Department of the Navy — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration SEP 25 2003 Mr. Daniel J. Burke Ref No.: 03-0219 Acting Head, Environmental, Safety and Security Department Depart of the Navy Naval Undersea Warfare Center Division 1176 Howell Street Newport RI 02841-1708 Dear Mr. Burke: This is in responds to your letter and subsequent telephone conversation with Gigi Corbin of my staff, requesting clarification of § 173.159(c)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you asked whether you may ship Batteries, wet, filled with alkali, 8, UN 2795, PG III under the provisions of § 173.159(c)(1) via rail, highway or vessel. According to your letter, you are shipping 200 batteries in the original manufacturer's crate or in similar newly constructed crates. The batteries will be packed and secured in a manner to prevent any of the battery terminals from supporting the superimposed weight. In addition, the crates will be secured to pallets or skids with banding. The estimated weight of the batteries, pallet or skid, and crate is 1100 Ibs. Section 173.159(c)(1) allows electric storage batteries protected against short circuits and firmly secured to skids or pallets capable of withstanding the shocks normally incident to transportation to be transported by rail, highway, or water. The height of the completed unit must not exceed 1 ½ times the width of the skid or pallet. The unit must be capable of withstanding, without damage, a superimposed weight equal to two times the weight of the unit or, if the weight of the unit exceeds 907 kg (2000 pounds), a superimposed weight of 1814 kg (4000 pounds). Battery terminals must not be relied upon to support any part of the superimposed weight. Provided all provisions in § 173.159(c)(1) are met, your understanding is correct. I hope this information is helpful. Plcase contact us if you require additional assistance Sincerely, Whoa Dol Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 173.159 030219#

Page 2Relerford DEPARTMENT OF THE NAVY NAVAL UNDERSEA WARFARE CENTER DIVISION $173. 159(0) NEWPORT RI 02841-170B 1176 HOWELL STREET Batteries IN REPLY REFER TO: 5090 03-0219 Ser 3551/75 Mr. Edward Mazzullo USDOT/RSPA/DHM10 Director, Office of Hazardous Material Standards Washington, D.C. 20590 400 Seventh Street, S.W. Dear Mr. Mazzullo: of preparing a procedure for shipping silver-zinc batteries The Naval Undersea Warfare Center (NUWC) is in the process July 29, 2003, phone call with Ms. Gigi Corbin in your Office of containing Potassium Hydroxide (KOH) . During a Hazardous Materials Safety, NUWC received verbal approval for shipping silver-zind batteries containing KOH under the conversation, Ms. Corbin consulted with another member of her regulatory requirements of 49 CFR $ 173.159 (c) (1). During that office, Mr. John Gale, who agreed with that approval. ensure our compliance with the intent of the Hazardous Materials written verification from your office in order to Regulations (HMR) . NUWC facilities use rechargeable silver-zino batteries for undersea warfare research, development, test, and evaluation batteries, measuring 1.5 x 6 x 6.5 inches, are manufactured and rate of approximately 5000-6000 cells annually. tested to manufacturer to the operational sites, strict military specifications. the batteries are dry. when shipped from the Two hundred batteries are packaged and shipped in a single non- NUW facilities before initial use. Each wet battery has a specification crate. The batteries are filled with KOH at the maximum weight of 4.55 pounds. After approximately two years of use, the batteries are no discharged with the polive and hegae a term none comicted salvageable. charge and possibly causing a short circuit during packing, with a jumper wire to prevent the batteries from developing a shipping, and unpacking. Hawthorne, Nevada for reclamation.#

Page 3Ser 3551/75 5090 follows: our proposed procedure for shipping these batteries is as original manufacturer's crate or in a a. No more than 200 batteries will be re-packaged in the crate. The crates will meet the superimposed weight similar newly constructed and requirements of the regulation. secured in a manner to prevent any of the battery terminals The batteries will be packed secured to the pallet or skid with banding. The estimated from supporting the superimposed weight The crate will then be pounds. weight of the batteries, pallet or skid, and crate is 1100 requirements of the regulation. The completed unit will comply with the dimension proper shipping name stipulated in the 49 CFR § 172.101 The skid or pallet of batteries will be marked with the lazardous Materials Table; specifically, with alkali, 8, UN2795". They will be labeled as "Batteries, wet, filled with arrow up indicators. "Corrosive" using the proper shipping name and all other applicable HMR A shipping document will be prepared requirements. request, or any recommended modifications, you may direct them If you have any questions regarding our proposal or this at (401) 832-5858. to Mr. Noel (Mac) Field in our Hazardous and Solid Waste Program to your reply. Thank you for your assistance on this issue. I look forward Sincerely, Daniel 2. Burke D. J. BURKE Safety and Security Department Acting Head, Environmental, By direction of the Commander Copy to: NUWCDIVKPT Code L PMS401 (E. Sutton) NUWCDIVKPT Code 30 (G. Cooper) (R. Jusko) NUWCDIVKPT Code 80 (D. Kohn) NUWDIVKPT Code 325 D. Herzog: J. Kucera)#