NASA Wallops Flight Facility — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 APR 7 0 2009 Mr. Ernest Cornwell NASA Wallops Flight Facility 32400 Fulton Street, Building M- 16 Room 107 Wallops Island, VA 23337 Ref. No.: 09-0022 Dear Mr. Comwell: This is in response to your letter dated January 23, 2009 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 17 1 - 1 80) applicable to the classification of explosives. In your letter you describe a parachute recovery system that uses reefing line cutters classed and approved by the Department of Transportation (DOT) as "Cutters, cable, explosive, 1.4S, UN0070." You ask if a reefing line cutter packed in the parachute recovery system may also be described as "Cutters, cable, explosive, UN0070, 1.4s.- The answer is no. A parachute recovery system with a previously approved reefing line cutter installed would be considered a new explosive under 5 173.56 and must be classed by DOT. In accordance with $ 173.56, a person requesting approval of a new explosive must submit to the Associate Administrator a report of the examination and assignment of a recommended shipping description, division, and compatibility group. If the Associate Administrator finds the approval request meets the regulatory criteria, the new explosive will be approved in writing and assigned an EX number. The Office of Hazardous Materials Approvals may be reached by telephone at (202) 366-45 1 1. I trust this satisfies your inquiry. If we can be of fiirther assistance, please contact us. Sincerely, h harles E. Betts f, Standards Development Office of Hazardous Materials Standards#

Page 2Page 1 of 2 Drakeford, Carolyn cPHMSA> - .-".-"".-..-* - - -**- " * - ---- --* " -- *- - From: INFOCNTR <PHMSA> Sent: To : Tuesday, January 27,2009 2:32 PM Dra keford, Carolyn <PHMSA> Subject: FW: REQUEST FOR CLARIFICATION OF IDENTIFICATION AND PACKAGING OF LIN0070 CUTTERS, CABLE, EXPLOSIVE, WITH WRITTEN REPLY From: Cornwell Ernest [mailto:Cornwell~Ernest@nsroc.net] Sent: Friday, January 23, 2009 2:23 PM To: INFOCNTR <PHMSA> Cc: Shreves Christopher Subject: REQUEST FOR CLARIFICATION OF IDENTIFICATION AND PACKAGING OF UN0070 CUlTERS, CABLE, EXPLOSIVE, WITH WRITEN REPLY January 23,2009 Completed via email by RE3 on 1/26 @ 12:47 pm From: Mr. Ernest R. Cornwell, Logistics Program Analyst NASA Wallops Flight Facility 32400 Fulton Street, Building M-16 Room 107 Wallops Island, Virginia 23337 SUBJECT: UN0070 CUTTERS, CABLE, EXPLOSIVE, 1.4S, when packaged in a recovery system NASA Wallops Flight Facility, Wallops Island, Virginia, uses parachute recovery systems for recovery of payloads. Normally these systems use reefing line cutters, identified through Department of Transportation as the subject LJN ID 0070. Each specific cutter is identified with EX number, Competent Authority Approval, as well as MSDS. When transporting these systems, each of the cognizant authorities understands the shipment of 1.4s in approved UN Certified Containers. When containers are purchased, it is specified that the material to be packaged will be explosive, 1.4 series (the containers will also be used to ship explosive 1.4 material in a host of UN identified numbers (i.e. UN0323, UN0276, UN0173, etc.). The regulations and requirements for packaging this material identifies the hazardous material to be packaged. The assembly is incidental. For Example: 1. DOMESTIC. U.S. Department of Transportation, provides identification, packaging, and shipment as follows, for UN0070 Cutters, Cable, Explosive, 1.4S, PGII (retrieved online 01/23/2009 from: htt~!edocket._a_c.ces_s~g~o~~.v!.cfr~Z.003!ocf.~~r!4Ucfr.~~73.~62.~1!tm~ 49CFR173.62, SPECIFIC PACKAGING REQUIREMENTS FOR EXPLOSIVES, PI 134: Inner packagings (1 1 varieties) including plastic bags. Intermediate packagings not required. The outer packaging (1 3 varieties) includes 4C1,4C2 Wooden Packages, and 4G Fiberboard packages.#

Page 3Page 2 of 2 49CFR173.6l(a), MUlED PACKAGING REQUIREMENTS, (http.:l!e~.~c~.~t,~~.cesst.gp.~ . go~~!.cf~ ...... Q03!.~.c~.qt~!49.~frl,7~..,6!..,~i~n states "An explosive may not be packed in the same outside packaging with any other material that could, under normal conditions of transportation, adversely affect the explosive or its packaging unless packaged by DOD or DOE in accordance with Sec. 173.7(a)." The parachute recovery system is engineered such that the explosive article is surrounded by sufficient cushioning material (parachute fabric), and enclosed in static plastic, to absorb shock and to prevent function of the device during 4G (Gravity Pressure) Rocket Launches. Therefore, the explosive or its packing cannot be adversely affected under normal conditions of transportation. 2. COMMERCIAL AIR. International Air Transportation Association (IATA), in the 5oth edition Dangerous Goods Regulations, provides identification, packaging, and shipment as follows, for UN0070 Cutters, Cable, Explosive, 1.4s: Table 4.2 (pg180) UNIID No., Proper shipping name, Class, as listed above. Padcargo Packaging Instruction 134, Maximum Net QtyIPkg 25 Kilograms Cargo Aircraft Only Packaging Instruction 134, Maximum Net QtyiPkg 100 Kilograms In the identification paragraph, 4.1.6.8 Column H, the "maximum net quantity (weight or volume) of the article or substance allowed in each package for transport on a passenger or cargo aircraft. The weight quoted is the net weight.. ." Packaging Instruction 134 (pg 345), subject to State and Operator Variations, provides specific packaging instructions for the cutters. Inner Packagings are described, including Plastic or Paper Bags. Intermediate Packaging is not required. Combination Packagings are allowed and identified, and, most importantly, Outer packaging is described with specific Certification Identifiers, including: 4C1,4C2 Wooden Packages, and 4G Fiberboard packages. Question: Does the UN family of UN0070 Cutters, Cable, Explosive, 1.4S, when in packaged and protected in certified parachute recovery systems, can be identified, packaged, marked, labeled, documented, and transported as UN0070. Ernest R. Cornwell#