{"operation":"document","citation":"09-0066","title":"URS Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-04-30","effective_on":null,"summary":"09-0066 response to URS Corporation concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0066.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0066.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0066","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2009/090066.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nAPR 3 0 2009\n1200 New Jersey Ave. S.E.\nWashington, D.C. 20590\nMr. Andrew Romach\nRegulatory Compliance Manager\nURS Corporation\n1600 Perimeter Park Drive\nMorrisville, NC 27560\nRef. No.: 09-0066\nDear Mr. Romach:\nThis is in response to your February 20,2009 letter requesting clarification of requirements\nin the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 1 80) applicable to design-\ntype testing of lithium ion batteries. The specific requirements you address are contained in\nSection 38.3 of the United Nations Manual of Tests and Criteria and are implemented\nthrough the provisions of fj 1 73.1 85 of the HMR. Specifically, you ask if your configuration\nconstitutes a single lithium ion battery pack or separate lithium ion battery packs.\nWith your letter, you enclose a drawing and describe the configuration of a piece of\nequipment containing two 9-cell lithium ion battery packs. Each battery pack contains 6.4\ngrams equivalent lithium content, and each battery pack is equipped with its own safety\ndevices designed to control voltage and current. The battery packs are connected in parallel\nthrough a printed circuit board located in a plastic tray. Based on the diagram and\ninformation provided, this instrument appears to contain two separate battery packs. You\nshould be aware that effective October 1,2009, the lithium ion batteries described in your\nletter must be of a type proven to meet the applicable requirements in the UN Manual of\nTests and Criteria (see HM-224C, HM-224E, published August 9,2007\n(72 FR 44929)).\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nief, Standards Development\nHazardous Materials Standards\n\n<<<PAGE 2>>>\n\nFebruary 20,2009\nMr. Ed Mazzullo, Director\nOffice of Hazardous Material Standards\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 7th Street, SW\nWashington, DC 20590-0001\nFAX: (202) 366-3012\nDear Mr. Mazzullo:\nI am writing to you to request written clarification about a lithium ion battery\nconfiguration. (See schematic attached on following page.) In discussions with Kevin\nLeary of your staff who reviewed the configuration with the DOT Engineering group, he\nconcluded that the configuration is two separate batteries. I am writing to you for your\nwritten confirmation that this lithium ion battery configuration would be considered two\nseparate batteries.\nAs shown in the attached schematic, each independent battery pack contains nine\nlithium-ion cells wired in a 3S3P configuration. Each pack contains its own \"safety\nboard\" to prevent over and under voltage and overcurrent. The equivalent lithium\ncontent of each pack is 6.4 grams (9 cells x 2.4 Ahr x 0.3). The packs are then connected\nto a pc board located in a plastic battery tray. Traces on the pc board will connect the two\npacks in parallel before they are connected to the instrument.\nPlease confirm that the above-described lithium-ion battery configuration as\nillustrated in the attached schematic would be considered two separate batteries.\nI appreciate your written clarification of this regulatory question.\nSincerely,\nAndrew N. Romach\nRegulatory Manager\nURS Corporation\n\n<<<PAGE 3>>>\n\nPage 2 of 2\n@ @\n8\nA\n@\nA\nI P C B in Battery Tray I 1\nk\n, , Banana Plugs\nInstrument\nFigure 1. Lithium-ion battery Schematic","truncated":false,"body_characters":3445}