Hunting Titan — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 June 30, 2021 Mr. Joseph Murphy Hunting Titan 16825 Northchase Drive, Ste. 600 Houston, TX 77060 Reference No. 21-0013 Dear Mr. Murphy: This letter is in response to your February 8, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to special provision 114 for “UN0494, Jet perforating guns, charged, oil well, without detonator.” In your letter, you note that—as provided by Special Provision 114 in § 172.102(c)(1)—jet perforating guns may be reclassed to Division 1.4 Compatibility Group D (1.4D) if: (1) 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 (2) the guns are packaged in accordance with Packing Method US 1 as specified in § 173.62. You state that your company would like to transport jet perforating guns containing 400 pounds of explosive contents on two separate “vehicles” in a single shipment. Your proposed configuration consists of 200 pounds of explosive contents on a truck, with an additional 200 pounds of explosive contents on a flatbed trailer attached to the truck. You ask whether this proposed configuration complies with the HMR and whether the term “vehicle”—as used in Special Provision 114—refers to “transport vehicle” or “motor vehicle” as defined in § 171.8. The answer is no, your proposed configuration does not comply with the HMR. It is the opinion of this Office that the word “vehicle” as used in Special Provision 114 of § 172.102(c)(1) refers to the term “motor vehicle” as defined in § 171.8. Specifically, a “motor vehicle” means “a vehicle, machine, tractor, trailer, or semitrailer, or any combination thereof, propelled or drawn by mechanical power and used upon the highways in the transportation of passengers or property.”#

Page 2Therefore, a shipment of more than 200 pounds of explosive content would not be authorized on a single motor vehicle. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3WOLCOTT From: INFOCNTR (PHMSA) To: Subject: Date: Attachments: Dodd, Alice (PHMSA); Hazmat Interps FW: Letter of Interpretation Request - Hunting Titan, Inc. Tuesday, February 9, 2021 2:50:04 PM Hunting Titan Letter of Interpretation Request.pdf 21-0013 Dear Alice, Please see the attached request for a letter of interpretation. Please contact our office with any questions. Thank you, Sarah (HMIC) From: Joe Murphy [mailto:Joe.Murphy@Hunting-intl.com] Sent: Monday, February 8, 2021 7:32 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Letter of Interpretation Request - Hunting Titan, Inc. CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. To whom it may concern, Please see attached Letter of Interpretation request from Hunting Titan, Inc. Regards, Joseph Murphy - Compliance Manager / Distribution Center HSE Hunting Titan, Inc. 16825 Northchase Dr. Suite 600 Houston,TX 77060 Office: 281-214-4500 Cell: 346-302-1607 WIPE surfaces, WEAR mask, WATCH distance, WASH hands This E-Mail is confidential and may also be subject to legal privilege. If you are not the intended recipient, do not copy, forward or use this E-Mail for any purpose, nor disclose its contents to any other parties and notify us by return E-Mail. Warning Although this message has been checked for all known viruses using Anti-Virus Software, © 2017 (all rights reserved), Hunting cannot accept responsibility for any loss or damage arising from the use of this E-Mail or attachments. Information about the company can be found at http://www.hunting-intl.com#

Page 4February 08, 2021 Hunting Titan 16825 Northchase Drive, Suite 600 Houston, TX 77060 Office 281-448-2200 Fax 281-448-2227 www.hunting-intl.com US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. SE Washington, DC 20590 Subject: Request of Letter of Interpretation To whom it may concern, Hunting Titan, Inc. respectfully request an interpretation of Special Provision 114 in 49CFR172.102. SP 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. Specifically, in (a) does the word vehicle refer to transfer vehicle? In 49CFR171.8 Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle. Our question, can we transport a total weight of 90.5kg (200 pounds) of loaded jet perforating on one shipment but two separate transport vehicles? Our example is a truck with a flatbed trailer. Your consideration of this request is appreciated. Please let me know if additional information is needed. I may be contacted at 346-302-1607 or joe.murphy@hunting-intl.com. Respectfully, Joseph Murphy Joseph Murphy Compliance Manager, Hazardous Materials#

Page 5February 08, 2021 Hunting Titan 16825 Northchase Drive, Suite 600 Houston, TX 77060 Office 281-448-2200 Fax 281-448-2227 www.hunting-intl.com US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. SE Washington, DC 20590 Subject: Request of Letter of Interpretation To whom it may concern, Hunting Titan, Inc. respectfully request an interpretation of Special Provision 114 in 49CFR172.102. SP 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. Specifically, in (a) does the word vehicle refer to transfer vehicle? In 49CFR171.8 Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle. Our question, can we transport a total weight of 90.5kg (200 pounds) of loaded jet perforating on one shipment but two separate transport vehicles? Our example is a truck with a flatbed trailer. Your consideration of this request is appreciated. Please let me know if additional information is needed. I may be contacted at 346-302-1607 or joe.murphy@hunting-intl.com. Respectfully, Joseph Murphy Joseph Murphy Compliance Manager, Hazardous Materials#