{"operation":"document","citation":"23-0088","title":"Wabtec Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2023-12-12","effective_on":null,"summary":"23-0088 response to Wabtec Corporation concerning 173.185.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0088.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0088.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0088","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/78101/230088.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDecember 12, 2023\nVincent M. Melillo\nWabtec Corporation\n2901 East Lake Road\nErie, PA 16531\nReference No. 23-0088\nDear Mr. Melillo:\nThis letter is in response to your October 5, 2023, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to lithium batteries. You\nprovide schematics for a lithium ion battery pack design that weighs approximately 1600 lbs,\nwith a completely enclosed fiberglass-resin composite casing comprised of “end cap” housings\nand “covers” with a nominal thicknesses of 0.20 inch and 0.13 inch respectively. The end caps\nare mounted and sealed to the ends of the covers at each end with an aluminum chill plate and\nthe covers are mounted and sealed against the top and bottom faces of the aluminum chill plate.\nWhen fully assembled, the battery pack is sealed. You ask for confirmation that the battery pack\ndesign described above, and illustrated in the schematics you provided, would meet the\nrequirement in § 173.185(b)(5) to have a “strong, impact-resistant outer casing.\"\nBased on the information in the schematics you provided, it is the opinion of this Office that the\nbattery pack design meets the performance standard of a strong, impact-resistant outer casing as\nspecified in § 173.185(b)(5).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nCardeez\n23-0088\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Interpretation and Application of 49 CFR § 173.185(b)(5)\nDate: Friday, October 6, 2023 10:52:37 AM\nAttachments: image001.png\nWABTEC BATTERY PACK DESIGN (97 & 83 kWH) OVERVIEW - 2023-10-05.pdf\nHello Alice,\nPlease see the below interpretation request. Let us know if you need anything.\nSincerely,\nJanaye\nFrom: Melillo, Vincent \nSent: Thursday, October 5, 2023 4:22 PM\nTo: INFOCNTR (PHMSA) \nCc: Perumal, Durai \nSubject: Interpretation and Application of 49 CFR § 173.185(b)(5)\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nTo Whom This May Concern at the Hazardous Materials Information Center,\nWabtec Corporation kindly requests an interpretation of 49 CFR § 173.185(b)(5) and the applicability\nof this clause to our battery pack design. Our Li-ion battery pack is designed to be incorporated into\nFreight and Diesel Locomotives, creating Battery Electric and Hybrid Locomotives.\nAn interpretation of 49 CFR § 173.185(b)(5) would be helpful due to our desire to transport our Li-\nion battery packs to customer service facilities as new replacement packs for our customers’ battery\nelectric locomotives (We understand that used/defective/damaged batteries have different\npackaging requirements).\nWe’re working with packaging companies to develop dunnage to safely ship our battery pack.\nHowever, we were recommended by consultant Lion Technology (Located in Sparta, NJ) to acquire\nan interpretation of 49 CFR § 173.185(b)(5) and whether our battery pack meets the requirements\nof this clause, specifically the “strong, impact-resistant outer casing” requirement.\nI’ve included an overview of our battery pack design in the presentation attached to this email. If you\nhave any questions about the design specifics or require additional images for clarity, please do not\nhesitate to contact me.\nLastly, if you could provide approximately how long an interpretation may take, that would allow us\n\n<<>>\n\nto design our dunnage and plan validation testing, if the interpretation requires.\nVincent M. Melillo\nLead Energy Storage Packaging Design Engineer\n2901 East Lake Road\nErie, PA 16531\nThis email and any attachments are only for use by the intended recipient(s) and may contain legally privileged, confidential, proprietary or otherwise\nprivate information. Any unauthorized use, reproduction, dissemination, distribution or other disclosure of the contents of this e-mail or its attachments\nis strictly prohibited. If you have received this email in error, please notify the sender immediately and delete the original. Neither this information block,\nthe typed name of the sender, nor anything else in this message is intended to constitute an electronic signature unless a specific statement to the\ncontrary is included in this message.\n\n<<>>\n\nWABTEC BATTERY PACK OVERVIEW\n97 kWh / 83 kWh\nVINCENT M. MELILLO\n10/05/2023\nThe information contained in this document may contain confidential, proprietary and/or privileged material of either Wabtec Corporation or\none of its subsidiaries. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by\npersons or entities other than the intended recipient is prohibited unless authorized in writing. If you have received this document in error,\nplease contact the sender and delete the material from any system and destroy any copies.\n\n<<>>\n\nBattery Pack Designs - Overview\n• Wabtec has designed the following battery packs for our next generation of locomotives - Battery Electric Locomotives (BELs) and Hybrid Locomotives\n• Height and width of both battery packs are consistent– 97 kWh Battery Pack is approximately 7” longer than 83 kWh Battery Pack\n97 kWh Battery Pack 83 kWh Battery Pack\n66”\n59”\n48”\n10”\nConfidential & Proprietary\n2\n\n<<>>\n\nBattery Pack Designs - Overview\n• Wabtec has designed the following battery packs for our next generation of locomotives - Battery Electric Locomotives (BELs) and Hybrid Locomotives\n97 kWh Battery Pack 83 kWh Battery Pack\nConfidential & Proprietary\n3\n\n<<>>\n\n49 CFR § 173.185(b)(5)\n• Interpretation of 49 CFR § 173.185(b)(5) and whether Wabtec battery packs meet the requirements will\nimpact the design of dunnage/packaging for new battery pack shipments\n• 49 CFR § 173.185(b)(5) states:\nLithium batteries that…\nweigh 12 kg (26.5 pounds) or more have a strong, impact-resistant outer casing ✓ (97 kWh = 1600 lbs; 83 kWh = 1400 lbs)\n? (Wabtec requires Interpretation)\nmay be packed in strong outer packagings; in protective enclosures (for example, in fully enclosed or\nwooden slatted crates); or on pallets or other handling devices, instead of packages meeting the UN\nperformance packaging requirements in paragraphs (b)(3)(ii) and (iii) of this section. Batteries must be\nsecured to prevent inadvertent shifting, and the terminals may not support the weight of other superimposed\nelements. Batteries packaged in accordance with this paragraph may be transported by cargo aircraft if\napproved by the Associate Administrator.\n• Please note: Wabtec does not intent to transport battery packs by aircraft (at this time)\nConfidential & Proprietary\n4\n\n<<>>\n\n“Outer Casing” of Battery Pack\n• The “End Cap” housings and the “Covers” of are made of a tough fiberglass-resin composite with a nominal thicknesses of 0.20” and 0.13” respectively.\n• The End Caps are mounted and sealed to the ends of the Covers at each end of the aluminum chill plate; the Covers are mounted and sealed against the top and\nbottom faces of the aluminum chill plate\n• When fully assembled, the battery pack is sealed and rated to IP67 (Test Results Pending)\nCOVER\n(TOP)\nEND CAP\n(EXHAUST)\nEND CAP\n(CONTROL)\nALUMINUM\nCHILL PLATE\nCOVER\n(BOTTOM)\nConfidential & Proprietary\n5\n\n<<>>\n\nValidation Testing\n• Wabtec’s Battery Pack Validation Plan includes, but is not limited to, the following Validation Tests that will\nvalidate the mechanical integrity of the Battery Pack:\nTEST NAME DUT STATUS\nUN 38.3 Transport Test* MODULE COMPLETE, ANALYZING RESULTS\nImpact Test (IAW IEC 62619) MODULE SCHEDULED\nService Height Drop Test (IAW SAE J2929; J2464: 1m) BATTERY PACK COMPLETE, ANALYZING RESULTS\nCorner Drop/Bump Test (IAW IEC 62619) BATTERY PACK SCHEDULED\nEnvironmental Qualification Testing (IAW IEC 61373) BATTERY PACK SCHEDULED\nTemperature Extremes (IAW 62619) MODULE SCHEDULED\nTemperature Cycling (IAW Wabtec Internal Environmental Standards) BATTERY PACK SCHEDULED\nVarious Thermal Runaway Tests\nCELL\nMODULE\nBATTERY PACK\nIN PROCESS\nIngress Protection (IP67 - IAW IEC 60529) BATTERY PACK SCHEDULED\n*Successful UN 38.3 Testing is required for battery pack transport\nConfidential & Proprietary\n6\n\n<<>>\n\nWabtec Battery Pack Images\nConfidential & Proprietary\n7\n\n<<>>\n\nWabtec Battery Pack Images\nConfidential & Proprietary\n8\n\n<<>>\n\nWabtec\nCORPORATION","truncated":false,"body_characters":8791}