UTRON Kinetics, LLC — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration JUN 2 5 2014 Ms. Tesa Bell Production Manager UTRON Kinetics, LLC 9441 Innovation Drive Manassas, VA 20110 Ref. No.: 14-0105 Dear Ms. Bell, This is in response to your May 27, 2014 letter requesting clarification on the proper classification of a fabricated product containing zinc, zirconium and tungsten under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). According to your letter, zirconium is a Class 4 reactive material when in a powder form. However, the process of fabricating the product into a solid state renders the material safe for handling. You have provided laboratory test results that indicate the fabricated product does not meet the definition of a Class 4 material. Specifically, you are requesting confirmation that your product is not subject to the requirements of the HMR when in a solid, compact state. In accordance with § 173.22, it is the shipper's responsibility to properly classify a hazardous material. This Office generally does not perform this function. However, based on the test data you provided, we agree that your fabricated product does not meet the definition of a Class 4 material. Therefore, if your company's product does not meet any other hazard class definition in Part 173, and is not a hazardous substance, hazardous waste, or marine pollutant, it is not subject to the HMR. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely ran M. Wim - for Shane C. Kelley Acting International Standards Coordinator Standards and Rulemaking Division#

Page 2Wiener UTRON 8171. 1 $172:101 Applicability May 27, 2014 14-0105 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Office of Hazardous Material Safety 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Request for Interpretation Letter Dear Sir: UTRON Kinetics, LLC ("UTRON") is a compacted-powder parts manufacturing company that specializes in parts that have specific, and often unique, characteristics. UTRON has developed a product for use in While the zirconium is a reactive material in its powder form, the process of fabricating this part into a solid Department of Defense Applications that is a combination of three materials: zinc, zirconium and tungsten. state renders the material safe for handling. the tests listed in the table below to determine if the Hazardous Materials Regulations contained in HMR: 49 At the advice of the Department of Transportation: Office of Hazardous Material Safety, UTRON conducted CFR Parts 171-180 are applicable to this product. Complete test results are attached for review and consideration. Test / Parameter Result Burn Rate Test (DOT/UN Test N.1) Not a readily combustible substance of Division 4.1 Self-Heating Substances Test (DOT/UN Test N.4) Not a self-heating substance of Division 4.2 Dangerous When Wet - Hazmat Label Substance is not dangerous when wet All tests returned a result indicative of material not subject to the Hazardous Materials Regulations referenced above. Accordingly, UTRON respectfully requests an interpretation that the Hazardous Materials Regulations do not apply to the packaging and transportation of this product when in a solid, compacted state. If you require any additional information to process this request, please contact Tesa Bell (tesab@utronkinetics.com) or Kevin McMahon (kevinm@utronkinetics.com) at (703) 369-5552. Respectfully submitted, Tesa Bell Production Manager UTRON Kinetics, LLC Phone: (703) 369-5552 9441 Innovation Drive Manassas, VA 20110 Fax: (703) 369-5298 0x000.7:s#

Page 3Drakeford, Carolyn (PHMSA) Sent: From: Dodd, Alice (PHMSA) Subject: To: Wednesday, May 28, 2014 11:49 AM Drakeford, Carolyn (PHMSA) Attachments: How to UNZIP.html; SecureZIP Attachments.zip FW: Request for Written Interpretation Carolyn can you assign this pls From: Tesa Bell [mailto:tesab@utronkinetics.com] Sent: Wednesday, May 28, 2014 9:55 AM To: Hazmat Interps Cc: kevinm@utronkinetics.com Subject: Request for Written Interpretation Dear Sirs: Attached for your review is a request for written interpretation of the applicability of Hazardous Materials Regulations to the packaging and shipping of our product. We thank you in advance for your consideration of this request. Regards, Tesa Bell Tesa Bell Production Manager UTRON Kinetics, LLC (703) 369-5552#

Page 49441 Innovation Drive Manassas, VA 20110 (703) 369-5552 Summary of Hazmat Testing of TZZ Cubes Testing conducted by: DEKRA / Chilworth Technology, Inc. and UTRON Kinetics, LLC Burning Rate Test Results - Fire Train Test Data (Conducted by Chilworth 4/5/14) Test Purpose: To determine the burning rate of any substance that can be ignited. Ignition Source: Flame or hot wire (above 1000°C) Results: Not a readily combustible substance of Division 4.1. Six separate trials all yielded the result of "sample did not ignite upon application of ignition source" Self-Heating Solids Testing (U.N. Division 4.2) - 140°C Temperature (Conducted by Chilworth 415/14) Test Purpose: U.N./DOT Classification for transport purposes with respect to self-heating Sample size: solids. Temperature: 4100 grams 140°C Results: Not self-heating substance of Division 4.2. No exothermic reaction was observed during the test. Dangerous When Wet - Hazmat label (Conducted by Utron Kinetics, 5/13/14-5/15/14) Test Purpose: To determine the consequences of a substance submersed in water over time. Three 8mm cubes submersed in a medium. Results: appearance or color. Substance is NOT dangerous when wet. No change in cubes geometry, No change in temperature of the water over the course of the 48 hour test. TZZ cube components: tungsten, zinc and zirconium TZZ Cubes Other Properties: Non Radioactive Not an Oxidizer Not Liquid Not Toxic Not a Gas lisabel 5/27114 UTRON Kinetics, LLC Date Attachments: Test Results from Chilworth Technology and UTRON Kinetics, LLC#

Page 5> DEKRA Client Utron Kinetics, LLG Contact Mr. Kevin R. McMahon Report issue date April 18, 2014 Report number UT14978RP TZZ 8mm CUBES DOT/UN Department of Transportation Flammability Testing Reviewed By UCeeu Da: Viste Granate Approved By .... .... Yuan Dai Don B. Churchwell Senior Laboratory Specialist Laboratory Manager Quote / Job Numbers: 23030 / 14978 Report prepared by R. Hammer © 2014, Chilworth Technology, Inc. The Ciwoal Experts ingy plosion & Process Safey 113 Campus Drive 609 799 5559฿ 509 799 4449 17 rinceton, NJ 0854( Chilworth Inited States Safey usa@chiv.chitwora.com/w a DEKRA company#

Page 6CONTENTS Page Introduction 1 Summary of Results 2 Flammability of Solids - Burning Rate 3 Self-Heating Solids 6 Appendix 11#

Page 7The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. > DEKRA Utron Kinetics, LLC Report Number: UT14978RP Page 1 of 11 INTRODUCTION This report presents the results of DOT/UN Department of Transportation flammability measurements performed on your TZZ 8mm CUBES sample. The results are summarized in Table 1 on the following page. The report includes a description of the test procedures and an interpretation of the results. Chilworth Technology is experienced in providing specific advice in the areas of dust explosion prevention and control, electrostatics, thermal stability and chemical reaction hazards. Site visits to discuss operational safety or to perform plant inspection and measurements can be arranged. Name and address of client: Mr. Kevin R. McMahon Utron Kinetics, LLC 9441 Innovation Drive Manassas, VA 20110#

Page 8The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. > DEKRA Utron Kinetics, LLC Page 2 of 11 Report Number: UT14978RP TABLE 1 SUMMARY OF TEST RESULTS For Test Sample: TZZ 8mm CUBES Parameter Test Results Burn Rate Test (DOT/UN Test N.1) Not a readily combustible substance of Division 4.1 Self-Heating Substances Test- Not classified as a (DOT/UN Test N.4) self-heating substance of Division 4.2 Note: The results given in this report apply to the sample tested. Changes in composition, particle size, and moisture content may affect the results.#

Page 9he Global Experts in Explosion & Process Safet hilworth Technology, In Utron Kinetics, LLC Page 3 of 11 Report Number: UT14978RP BURNING RATE TEST MEASUREMENT RESULTS AND INTERPRETATION FOR TZZ 8mm CUBES FOR AND ON BEHALF OF CHILWORTH TECHNOLOGY, INC.#

Page 10Chilworth Technology, Inc. The Global Experts in Explosion & Process Safety > DEKRA Utron Kinetics, LLC Page 4 of 11 Report Number: UT14978RP FLAMMABILITY OF SOLIDS BURNING RATE TEST (FIRE TRAIN TEST) Test Method This test is designed to meet the specification of the following documents: EEC Directive 79/831 ANNEX Part A. Methods for the Determination of Physico-Chemical Properties 3.10 Flammability of Solids. The United Nations Document, Recommendations on the Transport of Dangerous Goods (in part only). 3. HSE Code of Physico-Chemical Properties 1982. 4. D.O.T. ref 49CFR, Section 173, App. E Purpose The Fire Train Test is designed to measure the rate at which combustion moves away from an ignition source, along a 250mm train of powder. Fire or combustion properties are required to assess the type and magnitude of any fire risk associated with a powder. Measurement Method for the Fire Train Test The fundamental chemical mechanisms of combustion are complex and furthermore chemical mechanisms can be markedly affected by physical characteristics (e.g. particle size and packing density). 10mm and width 20mm. The powder as supplied is filled into a mould 250mm long with a triangular cross section of height After tapping the mould, to settle down the powder, it is inverted onto an impervious non- (flame or hot wire above 1000°C) is placed at one end of the powder train for 2 minutes (5 minutes combustible plate of low thermal conductivity. The mould is removed and the ignition source for powders of metals or metal alloy) or until the powder ignites. When the sample has burned a distance of 80mm the rate of burning over the next 100mm is measured. The test is repeated six times using a cool clean plate each time unless a positive result is obtained earlier. If a positive result is obtained with non-metallic powders, one ml of a wetting solution is applied to the train beyond the timed zone. Whether or not the wetted zone stops the propagation of the flame determines the packing group of the material.#

Page 11The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. > DEKRA Utron Kinetics, LLC Page 5 of 11 Report Number: UT14978RP FIRE TRAIN TEST DATA BURNING RATE TEST RESULTS Powder Information Test Sample Company Name TZZ 8mm CUBES UTRON KINETICS, LLC Ref. No. Origin of the Sample N/A N/A Size Information Comment Sample tested as received Gray metal square Test Information Test Purpose : To determine the burning rate of any substance that can be Apparatus ignited. : (20mm wide x 10mm high). Fire train mould (250mm long) with triangular cross section Ignition Source Flame or hot wire (above 1000°C). Date of Test 04.05.14 Operator A. Gangu Results Classification of Substance : Division 4.1. Not a readily combustible substance of Rate of Burning (over 100mm) : N/A Trial No. Burning Time Comments (seconds) 1 N/A Sample did not ignite upon application of ignition source 2 N/A source Sample did not ignite upon application of ignition 3 N/A source Sample did not ignite upon application of ignition 4 N/A source Sample did not ignite upon application of ignition 5 N/A source Sample did not ignite upon application of ignition 6 N/A Sample did not ignite upon application of ignition source#

Page 12le Global Experts in Explosion & Process Safe lilworth Technology, I > DEKRA Utron Kinetics, LL.C Page 6 of 11 Report Number: UT14978RP SELF-HEATING SOLIDS MEASUREMENT RESULTS AND INTERPRETATION FOR TZZ 8mm CUBES FOR AND ON BEHALF OF CHILWORTH TECHNOLOGY, INC.#

Page 13Chilworth Technology, Inc The Global Experts in Explosion & Process Safet DEKRA Report Number: UT14978RP Utron Kinetics, LLC Page 7 of 11 SELF-HEATING SOLIDS Test Standard Test performed according to section 14.5.5 United Nations Recommendations on the Transportation of Dangerous Goods test method for self-heating solids. Test Method A hot air circulating oven with a volume of greater than 9 liters is used. Cubic sample containers of 25 mm and 100 mm side made of stainless steel 0.053 mm mesh is used. Each container is housed in a cubic container cover made from stainless steel 0.595 mm mesh and slightly larger than the sample container, so that the container fits in this cover. In order to avoid the effect of air circulation, another stainless steel cage, made from 0.595 mm mesh and 150 x 150 x 250mm in size, is further installed to house the cover. Continuous temperature measurement is made using Chromel-Alumel thermocouples. The oven temperature is raised to 140°C and kept there for 24 hours. The first test is conducted with a 100mm cube sample. Observations are made to determine if spontaneous ignition occurs or if the temperature of the sample exceeds 200°C. If negative results are obtained no further test is necessary. If positive results are obtained a second test should be conducted with a 25mm cube. the material is to be transported in packagings of more than 450 liter volume and less than 3 m?, or If the test is negative in the 25mm cube, another test is performed in the 100mm cube at 120°C if tested in a 100mm cube at 100°C if the material is to be transported in packagings of less than 450 liter volume. Criterion for classification A substance should not be classified in Division 4.2 if: (a) A negative result is obtained in a test using a 100mm cube sample at 140°C. (b) A positive result is obtained in a test using a 100 mm sample cube at 140°C and a negative result is obtained in a test using 25 mm cube sample at 140°, a negative result is obtained in a test using a 100mm cube sample at 120°C and the substance is to be transported in packages with a volume not more than 3 m?. (c) A positive result is obtained in a test using a 100 mm sample cube at 140°C and a negative result is obtained in a test using a 25 mm cube sample at 140°C, a negative result is obtained in a test using a 100mm cube sample at 100°C and the substance is to be transported in packages with a volume not more than 450 liters.#

Page 14The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. → DEKRA Utron Kinetics, LLC Report Number: UT14978RP Page 8 of 11 Packing Group I! should be assigned to self-heating substances, which give a positive result in a test using a 25mm sample cube at 140°C. Packing Group Ill should be assigned to self-heating substances if: (a) A positive result is obtained in a test using a 100 mm cube at 140°C and a negative result is obtained in a test using a 25mm cube sample at 140°C and the substance is to be transported in packages with a volume of more than 3 m?. A positive result is obtained in a test using a 100 mm sample cube at 140°C and a negative in a test using a 100mm cube sample at 120°C and the substance is to be transported in result is obtained in a test using a 25 mm cube sample at 140°, a positive results obtained packages with a volume of more than 450 liters. (c) A positive result is obtained in a test using a 100mm sample cube at 140°C and a negative result is obtained in a test using a 25mm cube sample at 140°C and a positive result is obtained in a test using a 100mm cube sample at 100°C. Results The results follow on the next page.#

Page 15The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. → DEKRA eport Number: UT14978R tron Kinetics, LI Page 9 of 11 SELF-HEATING SOLIDS TESTING (U.N. Division 4.2) - AT 140°C TEMPERATURE Sample Information Company Name Ref. No. Test Sample : UTRON KINETICS, LLC TZZ 8mm CUBES Origin of the Sample N/A Size Information N/A Comment Sample tested as received Gray metal square Test information Test purpose : U.N./DOT Classification for transport purposes with respect Apparatus Type : to self-heating solids. Hot air circulation oven with an inner volume of >9 liters, Cubic stainless steel mesh containers Sample Mass Basket Size : 4100.0 g Date of Test 100 mm at 140°C Operator : 04.15.14 Y. Dai Results: Not self-heating substance of Division 4.2 Comment: No exothermic reaction was observed during the test.#

Page 16hilworth Technology, In he Global Experts in Explosion & Process Safet → DEKRA Utron Kinetics, LLC Page 10 of 11 Report Number: UT14978RP 100mm Basket Test - Isothermal at 140°C 800 Utron Kinetics, LLC - TZZ 8mm Cubes 700 Temperature (°C) - Oven Temp — Sample Temp 200 100 120 240 360 480 600 720 840 960 1080 1200 • 1320 1440 Time (minutes)#

Page 17The Global Experts in Explosion & Process Safety Chilworth Technology, Inc. DEKRA Report Number: UT14978RP Utron Kinetics, LLC Page 11 of 11 APPENDIX Legal Disclaimer and Liability Limitation of Liability. The test procedures and/or consulting services conducted by Chilworth Technology (the "Company") were performed under controlled laboratory conditions, which the Company considers reliable. Although the Company performed its testing services pursuant to reliable and generally accepted testing procedures in the industry, the Company does not guarantee or provide any representations or warranties with respect to Client's use, interpretation or application of the ne testing procedures are based upon certain assumptions, information, documents, ar est results and/or consulting services provided by the Company. Moreover, the results c procedures provided by the Customer. AS SUCH, IN NO EVENT AND UNDER NO CIRCUMSTANCE SHALL THE COMPANY BE LIABLE FOR SPECIAL, INDIRECT, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY NATURE WHATSOEVER INCLUDING WITHOUT LIMITATION, ANY LOST REVENUE OR PROFITS OF THE CUSTOMER OR ITS CUSTOMERS, AGENTS AND DISTRIBUTORS, RESULTING FROM, COMPANY OR THE RESULTS OF ANY TESTS PERFORMED BY THE COMPANY. The ARISING OUT OF OR IN CONNECTION WITH, THE SERVICES PROVIDED BY THE Customer agrees that the Company shall have no liability for damages, which may result from Client's use, interpretation or application of the test results and/or consulting services provided by the Company. The Company's pricing of the testing services provided does not contemplate that the Company shall have any liability resulting from its performance of the testing procedures, except as otherwise set forth in the Quotation from the Company. Accordingly, the Customer shall indemnify and hold harmless the Company, its shareholders, directors, officers, employees and agents (the "Indemnified Parties") from and against any and all loss, cost, liability and expense, including reasonable attorney's fees and costs, which any of the Indemnified Parties may incur, sustain or be subject to, as a result of any claim, demand, action, investigation or proceeding arising out of or relating to either: (a) the testing services provided by the Company; or (b) any material, equipment should have been supplied to the Company) by Customer and/or any failure of suct specifications or safety information (or lack thereof) supplied to the Company (or which or local law or safety standard. materials, equipment, specifications and safety information to comply with any federal, state of this report, see the Quotation provided by the Company and executed by Customer. If (c) For additional terms and conditions, which apply with respect to the provision forth herein shall apply. any terms set forth in the Quotation conflict with the terms set forth herein, the terms set#

Page 18UTRON TZZ DTRA Cubes in Water Kinetics Record of Observations and water temperature for three 8mm TZZ cubes in 500 mls of water over 48 hour period. Date of Test: May 13 - 15, 2014 Test Location: UTRON Kinetics VA Facility, Manassas, VA 20110 Test Technician: Kevin McMahon Time of Day Technician Initials Test Date Observation Temperature (°F) Water 1:50 PM KRM 05/13/14 First submersed - no reaction - 2 small bubbles (probably porosity) 77 2:00 PM KRM 05/13/14 no reaction 76 2:20 PM 05/13/14 no reaction 76 2:40 PM 05/13/14 no reaction 17 3:15 PM 05/13/14 3:37 PM no reaction 05/13/14 no reaction 76 4:20 PM 05/13/14 no reaction 78 5:00 PM 05/13/14 no reaction 79 5:55 PM 05/13/14 no reaction 79 6:36 AM 05/14/14 no reaction 71 7:23 AM 05/14/14 no reaction, cubes are intact 71 8:31 AM 05/14/14 no reaction 72 9:12 AM| 05/14/14 no reaction, cubes look the same as start of test 72 10:06 AM 05/14/14 no reaction 72 10:37 AM 05/14/14 no reaction 72 12:00 PM 05/14/14 no reaction 72 1:22 PM 05/14/14 no reaction 72 2:14 PM 05/14/14 no reaction 72 2:40 PM 05/14/14 no reaction 72 3:25 PM 05/14/14 no reaction 72#

Page 19UTRON IZZ DTRA Cubes in Water Kinetics Record of Observations and water temperature for three 8mm TZZ cubes in 500 mls of water over 48 hour period. Date of Test: May 13 - 15, 2014 Test Technician: Kevin McMahon Test Location: UTRON Kinetics VA Facility, Manassas, VA 20110 Time of Day Technician Initials Test Date Observation Temperature (°F) Water 5:20 PM| 4:20 PM CA CA 05/14/14 no reaction no reaction 74 6:10 PM CA 05/14/14 05/14/14 74 6:33 AM| 7:45 AM KRM KRM 05/15/14 05/15/14 no reaction no reaction 72 70 10:25 AM| 11:15 AM KRM no reaction 70 KRM 05/15/14 12:05 PM 05/15/14 no reaction 74 no reaction 74 1:05 PM CA CA 05/15/14 1:10 PM| KRM 05/15/14 05/15/14 no reaction 74 no reaction 74 2:05 PM KRM 05/15/14 no reaction 75 no reaction 75#