubleshoot the liquid feed system
 line.  When the employee  attempted to open the vacuum line to gain access to the feed line the
 employee  was  splashed with a "stinky" liquid.  The  maintenance employee  received  minor chemical
 bums and went to the locker room to wash off the chemical.

       Between 7:30 and 10:00 p.m., one hatchway on the PK-125 blender remained open to the
 atmosphere. During this period the operators continued to  run a nitrogen purge through the vacuum
 line into the blender so as to maintain an inert blanket in the head space of the blender.

       At approximately 10:00 p.m., another maintenance employee completed the disassembly of
the exterior portion of the vacuum line and took it to another room, where it was washed and dried.
When the  employee returned to the PK-125 room the employee smelled an odor that he described
 as a "dead animal" smell upon initially entering the  PK-125 room. This employee also observed and
 smelled the liquid from the separator bowl which had been collected in a beaker.   The employee
 described the smell as "awful."  The maintenance employee cleaned up  the liquid which had earlier
 spilled  on  the floor.  By this  time, it had been almost ten hours since the ingredients were  placed into
the blender (the blending should have taken not more than one hour to complete).

       At 10:00 p.m., the maintenance employee informed the shift supervisor about the unusual
 odors in the PK-125 room.  The maintenance employee finished reinstalling the vacuum line to the
blender, and the shift supervisor went to the lab to obtain more benzaldehyde to inject into the blend.

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                         -14-
FIGURE 3A: TYPICAL VACUUM COLLECTION SYSTEM As SUPPLIED
BY PATTERSON-KELLEY. # 1 SHOWS APPROXIMATE LOCATION OF
INLET FROM BLENDER VACUUM LINE; # 2 SHOWS VACUUM
SEPARATOR BOWL.

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                                            -15-

        Between midnight and 4:30 a.m. on April 21, 1995, the third shift attempted to inject
benzaldehyde into the batch on two occasions; each attempt failed. Operators observed the
benzaldehyde running back into the vacuum separator. During each attempt to add the liquid, the
blender was rotated for about two minutes with the intensifier bar running.  Suspecting that product
was blocking the spray tip of the nozzle and preventing the injection of the liquid, operators opened
the blender twice and  removed and washed the spray nozzle.  Operators reportedly  observed a slight
dusty powder wafting  within the head space of the  blender. This was reported to the shift supervisor,
who then  checked the  inside of the blender and directed the operators to remove and clean  the nozzle.
After the final attempt to charge benzaldehyde  into the vessel it was determined that no fresh
benzaldehyde remained. It was by then approximately 5:00 a.m. and coming to the end of the third
shift. The shift  supervisor told the operators to perform a lock and tagout of the blender.

        The shift supervisor noted that a pressure gauge on the blender was reading five pounds per
square inch (psi). Inasmuch  as the blend was to take place under atmospheric  conditions, in a blender
designed for non-pressurized service, concern arose that the rise in pressure could result in the two
charging ports being blown  out of the blender. Because there was a continuous flow of nitrogen into
the blender, the pressure gauge was replaced with an open nipple, and the pressure was released into
the PK-125 room. The nitrogen purge  rate was then increased.

        The shift supervisor reportedly  observed an area of about 8 inches in diameter bubbling and
smoking on the surface of the material inside the blender.

        2.4    The Explosion and Fire

        As employees  arrived at the plant for the morning shift on April 21, they noticed a rotten egg
odor.  At  approximately 5:30 a.m. the operators of the blender had observed puffs of white smoke
coming from the exhaust nipple affixed to the PK-125. By 6:00 a.m. employees on the first shift had
reported to their assembly  areas. Nearly all Napp employees smelled the odor of rotten eggs, which
by then had escaped the building and was noticeable in the parking lot behind the plant.   At
approximately 6:15 a.m. the plant was evacuated,  through verbal instructions; no audible alarms were
ever activated at the facility.

       At about the same time, there was a discussion about whether the GPA should be unloaded
from the blender. At approximately 6:30 a.m., the third shift supervisor placed a call to the Vice
President for Regulatory Affairs (VPRA) and advised him of the situation.  After asking a series of
questions for more information, in a subsequent phone conversation at approximately 6:45 a.m., the
VPRA directed the shift Supervisor to discharge the batch  "ASAP." The VPRA suggested tumbling
the blender with  cooling medium (glycol)  circulating in the  water jacket.  The shift  supervisor stated
that he did not want to rotate  the blender because that would, require  capping the exhaust  nipple that
had been installed to relieve the pressure buildup inside the blender.  The  VPRA directed the shift
supervisor to maintain the nitrogen purge into the blender. Additional phone calls were also made
from the plant to other Napp management personnel.

       During discussions regarding unloading of the blender and upon review of the GPA MSDS,

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                                            -16-

 it was suggested that a fire hose would be strung out to the PK-125 room but not charged in order
 to prevent accidental discharge of water. Later, an additional hose was made available.

       At approximately 7:00 am, the third  shift supervisor went outside and approached the plant
 employees who had been evacuated to the rear parking lot.  Several employees, including the first
 shift supervisor, returned to the blending room with him to assist with the unloading of the blender.
 Other employees, who were members of the Napp Fire Brigade, reentered the plant to stand by with
 fire hoses at the ready, but were instructed by the Production Manager not to  charge them with water
 unless they were told to do so by another employee who would be  closely watching the unloading
 operation.  The maintenance supervisor stood in a doorway that led from the blending room to a
 hallway from which he could see both the unloading activities and the fire brigade member standing
 by awaiting a signal to charge the fire hose.

       At approximately 7:47 a.m., three loud hissing noises were heard in succession.  The noises
 were closely followed by a "whoosh"  sound, then the explosion.   The blender and its two 10-ton
 concrete footings were  propelled in a westerly direction for a distance of approximately fifty feet. An
 employee standing by stated that he heard hissing noises, looked inside the blending room, and saw
 the other workers in animated activity.  He turned to run, saw two bright flashes of what reminded
 him  of lightning, and saw a yellow-orange ball of flame "like a snake's tongue" leap out of the room
 toward him.  He was blown  along the length of the corridor and  out  a passage door; he survived with
 minor injuries.

       Four of the five employees in the PK-125 blending room were killed in the explosion and
 ensuing fire,  and the fifth employee died of bums a week later.  Four other employees escaped with
 minor injuries.

       2.5    Emergency Response

       At the sound of the explosion, Lodi police, fire, and EMS responded to the scene within
 minutes. Information concerning  the  chemicals stored at the facility was promptly made available to
 responders.    Nine persons injured in the explosion were transported to a local hospital.
 Approximately  300 residents in the vicinity were evacuated from their homes, as well as a  nearby
 elementary  school.

       Other  responding agencies included EPA,  OSHA, United States  Coast Guard, Federal Bureau
 of Investigation, NJ Department of Environmental Protection (NJDEP),  NJ State Police Office of
 Emergency Management, Bergen and Passaic County Health Departments, Bergen County
 Prosecutor's Office and the  Arson Squad. Hundreds of volunteer fire and ambulance personnel also
 responded, as did more than 20 other municipal police.

       Continuous air  monitoring was conducted by seven NJDEP teams for the duration of the fire.
Downwind monitoring was conducted by NJDEP, Bergen and Passaic County Health Departments.

       Observable during the firefighting response was a discharge of the chemical fluorescein, a

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                                            -17-

bright green dye, which was stored at the Napp facility. Fluorescein-contaminated  firefighting runoff
water entered the Saddle River through the storm drains and by direct overland flow.  Fluorescein-
contaminated runoff also entered the sanitary sewer line feeding the sewage treatment plant.  The
Passaic  Valley Sewage  Commission was notified  of the release. Napp Technologies hired a cleanup
contractor to contain firefighting runoff.   Evidence  of firefighting runoff was  seen in the  Saddle River
in the form of a bright green discoloration for two  miles downstream to its confluence with the
Passaic River.

       A USEPA mobile laboratory vehicle was used to acquire downwind air samples of
inorganic/acid gases, organic, and ketones.  In addition, water samples were obtained at seven
locations for off-site analysis. Water samples were analyzed for volatile organic compounds, base-
neutral-acids, metals, pesticides, and PCBs.

       Fish kills were confined to the Saddle River, for approximately 2 miles downstream to the
confluence with the Passaic River. No fish kills were observed  in the Passaic River. The residential
evacuation order for Lodi and the surrounding communities was lifted on April 22 at 8:30 p.m.

       2.6  Napp Fire Brigade Members and  Emergency Responders

       Among the Napp employees involved in the  attempt to remove the GPA from the blender
were several who were members of the Napp fire brigade and had been trained in incipient fire
fighting techniques.

       Napp fire brigade members and other Napp emergency responders were directed by
management to respond to the ongoing chemical emergency. Nine  of the  twelve employees  who  were
inside the building immediately preceding the explosion (during the unloading of the GPA) were also
members of the Napp tire brigade. Training records revealed that some employees were given a
lecture on chemical fires, but no formal training was  conducted related to fighting chemical fires or
emergencies.  A course on hazardous materials was presented to the tire brigade in November 1993,
but the records note that none of five listed managers, including three of the deceased employees,
attended the  session.  The same training records indicate that four of the five managers  failed to
attend six  fire brigade training sessions in  1993 (the fifth manager attended  one session), and  the same
individuals failed to attend similar training courses, including one on hazardous materials and one on
emergency response in 1994. In 1995 the same individuals missed three fire brigade training sessions,
including one on fire  behavior given 10 days prior to  the explosion. The Napp Plant Safety Standard
for  Fire Protection  Organization specifically defines the function  of the Plant  Fire  Brigade as,  among
other things, to  "answer all fire calls." It also states  that the "intent of the  Brigade  is to fight incipient
stage fires  only." It further  states that "The Brigade  will perform a contain and hold function on  any
major interior structural fire until the Lodi Fire Department arrives."

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                                             -18-

 3.0     Analyses and Significant Facts

       3.1     Analyses

        After the  accident, investigators analyzed the chemical residues  in the blender and the  remains
 of the blender itself These analyses  are discussed in  detail in Appendix A. Appendix A also includes
 information on the injuries suffered by the victims of the explosion.

        The chemical analysis showed the presence of sodium, potassium, and aluminum, consistent
 with the blender contents. Phenol and methylphenol compounds were also found in large amounts.
 These compounds were probably  due to the insulating material remnants which were originally
 located in the annulus between the outer wall of the blender and the outer wall of the water-glycol
jacket.  These compounds could also be derivatives of the benzaldehyde that was added to the blender
 contents.

        The analysis of the remains of the blender showed extensive erosion damage in parts of the
 interior and around several openings.  Ejection of heated  material from the inside of the blender is the
 likely cause of the erosion. The blender also showed extensive damage attributed to impact when the
 blender  was propelled about 40 feet due  to the explosion. The investigators looked in particular for
 possible damaged areas where water could have entered the blender. Metallurgical examination of
 the water-cooled graphite seal for the vacuum tube showed grooves that could have allowed water
 to leak into the blender.

       Evaluation of injuries suffered by the victims indicate that the explosion at the Napp facility
 was a deflagration rather than a detonation.  A deflagration releases  energy at a lower rate, generates
 lower over-pressures, and is less  destructive than a detonation.

       3.2     Significant Facts

       Other facts considered by the accident investigation team in determining the causes  of the
 accident are listed below.

       Napp's Analysis of Hazards of Blending Operation

       The GPA was blended on one previous occasion by Napp in July 1992, using the same PK-
        125 blender.   The manufacturer of the blender states that the blender is not designed to mix
       water  reactive substances.

       Technic provided Napp with MSDSs  for components  of the GPA and an MSDS for the GPA.

       The MSDSs noted that aluminum and sodium hydrosulfite are water reactive.

       The MSDS for the GPA recommends "flooding with water" to control auto-ignition  of the
       material.

-------
                                            -19-
 •      Napp's "new product review" procedure was conducted primarily based on information
        included in the MSDSs.  Review was conducted individually (i.e., not by a team) by four
        managers of Napp to determine equipment suitability and health and safety concerns.

 •      Napp management was aware of the water reactivity of the materials in the blending
        operation.

        Sources of Water and Heat

        Literature review and a limited laboratory study of the hazards of the GPA mixture revealed
 that small quantities of water were capable of inducing a runaway reaction at relatively low
 temperatures.  Further, the presence of aluminum powder in the mixture provided a substantial
 increase in the amount of heat released during decomposition (see Appendix B).

        The following were possible sources of water and heat in or around the blender at the time
 of the accident, which were evaluated by the JCAIT as potential initiators of the event.

 *       The seal of the intensifier bar was water-cooled.

 *       Water was  observed on internal surfaces of the blender prior to charging; a drying procedure
        was subsequently performed.

 "       Water was used to clean the blender.

 •       Water was noted in the liquid feed tank and feed line filter just before the  feed line entered
        blender.

 "       The coolant in the blender jacket was a water/glycol mixture.

 *       Water was  seen in the packing gland area/bearings of blender prior  to the blending  operation.

 •       Although the blender was blanketed with nitrogen, the ports were opened and atmospheric
        humidity could have been a source of water.

 "       The intensifier bar moving at a high speed through dry powders my have been a  source of
        frictional heat.

*       Particulate matter between bearing surfaces at the intensifier bar shaft in the packing gland
        area may have been a source of frictional heat.

        Deviations from Napp's Expected Maintenance and Operating Procedures

«       During a routine maintenance procedure, water was noted between a packing gland and

-------
                                     -20-

 bearings  inside the  PK-125 blender. Because this location was inside the vacuum section of
 the intensifier  bar, no water should have been present. The water was dried and the gland re-
 packed.

 At3:30 a.m. on April 20, two operators and a foreman found that the vacuum head area
 inside the PK-125 blender was "wet." Water (droplets) was observed on the intensifier bar
 shaft connection as well as on the  inside walls of the blender.  The moisture was removed and
 the blender dried.

 The quantities of the ingredients were recalculated because Napp lacked the proper amount
 of potassium carbonate.

 Operators noted that the level of dry ingredients was above the level of the intensifier bar and
 up to  the middle of the vacuum head.  According to Patterson-Kelley, the level should be no
 higher than the middle of the intensifier bar.

 At 10:00 a.m.  on April 20, operators detected a vanilla-like odor in the liquid feed tank  (used
 to contain liquids prior to injection into the blender).

 Water was observed in the liquid feed tank and its filter system.  All parts of the injection
 system external to the blender were cleaned and dried. Because  the powdered ingredients
 were already in the blender, the components of the injection system inside the blender could
 not be cleaned or dried without contaminating the charged material.

 At 2:30 p.m.  on April 20, operators were unable to inject benzaldehyde, the sole liquid
 component of GPA, into the blender. For approximately 14 hours, operators attempted to
 clear the liquid feed line and re-inject the benzaldehyde, while intermittently operating the
 intensifier bar  and rotating the blender. The intensifier bar was used far longer than specified
 in the Napp procedure, in order to properly blend material.

 At 7:00 p.m. on April 20, an operator smelled a "rotten egg" odor inside the PK-125 room.
 The operator assumed it was from open drums which originally contained the raw materials
 which had been charged into the blender.

 Two distinct liquids, assumed by Napp employees to be benzaldehyde and drops of water or
 IPA, were seen in the vacuum  separator bowl. No analysis to determine the components  of
the liquid was performed.

 At 9:30 p.m. on April 20, a maintenance employee noted an unpleasant odor inside the PK-
 125 room.

By 4:30 a.m. on April 21, bubbling was reportedly observed on the surface of the materials
in the blender.

-------
                                            -21-

•       At approximately 6:00 a.m. on April 21, workers were verbally notified to leave the building.
        Arriving day shift employees were directed to remain in the rear parking lot of the building.

        Conditions at the Time of Employee Reentry to Unload Blender

»       Bubbling (in  an  area approximately eight inches in diameter) and smoking were noted on the
        surface of the material inside the blender approximately three hours earlier.

»       The blending operation is normally conducted at atmospheric pressure. However, an exhaust
        nipple was relieving pressure Tom the nitrogen blanket and off-gas products of the batch from
        within the blender. Blender could not be tumbled and cooled due to the open vent.

*       A strong sulfur smell was noted in the blending area.

•       With the exception of 12 employees  which were directed to assist in the off-loading of the
        blender, the facility  remained evacuated.

        Lack of Notification  of Local Community Immediately Preceding; Accident

«       Napp solely used verbal notifications  to  evacuate the building.  Use of an internal alarm would
        have automatically notified local emergency responders.

*       During the attempt to remove the contents of the blender, Napp did not charge fire hoses that
        were laid out  and held by Napp  employees in case of ignition.  The fire water system included
        a device that would  automatically notify local fire officials if a pre-set flow rate was met.
        Since the  system was not  utilized, no  alarm was initiated.

»       The Napp facility was located in a residential area,  with homes  and  other businesses  nearby.
        Napp did not provide any warning to  local  community of an on-going chemical emergency.

4.0     Causes of the Accident

        4.1    Possible Causes of a Chemical Reaction

        The reports of unusual odors in  the blending  room and building, bubbling and  smoking noted
on the surface of the  material in the blender, and pressure buildup in the blender all suggest that the
explosion and fire were triggered by an unwanted and uncontrolled chemical reaction occurring in
the blender.

        The GPA was successfully blended by Napp and other companies without incident on several
occasions prior  to this accident.  Based  on this history and an evaluation of the chemical components
of the GPA, the JCAIT believes the raw materials by themselves will not normally react with each
other in the absence of an  outside initiator such as water and/or heat. The JCAIT eliminated outside
sources, including sabotage and "Acts of God," as possible causes, as there was no evidence to

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                                            -22-
support these possibilities.
        The predominant reactions taking place most likely were:
        The exothermic reaction of sodium hydrosulfite with water;
 *
        The exothermic reaction of aluminum powder with water;
 *
        The exothermic thermal decomposition of sodium hydrosulfite, which would have been
 *       initiated by heat from the exothermic reactions with water;  and
        The exothermic oxidation of hot aluminum powder, which would have been initiated when
 *       air contacted the blender contents.
 The oxidation  of hot aluminum  powder  could have resulted  in a deflagration. The chemical reactions
 of sodium hydrosulfite, aluminum, and benzaldehyde are discussed in detail in Appendix B. Brief
 descriptions of other accidents in the past involving sodium hydrosulfite or  involving aluminum
 powder are presented in Appendix C.
        Reaction Initiation
        Based upon the nature of the chemicals in the blender at the time of the accident, and the
 circumstances of the accident, the JCAIT investigated possible sources of water and heat as the
 initiator of the reaction. The following table identifies the possible sources of heat and water in the
 blender system. These sources are discussed in more detail following the table.

           Initiator                               Possible Source
        Water                  Water used to clean blender/inadequate drying
        Water                  Water used to clean liquid feed line
        Water                  Leak of coolant from blender jacket
        Water                  Moisture from raw materials
        Water                  Water in nitrogen
        Water                  Atmospheric humidity entering blender
        Water                  Water in liquid feed tank
        Water                  Water-cooled seal failure
        Heat                   Shear from intensifier bar through dry powder solids     I
        Heat                   Particulate material in internal bearings of blender

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                                             -23-
        Based upon eyewitness testimony, the reaction seemed to be localized (as a hot spot) rather
 than a generalized reaction  of the materials  in the blender.  The eight-inch wide bubbling  area noted
 in the Description of the Accident also suggests that the hot spot was more near the center of the
 blended material rather than along the sides of the blender.  The JCAJT therefore considered the
 various sources of water/heat, as discussed below, to determine which  ones would likely have led to
 a reaction in the location observed.

        Inadequate drying of blender before use. Water was used to clean the inside of the blender
 before it was used. If water remained in the blender, it would have reacted with the raw materials.
 However, before the raw materials were added, water found in blender was drained and fully dried.
 While the bubbling noted towards the middle of the blender reveals that the reactions did not take
 place at the walls of the blender (where any moisture would have been located prior to use), it is
 likely that any moisture in the blender before it was  used would have been distributed throughout the
 batch.

        Leak of coolant from blender jacket into the raw materials. A water/glycol mixture is used
 in the outer jacket of the  blender to cool  or heat the blender.  A breach in the integrity of the blender
 wall could have allowed the water/glycol mixture to migrate from the jacket into the contents of the
 blender.  The JCAIT conducted  metallurgical analysis  of the blender after the accident. This analysis
 revealed one crack near the off-loading port; however, the crack was considered to be from  impact
 damage. (See Appendix A for  additional details.)

       Moisture from raw materials. Moisture present in any of the raw materials could  have been
 sufficient to initiate a reaction.  However, no signs of reactions (odors, heat) were detected by the
 operators charging the blender with raw materials. Also, Napp performed a quality assurance check
 on the raw materials,  and no moisture was  noted.

       Moisture in nitrogen. Nitrogen was used throughout the blending process  to inert the
 headspace in the blender and to  prevent atmospheric  moisture  from reacting with the materials  in the
 blender  Any moisture in the nitrogen would have been carried into the blender, and it would likely
 have caused reactions on the surface of the material in the blender. However, this nitrogen source
 included  a filter  to extract moisture from the supply.  There was no evidence that suggests moisture
 was in the nitrogen.

       Atmospheric  humidity. Atmospheric humidity is known to react with sodium hydrosulfite and
 aluminum.  Interviews revealed that a nitrogen  blanket was placed on the contents of the blender
when the blender was  opened to the atmosphere, minimizing the effects of atmospheric moisture on
the feed  materials.

       Water used to clean liquid feed line.  Some information indicated that  operators  may have
used water or steam to clear the liquid feed line  in an effort to add the benzaldehyde. In  this case,
water would have been injected into the contents of the blender.  However, the  JCAIT confirmed that
efforts to clean the liquid feed line after the initial attempt to inject benzaldehyde did not involve

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                                             -24

 water or steam.

        Water in liquid feed line or tank.  Water was noted in the liquid feed tank and line up to the
 in-line filter near the line's entry into the blender, prior to the attempts to inject benzaldehyde. The
 maintenance employees were not able to clean and dry the portion of the injection system that is
 inside the blender  because the raw materials were charged into the  blender.  Several drying/vacuum
 procedures  were performed prior to charging,  yet the liquid feed  line within the blender was not
 checked to ensure that it was dry. Any water left in this portion of the line could have been  deposited
 in the blender as the operators attempted to add benzaldehyde. However, given that operators were
 not able to inject the benzaldehyde into the blender it is unknown if any water in  the feed line actually
 entered the blender.

        Water-cooled seal failure.  Analysis of the graphite water-cooled seal for the intensifier bar
 after the explosion revealed wear patterns that could have allowed water to leak through the seal.
 Had the seal leaked, it is likely that the water would have been deposited in the material being
 blended. However,  analysis did not determine  whether the seal failed during the  blending of the GPA
 or during a previous use of the blender by Napp.   Before the  blending of the GPA, a Napp
 maintenance worker noticed water near a packing gland in the blender, which could be a sign of
 failure of the seal.  However, even though  it is unlikely- based on previous cleaning operations- it is
 possible that water used to clean the blender could also have been  the source of the water near the
 packing gland.

        Heat generated by shear of intensifier bar moving through dry metal Powder.   The heat
 generated by the friction between the  intensifier bar moving through the dry metal powders may have
 been adequate to initiate or contribute to the thermal decomposition of the sodium hydrosulfite.
 Thermal decomposition of sodium hydrosulfite is exothermic; therefore, once the decomposition was
 initiated, it could  have continued.   The intensifier bar was only used while, mixing the blender
 contents.    Overfilling the blender  may  have reduced the efficiency of the blending operation;
 therefore, heat generated would not have  been  distributed throughout the raw materials within the
 blender.

        Heat generated due to particulate matter between the bearing:  surfaces inside the packing
 gland for the intensifier bar shaft.  The area inside the packing gland for the  intensifier bar shaft
 contains bearing surfaces. Had any particulate matter been between those bearings, the particulate
 matter and the bearings could have become excessively hot due to friction. With this area in contact
 with the raw materials inside the blender, heat generated due to the friction would be transferred to
the raw materials.   If this heat transfer is sufficient it may have been enough to initiate the sodium
 hydrosulfite.

        4.2    Most Likely Causes  of Chemical Reaction

        Based on the witness testimony, physical evidence, and analysis, the JCAIT has determined
that the reaction and explosion of the sodium hydrosulfite and aluminum powder was most likely
initiated by  two  mechanisms:  water introduced that initiated the exothermic decomposition of sodium

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                                             -25-

hydrosulfite; and heat which caused the sodium hydrosulfite to decompose. The JCAIT believes the
most likely sources of water are the graphite water-cooled seal and the liquid feed line. The most
likely source of heat was the shear of the intensifier bar moving at a high rate of speed through the
dry  powder.

       Water from failed seal and  liquid feed  line. The JCAIT estimates that only a small amount of
water was needed to initiate a reaction.  If a large amount of water was injected into the material in
the blender, the JCAIT believes a  large hydrogen gas bubble would, have been formed, causing a
detonation with greater energy  then was released in this accident.  However, if a small amount of
water was injected into the material in the blender, the reaction would begin a series of exothermic
reactions  over a longer period of time (see  Appendix B).  This theory is consistent with the findings
of the accident investigation.

       Through interviews and review of the blueprints of the blender, the JCAIT believes that if the
water-cooled seal for the intensifier bar failed, it is likely that the water would have leaked into the
material in the blender. Analysis of the seal after the  accident revealed grooves that may have been
deep enough to allow water to  leak into the blender.

       Additionally, the JCAIT can not rule out that any water in the liquid feed line may have been
delivered into the blender when attempts were made to add benzaldehyde.

       Heat generated by intensifier bar.   The heat  generated by the friction of the blades of the
intensifier bar running through the  dry chemicals in the blender may have been sufficient to initiate
or contribute to the thermal decomposition of the sodium hydrosulfite. Thermal decomposition of
sodium hydrosulfite is exothermic; therefore, it is possible that once the decomposition was initiated,
sodium hydrosulfite  in the blender continued to decompose, generating more heat.   This  reaction
would have continued to create a "hot spot"  in the material in the area below the  intensifier  bar.  As
the material was being removed by the Napp employees, the hot spot ignited, setting off the rest of
the material in the blender.

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                                            -26-

        4.3     Root Causes and Contributing Factors

        Root causes are the underlying prime reasons, such as failure of particular management
 systems, that allow  faulty design inadequate training, or deficiencies in maintenance to exist.  These,
 in turn, lead to unsafe acts or conditions which can result in an accident.  Contributing factors are
 reasons that, by themselves, do not lead to the conditions that ultimately caused the event; however,
 these factors facilitated  the occurrence of the event. The root causes and contributing factors of this
 event have broad application to a variety of situations and should be considered lessons for the
 chemical processing industries which operate similar processes, especially the tolling industry.

        Immediately following the  accident, members of the JCAIT collected  and  recorded the  details
 on the event and the circumstances leading up to  the event, interviewed  witnesses, and collected,
 photographed (see Figures  4-24)  and analyzed  physical evidence and  documentation. In the following
 months, the JCAIT  conducted engineering  analyses  of this  information using  elements of Events and
 Causal Factors and Hazard-Barrier-Target techniques and professional judgement to determine the
 root causes and contributing factors, and to generate recommendations to  prevent a recurrence. The
 JCAIT  concludes that the root causes and contributing factors of this accident are:

        An inadequate  hazards analysis was conducted and appropriate preventive actions were not
        taken.

        Through Napp's accident report and interviews  with Napp employees, the  JCAIT learned that
 most of the pre-operation hazards assessment as part of the "New Product Review" was based upon
the information presented in the MSDSs for the GPA and its ingredients.   MSDSs can provide
 adequate chemical hazards information but not necessarily process hazards information.   For
 example, the information presented in the MSDS for the GPA was for a typical package size (up to
 one 55 gallon drum), not for the quantity being blended (22 drums).

        Under the New Product Review Procedure using the MSDSs, Napp noted that aluminum,
 sodium hydrosulfite, and GPA were water reactive. However, this procedure and the MSDSs did
not reveal or address accident history, identify and account for all of the potential sources of water,
ways to eliminate or control these sources (engineering safeguards or procedures), recognition of
water contamination of the raw materials or GPA,  the immediate steps necessary to stop or handle
an unwanted reaction inside the blender,  and the proper technology and design of the equipment
necessary to safely and effectively blend water reactive substances.  In addition, the procedure did
not identity that heat could also have an adverse  affect on the substances in  the blender.  Without this
information, appropriate prevention actions were not taken.

       Napp successfully conducted the blending operation previously (1992) using the  same
process, procedures, and equipment and was unaware of any major accidents involving this product
or process. However, Napp did not appear to know about,  or at least consider the consequences of,
past accidents that have occurred involving sodium hydrosuhite or aluminum powder.

        The lack of  an  adequate process  hazards analysis led to a  lack  of knowledge or understanding

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                                            -27-

 that small amounts of water or heat could trigger a self-sustaining exothermic reaction at relatively
 low temperatures. This exothermic reaction lead to the catastrophic deflagration and fire. Napp
 removed sources of water in the blending room and took steps to ensure the blender and raw
 materials were kept dry. However, other sources of water were still present and Napp did not fully
 eliminate the possibility that water could contaminate  the blending process and operation. Water was
 used to cool the mechanical seal  in the intensifier bar and a water/glycol mixture was used in the
 heating/cooling jacket. Evidence also suggests that water may have been present in the liquid feed
 tank and piping  system  since they were not cleaned and dried prior to the startup of blending
 operations.  This equipment was cleaned and dried during  the blending operation. However, since
 the blender was already loaded, the liquid injection piping inside the blender could not  be  cleaned and
 dried.  In addition, the intensifier bar offered a potential source  of heat input from bearings and mixing
 shear (see equipment selection, below).

        The JCAIT notes that OSHA allows the collection  of the MSDSs to suffice for compliance
 with its information collection requirements for process safety information, provided the MSDSs
 contain information to the extent that enable the employer and employee involved in operating
 processes to identify and understand the hazards posed by these processes.  Such specific information
 criteria include:  reactivity data,  thermal  and chemical stability data, and hazardous effects of
 inadvertent mixing of different chemicals that could foreseeably occur.  A review of MSDSs alone
 for highly hazardous processes in  lieu of a formal process hazard analysis would not meet OSHA's
 requirements. Industry may not clearly understand this distinction which may have contributed to less
 than adequate hazards analyses since MSDSs were relied upon to conduct the company's new
 product review. As a result, thermal and chemical stability as well as inadvertent mixing of chemicals
 were not adequately addressed in  the review process.

  »     Standard operation procedures and training were less than adequate.

       Napp's standard operating procedures (SOPS)  failed to adequately address emergency
 shutdown including conditions under which emergency shutdown is required and the assignment of
 shutdown responsibility to qualified operators to ensure that emergency shutdown is  executed in a
 safe and timely manner. Also, the  SOPS did not address operating limits, including the consequences
 of deviations and steps required to correct deviations. Consequently, employees could not have been
trained on these critical steps,  hampering their ability to properly execute the blending  process under
the conditions occurring on April  20 and 21.

       Napp did not recognize or understand the significance of the abnormal situation beginning on
April 20 and culminating in the explosion and fire on April 21. According to Napp's procedures,  the
blending portion of the process should occur in less than an hour.  However, employees  attempted
to correct a variety of deviations, including unusual odors, bubbling, pressure buildup, and difficulty
adding the liquid portion, while the blending operation continued for many more hours than normal.
The  odors, bubbling on the surface of the contents of the blender, buildup of pressure and  venting of
gases from the blender all signaled that an undesired reaction had been initiated and was ongoing.
There were no operating procedures to address the deviations observed, the corrective actions to be
taken, or conditions under which an emergency shutdown should be triggered.

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                                            -28-

        The decision to re-enter the facility and off-load the blender was based on inadequate
        information.

        The lack of a complete understanding of the chemical and process hazards led to a lack of
 knowledge of the significance of the conditions present at the time employees re-entered the facility
 to off-load the blender.  Once the contents of the blender began reacting, the reactions were self-
 sustaining. As described above, the reaction had progressed to a point where employees were
 evacuated because of the sulfur smell coming from the blender.  At the time the decision was made
 to unload the blender, Napp was aware of, and concerned for, the strong possibility of a tire.
 However,  there  is no evidence to  suggest that Napp was aware that off-loading the blender may have
 exacerbated the reaction mechanisms by exposing the contents to air or that the contents  could
 violently  erupt and deflagrate.  Any attempt to stop the reactions by smothering or providing a
 nitrogen blanket would have been ineffective (see the discussion of chemistry in Appendix B).

        The equipment selected for the GPA blending; process was inappropriate.
  *

        Napp took steps to eliminate or control sources of water but elected to use blending
 equipment that incorporated sources of water in the design (water cooled seal, water/glycol jacket).
 Although regular maintenance of seals and cooling jackets helps to prevent failure and leakage, the
 possibility of a malfunction still exists, allowing water to contaminate the blender. The Aluminum
 Association, in their brochure Recommendations for Storage and Handling  of Aluminum Powders
 and Paste, recommends "In mixing aluminum powder with other dry  ingredients, frictional heat
 should be avoided.  The best type of blender  for a dry mixing operation is one that contains  no
 moving parts, but rather effects a tumbling action such as a conical blender."  The PK-125 blender,
 as previously noted, was a closed blender which, for the batch blended, contained a high speed
 intensifier  bar for mixing.  Shear  from the movement of the intensifier bar through the dry powders
 may have been a source of frictional heat. In addition, particulate matter between bearing surfaces
 at the intensifier bar shaft in the packing gland area may have been a source of frictional heat.

        Communications between Napp and Technic were inadequate.
  »

        Inadequate communication between Napp and Technic also contributed to the lack of a
 complete understanding  of the process hazards and their consequences. There is no standard or
 delineation of responsibilities in the toll manufacturing/blending industry which specifically assigns
 the responsibilities for input into  hazard reviews at the toll manufacturer's facility.

        Technic, Inc. is the patent holder of the GPA and is in the best position to know the hazards
 of its product.  In this tolling operation, Technic contracted with Napp to perform the blending.
 Technic provided Napp  with MSDSs for the  raw materials and the finished product and a batch  recipe
 ticket.   As noted above, MSDSs  provide product hazard information but generally do not provide
process  hazard assessment information. This investigation showed that Napp did not possess all the
 information necessary to  make sound judgements regarding the responses to deviations from the
 procedures in the blending process. Napp is in the chemical processing industry; however, Napp did
 not have in-house  expertise  regarding the GPA nor did it have experience  in working with  water

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                                            -29-

reactive  materials.  Although some of its employees had previously used the ingredients of GPA
Napp blended the GPA only one other time prior to this event (the previous blend was performed in
 1992).

       It should be noted that the MSDSs for sodium hydrosulfite and aluminum powder also gave
contradictory emergency response directions. For sodium hydrosulfite, copious amounts of water
should be used, while the MSDS for aluminum clearly stated "avoid water," "reacts with water,"
"exothermic reaction with water ... to generate hydrogen and heat." The MSDS for the  GPA
advised the use of "A water spray ... to extinguish fire."  The JCAIT investigators have located
numerous scientific references, which were presumably readily available to Napp management
personnel as well, indicating that powdered aluminum that is moistened or wetted becomes a very
serious fire hazard.  The only information that Napp used to determine the emergency response
procedures for handling emergencies involving the GPA was the MSDSs. However, the MSDSs do
not provide sufficient information to guide a response to an uncontrolled reaction or fire, given the
significant quantity of material in the blender.  The recommendation in  the MSDS  for "small  fires"
was to flood with water; however, a small fire was not defined, and the amount of water necessary
to flood the fire was not specified. For a fire involving an agent that is reactive with water, the
addition of an inappropriate amount of water as part of an emergency response can  have tragic
consequences.

 •     The training of fire brigade members and emergency responders was  inadequate.

       Eight of the twelve employees who were inside the building immediately preceding the
explosion (during the unloading  of the GPA) were also members of the Napp  fire brigade and trained
to handle fire hoses.  Napp was concerned about the potential for fire  by arranging for hoses and
personnel to be ready. However, employee training records indicate that the employees standing by
with fire hoses were not trained to deal with chemical fires or  emergency response  operations
involving chemical fires.  Consequently, the lack of training of the  fire brigade members and
emergency responders may have contributed to the consequences since the personnel present had no
training to recognize, understand, and assist with a potentially significant emergency situation.

5.0    Recommendations

       Based upon the root causes and contributing factors of this accident described  above, the
JCAIT provides the following recommendations to prevent accidents like this one from happening
in the future:

PHAs, SOPS and Training

       Before handling any  substance,  facilities should ensure that all chemical and  process hazards
and the consequences and deviations  associated with  the chemical and process hazards are completely
understood, evaluated, documented, and appropriately addressed through preventive measures. This
assessment should  also include accident history, chemical incompatibilities and  equipment  design and
integrity.   One way facilities can carry out this evaluation is using a formal process hazard analysis

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                                            -30-

 (PHA) technique as required under the OSHA Process Safety Management Standard under 29 CFR
 1910.119 or the EPA Risk Management Program Rule under 29 CFR part 68.  The Center for
 Chemical Process  Safety (CCPS) of the American Institute of Chemical Engineers  (AIChE) has
 prepared guidance on PHA  methodologies.  In addition, the hazard evaluation can identify failure
 areas  that need to be addressed by safeguards such as  engineering controls, maintenance  and standard
 operating procedures.  The standard operating procedures (SOPS) should address steps for normal
 operations (including startups and shutdowns), anticipated deviations from normal, the consequences
 of such deviations and the steps to  correct them, emergency conditions and steps for emergency
 shutdowns and placing the operation into a safe mode.  After SOPs  have been developed, all
 operating personnel, including supervisors, should be trained on the newly developed SOPS. This
 training must also include recognition of deviations or upset conditions and their potential
 consequences and corrective actions or shutdowns.

       Facilities need to clarity and understand their respective responsibilities for the discovery and
 assessment of chemical and process hazards and process safety  information in tolling or other
 contracting agreements. Both parties must be clear as to who will be responsible for process safety
 information, including chemical hazards,  technology of the process, consequences of upset conditions,
 and identification of any previous incidents involving similar processes.  The chemical and petroleum
 processing industries should develop basic guidelines to be used in  tolling or contracting agreements
 the safety of which may depend on sound communication of chemical and process hazards. EPA has
 requested that CCPS examine whether guidance for conducting process hazards analyses and safety
 information sharing in tolling agreements should be developed.

 Recognition  and Evaluation of Abnormal Situations

       The value of a thorough assessment of the  chemical and process hazards using methods such
 as a process hazard analysis (PHA) is greater understanding of the range  of possible deviations, the
 consequences of the deviations, and corrective  actions to safely bring the process under control.
 without this information, evaluation and action to correct abnormal situations when they arise may
 become guesswork, placing the process, the facility, the employees, the community, and the
 environment at risk. Facilities should routinely review their chemical and process  hazards assessments
 to  make sure  new information is  included, monitor accident histories and  lessons learned and consider
 applications to their processes, and investigate deviations, no matter how minor, to prevent more
 serious  consequences.

 Proper Use of Equipment

       All facilities should ensure that equipment manufacturers'  recommendations are followed and
that equipment is installed, operated, and maintained as designed. Equipment manufacturers typically
 have a wealth of information regarding the maintenance and recommended uses of equipment they
manufacture.  Chemical processors and toll operators  should regularly contact equipment
manufacturers for updated information and seek advice should equipment application, installation,
 operation  or maintenance needs  deviate  or require modification from equipment manufacturers'
recommendations.

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                                           -31-

       Many types of industrial vessels or other equipment use mechanical seals to permit external
 drive of  internal equipment, such as pumps, mixers, or agitators. In certain applications, mechanical
 seals must be liquid cooled or purged to prolong seal integrity. While regular maintenance may help
 prevent failure and leakage, the possibility of a malfunction always exists.  Facilities should ensure
 that liquids used to cool or purge seals are not incompatible with materials processed in the vessels
 or other  equipment.

 OSHA/EPA Review of Highly Hazardous Chemicals List

       Appendix A of OSHA's existing Process Safety Management (PSM) standard (29 CFR
 1910.119) lists the toxic and reactive chemicals covered by that standard. At the time of the  process
 safety management rulemaking, OSHA decided to include only those chemicals having the NFPA
 (NFPA 49)  ratings of 3 or 4 for reactivity.  Chemicals rated 3 or 4 are those that are capable of
 undergoing  detonation or explosive decomposition and generating the most severe blast or shock
 wave.  NFPA 49  assigns sodium hydrosulfite a reactivity rating of 2 and aluminum powder a
 reactivity  rating of  1.  Because of this tragic event, OSHA is considering adding additional reactive
 chemicals to the Appendix A chemical list.

       EPA and OSHA have agreed to harmonize their lists of substances under the PSM standard
 and the List of Regulated Substances for the Risk  Management Program in 29 CFR part 68
 promulgated  under section  112(r) of the  Clean Air Act.  EPA's current list only addresses toxic and
 flammable substances. As part of the upcoming 5-year review of its list,  EPA will consider other
 hazards, including reactive chemicals.

 QSHA Review of Integration of Hazard Communication (HazCom)  and Hazardous Waste
 Operations and Emergency Response (HazWoper) Standards, with the Process  Safety
 Management  (PSM)  Standard

       OSHA's HazCom and HazWoper standards, combined with the PSM standard, provide an
 integrated approach to worker health and safety. OSHA's Hazard Communication Standard (29 CFR
 1910.1200)  permits the MSDS for the components  of a mixture to serve as the MSDS  for the
 mixture.  Employers that rely upon an  MSDS created by other entities must be aware that the MSDS
 for raw materials may not identify all hazards which may be encountered when mixing, blending or
 processing them with other materials.  This may be true even if there is no reaction anticipated or
 apparent.  Moreover, an MSDS for the final mixture  may specifically address the hazards of shipping
 container quantities, but may not apply to the hazards  of larger quantities in the processing phase.

       This accident demonstrates that  a review of the MSDS is an inadequate substitute for
performing a process hazards analysis. As noted above,  OSHA allows the collection of the MSDSs
to suffice for compliance with its information collection requirements for process safety information
if the MSDSs contain information to the extent that  they enable employers  and  employees, involved
in operating  processes  to identify and understand the hazards  posed by these processes.  Such specific
information criteria include: reactivity data, thermal and chemical stability data, and hazardous effects
of inadvertent mixing of different chemicals that could foreseeably occur.  A review of MSDSs alone

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                                           -32-

for highly hazardous processes in lieu of a formal process hazard analysis would not meet OSHA's
requirements. Industry may not clearly understand this distinction which, in this accident, may have
contributed to a less than adequate hazards analyses. As a result, thermal and chemical stability as
well as inadvertent mixing of chemicals were not adequately addressed in the review process.

       In addition, many companies rely on MSDSs to communicate hazard and emergency response
information with  communities and first responders as required  by EPA under the Emergency Planning
and Community Right-to-Know Act. EPA  and OSHA will consider whether additional guidance or
outreach in the form of an Alert or other means is necessary to advise industry and first responders
to make sure that MSDSs are not used beyond their intended design, to highlight areas where
information can  be  misunderstood, and to make sure that hazards information is complete.  The
American National  Standards Institute (ANSI) in  cooperation with  the Chemical Manufacturers
Association (CMA)  is working to revise an existing ANSI uniform MSDS format.  CMA and ANSI
and other industry organizations should also evaluate whether additional  consensus standards or
guidelines are needed for MSDS consistency and to avoid misunderstandings  (e.g. the difference
between chemical and process hazards) or faulty interpretations of terms (e.g. small fires or small
amounts of water).

        As a result of the devastating loss  of five emergency responders in this event, OSHA clarified
its HazWoper Standard (29 CFR 1910.120) and its Employee Emergency Plans and Fire Prevention
Plans (29 CFR 1910.38) (Memorandum  For  All  Regional  Administrators; Subject: Update to
HazWoper Emergency  Response Guidance:  Coordination with Local Fire Departments; Oct.  30,
1996). This clarification, while written for compliance officers, gives employers guidance for
conducting appropriate emergency response actions as part of their emergency response plans
contained in the subject standards.

       Finally, as a  result of this accident,  OSHA issued a Hazard Bulletin about MSDSs in July 3,
1996, recommending that a process safety  analysis be performed for all materials with catastrophic
potential, even if not covered by the PSM standard. The analysis should include a cautious review
of chemical hazards, incompatibilities and a thorough examination of all mechanical equipment.
Standard operating procedures should be developed and the consequences of deviation ought to be
identified. Further,  employers that rely on MSDSs created by other parties must be  aware that
MSDSs for raw materials may not identify all hazards that might be  encountered when mixing or
blending with other  materials. This may be true even if there is no anticipated or apparent reaction.
MSDSs for the final mixture may specifically address the hazards of shipping container quantities, but
may not apply to the hazards of the larger quantities needed to make the mixture.

6.0    Outcomes of OSHA/Napp Technologies Settlement

       As part of the  settlement between Napp Technologies and the  Occupational Safety and Health
Administration, Napp agreed to the following items: 1) conduct a comprehensive review of all SOP's
for worker health and  safety issues and.  compliance with worker safety and health  standards; 2)
conduct periodic  comprehensive safety and health audits utilizing a qualified independent safety and
health professional and develop action plans to abate all hazards found; 3)  contract with a  qualified

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                                            -34-

                                       Appendix  A

                            Results of Analysis of the Accident

 Chemical Analysis Results

       The results of the chemical analyses of the residues in the blender taken by EPA's
 Environmental Response Team revealed the presence of percentage amounts of various metals such
 as sodium, potassium and aluminum. This was expected, inasmuch as these metals were part of the
 GPA mixture.  In addition, the sampling revealed the presence  of large amounts of phenol and
 methylphenol compounds. Phenol was detected in internal ash samples and in an external crevice ash
 sample. To a lesser degree 2-methylphenol and  4-methylphenol were  also detected in the ash
 samples.

       Phenol and the  methylphenol compounds were likely due to the  insulating  material remnants
 which were originally located in the annulus between the outer wall  of the blender and the outer wall
 of the water-glycol jacket. Additionally, a review of the chemistry of benzaldehyde suggests that the
 presence of phenol and phenol compounds can be explanted as follows: the aluminum in the blender
 had reacted with the water and sodium hydrosulfite, causing an exothermic and reducing atmosphere
 to form inside the blender.  This resulted in the conversion of whatever benzaldehyde had  been
 successfully introduced into the blender to a methyl hydroxy (alcohol) intermediate.  This  material,
 in the reducing environment inside the blender, was transformed to  toluene, another intermediate.
 The toluene was in turn converted to phenol, and to a lesser degree 2-methyl phenol, and 4-methyl
 phenol. This reaction is a classic electrophilic aromatic substitution in which methyl groups reform
 preferentially onto the benzene ring in the ortho and para positions (relative to the OH group in
 phenol), creating phenol, and the 2- and 4-methyl phenol species respectively. This chemistry tends
 to eliminate the possibility that phenol,  rather than benzaldehyde,  had  been  inadvertently added  to the
 GPA blend.

 Post-Explosion Analysis of Blender

       After the accident, members of the Materials Reliability Division of the National Institute of
 Standards and  Technology (NIST)  analyzed the remains of the PK-125 blender.  A visual examination
 of the blender revealed that the outer jacket of the blender was ripped loose at the access ports and
 was peeled away from the stainless steel shell of the blender. The damage initially  appeared to be the
 result of a steam explosion inside the water jacket lining. The shell sustained little gross deformation
 except near the bottom unloading hatch assembly area.

       The bottom portion of the blender, where the discharge  port was located, was  severely
 deformed, and most of the unloading hatch assembly was missing.  Much of this damage was
probably caused by impact  when the blender was propelled through the block wall  of the blender
room and/or immediately afterwards as it came to rest.  The metal surrounding the discharge port was
most likely very hot, which  would have facilitated deformation.

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                                              -35-

        The metal surrounding the access ports had striation marks resembling those typical of
 oxyacetylene  cuts in steel. The striation marks are believed to be due to erosion that occurred when
 material from inside the blender was violently ejected from the loading ports at high temperature and
 velocity.

        Further visual observations were performed by NIST personnel off-site. The surface of the
 stainless steel shell was examined for any visible cracks through which water (from the  water jacket)
 could have entered  the blender. With the exception of a small crack (several millimeters  long) located
 near the discharge port, there were no visible signs of cracking.   This damage is believed to have
 occurred during the accident and was not part of the initiating event. No localized areas of melting
 or heat tinting were observed.

        A metal tube, approximately 400 millimeters (mm) diameter, to which the support flange is
 fastened on Lobe A of the blender, is welded to the  stainless  steel  shell inside the blender.  This tube
 had a sheet metal cover/seal  on the end.  Through this cover,  a series of concentric pipes and shafts
 (vacuum tube assembly) enter the blender. The cover, which is approximately 1.5 mm  thick, was
 severely deformed and bent in a  manner suggesting that  the concentric pipes were torn or blown  out
 of the blender in the accident.   Inspection of the cover inside the blender showed severe erosion
 damage around the opening through which the concentric pipes entered the blender. These erosion
 markings are similar to those found on the access ports and indicate GPA material was  ejected out
 of this opening of the blender as well.

        The interior shell near the off-load port is slightly buckled.  This deformation most likely
 resulted resulted impact damage during the accident. The damage on the outside of the blender around
 the off-load port is more extensive.  The wedge-shaped configuration of the damage was probably
 caused by the impact during the accident.

        The most notable features on the  surface of the interior were the erosion marks. These
 markings likely resulted from the ejection of heated material from inside the blender  during the
 accident.  The  erosion was  confined principally to the surfaces of the interior that form the "V
 between the two lobes.  The erosion occurred mostly within a region that was approximately one
 meter wide near the seam between the two lobes of the blender.  The heaviest erosion  damage is
 limited to a region about 200 mm wide near the centerline.  The surface at the seam is not eroded.
 Erosion appeared on the surfaces adjacent to the seam, in the lobes, and at the top of the lobes
 (around ports).  In both lobes, it appears that the erosion on the top side of the centerline is most
 severe. In addition, the erosion at the  tops of Lobes A and B differ:  on Lobe  B  the erosion is dimple-
 like around the access port, resembling impact damage, and erosion on Lobe A is wavy lines (flow-
 like) cut into the surface of the shell.

       The concentric pipes and shafts of the vacuum tube assembly enter the blender (Lobe A)
through the support  tube.  On the outside of the blender, near the end of the vacuum tube  assembly,
 is a water-cooled graphite seal that allows  the agitator shaft to turn at high speed.  Examination of
the seal components showed that the inboard steel ring was fractured and that the inboard graphite
 seal had radial fissures  and circumferential  gouging.  The depth of the grooving was measured on a

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                                            -36-

replicated  surface  of the inboard seal. The measurements were made on an optical microscope with
a calibrated z-axis. Typically, the depth of the grooves  varied from 25 to 125 microns. The width
of the groove exceeded 1 mm in some regions; these  grooves may have allowed water to pass
through the seal over time.

Coroner's Report

       This report will  not detail the injuries sustained by those Napp employees who perished in the
explosion. However, the physical condition of the victims provides some insight into the nature of
the chemical reactions that occurred inside the PK-125 blender.

       Autopsy information provided investigators by the Bergen County Medical Examiner indicates
that the deceased employees suffered a combination of trauma, burns, and smoke/fumes inhalation.
There were no physical signs that the victims had been subjected to the explosive force of a
detonation. Rather, the physical  signs indicated that what occurred was a deflagration, not a
detonation. The main difference between the two is the rate of energy release and the amount of
overpressure generated by the instantaneous and violent reactions of the materials involved.  Had a
hydrogen gas explosion occurred, it has been calculated that the entire plant, as well as a significant
portion of the nearby homes, would have been destroyed in  the blast.   The extent of the damage,
although catastrophic by any standards, was indicative of an explosion with a lower rate of energy
release than that which would have been produced by hydrogen gas.  This physical evidence indicates
that the reactions that occurred involved the decomposition of sodium hydrosulfite and subsequent
reaction products  interacting with powdered aluminum.

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                                           -37-

                                       Appendix B

                                    Chemical Reactions

 Sodium Hydrosulfite

        Sodium hydrosulfite decomposes exothermically in the presence of heat, moisture, or air.
 Although sodium hydrosulfite is flammable, it is not explosive. Contact with small amounts of water
 or moist air will cause a chemical decomposition reaction that generates sufficient heat to ignite
 combustible materials. In one reported accident (Bretherick 1990), smoldering started when water
 entered  a drum of sodium hydrosulfrte, which then ignited when tipped over for disposal. In another
 case (Bretherick 1 990),  a batch of sodium hydrosulfite violently decomposed during drying in a
 graining bowl. The likely explanation  was  contamination with water and/or oxidant.

       Exposure of sodium hydrosulfite to moisture, either from humid  air or traces of water, can
 cause reactions that may generate enough heat to initiate thermal decomposition (NFPA 49, 1994).
 The reaction of sodium hydrosulfite (Na2S204) with water can produce  sodium bisulfite  (NaHS03)
 and sodium thiosulfate (Na2S2O4) (Equation 1). Because sodium bisulfite is an unstable solid
 compound (Kirk-Othmer 1983), it most likely decomposes to  sodium metabisulfite (Na2S205) and
 water (Equation 2).  Sodium metabisulfite may then decompose to sodium sulfite (Na2S03) and sulfur
 dioxide (SO,)  (Equation 3).  Therefore, the bubbling of the GPA materials that was observed by a
 supervisor in the early morning of April 21 can be explained by the generation of sulfur dioxide.
 Because water is produced in this suggested reaction scenario, the overall reaction becomes self-
 sustaining; only a small  amount of water is needed to initiate the exothermic reaction. As the reaction
 proceeds, the temperature of the blender and the GPA components would have increased.
              2Na2S2O4 + H2O - 2NaHSO3

       (2)    2NaHSO3 - Na^A + H2O

       (3)    2Na2S2O5 - Na2SO4 + SO2 +
       Only catalytic amounts of water are needed to make the decomposition self sustaining. In
closed vessels, decomposition is likely to occur simultaneously with pressure buildup at low
temperatures.

       Anhydrous sodium hydrosulfite has a tendency to decompose spontaneously as in the
following equation (Equation 4), forming sodium thiosulfate and sodium sulfite and releasing sulfur
dioxide. Because this reaction is exothermic, the temperature of the GPA components would have
continued to increase. This increase in temperature would have accelerated the decomposition and,
thus, the production of sulfur dioxide, resulting in violent surface bubbling of the reaction mixture.

       (4)     2Na2S2O4 - Na^ + Na^A + SO2

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                                            -38-

        The reaction is violent above 150  -  190C. Simple geometry influences the mode of
 decomposition. In 'heap' samples, insulation,  and therefore self heating, is  greater than in thin layers
 of the chemical. When a sample was heated at 15C per minute, a sudden exotherm of 47 kilojoules
 per mole (kJ/mol) occurred at 205C (Goodhead, 1974). Another investigator performing calorimetry
 experiments on sodium hydrosulfite found that there were two large exotherms preceded by a small
 one (Tartani and Contessa). The initial decomposition temperature was lowered by 50C (from 1 IOC)
 in the presence of 0.5 to 1% water.  The investigator concluded that in closed vessels, the two sets
 of reactions above (i.e., wet and anhydrous sodium hydrosulfite) occur simultaneously with buildup
 of pressure at low temperatures.

        The intensifier bar rotating at a high speed, cutting through the aluminum powder and other
 GPA materials, may have generated factional heat.  Although tumbling the contents of the blender
 may have distributed some of the heat, the use of the intensifier bar may have contributed to the
 continuation  of the  sodium hydrosultite/aluminum/water reaction.

 Aluminum

        Aluminum is  a strongly electropositive metal and is  very reactive, burning rapidly  in air when
 strongly heated.  Finely divided aluminum powder or dusts forms highly explosive mixtures in air
 (flash point of 645C).  Ignition may be the -result of heat, shock or abrasion; it may also be
 spontaneous due to humidity or moisture. A severe explosion occurred in a plant producing fine
 aluminum powder in  1983 (Bretherick 1990). Fires and explosions have occurred during grinding
 and polishing operations where sparks may have set off the  reaction.   Because of the extreme
 exothermic nature of its reaction with air, aluminum is used as a metal fuel. It is incorporated into
 explosives  to increase the energy released. The use of substantial amounts of aluminum powder
 under high  temperatures with the reduction of liberated  carbon dioxide and  water by the  metal is used
 in conventional explosives enhances the energy release by up to 100%.

        In a finely divided form, aluminum will react violently with boiling water to form hydrogen
 and aluminum  hydroxide; the reaction is slow  in cold water. Under ordinary circumstances, aluminum
 is passivated by the formation of a layer of aluminum oxide.   If this  protecting layer is breached,
 reactions consistent with its strong electropositive character may occur.  In handling  fires where
 aluminum dust is present,  one is warned not to use water. In  one case where aluminum dust was
 ignited by sparks from a grinding machine, the activation of an automatic sprinkling system and the
 reaction of the water with burning metal resulted in the liberation of hydrogen, which, after mixing
 with air, exploded (Bretherick  1990). In the Bretherick case, the primary explosion created an
 aluminum  dust cloud which exploded forcefully, producing more dust and encompassing more
 aluminum dust, resulting in four  tertiary explosions in all.

       Because of its high affinity for oxygen, aluminum is used in  metallothermic reductions of
 metal compounds. These reactions produce enormous amounts  of heat. For example, in its reaction
 with chromic oxide, molten chromium (melting point 1907C) is formed. Thermite-type reactions may
 also occur with non-metals such as  sodium hydrosuhite, sulfur dioxide, and carbon  oxides. Even
though sodium  hydrosulfite is a reducing agent, aluminum has such an affinity for oxygen that it can

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                                           -39-

 extract oxygen from these compounds. A violent explosion occurred when an 8:3 molar mixture of
 aluminum powder and sodium sulfate was heated to 800C (Bretherick 1990). Application of sodium
 carbonate to red hot aluminum  caused an explosion (Bretherick 1990). At high temperatures,
 aluminum powder also reacts violently with sulfur to form aluminum sulfide.

        As examples, aluminum powder may react with sodium hydrosulfite or sulfur dioxide,
 produced from the decomposition of sodium hydrosulfite, according to the reactions:

                     4A1 + 3S02  2A1A + 3S

                     lAl + Na^A   NajO + A12O3 + 2S

        The heats of reactions at 25C are -615.3 kJ/mol Al and -428.9 kJ/mol Al, respectively.

        In another  case, butanol attacked an aluminum gasket at  100C, liberating hydrogen
 Brethrick 1990). Other alcohols would react similarly. Benzyl alcohol is produced by the reaction
 of benzaldehyde with sodium hydrosultite. Therefore, conditions may exist in the reaction vessel for
 a similar reaction of benzyl alcohol  and aluminum powder to occur.

 Reactions Occurring in Mixture

        The predominant reactions taking place probably were the exothermic reaction of sodium
 hydrosulfite with  water, or with water and oxygen;  the exothermic reaction of aluminum powder with
 water, the exothermic thermal decomposition of sodium hydrosulfite, which would have been initiated
 by heat from the  exothertmic reactions; and the  exothermic oxidation of hot aluminum powder, which
 would have been initiated when air contacted the blender contents. The reaction products  expected
 are consistent with the results of the  chemical analysis of the site (EPA Trip Report, July 5, 1995).
 The source of the large phenol concentration noted in the grab samples from the blender  does not
 seem to be a result of the reactions of the reported mixture materials, but most likely occurred at
 some time during initial attempts to blend the GPA components.

 Calorimetry Studies

       The following are the results  of accelerated rate calorimetry (ARC) studies of sodium
hydrosulfite and a sample approximating the composition of the GPA.  The purpose of the studies
was to measure the heat released from these substances in the presence of water to determine the
hazard posed by these substances. Calorimetric studies obtained from the literature and a limited
 study conducted  by the  Salt Lake  Technical  Center confirm that the mixture was extremely
hazardous.  These  studies confirm that small quantities of water were capable of inducing a runaway
reaction at relatively low temperatures and that the presence of aluminum in the mixture provided a
substantial increase in the amount  of heat released during the decomposition.


        'The heats of formation were obtained from CRC Handbook of Chemistry and Physics, 75th edition and Lange's Handbook of Chemistry,
 13th edition

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                                            -40-

       A review of the  literature disclosed a study  entitled "Water Influence on Thermal Stability of
Sodium Dithionite" (presented by V. Tartari and S. Contessa at the 5th International Symposium
"Loss Prevention and Safety Promotion in the Process Industries," sponsored by the Societe de
Chimie Industrielle, 28 rue Saint-Dominique,  F75007, Paris. This accelerated rate calorimetry (ARC)
study of the effect of water on the decomposition of sodium hydrosulfite (Na2S204, sodium dithionite)
demonstrated that addition of less than one percent of water to a sample of sodium hydrosulfite
reduced the temperature at which self-heating begins from approximately 111C down to
approximately  60C. Based on these results,  the authors conclude that a small amount of water
strongly influences the thermal stability of this  material.

       Additional, but limited, studies  were conducted by the Salt Lake Technical Center  using ARC
methods to determine the effects of including aluminum in a mixture containing sodium  hydrosulfite
and potassium carbonate. Under these conditions, which mimic the insulated (adiabatic) conditions
in the core of the mixer leading to thermal runaway, the net adiabatic temperature rise for 3.5 grams
(g) of the mixture without the  aluminum was 34C. For a comparable amount of the mixture including
aluminum and approximating the composition  of the ACR9031 mixture, the temperature excursion
went off scale, and the experiment had to be scaled down. For 0.5 g of the mixture containing the
aluminum the net adiabatic temperature rise was 486C. From these data, the heats of reaction were
determined These studies demonstrated that the addition of the aluminum produced an eleven-fold
increase in the amount of heat released per gram of mixture.

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                                               -41-

                                          Appendix C

                   Accidents Involving Sodium Hydrosulfite and Aluminum

Sodium Hydrosulfite

        The events leading to the explosion at Lodi involved the exothermic reaction of sodium
hydrosulfite with water, followed by thermal decomposition of sodium hydrosulfite. A number of
accidents are reported in the literature involving reaction of sodium hydrostite with water and
generation of sulfur dioxide. Exhibit C-l below provides short descriptions of some accidents
involving tires, explosions, or reactions of sodium hydrosulfite, culled from media and other
sources.  This exhibit does not include reports of spills of sodium hydrosulfite where no serious
consequences resulted, but evacuations were carried out as a precaution.
                                          Exhibit C-l
         Accidents Involving Fires, Explosions, or Reactions of Sodium Hydrosulfite
         Location

  Savannah, GA
  Chemical plant, Wuxi,
  Jiangsu, China

  Commercial laundry,
  Rhode Island
  Philadelphia, PA
  Accrington,  Lancashire,
  UK
  Los Angeles, CA
 Paper manufacturer,
 Madawaska, ME
 Trucking Company,
 Galveston County, TX
  Date                Description

4/1/95      Large fire may have resulted from tank
           leaks that caused the mixing of crude
           sulfate turpentine  and sodium hydrosulfite.

3/24/95    Drums containing sodium hydrosulfite
           exploded (no details available).

6/14/94    A small chemical fine was reported in a
           storage drum containing sodium
           hydrosulfite.

3/23/94     Water, possibly from a roof leak, hit a 30-
           gallon drum of powdered sodium
           hydrosulfite, generating fumes.

3/5/92      Drum of sodium hydrosulfite came in
           contact with moisture and began giving off
           sulfur dioxide. Several gallons of water
           were used to dilute chemical.

11/28/90   A 35-gallon drum tilled with sodium
           hydrosulfite burned

11/6/90    A spill of 5,000 pounds  of solid sodium
           hydrosuhite led to a release  of sulfur
           dioxide.

6/9/90     A trailer of sodium hydrosulfite caught fire.
    Effects on People

None reported



6 killed, 5 injured


None reported
4 workers injured, 12
evacuated
8 people (company stafi)
evacuated
2 firms evacuated


11 workers injured
 16-block area evacuated;
no injuries

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          -42-
Exhibit C-l (continued)
Location
Rail depot, Kensington,
Victoria, Australia
Landfill in Orlando, FL
Chemical plant, Phoenix,
AZ
Chemical plant, Rocky
Mount, NC
Dye plant, Los Angeles,
CA
Henrico, VA
Chemical truck,
Daglingworth,
Gloucestershire, UK
Chemical truck on
highway, Covington, LA
Chemical distribution,
and storage company, NC
Northenden, Greater
Manchester, UK
Liverpool, Merseyside,
UK
Date
4/20/90
1/26/90
4/6/89
6/28/89
5/25/89
2/15/89
1/13/89
1/1/89
3/88
1/20/87
11 /1 1/85
Description
Sodium hydrosulfite leaked from a shipping
container that held 122 drums and reacted
with moisture to form a huge toxic cloud.
Firemen neutralized the leak.
Fire started when a small amount of
calcium hypochlorite was added to a drum
containing sodium hydrosulfite.
A drum of sodium hydrosulfite ignited
while in storage.
Rain apparently fell into a rusted 30-gallon
container of sodium hydrosulfite, causing a
chemical reaction that formed a vapor
cloud.
Fire of sodium hydrosulfite reported.
Sodium hydrosulfite "ignited itself inside a
3 5 -gallon drum in the parking lot.
Driver of truck carrying drums of sodium
hydrosulfite noticed one on fire. Water wa:
sprayed onto drums, which then exploded.
Sixty-foot cloud of sulfur dioxide formed.
A truck carrying 43,000 pounds of granular
sodium hydrosulfite burst into flames.
A fire was blamed on improper cleanup of
a chemical spill. Employees accidentally
punctured a drum of sodium hydrosulfite;
the spill area should have been deluged
with "massive amounts" of water.
A drum of waste sodium hydrosulfite
periodically ignited and released toxic
fumes. Firemen used water to cool the
drum.
A chemical fire broke out in the hold of a
cargo ship. As a drum of sodium
hydrosulfite was being offloaded, some
material was spilled and instantly ignited,
causing a flash fire.
Effects on People
1300 residents evacuatec
Evacuation reported
None reported
16 people treated, 1
hospitalized
Evacuation reported
None reported
Residents told to stay
inside
12 miles of interstate
highway closed, residents
evacuated in a 1 -mile
radius
None reported
20 nearby residents
evacuated suffering from
nausea and sore eyes
7 people injured by
inhaling vapor

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         Location

  Dye plant, Leicester,
  Leicestershire, UK
  Penang, Malaysia
  Date

10/6/85
11/24/80
           -43-
Exhibit C-l (continued)


             Description

Water got into a drum of sodium
hydrosulfite, which ignited,  giving off
poisonous  fumes.
   Effects on People

 1 injury, evacuation
reported, residents
complained
 A vessel carrying 4,800 drums of sodium    None reported
 hydrosulfite caught fire. Some of the drums
 were transferred to barge, but many had
 their lids blown off in the heat. Dense
 poisonous fumes were given off.
  Avonmouth, Avon, UK
6/10/80
 A truck containing 160 drums of sodium
 hydrosulfite  overturned. Heavy rains
 caused severe problems.
42 people injured
Sources: Newspaper reports (on-line literature search), United Kingdom's Major Hazard Incidents Data Service
        (MHIDAS) database, EPA's Accidental Release Information Program (ARIP) database


Aluminum Powder

        The Lodi explosion  likely involved the aluminum powder in  the mixing  vessel.  Aluminum
powder has been reported in a number of accidents with fires or explosions. Fine aluminum
powder, like other finely powdered materials, has the potential to explode when dispersed in air.
In addition to dust cloud explosions involving aluminum, there are several reports in which
mixtures of aluminum powder and other chemicals exploded (e.g., an explosion of aluminum
powder and glass-making chemicals in a mixing machine).  A case of ignition  of aluminum powder
in hot weather is also reported. Exhibit C-2 presents brief descriptions of some accidents that
involved fires or explosions of aluminum powder,  culled from media and  other sources.
                                         Exhibit C-2
               Accidents Involving Fires or Explosions of Aluminum Powder
        Location
 Date
  Glass factory, Pittsburgh,  9/4/93
  PA
  Aluminum  flake        9/91
  processing plant, Darwen,
  Lancashire, UK
            Description

A mixture of aluminum powder and
glass-making chemicals exploded in a
mixing machine. The cause of the
explosion is unknown.

An explosion blew the roof off the plant
and caused a fire.The cause of the
explosion is unknown; a possible cause is
failure to stop process while maintenance
was being carried out.
   Effects on People

1 worker killed
                                               1 worker killed, 2 injured

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                                                  -44-
         Location

  Aerojet industry,
  Sacramento, CA

  Truck on highway, VA
  Date

7/26/91


7/24/91
  Newburgh, IN
5/16/90
  Darwen, Lancashire, UK    3/27/89
  Mixing plant, Eaton         7/2/86
  Township, OH


  Aluminum powder          7/16/83
  company, Gwynedd,
  Anglesey, UK
  Chemical works, Widnes,  2/6/83
  Cheshire, UK
  Aluminum works,         2/2/80
  Hermillion, France

  Albany, CA               1/23/78
  Metalwork plant,         4/16/53
  Chicago, IL
             Description                    Effects on People

A compound of potassium perchlorate and   1 worker cut and
aluminum powder exploded              seriously burned

Aluminum powder ignited while being     None reported
transported in hot weather. The aluminum
powder was  reported to be properly
contained, but the container might have
deteriorated during a heat wave.

A gap in an exhaust duct allowed aluminum  1 worker injured
lines and dust to be dispersed in the air.
Welding sparks ignited the dust, creating a
fireball.

An exothermic reaction occurred in an    None reported
aluminum powder storage area, starting a
fire which consumed about 40 metric  tons
of aluminum. The fire spread to other parts
of the factory and was allowed to burn itself
out.
           An aluminum powder compound exploded
           at a mixing plan, lifting the roof off. The
           cause of the explosion was unknown.
                                        8 workers injured
           Explosion in powder collection system sent  5 people injured
           fireball hundreds of feet in the air, two
           more explosions and a fire followed All
           buildings within 200 yards were wrecked
           and debris blocked rail line.
           A dust explosion occurred during filling
           operation when aluminum powder was
           being put into drums.

           Several buildings were destroyed in 3
           explosions. Fire raged for 6 hours.

           Explosion occurred in building where
           aluminum powder was precipitated and
           graded. Considerable  damage inside and
           outside plant.

           Plant demolished by fire following  dust
           explosion ignited by polishing machine.
                                        1 person killed
                                        None reported
                                        1 person injured
                                        35 people killed, more
                                        than 20 injured
Sources: Newspaper reports (on-line literature search), United Kingdom's Major Hazard Incidents Data Service
        (MHIDAS) database, Occupational Safety and Health Administration (OSHA) database

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                                         -45-



                                     Appendix D

                                      References

Aluminum Association. Recommendations for Storage and Handling of Aluminum Powders and
Paste. Washington  DC.

Bretherick's Handbook of Reactive Chemical Hazard, Fourth edition,  pp. 20-32,633, 1385,
 18101-2.  London:  Butterworths 1990.

CRC Handbook of Chemistry and Physics, 75th ed. Boca Raton, FL: CRC Press. 1995

Dean, J. Lange 's Handbook of Chemistry.  13th ed. New York, NY: McGraw-Hill Book
Company. 1985.

Dietz Jr., G., Skomoroski, R., Aluminum Containing Precipitating Agent for Precious Metals
and Method for its use. Patent No. 4,092,154. American Chemical and Refining Co., Inc.
Waterbury, CT. 1978.

Goodhead, K et al. The non-oxidative  decomposition of  heated sodium dithionite.  J. Appl.
Chem. Biotechnol. (24) pp. 71-79. 1974.

ICF, Inc., Production and Use, Accident History, Regulations/Recommendations for Transport
and Handling of Sodium Hydrosulfite and Aluminum Power.  Draft October 13, 1995.

ICF, Inc., Analysis of Process Issues and Chemical Reactions Concerning the Accident at Napp
Technologies, Inc. in Ludi, NJ. Draft October 16, 1995.

Kirk-Othmer 1983. Kirk-Othmer Encyclopedia of Chemical technology, 3rd ed., Vol22, p. 153-
4; Vol2,  p. 134; Vol 9, p. 562-3.  New York: John Wiley and Sons, 1983.

McGowan, C. and Siewert,  T., Site Assessment of a Large Blender. NIST, Boulder, CO. May
10, 1995.

McGowan, C. and Siewert, T., Inspection of P-KBlender  (Napp Technologies, Lodi, NJ, and
FortDix, NJ). NET, July and August 1995.

McLaughlin, Dr. H., Summery of Findings to Date - Napp Technologies Incident Review. Waste
Minlnc., October 4, 1995.

McLaughlin, Dr. H., Final Report - Chemical Safety Issues, Napp Technologies Incident Review.

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                                          -46-
Waste Min Inc., November 2,  1995.

NFPA 1994.  National Fire Protection Association, NFPA 49, Hazardous Chemicals Data.
Quincy, MA: NFPA, 1994.

NFPA 1993.  National Fire Protection Association, NFPA 651, Standard for the Manufacture of
Aluminum Power. Quincy, MA: NFPA 1993.

Occupational Safety and Health Administration.  Update to HazWoper Emergency Response
guidance: Coordination with Local Fire Departments. Memorandum for all Regional
Administrators. October 30, 1996.

Sage, G., Analysis ofNapp Technologies Explosion. Syracuse Research Corp. January 13, 1997.

Sax, TV and Lewis, R. Dangerous Properties of Industrial Materials. 5th ed. p. 352.
New York: Van Nostrand Reinhold.

SRI 1995.  SRI International, 1995 Directory of Chemical Producer & United States of America.
Menlo Park, CA: SRI International, 1995.

Tartani V, Contessa S.  Water influence on thermal stability of sodium dithionite.   5th
International Symposium "Loss Prevention and Safety Promotion in the Process Industries"
Societe de Chimie Industrielle, Paris, France.

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                      -47-
                  Appendix E




Photos of Napp Technologies Equipment and Facility




                 Figures 4 - 24

-------
Figure 4:  One of the top loading ports on the 150 cubic foot blender showing how the insulation
jacket is attached (weld) and access door tabs.

-------
Figure 5: Inside a PK-250 cubic foot blender, looking through top access port, the vacuum head
and spray nozzle configuration can be seen.

-------
Figure 6: The intensifier bar for a PK-150 cubic foot blender shown in its storage position.

-------
                                                                                   V
Figure 7: The gear drive and bearing that supports one side of a 150 cubic foot blender.
  Figure 8: The other side support (intensifier bar drive side) of a 150 cubic foot blender.

-------

*•€
                                            -—n-—   . «- -•—v*\.  T"""*e**-*ST, <^l"*^'4i^k:i£'*3^';*'W
                                            :^^J -. ' :^_.i->S» ,«S*iS«5^i^^J^p$«:j^


                                                                      in: •?JSi* W'''^j|^?4ar
                                                                     ^g^S
  Figure 9: The general condition of the 125 cubic foot blender: a) the top access ports and

  damaged insulation jacket, and b) the flange to which the belt drive attaches.

-------
Figure 10: Top access port: a) looking through a top port and out the bottom off-load port, and
b) close-up view of a top port.

-------
Figure  ll:The bottom off-load port of the blender was severely
damaged in the accident: a) the  stubs of the flange bolts that
the door to the port are visible,  b)  general  deformation to
water jacket and shell.

-------

-------
     t^Pi1^'S~" *' W   ~ -"."""" '***r*'\y''?*<"* "^
     ^ffi^'|^; ^-^.' ^H^
 •'-•«#
 :iS
Figure  13: The tabs  that held the  to access  port door  are bent
down  against the  stainless steel  shell.

-------
Figure 14: The insulation jacket has torn away from where it was attached to the stainless steel
shell and the access door tabs are bent over against the shell.

-------
Figure 15: The inside of the blender:  a)  area near the bettor
load port, b) just inside one of the top access ports.

-------
Figure  16: The gear drive side of the blender: a) the shaft (drive side) and b) the portion of the
gear that fractured and separated from the blender in the accident.

-------
Figure  17:  The  concrete  support and  bracket  that  secured  the
bearing on the gear drive side of the blender.
Figure 18 :  The concrete support and rollers
drive side of the blender.
                                          that supported the belt

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Figure 19:  The flange on the belt drive side of the blender: a)
bolt stubs are visible, b) the flange is bent.

-------
Figure 20: The wheel that supported the blender on the belt drive
side and  the shaft  components:  a)  the  wheel  and shaft,  b)  the
concentric  shafts  and  tube  that went  into  the' interior  of  the
blender.

-------
Figure 21: Close-ins views of the end  of the  shaft  shown in Figu
20.

-------
Figure 22: The end of the shaft, shown in Figure 20, holds the vacuum head, spray nozzle, and the
connecter for the intensifier bar shaft: a) Y-fitting where the vacuum and water spray nozzle
branch off the tube, b) the can that surrounds the vacuum head.

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Figure 23: The intensifier bar: a) the shaft of the bar is severely deformed, b) two of the mixing
plates are left, both are broken away from the shaft.

-------
Figure 24: The Napp facility after the explosion and fire showing location in the plant where the
processing took place and the location of the facility with respect to residential area in
background.

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;>EPA
    United States
    Environmental Protection Agency
    (5104)
    Washington, DC 20460

    Official Business
    Penalty for Private Use
    $300

-------