{"operation":"document","citation":"07-0106","title":"Cobasys — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-07-27","effective_on":null,"summary":"07-0106 response to Cobasys concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070106.pdf","body":"<<<PAGE 1>>>\n\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nAdministration\nHazardous Materials Safer\nJUL 27 2007\nMr. Anthony J. Serventi\nSenior Counsel\nRef. No.: 07-0106\n3740 Lapeer Road South\nCobasys\nOrion, MI 48359\nDear Mr. Serventi:\nThis is in response to your letter dated May 23, 2007 requesting clarification of the\nazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to desig\nbe testing of lithium-ion cells and batteries. The specific requirements vou address a\ncontained in section 38.3 of the United Nations Manual of Tests and Criteria and are\nimplemented through the provisions of § 173.185 of the HMR.\nvolt A123 cylindrical lithium-ion cells utilizing approximately 518 grams of aggregate\nIn your letter you describe a hybrid electric vehicle battery system consisting of 192 - 3.3\nequivalent lithium content. The battery system is equipped with a system that monitor:\ncell voltage and temperature and incorporates a service disconnect feature. Each cell\npassed the design-type tests in section 38.3 of the UN Manual of Tests and Criteria and\nthat since the individual cells passed the applicable tests and incorporate additional safet\nthe cells in this assembly are electrically connected by a circuit board. It is your opinion\nsystems, the cell assembly constitutes a \"battery assembly\" as described in 38.3.3 of the\nUN Manual of Tests and Criteria and thus the assembly is not required to be tested in\naccordance with the design-type tests outlined in section 38.3.\nWe do not agree. The system you described meets the definition of a battery or a battery\nelectrically connected together by permanent means, including case, terminals and\nack, defined in section 38.3 of the UN Manual of Tests and Criteria as one or more cell:\nsubject to the tests in the UN Manual of Tests and Criteria, even if the cells that make u\nnarkings. Except for single cell batteries, each new lithium cell and battery design-type i\nthe battery have been tested. The fact that the cells are electrically connected by a circuit\nboard that can be disconnected does not mean this assembly of cells constitutes a battery\nassembly.\n173.185 (e)\n070106\n\n<<<PAGE 2>>>\n\nIf you believe your hybrid electric vehicle battery system provides and equivalent level of\nsafety to the HMR requirements without additional testing, you may wish to apply for a\nspecial permit through the Office of Hazardous Materials Special Permits and Approvals\nat 202-366-4535.\nI hope this information is helpful.\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n:\nD COBASYS\nAnthony J. Serventi\nSenior Counsel\n07-0106\n3740 Lapeer Road South\nOrion, Michigan 48359\nFax:\nPhone: 248.620.5751\nwww.cobasys.com\n248.620.5753\ntserventi@cobasys.com\nMay 23. 2007\nUS Department of Transportation\nEdward Mazzullo. Director\nPipeline and Hazardous Materials Safety Administration\nOffice of Hazardous Materials Safety\nSE East Building. 2°° Floor\n1200 New Jersey Avenue\nWashington. DC 20590\nRc: Letter of Interpretation for 49 CFR $173.185(e)\nDear Mr. Mazzullo:\n$173.185(e) (\"Section 185(e)\") and Section 38.3 of the UN Manual of Tests and Criteria (\"UN\nThis correspondence is a formal request for a Letter of Interpretation regarding 49 CFR\nManual\"'). as it relates to Section 185(e). Cobasys LI.C (Cobasys\") is a developer and\nintegrator of batteries. battery packs and battery systems for transportation and stationary\napplications.\nCobasys is currently developing a hybrid electric vehicle (HEV) battery system. which\ndevelopment to further improve the fuel economy of HEVs. Cobasys intends to deliver\nincorporates lithium battery cells. The next generation of HEV battery systems are under\nprototypes of the HEV battery system to a customer. a US based automotive OEM. in early July\n2007. Initially. Cobasys intends to use ground transportation to deliver the HEV battery systems\nlithium cells or hatteries to be transported as items of Class 9. As subsection 5 has been\nSection 185(c) provides the requirements of subsections 1-7. which must be met for\nhave passed all the tests required under Section 38.3 of the UN Manual. Further, as incorporated\nReserved. it is not addressed. With respect to the Cobasys HEV battery system. the lithium cells\ninto the Cobasys HEV battery system. the lithium cells and Cobasys HEV battery system meet\nthe all the requirements of Section 185(c). The focus of our inquiry is the necessity to test the\nsubject Cobasys HEV battery system according to subsection 6 of Section 185(e). in view of the\nfact that the lithium cells. which make up the system, meet the requirements subsection 6 of\nSection 185(c). A description of the Cobasys HIV battery system is provided in Exhibit A.\nSection 38.3 of the UN Manual. \"cell\" is defined as \"a single encased electrochemical unit (one\nThe UN Manual provides a series of 8 tests for cells and batteries. For the purposes of\npositive and one negative electrode) which exhibits a voltage differential across two terminals\n\n<<<PAGE 4>>>\n\nPage 2\nSP\n310 - Approvel Process\nand \"battery\" is defined as \"one or more cells which are electrically connected together by\npermanent means. including case. terminals, and markings.\" Referring to Exhibits B and C. the\ncells of the Cobasys HEV battery system are electrically connected utilizing a circuit board.\nconnected. because the circuit board may be disengaged from the lithium cell assembly.\nAlthough the cells are electrically connected by a circuit. the cells are not permanently\nSection 38.3.3 of the UN Manual provides as follows:\n*When batteries that have passed all applicable tests are electrically connected to\nwhen fully charged, is more than 500g. that assembly does not need to be tested if\nform a battery assembly in which the aggregate lithium content of all anodes,\nit is equipped with a system capable of monitoring the battery assembly and\nand any overheat or overcharge of the battery assembly.\npreventing short circuits, or over discharge between the batteries of the assembly\nUN Manual. Cobasys has drawn the conclusion that the Cobasys HEV battery system is a\nAs indicated earlier, the lithium cells have passed all the tests required under Section 38.3 of the\nassembly of cells. The aggregate lithium content of the Cobasys HEV battery system is more\ncontent. Therefore, the Cobasys HEV battery system does not require testing under Section 38.3\nthan 500g. The Cobasys HEV battery system utilizes approximately 518 g of equivalent lithium\nassembly and preventing short circuits, or over discharge between the batteries of the assembly\nof the UN Manual, because it is equipped with a system capable of monitoring the battery\nand any overheat or overcharge of the battery assembly,\" as described in Exhibit A. For\nvoltage and temperature, and controls contactors which are. essentially, high-voltage switches.\nexample. the Cobasys HEV battery system includes an electronic controller which monitors cell\nclose and become conductive. Since the Cobasys HEV battery system will be shipped in an\nFurther, the contactors require external 12 V power to be applied to the controller in order to\nthrough the cell stack. Additionally. the Cobasys HEV battery system incorporates a service\nunpowered state, the contactors will be in an open state. also breaking the conductive path\ndisconnect system as illustrated in Exhibit D. The service disconnect system incorporates a\nservice disconnect which is removed from the Cobasys HEV battery system during transport.\nThe service disconnect is an integral part of the high-voltage current path. When the service\ndisconnect is removed from the pack. the conductive path is broken and no current may flow\nthrough the cell stack of the Cobasys HEV battery system.\nExhibits B and C, illustrations of the Cobasys lithium HEV system; and 3) Exhibit D, an\nAttached are 1) Exhibit A, a written description of the Cobasys lithium HEV system: 2)\nillustration of the service disconnect system.\n\n<<<PAGE 5>>>\n\nPage 3\nThank you for your time and help. Please contact me with any questions or concerns.\nSincerely.\nAnthony J. Serventi\n\n<<<PAGE 6>>>\n\nExhibit - A\nCobasys Lithium Hybrid Electric Vehicle Battery system\nDescription\nThe Li-ion battery system contains one-hundred-ninety-two (192) 3.3 Volt\ncylindrical cells which are connected in a series-parallel arrangement (2-parallel,\ndisconnect is implemented to divide the battery system into two separate\n96-series). The nominal system voltage is 370VDC (9.0 Ah per cell). A service\n185VDC strings. A centralized Battery Pack Control Module (BPCM) is included\nfor contactor control and provides energy storage system status information\nnecessary for optimized energy management. The BPCM interfaces with all cell\nsensors and controllers that offer voltage and temperature monitoring as well as\nfor a complete system are included.\ncell balancing for optimized cell usage. The other electronic components needed\nLAN allows full reporting to the vehicle control system including monitored\nBPCM communication to the vehicle via\nvariables,\nmanagement system utilizes air-cooling.\ndiagnostics\nand battery SOC/SOH/power-available.\n1. Cell Assemblies\nBus Bars / Interconnects\nLithium Ion Cells\nTemperature Sensors\nCell Restraint Structures\nSense Leads for Battery Voltages and Temperatures\n2. Battery Pack Control Module. The following sets of functions are implemented:\nA Battery Monitoring Functions\nMeasure HV Battery Voltage, Temperature, and Current.\nMonitor each Cell.\nBalance Cells (if necessary).\nDiagnose each input.\nMonitor Isolation of cells with Contactor Open, once per key cycle.\nB. HV Safety, Disconnect, and Thermal Functions\nCommunicate on high speed LAN\n\n<<<PAGE 7>>>\n\nControl Pre-Charge and Main Contractors.\nSource and Sense High Voltage Interlock Circuit (Simple Open /\nControl and Diagnose of a Variable Speed Cooling Fan.\nClosed circuit.\nC. Battery State Estimator Functions\nCobasys Battery State Estimator (BSE) Algorithms to Calculate:\nState of Charge,\nState of Health,\nVoltage Limits.\nPower Limits, and\n). Manage Charging\nNake-Up when Charger provides 12V power and \"Ready signal\nDetermine need for charging\nOpen contactors on fault\nControl charging with PWM signal to charger\nneeded)\nControl cooling system while charging lower battery temperature (if\nE. Precondition Battery Temperature\nManage battery heater to raise battery temperature during cold\nweather soaks to provide energy and power upon next use\nOnly active while connected to chargel\nand functions:\n3. High Voltage Battery Disconnect Unit includes the following subcomponents\nMain Serviceable Fuse.\n2 Main Contactors.\n2 Charger Contactors\nPre-Charge Resistor (~10 Ohm).\nPre-Charge Contactor.\nCurrent Sensor\nVoltage Sense Leads.\nHV Bus\nMain Positive/Negative Lugged Ring Terminal Connections for Propulsion\nSecondary Positive/Negative Lugged Ring Terminal Connections for 15 A\nCharger\n4. Service Disconnect\nWith Fuse rated for increased EV type driving duty cycle\nHigh Voltage Interlock (Shorting Plug Style)\n5. Thermal Management System.\nExternal Fan assumed.\nBattery Heater.\n\n<<<PAGE 8>>>\n\nShipping conditions of battery system\n1. Transported ground only Class 9 (Class 9 UN 3090 Packing Group II) Hazardous\nMaterial following requirements of 49 CFR 173.185(c)(1-7).\n2. Service disconnect handle removed.\nAll Battery Disconnect Unit contactors open. See Exhibit D.\n4. Protective cover on/over high voltage terminals.\n\n<<<PAGE 9>>>\n\nBoard lAl\nAuxiliary\nEXHIBIT - B\nCELL ASSEMBLY (2)\nPlate Ass. (TIPA) (3)\nTerminal Interconnect\n230\nPHEV BATTERY PACK ASSEMBLY\nUnit (BDU) (2)\nBattery Disconnect\n\n<<<PAGE 10>>>\n\nLion\n(32157)\nPHEY CELL\nASSEMBL\nEXHIBIT - C\n\n<<<PAGE 11>>>\n\nEXHIBIT - D\nservice Disconnect \"\nPHEV Battery Disconnect Unit Power Distribution\nU6\nU5\nU4\n10 ohm 40 w\nPre Charge Resistor\nTo Heater\n+ Main Power\nAssembly\nResistor\nPre Charge\nMain Power\n+ Charger\n- Charge!\nCharger\nTo\nVehicle\nTo","truncated":false,"body_characters":11911}