CLASSIFICATION RECOMMENDATION LETTER

SAFETY CONSULTING ENGINEERS, INC. 2131 Hammond Drive Schaumburg, Illinois 60173 847-925-8100 9180 W. White Eagle Rd Forreston, Illinois 61030 815-938-2578 Owen Oil Tools c/o Owen Compliance Services P. O. Box 765 Godley, Texas 76044-0765 CLASSIFICATION RECOMMENDATION LETTER Project No. 475 June 7, 2010 Attention: Subject: References: Mr. David Boston 847-551-0660 Recommended Shipping Classification for OOT-APRV-058A Exposed Crimp-on Electric Detonator Family containing not more than 1.7 grams of lead azide and HNS as depicted in drawing OOT-APRV-058A, Rev 0 and Part Number DET-3050-002. Test Report for Explosive Classification of OOT-APRV-058A Exposed Crimp-on Electric Detonator Family Dear Mr. Boston: Owen Oil Tools requested Safety Consulting Engineers, Inc., a Chilworth Global Company, to evaluate OOT-APRV-058A Exposed Crimp-on Electric Detonator Part Number (DET-3050-002) and to recommend the applicable shipping classification for this material. The OOT- APRV-058A Exposed Crimp-on Electric Detonator (Part Number DET-3050-002) is manufactured at Godley, Texas. The referenced drawing number gives the specifications of the detonators. The recommended shipping name, classification, UN number and packing group for the OOT-APRV-058A detonator family is: Detonators, Electric, 1.4S, II, 131, UN 0456

This recommendation IS package dependent. To complete the approval process and receive an EX number for this material and location: 1. Provide a cover letter requesting classification in accordance with 49 CFR, Section 107.705. 2. Submit your cover letter, along with this Classification Recommendation Letter and the above referenced report to: Online: https://hazmatonline.phmsa.dot.gov/online%20approvals/pages/welcome.aspx (online system use is the application method preferred by the US DOT) By Fax: to (202) 366-3308 and mail the hard copy to the following address: US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) 400 Seventh Street S.W. Room 8100 Washington, DC 20590-0001 Attention: Approvals, DHM-32 Telephone No. 202 366-4511 If you have any questions concerning this report or require further assistance, please call. Thank you, SAFETY CONSULTING ENGINEERS, INC. C. James Dahn Registered Professional Engineer

SAFETY CONSULTING ENGINEERS, INC. 2131 Hammond Drive Schaumburg, Illinois 60173 Approval CA2010040008 Project Name: Owen Compliance Project No. 475 Date: 7 June 2011 Report No. 070611-1 Rev 1 TEST REPORT FOR RECOMMENDED HAZARD CLASSIFICATION This report covers testing on product identified as: OOT-APRV-058A (Part Number DET-3050-002) Exposed Crimp-on Electric Detonator containing not more than 1.7 grams of lead azide and HNS as depicted in drawing OOT-APRV- 058A, Rev 0. Submitted for testing and analysis by: Owen Oil Tools LP c/o Owen Compliance Services, Inc. 12001 County Road 1000 Godley, TX 76044-0765 1.0 Recommended UN Classification for the above product according to 49 CFR Parts 100-185 - Transportation, Revised as of October 1, 20010: a. Proper shipping name Detonators, Electric b. Hazard Class/Division 1.4S c. Packing Group II d. Packaging Reference 131 e. UN Identification Number UN0456 f. UN Special Provision 347 g. Label Codes 2.0 Product Description: OOT-APRV-058A Exposed Crimp-on Electric Detonator Family containing not more than 1.7 grams of lead azide and HNS as depicted in drawing OOT-APRV-058A, Rev 0.

The explosive contents for each detonator is shown in Table 1. Table 1 N.E.W. (g ± 0.05g) Base (HNS) Primer (Lead azide) Total Part Number Cushion Main Nonel Total Main Nonel Total NEW DET-3050-002 0.065 0.454 0.648 1.2 0.26 0.162 0.4 1.6 3.0 Packaging OOT-APRV-058A Exposed Crimp-on Electric Detonators will be packaged to comply with the requirements of the 49 CFR 173.62 specifically, with packaging instruction 131. OOT uses the packaging described below for the OOT-APRV-058A Exposed Crimp-on Electric Detonators: Inner Packaging Each detonator is placed in a static-safe plastic bag and inserted in a chipboard carton. The assembly is housed in a 2.38 OD schedule 40 (nominal thickness of 0.15 inches) steel pipe 6 inches long with pipe end caps at both ends. Outer packaging - UN 4G fiberboard box containing 10 inner packagings. 4.0 Testing Performed at the SCE Test Site Facility in Forreston, Illinois on the detonators in packaging. The following tests were performed on the product and packaging: Tests Conducted on Articles and in packages Description Content (gm) 4(a) 4(b)(ii) 6(a) 6(c) 6(d) X Articles OOT APRV058A Exposed 1.7 LA/HNS in inner X - X X Crimp-on Electric Detonator packaging 4.1 UN Test Series 4 (a) Thermal Stability Test for Packaged Articles @ 75 C The articles listed above did not exhibit ignition or explosion, thermal runaway, or temperature difference of 3 C when subjected to the 75 C temperature for 48 hours.

4.2 UN Test Series 4 (b)(ii) Twelve-Meter Drop Test for Packaged Articles The OOT APRV-058A Exposed Crimp-on Electric Detonator articles showed no detonation/explosion when dropped from 12-m drop height in three orientations. No damage to the boxes of detonators was observed. 4.4 UN Test 6 (c) External Fire (Bonfire) Test The boxes were placed onto a steel stand 1-meter above the ground with 75 gallons of diesel (and 5 gallons of gasoline) fuel. After appropriate actions were taken, the video camera was turned on, the fuel fire was ignited and observations were made. Seven (7) boxes in the bonfire did not exhibit fiery projections, fireball out of the packages, projections onto the witness panels or mass explosions. After 30 minutes no detonator reports were noted. The boxes burned with copious black smoke resulting from the test. Of the 70 inner packaged schedule pipes, the following results were noted: Pipes intact Pipes bulged Pipes bulged/cracked Live detonators in pipes fell into liquid fuel 7 each 31 each 16 each 16 each 4.5 UN Test 6 (d) Unconfined Package Test Three UN boxes of OOT-APRV-058A Exposed Crimp-on Electric Detonator were tested each in different configurations to determine if there are hazardous effects outside the package arising from accidental ignition or initiation of the contents. Only one donor detonator (from the package) was initiated. In each test, the donor fired without disturbing the box. No change to the rest of the detonators in the box and no damage to the witness plates were observed. The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows: Packaging Section 173.62 Marking Section 172.300 Labeling Section 172.411 See Attachments for details on articles and packaging. To receive Department of Transportation (DOT) classification before any explosive is offered for shipment (per Section 173.56), you must forward this recommendation to:

Associate Administrator for Hazardous Materials Safety PHMSA U.S. DOT Attention: PHH-32 1200 New Jersey Avenue SE East Building, 2 nd Floor Washington, DC 20590 Telephone No. 202 366-4512. Recommended by: C. James Dahn Registered Professional Engineer

SAFETY CONSULTING ENGINEERS, INC. 2131 Hammond Drive Schaumburg, Illinois 60173 847-925-8100 9180 W. White Eagle Rd Forreston, Illinois 61030 815-938-2578 CLASSIFICATION RECOMMENDATION BY ANALOGY LETTER Owen Oil Tools c/o Owen Compliance Services P. O. Box 765 Godley, Texas 76044-0765 Project No. 475 June 7, 2010 Attention: Subject: References: Mr. David Boston 847-551-0660 Recommended Shipping Classification for OOT-APRV-058A Exposed Crimp-on Electric Detonator Family containing not more than 1.7 grams of lead azide and HNS as depicted in drawing OOT-APRV-058A, Rev 0. and Part Number DET-3050-001. Test Report for Explosive Classification of OOT-APRV-058A Exposed Crimp-on Electric Detonator Family Dear Mr. Boston: Owen Oil Tools requested Safety Consulting Engineers, Inc., a Chilworth Global Company, to evaluate OOT-APRV-058A Exposed Crimp-on Electric Detonator (Part Number DET-3050-001) and to recommend the applicable shipping classification for this material. The OOT- APRV-058A Exposed Crimp-on Electric Detonator (Part Number DET-3050-001) is manufactured at Godley, Texas. The referenced drawing number gives the specifications of the detonators. The recommended shipping name, classification, UN number and packing group for the OOT- APRV-058A detonator family is: Detonators, Electric, 1.4S, II, 131, UN 0456

SAFETY CONSULTING ENGINEERS, INC. 2131 Hammond Drive Schaumburg, Illinois 60173 Approval CA2010040008 Project Name: Owen Compliance Project No. 475 Date: 7 June 2011 Report No. 070611-2 Rev 1 TEST REPORT FOR RECOMMENDED HAZARD CLASSIFICATION BY ANALOGY 1.0 Product Type: Detonators, Electric 2.0 Designation of Product: OOT-APRV-058A EXPOSED CRIMP-ON ELECTRIC DETONATOR - PART NUMBER DET-3050-001 3.0 Designation of Similar Article for which Analogy is alleged: OOT-APRV-058A EXPOSED CRIMP-ON ELECTRIC DETONATOR - PART NUMBER - DET-3050-002 4.0 Recommended UN Classification for the Electric Detonator Article according to 49 CFR Parts 100-185 Transportation, Revised as of October 1, 2010: a. Proper shipping name Detonators, Electric_ b. Hazard Class/Division 1.4S c. Packing Group II d. Packaging Reference 131 e. UN Identification Number UN0456 f. UN Special Provision 347 g. Label Codes 5.0 Manufactured, shipped, and submitted for analysis by: Owen Oil Tools LP C/O Owen Compliance Services, Inc. 12001 County Road 1000 Godley, TX 76044-0765

6.0 Comments: The difference between the OOT-APRV-058A EXPOSED CRIMP-ON ELECTRIC DETONATOR - PART NUMBER DET-3050-001 and the previously tested OOT-APRV-058A EXPOSED CRIMP-ON ELECTRIC DETONATOR PART NUMBER - DET-3050-002 by SCE is shown in Table 1. Table 1 N.E.W. (g ± 0.05g) Base (HNS) Primer (Lead azide) Total Part Number Cushion Main Nonel Total Main Nonel Total NEW DET-3050-001 0.07 0.46 0.6 1.1 0.3 0.2 0.5 1.6 DET-3050-002 0.065 0.454 0.648 1.2 0.26 0.162 0.4 1.6 There are no significant differences in hazard characteristics of the two articles. 7.0 Packaging OOT-APRV-058A Exposed Crimp-on Electric Detonators will be packaged to comply with the requirements of the 49 CFR 173.62 specifically, with packaging instruction 131. OOT uses the packaging described below for the OOT-APRV-058A Exposed Crimp-on Electric Detonators: Inner Packaging Each detonator is placed in a static-safe plastic bag and inserted in a chipboard carton. The assembly is housed in a 2.38 OD schedule 40 (nominal thickness of 0.15 inches) steel pipe 6 inches long with pipe end caps at both ends. Outer packaging - UN 4G fiberboard box containing 10 inner packagings. The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows: Packaging Section 173.62 Marking Section 172.300 Labeling Section 172.411 See Attachments for details on articles and packaging. To receive Department of Transportation (DOT) classification before any explosive is offered for shipment (per Section 173.56), you must forward this recommendation by Fax to (202)366-3308 and forward the hard copy to the following: