The Mount Rushmore (MORU) National Memorial in the Black Hills of South Dakota is one of the most iconic national memorials administered by the National Park Service (NPS). It is the state’s most popular attraction with about 3,000,000 annual visitors from around the world.
The carvings of MORU (Presidents Washington, Jefferson, Lincoln and T. Roosevelt) were blasted out of the smooth, fine grain granite by some 400 workers between 1927 and 1941. Each carving is about 60 feet tall on southeast side of the mountain, which is 5,725 feet above sea level and some 500 feet above the Amphitheater.
This news report from South Dakota Public Broadcasting (SDPB) provides additional background on the history and the issues.
From 1998 to 2001 and 2003 to 2009 a non-profit organization (NPO) that partners with the NPS at MORU sponsored a fireworks display on July 3rd.
The fireworks displays were fired by a professional fireworks display company and consisted of thousands of aerial fireworks up to 12” fired electrically from high density polyethylene (HDPE) mortars in above ground wood frame racks, as well as multiple tube devices (cakes) from the Hall of Records.
In February 2009, NPS staff completed an internal report that addressed concerns with the feasibility of the location of the discharge site, to the manner in which fireworks display was set up and conducted, to the challenges with a fireworks display in a forest on steep slopes, to the safety and security of the spectators, to the compliance with national fire codes, as well as Federal and state laws.
The 2010 fireworks display was cancelled based on the concerns raised in the 2009 NPS report and recent forest conditions that increased the fuel load.
On May 6, 2019, the Department of the Interior and the State of South Dakota signed a Memorandum of Agreement (MOA) “to work to return fireworks to Mount Rushmore National Memorial in a safe and responsible manner on July 3, July 4, or July 5, beginning in the year 2020”.
In July 2019, staff from MORU and Regional NPS offices as well as from the South Dakota State Fire Marshal (SD SFM) and the Rapid City Fire Department (RC FD) surveyed potential discharge sites at MORU for a fireworks display in early July 2020. The group determined there were six potential discharge sites.
On September 6, 2019 the NPS retained the Author to conduct a survey and evaluation of the potential discharge sites to comply with national fire codes and best practices, as well as Federal and state laws.
The NPS provided the Author with the information available to date and the Author researched additional public information.
The Author surveyed MORU and met with NPS staff as well as the SD SFM the week of October 7, 2019.PO) that partners with the NPS at MORU sponsored a fireworks display on July 3rd.
The Author identified five additional potential discharge sites and divided one potential discharge site (Hall of Records) into five distinct portions.
Any such Show will be different from the previous fireworks displays, which were not in compliance with national fire codes and best practices, as well as Federal and state laws.
It will be up to the Operator and Sponsor(s) to determine the entertainment value, the logistical feasibility, the public service availability, and the economic viability of a show at MORU.
FIREWORKS DISPLAY OF JULY 3, 2020
The contract was awarded after the State of South Dakota and the NPS evaluated proposals from a number of companies.
Here is a video of the show flawlessly performed by Pyro Spectaculars of Rialto, California. It was an outstanding production anywhere, but even more so given the challenges of this unique site.
NPS DECLINED SPECIAL EVENT PERMIT FOR 2021
The NPS routinely evaluates special events and this one was no different. As stewards of our national parks and monuments, the NPS is charged with preserving and protecting these treasures as well as providing for public and employee safety.
After evaluating the issues with the July 3, 2020 fireworks display, the NPA declined to issue a special use permit to conduct a fireworks event at Mount Rushmore on July 3, 2021.
The reasons cited were:
public and employee health issues with a large public gathering during the COVID-19 pandemic
objections from sovereign tribes with treaty rights to the land
the logistics with turning away tens of thousands of visitors (only guests with special event tickets are allowed to enter for the all day event of presentations, speeches and music culminating with the fireworks display) [there is only one road to the monument and normally visitors come and go throughout the day]
the environmental concerns over perchlorate contamination and potential for wildfires
an ongoing construction project at the monument.
The State of South Dakota sued the NPS claiming the decision was “arbitrary and capricious”, but the final court ruling was the NPS acted according to the law, so the special event permit denial was sustained.
What’s next for fireworks displays from Mount Rushmore in 2022 and beyond?
The construction project is completed. The COVID-19 pandemic will eventually subside. But the other three reasons the NPS declined the special event permit for 2020 have not changed; in fact these reasons were in play for all prior years and will be in play for all future years.
The NPS will continue to consider and evaluate these reasons with the various sovereign tribes, the State of South Dakota and others, but whether there will be another July 3rd fireworks display at Mount Rushmore remains to be seen.
The May 13, 2000 Enschede fireworks disaster (Dutch: vuurwerkramp in Enschede) at the SE Fireworks facility was series of three very powerful blasts, thousands of secondary explosions and subsequent fires that resulted in at least 22 deaths, including 4 firefighters.
The tragic incident injured at least 974 people, many severely, and severely damaged and/or destroyed over 400 homes and businesses.
Enschede is a small city of about 150,000 people inland located near the German and Belgian borders. That Saturday, it was an unusually hot, windy day and unusually dry for the Low Countries along the North Sea.
SE Fireworks was primarily an importer of fireworks that packaged and distributed them in Western Europe. It was located in a mixed industrial and residential neighborhood that was developed in the late 19th and early 20th century.
As is typical for many businesses in metropolitan areas in Western Europe, the compound was surrounded by a tall brick wall with a large gate to the street. Houses and small businesses were adjacent to and across from the facility.
In the early afternoon a small fire broke out at the compound. The local fire brigade responded and attacked the fire in the main building with water hoses. A crowd gathered in the street outside the compound to witness the event.
At first the fire seemed to be confined to packing materials, but then it spread to the fireworks stored in nearby bunkers. The fireworks started shooting off in many directions, resulting in even more fireworks exploding and shooting into the air.
Photos and video taken by bystanders showed one of the owners running from the facility as the intensity of the fireworks going off increased.
A powerful fireworks blast occurred shortly after he moved out of view. The fireworks continued to go off with changing intensity as the fire moved through the facility. A second and third large blast followed with more fireworks going off all around the area.
The explosions killed the 4 fire fighters who were on the scene attempting to control the initial fire. Debris, firebrand and burning fireworks from the explosions came down in the area.
One of the blasts in the reinforced concrete bunker left a 4 foot (1.3 m) deep crater that was over 40 feet (13 m) wide. The most powerful blast was felt some 19 miles (30 km) away.
The blast damage was over 400 meters from the facility, with secondary fire damage up to 1 km away. Some of the largest pieces of debris, including pieces of reinforced concrete from the bunker, landed over ½ km.
THE FIREWORKS FACILITY
The SE Fireworks facility consisted of an administrative building, a main building (reinforced concrete ) w/ 13 “bunkers” where fireworks were stored, plus a “packing room”. The main building had initially been erected for a cardboard recycling facility that serviced the nearby Grolsch Brewery.
There were also 7 MAVO Boxes (A type of portable garage) and 14 – 40′ ISO shipping containers used for fireworks storage in small groups inside the compound. The groups of Mavo boxes and ISO containers were only separated from each other by a narrow walkway.
The facility was licensed for 158,000 kilos of fireworks classified as UN0336, 1.4g. The fireworks were primarily imported from China for distribution in Western Europe.
In reality, the facility had far more fireworks in storage than what it was licensed to contain. And more importantly, it contained tons of more powerful fireworks that should have been classified as either UN0335 1.3g or UN033 1.1g, including 12″ (305mm) aerial fireworks shells and salutes (flash powder based explosives).
These larger, more powerful fireworks are typically for professional use only in many countries. They present a mass explosion hazard, in particular when there are significant quantities in one place at one time.
Fireworks that are classified as UN0335 1.3g or UN033 1.1g usually have more stringent shipping, storage and handling standards than those for fireworks classified as UN0336, 1.4g. This is because of the greater hazard they present over their smaller, less powerful cousins.
Subsequent investigation revealed the fireworks were imported as UN 0336 1.4g because they were shipped from China under INCO terms Cost, Insurance, and Freight (CIF), which means the shipper must pay for the shipment rather than the buyer. As a result, the shippers will often choose the lowest dangerous goods classification for the particular commodity because it saves them money.
The transportation system is based in large part on trust that shippers will properly classify and declare their shipments. The ocean carriers, port and customs officials, and trucking companies will accept this classification, usually without question.
Holland, like many other countries, bases their the import, port, inland shipping and storage requirements on the the shipping classifications declared by the original shipper.
Many importers knowingly will take advantage of the situation, and even encourage shippers to use the wrong classifications because it saves money. It also may allow them to sell larger, more powerful fireworks devices to the general public.
BUILDINGS & STRUCTURES
Dutch homes and buildings are primarily wood frame structures with brick facades and clay tile roofs. This was a style mandated from the 14th century to reduce the risks of large fires in the densely populated cities and villages.
Unfortunately, the powerful blasts blew the windows out in many structures and also stripped the clay tiles off many roofs. This exposed the combustible contents to the smaller, secondary explosions of the fireworks spread over the area from the blasts. The high winds and hot temperatures also exacerbated the situation with firebrand from the initial fires.
Fire fighters were initially overwhelmed by the scope and intensity of the fires. Fire brigades from around the region, including neighboring Germany responded, but it took hours to get the fires under control.
A man came forward and confessed to starting the initial fire, however his story did not add up and he was eventually cleared.
It was known that the owners sometimes demonstrated small fireworks for customers inside the compound. There were reports that this was the case that day as well, however substantiated this proved difficult.
The the normal operating procedure was to open the doors of the packing room, the bunkers, the MAVO Boxes and the 40′ ISO containers to be able to access the fireworks for the workers to put orders together for shipment to customers. This certainly was a factor in the fire spreading to the fireworks stored in the bunker with the first large blast.
The fire fighters knew there were fireworks stored at SE Fireworks. In fact, they had purchased smoke devices for training. However, they were expecting to fight a fire of fireworks that were classified as UN0336 1.4g, which are never supposed to be a mass explosion hazard.
The neighborhood street was not evacuated because the fire fighters reacted based on the information that had from the Dutch government that licensed the facility. And the Dutch government in turn relied on the documents provided by SE Fireworks from the Chinese exporters that classified the fireworks as UN0336 1.4g.
Thus the response was not what it should have been, which would be to evacuate the area and not attempt to fight fires near large quantities of explosives with a mass explosion hazard.
No matter the initial cause, or the quantity of fireworks permitted by licensed or over the license, many of the cardinal rules of explosives storage and operations, especially for fireworks which are sensitive to impact, friction, heat, spark and flame were violated:
limit the quantity of fireworks in any one place at one time
the larger and more powerful the fireworks, the father away they need to be stored from public roads and occupancies as well as from each other
keep all fireworks storage magazines protected (doors closed) unless actively coming or going
eliminate or control all potential sources of ignition
restrict, limit or control all combustible materials (grass, weeds, shipping cartons, pacing materials, etc.) in or around fireworks storage magazines
if fireworks are tested, only do so in designated areas that are safe distances from stored fireworks
have an emergency response plan in place for the types and quantities of fireworks being handled and stored at the facility
educate and train employees and first responders to the emergency plan
understand that fireworks have solid fuels and oxidizers – they do not rely on atmospheric oxygen for combustion – only large quantities of water, can have an impact on burning fireworks
only fight small fires of combustible materials that are outside of fireworks storage magazines that can be suppressed quickly
only contain fires of fireworks that are UN 0336 1.4g from safe distance
never fight a fire of fireworks that are UN 0335 1.3g or UN033 1.1g – retreat, evacuate and prepare mass explosions followed by secondary explosions and fires
In most other countries a fireworks facility with this quantity of these types of fireworks would never, ever be permitted to be in a densely populated part of a city. Instead, it would be required to be in a remote area covering dozens of acres of open, unoccupied land.
I have served on the National Fire Protection Association (NFPA) Technical Committee on Pyrotechnics since 1988. One of the Fire Codes we are responsible for is NFPA 1124, Code for the Manufacture, Transportation, and Storage of Fireworks and Pyrotechnic Articles.
I had met the previous owner of SE Fireworks and had some basic idea about the operation and Dutch regulations. It seemed incredible that a modern country like Holland could experience a tragedy of this scale.
I began to make inquiries to try to learn more and managed to make contact with officials in Holland, including fire fighters and witnesses in Enschede. I began to learn not everything was as it seemed.
In March of the following year, I visited Enschede at my own expense. I met with fire fighters, officials and witnesses, and learned more about what happened and especially why.
My paper Enschede: Lessons to Relearn was presented at the 6th International Symposium on Fireworks in Orlando, Florida in December 2001.
The M/V Hanjin Pennsylvania was a 930 foot (282 m), 50,242 metric ton container vessel with a capacity of 4,389 Twenty-foot equivalency units (TEUs) on its 5th voyage from Asia to Europe. It was loaded with as many as 8 levels of containers stowed above decks and 14 levels of containers below decks.
Holds 1-6 are in front of the accommodation (The bridge and crew quarters) and general cargo is stowed below decks. Refrigerated cargo is stowed above decks where the crew can monitor and maintain the refrigeration units, which have both electric and diesel power units.
Hazardous materials, like chemicals, batteries, fireworks, etc. are stowed above decks near the bow (Holds 1-3) so they are away from the accommodation and the machinery. This also keeps them out of the holds below decks where they are confined by the hatches and containers above decks.
Holds 7 and 8 are behind the accommodation and above the machinery for general cargo.
There were over 50 containers of declared fireworks classified for transportation purposes as FIREWORKS UN0336 1.4G on board and stowed above decks in Holds 1-3. These types of fireworks devices are typically the smaller fireworks packaged for retail sales to consumers.
These shipments were bound for sale in Europe for the New Year’s Eve holiday, although some shipments are misdeclared and should be classified as FIREWORKS UN0336 1.3G or FIREWORKS UN0333 1.1G, which would be stowed in the same manner.
THE INITIAL FIRE
About 6:00 AM local time on November 11, 2002 and 88 miles (141 km) off the coast of Sri Lanka, there was a fire in a container stowed above deck on the port side of Hold 4. Two sailors apparently attempted to fight the fire when there was an explosion. One sailor was killed and the other went missing, presumably blown overboard by the blast.
The fire then swept to other containers, including some stowed above deck in Hold 3 that contained fireworks, which began to go off as the fires reach the contents. The crew fought the fires as best they could under the circumstances and salvage tugs were dispatched to assist.
FIRES ABOARD CONTAINER SHIPS
One of the challenges with fires aboard a container vessel is the difficulty to suppress fires inside the steel containers. There is limited space between the rows of stacked containers, which are all enclosed.
As the fires spread from container to container and build in intensity, the radiant heat will ignite the contents of other containers. This often spreads the fire further and faster than fire fighting efforts can manage.
Compounding the challenge with fire fighting on container vessels is the radiant heat will also spread the fires to containers stowed below decks. And then fires will spread via radiant heat from hold to hold.
FIRES BURNED FOR 4 DAYS
Over the next 4 days the fires raged both above and below decks as tons of water were poured onto the vessel from the tugs. The ship was abandoned except for a small crew that maintained the machinery and the pumps.
Fireworks in some containers stowed above decks exploded and shot out of the containers during these fire fighting efforts. Over the days of water being poured onto the burning containers, the ship took on so much water that it settled very low in the water.
THE “FIREWORKS” EXPLOSION
Then on November 15, 2002 there was a massive explosion in Hold 6 in front of the accommodation. This explosion was so powerful it tore 30 ton hatches off their pins and tossed some of them and stacks of loaded containers into the sea.
The photos of this explosion were described as a “fireworks explosion, however it only looked like a fireworks explosion to the untrained eye.
During my investigation, I managed to obtain the manifest for this sailing that showed there were two (2) containers of magnesium ingots stowed below decks in Hold 6. The manifest also showed no containers of fireworks stowed above deck in Hold 4.
The photos and descriptions of the initial fire and explosion of the single container above Deck in Hold 4 was more like a fire and explosion of calcium hypochlorite rather than any types of fireworks devices. This is a chemical that is used to purifying water and in swimming pools and is sensitive to both heat and moisture
Calcium hypochlorite can start fires and explode, especially when confined by itself, packaging, in a steel container or any combination. Thus it requires special handling and stowage, especially when carried by a vessel sailing on the ocean subject to sea spray and rain squalls along the equator.
This special handling and stowage adds to the cost of shipping. For companies that ship calcium hypochlorite under INCO terms Cost, Insurance, and Freight (CIF), it means they must pay more to ship their chemicals to customers. As a result, there is an incentive for shippers to not declare their shipments as hazardous materials, or choose a hazardous materials classification that costs less to ship, but is not handled and stowed as required.
There are a number of examples of containers of calcium hypochlorite that experienced fire and explosions aboard other container vessels before and after the initial fire and explosion aboard the M/V Hanjin Pennsylvania. In some instances the calcium hypochlorite was declared and in others it was considered “rogue”. Subsequent investigations revealed the stability of the calcium hypochlorite varies and the way it is packaged is also an issue.
Other suspected or known fires and explosions of calcium hypochlorite aboard container vessels include: M/V Aconcagua (1998), M/V Charlotte Maersk (2010), M/V CMA Djakarta (1999), M/V Contship France (1997), M/V DG Harmony (1998), M/V KMTC Hongkong (2019), M/V Maersk Mombasa (1998), M/V Mass (1997), M/V Recife (1991), M/V Sea Express (1998), M/V Tiger Wave (1997), and the M/V Zim Haifa (2007).
Maersk one of the largest ocean shipping carriers in the world, banned the transport of calcium hypochlorite in August 2015. Bans alone do little to prevent hazardous materials from being misdeclared because the system relies on the integrity of the shipper to properly classify and declare their cargos.
The M/V Hanjin Pennsylvania was declared a total loss and general average was declared. General average is a method of spreading the loss out to all of the parties, even if their cargo was untouched.
The vessel was towed back to Singapore for the final survey and damage assessment. Sound containers were unloaded and surveyed for internal damage, including most of the containers of fireworks. These are auctioned off to the highest bidders, with with the proceeds used to offset the loss.
The financial loss was $235 million, which was the highest maritime loss up to that point in time. The hull was eventually refurbished and sailed for various ocean carriers until 2016 when it was scrapped.
Shortly after the incident, I was commissioned by the National Fireworks Association (NFA) as an independent expert to investigate the cause and submit a report with my findings. I was dispatched to Singapore where the vessel had been towed for salvage. I surveyed the vessel from a small boat and some of the containers in Singapore, including the surviving containers of fireworks.
I also met with various officials and others to gather information. The process of a ship being salvaged and the payment of damage claims is very interesting to say the least!
Later, I spent a month visiting shipping and fireworks facilities and met with officials in Seoul, Shanghai, Beijing, Liuyang, Changsha, Guangdong, Hong Kong and Los Angeles in order to trace fireworks shipments from the factories through the supply chain to ports in the USA.
The report has been referenced by a number of organizations and agencies including Lloyds of London and the Formal Safety Assessment (FSA) submitted by Denmark to the International Maritime Organization (MTO) Maritime Safety Committee in September of 2009.
M/V Hanjin Pennsylvania: Explosions at Sea
M/V Hanjin Pennsylvania: Explosions at Sea PICTURES