The Oklahoma City Bombing Trial Transcripts
Terry Nichols
Wednesday, November 5, 1997 (afternoon)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Criminal Action No. 96-CR-68
UNITED STATES OF AMERICA,
Plaintiff,
vs.
TERRY LYNN NICHOLS,
Defendant.
REPORTER'S TRANSCRIPT
(Trial to Jury: Volume 64)
Proceedings before the HONORABLE RICHARD P. MATSCH,
Judge, United States District Court for the District of
Colorado, commencing at 1:35 p.m., on the 5th day of November,
1997, in Courtroom C-204, United States Courthouse, Denver,
Colorado.
Proceeding Recorded by Mechanical Stenography, Transcription
Produced via Computer by Paul Zuckerman, 1929 Stout Street,
P.O. Box 3563, Denver, Colorado, 80294, (303) 629-9285
APPEARANCES
PATRICK RYAN, United States Attorney for the Western
District of Oklahoma, 210 West Park Avenue, Suite 400, Oklahoma
City, Oklahoma, 73102, appearing for the plaintiff.
LARRY MACKEY, SEAN CONNELLY, BETH WILKINSON, GEOFFREY
MEARNS, JAMIE ORENSTEIN, and AITAN GOELMAN, Special Attorneys
to the U.S. Attorney General, 1961 Stout Street, Suite 1200,
Denver, Colorado, 80294, appearing for the plaintiff.
MICHAEL TIGAR, RONALD WOODS, ADAM THURSCHWELL, and
JANE TIGAR, Attorneys at Law, 1120 Lincoln Street, Suite 1308,
Denver, Colorado, 80203, appearing for Defendant Nichols.
* * * * *
PROCEEDINGS
(Reconvened at 1:35 p.m.)
THE COURT: Be seated, please.
Yes, Miss Wilkinson.
MS. WILKINSON: Your Honor, as to the exhibit,
Government Exhibit 1702B, I showed it to Mr. Tigar, and he
agreed -- we had the agent circle the portion and initial it.
THE COURT: You mean physically on that.
MS. WILKINSON: Yes, instead of the computer
printout -- we fixed the problem -- and he's agreed this would
be admissible.
MR. TIGAR: We agreed subject to all of the other
things we talked about it, it would be admissible.
MS. WILKINSON: Excuse me, your Honor.
THE COURT: What is the designation?
MS. WILKINSON: The number?
THE COURT: Yes.
MS. WILKINSON: 1702B.
THE COURT: Thank you.
(Jury in at 1:35 p.m.)
THE COURT: Members of the jury, we do have now 1702B
which is a little photograph of this one that you will recall,
1702, that was marked by the testifying agent didn't come out
right on the machine, so we got the picture, and he just marked
it physically, and we've taken it into evidence.
I mention a Polaroid, I oughtn't to be using a trade
name like that. I guess Kodak and some other Instamatics. But
you know what I mean.
Our next witness, please.
MR. MACKEY: As our next witness, we would call
Mr. Paul Rydlund.
THE COURT: All right.
THE COURTROOM DEPUTY: Would you raise your right
hand, please.
(Paul Rydlund affirmed.)
THE COURTROOM DEPUTY: Would you have a seat, please.
Would you state your full name for the record and
spell your last name.
THE WITNESS: Paul Harris Rydlund, R-Y-D-L-U-N-D.
THE COURTROOM DEPUTY: Thank you.
THE COURT: Miss Wilkinson.
MS. WILKINSON: Thank you, your Honor.
DIRECT EXAMINATION
BY MS. WILKINSON:
Q. Good afternoon, Mr. Rydlund.
A. Good afternoon.
Q. Could you tell the jury where you live.
A. St. Louis, Missouri.
Q. How old are you?
A. 59 years old.
Q. And what is your profession?
A. I'm a mining engineer.
Q. What has been the focus of your professional employment
over the past years?
A. I have been involved in the development and the uses of
ammonium nitrate in the commercial explosives industry.
Q. How long have you been doing that?
A. I've been doing that for 34 years.
Q. Where do you currently work?
A. I currently work for El Dorado Chemical Company in
St. Louis, Missouri.
Q. How long have you worked for them?
A. I've worked for them 13 years.
Paul Rydlund - Direct
Q. Can you tell us what El Dorado Chemical Company sells.
A. El Dorado Chemical Company is involved in both industrial
and agricultural businesses. In the industrial business, they
sell industrial acids such as sulfuric acid, weak nitric acid,
strong nitric acid. In the industrial business as well, we
sell industrial ammonium nitrate to the explosive industry, and
we also sell a number of explosive products directly to the
mining industry as well.
Q. What type of explosive products do you sell to the mining
industry?
A. We sell blasting agents such as ANFO. We sell high
explosives such as dynamite, water gels, high-explosive
emulsions. We sell detonators such as electric blasting caps,
non-electric blasting caps.
Q. Now, could you briefly tell us about your educational
background. Where did you attend university?
A. I attended the University of Missouri at Rolla, and I have
a bachelor of science and a master of science in mining
engineering.
Q. When did you obtain those degrees?
A. In 1963 and 1965.
Q. When you were in school, did you concentrate on explosives
at any time?
A. Yes, I did.
Q. What did you do?
Paul Rydlund - Direct
A. In my graduate work, I worked on the development of
ammonium nitrate for commercial explosives. This was done
under a project that was funded by Monsanto Company. And so I
was a graduate assistant and worked on that project.
Q. You said Monsanto funded that project?
A. Yes, they did.
Q. Where did you work after you left school?
A. After I left school, I went to work for Monsanto Company.
Q. Is that a coincidence --
A. No. I continued to work on that same project then.
Q. What did you do for them initially?
A. I spent five years in research in which we analyzed and
evaluated the uses of ammonium nitrate in commercial
explosives.
Q. And --
A. And then after that, I went into the operations and
marketing of industrial explosives.
Q. During your time with the company and your subsequent
experience, have you become familiar with the chemical
properties and the explosive capabilities of ammonium nitrate?
A. Yes, I have.
Q. Now, tell us how long you were involved in operations.
A. I was involved in operations for a period of five to eight
years.
Q. During that time did you become familiar with the
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manufacturing process of ammonium nitrate?
A. Yes, I did.
Q. Did you also become familiar with the common practices
throughout your industry?
A. Yes, I did.
Q. After you finished working in operations, what did you do?
A. Then I became involved in marketing, field marketing of the
products and field use of the products.
Q. And how long did you work for Monsanto?
A. I worked for Monsanto for 19 years.
Q. What happened to them at that point?
A. It -- after 19 years, Monsanto sold that business to a
company in Oklahoma City called LSB Industries, and they formed
El Dorado Chemical Company.
Q. And have you been employed by them ever since?
A. I've been employed by El Dorado Chemical Company ever
since.
Q. What did you do for El Dorado when you first joined their
company?
A. I was a director of industrial explosive group.
Q. What did you do in that capacity?
A. In that capacity I directed the marketing and the technical
use of the products.
Q. How long did you do that?
A. I did that up until 1992 at which time I was named vice
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president.
Q. And that's what you're doing today?
A. That's my current capacity.
Q. Could you tell us what your general duties are as vice
president.
A. My general duties are again to direct both the marketing of
our industrial acids and our industrial explosives group.
Q. During your 33 or 34 years in the commercial explosives
business, have you become involved with any professional
societies?
A. Yes, I have.
Q. Tell us about that.
A. I am a member of the Society -- I'm sorry, American Society
of Mining Engineers and also the International Society of
Explosives Engineers.
Q. How long have you been a member of those organizations?
A. Well, I've been a member of the Society of Mining Engineers
for about 30 years, I believe. And on the International
Society of Explosives Engineers for about 15 years.
Q. In your capacity as vice president, are you a member of any
professional safety associations?
A. Yes. I am currently serving as the chairman of the board
of governors for the Institute of Makers of Explosives, which
is a safety organization for the explosive industry.
Q. That's who they represent?
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A. Yes.
Q. And what are you doing in that position as the chairman?
A. As chairman of the board of governors, basically I preside
over the decisions of the board. But basically our basic work
there is to recommend or suggest regulations as to the safe
handling, use, transportation, and manufacture of industrial
explosives.
Q. So from that experience and from your other experience in
your business, are you familiar with the safety standards for
manufacturing, storing, handling, and using ammonium nitrate as
well as other explosives materials?
A. Yes, I am.
Q. Now, during your career, can you tell the jury a little bit
about the type of field experience you've had.
A. In the field -- the field experience I've had has been to
design blasts, evaluate blasts which would go into how many
pounds should we load into the blast hole, how should we
initiate the blast hole, what type of high explosives should we
use and what sequence should we use in shooting the individual
blast holes to provide the best breakage in the mine.
Q. Does your experience in the field include the mixing of
explosive products?
A. Yes, it does.
Q. Have you ever, yourself, mixed explosives?
A. Yes, I have.
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Q. Do you know how many times?
A. Well over a hundred times.
Q. Have you ever observed the detonation of ammonium nitrate
and fuel oil?
A. Yes, I have.
Q. Have you observed the detonation of ammonium nitrate and
other types of fuels?
A. Yes, I have.
Q. Do you also review literature to keep current in your
field?
A. I do.
Q. Tell us about that.
A. I review a number of periodicals, magazines as well,
resulting in improvements in industrial explosive business.
Recently authored a section on ammonium nitrate for the
International Society of Explosives Engineers' handbook on
blasting.
Q. In your career, have you had the opportunity to visit other
manufacturing facilities of other chemical companies that
compete in your market?
A. Yes, I have.
Q. Tell us which facilities you have visited.
A. I have visited the ammonium nitrate manufacturing facility
of ICI in Joplin, Missouri. And I have visited the ammonium
nitrate manufacturing facilities of DynoNobel in Louisiana,
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Missouri, and Donora, Pennsylvania, and I have visited the
explosive manufacturing facility of Austin Powder in McArthur,
Ohio.
Q. Are those some of the major competitors of El Dorado?
A. They are major competitors, yes, they are.
Q. Let's talk a little bit about ammonium nitrate. Can you
tell us what ammonium nitrate is.
A. Ammonium nitrate is a compound made out of ammonia and
nitric acid.
Q. Can you tell us: Is all ammonium nitrate the same?
A. Chemically, yes. Physically, no.
Q. What do you mean by that?
A. In the solid form, ammonium nitrate comes in basically two
forms: A very dense, a very dense particle size, and then it
also comes in a more porous particle size.
Q. And are there terms, common terms, used to refer to those
two types of ammonium nitrate?
A. Yes. The very dense or tightly packed product is called
high-density ammonium nitrate, and the porous material is
called low-density ammonium nitrate.
Q. And do you distribute those two different products to two
different type of customers?
A. Yes, we do.
Q. Tell us about that.
A. The high-density ammonium nitrate is sold into the
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agricultural industry.
Q. Why is that?
A. And because of the density of the product and the ability
of the product to spread evenly with other ingredients, with
other compounds used in the fertilizer industry such as potash
and phosphates.
Q. You said you also -- you, your company manufactures
low-density ammonium nitrate?
A. Yes, we do.
Q. Is that true? And you're familiar with that process?
A. Yes.
Q. And who is the typical customer for the low-density --
A. That is used in the explosive business.
Q. Are you aware of the practices in your industry about
distributing low-density ammonium nitrate?
A. Yes.
Q. And has there -- are there costs that you incur in terms of
distributing ammonium nitrate?
A. Well, yes. There's of course the manufacturing cost and
then the transportation cost to take the ammonium nitrate to
the market.
Q. Is that one of biggest costs you face?
A. Transportation is a very major cost in the distribution of
ammonium nitrate.
Q. Based on that, is it a practice within your industry to
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sometimes distribute low-density ammonium nitrate to the
agricultural community?
A. Yes, it is. Because there are lower costs, there could be
lower costs in doing so.
Q. Explain that, would you --
A. If the -- in a particular instance -- as an example, I
would use Joplin, Missouri -- there is a very good agricultural
market, particularly around Springfield, Missouri, that is
close to Joplin, and the Joplin plant makes low-density
ammonium nitrate, but they can cost that material into this
agricultural market, they have a pretty good cost because there
is very little transportation between the two locations. So
there are opportune times when that practice is used.
Q. Could you tell us in what form ammonium nitrate is
manufactured?
A. Ammonium nitrate is manufactured in a form that's called a
prill. P-R-I-L-L.
Q. What's a prill?
A. A prill resembles a miniature snowball. It's a glomeration
of ammonium nitrate crystals that are packed into just like a
miniature snowball. A prill is about 1 millimeter, 125th of an
inch in diameter. And it's spherical in shape.
Q. Can an ammonium nitrate prill or a group of prills be used
as an explosive?
A. No. No. Not by themselves, they cannot be.
Paul Rydlund - Direct
Q. And what do you need to make ammonium nitrate prills an
explosive?
A. You would need a sensitizer or a fuel such as fuel oil or
there are other fuels available that are used, nitromethane,
for instance.
Q. Now, is there a term for ammonium nitrate -- if you're
going to combine it to make it an explosive with fuel, is there
some term that you use?
A. ANFO is a term that's used for when you combine ammonium
nitrate with fuel oil.
Q. Is there a term for just the ammonium nitrate if you're
going to combine fuel, which you call a sensitizer, I
believe -- is there a term used to refer to the ammonium
nitrate?
A. As a blasting agent when we call the two of them, yes.
Q. Are you familiar with the term "oxidizer"?
A. Yes.
Q. What is that?
A. An oxidizer is a material that when -- well, ammonium
nitrate is an oxidizer, and an oxidizer is a material that when
it undergoes decomposition, particularly if it was burning, for
instance, it readily releases its own oxygen, so if you had
ammonium nitrate and it was burning, and you tried to put out
the fire or dump dirt on it, you couldn't cut off the oxygen
because it produces its own oxygen.
Paul Rydlund - Direct
Q. Before coming to court today, did you prepare an exhibit
that will demonstrate the manufacturing process for ammonium
nitrate, for low-density ammonium nitrate, used as an
explosive?
A. Yes, I did.
Q. And look on your computer screen, if you could, at
Government's Exhibit 674. Do you recognize that?
A. Yes, I do.
Q. Is that the chart that you prepared?
A. That is the chart that I prepared.
MS. WILKINSON: Your Honor, we'd offer Government's
Exhibit 674 as a demonstrative exhibit.
MR. TIGAR: No objection, your Honor.
THE COURT: All right. 674 is received as a
demonstrative exhibit.
Which means, members of the jury, simply that it's
used to illustrate or demonstrate the testimony. The document
itself is not evidence. It is useful to explain the testimony.
BY MS. WILKINSON:
Q. Mr. Rydlund, you told us that once ammonium nitrate is
manufactured, it usually comes out in a prill form; is that
right?
A. That's correct.
Q. Can we start on the left side of the chart and let me zoom
in here. And tell the jury how ammonium nitrate is
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manufactured.
A. See if I can work this.
Q. You need to go down underneath.
A. I'm sorry.
Q. There you go. You don't need to press the button; just use
the pen.
A. Okay. Okay. Ammonia and nitric acid are combined in a
reactor to produce an ammonium nitrate solution. The solution
is pumped to an ammonium nitrate solution storage tank. At
this point the solution has 10 percent water in it.
Q. And why is that important?
A. That is important because we're going to go through part of
the process that is going to remove the water from the solution
and put it into a solid.
Q. Okay. Let's move on to that. Here's the next portion of
the chart.
A. From the tank we put the material -- the solution into a
evaporator where an additional seven parts of water are
removed. And from the evaporator, we put -- we pump the
material to the top of the shot tower. Now, the shot tower
looks just like a big silo, it's about 200 feet high. And at
the top of the shot tower is a series of spray nozzles or
shower heads. And so the liquid ammonium nitrate is pumped
through the shower heads and what emerges is a liquid droplet.
And as the droplets fall down the shot tower, solid ammonium
Paul Rydlund - Direct
nitrate crystals are formed within the droplet until we get to
the bottom of the shot tower where all of the droplet is now
made up of solid ammonium nitrate crystals. It's spherical in
shape. It resembles, again, a miniature snowball, a millimeter
in diameter, and this is what we call a prill.
Q. Is there another part of the processing that must occur?
A. Yes. Because now the prill is still a 2 1/2 percent
moisture in it, and it's not very strong and it's not very
durable. And that wouldn't -- because we're going to have to
handle this and store it, we need to make it -- we need to make
it stronger.
Q. Okay. Let's go to the final portion of the chart. Tell us
what happens in this last phase.
A. So what we do is we take the material to a series of dryers
and a cooler, and at this point we have removed the moisture
and strengthened or made the prill more durable.
Q. And down there at the bottom, it says there's a coater?
A. Yes.
Q. Why do you coat the prills?
A. When we get to this point, when we're out of the coater,
we've gone to all of this trouble to make the prill strong and
durable and take the moisture out. And so what we don't want
to do is to have the ambient moisture from the air come back
and weaken the prill. I mean we've already gone through all of
this to make it strong. So now we want to keep the humidity
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from the air out of the prill. So what we do is we place it in
a coater and in the coater we spray on a surfactant, liquid
surfactant or a surface acting agent, which basically coats the
outside of the prill which will repel or disperse the humidity
or ambient moisture in the air and then for good measure we add
talcum powder to give us added protection.
Q. And all the steps you just described, the coating and the
talc, are to protect the ammonium nitrate crystals?
A. They are to protect the ammonium nitrate crystals in the
prill from the humidity in the air, yes.
Q. Now, before coming to court today, did you also gather a
sample of low-density ammonium nitrate prills?
A. Yes, I did.
MS. WILKINSON: Your Honor, may I offer this to the --
show this to the witness?
THE COURT: Yes.
BY MS. WILKINSON:
Q. You see Government's Exhibit 675?
A. Yes, I do.
Q. Is that the sample that you collected?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer 675 for
demonstrative purposes only.
MR. TIGAR: No objection, your Honor.
THE COURT: All right. 675 is received for
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demonstrative purposes.
BY MS. WILKINSON:
Q. Mr. Rydlund, could you hold up 675 and tell the jury what
we're seeing in that little jar?
A. Okay. 675 is a small jar of ammonium nitrate prills. The
prills are slightly off-white in cover -- color, I'm sorry.
Spherical in shape, and about 1 millimeter or again 125th inch
diameter in diameter. And they're free-flowing.
Q. Now, once you've completed this manufacturing process and
they've been coated, what do you do with the ammonium nitrate
prills?
A. From that point, we either ship it in bulk or we package
it.
Q. So they're ready for storage and distribution?
A. That's correct.
Q. Let me ask you to tell the jury a little about the effects
of humidity vs. water on ammonium nitrate prills and let's
focus on the low-density ammonium nitrate prills.
A. Okay.
Q. Once these prills are coated, what effect, if any, does
humidity have on ammonium nitrate prills?
A. In fact, the purpose of coating the prills is to prevent
the humidity from attacking the prill, from weakening the
prill. So the coating, the surfactant and the talcum powder,
are to resist or repel the humidity in the air.
Paul Rydlund - Direct
Q. So if ammonium nitrate prills are exposed to humidity,
would they stay intact or would you expect them to
disintegrate?
A. No, the prills would stay intact if exposed -- excuse me --
if exposed to humidity. Now, if they were exposed to humidity
over months and months, we would see some changes in the
structure of the prill.
Q. Could the prill break down into crystal form?
A. The prills could take -- they could break down and cake.
The crystals would reorient themselves, and what we might see
is that instead of free-flowing prills, we might see more of a
hard mass, caking of the prills.
Q. All right. Now, let's talk about the effect of water on
ammonium nitrate prills. What would happen to ammonium nitrate
prills if they were -- they came in direct contact with water?
A. They would dissolve. Ammonium nitrate is very soluble in
water. 200 parts of ammonium nitrate will dissolve in 100
parts of water. And relative to that, let's say table salt,
320 parts of table salt per hundred parts of water, so it will
give you an idea of the relative solubility of ammonium
nitrate.
Q. Let me ask you this. If ammonium nitrate prills were on a
surface that was protected from water, from direct contact with
water but was in the same area as humidity or water, what would
you think would happen to those prills?
Paul Rydlund - Direct
A. Again, depending upon the humidity and the time involved,
the prills would either stay intact or they would probably
reorient themselves and break down into crystals.
Q. Now, once you have these ammonium nitrate -- low-density
ammonium nitrate prills ready for distribution or storage, how
do you store them?
A. Well, again, sometimes they are stored in bulk bins. Many
times they are packaged in 50-pound bags or 80-pound bags,
packaged in multi-wall paper bags, or they're sometimes
packaged in plastic bags.
Q. Mr. Rydlund, can you look inside that clear plastic bag,
and do you recognize Government's Exhibit 69?
A. Yes, I do.
Q. Is that one of the bags you just described for the jury?
A. This is a multi-wall paper bag that I just described, yes.
MS. WILKINSON: Your Honor, we'd offer Government's
Exhibit 69 for demonstrative purposes only.
MR. TIGAR: May I just look at it, your Honor.
THE COURT: Yes, come forward and do so.
MR. TIGAR: Thank you.
Thank you, sir.
THE WITNESS: Sure.
Thank you, Mr. Rydlund.
Excuse me.
No objection, your Honor.
Paul Rydlund - Direct
THE COURT: All right. 69 is received for
demonstrative purposes.
BY MS. WILKINSON:
Q. Mr. Rydlund, let's start with the outside of the bag, and
if you can turn it to the jury and explain to them what's on
the top of that bag, the markings.
A. This is the name of the company, Atlas Powder Company.
The address.
This is the name of the parent company, ICI
Explosives.
This is the name of the product, ammonium nitrate
fertilizer.
These three numbers down here, 34, zero, zero
represent the nitrogen, potassium, and phosphorous contents of
what's in this bag. So at this 34, zero, zero, zero (sic),
that means there's 34 percent nitrogen, no phosphorous, and no
potassium. Now, those numbers are important to the
agricultural community because those three elements are very
important to crop growth.
It says, "Prills, 50 pounds net weight," which is the
weight of the bag.
This yellow diamond is a warning label for oxidizers.
The flame represents that when the material decomposes, it will
release its own oxygen.
This number down here, UN1942, is the United Nations
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classification for ammonium nitrate, and what it means is
ammonium nitrate is less than .2 percent combustibles
calculated as carbon which is a long way of saying ammonium
nitrate with less than .2 percent fiber.
Q. You can take your seat.
Now, look at the inside of that brown ammonium nitrate
bag.
A. Yes.
Q. And can you tell the jury if that's the multi-wall paper
bag that you've described.
A. This is a multi-wall paper bag, yes.
Q. What is the purpose of that type of lining?
A. The multi-wall paper bag basically consists of several
walls of paper. But you notice within the walls of paper is a
mil and a half of a high-density polyethylene in it. And this
polyethylene lining in here is to prevent the ambient humidity
from the air from entering the product.
Q. Go ahead and sit down. You told us that's an ICI product;
is that right?
A. This is an ICI bag, yes.
Q. Bag. And you've been to the ICI plant?
A. Yes.
Q. Are you familiar with the practice ICI used in 1994 of
selling the low-grade explosive-quality ammonium nitrate in
bags such as that as fertilizer?
Paul Rydlund - Direct
A. Yes. They sold low-density ammonium nitrate in bags such
as this for agricultural purposes.
Q. And because it was low density, would that make it have
more of an explosive capability?
A. It would have more of an explosive capability because the
prills, the low-density prills as such, could readily combine
with fuel oil.
Q. If someone were to purchase bags, sealed bags, of this
ammonium nitrate low-density prills and store it for several
months in a cool climate, let's say they purchased it in the
fall and they opened it in the spring, what -- what, if any,
impact or effect would there be on the prills?
A. I would expect the prills to continue to be free-flowing
and intact just like this.
Q. Even if they were stored in a storage shed?
A. Yes.
Q. You've told us that low-density prills -- and you can just
put that down, if you like, so you don't have to hold onto it.
You told us that low-density prills are better for
making an explosive; is that right?
A. That's correct.
Q. And that's because they're more porous and they absorb --
A. They will readily combine with the fuel oil. So that, yes,
they will readily combine with the fuel oil because porosity
has room for the fuel oil to absorb into the prill.
Paul Rydlund - Direct
Q. Did you ask that a photograph be taken of a low-density
ammonium nitrate prill so that you could explain this concept
to the jury?
A. Yes, I did.
Q. Could you look at your screen and see if you recognize
Government's Exhibit 678.
A. Yes, I do.
Q. Is that the photograph that you caused to be taken?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer Government's
Exhibit 678 for demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: Received for said purpose.
BY MS. WILKINSON:
Q. Mr. Rydlund, tell the jury what they're looking at.
A. This is a photograph taken with an electron scanning
microscope of a half a section of just one of these prills.
Now, because the prill itself is only about 1 millimeter in
diameter, this has been magnified well over a hundred times.
This is the surface of the prill. Does that --
Q. Is your pen working?
A. I'm not sure I'm doing this.
Q. Are you pressing up against the --
A. Yeah.
Q. There you go. You're still in the box. There you go.
Paul Rydlund - Direct
A. There, I got it, okay. Well, that's bad.
Here, this out here -- I'm not very good at this.
Q. I don't think it's your fault. The pen works sometimes and
it doesn't work the others. Why don't you just describe to the
jury.
A. Okay. On the surface, about -- we see the surface of the
prill, is the exterior of the picture. And that is the surface
of the prill. The white gray areas within that surface are the
ammonium nitrate crystals that were formed in the prilling
process and are packed inside the prill. Now, the dark areas,
the dark black areas within there are the paths and valleys
between the crystals, between, and that accounts for the
porosity in the prills so that when fuel oil is combined with
this prill, the fuel oil enters through these paths and
valleys, is dispersed and retained in there.
Q. Let me show you Government's Exhibit 681.
Now, did you collect a small fuel oil sample for
purposes of demonstrating the effect of mixing ammonium nitrate
with fuel oil?
A. Yes, I did.
Q. Is that what Government's Exhibit 678 is?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer it only for
demonstrative purposes.
MR. TIGAR: No objection.
Paul Rydlund - Direct
THE COURT: All right. Received. What's the number,
678?
MS. WILKINSON: 681, I'm sorry, your Honor.
THE COURT: 681, you said?
THE COURTROOM DEPUTY: 681.
THE COURT: Well, what's on that, Mr. Rydlund?
THE WITNESS: Oh, I'm sorry. Put my glasses on.
Sorry.
681.
THE COURT: Thank you.
BY MS. WILKINSON:
Q. I'm sorry, Mr. Rydlund, I didn't give you the right number.
Now, can you hold up 681?
A. 681.
Q. And tell the jury what's in it.
A. This is simply No. 2 fuel oil. Just like we would burn in
a diesel engine in a truck. It's just simply No. 2 fuel oil.
And this is the fuel oil that is used to add to ammonium
nitrate to make ammonium nitrate fuel oil or ANFO mixtures.
Now, for illustrative purposes, only, I've added a red dye in
this fuel oil so it shows up a little better. That's what this
is.
Q. Okay. Now, would one need to actually mix fuel oil into
the ammonium nitrate to ensure that it would be an effective
explosive material?
Paul Rydlund - Direct
A. Actually, they combine very easily. As a practice in the
mining industry, what we do is we blow ammonium nitrate prills
into a bin this way and then inject fuel oil another way so
that there's no mixing, it just combines as it goes up into the
bin.
Q. So if someone would pour ammonium nitrate into a barrel and
then fuel oil, would they need to do any kind of mixing?
A. Not really; it would disperse.
Q. How long would it take to disperse?
A. Oh, depending on the temperature and everything, probably 5
to 10 minutes.
Q. For purposes of demonstrating what you've just described,
did you cause photographs to be taken of a sole prill -- a
prill by itself and a prill when you added fuel oil?
A. Yes, I did.
Q. Okay. Let me show you Government's Exhibit 682. Is that
the photograph you caused to be taken?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer 682 for
demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: Received. May be shown.
BY MS. WILKINSON:
Q. Now, tell the jury about the prill on the left and the
prill on the right.
Paul Rydlund - Direct
A. The prill on the left, on the left is ammonium nitrate.
That's a half section. Again, that's just a half section of
one of these ammonium nitrate prills.
On the left is ammonium nitrate fuel oil or ANFO. And
what's happened there is that the fuel oil has been added to
the ammonium nitrate, and then we've taken a half section of
one of those prills. And the point there is you can see,
again, from the color -- and we've added the red dye in there
to show the color -- how evenly the fuel oil disperses in the
ammonium nitrate prill.
Q. Now, what if you mixed some other kind of fuel with
ammonium nitrate? For example, a nitromethane, would you have
the same absorbency?
A. With nitromethane, yes, uh-huh.
Q. Now, once you mix ammonium nitrate with a fuel, either fuel
oil, nitromethane or some other type, what do you have?
A. Well, basically in that particular case you would have a
blasting agent or in some cases, considering the amount of
nitromethane that could be added, you could conceivably have a
high explosive.
Q. Let's start with ammonium nitrate and fuel oil. What's the
common name for that mixture?
A. It's called ANFO.
Q. Does your company manufacture that?
A. Yes, we do.
Paul Rydlund - Direct
Q. Can it also be made by individuals?
A. Yes, it can.
Q. How difficult is it to make ANFO?
A. Actually it's very simple. It's just taking ammonium
nitrate and adding fuel oil.
Q. How much fuel do you need to mix in with ammonium nitrate
to make it into ANFO?
A. The optimum amount is 6 percent fuel oil, 94 percent
ammonium nitrate. That is the theoretical optimum efficiency.
Q. Can you mix different amounts and still have the ANFO
become a blasting agent?
A. Yes, you can. Within a certain range.
Q. Now, can you use other types of fuel to mix with ammonium
nitrate to make a blasting agent?
A. You could use nitromethane in limited quantities to do
that. You could use sugar. You could use other things that
have a fuel value that would provide carbon and hydrogen to the
mixture.
Q. Could you use a combination of fuels like fuel oil and
nitromethane with the ammonium nitrate?
A. Yes, you could.
Q. Now, you said you could mix sugar with ammonium nitrate.
Do you have to do anything to the ammonium nitrate once you mix
it -- or before you mix it with sugar to make it a explosive?
A. Well, if we took granulated sugar or solid sugar as we see
Paul Rydlund - Direct
it, yes, because the sugar particles wouldn't be able to work
themselves into the prills. So to get an intimate mixture, we
would have to crush and grind ammonium nitrate and the sugar
and then mix that.
Q. Have you read a book called C-4?
A. Yes, I have.
Q. In that book does it recommend grinding ammonium nitrate?
MR. TIGAR: Excuse me, your Honor, unless we have some
indication that this is a source customarily relied on, that
he's an expert in the field, I object to just quoting from the
book.
MS. WILKINSON: My understanding is there's a
stipulation about this book.
THE COURT: I believe the question being raised here
is whether this witness with his expertise recognizes that book
as being authoritative.
MS. WILKINSON: That wasn't the purpose of me asking
the question, but let me ask a few more questions.
THE COURT: All right.
BY MS. WILKINSON:
Q. Now, Mr. Rydlund, C-4 is not a book that you normally rely
on for your business, is it?
A. No.
Q. And are you aware of where that book came from, C-4? Do
you know anything about the book C-4?
Paul Rydlund - Direct
A. I've read the book, that's it.
Q. Do you know what the purpose of the book C-4 is?
A. According to the way the book was -- according to what I
read in the book, it was to provide a recipe for manufacturing
a homemade explosive that had the strength of C-4.
Q. Were you asked to read that book --
A. Yes, I was.
Q. -- before coming to court today?
A. Yes, I was.
Q. And were you asked to determine whether the mixtures
described in that book could make an explosive?
A. Yes, I was.
MS. WILKINSON: Your Honor, based on that, I would
like to ask him the question about grinding.
MR. TIGAR: Sure. No objection, your Honor.
THE COURT: That cleared it up for you?
MR. TIGAR: Yes, it did clear it up.
THE COURT: All right.
BY MS. WILKINSON:
Q. In that book that purports to tell its readers how to make
homemade C-4, does it recommend grinding ammonium nitrate?
A. Yes, it does.
Q. What would be the purpose of grinding ammonium nitrate?
A. The purpose of grinding that ammonium nitrate was to -- the
purpose of grinding that ammonium nitrate was to be able to mix
Paul Rydlund - Direct
or absorb a amount of nitromethane that was greater than the
porosity of the prills would allow.
Q. And then what would happen once those ammonium nitrate
prills were ground and the nitromethane was added?
A. In the amounts that they were -- in the amounts that the
book suggested, then you would have a high explosive.
Q. Now, to mix ammonium nitrate with nitromethane, do you have
to grind it?
A. No.
Q. So was it your understanding or is it -- what is your
opinion about the recommendations in the book, in C-4, that say
grind the ammonium nitrate and mix it with the nitromethane?
A. Well, in the book, if you wanted to make -- in the book
what they did was to grind the nitro -- was to grind the
ammonium nitrate and to add a large amount of nitromethane,
greater than of course, the porosity of the prills. However,
you could take ammonium nitrate prills and add nitromethane to
the prills as well. But you couldn't make a high explosive by
adding the ammonium nitrate (sic) to the prills. You could
make a blasting agent.
Q. You mean you couldn't add it -- the nitromethane with the
prills by itself is not an explosive; is that what you're
saying?
A. It would not be a high explosive. It would be a blasting
agent.
Paul Rydlund - Direct
Q. What else would you need to detonate --
A. To detonate that, you would need a high explosive such as
dynamite, TNT, high-explosive water gels such as Deta-Gel,
Tovex, a number of things like that.
Q. So if you had those components, then, you could detonate
ammonium nitrate and --
A. Right, the prills without grinding them and nitromethane
contents of 25 to 30 percent, I think like it talked about.
Q. Let's go back to ANFO. Is that -- you said your company
manufactures ANFO?
A. Yes.
Q. Is that a popular product in the commercial industry?
A. Yes, it is.
Q. Why is that?
A. Because it's very safe to handle. It is very -- it is very
safe to handle because it is not high explosive and so for
handling and transportation, it's relatively safe. It is very
energetic, it provides good energy when it's detonated; and
it's very economical.
Q. Now, let's turn to the actual detonation of ammonium
nitrate and a fuel oil. You told us you cannot do that if you
have ammonium nitrate prills and a fuel oil, you need something
else to actually detonate the explosive --
A. Yes.
Q. -- is that right?
Paul Rydlund - Direct
A. Uh-huh.
Q. Can you tell us what "detonation" means.
A. "Detonation" is a very violent, very, very violent chemical
reaction that takes place within the explosive material itself.
There is a tremendous amount of energy released, and the reason
this is is because the products of the reaction, what comes out
of the reaction, the gases that comes out of the reaction, the
volume of them is so much -- so much greater than the volume of
the explosive material itself.
Q. You also said that one would need a high explosive to
detonate that; is that right?
A. Yes.
Q. What is a high explosive?
A. Well, again, a high explosive is a material that can be
initiated or detonated with simply the use of a blasting cap or
a detonator.
Q. Did you bring a photograph to court today that would assist
you in explaining what occurs inside an explosive when it
detonates?
A. Yes, I did.
Q. All right. Let me show you Government's Exhibit 692. Is
that the photograph?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer Government's
Exhibit 692 for demonstrative purposes.
Paul Rydlund - Direct
MR. TIGAR: I'm sorry, your Honor. I was looking at
an exhibit.
No objection.
THE COURT: 692 is received.
BY MS. WILKINSON:
Q. Now, you just told us what detonation was.
A. Yes.
Q. Can you tell us how it's depicted here in Government's
Exhibit 692 and what we're looking at.
A. I can. What we are looking at is a stick of dynamite
undergoing detonation. And this may be a little -- if this
pen's not working, it may be a little more -- but there is the
unreacted dynamite. This is the material that's undergoing
reaction, the dynamite here.
Right here -- here we go -- right here; right at the
edge of that cloud is the detonation front. And this is the
detonation front that's consuming the material. This
detonation front moves very fast. It's moving through the
dynamite at 16,000 feet per second or 3 miles a second.
Right behind the detonation front, right in here, this
area -- boy, this thing -- right in here is what we call the
chemical reaction zone. And this is a very violent, energetic
reaction zone. This is where the dynamite is reacting to
produce the products. Inside this zone, the pressures will be
a million pounds per square inch. The temperatures will be
Paul Rydlund - Direct
6,000 degrees Fahrenheit. And it's this chemical reaction zone
that drives the reaction that consumes the dynamite.
This cloud up in here, these are the gases that are
the products of reaction of the chemical reaction zone. These
gases are very hot, they're under high temperatures, and
they're expanding very, very rapidly. This is a -- and right
at the edge along here is a shock front that leads -- that
leads the gases.
Again, and in looking at this picture, this picture
was taken with a very, very high-speed camera, that this thing
happened so fast, at 16,000 feet a second, you couldn't see it
with the naked eye.
Q. Are you familiar with the term "velocity of detonation"?
A. Yes, I am.
Q. What does that mean?
A. "Velocity of detonation" is the rate at which the
detonation front moves through the explosive. And at this
case, the velocity of detonation, this particular dynamite,
which is characteristic of the way a detonation front will move
through it, is 16,000 feet per second or again 3 miles a
second.
Q. So is that the speed of the explosion inside the material?
A. Yes, it is. Yes, it is.
Q. Do you know the range for the velocity of detonation for
ammonium nitrate and fuel oil?
Paul Rydlund - Direct
A. The velocity of detonation for ammonium nitrate and fuel
oil will vary according to the size of the charges and how well
they are initiated by the high-explosive booster, but typically
the velocity of detonation for ammonium nitrate fuel oil will
range anywhere from 16,000 feet per second to 9,000 feet per
second.
Q. What about the detonation -- or the range I guess I should
say -- of the detonation velocity for ammonium nitrate and
nitromethane?
A. Well --
Q. Again, sticking to prill ammonium nitrate, not ground?
A. For prilled ammonium nitrate, nitromethane, where we would
have nitromethane content somewhere in the neighbor of about --
just in prills, in the contents of 12 percent nitromethane,
let's say, we would have velocities of around 16 to 17,000 feet
per second.
Q. Now, you told us that if you mixed fuel oil with ammonium
nitrate, you need about 6 percent; is that right?
A. Right.
Q. And how much nitromethane do you need if you mix with
ammonium nitrate?
A. Optimum, the optimum amount, theoretical optimum amount for
mixing ammonium nitrate to nitromethane is close to 40 percent.
The optimum amount. The problem with that is that ammonium
nitrate won't absorb 40 percent of nitromethane, not even as
Paul Rydlund - Direct
prills, but even in the ground state. But the optimum amount
would be 40 percent.
In the ground state where the material is ground, the
optimum amount it could hold is somewhere around 25 to
30 percent.
Q. Let's assume you had a lower amount of nitromethane mixed
in with the ammonium nitrate. Could you still cause it to
detonate?
A. Yes.
Q. And what would you need to do to cause it to detonate?
A. You would need a high-explosive booster to do that.
Q. So you could make up for that optimum range --
A. Oh, sure.
Q. -- by -- by using a significant booster?
A. Uh-huh.
Q. You just told us about what happens when a material
explodes, what happens inside. Are there other effects that
occur outside?
A. Yes, there are.
Q. And did you review a chart before coming to court today
that explains the detonation and what occurs outside the
explosive?
A. Yes, I did.
Q. Look at Government's Exhibit 691, please. Is that the
chart?
Paul Rydlund - Direct
A. This is the chart.
Q. Would that assist you in explaining the detonation
phenomenon to the jury?
A. Yes, it would.
MS. WILKINSON: Your Honor, we'd offer 691 as a
demonstrative exhibit.
MR. TIGAR: No objection, your Honor.
THE COURT: Received for that purpose.
THE WITNESS: The detonation -- it's shown before the
detonation produced these rapidly expanding gases. So this
yellow in here are the high-pressure gases that are moving out
into the air. The -- right here at the edge is a shock front
that precedes the gases as they move out. And again, right in
the area of the detonation, back in here, we're looking at
pressures of a million pounds per square inch and 6,000 degrees
Fahrenheit.
Now, the supersonic shock front and the gases as they
move out, it's moving out at about 13,000 miles per hour, and
that kind of gives you the speed, for instance, of how the
shock front moves out. Now, what we feel or what we see is
this -- as these gases are moving out, consumed with this shock
front, it's almost like a giant tidal wave that just smashes
and shatters objects in its path. And so as it goes out, it
moves all the air out and is shattering and smashing these
objects in its path. But just like the tidal wave, at some
Paul Rydlund - Direct
point in time, it moves so far out and it expends all its
energy in moving all this air out that it loses strength and
eventually the pressure behind -- the pressure of these gases
return to normal atmospheric pressure.
BY MS. WILKINSON:
Q. And did you create another chart to explain the time phases
that you've just described?
A. Yes, I did.
Q. Let me show you Government's Exhibit 693. Does that show
the time phases of the blast wave?
A. Yes, it does.
MS. WILKINSON: Your Honor, we'd offer 693 for
demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: Received.
THE WITNESS: This illustrates the strength or the
pressure of this blast wave with time. Now, on the vertical
ordinate, we have pressure, and on the horizontal ordinate is
time. Now, as soon as the detonation goes off, we have this
shock front right up here at the front, the blast wave, and
this shock front provides like a real hammering or striking
effect to anything in its path. And then right behind it is
the compressive shock wave due to the gases that are coming
out. And these gases are like they put on a very violent push
to any object in its path.
Paul Rydlund - Direct
But again as we move out and move out and the energy
is expended in moving the air out, the strength of the pressure
of the shock wave declines until it reaches normal atmospheric
pressure. But now what's happened is we've moved all of this
air out so there's nothing in here. It's a void. It's like a
vacuum. So now what happens is that the air is violently
sucked back into this void, and we have a negative pressure
wave or a suction wave, and instead of the striking and
hammering and the pushing, now we have kind of like the pulling
of the objects so that what you have when a blast wave hits an
object, it's kind of like a dynamic one, two punch; you strike,
hammer, and then you violently push and you come right back and
then you pull on the object. And it's that pulling that causes
the windows to shatter and the walls to topple.
BY MS. WILKINSON:
Q. And would a blast have that effect on any object in close
proximity?
A. Oh, yes, it would.
Q. Now that you've told us about how detonation occurs, can
you tell us a little bit about what you need with ammonium
nitrate and fuel oil to actually make it detonate?
A. Yes.
Q. Okay. Let me show you Government's Exhibit 689. Is this a
chart that you've reviewed before coming to court that helps
you explain that? Can you see it? Hold on.
Paul Rydlund - Direct
A. Yes.
MS. WILKINSON: Your Honor, we'd offer 689 for
demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: You may -- it's received, you may use it.
BY MS. WILKINSON:
Q. Mr. Rydlund, this says four-step explosive train. Can you
tell us what that means.
A. Yes, it means -- this four-step explosive train tells us --
it's a diagram that tells us what it's going to take to
detonate, explode an ANFO charge. Our main charge is ANFO.
This is the objective. We want -- we want to be able to
detonate this charge. But because it's not a high explosive,
it requires a high-explosive booster, such as dynamite or TNT
or other products that we mentioned before. And so over here,
we have the high-explosive booster that we're going to need to
detonate that in turn will have to detonate the ANFO.
Now, to initiate the high-explosive booster, we're
going to need a detonator, like a blasting cap. And that's
going to shoot the high explosive. And to initiate the
detonator, we're going to need some type of energy to initiate
the detonator.
Q. Let's start with No. 4 in the ANFO main charge, I think you
called it. On this diagram, could that be any type of
ammonium -- could that be ammonium nitrate mixed with any type
Paul Rydlund - Direct
of fuel --
A. It could be.
Q. -- that you discussed previously?
A. It could be, as long as it was a blasting agent.
Q. Okay. And if you had a large amount of ammonium nitrate
and fuel, would you need some type of container?
A. Only to --
Q. To hold it.
A. Yes, to configure the charge, yes, uh-huh.
Q. And now let's turn -- I think you mentioned that you need
some kind of detonator; is that right?
A. We would need a high-explosive booster and a detonator,
yes, you're right.
Q. Now, look at Government's Exhibit 685.
A. Yes.
Q. Does this depict blasting cap?
A. Yes, it does, it depicts electric blasting cap.
MS. WILKINSON: Your Honor, we'd move in 685 for
demonstrative purposes only.
MR. TIGAR: No objection.
THE COURT: Received.
THE WITNESS: An electric blasting cap is a -- is a
cylinder with anywhere from about 1 to 3 inches long and about
a quarter of an inch in diameter. The objective of the
blasting cap is to detonate the base charge, PETN, that's in
Paul Rydlund - Direct
the cap.
BY MS. WILKINSON:
Q. What is PETN?
A. Pentaerythritol tetranitrate.
Q. Easy for you to say, but what it is?
A. It's a high explosive.
Q. And that's the high explosive you need to detonate the
booster --
A. Yes.
Q. -- and the main --
A. That is correct, yes.
Q. Now, this says electric blasting cap. What does that mean?
A. Okay. Here's how we make -- here -- the objective to
detonate the high-explosive base charge. Here's how we go
about doing it. We have a pair of electric wires are connected
to the cap. And electrical current is fed through these
electric wires in the cap, and they pass through a small --
they pass through a small bridge wire, and they pass through a
small bridge wire.
Now, this bridge wire is like the filament in a light
bulb so that as electricity goes through, it gets very hot and
it glows. And so as this thing -- as this bridge wire glows
and gets very hot, it ignites a very sensitive flash charge in
the cap. And this flash charge in turn goes around and
initiates a less sensitive but more powerful intermediate
Paul Rydlund - Direct
charge, which is right here and right there.
And then the intermediate charge is strong enough to
detonate the PETN high-explosive charge in the cap.
Q. So Mr. Rydlund, within this small blasting cap, you have a
series of little explosions --
A. There are three different explosives materials in the cap,
each one to progressively detonate to explode the PETN-based
charge, yes.
Q. Is there another system other than an electric blasting cap
that could be used to detonate a explosive?
A. There is another system other than electricity and these
are non-electric systems as well. There are non-electric
detonators as well.
Q. Okay. Let's look at Government's Exhibit 686. Is this a
diagram of a non-electric blasting cap?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer 686 for
demonstrative purposes only.
MR. TIGAR: No objection, your Honor.
THE COURT: Received.
BY MS. WILKINSON:
Q. Mr. Rydlund, briefly, could you tell the jury how a
non-electric blasting cap works.
A. Non-electric blasting cap, again I have a cylinder, we have
one to 3 inches long and quarter inch diameter to the cap. And
Paul Rydlund - Direct
again the idea is to detonate the base charge of the PETN in
the cap, which is the high-explosive material. Rather than
using electricity as we did in the electric cap, this time
we're going to use safety fuse, and safety fuse is inserted in
this portion of the cap. Okay.
The spit of the flame from the safety fuse will hit
this ignition or flash charge, will ignite this ignition or
flash charge, which in turn will initiate a less sensitive but
more forceful intermediate charge, which will detonate the
PETN-based charge.
Q. So for this system to operate, you need some safety fuses;
is that correct?
A. Yes, you do.
Q. Please look at Government's Exhibit 687. Is that a diagram
of safety fuses?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer 687, again for
demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: Received.
THE WITNESS: Safety fuse looks like a rope. It's
sold in spools of about a thousand meter a spool, and it looks
just like a rope. On the inside of it; right here in the
middle; right -- anyway; right in the middle of the black spot;
right in the middle is an inner core of black powder. Okay.
Paul Rydlund - Direct
That's about a fourth of a gram per foot of black powder that's
within the core of the safety fuse. And that's what accepts
the flame. Other than that, we have the -- we have some rayon
and textile wrappings about the core, and then there's a wax
finish on the surface of the rope.
But the idea of the safety fuse is to go ahead and to
ignite the inner core of black powder. Now, unique to safety
fuse is that this inner core of black powder is a very
controlled burning rate. And so if you want to turn around and
say, okay, I want, I want so many -- I want to light the safety
fuse here and I want the flame to come out here in so many
minutes, then you can determine and calculate what length of
fuse you need. And conversely, if you decide I want to light
the safety fuse and then I need so many minutes to retreat to a
place of safety, then you can determine the lengths of safety
fuse that you would need.
BY MS. WILKINSON:
Q. Is commercial safety fuse easy to obtain?
A. Yes, it is.
Q. Now, let's say you had a couple minutes that you wanted to
take to get away from the scene of an explosion and you used
safety fuse and this non-electric blasting cap that you're
talking about. If you cut the sufficient amount of safety
fuse, how would you actually detonate the explosion, how would
you start the four-train process you've been describing?
Paul Rydlund - Direct
A. Well, again, in the -- again to do this safety fuse, safety
fuse burns at a rate of about, for instance, in this particular
case, it burns at a rate of 2 minutes for every 3 feet of
safety fuse. So if you wanted 10 minutes of time, you would
use 15 feet of safety fuse.
Q. And how would you light the safety fuse?
A. Okay. Safety fuse can be lit with a flame, a match. Or
there are other commercial products available that will provide
a flame to light the safety fuse.
Q. So if you had all the components you described, including
the safety fuse, to actually detonate the bomb, all you would
need was a flame?
A. Yes.
Q. Now, are there other types of initiators that you're
familiar with?
A. There are other types of non-electric initiators, yes.
Q. And let me show you what's been marked at Government's
Exhibit 141. You recognize that?
A. Yes, I do.
Q. And are you familiar with the system that's depicted in
Government's Exhibit 141?
A. Yes, I am.
MS. WILKINSON: Your Honor, we offer 141 for
demonstrative purposes only at this time.
MR. TIGAR: Yes, your Honor, no objection.
Paul Rydlund - Direct
THE COURT: All right. 141 received for such
purposes.
BY MS. WILKINSON:
Q. Mr. Rydlund, what is the name of this initiating system?
A. Okay. This particular system is a non-electric system, and
it's a shock tube system, and this particular -- is called a
shock tube system and this particular product is called a
Primadet.
Q. Let's start with the orange tubing. What is that?
A. The orange tubing is the shock tubing.
Q. What's shock tubing?
A. Okay. And shock tubing is that instead of a inner core of
black powder where flame burns through it, this particular
tubing is dusted -- and it's hollow tubing. It's dusted with
a high explosive HMX, but it's just dusted. 1 pound of HMX
goes into a hundred thousand feet of tubing. So it's just
dusted.
So you introduce a shock at one end of the tubing, and
then the shock travels through the tubing until it comes out
the other end into the blasting cap. And it's just like a dust
explosion. And so it travels at about -- this shock travels in
the tubing at about 6500 feet per second.
Q. What's at the end of that orange tubing?
A. At the end of it -- at the end of an orange tube is a
non-electric blasting cap, just like we looked in the fuse cap,
Paul Rydlund - Direct
only instead of having the spit of the flame ignite the flash
charge, the shock from the tubing will initiate the
intermediate charge, which in turn will detonate the PETN-based
charge.
Q. Okay. Take a look at this white piece of paper that's
around the shock tube. What do you call that? It has the
markings on it that says Primadet. What is that called?
A. The system for the Primadet where it says 60 feet?
Q. No, I'm talking about the sleeve, I guess. Is that called
a sleeve?
A. Sleeve, yes.
Q. Holds the Primadet?
A. Yes, the extension -- it's wrapped like an extension cord,
and the sleeve is the mechanism to hold it so it doesn't become
all tangled up.
Q. And is that how it's commonly sold?
A. Yes, uh-huh.
Q. Now, it says "Primadet" there on the left, and it says
"60 feet" on the right. What does take indicate?
A. 60 feet indicates the lengths of tubing.
Q. You mean the orange shock tube is 60 feet long?
A. The orange stock tube is 60 feet long.
Q. Do you see on the side of these tubes are little tags that
say eight?
A. The tags that say eight indicate that the delay mechanism
Paul Rydlund - Direct
or the delay that is built into this system, into this
particular cap. And this eight refers to a delay of
200 milliseconds. And the reason that in some caps they would
put a delay element in so that we can -- so that when we shoot
a whole bunch of caps, a whole series of caps at the same time,
every one of them wouldn't go off at the same time in a
commercial blast. And by sequencing the times as when the
shots go off, we can produce a better energy absorption into
the rock and better breakage and less violence.
Q. Now, tell us why someone would buy Primadet for commercial
purposes.
A. For commercial purposes, well, in this particular case,
it's a 60-foot Primadet. That means it goes into a blast hole
that's almost 60 feet deep, and the cap would go down at the
bottom and be placed in a high-explosive booster. So this
would be used where you would have a hole that's close to
60-foot deep.
Q. Can you get Primadet that's shorter or longer?
A. You can.
Q. Would there be any reason to buy 60-foot Primadet to blow a
stump out?
A. No.
Q. Why is that?
A. Well, the -- for blowing the stump, you would -- I mean the
60-foot lead on the Primadet, it wouldn't offer you any ability
Paul Rydlund - Direct
to go to safety. You'd only be 60 feet away from the stump.
And that's -- that's too close. You certainly wouldn't want to
do that.
And because it shoots at 6500 feet per second through
the tubing, I mean you have no -- I mean, you're there, boom,
and that's it. So it doesn't offer you enough distance to be
able to do that. And if you were going to use it, you would
have to add, hook something onto the end of the tubing to be
able to get far enough away.
Q. Okay. But normally you use this tubing to go down a hole
60 feet?
A. It's strictly a commercial product, and frankly it's used
for blast holes that are almost 60 feet deep.
Q. What about a time delay of eight, would there be any reason
for someone who wanted to blow a stump out to use a time-delay
system?
A. No. No.
Q. Why is that?
A. Because basically you're looking to instantly shoot the
powder under the stump.
Q. Now, let's go to the last part of the train and go back to
Government's Exhibit 689.
A. Yes.
Q. You said that if we have a safety fuse and some kind of
detonator, which I assume are those blasting caps you talked
Paul Rydlund - Direct
about; right?
A. Correct.
Q. And we have a main charge of ammonium nitrate and some
fuel, all we need is a booster; is that right?
A. We need a high-explosive booster, that's correct.
Q. What type of materials are used as high-explosive boosters?
A. You can use cast TNT, you could use cast Pentalite, you
could use cast composition B. You can use dynamite. You can
use high-explosive water gels such as Tovex, Deta-Gel, to name
a couple. There are high-explosive emulsions made. Any
product that will reliably detonate with a blasting cap is a
high explosive.
Q. What about detonating cord?
A. Detonating cord would be as well.
Q. And can you look at Government's Exhibit 690.
A. Yes.
Q. Is this a picture of detonating cord?
A. Yes, it is.
MS. WILKINSON: Your Honor, we'd offer 690 as a
demonstrative exhibit.
MR. TIGAR: No objection, your Honor.
THE COURT: Received.
THE WITNESS: Okay.
BY MS. WILKINSON:
Q. Tell us what detonating cord is.
Paul Rydlund - Direct
A. First of all, detonating cord, again, is like a big old
rope, just like a big old clothesline. And it's about -- and
it's sold in spools of 2,000 feet to 1,000 feet. That's what
it looks like. Inside the detonating cord, inside the inner
core of the explosive, is PETN. And depending upon the grade
of detonating cord you buy, the loading of the PETN inside the
detonating cord can be anywhere from 50 grains per foot to
about 7 1/2 grains per foot. So there are a variety in there.
Now, the PETN -- and then covering the PETN is a
series of covering yarns, plastic jackets, textile yarns, again
for protection and handling. PETN within the detonating cord
itself will detonate at 27,000 feet per second, so it's pretty
fast.
Q. Now, it's not safety fuse; right?
A. No. No. No. No. Remember the safety fuse was -- safety
fuse was black powder, it was lit with a flame that we had 3
feet or, you know, we had like 3 feet for every 2 minutes.
So in this particular case, no, this is a high
explosive; and this detonates at 27,000 feet per second.
Q. Now, you also mentioned a product called Tovex. Are you
familiar with that product?
A. Yes, I am.
Q. What is that product?
A. It is a water gel that is sensitive to blasting cap that
will detonate, reliably detonate with just a blasting cap.
Paul Rydlund - Direct
Q. Now, did you help prepare a chart that showed possible bomb
components that you would need to make a ammonium nitrate and
fuel oil device?
A. Yes, I did.
Q. Let me show you Government's Exhibit 1298. Do you
recognize that?
A. Yes.
MS. WILKINSON: Your Honor, we'd offer 1298 for
demonstrative purposes.
MR. TIGAR: No objection, your Honor.
THE COURT: Received.
THE WITNESS: And this basically is a list of
materials, list that we would need. We would need an oxidizer
such as ammonium nitrate. We would need sensitizer such as
fuel oil or nitromethane. We would need the high-explosive
boosters, such as dynamite, Tovex, TNT, Pentalite. We would
need the detonators, whether they be non-electric or electric.
And we would need a container to configure the charge.
BY MS. WILKINSON:
Q. Once you had obtained all these components, is there a
specific recipe you have to follow for building this device?
A. Well, we have to go ahead -- as far as a specific recipe,
we have to configure the situation just like we showed the
four-step explosive train.
Q. But can you use different combinations of explosive to
Paul Rydlund - Direct
detonate ammonium nitrate and fuel oil?
A. Yes, I was just using those as examples. There are a
number of them that could be used.
Q. And could you combine -- could you have dynamite and Tovex
as your booster?
A. Yes, I could. I could take dynamite, Tovex, detonating
cord -- for instance, I could take Tovex or dynamite, wrap
detonating cord around it, and initiate the detonating cord
with a blasting cap, either electric or non-electric, shoot the
detonating cord, shoot the Tovex. A number of combinations are
possible.
Q. Once you have these components, how difficult is it to
build an ammonium nitrate and fuel oil device?
A. It's very simple.
Q. And how difficult or easy is it to obtain these components?
A. Many of these components -- oxidizers, ammonium nitrate,
the materials that are not explosives themselves, you know,
could be purchased. Ammonium nitrate can be purchased from
fertilizer locations, co-ops, places, feed and seed stores,
garden supply stores. I mean you could get ammonium nitrate
from there.
Fuel oil can be purchased from the local fuel -- you
know, fuel oil dealer or distributor.
Nitromethane may be obtained from places -- there are
distributors that sell nitromethane -- be obtained from there.
Paul Rydlund - Direct
It might be obtained from a chemical supply house.
Containers can be purchased almost anywhere -- which
brings us back only to the high explosives and to the --
high-explosive materials and to the blasting caps or the
detonators. Those are high explosives, and the commerce of
those articles are controlled by the ATF. And what that
requires is that you -- if you were to buy those interstate,
you simply go -- you could go to an explosive distributor, you
fill out a form that basically gives -- you show them a
driver's license, Social Security number, and then you fill out
a form indicating you've never been convicted of a felony or
drugs or this; and then those, according to the ATF rules, can
be sold to you and you could purchase them.
Now, in some states -- there are about 27 states which
have their rules in addition to the ATF rules as well. But in
most of these states, their rules are no more stringent than
the ATF rules.
Q. Now, some of these items, do you need a blaster's license
to purchase these items?
A. Depending upon the state. Because what happens in the
states -- for instance, some states, the fire marshal has
control, department of labor has control, department of mines
and minerals has control. So, no, there are locations you
could purchase them where you would not have to have a
blaster's -- a blaster's license.
Paul Rydlund - Direct
Q. Can you tell the jury how much it costs to buy a bag of
ammonium nitrate prills?
A. Oh, 50-pound bag of ammonium nitrate prills would cost
about $5.
Q. And a gallon of fuel oil?
A. Oh, probably diesel fuel oil, selling for, what, 80 cents,
a dollar a gallon, something like that.
Q. Now, if you had a large quantity of ammonium nitrate and
the proper amount of fuel oil, you said to us it wouldn't be
difficult to mix those two -- is that right -- as long as you
had some kind of container?
A. Uh-huh.
Q. How difficult would it be to boost that with a high
explosive?
A. Well, you could take the high explosive, you could either
set it in the material, or you could set it adjacent to the
material.
Q. Let's say you had a series of barrels --
A. No. By "adjacent," I mean like touching. Touching.
Q. Let's assume you had a series of barrels: Would you need
to boost each barrel of ammonium nitrate and fuel oil before
you could --
A. No, the detonation would be sympathetic. If you detonated
one barrel, the ANFO charge on that basis is strong enough to
detonate all of the other ones. I mean, basically what you get
Paul Rydlund - Direct
is just -- even with ten barrels, you just got one big, you
know, you got one charge times ten barrels.
Q. Now, what if you wanted to transport this device, if you
had the ammonium nitrate and fuel oil in the containers, if you
kept the high explosive separate from them: Would it be safe
to transport the device?
A. Yes, it would be. Ammonium nitrate/fuel oil mixtures are
transported daily.
Q. Now, if you had all the components that we're talking about
and you had 4 to 6,000 pounds of ammonium nitrate, how
difficult would it be to construct an explosive device?
A. It would not be -- it would not be difficult.
Q. Even with that quantity of ammonium nitrate?
A. Even with that quantity. It would take some time, but one
person could do it.
Q. Could two people do it?
A. Two people could do it.
Q. And could more than two people do it?
A. Yes.
Q. Now, before coming to court today, did we ask you to review
portions of a book called the Hunter?
A. Yes.
Q. Did you review the entire book?
A. Yes.
Q. I'm going to show you Government's Exhibit 158B, from page
Paul Rydlund - Direct
176 of the Hunter. Do you recognize that?
A. Yes.
Q. Did you review that before coming to court today?
A. Yes, I did.
MS. WILKINSON: Your Honor, we'd offer 158B for
demonstrative purposes only.
MR. TIGAR: We object, your Honor. He can read it
into the record. We object to that form.
THE COURT: It's just for demonstrative purposes. It
won't go into the evidence to go to the jury. So it will just
be used at this point. So you may do it.
MS. WILKINSON: Thank you, your Honor.
BY MS. WILKINSON:
Q. Now, Mr. Rydlund, it says here that someone bought 15 bags
of fertilizer-grade ammonium nitrate; is that right?
A. Yes.
MS. WILKINSON: I'm sorry. Your Honor, the screen is
not on for the jury. Thank you.
BY MS. WILKINSON:
Q. And can you read after that, where he said he would have
bought more.
A. Yes.
Q. Go ahead. Can you read it out loud.
A. You wanted me to read it. He would have bought more, but
1500 pounds was as much as he estimated he could manage in one
Paul Rydlund - Direct
load without damaging his truck.
I assume he had a three-quarter-ton pickup.
"After unloading that in the garage, he stopped at a
hardware and farm-supply store and bought two 50-pound cases of
Tovex cartridges [which would be the high-explosive water gels
that I had talked about] and a box of electric detonators.
Tovex was an aluminized water-gel dynamite commonly used by
farmers and contractors for blasting stumps and boulders."
Q. Would all of those components work to -- if you had those,
to make an improvised explosive device of ammonium nitrate?
A. Yes, it would.
Q. Now, look at 158C --
MS. WILKINSON: Your Honor, I'd offer this whole
series in as demonstrative exhibits, 158C, D, E, F -- E and F.
THE COURT: Just being used for that testimony.
MS. WILKINSON: That's all.
MR. TIGAR: Our objection is noted, your Honor.
THE COURT: Yes. The objection is overruled. You may
proceed.
BY MS. WILKINSON:
Q. Okay. Could you read this portion of the Hunter, please,
from page 179.
A. "In his rented garage he removed several five-gallon cans
of wallpaper adhesive and dozens of rolls of wallpaper from the
back of the van, replaced them with four 40-gallon plastic
Paul Rydlund - Direct
trash barrels he had purchased earlier in the day, and spent
the next three hours emptying sacks of ammonium nitrate into
the barrels and stirring a fuel-oil sensitizer into the white
pellets. The barrels were closely grouped around one of his
50-pound cases of Tovex. It was after four o'clock in the
morning when he finally was ready to place a time-delay
detonator in the Tovex."
Q. Mr. Rydlund, if someone followed these instructions and
mixed ammonium nitrate and fuel oil in plastic trash barrels
and surrounded them -- or they surrounded a box of Tovex, would
this be sufficient to, in part, to construct an ammonium
nitrate improvised explosive device?
A. Yes, it would.
Q. Let me show you Government's Exhibit 158B. And we don't
need to read this into the record but you may recall discusses
driving a truck full of those components up close to a
building. Do you recall reading that?
A. Yes.
Q. And let me show you Government's Exhibit 158D. Do you
recall this portion? Describes driving up --
A. Yes.
Q. -- closely to tightly curtained windows to George's rear
wall. Can you read that next sentence where it says, "He
leaned back."
A. "He leaned back into the cargo area just long enough to set
Paul Rydlund - Direct
the detonator to five minutes and started counting down."
Q. Now, would that have given -- if someone followed the
instructions that we've seen so far and followed these
instructions, would that have given someone sufficient time to
get away from the seat of the blast?
A. Yes.
Q. Now, look at Government's Exhibit 158E. Did you read that
before coming to court today?
A. Yes, I did.
Q. And that describes the damage that was caused and the
deaths that were caused due to this improvised explosive
device; is that right?
A. That's correct.
Q. And is consistent with your understanding of the detonation
velocity and damage patterns of an improvised ammonium nitrate
device?
A. Of the detonation velocity of ammonium nitrate, blasting
agents, and of the quantities that were discussed earlier in
the book, yes. That is correct.
MS. WILKINSON: We have no further questions, your
Honor.
THE COURT: I think we'll take the recess before
cross. I assume you have substantial cross-examination.
MR. TIGAR: Lengthy, anyway. I hope it's substantial,
your Honor.
THE COURT: All right.
We'll take a recess at this time. You may step down,
Mr. Rydlund.
THE WITNESS: Thank you.
Members of the jury, we will take our 20-minute break
at this time with the usual cautions, of course, of avoiding
discussion of anything connected with the case, anything you've
heard in connection with the case, keeping open minds.
And we'll resume this testimony in 20 minutes. You're
excused.
(Jury out at 2:57 p.m.)
THE COURT: 20 minutes.
(Recess at 2:58 p.m.)
(Reconvened at 3:21 p.m.)
THE COURT: Be seated, please.
Some jurors have asked to change the lighting there,
so that's why we turned some of those lights. They thought
there was a glare.
MR. WOODS: Keep them awake.
(Jury in at 3:22 p.m.)
THE COURT: Is the lighting better for you now?
I'm not going to put it to a vote. We'll try it this
way.
Bring in the witness. Please resume the stand.
Mr. Tigar, you may inquire.
Paul Rydlund - Cross
CROSS-EXAMINATION
BY MR. TIGAR:
Q. Good afternoon, Mr. Rydlund.
A. Good afternoon.
Q. My name is Michael Tigar. I'm one of the lawyers that's
appointed to help out Terry Nichols; and you are familiar with
cross-examination, are you not?
A. Yes.
Q. You have been cross-examined before?
A. Yes, I have.
Q. And sometimes at home at your house, you hear about it,
don't you?
A. Yes, I do.
Q. And that's because your wife's profession's -- she's a
public defender in St. Louis, isn't she?
A. Yes, she is.
Q. Would you take -- could we start -- please, would you pick
up that bag that you had the Government's Exhibit 68; and can
you --
MR. TIGAR: May I approach the witness, your Honor?
THE COURT: You may.
BY MR. TIGAR:
Q. Down here inside the bag are -- looks like little stipples,
little white marks on there. Is that from the coating of the
prills that left that deposit on there?
Paul Rydlund - Cross
A. Let me --
Q. If you could just look carefully.
A. Let me lay it like this and I'll -- these are some prills
down here, but you're not talking about these.
Q. Right, okay -- well, let's stop and talk about that for a
minute. So one thing that's left in are some of the prills are
actually inside there; right?
A. Yes.
Q. Did you shake that bag out, or was that provided to you
empty?
A. This was provided to me like this.
Q. But the prills have this tendency to -- to kind of stick to
things; right?
A. With enough humidity, yeah, sure.
Q. And now we're going to ask about this. Can we just turn it
inside out for a minute?
See the -- kind of the white stippling on there?
A. Uh-huh.
Q. Can you tell me what's that from? That is from the coating
that you put on at the factory?
A. I can't tell you whether this is from the coating or this
is from the prills themselves.
Q. All right. So you just don't know what the chemical
composition of those things is without further looking?
A. Of those stipples?
Paul Rydlund - Cross
Q. Of those stipple things.
A. I couldn't attest. No, I couldn't.
Q. Okay. That's all I want to ask about that. We'll put it
out of your way, sir.
A. Thank you.
Q. Now, I put up on the board here --
MR. TIGAR: And the Government has agreed to let me do
this, your Honor --
BY MR. TIGAR:
Q. I've written a formula here, if we could show that.
A. Uh-huh.
MR. TIGAR: And if we could exhibit that to the jury,
also. I think the Government is agreed.
MS. WILKINSON: No objection.
THE COURT: All right.
BY MR. TIGAR:
Q. Have I got this right?
A. Yes.
Q. That is ammonium nitrate?
A. That is the chemical formula for ammonium nitrate.
Q. So that's one molecule of ammonium nitrate. Correct? I
mean, if you -- and so ammonium nitrate is made of the NH4
part. What's that?
A. Well, it's nitrogen, hydrogen. Uh-huh.
Q. So that's one of nitrogen and 4 hydrogen. Right?
Paul Rydlund - Cross
A. Yes.
Q. And the NH4 together: Would that have a name?
A. It's an ammonia radical. It would be an ammonium radical,
I guess, yes.
Q. And the NO3?
A. Is a nitrate radical.
Q. So that's nitrogen and three parts oxygen; right?
A. That's correct.
Q. Okay. Now, one of the uses of ammonium nitrate is as
fertilizer. Correct?
A. That's correct.
Q. And in its use as fertilizer, it goes by the name "34-0-0";
correct?
A. Yes.
Q. And so if I --
MR. TIGAR: If I may display that, your Honor.
THE COURT: Yes.
MR. TIGAR: Yes, please, Ms. Hasfjord.
BY MR. TIGAR:
Q. So on a bag of ammonium nitrate, I would find a 34 and a
zero and a zero. Correct?
A. That's correct.
Q. So that if I'm a farmer that wants to use this or a
gardener, a home gardener, I would know that it's 34 percent
what, nitrogen?
Paul Rydlund - Cross
A. Nitrogen.
Q. And then zero percent?
A. Phosphorus.
Q. Phosphorus. And zero percent potassium?
A. Potassium.
Q. All right. And the chemical symbols are N, P, K. Is that
right?
A. That's correct.
Q. Now, you mentioned that there is a big plant near -- in
Joplin, Missouri, that makes ammonium nitrate. Is that right?
A. Yes.
Q. And is that in the center of an agricultural area?
A. It's close to -- I can't say that it's in the center of the
agricultural area, but it's close to an agricultural area near
Springfield, Missouri.
Q. And that's owned by ICI; correct?
A. Yes.
Q. And at that plant, do they make just the low-density
ammonium nitrate prills, or do they also make the high-density
ammonium nitrate prills?
A. They make the low-density ammonium nitrate prills.
Q. Now, when they sell the ammonium nitrate out at that plant,
do they sell it in bags as well as bulk?
A. Yes.
Q. And when they sell it to farmers in a bag such as the one
Paul Rydlund - Cross
you're looking at here, do they label it low-density, high-
density?
A. Two things. I don't believe ICI sells it directly to
farmers. And again, I'm not in the agricultural marketing part
of it, so I couldn't speak to it; but to my knowledge, they
don't -- they don't sell it to farmers.
However, they bag it and they do put it in their bags.
And it is not -- in the ones that I have seen and am familiar
with do not say low-density ammonium nitrate nor high-density
ammonium nitrate.
Q. Okay. That was the question.
A. I'm sorry.
Q. We understand. The farmer doesn't drive up to the big ICI
plants and say, "I'm planting today, just load my truck";
right? They go to a store and buy it. Correct?
A. Yeah. And again, I don't believe ICI sold directly to the
distributors, either.
Q. But the bag we saw today, for example, is a bag of ammonium
nitrate prills manufactured by ICI?
A. That's correct.
Q. And that bag, at any rate, did not have a label as to
whether it's low-density or high-density. Correct?
A. That is correct. That is correct.
Q. So that if I were a person who particularly wanted
low-density ammonium nitrate prills and I went to a farm store
Paul Rydlund - Cross
where ammonium nitrate was sold in bags, there is no way I
could tell by looking at the bags whether it was low-density or
high-density. Right?
A. That is correct.
Q. Okay. Now, the difference between low-density and high-
density -- I mean, I understand one is high and one is low --
the low-density has a specific gravity of about what?
A. It has a specific gravity of about .80.
Q. .80. And this is a cup of water. If I put my finger in it
and let a drop fall, the drop that -- there is another one --
that falls off there is about the size of an ammonium nitrate
prill -- right -- more or less?
A. Again, if it's a droplet. I understand.
Q. I'm not trying to be specific here.
A. I understand, sure.
Q. Now, if I had some ammonium nitrate that was the size of
low-density ammonium nitrate prill, the size of the droplet
that fell from my finger, it would weigh 80 percent of what the
water droplet does?
A. That's correct.
Q. Okay. And that's what the --
A. With the same volume, you're right.
Q. Okay. Now, a high-density ammonium nitrate prill has a
specific gravity of what?
A. Well, high-density ammonium nitrate prills have a specific
Paul Rydlund - Cross
gravity closer to 60 pounds a cubic foot or 60 divided by -- so
it would be closer to .9 or a little bit higher.
Q. So a difference of -- well, if it's 80 to 90, 12 1/2,
13 percent more?
A. Yeah, it's close.
Q. Now, in fact, sir, high-density ammonium nitrate prills can
be used to make an explosive device when combined with fuel oil
and something else; correct?
A. Yes. They could be -- and something else. That's correct.
Q. And the something else is carbonaceous black. Is that
correct?
A. Yes. That's true. But I'm sorry: Did you say
high-explosive device?
Q. No, I said an explosive device. A blasting agent. And if
my terminology is wrong, would you correct me.
A. Can be used to make a blasting agent, that's correct.
Q. In fact, sir, in 1970 -- you're smiling.
A. I know. Go ahead.
Q. You know. Tell us what happened in 1970 that lets you tell
me that you can use high-density prills to make a device.
A. In 1970, I authored a patent using carbon black, a mixture
of carbon black and fuel oil.
Q. Right.
A. And that was used to make an explosive device. It was a
great patent. I mean, to me it was a good idea.
Paul Rydlund - Cross
Unfortunately, the operation was a success but the patient
died. It had no practical value.
Q. The market has never picked up on this idea that you and
your colleague had. Is that right?
A. No. And actually, to be honest with you, there were some
problems with it. The carbonaceous black and the fuel oil --
it's almost like a slurry. It was very sensitive to flame.
That was the biggest problem. It couldn't be commercialized
because it was too hazardous to handle.
Q. Okay. When you say very sensitive to flame, I want to get
another basic fact out here. You said that if ammonium nitrate
catches fire that it's hard to put out.
A. I said that if ammonium nitrate catches fire, it produces
its own oxygen, so you can't -- so if you try to suffocate it,
if it was a fire and it was in a -- and it was in a -- in an
area where, you know, you'd tried to batten down the hatch and
not let the air get to it, it would still produce its own
oxygen. But no, an ammonium nitrate fire can be extinguished
by water.
Q. It can?
A. Yes.
Q. Okay. And when -- at what temperature does ammonium
nitrate start to burn?
A. I would have to go back and consult. I couldn't say off
the top of my head, but it's a very high temperature. But I
Paul Rydlund - Cross
don't have that number readily available.
Q. When you say very high, over a thousand degrees Fahrenheit,
or is it --
A. I'd have to go back and look at my numbers.
Q. Sure. And do you know at what temperature fuel oil starts
to burn?
A. The temperature where fuel oil will spontaneously ignite,
no, I don't have that particular number with me.
Q. Do you know at what temperature nitromethane starts to
burn?
A. I don't have that number with me, either.
Q. It wasn't mentioned earlier today, but do you know of a
substance called anhydrous hydrazine?
A. I've heard of it, and it had a very short life in the
commercial explosive industry.
Q. So it's not used any more for commercial explosive so far
as you're aware.
Was it used, do you know, for commercial ANFO-type
explosives?
A. The only use that I'm aware of -- it was used in -- as a
binary explosive.
Q. All right.
A. So it wouldn't be used in commercial mining ventures, no.
Q. Now, what's a binary explosive?
A. Where ammonium -- a binary explosive would be like what
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they call a two-component explosive; and for instance, a
product called Kinepack or T100, where you have a bottle of
crushed ammonium nitrate and you have a bottle of nitromethane
and you pour the nitromethane into the ammonium nitrate and
this makes a -- this makes a high explosive, and then it can be
detonated by a blasting cap. And they tried to do the same
thing with anhydrous hydrazine.
Q. Now, looking first to the agricultural use of ammonium
nitrate, you don't have a lot of experience in that field; is
that right?
A. I am not involved in the agricultural business, but no, I
don't have -- I would consider not a lot of experience in the
agricultural business; that's right.
Q. Do you know how many pounds of ammonium nitrate are used on
the commercial side every year; that is to -- excuse me -- the
agricultural side every year.
A. I'm trying to -- I'm trying to remember offhand what it is.
I do, but I don't recollect the number. I mean, what I'm
saying is I know, but I don't have the number with me.
Q. All right. Well, for explosive purposes, how many pounds
of ammonium nitrate are used annually in the United States, let
us say, in the most recent year --
A. I'm sorry.
Q. -- in the most recent year that you know?
A. Okay. In the most recent year that I know, basically what
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we're looking at is somewhere in the neighborhood of about, oh,
2 million tons.
Q. That's 4 billion pounds?
A. Yes.
Q. Is that right?
A. Uh-huh.
Q. So 4 billion pounds of this stuff are used annually for
explosive purposes; right?
A. (Witness nods head.)
Q. Now, who uses all this stuff?
A. The -- I'm sorry.
Q. Let's start -- first you mentioned that it's used by
rock -- for rock blasting?
A. Uh-huh.
Q. And that's used for quarrying and mining?
A. Uh-huh.
Q. Is it used for construction purposes, construction
excavation?
A. Uh-huh.
Q. Is it used by farmers?
A. Is it used by farmers? I -- it could be used by farmers
for stump-blasting, for maybe trench-shooting, although I don't
know if the farmer would do that himself. He would probably
get, you know, an explosive distributor or somebody to hire.
Maybe not for stump-blasting. However, that amount would be
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very, very small.
Q. And you say for trench-shooting?
A. Ditch-shooting. It could be used for ditch-shooting.
Q. What is that, sir?
A. Ditch-shooting is basically if you were going to go ahead
and shoot a ditch or a trench.
Q. So that would be lining up a series of charges all in a row
and then you make it go boom?
A. That's correct.
Q. And then you don't have to dig it out with a -- with a pick
and shovel?
A. Uh-huh.
Q. And you could also use it for a pond, for making a pond;
right?
A. You could.
Q. Now, can ammonium nitrate explosives, if they're properly
packaged, be used in an environment where there is water?
A. There are ammonium nitrate explosives that are used -- can
be used in certain water conditions.
Q. Now -- and in fact, the Primadet that we saw is waterproof;
correct? The cord itself?
A. The Primadet can be used in water conditions, yes.
Q. Yes. And -- well, you mentioned ammonium nitrate
explosives, and we've been using these terms interchangeably.
Ammonium nitrate -- that is, the chemical NH4NO3 -- is used in
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many explosive products, isn't it?
A. Yeah. It's used in a number of explosive products. That's
correct.
Q. And when we talked about the 4 billion pounds earlier, were
you talking only about use of it for ANFO purposes, or was that
for all explosive purposes?
A. That was for ammonium nitrate used in all explosive
products.
Q. And what are some other explosive products in which
ammonium nitrate would be used?
A. Besides ANFO?
Q. Yes, in addition to ANFO.
A. In addition to ANFO, they could be used in water gels.
Q. What is water gel?
A. Water gel is a mixture of solid ammonium nitrate, liquid
ammonium nitrate, sensitizers or fuels, and a gelling agent
which basically puts together a product that is called a water
gel, and it's called that because it resembles Jell-O. And so
that is a product that is used in ammonium nitrate.
Q. So finding ammonium nitrate residues at the scene of a
blast doesn't uniquely identify ANFO as the cause of the blast.
Correct?
A. Finding ammonium nitrate crystals?
Q. No, residue.
A. Residue?
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Q. Yes. We haven't talked about crystals yet. Just residues
generally.
A. Okay. Finding there -- that's right. I mean, it could be
from water gels.
Q. All right.
A. Product such as a water gel.
Q. Now, sir, I want to ask you about a characteristic of
ammonium nitrate. You said that -- excuse me. You said it's
very sensitive to water. Is that correct?
A. It's very soluble in water, yes.
Q. Very soluble. And is that characteristic referred to as
"hydroscopic"?
A. Well, in my opinion, hydroscopic is the ability to attract
moisture, the ability for moisture out of the air. And to me
that means the ability to trap moisture out of the air, such as
table salt. And it probably -- but solubility is the ability
to dissolve in water.
Q. Yes, sir.
A. But ammonium nitrate is hydroscopic; and again, it does
have the ability to attract moisture out of the air.
Q. Now, have you ever attempted to test the -- and how do you
spell -- is it hydroscopic or hydroscopic? Should I be saying,
the word -- the --
A. H-Y-D-R-O.
Q. Hydroscopic. Just like hydrant, water.
Paul Rydlund - Cross
A. Hydro, uh-huh.
Q. Yeah. And if I took a small quantity of ammonium nitrate
prills, crushed and placed them in a watch glass, which is a
small glass container, and I subjected them to 98 percent
humidity, what would happen to the crushed ammonium nitrate?
A. So you have 98 percent humidity at what temperature?
Q. Standard temperature and pressure, so that means we've got
to go back down to sea level and 90 degrees. Well, that's not
standard temperature, but let's --
A. Okay. But anyway, like a very hot, humid day --
Q. Like a hot, humid day.
A. -- is what we're trying to say, and you place them in a
watch glass.
Q. Now, by watch glass -- you've used those in chemistry
class?
A. Uh-huh.
Q. And that's just a small -- looks like a tiny, little
saucer?
A. Uh-huh. That's correct. Yes.
Okay, placed in that humidity and we placed the
prills -- we place the prills.
Q. I said crushed prills in my first example, sir.
A. So we place -- so we have an agglomeration of crystals in
there. Okay. All right. And we placed it to the humidity,
and the first thing that would happen would be, subjected to
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the humidity -- that is, the humidity would attack the surface
of the crushed prills and they would try to draw together and
they would cake. And so the flow-ability of these crushed
prills lying like this all of a sudden would become more of a
solid mass, is what they would do.
Q. And would there come a point at which the -- we would find
a puddle in our watch glass under these conditions?
A. Could you find a point at --
Q. Just a puddle; that is, we wouldn't see any --
A. Depending upon -- depending upon the amount of grains of
moisture that they were subjected to and the amount of material
that was there -- so it could be. So if you had two or three
little crushed prills and you subjected it to humidity where
you had so much moisture for several weeks, yes, you could.
Q. And -- well, do you have an opinion as to how much time it
would take for the puddling effect to occur with a small
quantity, 5 grams, let's say, of crushed prills in a watch
glass under 98 percent humidity conditions?
A. At that particular time, I would probably say it could
be -- let's say we're talking 100 degrees Fahrenheit, with 98
humidity -- and I don't have a chart with me to tell me how
much moisture is in the air. But in my opinion and from the
tests that I've run when I worked at Monsanto, I would say it
would probably be somewhere in terms of a week.
Q. You don't -- you think it would take that long?
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A. Again, I'm trying to look at how much moisture -- you know,
how much moisture, and I'm looking at maybe -- 5 grams of
prills and depending upon the exposure and everything. It
could be a week, I would say. Probably. Probably a week.
Q. Have you ever done that experiment?
A. Not with 5 grams. That's the problem I'm having trying to
relate to. I mean, I've done it more with like 50 grams, and
I've run it in temperature humidity cabinets; and that's what
I'm trying to recall. So I'm trying to extrapolate from that.
Q. Sure. 50 grams is just shy of 2 ounces; right?
A. Well, 50 grams is -- I'd have to go through the deal again,
but 450 divided by 50, so that's about a 9th of a pound, I
guess. I'm trying to get back to my ounces. Is that -- I'm
trying to think, 16 ounces a pound, probably about 2 ounces.
Okay.
Q. Now, you mentioned that if someone were going to make a
device made of ammonium nitrate and fuel oil that they would
then -- this person, whoever that was, would want to get the
low-density prills; right?
A. To absorb the fuel oil; that is correct.
Q. And the low-density prills, then, if you had a barrel with
a bunghole in the top of it and just poured the diesel in,
after 10 minutes or so, it would be absorbed; right?
A. Yeah, in my opinion, it would be, uh-huh.
Q. So that you wouldn't have to take a paddle and stir the
Paul Rydlund - Cross
stuff; right?
A. No. It would absorb. That's correct.
Q. In fact, somebody that took a paddle and started stirring
the stuff would show that they didn't really understand the
process very well; correct?
A. Well, I don't -- I mean, I don't know if that would -- I
don't know if that would be true or not. I couldn't say that.
I mean, it would seem, naturally, if you're going to combine
two things, if you can stir them, fine. I mean, our experience
is when they're just combined going into a blowpipe up to the
top of the bin, when we combine it we don't have to sit there
and have a mixer inside. But in normal cases, a lot of people
use a concrete mixer.
Q. So it's not necessary to stir?
A. Well, in this particular case to combine it, no. They will
disperse in time.
Q. Now, on this subject, if I wanted to find out how to make
an explosion using ammonium nitrate and fuel oil and say I'm a
farmer, I wanted to blow stumps, where would I go to find that
out?
A. If you wanted to blow some stumps and get some ammonium
nitrate fuel oil to blow the stumps?
Q. Right. I bought some land and I want to deep-break it but
I don't want to bring in heavy equipment. I want to blow the
stumps out.
Paul Rydlund - Cross
A. You might go to an explosive distributor.
Q. Okay.
A. You might know somebody that works at a mine that does
blasting in a mine that may be able to help you. There may be
literature available on the Internet, in book stores or sold
through different books that may tell you how to do it.
Q. Sure. Well, let's take those one at a time. If I go to an
explosive distributor, would I find some of your products
there?
A. You might.
Q. And when I found your products there, would I find
instructions on how to use them?
A. Complete instructions as to how to blow a stump?
Q. Yes, sir.
A. No.
Q. So we couldn't get it there.
Now, if I found somebody that worked in --
A. I'm sorry.
Q. Excuse me, sir.
A. You might ask them how to do it.
Q. Oh, I see. In other words, I could walk in the door and
say I want to buy this and this and this and how do I do it,
and they would tell me.
A. They might.
Q. They might, if I looked like the sort of person that they
Paul Rydlund - Cross
could trust with the information?
A. Depending upon the circumstance, the individual, if they
knew you and things like that. That's correct.
Q. You're in the business of selling these things to people,
and so you want them to buy them and use them responsibly;
right?
A. That's correct.
Q. And in order for them to be purchased by many people and
used responsibly, there has to be a way for them to buy them
and find out how to use them. Correct?
A. That's correct.
Q. Another source you mentioned was the Internet. Have you
ever looked on the Internet?
A. No, sir, I have not.
Q. Okay. We'll stop right there.
Have you ever -- are you familiar with an outfit
called Paladin Press?
A. I'm familiar that I believe they have published a couple
of -- I believe they have published a couple of books, some
books -- Hunter.
Q. You think they published Hunter?
A. I'm not sure. I've seen Paladin Press before, and I'm not
completely sure without looking at it whether they did or
didn't, but I believe they've published a couple of books
related to -- that have some involvement with explosives.
Paul Rydlund - Cross
Q. Well, in fact, sir, isn't Hunter published by something
called National Vanguard Books?
A. It may be. It may.
Q. Okay.
A. It may be, and again I said -- I remember seeing the name.
I can't recall which book I saw it in.
Q. But have you ever seen any books published by Paladin Press
that tell you how to make an ANFO explosive device?
A. Well, if I can't recall the books that I've seen the
Paladin Press name on, then I would have to answer you -- I
can't answer your question.
Q. And have -- have you also read publications that describe
the safety precautions that you should take when handling
ammonium nitrate/fuel oil mixtures?
A. Yes.
Q. And now are you familiar with the Manufacturing Chemists
Association Fertilizer-Grade Ammonium Nitrate Properties and
Recommended Methods for Packaging Handling, Transportation,
Storage and Uses?
A. Yes.
Q. Are you familiar with the National Fire Protection
Association publication Manufacture, Storage, Transportation
and Use of Explosives and Blasting Agents?
A. I'm familiar with seeing that. I haven't read that in a
while.
Paul Rydlund - Cross
Q. Okay. Have you read the Bureau of Mines' information
circular, Safety Recommendations for Sensitized Ammonium
Nitrate Blasting Agents?
A. Yes, I have.
Q. Now, what's a sensitized ammonium nitrate blasting agent?
That's not one that's been in therapy, is it? That's one
that's been prepared to explode --
A. That's correct.
Q. -- is all that means.
A. "Sensitized" means for ammonium nitrate blasting agents,
whether they used different sensitizer, uh-huh.
Q. I wanted to place up on the screen, if I may, what's been
admitted here as Government's Exhibit 674.
Now, we've seen this before. That's our -- how the
ammonium nitrate prills are made in a typical plant. And I
think you remember that.
A. Uh-huh.
Q. Now, I'm with you all the way through here till we get over
to this where I've got my finger. It says "coater."
A. Uh-huh.
Q. And then it says "talc .40 percent" and then "external
surfactant."
Now, is the external surfactant different from the
talc?
A. Yes.
Paul Rydlund - Cross
Q. What is talc?
A. Talcum powder.
Q. Chemically, what is it?
A. Talc is silicate. It's a -- I'm trying to think of the
exact chemical formula now.
I can't. But it basically is a silicate.
Q. All right. So it's a silicon plus something?
A. Uh-huh.
Q. And the external surfactant: Does that differ from
manufacturer to manufacturer about what is used?
A. Yes, it does. Yes, it does. The manufacturers of ammonium
nitrate may use different surfactive agents.
Q. Now -- if you have mixed your -- if you're using barrels,
mix -- if you're mixing in barrels, if one is doing that, this
absorption process means you don't have to roll the things on
the ground to get it dispersed or anything like that; right?
A. That is correct.
Q. Okay. So that one person could manufacture a -- or could
make a device with ammonium nitrate by pouring the bag material
and then measuring out the ammonium nitrate and just letting it
sit. Correct?
A. Yes.
Q. Now, would Primadet be something that you would use in an
improvised explosive device of the kind that was exploded in
Oklahoma City?
Paul Rydlund - Cross
MS. WILKINSON: Objection, your Honor. I'm not sure
he's familiar with the device. He wasn't in Oklahoma City.
MR. TIGAR: I'll lay a foundation, your Honor, if I
may.
THE COURT: All right.
BY MR. TIGAR:
Q. Do you know -- do you have information concerning the kind
of device that was exploded in Oklahoma City?
A. No, sir, I do not.
Q. Okay. Well, then, let me put a hypothetical to you.
A. Okay.
Q. If a person were going to park a truck, make a truck bomb,
and use 40-gallon plastic barrels and 1500 pounds of ammonium
nitrate mixed with the requisite amount of fuel oil and then
Tovex as the -- what would we call that, the blasting agent?
A. The high explosive.
Q. The high explosive. Would Primadet be used in that sort of
a setup?
A. As a --
Q. For any purpose.
A. Well, a Primadet could serve or would serve as the
detonator that detonates the Tovex.
Q. I see.
A. It could serve -- it could serve as that.
Q. But then how -- you said that it moves so fast through
Paul Rydlund - Cross
there, the fire, that you'd have a hard time getting away.
What else would you have to use?
A. Well, you would have to use -- you would have to use
something else as well. You would have to turn around and
perhaps attach an electric blasting cap to the Primadet. You
might have to attach detonating cord to the Primadet. You
would have to use another means -- you would have to use
another detonator to detonate the Primadet.
Q. Because otherwise you'd go up with your blast. Right?
A. Yes, sir.
Q. Similarly, if I were going to shoot a ditch on a farm and I
were down and it were springtime and it's low-lying ground so
I've got my -- I'm going to an ANFO mixture for that, let's
assume in some quantities, and that's going to be laying in
water -- all right -- Primadet might be useful in that --
right -- because it's waterproof, to hook the charges together?
A. The ANFO mixture may not -- the ANFO mixture may not be
very good in water, but the Primadet would be.
Q. Okay. So what would you suggest that I use if I am a
farmer and I'm going to shoot a ditch and I've got this water
condition -- Primadet would be useful there?
A. Primadet could be used and has been used in trenching or
ditching. Yes, it has been.
Q. So -- and -- but to make it safe, then, I'd have to attach
a piece of safety fuse to the end -- right -- so that I could
Paul Rydlund - Cross
get away?
A. Well, there would be -- there are different means of
initiating the Primadet.
Q. Okay. But I understood you to say on direct examination --
I'm not quarreling with you, sir -- that the main use of
Primadet in that 60-foot length would be to drop down a 60-foot
borehole.
A. That's correct.
Q. But are you now -- are you saying -- and I'm not suggesting
this is a contradiction -- this is an additional use for that
product: to shoot a trench on a farm under water conditions?
A. Well, Primadet can be used to shoot a ditch or a trench,
whether it be at a mine or wherever. I don't think the ditch
would be 60 feet deep.
Q. No, no. I understand that. But -- I'm sorry. I've
confused --
A. But you mean with that type of initiation system? Is that
what you're referring to?
Q. In other words -- I'm sorry.
A. That's correct.
Q. Okay.
A. That's correct. Primadet -- Primadets can be used to shoot
trenches. You're right.
Q. And when you say "shoot a trench," you mean it could be
used by a farmer up on the surface, not down in a mine, just
Paul Rydlund - Cross
out in the field somewhere?
A. It could be used. It could be used to shoot it, and
somebody that was knowledgeable -- and somebody that was
knowledgeable in those products and capable of using them --
and it would require some -- it would require some other
products as well, yes.
Q. Yes, indeed. I understand you can't just do it with
Primadet.
A. Well, you need a means to initiate. Right.
Q. Now, when you talked about this Tovex -- let's go back to
ANFO now.
A. Uh-huh.
Q. If a person had some barrels of ammonium nitrate, like in
that book Hunter, and that fella had his ammonium nitrate -- he
had, what, four barrels of it? Is that what he said in his
book?
A. I believe so.
Q. Yeah. And they were 40-gallon barrels; right?
A. Uh-huh.
Q. And they were bought at the hardware store; correct?
A. I don't remember if they bought -- I'm sorry. I can't
recall if he bought the barrels at the hardware store or not.
Q. And he bought 15 bags of ammonium nitrate; correct?
A. 1500 pounds, I believe. Correct.
Q. Well, what you read out was: "He bought 15 bags of
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fertilizer-grade ammonium nitrate. He would have bought more,
but 1500 pounds was about as much as he estimated he could
manage in one load." Do you remember that?
A. Yes.
Q. But this ammonium nitrate comes in 50-pound bags, doesn't
it?
A. Well, today, it's -- I've seen it sold in 80-pound bags and
50-pound bags. That's correct.
Q. 80 and 50.
A. Uh-huh.
Q. So whoever wrote this book didn't know how many pounds
there are in ammonium nitrate bags; correct?
A. Well, sir, there were times when ammonium nitrate was sold
in 100-pound bags.
Q. Okay.
A. That was not recently. And I can't give you -- I'm sorry I
can't gave you the same date, but there were times when it was
sold in 100-pound bags.
Q. Do you know when this book was copyrighted?
A. I don't recall, sir.
Q. Yeah. When is the last time you remember seeing 100-pound
bag?
A. Well personally, myself handling 100-pound bags?
Q. Yes, sir.
A. Probably 20 years ago.
Paul Rydlund - Cross
Q. Yeah. And anyway, that book Hunter is a fiction book,
isn't it? Did you read the whole thing?
A. Yes, I did.
Q. It has a certain political slant to it, doesn't it, sir?
A. Yes, it does.
Q. Yeah. The fellow that wrote that is about two bricks short
of a load, isn't he?
A. I don't know him. I don't know him. I mean I don't --
Q. You wouldn't agree with his politics, would you, sir?
MS. WILKINSON: Objection, your Honor.
THE COURT: Sustained.
BY MR. TIGAR:
Q. Let's talk about our Tovex. You've got four barrels of
ammonium nitrate and you put 50 pounds of Tovex in the middle.
Is that the most efficient way to detonate this product?
A. Is it the most efficient way to detonate the product?
Q. Yes, sir.
A. Given that situation -- and I guess I would have to answer
your question with the proper amount of Tovex -- and I believe
we had -- the cases that we had had been placed adjacent to the
barrels. It would provide an efficient detonation. I would
suspect if I had primed -- I would expect to receive in that
particular case if it was properly mixed and with the -- with
the -- and with the cases placed here that at the resulting --
end result detonation velocity would be the same if it -- if we
Paul Rydlund - Cross
did it that way or if we placed individual cases of Tovex
within each barrel.
Q. Now, you wrote a master's thesis called "Ignition Time Lag,
A Measure of Explosive Energy Release." Correct, sir?
A. Yes, I did. Yes, I did.
Q. And when you wrote that master's thesis, you were very
interested in identifying the most efficient way to detonate
certain things; right?
A. Yes. Yes, I was.
Q. And the objective when you use ammonium nitrate and a fuel
oil mixture is to make sure that you have the best velocity of
detonation; is that right?
A. Yes. We -- to make sure that you achieve the highest
detonation velocity of the ammonium nitrate -- or of the ANFO.
Excuse me.
Q. The ANFO. And when you do that, in order to do that, there
are a number of things you have to take into account; correct?
A. Yes.
Q. All right. And one of them is the percentage of the thing
that you're going to add to the ammonium nitrate; correct?
A. The percentage -- you mean like the booster?
Q. The percentage of fuel oil, for example.
A. Oh, yes. That's correct. Uh-huh.
Q. Because at a certain point, if I had 10 percent oil by
weight, the explosive would not be as efficient; correct?
Paul Rydlund - Cross
A. That is correct.
Q. Okay. And what would you have, then? You'd have
unexploded particles, or what would be the result if it was
10 percent?
A. Well, if it was 10 percent -- and again, it would depend
upon the location of the booster and the -- and the size of the
charge and the confinement; so there would be -- there would be
other factors involved as well. But there could be, if you had
a very, very small charge like a size of this cup -- okay --
Q. Yes, sir.
A. And it had 10 percent fuel oil in it -- okay -- in the
ammonium nitrate and there was very little confinement, it was
just in the cup, you know, and you turned around and you set
half a stick of dynamite or something close to it, conceivably
you could have some prills off to the side because you have a
very inefficient -- a very inefficient product.
Q. Now, what is "ignition time lag"?
A. Well, "ignition time lag" was a phrase I coined in my
master's thesis, and it referred to the time lag between the
time the ammonium nitrate and the ANFO mixture was initiated
and when it reached its maximum or steady state detonation
velocity.
Q. All right. And is there an ideal time lag there?
A. Well, the ideal time lag would be -- the ideal time lag --
would be immediate.
Paul Rydlund - Cross
Q. Would be zero?
A. That's correct.
Q. That is to say, if we could disregard the laws of physics
and chemistry and we had a quantity of ammonium nitrate and
fuel oil in a container, we'd like all of it to oxidize at once
or explode at once; right?
A. To reach its maximum efficiency all at once. That's
correct.
Q. Yes, sir. And if I'm using the wrong terms, please correct
me.
A. No, I'm not trying to be --
Q. But we can't do that; right. That's impossible?
A. That's pretty close to impossible, yes.
Q. And so there are different ways that the blaster can
maximize efficiency in that way by reducing the time lag, this
ignition time lag as much as possible; correct?
A. That's correct.
Q. Okay. And one of those ways is with the -- has to do with
the efficiency of whatever initiating charge you're using.
Right?
A. That's correct.
Q. And is another way the proximity of the initiating charge
to the prills that have absorbed the fuel oil or whatever
hydrocarbon you're using?
A. Yes.
Paul Rydlund - Cross
Q. Okay. So proximity is a factor in reducing this ignition
lag time. Is that fair to say?
A. Yes. And again, in the proper context, this was all done
within blast holes.
Q. I understand.
A. Placing it in blast holes as well. That's correct.
Q. When we speak of these things, we necessarily have, what --
there are 25 factors that have to do with whether this thing is
going to succeed or not. Correct?
A. Well, there is a number of them. I don't know if it's 25.
Q. Well, there are a large number?
A. Yes, sir.
Q. And one of them, as you've said, is containment?
A. One of them is containment.
Q. And by identifying proximity as one, we don't mean to
exclude the others; correct?
A. (Witness nods head.)
Q. Okay. Now, I want to put up, if I may, what has been
received as Government's Exhibit for demonstrative purposes
No. 691. Now, that is your -- did you make the diagram, sir,
or --
A. No.
Q. It was made at your direction?
A. The diagram was -- the diagram was shown to me, and I
agreed to discuss it, yes.
Paul Rydlund - Cross
Q. Okay. I'm not trying to --
A. I understand. No. That's correct.
Q. -- argue with you about it.
A. Uh-huh.
Q. Now, right at the middle here, we're talking about a shock
front. You say that's supersonic; and I believe you said on
direct 13,000 miles an hour, but you meant feet per second.
A. No, miles per hour.
Q. 13,000 miles per hour?
A. Right.
Q. What is that in feet per second?
A. Well, I'd have to go back and calculate that.
Q. 60 miles an hour is 88 feet per second; correct?
A. Well -- okay. I don't have my --
Q. We don't know?
A. Anyway, fine. 13,000 miles per hour is what I quoted, yes.
Q. And what is that in feet per second so that we're
consistent here? Aren't velocities of detonation usually
measured in feet per second?
A. But that is not the detonation velocity.
Q. I understand. But I want to be consistent. I want to see
if we can get a number. If we can't, it's okay.
A. Okay. So we're at 13,000 miles per hour.
Q. Would you accept about 10,000 feet per second? No, the
other direction. So about 20,000 feet per second?
Paul Rydlund - Cross
A. No, it would be much less.
Q. A little less?
A. Let's see, we've got thousand and feet, so we've got 5280
divided by 30 -- 60 times 60 is 3600, so 52 divided by 36 times
13 is -- yeah, I guess -- whatever it comes out.
Q. I'm sorry I asked.
Tell you what: I'm go on to something else. Excuse
me. I'm -- Very fast. Would you agree with that? Moving very
fast. Okay.
A. Now, but not as fast as the velocity of detonation.
Q. Okay. Not as fast as the velocity of detonation. That is
to say, as the pressure wave moves out, the speed tends to
reduce. Correct?
A. No, as it moves out, it's moving like a shock wave moves in
air, the speed of a shock wave moves in air.
Q. In air, you say, "initiation inside thermal effect."
That's the part I wanted you to look at where this very red
part is.
A. Uh-huh.
Q. What's the temperature in there?
A. The temperature at the point in the chemical reaction is
6,000 -- I'm sorry.
Q. Let's take it a moment at a time. Let's get a set of
assumptions here. Have you worked with mixtures of ammonium
nitrate and nitromethane?
Paul Rydlund - Cross
A. I've done -- I've done a little work with it, yes. I've
done some years ago.
Q. And is the temperature at the moment of detonation of a
nitromethane device going to be about the -- nitromethane --
nitromethane/ammonium nitrate device about the same as an ANFO
device?
A. I would -- I can't answer that question. I can't answer
that question completely because I don't know the exact
temperature, so I could only offer an opinion. I'm sorry.
Q. All right. Well, then let's stick -- An ANFO device you
could tell us without much trouble?
A. I think what I had come back and said was in the chemical
reaction zone where we were talking about, we're about 6,000
degrees Fahrenheit.
Q. 6,000 degrees Fahrenheit. So that if someone had a
40-gallon barrel of ammonium nitrate mixed with 6 percent fuel
oil and initiated it with the initiating charge stuck into the
mixture -- all right -- what would be the temperature
experienced by the barrel, plastic barrel?
A. Again, with the diameter of the plastic barrel -- I would
have to calculate it. I don't -- I can't tell you right now
what that temperature would be. All I can tell you is that
right at the point of detonation it would be that temperature.
Obviously --
Q. And is there a formula that we could use that we could look
Paul Rydlund - Cross
up to see what the temperature would be 2, 3, 4, 5 feet away
from the center point of ignition?
A. There would be a formula, but -- there would be a formula.
There would be some numbers, but I don't have that.
Q. I'm not asking you to speculate. But the point is, we
could find somebody; we could look it up.
A. Yes.
MR. TIGAR: Okay. Now, we had picture up here, if I
may show that, Mrs. Hasfjord.
I'm sorry. 685. The clerk is helping me.
Oh, good.
BY MR. TIGAR:
Q. This is Government's Exhibit 685 -- is an electric blasting
cap; and then you had another one that was a nonelectric. Is
that the sort of thing that is regulated differently depending
on what state you're in? Blasting caps?
A. That comes under the ATF regulations, and there are some
state regulations that speak to, you know, how you can handle
the commerce of it, yes.
Q. Let me see, here. Now, sir, finally I want to turn to this
question of how you handle and store this material. Right?
A. Ammonium nitrate?
Q. Yes, sir. Ammonium nitrate. Now, we looked at the bag
earlier, and are there regulations that you all follow in your
business as to how to deal with this material?
Paul Rydlund - Cross
A. Ammonium nitrate, or ammonium nitrate fuel oil?
Q. Ammonium nitrate.
A. Ammonium nitrate? Are there regulations that we have?
Q. Yes, sir.
A. With respect to safety?
Q. Yes, sir.
A. I suspect that's what we're coming to.
Q. Yes, sir.
A. And how we would store it?
Q. As to how you would store it and how personnel are
instructed to treat it.
A. Okay. All right. Yes. It can be stored in bulk. It can
be stored in bulk bins. Basically, it is transported by rail
cars and then generally put into bulk bins or put into trucks
and then put into bulk bins.
The material, again, is -- for purposes of the bins
and where it's stored is we want to try to keep fire away from
it, so that brush and everything is cleaned away, no trash
around it. Things like that. Those are important.
Q. Now, do you have people -- do you ventilate the areas in
which it's stored?
A. Well, let me try to give you some examples as to where
we're at because -- in using the term "ventilate" -- excuse me.
In a mine, for instance, okay, we would store ammonium nitrate
perhaps in just a great big 60-ton overhead bin that's
Paul Rydlund - Cross
completely enclosed. All right? It's completely enclosed and
maybe sits 12, 14 feet off the ground and holds 60 tons. Okay?
A lot of times it's stored in a rail car, and it's not
even used to make ANFO until they take it out of a rail car;
and of course -- it's a hopper car which is completely enclosed
to keep moisture away from it. Those are cases --
If you are using it in a fixed-plant location -- if
you were going to try to make, for instance, a water gel like
you discussed or you're going to try to make ANFO in a
fixed-plant location, then you would look -- it's the people
working in that fixed-plant location, and you would obviously
try to have some air movement, ventilation, fans, or whatever
it is in that area as well. But the main hazard with ammonium
nitrate is fire and to try to keep flame away from it.
Q. Now, in your material safety data at El Dorado, do you have
a provision about respiratory protection?
A. Yes, we do.
Q. And what is the purpose of your provision on respiratory
protection?
A. The purpose on the respiratory protection is to try to get
fine -- is to try to prevent very fine airborne particles of
ammonium nitrate from getting into the system, into -- into
your -- being not ingested but to get into --
Q. Into your respiratory system?
A. Respiratory system. Right. Uh-huh.
Paul Rydlund - Cross
Q. And the reason you have those is that that is a real-life
possibility; that is to say, that could happen. Correct?
A. The purpose of it is that there are fine airborne particles
in there you want to be able to -- you don't want them -- to
get them in. Now, that's if there are fine airborne particles
in there which we might call dust or pieces -- or very fine
particles of ammonium nitrate that are suspended in air.
Prills aren't.
Q. Now -- and I said "finally," but I didn't mean it. This
really is final. Okay?
A. Okay.
Q. If I wanted to test the hydroscopic properties of ammonium
nitrate, would you agree with me that it would be a proper
experiment to do this to set up a bell jar with a sealed --
sealed bell jar with 98 percent relative humidity regulated in
there and then put a small sample on a watch glass and time how
long it took to puddle?
A. That could be a test for it. I don't know how much
moisture is in the bell jar, how big it is, and that's --
Q. You know what a bell jar is?
A. I know what a bell jar is; and if you were trying to
develop a test for it, that could be a test. And yeah, you
would have -- if you knew, you know, the size of the nitrate
and how much -- you'd have to know the grains of moisture in
the bell jar.
Paul Rydlund - Cross
Q. Which you would know by knowing the percentage of humidity,
the temperature, and so forth and so on.
A. The temperature. You could calculate it, yes.
Q. You also need to know the temperature?
A. Yes. Uh-huh.
MR. TIGAR: Would your Honor indulge me for a moment?
THE COURT: Yes.
MR. TIGAR: Mr. Rydlund, thank you very much. I
really appreciate your answering our questions.
THE WITNESS: Sure.
THE COURT: Do you have some redirect?
MS. WILKINSON: Just briefly, your Honor.
REDIRECT EXAMINATION
BY MS. WILKINSON:
Q. Mr. Rydlund, do you recall being asked by defense counsel
about the passage from the Hunter that discusses placing the
barrels of ammonium nitrate and fuel oil around the cases of
Tovex? Do you remember --
A. Yes.
Q. -- Mr. Tigar asked you about that? And he asked you was
that the most efficient way to detonate or build a bomb; is
that right?
A. Yes.
Q. Let me ask you: Is it efficient enough?
A. Yes.
Paul Rydlund - Redirect
Q. And what do you mean by that?
A. I mean that it's efficient enough that we can detonate the
ammonium nitrate at the -- at the maximum velocity that could
be achieved in that particular barrel with that particular
amount of fuel oil.
Q. And if it was detonated properly, would you expect the
ammonium nitrate and the fuel oil to be consumed in the
explosion?
A. Yes, I would.
Q. And is ANFO used in the commercial industry because it is
an efficient product?
A. Yes, it is.
Q. And in your experience when you've done testing and you've
done your field work, are ammonium nitrate prills left behind
after an explosive device is detonated properly?
A. No.
Q. Now, you were also asked about that bag, the brown bag
that -- ICI bag that holds the ammonium nitrate prills.
A. Yes.
Q. Do you recall that? And you were asked -- I don't remember
what it was called but about the white residue that was on
there, the "striplings," I think they referred to.
A. Uh-huh.
Q. If you were storing ammonium nitrate in the sealed bags
over several months in a storage shed, would you expect to see
Paul Rydlund - Redirect
any of those prills on the outside of the bag?
A. On the outside of the bag? No.
Q. Would you expect those bags to leave any ammonium nitrate
residue if you had stored them closed and then you removed them
from the storage shed?
A. No.
Q. You were also asked about the efficiency of a charge if you
used a very small charge. I think you qualified it and said if
you use more fuel than recommended -- used 10 percent, I think
you said, or Mr. Tigar asked you -- and whether it would or
wouldn't detonate efficiently. Do you recall that?
A. Uh-huh.
Q. If you have a very large main charge -- that is, an
ammonium nitrate charge of 4 to 6,000 pounds -- what would be
the effect if you had 10 percent fuel instead of 6 percent
fuel?
A. If -- on a charge of that size?
Q. Of that size.
A. On the configuration that we discussed before on that?
Q. Yes.
A. Then if we had 10 percent -- if we had 10 percent fuel oil,
then I would expect to see prills remain. I would expect it to
be a very inefficient explosion.
Q. If you had 10 percent fuel?
A. Yes.
Paul Rydlund - Redirect
Q. What if you changed the booster?
A. Even if you changed the booster, it would still -- it would
still be an inefficient explosion.
Q. And why is that?
A. Because it's -- because there is too much fuel for the
ammonium nitrate.
Q. Now, what about the question about the -- if barrels were
exposed to -- I think that's what you were being asked about,
the barrels that held ammonium nitrate, if they were exposed to
the seat of the blast and the actual explosion whether any
portions of those barrels would remain.
MR. TIGAR: Excuse me, your Honor. I didn't ask that.