General Dynamics - OTS — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration MAY 26 2004 Mr. John Wells Ref. No. 04-0113 Environmental Specialist General Dynamics - OTS Environmental and Regulatory Compliance 8820 Route 148 South Marion, IL 62959 Dear Mr. Wells: This is in response to your letter dated April 29, 2004 regarding the shipment of 30 millimeter primed ammunition cases for laboratory testing under the requirements of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). You state that each case has a 0.25 inch hole drilled in its sidewall and contains an empty flash tube and no propellent. Additionally, an inert projectile will be crimped into each case. You would like to know if the EX number assigned to the primed case would still be appropriate for your shipment and if Special Provision 50 would still apply. It is our opinion that by drilling a hole in the side of a shell casing and crimping an inert projectile into the neck of the case you are not changing the classification of the explosive. Therefore, according to the information you provided, the EX number assigned to a primed case would still be accurate for your casings. According to Special Provision 50 a material classed as "Cases, cartridge, empty with primer" that is constructed of metal or plastic and meets the classification criteria of Division 1.4 is not regulated for domestic transportation. From the information you provided, it is our opinion that your casings meet Special Provision 50 and, therefore, are not regulated for domestic transportation. I hope this satisfies your request. Sincerely Office of Hazardous Materials Standards 173:56 173.59 040113#

Page 2Apr-29-2004 09:29 From-GENERAL DYNAMICS +6189939495 T-757 P.001/001 F-258 GENERAL • DYNAMICS Ordnance and Tactical Systems Supko April 29, 2004 §173.56 U.S. Department of Transportation Mr. Edward Mazzullo, Director 173.59 Office of Hazardous Materials Standards DHM-10 Explosives Washington, DC 20590-0001 400 Seventh Street, S.W. 04-0113 202-366-3012 FAX 202-366-8553 Subject: Request for Clarification Reference: 49 CFR 173.56, 173.59, 172.102 special provision #50 Dear Mr. Mazzullo: General Dynamics, OTS, Marion, is requesting a letter of interpretation. General Dynamics has a need to ship some 30MM primed cases to a laboratory for testing purposes. • There is no propellant in this item. There is an empty flash tube in this item. : The emply case will have one hole drilled in the side. The hole diameter is 0.25 inches. An inert projectile will be crimped to the case. There is no tracer or explosives in the projecrile. Our questions are: 1. 2. If not, would these items need a separate EX number or would they fall under the EX number Would these items still be considered unregulated for domestic transportation? already assigned to the primed case? Regards, : John Wells Envirorimental Specialist General Dynamics - OTS John Wells, Environmental Specialist Environmental and Regulatory Compliance Marion, IL 62959 8820 Route 148 South, Tel 618-993-8511 Fax 618-993-9495#