Reference Number: SMS-5661-L1, Rev 0 Date: April 20, 2020...SMS-5661-L1, Rev 0 Page 3 of 3...

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1847 West 9000 South, Suite 205 • West Jordan, Utah 84088 • 801-567-0456 • www.smsenergetics.com

Reference Number: SMS-5661-L1, Rev 0 Date: April 20, 2020 Owen Oil Tools LP 12001 County Road 1000 Godley, Texas 76044 Attention: David Boston Subject: Shipping Classification Recommendation OOT-APRV-037 Stim™ Product Family

Recommendation Type (Via):

Testing Analogy Not New Examination/Integrator Reference: (1) “Test and Examination Report for OOT-APRV-037 Stim™ Product Family,”

SMS-5661-R1, Rev 0, Safety Management Services, Inc., April 20, 2020. The OOT-APRV-037 Stim™ Product Family was examined in the referenced report. If it is interpreted that the articles are not transported in the form which they are intended for use, SMS recommends that the OOT-APRV-037 Stim™ Product Family be excluded from Class 1 and be assigned to:

Product Names/Description: OOT-APRV-037 Stim™ Product Family consisting of StimGun™ Sleeve (SGS), StimTube™ Tool (STS), Well Stimulation Tool (WST), and StimDisc™ (SGD) configurations containing not more than 18,144 grams of a proprietary propellant mix as depicted in drawings OOT-APRV-037SGS (Rev.2), OOT-APRV-037STS (Rev.3), OOT-APRV-037WST (Rev.2), and OOT-APRV-037SGD (Rev.0).

Recommended Product Shipping Description:

Division 5.1, UN 1489 (Potassium perchlorate, mixture)

This recommendation IS packaging specific.

• The OOT-APRV-037 Stim™ Product Family will be transported in non-bulk packaging compliant to 49 CFR § 173.212 as follows:

o Outer packaging: UN 4G fiberboard box, or UN 1G fiber drum, or UN 4C1 or UN 4C2 wooden box,

• Labeling requirements are given in 49 CFR Section 172.426.

http://www.smsenergetics.com/

dboston

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Despite this recommendation, PHMSA classified as 1.4S; UN 0349; Articles, explosive, n.o.s., (Potassium perchlorate /epoxy) on 8/28/2020 (EX2020046500)

SMS-5661-L1, Rev 0

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However, if the product is accepted as Class 1 articles, based on that examination, SMS makes the following recommendation in accordance with Title 49 CFR § 172.101 and 49 CFR § 173.56 - § 173.58. Product Names/Description:

OOT-APRV-037 Stim™ Product Family consisting of StimGun™ Sleeve (SGS), StimTube™ Tool (STS), Well Stimulation Tool (WST), and StimDisc™ (SGD) configurations containing not more than 18,144 grams of a proprietary propellant mix as depicted in drawings OOT-APRV-037SGS (Rev.2), OOT-APRV-037STS (Rev.3), OOT-APRV-037WST (Rev.2), and OOT-APRV-037SGD (Rev.0).

Recommended Product Shipping Description:

UN0349, Articles, explosive, n.o.s. ( Potassium perchlorate / epoxy), 1.4S

This recommendation IS packaging specific.

• The OOT-APRV-037 Stim™ Product Family will be transported in non-bulk packaging compliant to 49 CFR § 173.62(c), Table of Packing Methods, Packing Instruction 101 with the following restrictions:

• Inner: None.

• Intermediate: None.

• Outer: UN 4G fiberboard box, or UN 1G fiber drum, or UN 4C1 or UN 4C2 wooden box, or UN 4D plywood box, or UN 4F reconstituted wood box

• Marking requirements are given in 49 CFR Section 172.320.

• Labeling requirements are given in 49 CFR Section 172.411. To complete the approval process for this material and location: Provide a cover letter in accordance with 49 CFR §107.705 that SMS has determined that the explosive is considered a “Not New Explosive” per 49 CFR §173.56(a). File the documents (i.e. this letter and the enclosed report with attachments together with all pertinent drawings and chemical composition data) using the PHMSA Online Application at https://portal.phmsa.dot.gov/PHMSAPortal2/

https://portal.phmsa.dot.gov/PHMSAPortal2/

SMS-5661-L1, Rev 0

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Alternatively, the documents may be filed by facsimile (fax) to 202-366-3753 or 202-366-3308, by electronic mail (e-mail) to [email protected], or by hard copy to:

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

Important: THIS DETERMINATION THAT THE EXPLOSIVE IS CONSIDERED A “NOT NEW

EXPLOSIVE” MUST BE CONFIRMED IN WRITING TO THE ASSOCIATE ADMINISTRATOR BEFORE OFFERING THE EXPLOSIVE FOR TRANSPORT USING THE EXISTING APPROVAL. The PHMSA tracking number for this application may be included on the shipping paper, documenting compliance with the 49 CFR §173.56(a)(2) notification requirement, after the basic description provided the information is not inconsistent with the required elements of the basic description (see 49 CFR §172.201(a)(4)).

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 (Fourth Revision). If you have any questions concerning this recommendation or require further assistance, please call SMS at 801-567-0456 or fax SMS at 801-567-0457. If you have any questions concerning this recommendation 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

Jason T. Ford Test Site/ Test Equipment Manager DOT Explosive Examiner Safety Management Services

mailto:[email protected]

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1847 West 9000 South, Suite 205 • West Jordan, Utah 84088 • 801-567-0456 • www.smsenergetics.com

Reference Number: SMS-5661-R1, Rev 0 Date: April 20, 2020 Manufacturer: Owen Oil Tools LP 12001 County Road 1000 Godley, Texas 76044 Subject: Test and Examination Report for OOT-APRV-037 Stim™ Product Family

TEST AND/OR ANALYSIS REPORT

The OOT-APRV-037 Stim™ Product Family is manufactured by Owen Oil Tools LP at its Godley, TX and other U.S. facilities. Owen Oil Tools LP requested that SMS perform testing in accordance with the United Nations (UN) Recommendations on the Transport of Dangerous Goods, Model Regulations, Volume I, Nineteenth Revised Edition, ST/SG/AC.10/Rev.17 (Vol. I), 2015, to determine whether the article is a candidate for exclusion from Class 1. The following report details the testing and analysis performed in support of a shipping division classification recommendation. A. Description of the OOT-APRV-037 Stim™ Product Family

The OOT-APRV-037 Stim™ Product Family consists of StimGun™ Sleeve (SGS), StimTube™ Tool (STS), Well Stimulation Tool (WST), and StimDisc™ (SGD) configurations containing not more than 18,144 grams of a proprietary propellant mix as depicted in drawings OOT-APRV-037SGS (Rev.2), OOT-APRV-037STS (Rev.3), OOT-APRV-037WST (Rev.2), and OOT-APRV-037SGD (Rev.0). The family has four configurations:-

- StimGun™ Sleeve (SGS) - a hollow cylinder of the composition. - StimTube™ Tool (STS) - a steel tube with the composition cast on the outside: and - Well Stimulation Tool (WST) - A cylindrical casing of the composition with steel stubs at

each end. - StimDisc™ -- A cylindrical disk (or pellet) with a hole through its center.

The STIMGUN® System combines conventional perforating with propellant stimulation, computer modeling and dynamic pressure measurement to improve perforation efficiency, hydraulic fracturing efficiency and well productivity/injectivity. These tools allow for both well perforation and perforation breakdown. The STIMTUBE® uses propellant assisted perforation breakdown and near wellbore stimulation for through tubing applications. The articles are shown in Figures 1-4. A representative photo of the articles is provided in Photo 1.

OOT-APRV-037 Stim™ Product Family SMS-5661-R1, Rev 0 Owen Oil Tools LP April 20, 2020

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Figure 1: StimGun™ Sleeve (SGS)

Figure 2: StimTube™ Tool (STS)

Figure 3: Well Stimulation Tool (WST)


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Figure 4: StimDisc™

Photo 1: OOT-APRV-037 Stim™ Product Family B. Energetic Constituents

The energetic ingredient of all the products in the family is a propellant - a cast mixture of potassium perchlorate and epoxy resin. This resultant cast mixture is a hard, non-pliable material that is formed around the outside of the specific metal tools for both the STS and WST articles or simply a hollow sleeve of cast material for the SGS and SGD articles. C. Packaging

The OOT-APRV-037 Stim™ Product Family will be transported in non-bulk packaging compliant to 49 CFR § 173.62(c), Table of Packing Methods, Packing Instruction 101 with packaging as follows:

• Inner: None.

• Intermediate: None.

• Outer: UN 4G fiberboard box, or UN 1G fiber drum, or UN 4C1 or UN 4C2 wooden box, or UN 4D plywood box, or UN 4F reconstituted wood box


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D. Previous Testing

Previous testing was conducted by the Canadian Explosives Research Laboratory (CERL) in January-March of 2000. A summary of test results is provided in the table below. Table 1: Summary of UN Series Testing on the Transfer Line Assembly Family (P/N 837021)

Test Conditions and Results Pass/Fail

UN Series 1 (a) UN Gap Test

“‒“ (negative) Pass

UN Series 1 (b) Koenen Test

“‒“ (negative) Pass

UN Series 1 (c)(i) Time-Pressure Test

“+” (positive) FAIL – however, tested in form not offered for transportation (small granulated pieces)

UN Series 3 (c) Thermal stability

“‒“ (negative) Pass (not forbidden)

UN Series 4 (b) (ii) 12-meter drop

“‒“ (negative) Pass (not forbidden)

UN Series 6 (a) Single package

No mass explosion Pass (no mass explosion)

UN Series 6 (b) Stack test

Waived based on Single package test results.

Waived

UN Series 6 (c) External fire (bonfire)

No mass explosions, fireballs, jets of flame, or fiery projections observed. No perforations or dents to the witness screens; no projections found. No significant quantity of unconsumed product remaining. The effects at 5 m were limited to smoke and heat as would be produced by the bonfire.

Pass (behavior consistent with Division 1.4S criteria or not Class 1)

UN Series 6 (d) Unconfined package

Three trials resulted in limited burning but no denting or perforation of the witness plate; some scorching to outer package but generally intact.

Pass (behavior consistent with Division 1.4S criteria)

CERL concluded that the results of the tests were consistent with exclusion from Class 1, if it is interpreted that the articles are not transported in the form which they are intended for use. Based on this conclusion, OCS recommended assignment to Division 5.1, (Potassium perchlorate, mixture, UN 1489). They also concluded that, if the product is accepted as Class 1 articles, then UN0349, Articles, explosive, n.o.s. ( Potassium perchlorate / epoxy), 1.4S was recommended for classification.


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E. SMS Testing

Owen Oil Tools requested that SMS perform the Exclusion from Class 1 test on its unpackaged OOT-APRV-037 Stim™ Product Family articles. Initial screening tests were performed to help determine an appropriate ignition system for these articles. However, this proved to be very difficult as the products are designed to operate in an oil well were the pressures and confinement are much more than what can be replicated at the SMS test facility. Tests were witnessed by Kirt Sasser and Jason Ford. It should be noted that section 2.1.3.6.4 of the Model Regulations states that the tested product should be “… activated by its own means of initiation or ignition or external means to function in the designed mode …”. None of activation methods employed by SMS in Trials 1 – 6 described below are ones of “its own means of initiation” nor were they causing function “in the designed mode”. However, to more thoroughly examine the product, alternate means of activation were attempted. Trial 1 - Pyrogen Match Ignition Source Based on CERL’s test results, SMS tried using pyrogen matches to ignite the material (STS-2000-T05A), but this proved to be an insufficient means of ignition. The STS-2000-T05A article had a NEW of 16 pounds and was 60” long. The hot burning match (~ 300 mg) only left scorch marks on the composition surface. At one point it appeared that the surface began to burn but ignition was not sustainable. The setup is presented in Photos 2 and 3. The ignition attempt is shown in Photos 4-6. The results are shown in Photo 7.

Photo 2: Trial 1 - Exclusion from Class 1 Test Setup - STS-2000-T05A with Pyrogen Match

Sound Meter


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Photo 3: Trial 1 - Exclusion from Class 1 Test Setup - STS-2000-T05A with Pyrogen Match

Photo 4: Trial 1 - Exclusion from Class 1 Test - STS-2000-T05A – Ignition w/ Pyrogen Match

Thermocouple

Pyrogen Match


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Photo 5: Trial 1 - Exclusion from Class 1 Test - STS-2000-T05A – Ignition with Pyrogen Match

Photo 6: Trial 1 - Exclusion from Class 1 Test - STS-2000-T05A – Ignition with Pyrogen Match


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Photo 7: Trial 1 - Exclusion from Class 1 Test Results - STS-2000-T05A – with Pyrogen Match Trials 2 & 3 - Bernzomatic Propane Torch Ignition Source - STS-2000-T05A After the high temperature pyrogen matches failed to ignite the article, SMS switched to the Bernzomatic propane torch which is normally used as the ignition source for the UN Test N.1: Test method for readily combustible solids. Again, an article STS-2000-T05A (16 lbs. NEW, 60 inches long) was used as the test subject. The torch was left on the sample for 15 seconds before the article ignited and began to burn (Photo 8) and the torch removed. The article burned for 10 seconds (along ~3 inches of the outer surface only), producing thick cloud of smoke and a small ball of fire/flames of approximately 5 inches in diameter (Photo 9), and then self-extinguished. This process was repeated over and over, without being able to achieve sustained burning once the torch was removed. A third trial was performed with the same results (Photos 10-11). Under the Test N.1 criteria, it is noted whether combustion propagates along 200 mm of the product within a 2-minute test period. If the product “does not ignite and propagate combustion either by burning with a flame or smoldering” along 200 mm of the length within the 2-minute test period, then the product “should not be classified as a flammable solid.” The product would not burn more than 75 mm (along the outer surface only) and could not sustain reaction. Comparing the burning characteristics of this product to the Test N.1 criteria, the product would not even qualify as a flammable solid.


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Photo 8: Trial 2 - Exclusion from Class 1 Test Setup - STS-2000-T05A –with Propane Torch

Photo 9: Trial 2- Exclusion from Class 1 Test Results - STS-2000-T05A – Propane Torch

Photo 10: Trials 2 & 3 - Exclusion from Class 1 Test Results - STS-2000-T05A – Propane Torch


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Photo 11: Trial 3- Exclusion from Class 1 Test Results - STS-2000-T05A - No Sustained Reaction Trial 4 - Bernzomatic Propane Torch Ignition Source - WST-2000-L05A This setup was tried again using a WST-2000-L05A article (13.8 lbs. NEW, 60 inches long), Photos 12-13. In this trial, the torch would not be removed unless the article caused a flameout. The propane torch was left on the sample for approximately one minute with the article producing lots of white smoke and burning with a fireball of approximately 6 inches (Photo 14). After approximately 60 seconds, the torch flamed out (Photos 15-16). The article had burnt approximately 6 inches along its length at this time (Photo 17). At this point the article sustained reaction, burning at a slow rate with a fireball size of approximately 8-10 inches in diameter and producing lots of white smoke (Photo 18). The article continued to burn along its length for another 35 minutes at a burn rate of 1.7 inches/minute. Under the Test N.1 criteria, the minimum burn rate over a 200 mm length is 100 mm/min (3.94 inches/min). As this product burned at a slower burn rate, the product would not even qualify as a flammable solid.

Photo 12: Trial 4 - Exclusion from Class 1 Test Setup - WST-2000-L05A


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Photo 13: Trial 4 - Exclusion from Class 1 Test Setup - WST-2000-L05A – with Propane Torch

Photo 14: Trial 4 - Exclusion from Class 1 Test - WST-2000-L05A – with Propane Torch

Photo 15: Trial 4 - Exclusion from Class 1 Test - WST-2000-L05A – Torch Flameout


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Photo 18: Trial 4 - Exclusion from Class 1 Test - WST-2000-L05A – Sustain Burn


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Photo 19: Trial 4 - Exclusion from Class 1 Test Results - WST-2000-L05A

Photo 20: Trial 4 - Exclusion from Class 1 Test Results - WST-2000-L05A Trial 5- Bernzomatic Propane Torch Ignition Source - STS-2000-T05A This setup was tried again using the same STS-2000-T05A article (16 lbs. NEW, 60 inches long) from Trial #2 with the intent to leave the torch on the article unless if flamed out (Photo 21). The article began producing lots of white smoke and burning with a fireball of approximately 6 inches in diameter (Photo 22). After three minutes the torch was removed, and the article continued to burn exhausting smoke and flame out the center of the pipe (Photos 23-24) and popping off a couple of small propellant pieces before self-extinguishing after 108 seconds from the torch being removed. The article had only burned approximately 10-12 inches along the length of the article (Photos 25-26). The article was burning at a rate of ~2.2 inches/minute before self-extinguishing. Under the Test N.1 criteria, the minimum burn rate over a 200 mm length is 100 mm/min (3.94 inches/min). As this product burned at a slower burn rate, the product would not even qualify as a flammable solid.


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Photo 21: Trial 5 - Exclusion from Class 1 Test Setup - STS-2000-T05A – with Propane Torch

Photo 22: Trial 5 - Exclusion from Class 1 Test - STS-2000-T05A – with Propane Torch


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Photo 23: Trial 5 - Exclusion from Class 1 Test - STS-2000-T05A – Propane Removed

Photo 24: Trial 5 - Exclusion from Class 1 Test - STS-2000-T05A – Propane Removed

Photo 25: Trial 5 - Exclusion from Class 1 Test Results - STS-2000-T05A


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Photo 26: Trial 5 - Exclusion from Class 1 Test Results - STS-2000-T05A Trial 6 - Bernzomatic Propane Torch Ignition Source - STS-2000-T05A This setup from Trial 5 was repeated (Photo 27) with a similar result but with flameout occurring sooner. The article burned for approximately 3 minutes (Photo 28) and self-extinguished (Photos 29-30). The distance of the burn was slightly less in this trial (~8 inches). A noise reading was measured during the burn with a measured value of 105.6 dB (Photo 31). The article was burning at a rate of ~4 inches/minute.

Photo 27: Trial 5 - Exclusion from Class 1 Test Setup - STS-2000-T05A – with Propane Torch


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Photo 28: Trial 5 - Exclusion from Class 1 Test - STS-2000-T05A – with Propane Torch



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Photo 31: Trial 6 - Exclusion from Class 1 Test Results - STS-2000-T05A – Noise Reading


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A summary of screening test results is provided in the table below. Table 2: Testing Summary on OOT-APRV-037 Stim™ Product Family - Exclusion from Class 1

Trial Part No. Ignition Source Conditions and Results Pass/Fail

1 STS-2000-T05A Pyrogen Match Failed to ignite NA

2 STS-2000-T05A Propane Torch

Ignited with torch on for ~15 sec; torch removed; continued to burn for ~10 sec and self-extinguished. During the burn, article produced a lot of white smoke with ~ 5” diameter fireball.

Fail (temperature,

flame, & smoke)


Ignited with torch on for ~15 sec; torch removed; continued to burn for ~10 sec and self-extinguished. During the burn, article produced a lot of white smoke with ~ 5” diameter fireball.

Fail (temperature,

flame, & smoke)

4 WST-2000-L05A Propane Torch

Ignited with torch on for ~60 sec; torch removed; continued to burn for ~35 min and self-extinguished. During the burn, article produced a lot of white smoke with ~ 8” diameter fireball.

Fail (temperature,

flame, & smoke)


Ignited with torch on for ~3 min; torch removed; continued to burn for ~108 sec and self-extinguished. During the burn, article produced a lot of white smoke with ~ 6” diameter fireball.

Fail (temperature,

flame, & smoke)


Ignited with torch and burned for ~2 min before self-extinguishing. During the burn, article produced a lot of white smoke with ~ 6” diameter fireball.

Fail (temperature,

flame, & smoke)

Based on SMS’s experience, the testing was halted at this point, as additional testing would not provide further insight. As tested, ignition of the articles would ultimately result in failing the criteria for the Exclusion from Class 1 test; however, the ignition mode called out in the UN Model Regulations is not attainable in transport. SMS resulted to using an ignition method that is generally reserved for flammable solid materials.

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The test criteria for the Exclusion from Class 1 test are paraphrased as follows:

a) No external surface temperature exceeding 65 °C other than a momentary spike not exceeding 200 °C

b) No rupture or fragmentation of the external casing or movement of the article or detached parts to exceed 1 meter in any direction Note: Where the integrity of the article may be affected in the event of an external fire these criteria shall be examined by a fire test, such as described in ISO 12097-3.

c) No audible report exceeding 135 dB(C) peak at 1 meter d) No flash or flame capable of igniting a material such as a sheet of 80 ± 10 g/m2 paper in

contact with the article e) No production of smoke, fumes or dust with specific density requirements in a 1-cubic

meter enclosure.

Note 1: If during the tests addressing criteria (a), (b), (c) and (d) no or very little smoke is observed the test described in (e) may be waived.

Note 2: The competent authority may require testing in packaged form if it is determined that, as packaged for transport, the article may pose a greater risk.

Based on SMS’s experience, of the five criteria, these articles would/did fail three of the five:

1. the temperature during burning would exceed the 65°C criteria 2. the flame would certainly burn a piece of paper 3. the amount of smoke would easily fill a 1 cubic meter chamber to point of obscurity

beyond the allowed levels. However, as noted above, the ignition modes employed by SMS are not attainable in transport of the subject products. In addition, based off the Test N.1 criteria, the product burns slower than what would even be considered a flammable solid material. F. Conclusions and Recommendation

The CERL tests showed that the potassium perchlorate/epoxy mixture is not sensitive to detonative shock and does not show any violent effect with heating under confinement as well as no other mass explosive type properties. In trying to determine an ignition method for these articles, during SMS’s testing the product was also shown to burn slower than regulated flammable solid materials and if being evaluated under the Test N.1 criteria, the product would not even qualify as a flammable solid. Based on the test results, SMS echoes the conclusions reached by CERL in that if it is interpreted that the articles are not transported in the form which they are intended for use, SMS recommends that the OOT-APRV-037 Stim™ Product Family be excluded from Class 1 and that these articles are “Not regulated as Class 1 Hazardous


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Material.” Furthermore, SMS would also agree, that if these are not treated within Class 1, that they should be assigned to Division 5.1, UN 1489 (Potassium perchlorate, mixture). However, if the product is accepted as Class 1 articles, SMS recommends that the OOT-APRV-037 Stim™ Product Family of articles, manufactured by Owen Oil Tool LP, be assigned into Class 1 as UN0349, Articles, explosive, n.o.s. ( Potassium perchlorate / epoxy), 1.4S. 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 (Fourth Revision). If you have any questions concerning this recommendation or require further assistance, please call SMS at 801-567-0456 or fax SMS at 801-567-0457. Thank you, Kirt N. Sasser, PE Vice President Safety Management Services, Inc.

Jason T. Ford Test Site/ Test Equipment Manager DOT Explosive Examiner Safety Management Services, Inc.

References: (1) Owen Compliance Services, Inc. Drawing No. OOT-APRV-037SGS, Rev 1,

“STIM™ PRODUCT FAMILY CONFIGURATION: STIMGUN™ SLEEVE (SGS),” Sheet 1 of 3, February 7, 2001.

(2) Owen Compliance Services, Inc. Drawing No. OOT-APRV-037STS, Rev 1, “STIM™ PRODUCT FAMILY CONFIGURATION: STIMTUBE™ TOOL (STS),” Sheet 2 of 3, February 7, 2001.

(3) Owen Compliance Services, Inc. Drawing No. OOT-APRV-037STS, Rev 1, “STIM™ PRODUCT FAMILY CONFIGURATION: WELL STIMULATION TOOL (WST),” Sheet 2 of 3, February 7, 2001.

dboston

Highlight

Despite this recommendation, PHMSA classified as 1.4S; UN 0349; Articles, explosive, n.o.s., (Potassium perchlorate /epoxy) on 8/28/2020 (EX2020046500)

Reference Number: SMS-5661-L1, Rev 0 Date: April 20, 2020...SMS-5661-L1, Rev 0 Page 3 of 3...

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