Johnson Matthey, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration JUL 31 2002 Mr. Bill Erickson Ref. No. 02-0162 Operations Manager Johnson Matthey, Inc. 1397 King Road West Chester, PA 19380 Dear Mr. Erickson: This is in response to your letter dated May 24, 2002, requesting clarification regarding the selection of a proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you asked material can be classified as "Self-heating solid, inorganic, whether your nickel catalyst n.o.s., 4.2, UN3190. For a material not specifically identified by name in the Hazardous Material Table (HMT), the HMR requires that the material be described by the shipping name that "most appropriately describe" the material. one shipping name could "most appropriately describe a material." In some cases, more than Under § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material. This office generally does not perform this function. assistance when we have the information available. However, we provide testing performed on the material was inconclusive due to the In your letter, you stated that the third party laboratory temperature of the test sample climbing rapidly from ambient to over 300 °C within the first three minutes. You further stated that the temperature continued to climb to over 400 oC within 10 minutes, where it remained for approximately 30 minutes before dropping back down to ambient temperature two hours after the start of the test. In the HMR, § 173.124(b) defines a Division 4.2 (Spontaneously Combustible) as being one of the following: (1) A pyrophoric material. A pyrophoric material is a liquid or solid that, even in small quantities and without an external ignition source, can ignite with five (5) minutes after coming in contact with air when tested according to UN Manual of Test and Criteria.#

Page 2(2) A self-heating material. A self-heating material is a material that, when in contact with air and without an energy supply, is liable to self-heat. A material of this type which exhibits spontaneous ignition or if the temperature of the sample exceeds 200 °C (392 oF) during the 24-hour test period when tested in accordance with the UN Manual of Tests and Criteria, is classed as a Division 4.2 material. Therefore, based on the information you provided, in addition to the fact that your material is heating up to a temperature of over 300 °C within the first three minutes upon contact with air, it is the opinion of this office that the proper shipping name "Pyrophoric solid, inorganic, n.o.s., 4.2, UN3200" most appropriately describes your nickel catalyst material. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Nathe z. Michel Hattie I. Mitchell : Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards un.#

Page 3Betts Johnson Matthey §73. 10t May 24, 2002 Classification Ed Mazzullo Director of Office of Hazardous Material Standards 02-0162 DHM-10 USDOT/RSPA 400 7" Street Southwest Washington, DC 20590. Dear Mr. Mazzullo: My company, Johnson Matthey Inc., is seeking an interpretation on third party laboratory testing which Stresau Laboratories Inc. performed on nickel catalyst material. The testing was inconclusive, however, Dr. Spence Watson of the DOT has recommended we classify this material as Division 4.2, Packing Group II - Self-heating solid. Would you please let me know if your Office concurs. Thank you for your help in this matter. If you have any further questions, please contact me at 610-232-1953. sincerely Bill Erickson Operations Manager Johnson Matthey Inc. Fuel Cells - GPT 1397 King Road West Chester, PA 19380 Enclosure CATALYST AND CHEMICALS DIVISION - FUEL CELLS GAS PROCESSING TECHNOLOGY 434 Devon Park Drive, Wayne, PA 19087-1889 | TEL: (610) 971-3100, FAX: (610) 971-3116#

Page 41HT-14-EUUE 10:10 FRUM: SIRESHU LU ristssryry IU: 1610252195U p:213 STRESAU LABORATORY INC. • N8265 Medley Road, Spooner, W1 54801-7819, Tel. 715-635-2777, Fax 715-635-7979 wwww.streaau.com May 13, 2002 Mr. Allen Foster Johnson Matthoy 1397 King Road West Chester, PA 19380 Dear Mr. Foster: Enclosed please find Laboratory Report # 02069 for Division 4:1 Flammable Solid and 4.2 Self- Hoat testing of your sample. Full details are in the enclosed report. n invoice to cover the cost of the laboratory examinations will be sent to your accountin epartment under separate cover. Your sampic remnants will be icturned to you shortl We appreciate your business. If we may be of further assistance or if you have any questions, please call me at (715) 635-2777. Sincerely, thran E Baton Thomas E. Basham Hazardous Materials Manager tb (02069) Iver Thirty ycars of Devclopment a Evaluation a Production of Ererretic Device Classification • Packaging a Testing of Hazardous Material#

Page 5MAY-14-2002 13:18 FROM: STRESAU LAB 7156357979 TO: 16102321930 P: 3/5 STRESAU LABORATORY INC. NB265 Medley Road, Spooner, WI 54801-7819, Tel. 715-635-277. Fax 715-635-7979 www.stresal.com LABORATORY REPORT # 02069 "FLAMMABLE SOLID AND SELF-HEAT TESTING" May 13, 2002 for Johnson Matthey 1397 King Road West Chester, PA 19380 Atin: Mr. Allen Foster Prepared by: thomE Botan Thomas E. Basham Hazardous Materials Manager Reviewed by: lichael J. Pesk - MinaPart Chief Operating Officer ver Thirty years of Development a Evaluation • Production of Enorgotic Devics lassification • Packzging o Testing of Hazardous Materia#

Page 6MHY-14-2402 15:18 FROM: STRESAU LAB 7156357979 TO: 16102321930 P: 4/5 STRESAU LABORATORY, INC. May 13, 2002 LABORATORY REPORTS NO. 02069 Page 1 of 2 Prepared for: Johnson Matthey 1397 King Road Wost Chester, PA 19380 Subjcct: Preliminary Screen and Self- Heat Test 1.0 OJECT Your sample identified as Ni-3288 E 1/16" 3F Nickel Catalyst was subjected to a Preliminary Screen/Burn Rate and Self-Heating Test in accordance with the Code of Podoral Regulations, Title 49, (also United Nations Test Mcthod N.1 and Test Method N.4) as reguested by Rob Smith, Cargopak Corp., P.O. # 02-2066 dated March 18, 2002. 2.0 PHYSICAL APPEARANCE The sample was a black extrusions contained in a metal cylinder, 10"L × 1"od, with Swage-Lok pipe fittings and caps on both ends. The sample was prepared for testing by opening one end and pouring the contents into the proper test fixtures. The sample arrived at Stresau at ambient terperaturo, and was tested in the form received. 3.0 TEST CONDUCTED 3.1 Class 4.1 Preliminary Screen Test, UN method N.1 Procedure A portion of the sample is filled into a metal mold 250mm long by 20mm wide by 10 mm high, and inverted onto a cool, impervious base plate. The sample is ignited by application of a gas burner at one end, and the titte needed to propagate 100 mm is recorded. 4.0 SUMMARY Upot pouring the sample into the metal mould, it itamediately began to heat in contact with air and without an ignition source. A color change from black to gray further indicated that a reaction was taking place. A gas flame was applied to on end, but no additional changes occutted.#

Page 7InI 1 T LOU dO IAUIVINLUMU A FUNDIS IN• LULULULAINN STRESAU LABORATORY, INC. May 13, 2002 LABORATORY REPORTS NO. 02069 Page 2 of2 5.1 Class 4.2 Self Heating Test, UN method N.4 Procedure A portion of the sample (as received) was prepared for testing by filling a 1.0cm' fine mesh stainless steel wire basket. The basket was tested by placing it into an oven set at 140°C (284°F) with a thermocouple probe and a wiro mesh basket cover. The temperature of the sample and oven are recorded throughout the test. 6.0 SUMMARY Approximately 100 grams of sample was poured into a 10cma? fine mesh stainless sicel wire basket at ambient temperature. The sample immediately began to generate heat. A thermocoup) vas placed in the sample. The sample temperature climbed rapidly from ambient to over 300°C within the first threc minutes. The temperature continued to climb to ovcr 400°C within 10 minutes after insertion, where it remained for approximately 30 minutes before dropping back down to ambient temperature two hours after the start of the tost. 7.0 CONCLUSIONS Test results from the Preliminary Screen and Self-Heat Tests are inconclusive due to the materials ability to generate significant heat before complete application of UN/DOT methodology such as flame contact in the Preliminary Screen and 140°C atmosphere in the Self-Heat Test. 8.0 DATA STORAGE The field data for this report is contained in Data Book #SLF 2002-1, and will be filed with Strosau Laboratory Document Control. No photographic or video documentation was made.#