Reference Number: SMS-4129-L1, Rev 0 Date: PCT, and 1.1D ... · OOT-APRV-065 Waste Streams SMS-4036-R1, Rev 0 Owen Oil Tools, LP August 11, 2017 Page 11 of 23 Based on the test results,

1847 West 9000 South, Suite 205 • West Jordan, Utah 84088 • (801) 567-0456 • (801) 567-0457 fax • www.sms-ink.com

Reference Number: SMS-4129-L1, Rev 0 Date: August 11, 2017

Owen Oil Tools LP

12001 County Road 1000

Godley, Texas 76044

Attention: Amanda Swope

Subject: Shipping Classification Recommendation for OOT-APRV-065 Waste

Streams (including 1.1D-CTM, 1.1D-DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-

PCT, and 1.1D-APP Waste Streams)

Reference 1: “Test and Examination Report for OOT-APRV-065 Waste Streams (including

1.1D-CTM, 1.1D-DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-PCT, and 1.1D-APP

Waste Streams),” SMS-4036-R1, Rev 0, Safety Management Services, Inc.,

August 11, 2017

Dear Mrs. Swope:

The referenced examination report details the results of testing of your OOT-APRV-065 Waste

Streams (including 1.1D-CTM, 1.1D-DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-PCT, and 1.1D-

APP Waste Streams) according to requirements for new explosives and explosive articles. Based

on that examination, SMS makes the following recommendation in accordance with Sections

172.101, and 173.56 of Title 49 CFR.

Product Names/Description: OOT-APRV-065 Waste Streams (including 1.1D-CTM,

1.1D-DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-PCT, and 1.1D-APP Waste

Streams)

Recommended Product Shipping Description: UN0475, Waste Substances, explosive,

n.o.s., 1.1D

This recommendation IS packaging specific.

Packaging requirements are given in 49 CFR Section 173.62c, Table, Packing Instruction 101

applies and is limited to the following:

• Outer Packaging: Drums, plastic (1H1 or 1H2) or Boxes, fiberboard (4G) or

Drums, fiberboard (1G)

• Intermediate Packaging: Bags, plastic, anti-static

• Inner Packaging: Bags, plastic, anti-static

Note: Intermediate and/or inner packaging not required if leakproof outer packaging is used.

SMS-4036-L1, Rev 0

Page 2 of 2

Marking requirements are given in 49 CFR Section 172.320.

Labeling requirements are given in 49 CFR Section 172.411.

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 CA1999080005 (Second

Revision).

If you have any questions concerning this report or require further assistance, please call SMS at

801 567-0456 or Fax SMS at 801 567-0457.

Thank you,

Kirt N. Sasser, PE

Director of Engineering & Testing

Safety Management Services, Inc.

w/ attachments

1847 West 9000 South, Suite 205 • West Jordan, Utah 84088 • (801) 567-0456 • (801) 567-0457 fax • smsenergetics.com

Reference Number: SMS-4036-R1, Rev 0 Date: August 11, 2017

Manufacturer: Owen Oil Tools LP

12001 County Road 1000

Godley, Texas 76044

Subject: Test and Examination Report for OOT-APRV-065 Waste Streams (including

1.1D-CTM, 1.1D-DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-PCT, and 1.1D-APP

Waste Streams)

TEST AND/OR ANALYSIS REPORT

The OOT-APRV-065 Waste Streams (including 1.1D-CTM, 1.1D-DST, 1.1D-CWAT, 1.1D-

SEGW, 1.1D-PCT, and 1.1D-APP Waste Streams) are generated by Owen Oil Tools LP at its

Godley, Texas facility. The following report details the testing and analysis performed in support

of a shipping division classification recommendation. Owen Oil Tools is seeking a 1.1D

classification for these waste streams.

I. SAMPLE DESCRIPTIONS

A. 1.1D-CTM Waste Stream

The 1.1D-CTM Waste Stream consist of waste floor sweepings and/or manufacturing supplies and

PPE, contaminated with energetic materials (HMX, HNS, RDX, PYX, NONA, BKNO3, and/or

Black/Smokeless powders). The waste was wetted with standing water in the bottom of each

package. The 1.1D-CTM Waste Stream as received is shown in Photos 1-2.

Photo 1: 1.1D-CTM Waste Stream

OOT-APRV-065 Waste Streams SMS-4036-R1, Rev 0

Owen Oil Tools, LP August 11, 2017

Page 2 of 23

Photo 2: 1.1D-CTM Waste Stream

B. 1.1D-DST Waste Stream

The 1.1D-DST Waste Stream consist of dust from testing facilities contaminated with energetic

materials (HMX, HNS, RDX, PYX, NONA, BKNO3, and/or Black/Smokeless powders). The

1.1D-DST Waste Stream as received for testing is a grey, dry powder as shown in Photo 3.

Photo 2: 1.1D-DST Waste Stream



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C. 1.1D-CWAT Waste Stream

The 1.1D-CWAT Waste Stream consist of water contaminated with trace quantities of explosive

(less than 1% contamination). The 1.1D-CWAT waste stream was not tested but is being

recommended for classification based on the other waste streams being tested as well as SMS’s

experience with solutions with 1% or less of explosive contamination.

D. 1.1D-SEGW Waste Stream

The 1.1D-SEGW Waste Stream consist of sludge and segments of cutters produced during milling

process (copper fillings and explosive fill) wetted with not less than 25% water wet. The 1.1D-DST

Waste Stream as received for testing is shown in Photos 3-5.

Photo 3: 1.1D-SEGW Waste Stream



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E. 1.1D-PCT Waste Stream

The 1.1D-PCT Waste Stream consist of waste floor sweepings and/or manufacturing supplies and

PPE, contaminated with energetic materials (ammonium perchlorate, potassium perchlorate). The

1.1D-PCT Waste Stream as received for testing is shown in Photos 6-7.

Photo 6: 1.1D-PCT Waste Stream

Photo 7: 1.1D-PCT Waste Stream



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F. 1.1D-APP Waste Stream

The 1.1D-APP Waste Stream consist of Scrap powder from KODIAK™ product which include

aluminum and potassium Perchlorate. The 1.1D-APP Waste Stream as received for testing is a

silver, dry powder as shown in Photo 3. This powder is used in the KODIAK Pellets produced by

Owen Oil Tools and shipped under approval number EX2008040541.

Photo 8: 1.1D-APP Waste Stream

Photo 9: 1.1D-APP Waste Stream



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Packaging

For all waste streams, the packaging consisted of an outer UN 4G fiberboard box (Photo 3) with

intermediate and inner packaging consisting of plastic anti-static bags. The standard package

configuration is as follows:

• Outer Packaging: Boxes, UN 4G, fiberboard with a maximum of one

intermediate package per outer package.

• Intermediate Packaging: Bags, plastic, anti-static with maximum of one inner package

per intermediate package.

• Inner Packaging: Bags, plastic, anti-static.

Photo 10: Outer Packaging for Waste Streams as Received



Page 8 of 23

Photo 11: Intermediate and Inner Packaging

II. TEST RESULTS AND/OR ANALYSIS

UN Series 3 tests were performed on the 1.1D-DST and 1.1D-APP samples. UN Series 4 tests were

performed on the 1.1D-CTM, 1.1D-SEGW, and 1.1D-PCT Waste Streams. All tests were

performed at SMS’s test facility in Tooele, Utah. Tests were performed in May of 2017. All tests

were witnessed by Kirt Sasser and performed in accordance with the UN Manual of Tests and

Criteria. Summaries for each of the samples tested are provided Tables 1-5 below with details

following each test.

A. 1.1D-CTM Waste Stream Test Results

Tests included UN Series 4a (Thermal Stability) and 4b (12-Meter Drop). A summary of test

results is given in Table 1.

Table 1: Results of DOT UN Series Testing on 1.1D-CTM Waste Stream

Test Conditions and Results Pass/Fail

Thermal Stability UN 4(a)

No change in appearance. Minimal weight loss. No increase in temperature.

Pass – not forbidden

12-meter Drop UN 4(b)(ii)

Three trials resulted in minor external damage to packaging and no initiations of any article. No damage to any articles in the packaging was observed in any of the three trials.




Page 9 of 23

Details of results:

UN Series 4a, Thermal Stability for Packaged Articles

UN Series 4(a), Thermal Stability Test, was conducted on the 1.1D-CTM Waste Stream in the outer

package. There was minimal weight loss after 48 hours at 75°C. Pre-test package weight was

25.21 lbs. The post-test package weight was 24.74 lbs. Weight loss was attributed to water loss.

No visual signs of reaction were observed on the post-test samples. A temperature rise of 3°C did

not occur. The temperature plot is shown in Figure 1.

Figure 1: Thermal Stability Temperature Plot for 1.1D-CTM Waste Stream

Photo 12: Thermal Stability – 1.1D-CTM Waste Stream



Page 10 of 23

UN Series 4b(ii), 12-Meter Drop Test

UN Series 4(b), 12-Meter Drop Test, was conducted on the packaged 1.1D-CTM Waste Stream.

Three drops were performed (Photo 13). No fire or explosion occurred in any of the three trials.

There was some slight damage to outer packaging with the box tearing open as well as the bags,

with some leaking of the wetting agent (Photo 14).

Photo 13: 12-Meter Drop Test – Typical Setup

Photo 14: 12-Meter Drop Test – Typical Results



Page 11 of 23

Based on the test results, the packaged 1.1D-CTM Waste Stream is consistent with a

recommendation into hazards division 1.1.

B. 1.1D-DST Waste Stream Test Results

Tests included Tests included UN Series 3a (Impact Sensitivity), 3b (Friction Sensitivity), 3c

(Thermal Stability), and 3d (Small-scale Burn). A summary of test results is given in Table 2.

Table 2: Test Results for 1.1D-DST


BOE Impact UN 3(a)(i)

0 initiations in 6 trials at a height of 4 inches Pass – not forbidden

BAM Friction UN 3(b)(i)

Zero initiations in 6 trials at 80 N force Pass – not forbidden

Thermal Stability UN 3(c)(i)

Minimal weight loss, no evidence of reaction or physical change in appearance


Small Scale Burn UN 3(d)

No explosion. Sample appeared to not burn within the flames (un-noticeable) over 10-minute period.


Details of results:

UN Series 3a, Impact Sensitivity

The impact initiation testing was performed on a BOE impact apparatus. Six trials were performed

at a height of 4 inches resulting in zero reactions (Go) out of six (No-Go’s). The 1.1D-DST Waste

Stream passed the impact test criteria.

UN Series 3b, Friction Sensitivity

The friction initiation testing was performed on the BAM friction apparatus at 80 N force. Six trials

were conducted at this level with no reactions (Photo 15); thus, 1.1D-DST Waste Stream passed the

friction test criteria.

Photo 15: BAM Friction – Typical Results



Page 12 of 23

UN Series 3c, Thermal Stability

A UN Series 3c un-instrumented test was performed on the 1.1D-DST Waste Stream (50 grams).

Minimal weight loss was observed (1.93 grams of the 50-gram sample). No physical change in

appearance or evidence of reaction was observed. The 1.1D-DST Waste Stream passed the test

criteria.

Photo 16: Thermal Stability Test Setup – 1.1D-DST Waste Stream


1.1D-DST Waste Stream

1.1D-DST Waste Stream



Page 13 of 23

UN Series 3d, Small-scale Burn

Two 100-gram Small-scale Burn trials were performed on the 1.1D-DST Waste Stream (Photo 18).

In both trials, the 1.1D-DST Waste Stream sample appeared to not burn within the fire with most of

the dust sample remaining after the fire. There was no explosion or flames, etc., over a 10-minute

period. The 1.1D-DST Waste Stream passed the test criteria.


Photo 19: Thermal Stability Test Results – 1.1D-DST Waste Stream

Based on the test results, the packaged 1.1D-DST Waste Stream is consistent with a




Page 14 of 23

C. 1.1D-CWAT Waste Stream Analysis

No testing was performed on the 1.1D-CWAT Waste Stream as the waste stream consist of consist

of at least 99% water contaminated with no more than 1% explosives (HMX, HNS, RDX, PYX,

NONA, BKNO3, Black/Smokeless powders, aluminum, ammonium perchlorate, and/or potassium

perchlorate). SMS has tested wetted explosives and it is our experience that water contained with

this small amount of explosive is acceptable as being not forbidden. However, with the desire to

ship a larger volume, 1% contamination could be a substantial amount of material (e.g., 1%

contamination of a 55-gallon drum results in 4.6 pounds of explosive). Based on the potential

quantity and the type of potential type of explosives, keeping the classification within Division 1.1

is appropriate.

D. 1.1D-SEGW Waste Stream



Table 3: Results of DOT UN Series Testing on 1.1D-SEGW Waste Stream








Details of results:


UN Series 4(a), Thermal Stability Test, was conducted on the 1.1D-SEGW Waste Stream in the

outer package. There was minimal weight loss after 48 hours at 75°C. Pre-test package weight was

21.51lbs. The post-test package weight was 20.73 lbs. Weight loss was attributed to water loss.



Figure 2: Thermal Stability Temperature Plot for 1.1D-SEGW Waste Stream



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UN Series 4(b), 12-Meter Drop Test, was conducted on the packaged 1.1D-SEGW Waste Stream.








Page 16 of 23

Based on the test results, the packaged 1.1D-SEGW Waste Stream is consistent with a


E. 1.1D-PCT Waste Stream Test Results



Table 4: Results of DOT UN Series Testing on 1.1D-PCT Waste Stream








Details of results:


UN Series 4(a), Thermal Stability Test, was conducted on the 1.1D-PCT Waste Stream in the outer

package. There was minimal weight loss after 48 hours at 75°C. Pre-test package weight was

29.04 lbs. The post-test package weight was 28.54 lbs. Weight loss was attributed to water loss.



Figure 3: Thermal Stability Temperature Plot for 1.1D-PCT Waste Stream



Page 17 of 23

Photo 22: Thermal Stability – 1.1D-CTM Waste Stream


UN Series 4(b), 12-Meter Drop Test, was conducted on the packaged 1.1D-CTM Waste Stream.







Page 18 of 23


Based on the test results, the packaged PTC Waste Stream is consistent with a recommendation into

hazards division 1.1.

F. 1.1D-APP Waste Stream Test Results

Tests included Tests included UN Series 3a (Impact Sensitivity), 3b (Friction Sensitivity), 3c

(Thermal Stability), and 3d (Small-scale Burn). A summary of test results is given in Table 5.

Table 5: Test Results for 1.1D-DST


BOE Impact UN 3(a)(i)

2 initiations in 8 trials at a height of 4 inches Pass – not forbidden

BAM Friction UN 3(b)(i)

Zero initiations in 6 trials at 80 N force Pass – not forbidden

Thermal Stability UN 3(c)(i)

No weight loss occurred; no evidence of reaction or physical change in appearance.


Small Scale Burn UN 3(d)

No explosion. Sample ignited and burned for ~ 90 seconds with a small flame.




Page 19 of 23

Details of results:

UN Series 3a, Impact Sensitivity

The impact initiation testing was performed on a BOE impact apparatus. Eight trials were

performed at a height of 4 inches resulting in two reactions (Go) out of eight (No-Go’s). The 1.1D-

APP Waste Stream passed the impact test criteria.

UN Series 3b, Friction Sensitivity

The friction initiation testing was performed on the BAM friction apparatus at 80 N force. Six trials

were conducted at this level with no reactions (Photo 25); thus, 1.1D-DST Waste Stream passed the

friction test criteria.

Photo 25: BAM Friction – Typical Results

UN Series 3c, Thermal Stability

A UN Series 3c un-instrumented test was performed on the 1.1D-APP Waste Stream (50 grams).

No weight loss was observed. No physical change in appearance or evidence of reaction was

observed. The 1.1D-APP Waste Stream passed the test criteria.



Page 20 of 23

Photo 26: Thermal Stability Test Setup – 1.1D-APP Waste Stream


UN Series 3d, Small-scale Burn

Two 100-gram Small-scale Burn trials were performed on the 1.1D-APP Waste Stream (Photo 28).

In both trials, the 1.1D-APP Waste Stream sample ignited approximately 60 seconds after the fire

started and burned with a low, white flame (Photo 29) for 90 seconds leaving a crusty residue

(Photo 30). There was no explosion or flames, etc., over a 10-minute period. The 1.1D-APP Waste

Stream passed the test criteria.

1.1D-APP Waste Stream

1.1D-APP Waste Stream



Page 21 of 23


Photo 29: Thermal Stability Test Results – 1.1D-APP Waste Stream



Page 22 of 23

Photo 30: Thermal Stability Test Results – 1.1D-APP Waste Stream

Based on the test results, the packaged 1.1D-APP Waste Stream is consistent with a


Conclusions and Recommendation:

Behavior of the 1.1D-CTM, 1.1D-DST, 1.1D-SEGW, 1.1D-PCT, and 1.1D-APP Waste Streams is

consistent with a recommendation into hazards division 1.1. The 1.1D-CTM, 1.1D-SEGW, and

1.1D-PCT Waste Streams passed all the UN Series 4 tests. The 1.1D-DST and 1.1D-APP Waste

Streams passed all the UN Series 3 tests. The 1.1D-CWAT Waste Stream is dilute to the point (99

% water) that it can be considered not forbidden for shipment.

Based on the results of testing and analysis, and in accordance with 49 CFR Section 172.101 and

173.56, SMS recommends that the OOT-APRV-065 Waste Streams (including 1.1D-CTM, 1.1D-

DST, 1.1D-CWAT, 1.1D-SEGW, 1.1D-PCT, and 1.1D-APP Waste Streams), manufactured by

Owen Oil Tools LP, be classed into Division 1.1 as UN0475, Waste Substances, explosive, n.o.s.,

1.1D.

This recommendation IS packaging specific.

Packaging requirements are given in 49 CFR Section 173.62c, Table, Packing Instruction 101

applies and is limited to the following:

• Outer Packaging: Drums, plastic (1H1 or 1H2) or Boxes, fiberboard (4G) or

Drums, fiberboard (1G)

• Intermediate Packaging: Bags, plastic, anti-static

• Inner Packaging: Bags, plastic, anti-static



Page 23 of 23

Note: Intermediate and/or inner packaging not required if leakproof outer packaging is used.

Marking requirements are given in 49 CFR Section 172.320.

Labeling requirements are given in 49 CFR Section 172.411.

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 CA1999080005 (Second

Revision).

Thank you,

Kirt N. Sasser, PE

Director of Engineering & Testing

Safety Management Services, Inc.

Documents

Reference Number: SMS-4129-L1, Rev 0 Date: PCT, and 1.1D ... · OOT-APRV-065 Waste Streams SMS-4036-R1, Rev 0 Owen Oil Tools, LP August 11, 2017 Page 11 of 23 Based on the test results,