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
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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
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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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Photo 4: 1.1D-SEGW Waste Stream
Photo 5: 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
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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.
Pass – not forbidden
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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
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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
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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
Test Conditions and Results Pass/Fail
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
Pass – not forbidden
Small Scale Burn UN 3(d)
No explosion. Sample appeared to not burn within the flames (un-noticeable) over 10-minute period.
Pass – not forbidden
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
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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
Photo 17: Thermal Stability Test Setup – 1.1D-DST Waste Stream
1.1D-DST Waste Stream
1.1D-DST Waste Stream
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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 18: Thermal Stability Test Setup – 1.1D-DST Waste Stream
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
recommendation into hazards division 1.1.
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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
Tests included UN Series 4a (Thermal Stability) and 4b (12-Meter Drop). A summary of test
results is given in Table 3.
Table 3: Results of DOT UN Series Testing on 1.1D-SEGW 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.
Pass – not forbidden
Details of results:
UN Series 4a, Thermal Stability for Packaged Articles
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.
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 2.
Figure 2: Thermal Stability Temperature Plot for 1.1D-SEGW Waste Stream
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UN Series 4b(ii), 12-Meter Drop Test
UN Series 4(b), 12-Meter Drop Test, was conducted on the packaged 1.1D-SEGW Waste Stream.
Three drops were performed (Photo 20). 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 21).
Photo 20: 12-Meter Drop Test – Typical Setup
Photo 21: 12-Meter Drop Test – Typical Results
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Based on the test results, the packaged 1.1D-SEGW Waste Stream is consistent with a
recommendation into hazards division 1.1.
E. 1.1D-PCT 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 4.
Table 4: Results of DOT UN Series Testing on 1.1D-PCT 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.
Pass – not forbidden
Details of results:
UN Series 4a, Thermal Stability for Packaged Articles
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.
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 3.
Figure 3: Thermal Stability Temperature Plot for 1.1D-PCT Waste Stream
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Photo 22: Thermal Stability – 1.1D-CTM Waste Stream
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 23). 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 24).
Photo 23: 12-Meter Drop Test – Typical Setup
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Photo 24: 12-Meter Drop Test – Typical Results
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
Test Conditions and Results Pass/Fail
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.
Pass – not forbidden
Small Scale Burn UN 3(d)
No explosion. Sample ignited and burned for ~ 90 seconds with a small flame.
Pass – not forbidden
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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.
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Photo 26: Thermal Stability Test Setup – 1.1D-APP Waste Stream
Photo 27: 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
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Photo 28: Thermal Stability Test Setup – 1.1D-APP Waste Stream
Photo 29: Thermal Stability Test Results – 1.1D-APP Waste Stream
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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
recommendation into hazards division 1.1.
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
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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.