{"operation":"document","citation":"10-0135","title":"Naval Surface Warfare Center Energy Power & Interconnect Technologies Division — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-08-02","effective_on":null,"summary":"10-0135 response to Naval Surface Warfare Center Energy Power & Interconnect Technologies Division concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0135.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0135.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0135","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100135.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department ofTransportation Pipeline and Hazardous Materials\nSafety Administration\nAUG 2 2010\n1 200 New Jersey Ave, SE\nWashington, D.C. 20590\nMr. Mark Tisher\nCrane Division\nNaval Surface Warfare Center\nEnergy Power & Interconnect Technologies Division\n300 Highway 361, Bldg. 3235 GSX\nCrane, IN 47522-5001\nRef. No.: 10-0135\nDear Mr. Tisher:\nThis responds to your June 10, 2010 letter and subsequent conversation with a member of my\nstaffrequesting clarification of the requirements in the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180) applicable to design-type testing of lithium ion batteries. Specifically,\nyou ask if a device containing a lithium battery composed of either four or seven modules must\nbe tested in accordance with the UN Manual ofTests and Criteria when the cells and the\nmodules are of a type proven to meet each ofthe appropriate tests in accordance with the UN\nManual of Tests and Criteria.\nIn your letter, you state the two configuration ofthe battery in the device differ only in the\nnumber ofbattery modules contained within the battery. Specifically, one battery contains four\nmodules and the other contains seven. Each battery module containing 446.1 grams of lithium\nconsists of43 DD cells connected in series. The cells contained in the module, and the module\nare both ofa type proven to meet each of the applicable tests described in Section 38.3 of the\nUN Manual of Tests and Criteria. The modules remain electrically isolated during transport and\nthe battery modules can only be connected after a deliberate sequence expected to occur after\ntransportation has ended.\nProvided no electrical connections exist between the modules, the configurations described in\nyour letter would constitute individual batteries contained in equipment and would not require\nadditional testing. .\nI hope this answers your inquiry. If you have further questions, please do not hesitate to contact\nthis office.\nSinc;:l'~\nCharles E. Betts\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nDEPARTMENT OF THE NAVY CRANE DIVISION\nNAVAL SURFACE WARFARE CENTER 300 HIGHWAY 361 CRANE INDIANA 47522-5001\nlear:q\n~/13·/~S\nW%cum '-&.tferie.s\nlO- 0135\nIN REPLY REFER TO:\n8020\nSer GXS/l0031\n10 Jun 10\nFrom: Commander, Naval Surface Warfare Center, Crane Division\nTo: U.S. Department Of Transportation, PHMSA Office ofHazardous Materials Standards,\nAttn: PHH-I0, East Building, 1200 New Jersey Avenue, SE, Washington, DC\n2059(4)001\nSubj: REQUEST FOR INTERPRETATION OF LITHIUM BATTERY\nRef: (a) UN Recommendations on the Transport of Dangerous Goods, Manual ofTests and\nCriteria\n1. The US Navy is currently developing an application using a lithium primary battery and is\nseeking an interpretation ofwhether the device with the lithium battery installed in the\nequipment can be shipped under an existing approval or if a new approval is required and\ntherefore additional testing in accordance with reference (a).\n2. There are two battery configurations differing only in the number of battery modules. One\nconfiguration uses four of the modules and the other uses seven of them. The battery module\nmanufacturer is also the cell manufacturer, and the cell has been tested and passed testing in\naccordance with reference (a). The manufacturer of the battery module has obtained approval to\nship the battery module by similarity to another of its products that has also been tested and\npassed in accordance with reference (a). For the battery module construction, the cells are semi\npotted and attached to a non-conductive baseplate. The electrical connection is made through a\nrigidly mounted connector and insulating material covers the entire outer surface to protect from\nexternal shorting. In addition, every cell has an integral electrical fuse to protect from short\ncircuits and an integral diode. The battery modules contain 446.1 grams of lithium and are\nshipped as Class 9 material.\n3. For transportation ofthe device, the battery housing would be an aluminum cylinder. The\nbattery module baseplates are bolted to an aluminum plate which is circumferentially bolted to\nthe inside ofthe battery housing to prevent movement. The battery housing has endplates\ninstalled with one ofthe endplates incorporating a burst disk that operates at 190 PSI. The\nbattery modules are individually wired to an electronics circuit card. The battery modules are\nelectrically isolated during transport and the battery modules would only be electrically\nconnected after a deliberate sequence ofmultiple events that would only be expected to occur\nduring deployment.\n4. The outer packaging is a MK 714 MOD 1 Shipping Container (Drawing #6213165, NSN\n#8140-01-342-6883). It was POP tested in January 1997. The report number is\nDODPOPHMlUSAlDODINADTR95011A. A copy ofthe report can be provided. It consists of\nwelded, extruded aluminum base and cover assemblies. The cover is secured to the base by 16\nover-center latches. Leakage integrity is provided by a rubber sealing gasket located along the\n\n<<<PAGE 3>>>\n\nSubj: REQUEST FOR INTERPRETATION OF LITHIUM BATTERY\nbase closure flange. Shock mitigation is provided by two welded cradles supported by\ne1astomeric shock mounts. POP testing has certified similar sized devices up to a total gross\nweight of 559kg (l,1233Ibs), with a HaziClass up to 1.1D. There are no external connections to\nthe battery circuits once the device is assembled in the shipping configuration, therefore external\nshorting is not possible.\n5. Please advise if it is acceptable to commercially ship this piece of equipment containing a\nlithium battery composed ofup to seven battery modules as Class 9 Hazardous Material as\ncurrently tested, in accordance with reference (a), at the battery module level.\n6. Crane Division, Naval Surface Warfare Center point of contact is Mr. Mark Tisher, Energy,\nPower & Interconnect Technologies Division, DSN 482-5912, or commercial 812-854-5912, or\nE-mail atmark.tisher@navy.mil.\nGsx\nDigitally signed by\nWERNERKYLE.R.123032860S\nON: c=US, o=U,S. Government..\n,ou=:-4>oD. DU:::PKI, ou:::::USN.\nc~=WERNER.KVlE.R.123032860\nS\nOate:lOl\"0.06.1017:1l:04\n-04'00'\nKYLE WERNER\nBy direction\n2","truncated":false,"body_characters":6187}