INDIVIDUAL COMPANY DATA, PROPRIETARY CA EXPLOSIVEE CLASSIFICATION ANALOGY REPORT

Transcription

1 INDIVIDUAL COMPANY DATA, PROPRIETARY SAFETY CONSULTING ENGINEERS, INC. A DEKRA Company 2131 Hammond Drive Schaumburg, Illinois W. White Eagle Rd Forreston, IL CA /28/2015 EXPLOSIVEE CLASSIFICATION ANALOGY REPORT Title: DOT Recommendation for OOT-APRV-055 Igniter Family Report No.: LR SCE No.: 1184 Examiner: Graham Walsh Owen Oil Tools c/o Owen Compliance Services PO Box 765 Godley, TX Attention: Mr. Ben Potter This report covers testing on an article identified as: OOT-APRV-055 Igniter Family Submitted for analysis by: Owen Oil Tools 1.0 Recommended UN Classification Recommended UN Classification for the above article according to 49 CFR Parts Transportation: a. Proper shipping name: Igniters b. UN Identification Number: UN0454 c. Hazard Class: 1.4S 2.0 Method of Examination: ANALOGY INDIVIDUAL COMPANY DATA, PROPRIETARY Page 1 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

2 INDIVIDUAL COMPANY DATA, PROPRIETARY 3.0 Test Location: Analysis to support this analogy was conducted at SCE facilities in Schaumburg, Il. 4.0 Product Description: The OOT-APRV-055 Igniter Family consists of four articles (Types A D) which are electrically initiated articles using a pyrotechnic load to begin a reaction in the oil tool services industry. 5.0 Maximum Parameters of Design Type Drawing number OOT-APRV-055 Rev 2, dated 3/2/2015 and is attached. The formulations and energetic weights are listed on the drawing. 6.0 Packaging Examined: Inner Packaging: Fiberboard box containing one article in a plastic bag. Intermediate Packaging: Fiberboard dividers defining 50 cells, each cell containing one inner package Outer Packaging: UN 4G fiberboard box containing one intermediate package for a maximum of 50 articles. 7.0 Justification for Analogy: The OOT-AAPRV-055 Family of Igniters now produced by Owen Oil Tools have the same design as the previously tested article (Reference: SCE Report No Rev 2) which was approved (Reference: EX , Revision 2). This report covers a proposed change to the Type A and Type C Igniters, which are used for igniting power charges. Owen Oil Tools previously loaded the Type A and Type C Igniters with Black Powder or a mixture of Black Powder and TSPP. In order to increase reliability of the article, Owen Oil Tools is proposing an additional third option to use BKNO 3 in the articles. To support this change, a UN 6(d) test was conducted on the Type A Igniter using load of BKNO 3. In the testing, there was no propagation of the donor charge to any acceptors, and as seen in the figures below, there was slight damage to the inner package in the form of scorching, but there was no ignition of the packaging materials or hazardous effects outside of the package. The addition of BKNO 3 to the articles would not create a higher hazard in the external fire test, as the articles are small and do not create projection hazards, and the articles do not show a propensity for mass reaction. INDIVIDUAL COMPANY DATA, PROPRIETARY Page 2 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

3 INDIVIDUAL COMPANY DATA, PROPRIETARY Figure 1. UN 6(d) test setup Figure 2. UN 6(d) test result inner pkg 8.0 Conclusion: The substitution of BKNO 3 for Black Powder resulted in no increase in the hazard of the igniter in the UN 6(d) single package test, and therefore, the articles would test out as a 1.4S for transportation. 9.0 Recommendation: Add BKNO 3 as a defined composition, per the attached drawing to EX ; Igniters, UN0454; Hazard Classification or Division 1.4S, PG- II 10.0 The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows: Packaging: Section Marking: Section Labeling: Section INDIVIDUAL COMPANY DATA, PROPRIETARY Page 3 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

4 INDIVIDUAL COMPANY DATA, PROPRIETARY If you have any questions about this requirement or how to proceed please do not hesitate to call us. 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: a DEKRA Company Graham Walsh Senior Explosives Engineer DOT Examiner INDIVIDUAL COMPANY DATA, PROPRIETARY Page 4 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

5 INDIVIDUAL COMPANY DATA, PROPRIETARY INSTRUCTIONS FOR DOT SUBMISSION To receive Department of Transportation (DOT) classification before any explosive product is offered for shipment (per Section ). You may go ONLINE to To access the Hazmat Special Permits and Approvals Online Application 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 New Jersey Avenue SE East Building, 2nd Floor Washington, DC (Telephone No ) INDIVIDUAL COMPANY DATA, PROPRIETARY Page 5 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

6 INDIVIDUAL COMPANY DATA, PROPRIETARY ATTACHMENT: Drawing number OOT-APRV-055 Rev 2, dated 3/2/2015 INDIVIDUAL COMPANY DATA, PROPRIETARY Page 6 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

7 INDIVIDUAL COMPANY DATA, PROPRIETARY INDIVIDUAL COMPANY DATA, PROPRIETARY Page 7 Final Report No LR, DOT Recommendation for OOT-APRV-055 Igniter Family by Analogy

8 INDIVIDUAL COMPANY DATA PROPRIETARY SAFETY CONSULTING ENGINEERS, INC Hammond Drive Schaumburg, Illinois Project Name: Owen Compliance Project No D Date: 24 November 2008 Report No._241108_(Rev. 2) 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 County Road 1000 Godley, TX Recommended UN Classification for the above product according to 49 CFR Parts 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 Black Powder Amount g

9 Alternative compositions (as shown on drawing OOT-APRV-055A) are shown in Table 2. Table 2 Composition TSPP 1 and Black powder Amount g 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 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

10 The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows: Packaging Section Marking Section Labeling Section To receive Department of Transportation (DoT) classification before any substance or article is offered for shipment (per Section ), Owen Compliance must send this recommendation by fax to (202) 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 Telephone No Recommended by: C. James Dahn, P.E. Principal Process Safety Specialist INDIVIDUAL COMPANY DATA PROPRIETARY

11 Appendix A Shipping Configuration for OOT-APRV-055B

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13 INDIVIDUAL COMPANY DATA PROPRIETARY SAFETY CONSULTING ENGINEERS, INC Hammond Drive Schaumburg, Illinois Project Name: Owen Compliance Project No D Date: 25 November 2008 Report No._ (Rev. 1) 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 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 County Road 1000 Godley, TX 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

14 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. Composition Black Powder Table 1 Amount g Alternative compositions (as shown on drawing OOT-APRV-055A) are shown in Table 2. Composition Type B: Black powder and #800 Propellant Type C: Black powder or TSPP 1 and Black powder 7.0 Packaging Configuration: Table 2 Amount g g g g 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: Packaging Section Marking Section Labeling Section To receive Department of Transportation (DoT) classification before any substance or article is offered for shipment (per Section ), Owen Compliance must send this recommendation by fax to (202) 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 Telephone No Titanium Sub-hydride Potassium Perchlorate

15 Recommended by: C. James Dahn, P.E. Principal Process Safety Specialist INDIVIDUAL COMPANY DATA PROPRIETARY

16 INDIVIDUAL COMPANY DATA PROPRIETARY SAFETY CONSULTING ENGINEERS, INC. A DEKRA Company 2131 Hammond Drive Schaumburg, Illinois CA EXPLOSIVES CLASSIFICATION REPORT Report/Project Title: DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) Project Name/No. Owen Compliance Services, Inc./ SCE # 828 Report No LR Date August 21, 2013 Owen Oil Tools LP c/o Owen Compliance Services, Inc. P.O. Box 765 Godley, TX Attention: Mr. David W. Boston, President This report covers examination on the article identified as: OOT-APRV-055 Igniters, Type D (Swing Jet Release) Submitted for Examination by: Owen Oil Tools LP P.O. Box County Road 1000 Godley, TX Examination Method used: Hazard Classification by Analogy 2.0 Designation of Similar Articles to which Analogy is alleged: OOT-APRV-055 Igniters, Type A (Power Charge Igniters) 3.0 Manufactured and Submitted for Classification by: Owen Oil Tools LP County Road 1000 Godley, TX INDIVIDUAL COMPANY DATA, PROPRIETARY Page 1 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

17 INDIVIDUAL COMPANY DATA PROPRIETARY 4.0 Recommended UN Classification The recommended classification for the article above according to 49 CFR Parts Transportation (Revised as of Oct. 1, 2012) would be: a. Proper Shipping Name: Igniters b. Hazard Class: 1.4S c. UN Number: UN 0454 d. Packaging Group: II e. Label Code: 1.4S 5.0 The recommended packaging, marking, and labeling for surface transportation (rail or highway) may be found in CFR 49 sections as follows: A. Packaging Section B. Marking Section C. Labeling Section The comparison of the article evaluated in this report versus the article to which the analogy is performed is shown in Table 1. Table 1 OOT-APRV-055 Igniter Type Type D (Swing Jet Release) Type A (Power Charge Igniter) EX Description 0.26 ± ± 0.05 or 3.3 ± 0.05 N.E.W. (grams) Content Black Powder (BP) Black Powder (BP) or BP & Titanium Sub-hydride Potassium Perchlorate (TSPP) Application: The OOT-APRV-055 Type D Swing Jet Release is a small igniter containing a minimal amount (0.26 +/- 0.05g) of black powder. It is used to release a SwingJet perforator from its folded down hole transport position to its functional firing position. A SwingJet perforating gun is a small diameter perforating gun that is used to pass through tight restrictions within the well tubing or casing through which a perforating gun of a larger diameter desired for the work cannot pass. This is accomplished by transporting the perforators into the well to the target zone in a folded position presenting a much smaller diameter footprint into the well. Once in position, the INDIVIDUAL COMPANY DATA, PROPRIETARY Page 2 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

18 INDIVIDUAL COMPANY DATA PROPRIETARY Type D Swing Jet Release is electrically actuated causing the resistor to heat up (burn) and ignite the explosive material (black powder) around it. This explosive material burns rapidly and produces enough internal pressure to push the Plug out of the swing jet release tripping a mechanical catch that releases the SwingJet perforator from its folded position to its firing position. Then, a separate detonator is used to initiate the SwingJet perforators in the perforating gun. 7.0 Analogy The OOT-APRV-055 Igniters, Type D (Swing Jet Release) contains significantly less explosive material (NEW), as shown in Table 1, than that authorized for the OOT- APRV-055 Igniters, Type A Igniter (EX ) that was tested by SCE. The specifications and drawings are shown in Appendix A. 8.0 Packaging Configuration The OOT-APRV 055 Igniters, Type D (Swing Jet Release) are packaged as follows: One to fifty igniters are packaged in a UN4G Fiberboard box. Each igniter is individually packaged in a chipboard carton and suitable packing material is added to each carton to prevent movement of the igniter within its carton during shipment. Fiberboard dividers are used to separate the individual cartons from each other and from the package top and bottom. See Appendix A for OOT-APRV-055 Igniter Family Product Packaging details. 9.0 Comments: The evaluations were performed in accordance with 49 CFR, Part The recommendation for hazard classification on the igniters was based on the information provided by Owen Oil Tools LP, our knowledge, and previous experience by the undersigned. To receive Department of Transportation (DOT) classification before any explosive is offered for shipment (per Section ). You may go ONLINE to To access the Hazmat Special Permits and Approvals Online Application OR, INDIVIDUAL COMPANY DATA, PROPRIETARY Page 3 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

19 INDIVIDUAL COMPANY DATA PROPRIETARY You must forward this Explosive Classification Report, all attachments and the accompanying Recommendation Letter to the following address: Associate Administrator for Hazardous Materials Safety PHMSA U.S. DOT Attention: PHH New Jersey Avenue SE East Building, 2nd Floor Washington, DC (Telephone No ) If you have any questions about this requirement or how to proceed please do not hesitate to call us. 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. Examination by: Bernadette N. Reyes Sr. Process Safety Specialist DOT Approved Examiner A Dekra Company INDIVIDUAL COMPANY DATA, PROPRIETARY Page 4 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

20 INDIVIDUAL COMPANY DATA PROPRIETARY Appendix A Technical Specifications/Drawing and Packaging Configuration for OOT-APRV-055 Igniter Family INDIVIDUAL COMPANY DATA, PROPRIETARY Page 5 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

21 INDIVIDUAL COMPANY DATA PROPRIETARY INDIVIDUAL COMPANY DATA, PROPRIETARY Page 6 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy

22 INDIVIDUAL COMPANY DATA PROPRIETARY INDIVIDUAL COMPANY DATA, PROPRIETARY Page 7 Report No LR, DOT Examination of OOT-APRV-055 Igniters, Type D (Swing Jet Release) by Analogy