Textron Systems Corporation — Hazardous Materials Safety Interpretation

Page 1S. Departmer 400 Seventh Street. S.W. Transportatio Washington, D.C. 20590 Research and Special Programs administratior APR | 9 2000 Mr. William Porter Ref. No. 00-0056 Textron Systems Corporation 201 Lowell Street Wilmington, MA 01887-2941 Dear Mr. Porter: This is in response to your letter dated February 17, 2000, regarding the segregation requirements for Class 1 (explosive) materials on a transport vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked whether explosives products, "Gas Generator, 1.4C", "Gas Generator/Initiator, 1.4G", and "Smoke Sublet, 1.4B", having a total weight of no more than 18 grams per shipment, may be transported on the same motor vehicle. If not, how can such explosives be transported on the same motor vehicle and not be in violation of the regulations? The explosives described as "Gas Generator, 1.4C", "Gas Generator/Initiator, 1.4G" and "Smoke Sublet, 1.4B" may not be loaded or transported together, except as provided in the "Compatibility Table for Class 1 (Explosive) Materials", in § 177.848(f), which, depending on the combination of explosives and their compatibility groups, may require use of separate vehicles. Except for fireworks and explosive articles requiring special stowage, and provided no explosive substances are carried in the same motor vehicle, explosive articles in compatibility group "G" may be transported in the same motor vehicle with explosive articles in compatibility group "C" (§ 177.848(f)(3)(vi)). An explosive substance is a material which meets the definition of an explosive artridge for weapons. 000056 177,848#

Page 2• You may wish to apply for an exemption from the regulations. The requirements for applying for an exemption are found in § 107.105. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, amn Religo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3FEB 17 2000 15:35 FR TEXTRON 508 657 2391 TO 92023663012 P.02/03 • . TEXTRON Systems Division extron Systems Divisio absidiary of Textron Ir Wilmington, MA 01887-2941 201 Lowell Strest To: Office of Hazardous Materials Transportation Research and Special Programs Administration Att: Edward Mazzullo Phone: 202-366-4488 Telecopier: 202-366-3012 From: William Porter PSHT/Explosive Safety Engineer Mailstop: 3213 Phone: 978-657-1278 Telecopier: 978-657-2391 Date: February 17, 2000 Subject: Transportation of Explosives Wide Area Muritions (WAM) Reference: CFR 49, PARA(s) 177.848, Compatibility Table for Class 1 (Explosive) Material Background: - Textron Systems Corporation (TSC) is a defense contractor (building/testing/ explosive products) for USA/SN/USAF. - TSC must transport the following munition components from Wilmington, Massachusetts to Ft. Devens, Massachusetts (10 miles) Product Name Part No. Explosive Material Elazardous I COE/REF Gas Generator 12908056 Class NR Gas Generator/initiator 12908055 BKNO3/propellant /M-36/7.34g. 1.4C BX-9105240 ZPP/.130g Smoke Sublet 19386382 /EO100044-1**/ZPP/.189g 1.4G EX-9105239 1.4B EX-9808210 ** Mixture(s) plus ZPP * Zirconium potassium perchlorate - All products are packaged /labeled per CFR 49 and are being transported in. three (3) separate vehicles.#

Page 4FEB 17 2000 15:35 FR TEXTRON 508 657 2391 TO 92023563012 P.Ø3/Ø3 ... Office of Hazardous Materials Transportation Page 2 Request Your Assistance 1. Do we really need three (3) vehicles to transport Class 1.4 explosives? 2. We are presently only transporting; one (1) or two (2) of these items with a total explosive weight of no more than 18g per shipment. 3. Do you know of anyway we can legally transport the above products together? 4. In our review of Compatibility Table (reference) for Class 1, we noted that compatibility Group G is compatible with C per Item 6. Is this true? If additional information is required, please feel free to contact me at 978-657-1278 or fax at 978-657-2391. Thank you for your assistance in this matter. Date out William Porter PHST/Safety ** TOTAL PAGE.03 **__#