AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS. Stowage of jet perforating guns. Submitted by the United States SUMMARY

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1 E SUB-COMMITTEE ON CARRIAGE OF CARGOES AND CONTAINERS 3rd session Agenda item 6 CCC 3/6/5 30 June 2016 Original: ENGLISH AMENDMENTS TO THE IMDG CODE AND SUPPLEMENTS Stowage of jet perforating guns Submitted by the United States SUMMARY Executive summary: This document contains proposals for modifications of existing stowage requirements for jet perforating guns Strategic direction: 5.2 High-level action: Output: Action to be taken: Paragraph 10 Related documents: None Background 1 Jet perforating guns are utilized in the oil and gas industry for exploration and drilling. Often this oil and gas exploration and drilling is conducted at offshore wells or platforms. These platforms are generally serviced by Offshore Supply Vessels (OSVs) that cannot facilitate on or under deck stowage of traditional freight containers. Examples of jet perforating guns on offshore well tool pallets are set out in the annex. Introduction 2 This document proposes to provide an authorization for Jet Perforating Guns, Charged, to be transported on deck on offshore supply vessels in offshore well tool pallets, cradles, or other means of containment provided certain explosive content limits, containment of the explosives, securement of the perforating guns, and separation distances between tool pallets stowed on deck are met. 3 Jet Perforating Guns, Charged, are currently assigned to two UN numbers, "UN 0124", a 1.1D entry, and "UN 0494", a 1.4D entry. Jet perforating guns range in length from 0.3 m to 6.4 m and "JET PERFORATING GUNS, CHARGED, oil well, without detonator" are defined as "articles consisting of a steel tube or metallic strip, into which are inserted shaped charges connected by detonating cord, without means of initiation". Both of these articles are assigned packing instruction P101 in the Dangerous Goods List. Packing instruction P101 authorizes only packagings which are approved by the competent authority to be used.

2 CCC 3/6/5 Page 2 4 Jet perforating guns for use in the oil and gas industry are transported by OSVs to offshore platforms. An OSV is defined by the IMO Guidelines for the design and construction of Offshore Supply Vessels, 2006 as a vessel:.1 which is primarily engaged in the transport of stores, materials and equipment to offshore installations; and.2 which is designed with accommodation and bridge erections in the forward part of the vessel and an exposed deck in the after part for the handling of cargo at sea. 5 The 1.1D entry is assigned stowage category 04 and the 1.4D entry is assigned stowage category 02. For cargo ships, both of these stowage categories require stowage on deck in closed cargo transport unit (CCTU) or under deck in CCTU. Discussion 6 The design, stowage capabilities, and cargo handling equipment of OSVs makes stowage of jet perforating guns in traditional freight containers impractical. Additionally, transportation in means of containment meeting the definition of a CCTU often requires additional handling steps (e.g. removing a lid from a container, removing palletised guns from a CCTU) either on board the OSV or on the offshore platform. Each additional handling step introduces further risk into the loading and unloading process. 7 Provided the separation distances between tool pallets stowed on deck are appropriate and perforating guns are properly secured, the metal body of jet perforating guns provides ample protection for the contained explosives during transportation by OSV. 8 In addition to separation distances and securement requirements, this proposal includes explosive content limits to minimize any possible impacts from incidents in transportation, and limits transportation to OSVs servicing offshore oil platforms or wells to limit the range of transportation authorized. Proposal 9 Taking into consideration the stowage and handling capabilities of OSVs, additional risks posed by added handling steps, and the design and construction of jet perforating guns, it is proposed to amend the stowage of goods of class 1 requirements found in and add a new stowage code as follows: ".1 Renumber existing as and insert new to read: Irrespective of the stowage category assigned by , UN 0494 and UN 0124 Jet Perforating Guns, Charged, may be stowed on deck in offshore well tool pallets, cradles or baskets on a private offshore supply vessel 1 engaged in transportation to or from offshore oil platforms or wells provided that:.1 Initiation devices carried on the same offshore supply vessel must be segregated; each kind from every other kind, and from any gun, tool or other supplies, unless approved by the competent authority; 1 As defined in Guidelines for the design and construction of Offshore Supply Vessels, 2006, as amended.

3 .2 Guns must be securely held in place during transportation; CCC 3/6/5 Page 3.3 Each shaped charge affixed to the gun may not contain more than 112 g of explosives;.4 Each shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal cover after installation in the gun;.5 The total explosive contents do not exceed 91 kg per tool pallet, cradle, or basket;.6 When more than one tool pallet, cradle, or basket is stowed "on deck" a minimum horizontal separation of 3 m must be provided..2 In new stowage code SW 29 is added and assigned to column 16a for UN 0494 and UN 0124 to read: SW 29 For special stowage provisions for transport on offshore supply vessels, see " Action requested of the Sub-Committee 10 The Sub-Committee is invited to consider the comments and proposal provided in this document and take action as appropriate. ***

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5 CCC 3/6/5 Annex, page 1 ANNEX EXAMPLES OF JET PERFORATING GUNS ON OFFSHORE WELL TOOL PALLETS