Reference Number: SMS-4211-L1, Rev 0 Date: May 2, 2018

Transcription

1 Reference Number: SMS-4211-L1, Rev 0 Date: May 2, 2018 Manufacturer: Owen Oil Tools Country Road 1000 Godley, Texas Subject: Shipping Classification Recommendation for OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E 1 (Packaging Option 1) Reference 1: Test and Examination Report for OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E (Packaging Option 1) SMS-4211-R1, Rev 0, Safety Management Services, Inc., May 2, 2018 Dear Mr. James Kinsey, The referenced examination report details the results of testing of your OOT-APRV-066 Fluid Sensitive Electric Detonator Family in Option 1 packaging. Based on the test results, SMS makes the following recommendation in accordance with Sections , and of Title 49 CFR for a new explosive: Product Names/Description: OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT- APRV-066 Rev E. Recommended Product Shipping Description: UN0255, Detonators, electric, 1.4B. This recommendation is NOT packaging specific. Packaging per 49 CFR (c), Table of Packing Methods, Packaging Instruction 131. Marking requirements are given in 49 CFR Section Labeling requirements are given in 49 CFR Section To complete the approval process for this material and location: Provide a cover letter requesting classification in accordance with 49 CFR, Section Hereafter referred to as OOT-APRV-066 Fluid Sensitive Electric Detonator Family 1847 West 9000 South, Suite 205 West Jordan, Utah

2 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L1, Rev 0 Option 1 Packaging May 2, 2018 Submit this recommendation letter and the enclosed report with attachments together with all pertinent drawings and chemical composition data using the PHMSA On-Line Special Permit & Approval Application Process located at following web address: Or submit in hard copy to: Associate Administrator for Hazardous Materials Safety PHMSA U.S. Department of Transportation Attention: PHH New Jersey Avenue, SE East Building, 2nd Floor Washington, DC Important: An approval must be received from the Department of Transportation before any explosive may be offered for shipment. I hereby certify that this classification recommendation report, and all evaluation, examination, and testing carried out by Safety Management Services in preparation of this report are in full compliance with the applicable requirements of the HMR and Approval CA (Second Revision). If you have any questions concerning this report or require further assistance, please call SMS at or fax SMS at Thank you, Clint Guymon, PhD, PE Director of Research and Development Safety Management Services, Inc. Kirt N. Sasser, PE Director of Engineering & Testing Safety Management Services, Inc. Page 2 of 2

3 Reference Number: SMS-4211-L2A, Rev 0 Date: May 2, 2018 Owen Oil Tools Country Road 1000 Godley, Texas Subject: OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E 1 (Packaging Option 2) by Analogy Reference 1: Test and Examination Report for OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E (Packaging Option 1) SMS-4211-R1, Rev 0, Safety Management Services, Inc., May 2, 2018 Dear Mr. James Kinsey, A request was made by Owen Oil Tools to provide a recommendation for classification of OOT-APRV-066 Fluid Sensitive Electric Detonator Family in Option 2 packaging via analogy to testing performed by SMS on the OOT APRV-066 Fluid Sensitive Electric Detonator Family in Option 1 packaging (Ref 1). Based on results of that testing, as detailed in the supporting data section of this recommendation, SMS has determined that the hazard characteristics are NOT significantly different from the detonator previously tested (OOT APRV-066 Fluid Sensitive Electric Detonator Family in Option 1 packaging). SMS makes the following recommendation in accordance with 49 CFR and : Product Names/Description: OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT- APRV-066 Rev E. Recommended Product Shipping Description: UN0255, Detonators, electric, 1.4B. This recommendation IS NOT packaging specific. Packaging requirements are given in 49 CFR Section (c), Table of Packing Methods, Packing Instruction 131 applies. Marking requirements are given in 49 CFR Section Hereafter referred to as OOT-APRV-066 Fluid Sensitive Electric Detonator Family 1847 West 9000 South, Suite 205 West Jordan, Utah

4 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Labeling requirements are given in 49 CFR Section To complete the approval process for this material and location: Provide a cover letter requesting classification in accordance with 49 CFR, Section Submit this recommendation letter and the enclosed report with attachments together with all pertinent drawings and chemical composition data using the PHMSA On-Line Special Permit & Approval Application Process located at following web address: Or submit in hard copy to: Associate Administrator for Hazardous Materials Safety PHMSA U.S. Department of Transportation Attention: PHH New Jersey Avenue, SE East Building, 2nd Floor Washington, DC Important: An approval must be received from the Department of Transportation before any explosive may be offered for shipment. I hereby certify that this classification recommendation report, and all evaluation, examination, and testing carried out by Safety Management Services in preparation of this report are in full compliance with the applicable requirements of the HMR and Approval CA (Second Revision). If you have any questions concerning this report or require further assistance, please call SMS at or Fax SMS at Thank you, Clint Guymon, PhD, PE Director of Research and Development Safety Management Services, Inc. Kirt N. Sasser, PE Director of Engineering & Testing Safety Management Services, Inc. Page 2 of 7

5 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Analogy Support Data: These articles are manufactured by Owen Oil Tools at their Godley, TX facility. SMS previously tested the Fluid Sensitive Electric Detonator OOT-APRV-066 Configuration #1 (P/N DET ) and is making a recommendation from the tested part number for the parts described and listed herein. SMS reviewed the specifications and drawings for the Fluid Sensitive Electric Detonator Assemblies, OOT-APRV-066 Configuration #2 and Configuration #4. The drawings will be provided to the DOT as part of the submittal process. Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #2 The Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #2 differs from Configuration #1 in that the detonator (Configuration #1) is surrounded by a plastic piece as shown in Figure 1. Figure 1: Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #2 Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #4 The Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #4 likewise only differs from Configuration #1 in that the detonator (Configuration #1) is surrounded by a plastic piece as shown in Figure 2. Page 3 of 7

6 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Figure 2: Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #4 The explosive formulations for the Fluid Sensitive Electric Detonators under review are identical to that of the tested Fluid Sensitive Electric Detonator, OOT-APRV-066 Configuration #1 (P/N DET ). The explosive components with their maximum explosive loads are listed in Table 1. Lesser loads may be used as required. Table 1: Fluid Sensitive Electric Detonator Explosive Components and Maximum Loads Maximum N.E.W. (grams +/- 0.05g) Non-Primary Expl. Primary Expl. Ignition Base (RDX or Main Total N.E.W. Total Total (BKNO3) HNS) (Lead Azide) Packaging Packaging for the configurations of the Fluid Sensitive Electric detonators under review (Photos 1-2) is similar to the previously tested part (Fluid Sensitive Electric Detonator: OOT-APRV-066 Configuration #1 P/N DET ) but with fewer detonators per outer box as follows: Outer Packaging: Box, fiberboard (4G), containing not more than 10 inner packagings per outer box. Intermediate Packaging: Dividers, fiberboard, with 3 or more layers to separate inner packaging layers from each other within the outer packaging and to fill void spaces within the package. Page 4 of 7

7 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Inner Packaging: Chipboard carton containing 1 detonator. Suitable packing material may be used if needed to prevent movement of the detonator within its carton during shipment. Photo 1: Inner Packaging for Option 2 Packaging Chipboard Box Photo 2: Outer Packaging for Option 2 Packaging UN 4G Box Page 5 of 7

8 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Previous Testing Previous Tests on (Fluid Sensitive Electric Detonator: OOT-APRV-066 Configuration #1 P/N DET ) included UN Series 4(a) (Thermal Stability), 4 (b) (12-Meter Drop), 6 (a) (Single Package Test), 6(c) (External Fire), and 6(d) (Unconfined Package). UN Series 6 (b) (Stack Test) were waived based on the results of the Sigle Package test. A summary of test results is given in Table 2. Table 2: Test Results for Fluid Sensitive Electric Detonator: OOT-APRV-066 Configuration #1 P/N DET Test Conditions and Results Pass/Fail Thermal Stability 12-meter Drop Single Package No external effects or temperature increase observed. Three trials resulted in minor external damage to packaging and no initiation of any of the articles. Articles caused to function as designed. Three trials confined with loose sand resulted in no crater, no damage to the witness plate, and no scattering of the sand. Outer package was undamaged with no propagation to adjacent articles. Pass (not forbidden) Pass (not forbidden) Pass (no explosion) Stack Waived based on Single Package Test results Waived External Fire Unconfined Package No mass explosion. Hazardous projectiles were not observed. No damage to the witness screens occurred. No mass explosion, propagation to one adjacent inner article. Projections tore completely through the outer package. No damage to the witness plate. Pass (1.4S Candidate) Fail (1.4B Candidate) Page 6 of 7

9 OOT-APRV-066 Fluid Sensitive Electric Detonator Family by Analogy SMS-4211-L2A, Rev 0 Option 2 Packaging May 2, 2018 Comparison Based on the following, the behavior of the Fluid Sensitive Electric Detonators: OOT-APRV-066 Configurations #2 and #4 are anticipated to be no greater hazard than that of the previously tested Fluid Sensitive Electric Detonator: OOT-APRV-066 Configuration #1 (P/N DET ): All Fluid Sensitive Electric Detonator configurations have the exact same explosive formulation. The physical dimensions of the detonator housing inside the plastic (Configuration #2 and #4) are identical for all articles. The material surrounding the detonator will limit the likelihood of propagation between articles. The plastic material surrounding the detonator in Configuration #2 and #4 is not expected to result in fiery projections from the fire or metallic projections The proposed packaging is similar to that tested but allows for only 1/5 of the total number of detonators per box. Conclusions and Recommendation: In accordance with 49 CFR Section and , SMS has examined Fluid Sensitive Electric Detonators: OOT-APRV-066 Configurations #2 and #4, manufactured by Owen Oil Tools and has determined that the hazard characteristics are no more hazardous than the article previously tested (Fluid Sensitive Electric Detonators: OOT-APRV-066 Configurations #1, P/N DET ). SMS recommends by analogy that the articles be classified as UN0255, Detonators, electric, 1.4B. References: (1) Test and Examination Report for Fluid Sensitive Electric Detonator (OOT- APRV-066 Configuration #1) SMS-4211-R1, Rev 0, Safety Management Services, Inc., May 2, (2) Fluid Sensitive Electric Detonator Assembly Drawings, OOT-APRV-066 Approval Drawing Concept (Rev C).pdf, DWG No. OOT-APRV-066, Rev. C, Owen Oil Tools LP, Sheets 1, 2, and 4, March 7, Page 7 of 7

10 Reference Number: SMS-4211-R1, Rev 0 Date: May 2, 2018 Manufacturer: Owen Oil Tools Country Road 1000 Godley, Texas Subject: Test and Examination Report for OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E 1 (Packaging Option 1) References: (1) Application for Examination and Classification of the OOT-APRV-066 Fluid Sensitive Electric Detonator Family dated December 7, (2) Drawing No. OOT-APRV-066, Owen Oil Tools LP, Rev E TEST AND/OR ANALYSIS REPORT This report describes testing and analysis performed in support of a shipping division classification recommendation of the OOT-APRV-066 Fluid Sensitive Electric Detonator Family in packaging option 1 as described Section 9 of the OOT application. Detonators in this product family are manufactured by Owen Oil Tools at their Godley, TX facility. OOT-APRV-066 Fluid Sensitive Electric Detonators The OOT-APRV-066 Fluid Sensitive Electric Detonator Family consists of detonators designed to be loaded into and to initiate oil & gas well downhole tools such as perforating guns. The tool into which the detonator is loaded provides a barrier between fluids present in the well and detonator (hence the designation non-exposed ), thereby ensuring that the detonator remains dry and useable. The detonator is functioned by applying a sufficient current to the electrical header assembly to initiate the BKNO3 igniter to then initiate the primary and secondary explosive charges in the perforating gun. The article is shown in Photo 1 and Figure 1. 1 Hereafter referred to as OOT-APRV-066 Fluid Sensitive Electric Detonator Family 2 Hereafter referred to as OOT application 1847 West 9000 South, Suite 205 West Jordan, Utah Page 1 of 12

11 Photo 1: Tested Detonator from OOT-APRV-066 Fluid Sensitive Electric Detonator Family (P/N DET ) Figure 1: Tested Detonator from OOT-APRV-066 Fluid Sensitive Electric Detonator Family (P/N DET ) Page 2 of 12

12 For this analysis, OOT detonator P/N DET was selected. Each DET detonator has a maximum net explosive weight (NEW) of g. Properties of the OOT-APRV-066 Fluid Sensitive Electric Detonator Family are provided in Table 1. Table 1: Properties of the OOT APRV 066 Fluid Sensitive Electric Detonator Family Maximum N.E.W. (grams +/- 0.05g) Non-Primary Expl. Primary Expl. Ignition Base Main Total N.E.W. Total Total (BKNO3) (RDX or HNS) (Lead Azide) Packaging As described in Option 1 of Section 9 of the OOT application, for transport, non-bulk packaging compliant to 49 CFR (c), Table of Packing Methods, will be used, as follows: Outer Packaging: Box, fiberboard (4G), containing not more than 50 inner packagings per outer box. Intermediate Packaging: Dividers, fiberboard, with 1 or more layers to separate inner packaging layers from each other within the outer packaging Inner Packaging: Bag, sealed, moisture barrier, anti-static containing 1 plastic, static dissipating containing 1 article detonator. No more than 5 inner packagings per layer. Each outer package contains 50 units (38.5 grams maximum N.E.W per box.) and is approximately m 3 in volume. Photos 2-4 show the Option 1 packaging of the OOT-APRV-066 Fluid Sensitive Electric Detonator Family. Photo 2: Outer Packaging for Fluid Sensitive Electric Detonators Page 3 of 12

13 Photo 3: Packaging for Fluid Sensitive Electric Detonators Photo 4: Inner Packaging for Fluid Sensitive Electric Detonators Page 4 of 12

14 Testing UN Series 4 and 6 were performed on the OOT-APRV-066 Fluid Sensitive Electric Detonator Family as packaged for shipment in Option 1 packaging. Tests included UN Series 4(a) (Thermal Stability), 4(b)(ii) (12-Meter Drop), 6(c) (External Fire), 6(a) (Single Package), and 6(d) (Unconfined Package) tests. The 6(b) (Stack Test) was waived based on the results of the Single Package test. A summary of test results is given in Table 2. Table 2: Test Results for Fluid Sensitive Electric Detonators (OOT-APRV-066 Configuration #1) Test Conditions and Results Pass/Fail Thermal Stability No external effects or temperature increase observed. Pass (not forbidden) Three trials resulted in minor external damage 12-meter Pass to packaging and no initiation of any of the Drop (not forbidden) articles. Single Package External Fire Articles caused to function as designed. Three trials confined with loose sand resulted in no crater, no damage to the witness plate, and no scattering of the sand. Outer package was undamaged with no propagation to adjacent articles. Pass (no explosion) Stack Waived based on Single Package Test results Waived No mass explosion. Hazardous projectiles were not observed. No damage to the witness screens occurred. Unconfined Package No mass explosion, propagation to one adjacent inner article. Projections tore completely through the outer package. No damage to the witness plate. Pass (1.4S Candidate) Fail (1.4B Candidate) The UN Series 4(a), Thermal Stability Test, was conducted on the articles in a worst-case packaging configuration. No visual signs of reaction (explosion, ignition, damage to the case, exudation) were observed on the post-test article and no temperature increase above 3 C was observed. Page 5 of 12

15 Figure 2: Thermal Stabilty Test for OOT-APRV-066 Fluid Sensitive Electric Detonators in Option 1 Packaging The UN Series 4(b), 12-Meter Drop Test, was conducted on OOT-APRV-066 Fluid Sensitive Electric Detonators as packaged for shipment in Option 1 packaging. Three drops in three different orientations (right-side up, upside down, and on a side) were performed on the packaged articles (50 articles per package). No fire or explosion occurred in any of the three trials. The boxes opened on impact and some articles were scattered onto the plate. The test setup is shown in Photo 5. Photo 6 shows the results. Photo 5: 12-Meter Drop Test Setup Page 6 of 12

16 Photo 6: 12-Meter Drop Test Results A UN Series 6(a) Single Package test was performed on the OOT-APRV-066 Fluid Sensitive Electric Detonators in Option 1 packaging (Photo 7). No mass explosion occurred in any of the trials and only the donor functioned in each trial (Photos 8-9). The sand was not disrupted. There was no damage to any of the witness plates (Photo 10). Photo 7: Single Package Test Setup Page 7 of 12

17 Photo 8: Representative Single Package Test Results Photo 9: Representative Single Package Test Results Page 8 of 12

18 Photo 10: Single Package Test Results A UN Series 6(c), External Fire test, was performed on the OOT-APRV-066 Fluid Sensitive Electric Detonators in Option 1 packaging. Twelve outer packages (each with volume of m 3 ) with 50 units per package and three packages with 10 units per package were placed on the fire (Photo 11) with a total NEW of 438 grams. The packages meet the 0.15 m 3 requirement. The environmental conditions at time of the test were as follows: Wind: 14 mph Temp: 49 F RH: 47% Photo 11: External Fire Test Setup Page 9 of 12

19 Articles initiated individually over a 10-minute period. A mass explosion was not observed. A fireball or jet of flame was not observed. No fiery projections from the product were observed. Upon post-test inspection, there were no indentations in the witness screens. Metallic projections exceeding 8 J were not observed based on the distance-mass relation in the UN Manual of Tests and Criteria, Figure Based on the results of the External Fire test, the units passed all the requirements to be a candidate for Division 1.4S, subject to the results of the Unconfined Package Test detailed below. Owen Oil Tools OOT-APRV-066 Fluid Sensitive Electric Detonators (Option 1 packaging) External Fire Test DOT Witness: Clint Guymon OOT Photo 12: External Fire Test Results Photo 13: External Fire Test Results Page 10 of 12

20 A UN Series 6(d), Unconfined Package test, was performed on the OOT-APRV-066 Fluid Sensitive Electric Detonators in Option 1 packaging. A donor article was initiated as designed. The articles were oriented such that if a flame or flash was produced it would be facing the sheet of paper 25 cm from the package (Photo 14). Photo 14: Unconfined Package Test Setup Donor Article Three unconfined trials were conducted. No mass explosion occurred in any of the trials and only the donor functioned in each trial. Projections passed completely through the packaging, tearing the packaging and the sheet of paper next to the package. The other articles were scattered about the package (Photo 15). No damage to the witness plate occurred. Based on the test results, these articles are excluded from compatibility group S and the Single Package test was required to be performed on the packaged articles. Photo 15: Unconfined Package Test - Typical Results - Projections Page 11 of 12

21 Conclusions and Recommendation: Behavior of the OOT-APRV-066 Fluid Sensitive Electric Detonators in Option 1 packaging is consistent with a recommendation into hazards division 1.4B. The unconfined package test showed that there is a projection hazard. The external fire resulted in no mass propagation, and no damage to the witness screens. The Unconfined Package Test indicated that hazardous effects escaped the packaging and thus the articles, as packaged, are candidates for 1.4 other than S. Based on the results of testing and in accordance with 49 CFR Section , , and , Special provisions 103, 148, and 347, SMS recommends that the OOT-APRV-066 Fluid Sensitive Electric Detonator family containing not more than ±0.05 grams of BKNO3, Lead Azide, and RDX or HNS as depicted in drawing OOT-APRV-066 Rev E (Packaging Option 1), manufactured by Owen Oil Tools, be classed into Division 1 as UN0255, Detonators, electric, 1.4B. This recommendation is NOT packaging specific. Packaging per 49 CFR (c), Table of Packing Methods, Packaging Instruction 131. Marking requirements are given in 49 CFR Section Labeling requirements are given in 49 CFR Section I hereby certify that this classification recommendation report, and all evaluation, examination, and testing carried out by Safety Management Services in preparation of this report are in full compliance with the applicable requirements of the HMR and Approval CA (Second Revision). Thank you, Clint Guymon Director of Research and Development Safety Management Services, Inc. Kirt N. Sasser Director of Engineering & Testing Safety Management Services, Inc. Rusty Christensen Engineer Safety Management Services, Inc. Page 12 of 12