Safety Consulting Engineers, Inc. DEKRA Process Safety www.sceinc.com SAFETY CONSULTING ENGINEERS, INC. DEKRA Process Safety 2131 Hammond Drive, Schaumburg, Illinois 60173 Tel: 847‐925‐8100 9180 W. White Eagle Rd, Forreston, IL 61030 Tel: 815‐938‐2578 TRANSPORATION CLASSIFICATION REPORT CA2010040008 April 29, 2019 Report No. 1899‐2019039 Rev.1 Owen Oil Tools c/o Owen Compliance Services, Inc. P.O. Box 765 12001 County Road 1000 Godley, TX 76044-0765 Attention: David Boston, President Tel: (817) 851‐0660 [email protected]References: Test Report No. 2019039, “Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)”, Safety Consulting Engineers, Inc, April 29, 2019. TITLE: Testing and Recommendation for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter) The recommended shipping name, classification, UN number and packing group for the article are: Igniters, UN0454, 1.4S 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://portal.phmsa.dot.gov/PHMSAPortal2/ (online system use is the application method preferred by the US DOT) If you have any questions concerning this report or require further assistance, please call. Examination by: Thaddeus C. Speed, Physicist Senior Technical Engineer DOT Examiner
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Safety Consulting Engineers, Inc. DEKRA Process Safety www.sceinc.com
SAFETY CONSULTING ENGINEERS, INC. DEKRA Process Safety
9180 W. White Eagle Rd, Forreston, IL 61030 Tel: 815‐938‐2578
TRANSPORATION CLASSIFICATION REPORT CA2010040008
April 29, 2019 Report No. 1899‐2019039 Rev.1 Owen Oil Tools c/o Owen Compliance Services, Inc. P.O. Box 765 12001 County Road 1000 Godley, TX 76044-0765 Attention: David Boston, President Tel: (817) 851‐0660
[email protected] References: Test Report No. 2019039, “Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)”, Safety Consulting Engineers, Inc, April 29, 2019.
TITLE: Testing and Recommendation for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
The recommended shipping name, classification, UN number and packing group for the article are:
Igniters, UN0454, 1.4S 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://portal.phmsa.dot.gov/PHMSAPortal2/ (online system use is the application method preferred by the US DOT)
If you have any questions concerning this report or require further assistance, please call. Examination by: Thaddeus C. Speed, Physicist Senior Technical Engineer DOT Examiner
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 1 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
SAFETY CONSULTING ENGINEERS, INC. DEKRA Process Safety
This report covers testing on an article identified as: OOT‐APRV‐055 Igniter, Type E. Submitted for testing and analysis by
Owen Compliance Services, Inc. on behalf of Owen Oil Tools P.O. Box 765 12001 County Road 1000 Godley, TX 76044-0765
Manufactured by Owen Oil Tools P.O. Box 765 12001 County Road 1000 Godley, TX 76044-0765
References:
1. Test Report No. 1899‐2019039, “Testing and Recommendation for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)”, Safety Consulting Engineers, Inc, April 29, 2019.
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 2 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
2. Drawing: “Owen Oil Tools OOT‐APRV‐055, Comparison of Type E to Type A”, OOT-APRV-055C, Rev. 3.
Type A (Power Charge Igniters) Note: For convenience, References 2‐4 are included as Attachments to this report.
1.0 RECOMMENDED UN CLASSIFICATION ACCORDING TO 49 CFR PARTS 100‐185 ‐ TRANSPORTATION:
Igniters, UN0454, 1.4S
2.0 METHOD OF EXAMINATION: Analogy
3.0 EXAMINATION LOCATION: SCE’s office, Schaumburg, IL, week of 4/25/2019. 4.0 SUMMARY OF RESULTS Type E is very similar to all of the igniters, i.e., Types A, B, C and D, that are already approved within the Owen Oil Tools EX2008120360 approval. This Type E (Power Charge Igniters) uses the same explosive ingredients, similar quantities, provides the same function, is similarly constructed when compared to the currently approved igniters in this family of articles and will be packaged using the same packaging. Analogy was performed based on Type A (Power Charge Igniters), which was tested previously (Reference 4). Based on this examination, it is recommended that the Type E igniters be included on Owen Oil Tools EX2008120360 approval.
5.0 ARTICLE DESCRIPTION
5.1 Purpose and Function As power is applied, the bridge wire heats and ignites the ignition powder surrounding it, which produces a flame which then ignites the larger propellant device with which it is used.
5.2 Explosive Content
Several loadings are proposed:
≤ 2.0 ± 0.05 grams, BP or ≤ 2.0 ± 0.05 grams, BKNO3 (50/50 or 25/75 mixture) or
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 3 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
≤ 2.4 ± 0.05 grams, BP & TSPP (67/33 to 50/50 mixture)
6.0 EXAMINATION:
6.1 Article & Packaging
The OOT‐APRV‐005 Igniters, Type E (Power Charge Igniter) are packaged as follows: Inner Packaging ‐ Boxes, chipboard, each containing one (1) igniter. Outer Packaging ‐ UN4G fiberboard box, each containing not more than fifty (50) inner packagings uniformly segregated from one another and the box sidewalls by not less than three layers of corrugated fiberboard divider pieces and with top and bottom fiberboard pads. See photos, reference 4. Section 10
6.2. Analysis
Analogy is performed between this article OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter) and OOT‐APRV‐055 Igniters, Type A (Power Charge Igniter); see drawing, reference 2.
Table 1: Comparison of Types A and E OOT‐APRV‐055 Igniters
Feature Type A(Power Charge Igniter)
Type E(Power Charge Igniter)
Classification UN 0454/1.4S, EX2008120360(Tested DET‐5306‐074, 2.8g BP)
TBD
Authorized N.E.W. and Content ≤ 2.8 ± 0.05 BP or≤ 2.8 ± 0.05 BKNO3 (50/50 or 25/75 mixture) or ≤ 3.3 ± 0.05 BP & TSPP
≤ 2.0 ± 0.05 BP or ≤ 2.0 ± 0.05 BKNO3 (50/50 or 25/75 mixture) or ≤ 2.4 ± 0.05 BP & TSPP
Contact Spring Configuration Cylindrical Conical
Electrical Circuit One 51 Ω resistor Two 27 Ω resistors with bridge wire
Grounding Wire Sleeve
End Closure Foil & JB weld End seal with adhesive
Packaging Inner: Chipboard box with one igniter; Outer; 4G fiberboard box, up to 50 inner packages per outer package. Separation dunnage required.
Inner: Chipboard box with one igniter; Outer; 4G fiberboard box, up to 50 inner packages per outer package. Separation dunnage required.
The Type E igniter uses the same compositions and less maximum load as compared to the Type A igniter. The change of a conical spring versus a cylindrical spring and the grounding from a wire to the sleeve make no difference on the transportation hazards of these articles. Similarly, the change from a single resistor that heats to provide for electrical ignition of the article versus a bridge wire that heats to provide for electrical ignition will not have an effect on the transportation explosive hazard.
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 4 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
The change in the seal method at the end of the Type E igniter versus the Type A igniter would be a concern if the igniters were packaged in bundles. However, based on the packaging of each igniter per chipboard box, and the fact the Type A igniters qualified as 1.4S, no increased propagation hazard will occur due to this change.
7.0 CONCLUSION: The new article, OOT‐APRV‐055, Type E (Power Charge Igniter), is classed by analogy to OOT‐APRV‐055, Type A (Power Charge Igniter). 8.0 RECOMMENDATION: It is recommended that OOT‐APRV‐055, Type E (Power Charge Igniter), be classed as follows:
a. Proper shipping name: Igniters b. Hazard Class: 1.4S c. UN Identification Number: UN 0454 d. Label Code: 1.4S
It is further recommended that this group of articles be included as an addition to the family of articles currently approved under EX2008120360. See drawing, reference 3. If you have any questions about this requirement or how to proceed please do not hesitate to call us.
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 5 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
I hereby certify that this classification recommendation report, and all evaluation, examination, and testing carried out by Safety Consulting Engineers in preparation of this report are in full compliance with the applicable requirements of the HMR and this approval.
Certification and Examination by: __________________________ Thaddeus C. Speed Senior Technical Engineer DOT Examiner
Safety Consulting Engineers, Inc.
DEKRA Process Safety www.dekra‐process‐safety.com
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 6 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
INSTRUCTIONS FOR DOT SUBMISSION
To receive Department of Transportation (DOT) classification before any explosive product is offered for shipment (per Section 173.56). You may go ONLINE to https://portal.phmsa.dot.gov/PHMSAPortal2/ To access the “Hazmat Special Permits and Approvals Online Application” OR, Email the Approvals Application to: [email protected] OR, You must forward this Test Report and the accompanying Recommendation Letter to the following address:
Associate Administrator for Hazardous Materials Safety PHMSA U.S. DOT
Attention: PHH‐32 1200 New Jersey Avenue SE East Building, 2nd Floor Washington, DC 20590
(Telephone No. 202 – 366‐4512)
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 7 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
ATTACHMENTS
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 8 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
Attachment 1 (Reference 2)
Drawing: “Owen Oil Tools OOT‐APRV‐055, Comparison of Type E to Type A”, OOT-APRV-055C, Rev. 3.
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 9 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 10 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
Attachment 3 (Reference 4)
SCE Test Report No. 241108, Rev. 2, dated 24 November 2008, OOT‐APRV‐055 Igniters Type A (Power Charge Igniters)
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 11 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
CONFIDENTIAL INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 12 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
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INDIVIDUAL COMPANY DATA, PROPRIETARY Page 13 Report No. 2019039, Recommended Shipping Classification for OOT‐APRV‐055 Igniters, Type E (Power Charge Igniter)
Safety Consulting Engineers, Inc.
INDIVIDUAL COMPANY DATA, PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARYFinal Report No. 2015040-LR
TEST REPORT FOR RECOMMENDED HAZARD CLASSIFICATION This report covers testing on power charge igniters identified as:
OOT-APRV-055 Igniters, Type A (Power Charge Igniters)
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, November 1, 2006 Revision:
a. Proper shipping name __Igniters_______________________ b. Hazard Class _______________1.4S__ ___________________
c. Packing Group ______________II_________________________ d. UN Identification Number ___UN 0454__________________ e. Label Code 1.4S______________________________
2.0 Product Description: OOT-APRV-055 Type A igniter is used for igniting power charges. The function is as follows: As power is applied, the resistor heats up (burns) and ignites the explosive material around it. This ignition produces a flame that ignites the Power Charge, which is loaded in a setting tool. The power charge burns and the gas generated is used to drive a piston that sets a plug or a packer in oil/gas well tubing or casing. The ingredient (composition) of the igniter (Type A) tested is shown in Table 1.
Table 1
Composition Amount
Black Powder 2.6 – 2.8 g
Alternative compositions (as shown on drawing OOT-APRV-055A) are shown in Table 2.
Table 2
Composition Amount
TSPP1 and Black powder
0.7 – 1.3 g 1.3 – 2.0 g
3.0 Packaging Configuration:
Shipping container: UN 4G Fiberboard Box containing 50 igniters per box (as depicted in Drawing OOT-APRV-055B, see Appendix A).
4.0 Testing Performed at the SCE Schaumburg Laboratory and Test Site Facility in Forreston, Illinois on the OOT-APRV-055 Type A igniters:
4.1 UN Test Series 4 (a) Thermal Stability Test for Packaged Articles @ 75°C
The OOT-APRV-055 Type A igniter 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
Three UN boxes containing OOT-APRV-055 Type A igniters (see Section 3.0 for packaging description) showed no detonation/explosion when dropped from 12-m drop height. No damage to the box of igniters was observed.
4.3 UN Test Series 6 (a) Single Package Test
Three UN boxes containing OOT-APRV-055 Type A igniters were each tested and each one did not result to propagation when one igniter was set off. No change to the rest of the igniters in the box and no damage to the witness plates were observed.
4.4 UN Test 6 (c) External Fire (Bonfire) Test
Six UN boxes were placed onto a steel stand 1-meter above the ground with 25 gallons of diesel (and gasoline) fuel. The fuel was ignited and observations were made. The packages of OOT-APRV-055 Type A igniters did not exhibit mass explosions. The boxes burned with copious black smoke resulting from the test.
1 Titanium Sub-hydride Potassium Perchlorate
The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows:
To receive Department of Transportation (DoT) classification before any substance or article is offered for shipment (per Section 173.56), Owen Compliance must send this recommendation by fax to (202) 366-3308 and forward the hard copy to the following:
US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA)
400 Seventh Street S.W., Room 8100 Washington, DC 20590
Telephone No. 202 – 366-4512
Recommended by:
C. James Dahn, P.E.
Principal Process Safety Specialist
INDIVIDUAL COMPANY DATA PROPRIETARY
Appendix A
Shipping Configuration for OOT-APRV-055B
INDIVIDUAL COMPANY DATA PROPRIETARY
SAFETY CONSULTING ENGINEERS, INC. 2131 Hammond Drive
TEST REPORT FOR RECOMMENDED HAZARD CLASSIFICATION BY ANALOGY
1.0 Product Type: Core Load Igniters, Power Charge Igniters 2.0 Designation of Item: OOT-APRV-055 Igniters, Type B (Core Load Igniters) and C (Power Charge Igniters)
3.0 Designation of Similar Item for which Analogy is alleged: OOT-APRV-055 Igniter, Type A (Power Charge Igniters) 4.0 Recommended UN Classification for the above product according to
49 CFR Parts 100-185 - Transportation, November 1, 2006 Revision:
a. Proper shipping name __Igniters_______________________ b. Hazard Class _______________1.4S__ ___________________
c. Packing Group ______________II_________________________ d. UN Identification Number ___UN 0454__________________ e. Label Code 1.4S______________________________
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 Product Description: Type B is used for igniting Core Loads (a small can of black powder). During assembly of the tool, the needle from this igniter punctures into Core Load. As power is applied, the resistor heats up (burns) and ignites the black powder surrounding it, which then ignites the propellant inside the needle. A small flame exits the needle, which then ignites the black powder in the Core Load. The power produced from the Core Load then forces a barrel that is on top of the Core Load into the formation. The barrel is then retracted back into the gun body and brought to surface.
OOT-APRV-055 Type C igniter is similar to the Type A igniter. It is used for igniting
power charges. The function is as follows: As power is applied, the resistor heats up (burns) and ignites the explosive material around it. This ignition produces a flame that ignites the Power Charge, which is loaded in a setting tool. The power charge burns and the gas generated is used to drive a piston that sets a plug or a packer in oil/gas well tubing or casing. The ingredient (composition) for both igniters (Type B and C) tested is shown in Table 1.
Table 1
Composition Amount
Black Powder 2.6 – 2.8 g
Alternative compositions (as shown on drawing OOT-APRV-055A) are shown in Table 2.
Table 2
Composition Amount
Type B: Black powder and #800 Propellant
Type C:
Black powder or
TSPP1 and Black powder
0.2 – 0.3 g 0.1 – 0.3 g
1.6 – 2.7 g
0.3 – 1.3 g 1.3 – 2.0
7.0 Packaging Configuration:
Shipping container: UN 4G Fiberboard Box containing 50 igniters per box (as depicted in Drawing OOT-APRV-055B).
The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows:
To receive Department of Transportation (DoT) classification before any substance or article is offered for shipment (per Section 173.56), Owen Compliance must send this recommendation by fax to (202) 366-3308 and forward the hard copy to the following:
US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA)
400 Seventh Street S.W., Room 8100 Washington, DC 20590
Telephone No. 202 – 366-4512
1 Titanium Sub-hydride Potassium Perchlorate
Recommended by:
C. James Dahn, P.E.
Principal Process Safety Specialist
INDIVIDUAL COMPANY DATA PROPRIETARY
INDIVIDUAL COMPANY DATA PROPRIETARY
INDIVIDUAL COMPANY DATA, PROPRIETARY Page 1 Report No. 2013092-LR, DOT Examination of OOT-APRV-055 Igniters,
Type D (Swing Jet Release) by Analogy
Safety Consulting Engineers, Inc.
SAFETY CONSULTING ENGINEERS, INC.
A DEKRA Company
2131 Hammond Drive
Schaumburg, Illinois 60173
CA2010040008
EXPLOSIVES CLASSIFICATION REPORT
Report/Project Title: DOT Examination of OOT-APRV-055 Igniters, Type D