MEMBER COMPANIES (As Of October 2018) - Ime

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MEMBER COMPANIES (As of October 2018)Accurate Energetic Systems, LLCMcEwen, TennesseeAustin Powder CompanyCleveland, OhioBaker Hughes, A GE CompanyHouston, TexasDavey Bickford North AmericaSalt Lake City, UtahDetotec North America, Inc.Sterling, ConnecticutDynaEnergetics US, Inc.Houston, TexasDyno Nobel Inc.Salt Lake City, UtahGeneral Dynamics – OTS – Munition ServicesJoplin, MissouriGEODynamics Inc.Millsap, TexasHilltop EnergyMineral City, OhioHunting TitanHouston, TexasJet Research Center/HalliburtonAlvarado, TexasMaine Drilling & BlastingAuburn, New HampshireMaxam North America Inc.Salt Lake City, UtahMP Associates, Inc.Ione, CaliforniaNelson Brothers Inc.Birmingham, AlabamaNobel Insurance ServicesIrving, TexasOrica USA Inc.Watkins, ColoradoOwen Oil Tools LPGodley, TexasRA McClure Inc.Powell, OhioSafety Consulting Engineers, Inc.Schaumberg, IllinoisSenex Explosives, Inc.Cuddy, PennsylvaniaSpecial Devices, Inc.Mesa, ArizonaTeledyne RISI, Inc.Tracy, CaliforniaTradestar CorporationSalt Lake City, UtahTread CorporationRoanoke, VirginiaVet’s Explosives, Inc.Torrington, ConnecticutVisible AssetsStratham, New HampshireW.A. Murphy, Inc.South Pasadena, CaliforniaLiaison Class Members:Brazilian Association of Explosive and AggregateMaterials Industries (ABIMEX)Sao Paulo, BrazilAssociation of Energy Service Companies (AESC)Friendswood, TexasAustralian Explosives Industry & Safety Group(AEISG)Tweeds Head, NSW AustraliaCanadian Explosives Industry Association(CEAEC)Ottawa, Ontario, CanadaFederation of European ExplosivesManufacturers (FEEM)Brussels, BelgiumInternational Society of Explosives Engineers(ISEE)Cleveland, OhioNational Institute for Explosives Technology(NIXT)Lonehill, South AfricaSAFEX InternationalBlonay, SwitzerlandExplosives Safety & Technology Society –VisfotakMaharashtra, India

WASHINGTON, DC(202) 429-9280www.ime.orginfo@ime.orgIME is a nonprofit association founded in 1913 to provide accurate information and comprehensiverecommendations concerning the safety and security of commercial explosive materials. IME represents U.S.manufacturers and distributors of commercial explosive materials and oxidizers as well as other companiesthat provide related services. Although our member companies are based in North America, IME membersoperate globally with operations and distribution points on all continents except Antarctica.IME was created to provide technically accurate information and recommendations concerning commercialexplosive materials and to serve as a source of reliable data about their use. Committees of qualifiedrepresentatives from IME member companies developed this information and a significant number of theirrecommendations are embodied in the regulations of state and federal agencies.The Institute’s principal committees are: Environmental Affairs; Government Affairs; Legal Affairs; Safetyand Health; Security; Technical; and Transportation and Distribution.1

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Table of ContentsFOREWORD . 5SECURITY . 7CLASSIFICATIONS. 8STORAGE . 9SHELF LIFE . 11TRANSPORTATION. 11USE OF EXPLOSIVES IN OIL AND GAS OPERATIONS . 14INITIATION COMPONENTS AND SYSTEMS . 14GROUND VIBRATION . 16MISFIRES. 17RADIO FREQUENCY . 17TRAINING. 18ENVIRONMENTAL MANAGEMENT . 19REFERENCES . 20Appendix A . 23Appendix B . 57Appendix C . 593

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SLP 32Recommendations for Safe and Secure Use, Storage, and Transportation of CommercialExplosives in Oil and Gas OperationsFOREWORDThe oil and gas industry uses explosives in well completions and plug and abandonment projects. This SLPis designed to offer best practices in the manufacture, testing and transportation of the explosive articlesused. It is not a replacement for the API RP-67 which discusses safety at the well site. These practices arebased on U.S. standards, primarily ATF and DOT regulations, although compliance with all federal, state,and local requirements is required. Terms found in this SLP are defined in SLP 12.The best practices described in this SLP constitute what IME considers to be the minimum requirements forsafety and security, and they are recommended to entities engaged in the manufacture, transportation,storage, and handling of the commercial explosive materials described herein. This SLP is not intended to beexhaustive. Nor is it intended to be a single source document for explosives operations in the oil and gasindustry. Accordingly, the SLP should not be relied upon as a substitute for company-specific safety andsecurity planning, or for seeking individual and case-specific legal and/or technical expert consultation.5

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SECURITYThis section of SLP-32 contains guidelines for explosives security in oil and gas operations. It is intended toaugment the extensive explosives industry security guidelines listed in SLP-27, Security in Manufacturing,Transportation, Storage, and Use of Commercial Explosives. Explosives use in oil and gas operations maybe located at well site (both land and offshore) and facility locations ranging from remote to urban, withpotentially large numbers of personnel and numerous entities present at any given time. Each operatingenvironment presents its own security considerations. For example, law enforcement response time andeffectiveness may vary with proximity to population centers. Consider how the following recommendationsand those given in SLP-27 apply to your operations.1. Generala. During domestic operations, adhere to federal, state, and local explosives regulations for security instorage, transport, and use. These regulations are mainly prescribed by ATF, DOT, and DHS (ifapplicable).b. Control access to explosives shipping, receiving, use, and storage areas. Keep numbers of personnelin explosives areas to the minimum required to complete the task.c. Be cognizant of widely varying explosives regulations when operating in foreign countries.i. Observe local laws in jurisdictions where regulations are more stringent than or conflictwith U.S. regulations.ii. U.S. regulations may serve as a basis for procedures in jurisdictions where regulations arenonexistent or loosely prescribed.2. Oil and Gas Operation Explosives Transportationa. Jet perforating guns, charged, are transported per packing instructions provided in 49 CFR 173.62,US1. Loaded perforating guns should be secured in a manner that will prevent their unauthorizedremoval, as well as removal of their explosive contents. This can be accomplished by locking theperforating guns to the truck, trailer or rack through the use of chains and locks or locking bars, orlocked in a closed compartment of the truck.b. Transporters should confirm periodically that the explosives remain properly secured to the vehicleor trailer during transport. Checks should be conducted according to company-establishedinspection intervals.c. Be knowledgeable of, and adhere to, all company and regulatory security requirements relating tothe explosives being transported. Certain articles and substances in Class 1 have stringentrequirements regarding attendance during transport.d. If security concerns exist when transporting explosives in magazines, assess the magazine type. Forexample, mobile type 2 magazines may reduce the likelihood of theft or unauthorized access whencompared to type 3 magazines because of heavier construction and an additional lock. Wheresecurity concerns exist with unaccompanied loaded magazine transport, keys should be sent in acontrolled manner to the destination separately from the driver of the magazine shipment, anddelivery of the keys to a responsible recipient should be confirmed prior to shipping the magazines.3. Oil and Gas Operation Explosives Receipt and Storagea. Explosive storage at gun-loading shops and well sites is regulated in 27 CFR 555, Subpart K of theATF regulations.7

b. Loaded perforating guns may be stored outside of magazines provided the conditions within ATFRuling 2010-7 are met.c. Identify well site explosives deliveries intended for immediate use from those intended to be stored.i. Upon arrival at the destination, remove all explosives from the vehicle.ii. Loaded perforating guns are an exception as they may be stored on vehicles or trailers aslong as they are parked and secured in a designated loaded perforating gun storage area.d. Plan for security contingencies in the event of natural disaster, civil unrest or other circumstancesthat cause unplanned evacuations. This may include ensuring accountability of inventories (properand updated documentation) and moving explosives.4. Use – Many gun loading shops and well sites operate continuously and explosives security andaccountability can be supported by enacting a shift change procedure. Sample format may include:a.b.c.d.e.Conveying any security concerns noted on the previous shift to the incoming shift.Briefing to and/or verification by incoming shift of the quantities and types of explosives present.Any upcoming scheduled explosives deliveries to the site of operations or shipments from the site.Any changes to personnel explosives access rosters, if applicable.Verification that the conditions in the variance received under ATF Ruling 2010-7 are met.CLASSIFICATIONSTransportation classifications under Department of Transportation (DOT) are not always the same as storageclassifications under the Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF).1. Classification for TransportationFor transportation purposes, explosives are classified by DOT in accordance with that agency’sHazardous Materials Regulations (49 CFR, Subtitle B, Chapter I, Subchapter C and more specifically 49CFR §§173.50 – 173.59) and under these regulations all explosives are assigned to hazard materialsClass 1 1. DOT classifications for common oil and gas explosive articles are based on packaging.Explosives classifications are not self-assigned like other hazard classes. They are issued by DOT’sPipeline and Hazardous Materials Administration (PHMSA) based on results of tests conducted byPHMSA-approved labs or, in some cases, by analogy to previous classifications.Class 1 materials applicable to the oil and gas industry are divided into four divisions to note theprincipal hazard of the explosive 2.a. Division 1.1 – Explosives that have a mass explosion hazard. A mass explosion is onewhich affects almost the entire load virtually instantaneously. Typical examples arecertain shaped charges, cutters, detonating cord, severing tools, detonators, loadedperforating guns.b. Division 1.2 – Explosives that have a projection hazard but not a mass explosionhazard. Typical examples are certain power charges.c. Division 1.3 – Explosives that have a fire hazard and either a minor blast hazard or aminor projection hazard or both, but not a mass explosion hazard. Typical examples arecertain types of propellants and certain power charges.1249 CFR 173.2Division Placards are example depictions and are not comprehensive. For a full list of divisions see 49 CFR 173.28

d. Division 1.4 – Explosives that present a minor explosion hazard. The explosive effectsare largely confined to the package and no projection of fragments of appreciable size orrange is to be expected. An external fire must not cause virtually instantaneousexplosion of almost the entire contents of the package. Typical examples includecertain shaped charges, certain loaded perforating guns, detonating cord in specialpackaging, power charges, safety fuse and electric, electronic, and nonelectricdetonators.As noted above different classifications can have the same type of explosive. Thedifferences may be due to explosive loads or may be due to packaging differences. Alltesting is evaluated based on how the explosive performs in its package. Also note, theexamples provided in the divisions above may fall under more than one division.Two other classes of hazardous materials are commonly utilized by the oil and gas industry in downholeoperations.a. Division 4.1 – Flammable solid, not an explosive. Typical examples are certain powercharges and some chemical cutter propellants.b. Division 5.1 – Oxidizers, not an explosive. Typical examples are StimGunsTM andbromine triflouride (used in chemical cutters)2. Classification Divisions for Storage PurposesFor storage purposes, ATF separates oil and gas related explosives into two classes 3 as follows:a. High Explosives – Explosive materials that can be caused to detonate by means of a blastingcap when unconfined. Typical examples include shaped charges, detonating cord, jet cutters,detonators, severing tools, bi-directional boosters, and time delay fuzes.b. Low Explosives – Explosive materials that can be caused to deflagrate when confined. Typicalexamples include igniters, core gun loads, and power charges that are classified as explosives.STORAGEThis section of SLP 32 contains guidelines for explosives storage in oil and gas operations. It is intended tosupplement IME SLPs 1, 2, 3, 14, and 17. In general, all explosive materials must be stored in magazinesconstructed and located in accordance with federal, state and local regulations. Magazines should be keptlocked at all times except for inspection, inventory, or the movement of explosive materials in or out of themagazine.Approved storage magazines are designed to prevent unauthorized persons from having access to theexplosives and to protect the explosive materials from deterioration. Accordingly, magazine sites should beinspected frequently (at least every seven days). Accurate inventories should be kept of all explosivematerials and stocks of older materials should be used first. A daily summary of magazine transactions(DSMT) must be maintained. Roofs, walls, doors, floors, locks and ventilators of magazines must be kept ingood repair. The area inside the magazine should be kept clean, dry and orderly. No combustible material3ATF has three classifications of explosives, however only high explosives and low explosives categories areapplicable to the oil and gas industry.9

should be stored within 50 feet (15.2 m) of the magazine and all dry grass or brush cleared for a distance of25 feet (7.6 m) around the magazine.Anyone contemplating building or locating a storage magazine or purchasing explosive materials shouldmake sure that they are in compliance with all applicable regulations.The following table provides examples of common oilfield explosive products and magazine types in whichthese products can be stored.Explosives Compatibility Based on ATF RequirementsMagazine TypeClasses of materials that maybe stored together 4All classes of explosives:High explosives and lowexplosives.Detonator storage magazine:Examples of allowed storageDetonators, igniters, time delayfuzes, and percussion initiators.Type 2–portableAll classes of explosives:High explosives and lowexplosives.Detonators, igniters, time delayfuzes, and percussion initiators.Type 3 – daybox (Not to beused forunattendedstorage.)All classes of explosives:High explosives and lowexplosives.Detonators, time delay fuzes,and percussion initiators.Type 4 –permanent orportableLow explosives only.Non-mass detonatingdetonators, igniters and squibs.Type 1 –permanentstorageOther storage magazine:ExamplesShaped charges,detonating cord, jetcutters, severing tools,power charges, core gunloads, bi-directionalboosters and ignitersShaped charges,detonating cord, jetcutters, severing tools,power charges, core gunloads, bi-directionalboosters, and ignitersShaped charges,detonating cord, jetcutters, severing tools,power charges, bidirectional boosters,igniters, and core gunloadsCore gun loads, powercharges, and ignitersIn order to store detonators in Type 4 magazines, they must be stored in a manner which will prevent themfrom mass-detonating. As an example, DOT Division 1.4 explosives will not mass detonate if the conditionsof DOT’s approval are maintained. Changes to an explosive’s package or storage of other materials,explosive or non-explosive, in the package, may invalidate the DOT Division 1.4 classification. Forexample, removing Division 1.4 detonators from their package and placing them in another box or removinga portion of the packaging material may allow for a mass explosion. The DOT approval documentation willdescribe packaging requirements for proper classification.Loaded perforating guns may be stored in areas outside of a magazine according to the conditions listed inATF Ruling 2010-7, which requires the following: Notification for each site at which perforating guns are to be storedSite security features and practicesConfigurations and positions of stored gunsMaximum limitations on quantities of stored guns and net quantities of explosivesNotification of local fire safety authority and local ATF officeSpecific documentation of perforating guns and contents4Detonators, with certain exceptions, may not be stored with other explosive materials. Refer to “Detonator StorageMagazine” column in this table.10

Use the American Table of Distances for Storage of Explosive Materials to determine safe distances frominhabited dwellings, highways, passenger railways, and between explosive materials magazines. ATF mayapprove, via variance, use of an IMESAFR quantitative risk assessment in lieu of quantity-distance.SHELF LIFEExplosives should be used on a first-in/first-out basis to prevent accumulation of aged shelf stock. Somemanufacturers may specify a shelf life and storage conditions on their explosives. Unless specifiedotherwise by the manufacturer, shelf life should be treated as a guideline to verify that condition andperformance are still suitable for intended use rather than as a maximum storage length or expiration date forthe explosives. Excess heat, humidity, or vibration may significantly affect shelf life.TRANSPORTATION1. Explosives are to be transported in compliance with applicable local, national or international transportregulations, including air and vessel regulations. In the United States, these are the regulations written bythe U.S. Department of Transportation (DOT) and published in Title 49 Code of Federal Regulations. IMEaddresses the transport of explosives in depth in IME Safety Library Publication Number 14, Handbook forthe Transportation and Distribution of Explosive Materials. The sections below supplement thatinformation for products specific to the oil and gas industry, such as loaded perforating guns.Transportation of explosives via railroad, water, or highway under the jurisdiction of DOT or theDepartment of Homeland Security (U.S. Coast Guard)), is exempt from the storage regulations of theBureau of Alcohol, Tobacco, Firearms and Explosives (ATF).2. The driver of a motor vehicle meeting the definition of a commercial motor vehicle in 49 CFR 383.5,must hold a valid commercial driver’s license (CDL). In summary, a commercial motor vehicle is defined inthat section as a motor vehicle or combination of motor vehicles that: Has a gross vehicle weight rating (GVWR) of 26,001 pounds or more; orHas a gross combination weight rating of 26,001 pounds or more, inclusive of a towed unit(s) thathas a GVWR of more than 10,000 pounds; orIs of any size and is used to transport hazardous materials in quantities that require the vehicle to beplacarded, or any quantity of a material listed as a select agent or toxin in 49 CFR 73.When transporting explosives, or any hazardous material, in a quantity that requires the vehicle to beplacarded, the driver’s CDL must also have a hazardous material endorsement.3. Prior to loading explosives onto a vehicle, the compatibility of explosives with other explosives and withother hazardous materials, should be determined by reviewing the segregation and compatibility chartsfound in 49 CFR 177.848.4. Perforating Gun Transportation.a. Classification: Prior to transporting or offering perforating guns for transport, they must beapproved by DOT. The approval, titled Classification of Explosives (also known as an EX-letter),specifies the UN number, proper shipping name, UN division and compatibility group assigned to aparticular style of perforating guns.The approval process for any explosive can be expensive, complicated and time consuming, usuallyrequiring evaluation and/or testing by an approved laboratory before the approval application will beconsidered by DOT. To simplify the process, IME and the Association of Energy ServiceCompanies (AESC) developed the Guide to Obtaining DOT Approval of Jet Perforating Gun usingAESC/IME Perforating Gun Specifications (“Specifications”); see Appendix A. The Specificationsare a series of documents setting forth standardized parameters for various perforating gun systems.11

The documents include a drawing representative of the perforating gun system, technical details forthe system, authorized components and compliance requirements that govern the applicability of theperforating gun specification.The Specifications have been reviewed and approved by DOT for companies to use to apply forapproval of their loaded perforating guns. Use of the Specifications will enable the applicant toobtain DOT approval of their qualifying perforating gun systems without the need for testing andwith a minimum of effort and delay. Perforating gun systems covered by the Specifications are: Ported tube systems (without detonator)Tube & strip systems (without detonator)Tube & tube systems (without detonator)Strip carrier systems (without detonator)Wire carrier systems (without detonator)Link carrier systems (without detonator)Swing carrier systems (without detonator)Tube & Tube Kodiak system (without detonator)Every company that loads perforating guns must have their perforating guns approved by DOT,before transporting or offering the perforating guns for transport. Details regarding the approvalprocess using the Specifications is provided in the Specification document which is available on theIME website at: https://www.ime.org/content/recommendations and guidelines.b. Transporting perforating guns: Loaded perforating guns are to be transported in compliance withthe applicable hazardous materials transportation regulations. This includes marking and labelingeach perforating gun, preparation of shipping papers, and if applicable, applying placards to thevehicle. Details are included in 49 CFR 172, Subparts C – F. IME’s Safety Library Publication 14,Handbook for the Transportation and Distribution of Explosive Materials, provides guidance inmeeting those requirements.Additionally, loaded perforating guns must be carried as specified in 49 CFR 173.62 PackingInstruction US 1 (see Appendix B). Among the provisions of US 1 is the requirement in paragraph1.d.(i) that guns are not subject to damage by contact, one to the other or any other article ormaterial carried in the vehicle. In March 2015, DOT clarified this provision stating that merecontact between perforating guns is not a violation of the regulation, unless the contact allows formovement between the guns that could cause damage by contact. Perforating guns that aretouching, but that are appropriately secured for conditions normally incident to transportation,would be compliant with the requirements of US 1, paragraph 1.d.(i). See Appendix C for the DOTclarification.As with all explosives, security is a critical component when transporting loaded perforating guns.Implementing sound security practices reduces vulnerability to loss or theft. Loaded perforatingguns should be secured in a manner that will prevent their unauthorized removal, as well as removalof their explosive contents. This can be accomplished by locking the perforating guns to the truck,trailer or rack through the use of chains and locks or locking bars, or locked in a closed compartmentof the truck.5. Transportation of Detonators with Loaded Perforating Guns:Detonators may be carried on the same vehicle as loaded perforating guns, as specified in PackingInstruction US 1, paragraph 1.a. They are to be carried in their original UN certified packaging or, asauthorized by 49 CFR 173.63(f) and (g) for 1.4B and 1.4S detonators, in an IME 22 box. Refer to IME’sSafety Library Publication 22 for construction details for an IME 22 box. Additionally, detonators maybe carried by road in an alternate container that has been approved by DOT’s Associate Administrator,12

per 49 CFR 177.835(g)(3). One such authorization was issued by DOT through Special Permit DOT-SP11432. Each company that is a Party to that Special Permit may carry up to 24 detonators (each in aheavy wall tube) in a steel “cap box” constructed of at least 12 gauge low-carbon steel, lined with at least¼” foam or wood, with at least two means for preventing the lid from opening should accidental initiationof the contents occur. To apply for Party status to that Special Permit, or any other, follow the directionsspecified in 49 CFR 107.107. To view DOT-SP 11432 or any other Special Permit, follow this -permits/search6. Special Requirements for Transportation of Detonating Cord:Detonating cord, not contained in a loaded perforating gun, must be packaged as specified in PackingInstruction (PI) 139 of 49 CFR 173.62. That PI allows cords that are classified as UN0065, UN0104,UN0289 and UN0290 to be carried without the ends of the cord sealed, provided the inner packagingused to contain the cord consists of a static-resistant plastic bag of at least 3 mil thickness and the bag issecurely closed. The inner packaging must then be placed in the appropriate UN certified box, alsospecified in PI 139, and closed in the manner specified by the cord manufacturer. In the U.S., detonatingcord may be transported as UN0289 / 1.4D shipment if shipped pursuant to 49 CFR 173.63(a). Shipmentunder conditions other than described in 49 CFR 173.63(a) requires that this package be marked / labeledUN0065 / 1.1D.13

USE OF EXPLOSIVES IN OIL AND GAS OPERATIONSThe oil and gas industry uses different types of explosives in its day to day operations. Among thecommonly used articles are: Perforating ChargesJet cuttersSetting toolsCore gunsPerforating gunsPropellent productsIgnitersPower ChargesInitiating systems (including detonators, cartridge actuated, hydraulic and impact firing heads)Bidirectional BoostersDetonating CordEach of these explosives have a unique makeup. For example, there are several different types of explosiveloads, explosive types, and physical configurations. These explosive articles are selected based on physicalrequirements unique to the wellbores in which they are to be used.Each manufacturer of these explosives has their own instructions for application and use of their products.Users should be well trained in the installation and use of these explosives and follow those instructions.INITIATION COMPONENTS AND SYSTEMS1. Electric Detonators – Oilfield electric detonators are explosive devices that require electrical stimulus tobegin the initiation process. There are multiple types of electric detonators:a. Bridgewire detonators – Oilfield bridgewire detonators should have a minimum resistance of 50Ohms and a 200mA no-fire current, per RP67. The resistance will typically come from resistors thatare inserted in the detonator circuit. This type of detonator typically employs a primary explosive(such as lead azide, lead styphnate, silver azide, etc.) to begin the initiation train but may also use apyrotechnic mix. Secondary explosives (such as PETN, RDX, HMX, HNS, etc.) are used as the mainoutput explosive. These detonators are normally 1-4” in length and 1/4-1/3” in diameter.b. High Energy Electric Detonator

Division 1.2 - Explosives that have a projection hazard but not a mass explosion hazard. Typical examples are certain power charges. c. Division 1.3- Explosives that have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard. Typical examples are

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