United States
        Environmental Protection
        Agency
                 United States
                 Occupational Safety and
                 Health Administration
November 1998
www.epa'.gov/ceppo/
&EPA
         EXPERT REVIEW OF
         EPA/OSHA JOINT
         CHEMICAL
         ACCIDENT
         INVESTIGATION
         REPORT

         Napp Technologies, Inc.
         Lodi, New Jersey
EPA and OSHA
                         Printed on recydedpaper

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                                            -1-
                      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 hi 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
 operatioa 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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                                             -11-
                                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 nearbv
 Saddle River.                                                                           J

        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 hydrosuffite 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
       iailures 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-lnqd 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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                                           -iii-
       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 fire brigade members and emergency responders was inadequate. Napp fire
       brigade members were not trained to respond to the type of emergency that occurred.

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

       Facilities need to My  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-

                                   Table of Contents
                                                                                 Page
 1.0   Background	1

        1.1    Facility Information	1

        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




B
.Results of Analysis of the Accident




Chemical Reactions 	
C      Accidents Involving Sodium Hydrosulfite and Aluminum




D      References	



E      Photographs of Napp Technologies (Figures 4-24)	
34




37




41




45




47
                              List of Figures and Exhibits
Figure 2
FisureS
Exhibit 1
Fisure 3A
P-K Blender 	
Intensifier Bar 	 	
Timeline of Events 	 	 	
Vacuum Svstem 	 	
	 4
	 	 6
	 11
	 14

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                                             -1-
   1.0    Background
         .1.1    Facility Information

         The Napp Technologies, Lie. (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
  AGR 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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                                             -3-
  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.

         Accordingto 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 disclosure from Technic
  of prior explosions, uncontrolled reactions or other accidents that had previously occurred durins
  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
SSFSKS
                                                    GEAR DRIVE/COVER
                              FIGURE  2

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                                             -5-

         Patterson-Kellev 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), Na^A,  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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                        INTENSIFIER  BAR/VAnilll^  HEAP
                                       SPRAY HEAD
  VACUUM TUBE ASSEMBLY
GRAPHITE SEAL
APPROXIMATE LOCATION
                     APPROXIMATE LOCATION
                     OF INTENSIFIER BAR
                     PACKING GLAND
FIGURE  3

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                                            -7-

  (spontaneously combustible material), Packing Group H  Packing Group n 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 hi proper proportions and exposed to a small amount of ignition energy, will
 bum 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 hi 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 E  ("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 3 52) 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 \viih -water to ensure complete -wetting, as this procedure
                           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 fire fighting 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 then- 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
  contaminatioa 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 hi 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 a.m. on April 20, as part of the precharging verification, operators made a final check
 to assure the blender was ready (i.e.5  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 o'n 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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                                                                        Exhibit  1
                                                               Timeline of Events
                                               April 21,1995  Explosion  of Blender
                                              at  Napp Technologies,  Inc.  - Lodi, NJ
 April 19,10:30 pm
 Shift supervisor
 conducts process
 review
     April 20,3:30 am
    Two operators
    dry blander of
    drops of moisture
    on top of Intensifies
    bar assembly.
    Vessel dry before
    loading
        Operators Inert
        blender and start
        loading
        components of
        QPA
           New shift
           operators arrive,
           given a process
           hazard review by
           supervisor. They
           recommence
           loading of the
           blender at
           approximately
           8:00am
              Operators smelted
              "vanllla-llke"odor
              and observed
              water In liquid
              feed tank, line, and
              niter
                  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 splashed
with "stinky"
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
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 lagged out.
Pressure gauge
on blender
replaced with
open nipple
and Nitrogen purge
rate Increased
Vice President for
Regulatory Affaire
directs shift
supervisor to
unload Ihe
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
                     S employees
                     killed; 4
                     employees Injured;
                     area evacuated;
                     Fluoresceln In
                     flreflghting runoff
                     into Saddle River
                     and sanitary
                     sewers
                     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 a.m. 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 (IP A) into the liquid feed tank and
blew inert nitrogen through the tanks and lines into a bucket forcing the IP A 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 3 A). 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 IP A 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 p.m., 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
burns 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 aniinal" smell upon initially entering the PK-125 room. This employee also observed and
smelled the liquid from the separator bowl which had  been collected hi 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-
                                                    #1
FIGURE 3A: TYPICAL VACUUM COLLECTION SYSTEM AS SUPPLIED
BY PATTERSON-KELLEY. # I  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 hi 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 hi 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 hi 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 a.m., 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 burns 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 hi 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  fire 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 fire 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 overpressures, 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.

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                                            -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.                                                                       6

        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 atmosph.
      humidity could have been a source of water.
:enc
      The intensifier bar moving at a high speed through dry powders my have been a source of
      fiictional heat.

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

     Deviations from Napp's Expected Maintenance and Operating Procedure.;

     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.

  At 3:30 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 hi 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, hi 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
hi 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 Cm 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 from 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 pnor to this accident. Based on this history and an evaluation of the chemical components
or the GPA, the JCATT 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 JCATT 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
==================:=======:
Water
Water
Water
Water
Water
Water
Water
Water
Heat
Heat
Possible Source
'
Water used to clean blender/inadequate drying
Water used to clean liquid feed line
Leak of coolant from blender jacket
Moisture from raw materials
Water in nitrogen
Atmospheric humidity entering blender
Water in liquid feed tank
Water-cooled seal failure
Shear from intensifier bar through dry powder solids
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 JCAIT 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 hi 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
 Mure 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 bv shear of intensifier bar moving through drv 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 hi
 the blender, the JCAIT believes a large hydrogen gas bubble would have been formed,  causing a
 detonation with greater energy then was released hi 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 tune (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 JCATT can not rule out that any water  hi the liquid feed fine 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 hi 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" hi 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 hi 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 Mowing the accident, members of the JCATT 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 foUowini
   months  the JCATT 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
  JGAIT concludes that the root causes and contributing factors of this accident are:

                                        i conducted and appropriate preventive actions were not
An inadequate ha;
  Icen.
  .nn* ^°Ug^   PP- $ af  ? repOIt "^ hterviews ^A 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
  etmnt,; :   7 "* J™* ******* but not necessarily^^ hazards information.   For
  o^S o If "f nnation 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).
                              ***** Procedure using «» MSDSs, Napp noted that aluminum,
 no,           '    •*      6re WEter reSCtiVe- H°Wever> *** Proced"re «* *e MSDSs^S
 not reveal or address accident history, identify and account for all of the potential sources of water
 ways to e iminate or control these sources (engineering safeguards or procedures), recognition of
 water con animation of the raw materials or GPA, the immediate steps necessary to stop orhandle
 an unwanted reaction inside the blender, and the proper technology^ desig? of ^equipment
 nS7^Sf^ y    f^lQfy Wend WatCr reaCtive Substances" * additiot the procedure dfd
 not identify that heat could also have an adverse affect on the substances in the blender  Without this
 information, appropriate prevention actions were not taken.

       Napp juccessfully conducted the blending operation previously  (1992) using  the same
p ocess, procedures, and equipment and was unaware of any major accidents involving 4 proTct
or process. However, Napp did not appear to know about, or at least consider the consequences of
past accidents that have occurred involving sodium hydrosulfite 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 operating 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 procedure's, 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
          information.
                                                           Dlenderwasjbass
          The lack of a complete understanding of the chemical and process hazards led to a lack of

             °l^CT °?6 C°nditi0nS PreS6nt St the *"• «***«• -entered the S%
      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 poi£ where employTes wefe

   to"SK tehCT °/thMUlfor SmeU COminSfr°mthe^^ At *>time*> decisi°°™S
   to unload the blender, Napp was aware of, and  concerned for, the strong possibility of a fire
   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 handing proces
  eouinm               Pff       al6 °r C°ntrol SOUrces °f water but elected  to'"* blending
  equipment that incorporated sources of water in the design (water cooled seal, water/glycol jacket)
  Ahhough regular maintenance of seals and cooling jackets helps to prevent failure  and leakage Se

            ° in ?TT *£ 6XiStS' ""?** "^ t0 C°ntaminate the Wender- The iSum
              in their brochure Recommendations for Storage and Handling of Aluminum Powders
             rTT™S ? mbdn§ 8lUminUm P°wder ^ other ^ -^dients, SonTS
              ^  tH   ^ ** °MbIender f°r a diy "^^ operation is one that conSisTo
              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
  mtensifi er bar for mixmg.  Shear from the movement of the intensifier bar through the
  may have been a source of foctional heat. In addition, particulate matter betweS
  at the intensifier bar shaft in the packing gland area may have been a source

        Communications between Napp and Technic were inadequate
 cnmn             ^Onmifucation between N^PP and Technic also contributed to the lack of a
 complete understanding of the process hazards and their consequences. There is no standard I or"
                           m ^ ^ ^^^^^nding industry which specifically
                          into hazard reviews at the toll manufacturer's faculty
of its
                                                  isin *e best position to know the hazards
                                      Technic contracted with Napp to perform the blending
                                                  "d me finished product and a batch
                                                   infoimation but generaUy do not
                                 -  ™S bvestiSation ^wed that Napp did not possess
mfonnation necessary to make sound judgements regarding the responses to deviations
no°ttrrh   bIendiDS?roceSS- ,NaPP,is » ^ chemical processing' industry; h^N    &
not have m-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, aU
 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 clarify 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) fists 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.

 OSHA 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
 itsHazWoper 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 hems: 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 utilising 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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                                            -33-

safety professional to train Napp Safety Council members (including supervisory, technical and
employee representatives) to perform their duties effectively; 4) create an SOP institutionalizing
review.all facility processes to identify those that should undergo a more detailed process hazard
analysis; and 5) designate a responsible management official whose primary responsibility will be to
oversee Napp's safety and health program, worker health and safety issues and compliance with
applicable health and safety standards.

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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 explained 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 MIST 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 from 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/fomes 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 Hvdrosulfite
        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 hydrosulfite, which then ignited when tipped over for disposal. In another
  case (Bretherick 1990), 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 (NajSjOJ with water can produce sodium bisulfite (NaHSO3)
  and sodium thiosulfate (NaAOJ (Equation 1).  Because sodium bisulfite is an unstable solid
  compound (Kirk-Othmer 1983), it most likely decomposes to sodium metabisulfite (Na^Os) and
 water (Equation 2).  Sodium metabisulfite may then decompose to sodium sulfite (NajSOs) and sulfur
 dioxide (SOj) (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.
       (1)    2Na2S204 + H20-2NaHS03+Na2S203

       (2)    2NaHS03 -* NajSA + H2O
 (3)
                                  SO2 + S
       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)
                                           SO

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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 frictional 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 hydrosulfite/aluminum/water reaction.

  Aluminum

        Aluminum is a strongly electropositive metal and is very reactive, burning rapidly hi 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
 hi 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, hi its reaction
 with chromic oxide, molten chromium (melting point 1907C) is formed. Thermite-type reactions may
 also occur with non-metals such as sodium hydrosulfite, 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 + 3SO2   2A1A + 3S

                     2Al + Na2S2O4   NajO + A12O3 + 2S

       The heats of reactions at 25C are -615.3 kJ/mol Al and -428.9 kJ/mol Al, respectively.1

       In another case, butanol  attacked  an aluminum  gasket  at  100C, liberating hydrogen
(Bretherick 1990). Other alcohols would react similarly. Benzyl alcohol is produced by the reaction
of benzaldehyde with sodium hydrosulfite. 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 exothermic 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.

Calorimetrv 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 hi the mixture provided a
substantial increase hi the amount of heat released during the decomposition.
       1The 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 (Na^C^, 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 Hvdrosulfite

       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 hydrosulfite with water and
generation of sulfur dioxide. Exhibit C-l below provides short descriptions of some accidents
involving fires, 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
1 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
4/1/95
3/24/95
6/14/94
3/23/94
3/5/92
1 1/28/90
11/6/90
6/9/90
Description
Large fire may have resulted from tank
leaks that caused the mixing of crude
sulfate turpentine and sodium hydrosulSte.
Drums containing sodium hydrosulfite
exploded (no details available).
A small chemical fire was reported in a
storage drum containing sodium
hydrosulfite.
Water, possibly from a roof leak, hit a 30-
gallon drum of powdered sodium
hydrosulfite, generating fiimes.
Drum of sodium hydrosulfite came in
contact with moisture and began giving off
sulfur dioxide. Several gallons of water
were used to dilute chemical.
A 35-gallon drum filled with sodium
hydrosulfite burned.
A spill of 5,000 pounds of solid sodium
hydrosulfite led to a release of sulfur
dioxide.
A frailer of sodium hydrosulfite caught fire.
Effects on People
— 	 — 	 B 	
None reported
6 lolled, 5 injured I
None reported
4 workers injured, 12 [I
evacuated II
8 people (company staff)
evacuated
2 firms evacuated 1
1 1 workers injured
1 6-block area evacuated;
no injuries 	 	 |j

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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
11/11/85
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
35-gallon drum in the parking lot.
Driver of truck carrying drums of sodium
hydrosulfite noticed one on fire. Water was
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 evacuated
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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                                           -43-    _,
                                 Exhibit C-l (continued)
Location
Dye plant, Leicester,
Leicestershire, UK
Penang, Malaysia
Avonmouth, Avon, UK
Date
10/16/85
11/24/80
6/10/80
Description
Water got into a drum of sodium
hydrosulfite, which ignited, giving off
poisonous fumes.
A vessel carrying 4,800 drums of sodium
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.
A truck containing 160 drums of sodium
hydrosulfite overturned. Heavy rains
caused severe problems.
Effects on People
1 injury, evacuation
reported, residents
complained
None reported
42 people injured
 Sources: Newspaper reports (on-line literature search), United Kingdom's Major Hazard Incidents Data Service
     .  (MHEDAS) database, EPA's Accidental Release Information Program (ARJP) 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
Glass factory, Pittsburgh,
PA
Aluminum flake
processing plant, Darwen,
Lancashire, UK
Date
9/4/93
9/91
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
I Aerojet industry,
1 Sacramento, CA
Truck on highway, VA
Newburgh,IN
Darwen, Lancashire, UK
Mixing plant, Eaton
Township, OH
I! Aluminum powder
1 company, Gwynedd,
Anglesey, UK
I Chemical works, Widnes,
Cheshire, UK
Aluminum works.
I Hermillion, France
1 Albany, CA
Metalwork plant,
1 Chicago, IL
Date
7/26/91
7/24/91
5/16/90
3/27/89
7/2/86
7/16/83
2/6/83
2/2/80
1/23/78
4/16/53
Description
A compound of potassium perchlorate and
aluminum powder exploded.
Aluminum powder ignited while being
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
fines and dust to be dispersed in the air.
Welding sparks ignited the dust, creating a
fireball.
An exothermic reaction occurred in an
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 plant, lifting the roof off. The
cause of the explosion was unknown.
Explosion in powder collection system sent
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
'lant demolished by fire following dust
explosion ignited by polishing machine |
Effects on People
1 worker cut and
seriously burned
None reported
1 worker injured
None reported
8 workers injured
5 people injured
1 person killed
None reported
1 person injured
35 people lolled, 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-
                                      AppendixD

                                       References

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


  Bretherick's Handbook of Reactive Chemical Hazards, Fourth edition,  pp. 20-32, 633, 1385
  1810-2. London: Butterworths 1990.                                 -     '


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

  Dean,J. Lange's Handbook of Chemistry. 13thed.  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 Powder.  Draft October 13, 1995.

 ICF, Inc., Analysis of Process Issues and Chemical Reactions Concerning the Accident atNapp
 Technologies, Inc. inLodi, NJ. Draft October 16, 1995.


 Kirk-Othmer 1983.  Kirk-Othmer Encyclopedia of Chemical technology, 3rded  Vol 22 p 153-
 4; Vol 2, p. 134; Vol 9, p. 562-3. New York: John Wiley and Sons, 1983.

 McCowan, C. and Siewert, T., Site Assessment of a Large Blender. MIST Boulder  CO  Mav
 10, 1995.                                                               '


 McCowan, C. and Siewert, T., Inspection ofP-K Blender (Napp Technologies Lodi  NJ, and
Fort Dix, NJ). MIST, July and August 1995.

McLaughlin, Dr. H., Summary of Findings to Date - Napp Technologies Incident Review Waste
Min Inc., 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 Powder. 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 of 'Napp Technologies Explosion. Syracuse Research Corp. January 13, 1997.

Sax, N 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 Producers, United States of America.
MenloPark, 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 Chirnie Industrielle,  Paris, France.

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                     -47-
                 Appendix £




Photos of Napp Technologies Equipment and Facility




                 Figures 4-24

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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.

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Figure 5: Inside a PK-150 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.

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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.

-------
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.

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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.

-------
   -load port  Qf the blender
:  a) the Stui3s of the
 severel
that Sid

-------
Figure 12: The striation markings on the top access ports.

-------
Figure 13: The  tabs  that held the top 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 bottom off-
load port, b) ;just inside one of the top access ports.

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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 that supported the belt
drive side of the blender.

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£- '
•* , _
Figure 19: T3ie flange on the belt drive side of the blender:  a)  the
bolt stubs are visible,  b)  the flange is bent.

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                                 •*.?•    <_x —: >\".    ..•;  ,  •-.-.  %r -.
                                 -\~" ~i .--'•' ""'  .->,---^-'  -  ^.'- t  ' >-'N--..;

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.

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

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                                          *»    - .-*r-
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.

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Figure 24: The Napp facility after the explosion and fire showing location in the plant where the
           0  P    and ±Q 10Cati°n °f ^ fadH£  Wl                     areat

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