ICC Nexergy — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue SE u.s. Department Washington. DC 20590 of Transportation Pipeline and Hazardous Materials Safety Administration AUG 29 2011 Mr. David Brongiel Applications Engineering Manager ICC Nexergy 4 Westbrook Corporate Center, Suite 900 Westchester, IL 60154 Ref. No.: 11-0143 Dear Mr. Brongiel: This responds to your June 9, 2011 letter and subsequent telephone conversation with a member ofmy staffregarding the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a lithium battery pack. In your letter you describe a device that uses three 95 Watt-hour lithium ion battery packs, each ofwhich consists of24, 1.1 Ah cells in a 4S6P configuration. The three lithium ion batteries described in your letter are electrically connected within the device but utilize a micro controller to ensure that the battery pack will not activate during transportation. Specifically, you ask ifthe configuration described in your letter may be considered separate lithium ion batteries under the HMR. No. Since the three battery packs are electrically connected, the configuration described in your letter meets the definition ofa battery as defined in section 38.3 ofthe United Nations Manual of Tests and Criteria. The definition states that a battery means one or more cells which are electrically connected together by a permanent means, including case, terminals and markings. The lithium battery described in your letter exceeds the size requirements outlined in § 172.102, Special Provision 188. This battery pack may be transported in conformance with requirements in §172.1 02, Special Provision 189 by highway or rail only and § 173.185 as Class 9 by highway, rail, vessel and aircraft. I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553. iI1S~ Ben Supko Acting Chief, Standards Development Standards and Rulemaking Division#

Page 2ICCNEXERGY™ Intelligent Power Solutions Ben Supko June 9, 2011 Office of Hazardous Material Standards Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Re: SPMU Lithium Ion Battery Design Dear Mr. Supko: I am writing this letter in regards to our lithium ion battery configuration in a power unit for portable ultrasound stand, known as the SPMU (Stand Power Management Unit). We would like confirmation from PHMSA that our current understanding of the battery configuration meets the requirements for the small battery exception in 49 CFR § 171.102, Special Provision 188 of the U.S. Hazardous Materials Regulations (HMR) and thus is exempt from the requirements of the HMR. Our current understanding is based primarily on the battery definitions in the UN Manual of Tests and Criteria, the regulatory requirements for lithium ion batteries found at 49 CFR § 173.185. SPMU The SPMU is a medical grade Stand Power Management Unit with universal AC input and provides +24VDC output, rated at 275W. The SPMU can be fitted with three optional lithium ion batteries. The SPMU charges the batteries while plugged into AC power. If AC power is removed from the SPMU, the SPMU automatically runs the system off of the battery packs. Lithium Ion Batteries Designed for SPMU ICCNexergy uses three 95Wh lithium ion batteries that consist of 24 1.1 Ah cells in a 4S6P configuration. The batteries are still under development; however, they are being designed to be certified in accordance with the requirements of UN Manual of Tests and Criteria. ICCNexergy will ship the batteries in a carton of three units to the customer, who would like to install the batteries in the SPMU prior to shipping the SPMU. The batteries are installed in the SPMU by securely fastening them to an aluminum plate and held in place with a set of M5 screws. The batteries ship from ICCNexergy in "shut-down" mode, which means the charge and discharge FETs are "off', and the battery is electrically isolated at its connector contacts. The batteries can "wake up" only when all three batteries have been installed in an SPMU, and the SPMU is connected to AC power. 4 Westbrook Corporate Center Suite 900 IWestchester, !L 60154 Phone: 708-836-3800 IFax: 708-836-3801 China Germany USA Mexico Hong Kong Unfted Kingdom#

Page 3If the SPMU is connected to AC power, the SPMU microcontroller will be active and can detect that all three batteries have been installed. Only after the SPMU microcontroller detects that all three batteries have been installed that the SPMU will apply a 12VDC charge voltage to the batteries to "wake" them up. At this time, the battery microcontrollers are now active, but the charge and discharge FETs remain "off", The SPMU and batteries can now communicate via 5MBus. The battery charge and discharge FETs remain "off" until the SPMU provides an operational 5MBus command to the batteries. During preparation for shipment, the SPMU will not have AC power applied so that the batteries will always remain in the "shut-down" mode. The three batteries are electrically connected together within the SPMU. That is, within the SPMU, all three batteries have the battery positive terminal connected together, and all three batteries have the battery negative terminal connected together. The batteries are isolated from each other via the batteries being in shut-down mode and their charge and discharge FETs being "off". A diagram illustrating the SPMU battery system is enclosed with this letter. In summary, we understand our battery design consists of three individual batteries that meet the requirements of the small battery exception found in 49 CFR § 171.102, Special Provision 188 of the U.S. HMR, and, when these batteries are installed in the SPMU and offered for transport, the SPMU also qualifies for the exceptions found in Special Provision 188 (provided the SPMU has not been plugged into AC power). We would appreciate written confirmation from PHMSA that our understanding of these lithium ion battery regulatory requirements is consistent with previous interpretation letters issued by PHMSA on this issue. Thank you very much for taking the time to respond to our letter. Please feel free to contact me with any questions. Sincerely, G~f~.J David Bronglel Applications Engineering Manager ICCl\lexergy dbronq iel@ iccnexe rgy.com 0: 708.316.4428 M: 708.890.2515 4 Westbrook Corporate Center Suite 900 IWestchester, IL 60154 Phone: 708-836-3800 IFax: 708-836-3801 China Germany USA MeKico Hong Kong United Kingdom#

Page 4ICCNEXERGY " Intelligent Power Solu Ions SPMU Concept -------------------------------------~ ,l Westbrook Corpo!att! Center Suite 900 IWestche$ter. IL 6015 ~ Phone. 708-836-3800 IFax: 708·836·38u1 Chin.J GBlTI1sny USA Hong Kong Uni/t!d Kingdom#

Page 5ICC NEXERGY ~ Intelhgent Power Soilltlons SPMU dummy sample with 1 battery installed -+ Westbrook Corporate Canter SUite 900 IWestchester, lL 6015,1 Phone. 708-836-3800 IFax: 708-836-3801 Chin" GennllllY USA Me/lico HOllg Kong U/JI led Kingdom#

Page 6ICCNEXERGY" Intelligent Power Solutions SPMU underside view: 4 Westbrook Corporate Ct3nler SllIl 900 IWestchester, IL 60154 P~,one 708-836-3800 I Fax. 708-836·3801 China GemlBflY USA Me ieo Hong Kong United Kingdom#

Page 7cc EXERGY '~ Intelligent Power Solu1ions SPMU with all three batteries installed End . 4 Westbrook Corporate Center SUite 900 IWestchester. IL 6015:1 Phone: 708·836·3800 IFax: 708-836-3801 Chmil GermRny USA M 1<;CO Hong Kong United Kingdom#