This electrochemistry case takes place in South Carolina and involves an employee of a chemical supplies plant who was involved with the operations of a large chemical reactor, which was used to produce a caustic product. The water that is recovered from the reactor during the production process is reused in the plant, while dangerous waste products are disposed of. In order to carry out the safe disposal of waste, a large and complicated network of pipes runs throughout the facility that requires constant maintenance and inspection. The decedent was preparing the pipes for cleaning purposes when a large quantity of chemical waste exploded violently, killing the worker instantly and causing significant contamination of the building. It is believed that caustic material had been dammed up in the pipes with no removal method. A number of experts with specializations in chemical explosives, forensic chemistry, equipment design, and equipment appraisal were sought to opine on the issue.
Question(s) For Expert Witness
- 1. Please explain why you're qualified to serve as an expert witness on this engagement.
- 2. (A.) Is it foreseeable that the mixture produced, which turns into a sludge before it goes outside into the holding pins, will become solid enough that a dam like effect can be created, so that absent some way of assessing whether there is a quantity of sludge sitting adjacent to the pump that is known to have to be serviced 2 or more times a year, by removal of the pump one can break the sludge dam thereby causing the gravity fed drainage system to explode onto the workers and (B.) if the pump is to be serviced shouldn't the design call for a lock out/block out valve system to prevent any danger to the worker at the time of removing the pump?
- 3. Please explain your familiarity with the design and installation of this system or systems similar to it.
- 4. Please explain your familiarity with the various block out/lock out systems which are utilized where a pump on a vertical pipe is close to or adjacent to a vertical pipe feeding it.
Expert Witness Response E-029729
I was manager of product development at a major manufacturer of Aluminum Electrolytic Capacitors. It was foreseeable that the mixture produced will become solid enough that a dam like effect can be created. In a recirculating system a lock out/block out valve system should have been utilized. During my career, I worked for a major manufacturer of aluminum electrolytic capacitors where I was in charge of new product development, electrolytes, separators, product design models, Engineering Test Lab, Analytical Lab, anodic oxidation and manufacturing processes as well as special quality issues. Currently, I consult for the electronic components and aluminum electrochemical processing industries. I am an expert in aluminum electrolytic capacitors for materials, design, manufacturing, quality, and applications engineering.