member companies (as of october 2018)

MEMBER COMPANIES (As of October 2018)

Accurate Energetic Systems, LLC McEwen, Tennessee Austin Powder Company Cleveland, Ohio Baker Hughes, A GE Company Houston, Texas Davey Bickford North America Salt Lake City, Utah Detotec North America, Inc. Sterling, Connecticut DynaEnergetics US, Inc. Houston, Texas Dyno Nobel Inc. Salt Lake City, Utah General Dynamics – OTS – Munition Services Joplin, Missouri GEODynamics Inc. Millsap, Texas Hilltop Energy Mineral City, Ohio Hunting Titan Houston, Texas Jet Research Center/Halliburton Alvarado, Texas Maine Drilling & Blasting Auburn, New Hampshire Maxam North America Inc. Salt Lake City, Utah MP Associates, Inc. Ione, California Nelson Brothers Inc. Birmingham, Alabama Nobel Insurance Services Irving, Texas Orica USA Inc. Watkins, Colorado Owen Oil Tools LP Godley, Texas

RA McClure Inc. Powell, Ohio Safety Consulting Engineers, Inc. Schaumberg, Illinois Senex Explosives, Inc. Cuddy, Pennsylvania Special Devices, Inc. Mesa, Arizona Teledyne RISI, Inc. Tracy, California Tradestar Corporation Salt Lake City, Utah Tread Corporation Roanoke, Virginia Vet’s Explosives, Inc. Torrington, Connecticut Visible Assets Stratham, New Hampshire W.A. Murphy, Inc. South Pasadena, California Liaison Class Members: Brazilian Association of Explosive and Aggregate Materials Industries (ABIMEX) Sao Paulo, Brazil Association of Energy Service Companies (AESC) Friendswood, Texas Australian Explosives Industry & Safety Group (AEISG) Tweeds Head, NSW Australia Canadian Explosives Industry Association (CEAEC) Ottawa, Ontario, Canada Federation of European Explosives Manufacturers (FEEM) Brussels, Belgium International Society of Explosives Engineers (ISEE) Cleveland, Ohio National Institute for Explosives Technology (NIXT) Lonehill, South Africa SAFEX International Blonay, Switzerland Explosives Safety & Technology Society – Visfotak Maharashtra, India

1

WASHINGTON, DC (202) 429-9280 www.ime.org [email protected]

IME is a nonprofit association founded in 1913 to provide accurate information and comprehensive recommendations concerning the safety and security of commercial explosive materials. IME represents U.S. manufacturers and distributors of commercial explosive materials and oxidizers as well as other companies that provide related services. Although our member companies are based in North America, IME members operate globally with operations and distribution points on all continents except Antarctica. IME was created to provide technically accurate information and recommendations concerning commercial explosive materials and to serve as a source of reliable data about their use. Committees of qualified representatives from IME member companies developed this information and a significant number of their recommendations are embodied in the regulations of state and federal agencies. The Institute’s principal committees are: Environmental Affairs; Government Affairs; Legal Affairs; Safety and Health; Security; Technical; and Transportation and Distribution.

http://www.ime.org/

mailto:[email protected]

3

Table of Contents FOREWORD ....................................................................................................................................................... 5

SECURITY ........................................................................................................................................................... 7

CLASSIFICATIONS ............................................................................................................................................... 8

STORAGE ........................................................................................................................................................... 9

SHELF LIFE ....................................................................................................................................................... 11

TRANSPORTATION........................................................................................................................................... 11

USE OF EXPLOSIVES IN OIL AND GAS OPERATIONS ........................................................................................ 14

INITIATION COMPONENTS AND SYSTEMS ...................................................................................................... 14

GROUND VIBRATION ....................................................................................................................................... 16

MISFIRES .......................................................................................................................................................... 17

RADIO FREQUENCY ......................................................................................................................................... 17

TRAINING......................................................................................................................................................... 18

ENVIRONMENTAL MANAGEMENT .................................................................................................................. 19

REFERENCES .................................................................................................................................................... 20

Appendix A ...................................................................................................................................................... 23

Appendix B ...................................................................................................................................................... 57

Appendix C ...................................................................................................................................................... 59

5

SLP 32

Recommendations for Safe and Secure Use, Storage, and Transportation of Commercial

Explosives in Oil and Gas Operations

FOREWORD

The oil and gas industry uses explosives in well completions and plug and abandonment projects. This SLP is designed to offer best practices in the manufacture, testing and transportation of the explosive articles used. It is not a replacement for the API RP-67 which discusses safety at the well site. These practices are based on U.S. standards, primarily ATF and DOT regulations, although compliance with all federal, state, and local requirements is required. Terms found in this SLP are defined in SLP 12. The best practices described in this SLP constitute what IME considers to be the minimum requirements for safety and security, and they are recommended to entities engaged in the manufacture, transportation, storage, and handling of the commercial explosive materials described herein. This SLP is not intended to be exhaustive. Nor is it intended to be a single source document for explosives operations in the oil and gas industry. Accordingly, the SLP should not be relied upon as a substitute for company-specific safety and security planning, or for seeking individual and case-specific legal and/or technical expert consultation.

7

SECURITY

This section of SLP-32 contains guidelines for explosives security in oil and gas operations. It is intended to augment the extensive explosives industry security guidelines listed in SLP-27, Security in Manufacturing, Transportation, Storage, and Use of Commercial Explosives. Explosives use in oil and gas operations may be located at well site (both land and offshore) and facility locations ranging from remote to urban, with potentially large numbers of personnel and numerous entities present at any given time. Each operating environment presents its own security considerations. For example, law enforcement response time and effectiveness may vary with proximity to population centers. Consider how the following recommendations and those given in SLP-27 apply to your operations.

1. General a. During domestic operations, adhere to federal, state, and local explosives regulations for security in

storage, transport, and use. These regulations are mainly prescribed by ATF, DOT, and DHS (if applicable).

b. Control access to explosives shipping, receiving, use, and storage areas. Keep numbers of personnel in explosives areas to the minimum required to complete the task.

c. Be cognizant of widely varying explosives regulations when operating in foreign countries. i. Observe local laws in jurisdictions where regulations are more stringent than or conflict

with U.S. regulations. ii. U.S. regulations may serve as a basis for procedures in jurisdictions where regulations are

nonexistent or loosely prescribed.

2. Oil and Gas Operation Explosives Transportation a. Jet perforating guns, charged, are transported per packing instructions provided in 49 CFR 173.62,

US1. Loaded perforating guns should be secured in a manner that will prevent their unauthorized removal, as well as removal of their explosive contents. This can be accomplished by locking the perforating guns to the truck, trailer or rack through the use of chains and locks or locking bars, or locked in a closed compartment of the truck.

b. Transporters should confirm periodically that the explosives remain properly secured to the vehicle or trailer during transport. Checks should be conducted according to company-established inspection intervals.

c. Be knowledgeable of, and adhere to, all company and regulatory security requirements relating to the explosives being transported. Certain articles and substances in Class 1 have stringent requirements regarding attendance during transport.

d. If security concerns exist when transporting explosives in magazines, assess the magazine type. For example, mobile type 2 magazines may reduce the likelihood of theft or unauthorized access when compared to type 3 magazines because of heavier construction and an additional lock. Where security concerns exist with unaccompanied loaded magazine transport, keys should be sent in a controlled manner to the destination separately from the driver of the magazine shipment, and delivery of the keys to a responsible recipient should be confirmed prior to shipping the magazines.

3. Oil and Gas Operation Explosives Receipt and Storage

a. Explosive storage at gun-loading shops and well sites is regulated in 27 CFR 555, Subpart K of the

ATF regulations.

8

b. Loaded perforating guns may be stored outside of magazines provided the conditions within ATF Ruling 2010-7 are met.

c. Identify well site explosives deliveries intended for immediate use from those intended to be stored. i. Upon arrival at the destination, remove all explosives from the vehicle.

ii. Loaded perforating guns are an exception as they may be stored on vehicles or trailers as long as they are parked and secured in a designated loaded perforating gun storage area.

d. Plan for security contingencies in the event of natural disaster, civil unrest or other circumstances that cause unplanned evacuations. This may include ensuring accountability of inventories (proper and updated documentation) and moving explosives.

4. Use – Many gun loading shops and well sites operate continuously and explosives security and

accountability can be supported by enacting a shift change procedure. Sample format may include: a. Conveying any security concerns noted on the previous shift to the incoming shift. b. Briefing to and/or verification by incoming shift of the quantities and types of explosives present. c. Any upcoming scheduled explosives deliveries to the site of operations or shipments from the site. d. Any changes to personnel explosives access rosters, if applicable. e. Verification that the conditions in the variance received under ATF Ruling 2010-7 are met.

CLASSIFICATIONS

Transportation classifications under Department of Transportation (DOT) are not always the same as storage classifications under the Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF).

1. Classification for Transportation

For transportation purposes, explosives are classified by DOT in accordance with that agency’s Hazardous Materials Regulations (49 CFR, Subtitle B, Chapter I, Subchapter C and more specifically 49 CFR §§173.50 – 173.59) and under these regulations all explosives are assigned to hazard materials Class 11. DOT classifications for common oil and gas explosive articles are based on packaging. Explosives classifications are not self-assigned like other hazard classes. They are issued by DOT’s Pipeline and Hazardous Materials Administration (PHMSA) based on results of tests conducted by PHMSA-approved labs or, in some cases, by analogy to previous classifications. Class 1 materials applicable to the oil and gas industry are divided into four divisions to note the principal hazard of the explosive2.

a. Division 1.1 – Explosives that have a mass explosion hazard. A mass explosion is one which affects almost the entire load virtually instantaneously. Typical examples are certain shaped charges, cutters, detonating cord, severing tools, detonators, loaded perforating guns.

b. Division 1.2 – Explosives that have a projection hazard but not a mass explosion hazard. Typical examples are certain power charges.

c. Division 1.3 – Explosives that have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard. Typical examples are certain types of propellants and certain power charges.

1 49 CFR 173.2 2 Division Placards are example depictions and are not comprehensive. For a full list of divisions see 49 CFR 173.2

9

d. Division 1.4 – Explosives that present a minor explosion hazard. The explosive effects

are largely confined to the package and no projection of fragments of appreciable size or range is to be expected. An external fire must not cause virtually instantaneous explosion of almost the entire contents of the package. Typical examples include certain shaped charges, certain loaded perforating guns, detonating cord in special packaging, power charges, safety fuse and electric, electronic, and nonelectric detonators.

As noted above different classifications can have the same type of explosive. The differences may be due to explosive loads or may be due to packaging differences. All testing is evaluated based on how the explosive performs in its package. Also note, the examples provided in the divisions above may fall under more than one division.

Two other classes of hazardous materials are commonly utilized by the oil and gas industry in downhole operations.

a. Division 4.1 – Flammable solid, not an explosive. Typical examples are certain power charges and some chemical cutter propellants.

b. Division 5.1 – Oxidizers, not an explosive. Typical examples are StimGunsTM and bromine triflouride (used in chemical cutters)

2. Classification Divisions for Storage Purposes

For storage purposes, ATF separates oil and gas related explosives into two classes3 as follows:

a. High Explosives – Explosive materials that can be caused to detonate by means of a blasting cap when unconfined. Typical examples include shaped charges, detonating cord, jet cutters, detonators, severing tools, bi-directional boosters, and time delay fuzes.

b. Low Explosives – Explosive materials that can be caused to deflagrate when confined. Typical examples include igniters, core gun loads, and power charges that are classified as explosives.

STORAGE

This section of SLP 32 contains guidelines for explosives storage in oil and gas operations. It is intended to supplement IME SLPs 1, 2, 3, 14, and 17. In general, all explosive materials must be stored in magazines constructed and located in accordance with federal, state and local regulations. Magazines should be kept locked at all times except for inspection, inventory, or the movement of explosive materials in or out of the magazine.

Approved storage magazines are designed to prevent unauthorized persons from having access to the explosives and to protect the explosive materials from deterioration. Accordingly, magazine sites should be inspected frequently (at least every seven days). Accurate inventories should be kept of all explosive materials and stocks of older materials should be used first. A daily summary of magazine transactions (DSMT) must be maintained. Roofs, walls, doors, floors, locks and ventilators of magazines must be kept in good repair. The area inside the magazine should be kept clean, dry and orderly. No combustible material

3 ATF has three classifications of explosives, however only high explosives and low explosives categories are applicable to the oil and gas industry.

10

should be stored within 50 feet (15.2 m) of the magazine and all dry grass or brush cleared for a distance of 25 feet (7.6 m) around the magazine.

Anyone contemplating building or locating a storage magazine or purchasing explosive materials should make sure that they are in compliance with all applicable regulations.

The following table provides examples of common oilfield explosive products and magazine types in which these products can be stored.

Explosives Compatibility Based on ATF Requirements

Magazine Type Classes of materials that may be stored together4

Detonator storage magazine: Examples of allowed storage

Other storage magazine: Examples

Type 1 –permanent storage

All classes of explosives: High explosives and low explosives.

Detonators, igniters, time delay fuzes, and percussion initiators.

Shaped charges, detonating cord, jet cutters, severing tools, power charges, core gun loads, bi-directional boosters and igniters

Type 2– portable


Detonators, igniters, time delay fuzes, and percussion initiators.

Shaped charges, detonating cord, jet cutters, severing tools, power charges, core gun loads, bi-directional boosters, and igniters

Type 3 – day box (Not to be used for unattended storage.)


Detonators, time delay fuzes, and percussion initiators.

Shaped charges, detonating cord, jet cutters, severing tools, power charges, bi-directional boosters, igniters, and core gun loads

Type 4 – permanent or portable

Low explosives only. Non-mass detonating detonators, igniters and squibs.

Core gun loads, power charges, and igniters

In order to store detonators in Type 4 magazines, they must be stored in a manner which will prevent them from mass-detonating. As an example, DOT Division 1.4 explosives will not mass detonate if the conditions of DOT’s approval are maintained. Changes to an explosive’s package or storage of other materials, explosive or non-explosive, in the package, may invalidate the DOT Division 1.4 classification. For example, removing Division 1.4 detonators from their package and placing them in another box or removing a portion of the packaging material may allow for a mass explosion. The DOT approval documentation will describe packaging requirements for proper classification.

Loaded perforating guns may be stored in areas outside of a magazine according to the conditions listed in ATF Ruling 2010-7, which requires the following:

• Notification for each site at which perforating guns are to be stored • Site security features and practices • Configurations and positions of stored guns • Maximum limitations on quantities of stored guns and net quantities of explosives • Notification of local fire safety authority and local ATF office • Specific documentation of perforating guns and contents

4 Detonators, with certain exceptions, may not be stored with other explosive materials. Refer to “Detonator Storage Magazine” column in this table.

11

Use the American Table of Distances for Storage of Explosive Materials to determine safe distances from inhabited dwellings, highways, passenger railways, and between explosive materials magazines. ATF may approve, via variance, use of an IMESAFR quantitative risk assessment in lieu of quantity-distance.

SHELF LIFE

Explosives should be used on a first-in/first-out basis to prevent accumulation of aged shelf stock. Some manufacturers may specify a shelf life and storage conditions on their explosives. Unless specified otherwise by the manufacturer, shelf life should be treated as a guideline to verify that condition and performance are still suitable for intended use rather than as a maximum storage length or expiration date for the explosives. Excess heat, humidity, or vibration may significantly affect shelf life.

TRANSPORTATION

1. Explosives are to be transported in compliance with applicable local, national or international transport regulations, including air and vessel regulations. In the United States, these are the regulations written by the U.S. Department of Transportation (DOT) and published in Title 49 Code of Federal Regulations. IME addresses the transport of explosives in depth in IME Safety Library Publication Number 14, Handbook for the Transportation and Distribution of Explosive Materials. The sections below supplement that information for products specific to the oil and gas industry, such as loaded perforating guns.

Transportation of explosives via railroad, water, or highway under the jurisdiction of DOT or the Department of Homeland Security (U.S. Coast Guard)), is exempt from the storage regulations of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

2. The driver of a motor vehicle meeting the definition of a commercial motor vehicle in 49 CFR 383.5, must hold a valid commercial driver’s license (CDL). In summary, a commercial motor vehicle is defined in that section as a motor vehicle or combination of motor vehicles that:

• Has a gross vehicle weight rating (GVWR) of 26,001 pounds or more; or • Has a gross combination weight rating of 26,001 pounds or more, inclusive of a towed unit(s) that

has a GVWR of more than 10,000 pounds; or • Is of any size and is used to transport hazardous materials in quantities that require the vehicle to be

placarded, or any quantity of a material listed as a select agent or toxin in 49 CFR 73.

When transporting explosives, or any hazardous material, in a quantity that requires the vehicle to be placarded, the driver’s CDL must also have a hazardous material endorsement.

3. Prior to loading explosives onto a vehicle, the compatibility of explosives with other explosives and with other hazardous materials, should be determined by reviewing the segregation and compatibility charts found in 49 CFR 177.848.

4. Perforating Gun Transportation.

a. Classification: Prior to transporting or offering perforating guns for transport, they must be approved by DOT. The approval, titled Classification of Explosives (also known as an EX-letter), specifies the UN number, proper shipping name, UN division and compatibility group assigned to a particular style of perforating guns.

The approval process for any explosive can be expensive, complicated and time consuming, usually requiring evaluation and/or testing by an approved laboratory before the approval application will be considered by DOT. To simplify the process, IME and the Association of Energy Service Companies (AESC) developed the Guide to Obtaining DOT Approval of Jet Perforating Gun using AESC/IME Perforating Gun Specifications (“Specifications”); see Appendix A. The Specifications are a series of documents setting forth standardized parameters for various perforating gun systems.

12

The documents include a drawing representative of the perforating gun system, technical details for the system, authorized components and compliance requirements that govern the applicability of the perforating gun specification. The Specifications have been reviewed and approved by DOT for companies to use to apply for approval of their loaded perforating guns. Use of the Specifications will enable the applicant to obtain DOT approval of their qualifying perforating gun systems without the need for testing and with a minimum of effort and delay. Perforating gun systems covered by the Specifications are:

• Ported tube systems (without detonator) • Tube & strip systems (without detonator) • Tube & tube systems (without detonator) • Strip carrier systems (without detonator) • Wire carrier systems (without detonator) • Link carrier systems (without detonator) • Swing carrier systems (without detonator) • Tube & Tube Kodiak™ system (without detonator)

Every company that loads perforating guns must have their perforating guns approved by DOT, before transporting or offering the perforating guns for transport. Details regarding the approval process using the Specifications is provided in the Specification document which is available on the IME website at: https://www.ime.org/content/recommendations_and_guidelines.

b. Transporting perforating guns: Loaded perforating guns are to be transported in compliance with the applicable hazardous materials transportation regulations. This includes marking and labeling each perforating gun, preparation of shipping papers, and if applicable, applying placards to the vehicle. Details are included in 49 CFR 172, Subparts C – F. IME’s Safety Library Publication 14, Handbook for the Transportation and Distribution of Explosive Materials, provides guidance in meeting those requirements.

Additionally, loaded perforating guns must be carried as specified in 49 CFR 173.62 Packing Instruction US 1 (see Appendix B). Among the provisions of US 1 is the requirement in paragraph 1.d.(i) that guns are not subject to damage by contact, one to the other or any other article or material carried in the vehicle. In March 2015, DOT clarified this provision stating that mere contact between perforating guns is not a violation of the regulation, unless the contact allows for movement between the guns that could cause damage by contact. Perforating guns that are touching, but that are appropriately secured for conditions normally incident to transportation, would be compliant with the requirements of US 1, paragraph 1.d.(i). See Appendix C for the DOT clarification. As with all explosives, security is a critical component when transporting loaded perforating guns. Implementing sound security practices reduces vulnerability to loss or theft. Loaded perforating guns should be secured in a manner that will prevent their unauthorized removal, as well as removal of their explosive contents. This can be accomplished by locking the perforating guns to the truck, trailer or rack through the use of chains and locks or locking bars, or locked in a closed compartment of the truck.

5. Transportation of Detonators with Loaded Perforating Guns:

Detonators may be carried on the same vehicle as loaded perforating guns, as specified in Packing Instruction US 1, paragraph 1.a. They are to be carried in their original UN certified packaging or, as authorized by 49 CFR 173.63(f) and (g) for 1.4B and 1.4S detonators, in an IME 22 box. Refer to IME’s Safety Library Publication 22 for construction details for an IME 22 box. Additionally, detonators may be carried by road in an alternate container that has been approved by DOT’s Associate Administrator,

https://www.ime.org/content/recommendations_and_guidelines

13

per 49 CFR 177.835(g)(3). One such authorization was issued by DOT through Special Permit DOT-SP 11432. Each company that is a Party to that Special Permit may carry up to 24 detonators (each in a heavy wall tube) in a steel “cap box” constructed of at least 12 gauge low-carbon steel, lined with at least ¼” foam or wood, with at least two means for preventing the lid from opening should accidental initiation of the contents occur. To apply for Party status to that Special Permit, or any other, follow the directions specified in 49 CFR 107.107. To view DOT-SP 11432 or any other Special Permit, follow this link: http://phmsa.dot.gov/hazmat/regs/sp-a/special-permits/search

6. Special Requirements for Transportation of Detonating Cord:

Detonating cord, not contained in a loaded perforating gun, must be packaged as specified in Packing Instruction (PI) 139 of 49 CFR 173.62. That PI allows cords that are classified as UN0065, UN0104, UN0289 and UN0290 to be carried without the ends of the cord sealed, provided the inner packaging used to contain the cord consists of a static-resistant plastic bag of at least 3 mil thickness and the bag is securely closed. The inner packaging must then be placed in the appropriate UN certified box, also specified in PI 139, and closed in the manner specified by the cord manufacturer. In the U.S., detonating cord may be transported as UN0289 / 1.4D shipment if shipped pursuant to 49 CFR 173.63(a). Shipment under conditions other than described in 49 CFR 173.63(a) requires that this package be marked / labeled UN0065 / 1.1D.

http://phmsa.dot.gov/hazmat/regs/sp-a/special-permits/search

14

USE OF EXPLOSIVES IN OIL AND GAS OPERATIONS

The oil and gas industry uses different types of explosives in its day to day operations. Among the commonly used articles are:

• Perforating Charges • Jet cutters • Setting tools • Core guns • Perforating guns • Propellent products • Igniters • Power Charges • Initiating systems (including detonators, cartridge actuated, hydraulic and impact firing heads) • Bidirectional Boosters • Detonating Cord

Each of these explosives have a unique makeup. For example, there are several different types of explosive loads, explosive types, and physical configurations. These explosive articles are selected based on physical requirements unique to the wellbores in which they are to be used.

Each manufacturer of these explosives has their own instructions for application and use of their products. Users should be well trained in the installation and use of these explosives and follow those instructions.

INITIATION COMPONENTS AND SYSTEMS

1. Electric Detonators – Oilfield electric detonators are explosive devices that require electrical stimulus to begin the initiation process. There are multiple types of electric detonators:

a. Bridgewire detonators – Oilfield bridgewire detonators should have a minimum resistance of 50 Ohms and a 200mA no-fire current, per RP67. The resistance will typically come from resistors that are inserted in the detonator circuit. This type of detonator typically employs a primary explosive (such as lead azide, lead styphnate, silver azide, etc.) to begin the initiation train but may also use a pyrotechnic mix. Secondary explosives (such as PETN, RDX, HMX, HNS, etc.) are used as the main output explosive. These detonators are normally 1-4” in length and 1/4-1/3” in diameter.

b. High Energy Electric Detonators (HEED) – HEED operate in a fundamentally different manner than bridgewire detonators, in that they contain no primary explosives and are activated by a sudden pulse of voltage or voltage and current. There are two main types of HEED: exploding bridgewire detonators (EBW) and exploding foil initiators (EFI). In an EBW, a bridgewire is vaporized by a high voltage, high current pulse which initiates a secondary explosive such as PETN, RDX, or HMX. In an EFI, a high voltage pulse vaporizes foil, causing a “flyer plate” to strike a secondary explosive pellet, often HNS.

c. Deflagration to Detonation Transition (DDT) detonator – DDT detonators contain an initiation source, such as a bridge element, which ignites an insensitive pyrotechnic or explosive upon receiving a short duration, high current pulse. This ignited material is coupled to a column of secondary explosive, the reaction rate of which increases from deflagration to the point of detonation, providing an output that will initiate secondary explosives. DDT detonators do not contain primary explosives.

2. Electronic initiation detonators – Electronic initiation detonators are specialized devices that employ an electronic circuit to control functions such as device identification, communication, and activation of the

15

charging, and/or firing commands. Some electronic initiation systems may use a form of an electric detonator as the output or some other explosive device.

3. Non-Electric Detonators – Oilfield non-electric detonators are explosive devices that have no electric or electronic initiation methods and rely on another explosive device or mechanical means to begin its initiation process. These devices are typically made up of secondary explosives (PETN, HMX, RDX, HNS, etc.) that are usually housed in a steel or aluminum cylindrical housing generally 1/4” to 1/3” in diameter and 1/2” to 2” in length.

4. Percussion Initiators – A detonator designed to be initiated by mechanical impact. They generally contain primary and secondary explosives. The secondary explosives are mainly RDX, HMX, HNS and PYX. Percussion initiators shall be designed and manufactured to withstand a drop, without firing, of at least 4.6m (15ft) onto a steel plate supported by concrete. They are designed to require a minimum impact energy using a specific firing pin to be initiated.

5. Ballistic Interrupters (also known as detonator interrupter devices) – Some electric detonators may be designed to include, or be combined with, a ballistic interrupt safety feature. The interrupt feature is typically a physical barrier designed to prevent the detonator output from initiating the detonating cord or next explosive component in the explosive train. The ballistic interrupter is required when transporting loaded perforating guns with a detonator attached.

6. Igniters – Igniters, which can be initiated electrically, electronically, or by other means, are spark, flame producing or pyrotechnic initiators that can be used to initiate power charges, plasma cutting torches, or other similar devices. API RP-67 states that these devices must have a minimum of 50 ohms of resistance.

7. Detonating Cord – Detonating cord is a flexible cord containing a center core of high explosives that is typically used to initiate other explosives. Detonating cord supplied for oil field operations generally contain explosive loads of 4 to 120 grains of explosive per foot (0.85 to 25.5 grams per meter). The explosive loads may be covered by textiles, waterproofing compounds, and plastics designed to protect the explosive core from damage by water, abrasion or oil penetration. A non-electric, electric, or electronic detonator can be used to initiate the detonating cord as well as other explosive devices that are properly sized and connected. Detonating cord has applications ranging from perforating guns (as a means to initiate the shaped charges within) to pipe recovery (as a means of jarring stuck pipe as in a “string shot”).

8. Other Explosive Devices – Other explosive devices that are used may include boosters, bi-directional boosters, time delays, and connection devices. Boosters and bi-directional boosters are explosive devices that are used to carry on the ballistic train and typically employ secondary explosives. Time delays are used in the perforating event to allow for a pause between the detonation sequences between perforating guns. Connection devices may also include the use of explosives. The devices can be used to connect components such as detonating cord, detonators, shaped charges, or other devices

9. Electronic Instruments

a. Safety Meters – Safety meters, also called blasting ohmmeters, blasting multimeters, and/or blasting galvanometers, are test instruments with built-in current limiting features used to measure electrical resistance or conductivity in a blasting circuit.

b. Systems Surface Testers – These instruments are used in conjunction with electronic detonators and electronic switches to ensure that these devices are wired in properly and have proper communication with the surface test equipment. Please refer to the latest edition of API RP-67 for features and characteristics of testing equipment for electronic switches.

c. Mechanical and Electronic Switches – Mechanical and electronic switches are used to select which guns are fired independently as opposed to initiating all guns simultaneously. Mechanical switches rely on the internal pressures generated by the firing of a perforating gun to disable the original firing circuit and enable the circuit for the adjoining perforating gun. Electronic switches do not rely on perforating gun detonation pressures but rather are selectively addressed from the surface firing panel. Electronic switches are capable of relaying continuity back to the surface panel instrumentation, and if necessary, re-route continuity and selectively fire a perforating gun in a non-sequential order.

16

10. Hand Tools

a. Detonator Safety Tubes – Detonator safety tubes are typically tubular vessels used to contain an electric detonator during arming. They are designed to contain the fragments and most of the blast if the detonator inadvertently functions. The detonator safety tube is typically a heavy-walled tube with one end closed and a cover at the other end. Each tube design should be such that it will contain the fragments of the detonator in use and mitigate the blast.

b. Wire Strippers – Wire strippers are handheld devices that are used when stripping the protective insulation from electrical wires.

c. Detonator Crimpers – Detonator crimpers are used to attach end (or axial) initiated detonators to detonating cord. These devices are designed to apply a prescribed maximum amount of crimp (or crush) to the detonator crimp extension and the detonating cord. Only approved detonator crimpers and techniques recommended by manufacturers of detonator attachment devices (or authorized by the service company) should be used.

d. Detonating Cord Cutters – Detonating cord cutters are hand tools used to cut detonating cord. Typically, these devices will use a razor blade as the means to cut the detonating cord. The size and shape of the cutters may vary, but the method of cutting the detonating cord is essentially the same. The cord is positioned in the cutter near the razor blade. The blade is brought down and thru the cord as it cuts. Use of a properly designed detonating cord cutter minimizes conditions that could initiate the detonating cord. At no time should any other devices be used to cut detonating cord other than what is recommended by explosive manufacturers or authorized by the service company. ALWAYS use a sharp, single-bladed device designed or approved for cutting detonating cord. NEVER cut detonating cord with devices such as scissors, plier-type cutters, cap crimpers, or similar instruments.

11. Firing Panels – Firing panels, also called shooting panels, are used to provide energy from the surface to inside the well bore to initiate detonators. There are three basic types of firing panels: variable output, capacitive discharge (dump fire), and electronic firing panels.

a. Variable Output – Firing panels that have a variable output are typically used for initiating standard electric detonators. These panels generally have outputs of 300 volts and 3 amps. Variable output firing panels have several safety features including a requirement that at least three deliberate actions are required to fire the explosive device. Additionally, at least one of these actions typically require the use of two hands, and at least one of these actions involves a spring-loaded switch.

b. Capacitive Discharge – Firing panels that have a capacitor inside the firing panel that is charged before firing. On firing the stored energy is instantaneously dumped to initiate the detonator. These panels generally have outputs of 300 volts and 3 amps. Capacitive Discharge firing panels will have the same safety features as Variable Output firing panels.

It is possible to use capacitive discharge devices located in the perforating gun assembly to detonate HEED such as EBW’s and EFI’s. These devices receive energy from the variable output firing panel and store the energy in the capacitive discharge device from which the energy is dumped to the EBW or EFI for firing.

c. Electronic Firing Panel for Electronic Detonators and Switches – Electronic firing panels are similar to the variable output panels in size, shape, and intended purpose. However, the main difference is that electronic firing panels only work with electronic initiation systems that meet the proprietary electronic protocols.

GROUND VIBRATION

Ground vibration is not usually considered an issue with oil and gas explosive operations due to the depths at which explosives are used in wellbores. However, for testing areas and firing ranges, it is necessary to consider buried pipelines that may cross the property of explosive sites. These pipelines can include large diameter pipes across a field that carry natural gas, oil, or other fluids such as steam; they may also be small diameter trunk lines that carry these fluids to buildings. Often, these pipelines, whether large or small, are

17

pre-existing and expansion of explosive testing sites may now encroach upon them. Some factors that are important when considering the effects of explosive detonations on buried pipelines include:

• Diameter

• Wall thickness

• Material strength

• Age

• Line pressure

• Line temperature

• Working fluid inside

• Distance from pipeline to explosive detonation point

• Depth of pipeline

• Depth of explosive detonation

• Soil type

• Size and configuration of test shot

• Attenuation methods It is important that an analysis be conducted, by calculation and/or experiment, to ensure that explosive detonations at the test location do not cause an adverse response to the buried pipeline. The analysis may provide information about ground particle velocity or the stress and strain on the pipeline. Regulatory requirements that define ground motion criteria may also be a factor that needs to be considered during the analysis.

MISFIRES

Misfire procedures at the well site are well documented in API RP-67. Each manufacturer has their own processes to be followed when a misfire is detected during manufacturing and testing.

Whenever a firing system, electrical or mechanical, is used to initiate explosives, during manufacturing, testing, or other non-wellsite use there is a possibility of a misfire. Should the first attempt to fire result in a misfire, at least two more attempts to initiate the explosives should be made. If there is still no positive indication of an explosive output using an electrical firing system, the firing line should be disconnected at the control panel and shunted and a half-hour waiting period observed before attempting recovery or any other activity involving the suspected misfired explosives. If no explosive output is detected using a mechanical firing system, the mechanical actuating device should be returned to a safe position and a half-hour waiting period observed before attempting recovery or any other activity involving the suspected misfired explosives.

Please refer to the manufacturer’s instructions for possible longer or shorter wait times.

RADIO FREQUENCY

Please refer to SLP-20 and API RP-67 for safety precautions with Radio Frequency and stray voltages.

Each manufacturer will have their own procedures regarding the use of phones and radios in different parts of their facility. Always follow manufacturer’s instructions.

18

TRAINING

1. IME SLP 25 Explosives Manufacturing & Processing Guideline to Safety Training discusses five general aspects of good safety training that should be considered when creating a training program for oilfield explosives assembly operations. Another reference, API RP-67, contains field safety procedures for explosive device transportation, assembly, and handling at the wellsite. The importance of appropriate safety training is emphasized in the following excerpt from IME SLP 25:

Safety training is an essential component of any program designed to protect employees’ health and safety. Proper training ensures adequate understanding of Code of Federal Regulations, standard procedures, operational parameters, and emergency procedures and their successful completion each time they are needed.

2. Companies using explosives in oil and gas operations should ensure that personnel are properly trained in their assembly and use. As there are many types of oilfield explosives products and new products are continually being released as technology adapts to different challenges, regular review and updating of training programs is recommended.

3. Due to the wide variety of processes, equipment, and products in oilfield use, manufacturer instructions should always be consulted in formulating training, and each training program should be customized to the unique processes, equipment, and products used. A partial list of those processes, equipment and products that should be addressed in training is provided below: a. Propellants

i. Power charges ii. Gas fracturing devices

b. Perforating gun loading i. Gun types

a) (Scalloped) Hollow carrier guns b) Strip guns c) Port plug guns

ii. Appropriate tools iii. Shaped charge size and explosive load compatibility with selected perforating gun iv. Installation of shaped charges v. Cutting and installation of detonating cord

vi. Installation of explosive transfer devices vii. Arming procedures

viii. Detonator interrupts ix. Specialty charges x. Capsule charges

xi. Port plug gun charges xii. Regulatory requirements

a) Storage b) Transport

xiii. Perforating gun downloading (not including misfires) xiv. Spent perforating gun

c. TCP firing heads i. Pressure actuated

ii. Drop bar actuated d. Jet cutter assembly e. Severing tool assembly f. Setting tool assembly

i. Igniters ii. Power charges

g. Core Guns

19

ENVIRONMENTAL MANAGEMENT 1. Compliance with Federal, State, and Local Requirements

Companies responsible for operating sites involved in oilfield explosives manufacturing, assembly, distribution, and use must be aware of the myriad of federal, state, and local environmental requirements that have the potential to impact their activities. IME SLP 29 (Recommendations for the Environmental Management of Commercial Explosives) provides manufacturers of commercial explosives with an outline of federal environmental laws administered by the U.S. Environmental Protection Agency (EPA). The materials presented in SLP 29 are intended to enhance the reader’s familiarity with those statutory and regulatory requirements. While the SLP is primarily intended to be a reference source for managers at explosives manufacturing facilities, some of the information may also be useful to managers at assembly, distribution, and use sites. Additional state and local environmental requirements may also be applicable, and companies should ensure that site and/or company environmental management plans address those requirements. State environmental authorities, where they administer federal environmental programs, must promulgate regulations that are at least as stringent as the equivalent federal requirements. In many cases, these regulations may be even more restrictive than their federal counterparts.

2. Offshore Considerations

The Bureau of Safety and Environmental Enforcement (BSEE) of the U.S. Department of the Interior, administers and enforces environmental standards applicable to outer continental shelf (OCS) operations. Environmental standards may be included in environmental laws and regulations as well as in conditions included in OCS leases, plans, and permits. Environmental programs overseen by BSEE include, but may not be limited to: air quality, archeological/cultural resources, benthic ecology/corals/fisheries, compliance with the National Environmental Policy Act (NEPA), marine trash and debris oversight, protected species, artificial reefs, and water quality. BSEE also is responsible for enforcing training and environmental compliance programs and has regulatory authority over well decommissioning activities. BSEE’s oversight and enforcement may, depending on the particular program, be conducted in cooperation with the Bureau of Ocean Energy Management (BOEM), the U.S. Coast Guard, the National Oceanic and Atmospheric Administration (NOAA), and EPA.

3. Disposal / Recycling of Spent Perforating Guns

Companies managing the disposition of spent perforating guns must understand the potential applicability of federal, state, and local laws and regulations governing the management of solid and/or hazardous waste, including relevant exclusions for scrap metal that is recycled. In order to meet these requirements, spent perforating guns must be examined to determine whether they contain any explosive material.

After perforating, physically inspect each gun to confirm all charges have detonated by cross referencing the corresponding load sheet. In accordance with best available practices, the cause behind any undetonated charges should be determined.

Every spent perforating gun body and firing head must be inspected to confirm the absence of any explosive material, prior to shipment to a disposal or recycling facility. Confirmation of this inspection should be communicated to the disposal or recycling facility. Each gun with unperforated

20

scallops or ports should be identified and the reason(s) for lack of perforation communicated to the disposal or recycling facility.

Spent perforating guns that are found to contain explosive material must be properly managed and disposed of in accordance with applicable environmental regulations. Federal requirements that may be applicable to such materials are found in EPA regulations implementing the Resource Conservation and Control Act (RCRA). Please refer to SLP 29 for more information on RCRA. Additional state and/or local requirements may also apply.

Additionally, a process for evaluating spent perforating guns for disposal and/or recycling is set out in API Recommended Practice 67 (RP67).

4. Carbon Monoxide Generated from Long Gun Perforating Perforating may generate carbon monoxide in sufficient quantities that its emergence from the wellbore can cause harm or death to wellsite personnel. Safety planning must consider methods to mitigate carbon monoxide emergence from the wellbore. High temperature stable explosives, such as HNS or PYX, produce a higher proportion of carbon monoxide in the gas generated from perforating than do RDX or HMX. Shallow perforating depths, large or long gun strings, and high circulation rates may increase the rapidity of emergence and concentration of carbon monoxide at the well site.5

REFERENCES Explosives users must make sure they know and comply with the regulations that apply to their particular operations. While this publication will assist you in regulatory compliance, it does not contain all applicable regulatory criteria. Agencies administering regulations that involve explosive materials are listed below:

1. Regulatory Agencies

Area of

Concern

Dept./ Agency

Responsibility Authority∗

Transportation DOT

• Pipeline and Hazardous Materials Safety Administration (PHMSA) (all transport modes)

• Federal Motor Carrier Safety Administration (FMSCA)

49 CFR 105 – 180

49 CFR 300-399

Security DHS • Infrastructure Security Compliance

Division (Facility Security)

• US Coast Guard (Transportation and Port Safety and Security)

6 CFR

46 CFR

Environmental EPA Environmental protection (e.g., waste management)

40 CFR

Worker Safety and Environmental

Interior, BSEE

Worker safety, environmental protection (offshore operations)

30 CFR

5 SPE paper: SPE-187036-MS. Carbon Monoxide Hazards from Perforating During Plug and Abandonment Operations. Thomas Burky, G.G.Craddock, Justin Mason, Federico Rios and Kevin Harive, Halliburton. 2017.

21

Area of

Concern

Dept./ Agency

Responsibility Authority∗

Storage Safety and Security

ATF Product storage, inventory accountability 27 CFR 555

Worker Safety OSHA

Worker Safety and Health 29 CFR

Miscellaneous State & Local

Agencies

All of the above Various state and local regulations

∗ Reference Title Code of Federal Regulations. Available from the U.S. Superintendent of Documents, Government Printing Office, Washington, D.C. 20402

2. Other Resources

• American Petroleum Institute (API), Recommended Practice (RP) 67 – Recommended Practice for Oilfield Explosives Safety

• The National Fire Protection Association (NFPA), Publication Number 495, Manufacture, Transportation, Storage and Use of Explosive Materials

• NFPA, Publication Number 400, Hazardous Materials Code • Product Safety Data Sheets and technical data sheets published by manufacturers of explosive materials • Case Inserts or Warnings (packed in cases or cartons of explosives materials) • ISEE Blasters’ Handbook • ATF Federal Explosives Law and Regulations (ATF P 5400.7), 27 CFR Part 555, Subpart K

• IME Safety Library Publication Number 1, Construction Guide for Storage Magazines

• IME Safety Library Publication Number 2, The American Table of Distances

• IME Safety Library Publication Number 3, Suggested Code of Regulations for the Manufacture, Transportation, Storage, Sale, Possession, and Use of Explosive Materials

• IME Safety Library Publication Number 4, Warning and Instructions for Consumers in Transporting, Storing, Handling and Using Explosive Materials

• IME Safety Library Publication Number 14, Handbook for the Transportation and Distribution of Explosive Materials

• IME Safety Library Publication Number 12, Glossary of Commercial Explosives Industry Terms

• IME Safety Library Publication Number 17, Safety in the Transportation, Storage, Handling and Use of Explosives

• IME Safety Library Publication Number 20, Safety Guide for the Prevention of Radio Frequency Radiation Hazards in the Use of Commercial Electric Detonators (Blasting Caps)

• IME Safety Library Publication Number 22, Recommendations for the Safe Transportation of Detonators in Vehicle with Certain Other Explosive Materials

• IME Safety Library Publication Number 25, Explosives Manufacturing Processing Guideline to Safety Training

• IME Safety Library Publication Number 27, Security in Manufacturing, Transportation, Storage and Use of Commercial Explosives

• IME Safety Library Publication Number 29, Recommendations for the Environmental Management of Commercial Explosives

• IME Safety Library Publication Number 31, Methods and Algorithms Used for Quantitative Risk Analysis

23

Appendix A Guide to Obtaining DOT Approval of Jet Perforating Guns using AESC/IME Perforating Gun Specifications

Version 02 Effective Date: September 1, 2017

1. What is required?

Transportation of Jet perforating guns (hereafter referred to as “perforating guns”) in the USA is subject to the provisions of the Hazardous Materials Regulations (HMR)1 of the U.S. Department of Transportation (DOT). In the HMR, DOT describes perforating guns as follows:

Jet perforating guns, charged, oil well, without detonator. Articles consisting of a steel tube or metallic strip, into which are inserted shaped charges connected by detonating cord, without means of initiation.2

As explosive devices, the following DOT requirements, administered by its Pipeline and Hazardous Materials Safety Administration (PHMSA), apply to perforating guns:

• Classification and approval • Registration of parties who offer and/or transport hazardous materials • Training of hazmat employees • Hazard communication (marking, labeling, placarding and shipping papers) • Provision of emergency response information • Security plans • Packaging of hazardous materials • Modal transportation requirements

This document discusses classification and approval of perforating guns, specifically when using AESC/IME Perforating Gun Specifications.

2. What are the AESC/IME Perforating Gun Specifications?

Before transporting or offering perforating guns for transport, they must be approved by the Associate Administrator of PHMSA3. This approval, signified by a Classification of Explosives (also known as EX-letter), sets forth the UN number, proper shipping name, UN division and compatibility

1 49 CFR Subchapter C 2 49 CFR 173.59 3 49 CFR 173.51

Guide to Obtaining DOT Approval of Jet Perforating Guns using AESC/IME Perforating Gun Specifications

24

group to be assigned to perforating guns as well as the terms and conditions for the use of said classification.

♦ Every perforating gun that is transported within the US must be approved by PHMSA before it may be offered for transport.

♦ Every person (company) that loads perforating guns and either transports them, or offers them for transport, within the US must obtain approval from PHMSA before they do so.

The approval process can be expensive, complicated, and time-consuming, and often requires testing by an approved laboratory before the approval application will be considered by PHMSA. The Association of Energy Service Companies (AESC) and the Institute of Makers of Explosives (IME) have devised the AESC/IME Perforating Gun Specifications (see Annex 1) to provide a resource for reducing the expense, effort, and time required to obtain classification and approval of perforating guns.

The AESC/IME Perforating Gun Specifications are a series of documents setting forth standardized parameters for various perforating gun systems. These series of documents include a drawing representative of the perforating gun system described, technical details for the system, authorized components of the systems, and compliance requirements that govern the applicability of the perforating gun specification. The perforating gun systems covered by the AESC/IME Perforating Gun Specifications are:

♦ Ported tube systems (without detonator) ♦ Tube & strip systems (without detonator) ♦ Tube & tube systems (without detonator) ♦ Strip carrier systems (without detonator) ♦ Wire carrier systems (without detonator) ♦ Link carrier systems (without detonator) ♦ Swing carrier systems (without detonator) ♦ Tube & Tube Kodiak™ system (without detonator)

The AESC/IME Perforating Gun Specifications have been previously reviewed and approved by PHMSA for the use of perforating gun assemblers (see Annex 2). Approval applications submitted to PHMSA which fall within the parameters of these qualified perforating gun systems may therefore be processed without testing and with a minimum amount of effort and/or delay. Perforating guns that do not meet the parameters of the AESC/IME Perforating Gun Specifications are subject to testing and the applicant must follow the process described in 49 CFR 173.56.

3. Classifications available using AESC/IME Perforating Gun Specifications

Classification for perforating guns without detonators affixed to them may be obtained using the AESC/IME Perforating Gun Specifications:

3.1. 1.1D – PHMSA will issue approvals for qualifying perforating gun systems as UN0124; JET PERFORATING GUNS, CHARGED; 1.1D.


25

3.2. 1.4D – Excluding the Tube & Tube Kodiak™ system4, perforating gun systems that have been approved as UN0124 and that meet the requirements of Special Provision 1145

and Packing Method US 16 may be transported as UN0494: JET PERFORATING GUNS, CHARGED; 1.4D. See Annex 3 for the text of Special Provision 114 and Annex 4 for the text of Packing Method US 1.

4. ATF License/Permit required7

Parties who seek authorization of perforating gun systems using the AESC/IME Perforating Gun Specifications are advised that they must also be authorized by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)8 to possess explosives and must be in possession of the appropriate ATF license or permit. Within the scope of this document:

4.1. Manufacturers must have an ATF type 20 license for each manufacturing location that will be seeking PHMSA approval of perforating guns.

4.2. Importers must have an ATF type 23 license for each importing location that will be seeking PHMSA approval of perforating guns.

4.3. Dealers must have an ATF type 26 license for each dealing location that will be seeking PHMSA approval of perforating guns.

4.4. Users must have an ATF type 33 permit. One type 33 permit per company is valid for all user locations that the company operates within the USA.

5. Approval of perforating gun systems

5.1. General requirements

5.1.1. Perforating guns to be approved using an AESC/IME Perforating Gun Specification must be consistent with the configuration in the drawing of the applicable gun system.

5.1.2. All explosive components to be loaded into perforating guns must themselves be PHMSA approved. Copies of these approvals must be maintained at each location where jet perforating guns are assembled.

5.2. Approval application

5.2.1. A single application must be submitted for each perforating gun system to be

approved. For example, if company A plans to utilize ported gun systems, tube/tube gun systems, and strip gun systems, then company A would submit 3 approval applications. Once approved, the classification applies to all locations

4 This exclusion is described in Note 5 of the Tube & Tube Kodiak™ specification sheet found in Annex 1. 5 49 CFR 172.102 6 49 CFR 173.62 7 This notification is advisory only and is not a PHMSA imposed condition of jet perforating gun approvals issued pursuant to the AESC/IME Perforating Gun Specifications. 8 U.S. Department of Justice


26

operated by the applicant (company A) that load the approved perforating gun systems.

5.2.2. Applications for approval of perforating guns using AESC/IME Perforating Gun Specifications must:

5.2.3. 5.2.3.1. Identify the section of the HMR under which the application is submitted. 5.2.3.2. Identify the applicant. 5.2.3.3. Identify the perforating gun system to be approved. 5.2.3.4. Identify the classification for which approval is desired. 5.2.3.5. Identify the transport modes for which approval is desired. 5.2.3.6. Include a copy of the AESC/IME Perforating Gun Specification that will

serve as the basis for approval and contain a certification of adherence to the specifications and requirements contained on that document.

Annex 5 contains an example application that is recommended for use in preparing applications in fulfillment of these requirements.

5.3. Use of approval

Compliance with applicable requirements of the HMR when shipping perforating guns approved using an AESC/IME Perforating Gun Specification is required, including, but not limited to:

5.3.1. Perforating guns cannot be transported or offered for transport until DOT has

issued an approval in the form of a Classification of Explosives (EX-letter). A copy of the approval must be on file in every location from which loaded perforating guns are transported or offered for transport.

5.3.2. All perforating guns approved using an AESC/IME Perforating Gun Specification

must always meet Packing Instruction US 1 of 49 CFR 173.62 (see Annex 4).

5.3.3. All perforating guns approved as 1.1D (UN0124) using an AESC/IME Perforating Gun Specification must always meet the requirements of Special Provision 114 of 49 CFR 172.102 (see Annex 3) if offered as 1.4D (UN0494).

5.3.4. All shipments of perforating guns approved using an AESC/IME Perforating Gun Specification must:

5.3.4.1. comply with the DOT’s shipping paper requirements found in 49 CFR 172,

Subpart C;. 5.3.4.2. comply with the DOT’s marking requirements found in 49 CFR 172,

Subpart D:


27

5.3.4.3. comply with the DOT’s labeling requirements found in 49 CFR 172, Subpart E; and

5.3.4.4. must comply with DOT placarding requirements found in 49 CFR 172, Subpart F.

5.3.5. All persons transporting or offering for transport perforating guns approved using

an AESC/IME Perforating Gun Specification must comply with the applicable portions of 49 CFR 172, Subparts G (Emergency Response Information), H (Training), and I (Safety and Security Plans).

28

This page is intentionally blank to facilitate 2-sided printing

29


Annex 1

AESC/IME Perforating Gun Specifications

(see next page)

30


Perforating Gun Specification

31

Ported Tube System (w/o Detonator) Version: 02 (9/1/2017)

Gun System Details

Min Max Size

Length (ft) 0.5 21 Diameter (in) 2.500 6

Perforators #/gun 1 81 Device NEW (g) 2 39 Perforating gun NEW (kg) 0.0020 3.1590

Detonating Cord ft/gun 0.5 26 Device NEW (g/ft) 3.89 5.18 Perforating gun NEW (kg) 0.0019 0.1347

Explosive Transfer Device (when present) (when present) #/gun 1 2 Device NEW (g) 0.3 2 Perforating gun NEW (kg) 0.0003 0.0040

Total Gun NEW (kg) 0.0042 3.2977 NEW = net explosive weight

Gun System Components

Label Component Comments A Gun body B Perforator C Detonating Cord D Explosive Transfer Device (explosive)

or Detcord End Seal (non-explosive) Optional Optional

E Alignment Plug & Sleeve F Lead Wire Optional

Notes:

1. Components B - D (explosive transfer device) must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.

2. Drawing is a typical representation depicting major components of the specified perforating gun system. Actual details may vary. Additional, non-explosive components may be present (for example: bull plugs, tandem subs, and/or alignment mechanisms). Drawing depicts a single gun. One or more guns may be connected together in tandem during transport.

3. here Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may be classed, marked, labeled, described, and transported as UN0494 (1.4D).

4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.

Dangerous Goods Information (as assigned by DOT): 5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to transport.

EX-Number: UN No:

Description:

Label:

As assigned by DOT UN0124 (See also Note 3)

JET PERFORATING GUNS, CHARGED

oil well, without detonator

1.1D (See also Note 3)

32


33

Tube & Strip System (w/o Detonator) Version: 02 (9/1/2017)

Gun System Details

Min Max Size

Length (ft) 1 31 Diameter (in) 1.375 5

Perforators #/gun 1 180 Device NEW (g) 1.5 32 Perforating gun NEW (kg) 0.0015 5.7600

Detonating Cord ft/gun 1 35 Device NEW (g/ft) 1.62 5.18 Perforating gun NEW (kg) 0.0016 0.1813

Explosive Transfer Devices (when present) (when present) #/gun 1 2 Device NEW (g) 0.3 2 Perforating gun NEW (kg) 0.0003 0.0040



Label Component Comments A Gun body B Perforator C Detonating Cord D Explosive Transfer Device (explosive)


E Lead Wire Optional F Carrier Strip Flat or Spiral

Notes:

1. Components B - D (explosive transfer device) must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.


3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may be classed, marked, labeled, described, and transported as UN0494 (1.4D).


5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to Dangerous Goods Information (as assigned by DOT): transport.

EX-Number: UN No:

Description:

Label:




1.1 D (See also Note 3)

34


35

Tube & Tube System (w/o Detonator) Version: 02 (9/1/2017)

Gun System Details

Min Max Size

Length (ft) 0.75 31 Diameter (in) 1.375 10






Label Component Comments A Gun body B Perforator C Detonating Cord D Carrier Tube E Explosive Transfer Device (explosive)


F Lead Wire Optional (not shown)

Notes:

1. Components B - C & E (explosive transfer device) must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.





EX-Number: UN No:

Description:

Label:




1.1 D (See also Note 3)

36


37

Strip Carrier System (w/o Detonator) Version: 02 (9/1/2017)

Gun System Details

Min Max Size

Length (ft) 1 24 Diameter (in) 1.375 3.5






Label Component Comments A Adapter Optional B Detonating Cord C Perforator D Carrier Strip Flat, Twisted, or Zig-Zag E Explosive Transfer Device (explosive)



Notes:

1. Components B - C & E (explosive transfer device) must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.

2. Drawing is a typical representation depicting major components of the specified perforating gun system. Actual details may vary. Additional, non-explosive components may be present (for example: bull plugs, tandem subs, and/or alignment mechanisms). Drawing depicts a single gun. One or more guns may be connected together in tandem during transport




EX-Number: UN No:

Description:

Label:

As assigned by DOT UN0124 (See also Note 3) JET PERFORATING GUNS, CHARGED

oil well, without detonator 1.1D (See also Note 3)

38


39

Wire Carrier System (w/o Detonator) Version: 02 (9/1/2017)

Dangerous Goods Information (as assigned by DOT):

Gun System Details

Min Max Size






Label Component Comments A Adapter Optional B Detonating Cord C Perforator D Carrier Wire Two or more E Detcord End Seal (non-explosive) Optional F Lead Wire Optional

Notes:

1. Components B - C must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.

2. Drawing is a typical representation depicting major components of the specified

perforating gun system. Actual details may vary. Additional, non-explosive components may be present (for example: bull plugs, tandem subs, and/or alignment mechanisms). Drawing depicts a single gun. One or more guns may be connected together in tandem during transport.

3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may

be classed, marked, labeled, described, and transported as UN0494 (1.4D).


5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to transport.

EX-Number: UN No:

Description:

Label:




1.1D (See also Note 3)

40


41

Link Carrier System (w/o Detonator) Version: 02 (9/1/2017)


Gun System Details

Min Max Size






Label Component Comments A Adapter Optional B Detonating Cord C Perforator D Charge Holder Two or more E Detcord End Seal (non-explosive) Optional F Lead Wire Optional

Notes:








EX-Number: UN No:

Description:

Label:



42


43

Swing Carrier System (w/o Detonator) Version: 02 (9/1/2017)


Gun System Details

Min Max Size



Detonating Cord ft/gun 1.8 25 Device NEW (g/ft) 2.59 3.89 Perforating gun NEW (kg) 0.0047 0.0973



Label Component Comments A Detcord End Seal (non-explosive) Optional B Detonating Cord C Perforator D Carrier

Notes:








EX-Number: UN No:

Description:

Label:



44


45

Perforating Gun Specification

Tube & Tube KodiakTM System (w/o Detonator) Version: 02 (9/1/2017)


Gun System Details

Min Max Size

Length (ft) 0.75 21 Diameter (in) 1.563 4.5




Kodiak Disks #/gun 1 60 Kodiak Disk NEW (g) 5.0000 110.0000 Perforating gun NEW (kg) 0.0050 6.6000



Label Component Comments A Gun body B Perforator C Detonating Cord D Carrier Tube E Explosive Transfer Device (explosive)



G Kodiak Disk See note 6

Notes:

1. Components B - C, E (explosive transfer device), & G must be DOT approved. See Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.



4. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to transport..

EX-Number: UN No: Description: Label:

As assigned by DOT UN0124 JET PERFORATING GUNS, CHARGED

oil well, without detonator 1.1D

5. Perforating guns approved pursuant to this specification are not eligible for shipment as 1.4D under Special Provision 114. 1.4D classification of perforating guns containing Kodiak™ Disks are subject to prior approval by the U.S. Department of Transportation.

6. Must be approved under EX2008040541.

46


47


Annex 2

PHMSA Approval of AESC/IME Specifications

This document may be retrieved from the following:

https://www.ime.org/uploads/public/PHMSA/PHMSAApprovalJPGStandard2017.09.01.pdf

http://www.ime.org/uploads/public/PHMSA/PHMSAApprovalJPGStandard2017.09.01.pdf

48


49


Annex 39

Text of Special Provision 114 of 49 CFR 172.102 (as of February 15, 2017)

114 Jet perforating guns, charged, oil well, without detonator may be reclassed to Division 1.4 Compatibility Group D (1.4D) if the following conditions are met:

a. The total weight of the explosive contents of the shaped charges assembled in the guns does not exceed 90.5 kg (200 pounds) per vehicle; and

b. The guns are packaged in accordance with Packing Method US 1 as specified in §173.62 of this subchapter.

9 This text is provided here as a convenience to the reader; however, the version published in the currently effective CFR is the version that applies to use of the AESC/IME Perforating Gun Specifications.

50


51


Annex 4

Text of Packing Method US 1 of 49 CFR 173.62 (as of February 15, 2017)10

1. A jet perforating gun, charged, oil well may be transported under the following conditions:

a. Initiation devices carried on the same motor vehicle or offshore supply vessel must be segregated; each kind from every other kind, and from any gun, tool or other supplies, unless approved in accordance with §173.56. Segregated initiation devices must be carried in a container having individual pockets for each such device or in a fully enclosed steel container lined with a non- sparking material. No more than two segregated initiation devices per gun may be carried on the same motor vehicle.

b. Each shaped charge affixed to the gun may not contain more than 112 g (4 ounces) of explosives.

c. Each shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal

cover after installation in the gun.

d. A jet perforating gun classed as 1.1D or 1.4D may be transported by highway by private or contract carriers engaged in oil well operations.

(i) A motor vehicle transporting a gun must have specially built racks or carrying cases designed

and constructed so that the gun is securely held in place during transportation and is not subject to damage by contact, one to the other or any other article or material carried in the vehicle; and

(ii) The assembled gun packed on the vehicle may not extend beyond the body of the motor vehicle.

e. A jet perforating gun classed as 1.4D may be transported by a private offshore supply vessel only

when the gun is carried in a motor vehicle as specified in paragraph (d) of this packing method or on offshore well tool pallets provided that:

(i) All the conditions specified in paragraphs (a), (b), and (c) of this packing method are met;

(ii) The total explosive contents do not exceed 90.8 kg (200 pounds) per tool pallet;

(iii) Each cargo vessel compartment may contain up to 90.8 kg (200 pounds) of explosive content

if the segregation requirements in §176.83(b) of this subchapter are met; and

10 This text is provided here as a convenience to the reader; however, the version published in the currently effective CFR is the version that applies to use of the AESC/IME Perforating Gun Specifications.

52

(iv) When more than one vehicle or tool pallet is stowed “on deck” a minimum horizontal separation of 3 m (9.8 feet) must be provided.

53

Guide to Obtaining DOT Approval of Jet Perforating Guns using

AESC/IME Perforating Gun Specifications

Annex 5

Example Application Format

(see next page)

54


55

Date Optional document ID

Associate Administrator for Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation Office of Approvals and Special Permits, PHH-32 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001

Subject: Approval Application – Perforating Gun System using AESC/IME Perforating Gun Specification (Ver. 02, Effective: 9/1/2017)

Dear Associate Administrator:

Application for an explosives approval as described below is submitted. In compliance with 49 CFR 107.705, the following information is provided:

49 CFR §173.51(a), §173.56(b)(1), and §173.58

EX-number to be assigned.

Applicant Name:

Applicant Mailing Address:

Contact Name:

Contact Phone Number:

Contact Fax Number:

Contact E-mail Address:

The product to be approved is described as (check only one entry and, if "Other" checked, fill in blank):

Please use Applicant Name (Section C) + System Name + Division (Section D) Other (please specify):

A. Section under which application is made

B. Approval, registration, or exemption number

C. Name, address, and telephone number of the applicant

D. Product Identification

56

Approval of the following AESC/IME Perforating Gun Specification Gun System (check only one entry):

Ported tube systems Tube & strip systems Tube & tube systems Strip carrier systems Wire carrier systems Link carrier systems Swing carrier systems

Tube & tube Kodiak™ system

Classification sought:

UN0124, 1.1D, Jet Perforating Guns, Charged, Oil Well

Consistent with current DOT policy.

Check all that apply:

Highway

Cargo-only Rail Vessel

By my signature below, I certify that I have reviewed the AESC/IME Perforating Gun Specification indicated in Section D above and confirm that my perforating gun system meets the graphical representation, the technical specifications, and compliance requirements contained thereon.

Sincerely,

Name Title

Attachments: AESC/IME Perforating Gun Specification (Ver. 02, Effective 7/31/2017)

E. System to be Approved and Classification Sought

F. Proposed duration of approval

G. Transport mode(s) affected

H. Certification

57

Appendix B

49 CFR 173.62 Specific Packaging Requirements for Explosives

US 1

1. A jet perforating gun, charged, oil well may be transported under the following conditions: a. Initiation devices carried on the same motor vehicle or offshore supply vessel must be

segregated; each kind from every other kind, and from any gun, tool or other supplies, unless approved in accordance with §173.56. Segregated initiation devices must be carried in a container having individual pockets for each such device or in a fully enclosed steel container lined with a non-sparking material. No more than two segregated initiation devices per gun may be carried on the same motor vehicle.

b. Each shaped charge affixed to the gun may not contain more than 112 g (4 ounces) of explosives.

c. Each shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal cover after installation in the gun.

d. A jet perforating gun classed as 1.1D or 1.4D may be transported by highway by private or contract carriers engaged in oil well operations. i. A motor vehicle transporting a gun must have specially built racks or carrying cases

designed and constructed so that the gun is securely held in place during transportation and is not subject to damage by contact, one to the other or any other article or material carried in the vehicle; and

ii. The assembled gun packed on the vehicle may not extend beyond the body of the motor vehicle

e. A jet perforating gun classed as 1.4D may be transported by a private offshore supply vessel only when the gun is carried in a motor vehicle as specified in paragraph (d) of this packing method or on offshore well tool pallets provided that i. All the conditions specified in paragraphs (a), (b), and (c) of this packing method are

met; ii. The total explosive contents do not exceed 90.8 kg (200 pounds) per tool pallet;

iii. Each cargo vessel compartment may contain up to 90.8 kg (200 pounds) of explosive content if the segregation requirements in §176.83(b) of this subchapter are met; and

iv. When more than one vehicle or tool pallet is stowed “on deck” a minimum horizontal separation of 3 m (9.8 feet) must be provided.

59

Appendix C US. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration

MAR 2 4 2015

Institute of Makers of Explosives 1120 Nineteenth Street, NW, Suite 300 Washington, DC 20036 Reference No.15-0023

Dear Ms. Hilton:

This is in response to your January 29, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging instruction US 1 in the Table of Packing Methods in § 173.62. You ask if the text "is not subject to damage by contact" is intended to prohibit any contact with other perforating guns or articles in the load or is only intended to prohibit contact that under conditions normally incident to transportation that could cause damage.

Packaging instruction US 1 only prohibits contact with other perforating guns or articles in the load that could cause damage. Mere contact between perforating guns is not a violation of US 1 (l)(d)(i) unless the contact allows for movement between the contacting guns that could cause damage by contact. Therefore, perforating guns that are touching, but that are appropriately secured for conditions normally incident to transportation, would be compliant with the requirements of US 1 (l)(d)(i).

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.

Sincerely, Duane Pfund

International Standards Coordinator Standards and Rulemaking Division

Safety Library Publications SLP Number

SLP Name Copyright Date

SLP 1 Construction Guide for Storage Magazines

October 2017

SLP 2 American Table of Distances June 1991 (Incorporates changes through April 2017)

SLP 3 Suggested Code of Regulations for the Manufacture, Transportation, Storage, Sale, Possession and Use of Explosive Materials

October 2015

SLP 4 Warning and Instructions for Consumers in Transporting, Storing, Handling and Using Explosive Materials

October 2016

SLP 12 Glossary of Commercial Explosives Industry Terms

March 2018

SLP 14 Handbook for the Transportation and Distribution of Explosive Materials

May 2013

SLP 17 Safety in the Transportation, Storage, Handling and Use of Explosive Materials

October 2015

SLP 20 Safety Guide for the Prevention of Radio Frequency Radiation Hazards in the Use of Commercial Electric Detonators (Blasting Caps)

December 2011

SLP 22 Recommendations for the Safe Transportation of Detonators in a Vehicle with Certain Other Explosive Materials

February 2007

SLP 23 Recommendations for the Transportation of Explosives, Division 1.5, Ammonium Nitrate Emulsions, Division 5.1, Combustible Liquids, Class 3, and Corrosives, Class 8 in Bulk Packaging

October 2011

SLP – 24 Recommendations for

Handling 50 Metric Tons or more of Commercial Division 1.1 or 1.2 Break-Bulk and Containerized Explosive Materials in Transportation at Commercial Waterfront Facilities in the United States

May 2011

SLP – 25 Explosives Manufacturing & Processing Guideline to Safety Training

October 2018

SLP – 27 Security in Manufacturing, Transportation, Storage and Use of Commercial Explosives

April 2012

SLP – 28 Recommendations for Accountability and Security of Bulk Explosives and Bulk Security Sensitive Materials

September 2007

SLP – 29 Recommendations for the Environmental Management of Commercial Explosives

October 2016

SLP – 30 Safe Handling of Solid Ammonium Nitrate

April 2017

SLP—31 Methods and Algorithms Used for Quantitative Risk Analysis

June 2018

SLP—32 Recommendations for Safe and Secure Use, Storage, and Transportation of Commercial Explosives in Oil and Gas Operations

October 2018

M4-11

The first time a registered image is loaded into the program, an image cache file is created the computer.

Image tiles can be easily loaded right into the program for future use.

Importing Site ImagesLoading a Registered Image Cache

IMESAFRInstitute of Makers of Explosives Safety Analysis for Risk

Why was IMESAFR developed?IMESAFR was developed

to provide a more comprehensive

assessment of the overall risk of explosives operations. The commercial explosives industry in the United States uses the American

Table of Distances (ATD) as the basis for

safe siting of explosives storage facilities. ATD siting

involves the evaluation of a specific magazine and inhabited building or public highway, which are referred to as a Potential Explosion Site (PES)/Exposed Site (ES) pair in IMESAFR. This evaluation yields the recommended separation distance based on the factors that affect risk, including whether a barricade exists. Although the same criteria can be applied to explosives manufacturing operations, the ATD was intended for use in limited permanent storage situations. In addition to permanent storage situations, IMESAFR accounts for other activities such as manufacturing, assembly, and loading and unloading.

What is IMESAFR?Institute of Makers of Explosives (IME) Safety Analysis for Risk (IMESAFR) is a software model that was developed through a joint effort by IME and A-P-T Research, Inc.

IMESAFR is a probabilistic risk assessment tool used to calculate risk to personnel from explosives facilities. This software not only calculates Quantity Distances (QD) based on the American Table of Distances and other QD regulations, it can determine a level of safety based upon risk.

M6-7

Risk drivers can control the overall risk at a site so it is important to determine what they are before spending time and money on mitigation efforts. Consider a hypothetical scenario with the consequences shown below:

Based on the bar chart above, what is the risk driver? What could be done to address the risk driver?Would removing all of the glass from the ES be effective?

Identifying Risk Drivers

1e-02

1e-04

1e-06

1e-08

1e-10

1e-12

DebrisOverpressure Glass Building Collapse

IMESAFR uses the donor structure and activity, the structure of the exposed sites, and duration of exposed personnel to determine a level of safety. The program provides users with the ability to work in metric or imperial measures, and allows users to import maps or drawings of their site to assist with visualizing facility layouts and results.

4950 Research Drive Huntsville, AL 35805

www.apt-research.com

1212 New York Avenue, NW, Suite 650 Washington, DC

202.429.9280 | www.ime.org

APT Point of Contact

Mary Robinson 256.327.3373

[email protected]

M-09-00810

IMESAFR Training Course The course is presented over three days with eight hours of mixed lecture and discussion each day for a total of 24 classroom hours. Daily class hours are from 8am to 5pm with an hour for lunch and breaks mid-morning and mid-afternoon. A competency test will be given at the end of the course.

Class Size: minimum of 10, maximum of 25.

WhereThe class is normally held at the APT Safety Engineering and Analysis Center (SEAC) in Huntsville, AL, conveniently located in Cummings’ Research Park near Redstone Arsenal. See www.apt-research.com/contacts/contactUs.html for detailed directions.

The class may also be offered at other locations. On-site training courses can be arranged, as well as courses that run in conjunction with conferences and meetings.

Course ContentThe IMESAFR Training Course will guide the user through the overall user interface of the IMESAFR Software. Some of the topics discussed are listed below.

� A background on the concepts and terminology used in the IMESAFR risk assessment software.

� A thorough guide on using input screens and choosing the proper input selection.

� A description of the capabilities of IMESAFR including menu options, functions of the tool bar, help menu and generating reports.

� An overview of the 26-step process used by IMESAFR to familiarize the user with the exposure and consequence analysis.

� Multiple examples (some worked individually and some as a group) demonstrating the various capabilities of IMESAFR.

� Practical applications of the software and its use in the risk management process.

Course Outline1. Overview2. QD Concepts & Background3. QRA Concepts & Background4. IMESAFR Features5. Class Exercise 16. Risk Management7. Advanced Tools8. Architecture - Part 19. Architecture - Part 210. IMESAFR Protocols11. Linking Architecture to Testing12. Class Exercise 213. Approval Process14. Input Decisions15. Group Exercise16. TestEach student is responsible for bringing a laptop to training. A training book is included in the course fee.

Schedulewww.apt-research.com/ capabilities/training.html

CEUUpon completion of this course, attendees will be credited with 2.0 Continuing Education Units (CEU).

CostIMESAFR v2.1 Training: US$1800

IMESAFR v2.1 Software: � Standard Price: US$1500 � IME member: US$750

Upgrade IMESAFR v : � Non IME member: US$750 � IME member: US$375

Registration InformationTo register for a class in Huntsville or if you are interested in setting up a training course at a location other than Huntsville, please contact:

Mary Robinson 256.327.3373 [email protected]

institute of makers of explosives

DESTRUCTION OF COMMERCIAL EXPLOSIVE MATERIALS At times it may be necessary to destroy commercial explosive materials. These may consist of explosives or blasting agents from containers that have been broken during transportation or may be materials that have exceeded their recommended shelf life or are believed to be overage or are no longer needed. Due to the many developments in explosive technology over the past few years, the appearance and characteristics of products have undergone marked changes. To be sure that you are familiar with the properties of the product that you plan to destroy, the manufacturer of that product should be consulted for the most current product information and the recommended method of disposal and/or destruction. The member companies of the Institute of Makers of Explosives have agreed to supply advice and assistance in destroying explosives. If the manufacturer is known, seek his assistance. If the manufacturer is not known, a member company of the Institute of Makers of Explosives may provide advice or assistance. The above policy of IME member companies relates only to commercial explosive materials. It does not include handling improvised explosive devices or bombs, military ordnance, military explosives, or homemade explosive materials. IME member companies also cannot become involved in destroying explosive materials, which have been used for illegal purposes, are reportedly stolen property or are considered as evidence in any potential civil litigation or criminal prosecution.

1212 New York Avenue, NWSuite 650

Washington, DCTel 202/429-9280Fax 202/293-2420

[email protected]