Trojan Battery Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Special Programs Research and Administration JAN 1 3 1999 Ms. Diane H. Kennedy Trojan Battery Company Ref. No. 98-0358 12380 Clark Street Santa Fe Springs, CA 90670 Dear Ms. Kennedy: This is in response to your letter dated November 11, 1998, batteries classified and described as "Rl, Environmentally regarding packaging requirements of lead pasted plates for under the Hazardous Materials Regulations (HMR; 49 CER Parts hazardous substances, solid, n.o.s. (Lead), 9, UN3077, PGIII, " 171-180). Specifically, you ask if the container described in your letter meets the definition of a closed bulk bin. A non-specification closed bin, as authorized under § 173.240, must be an enclosed packaging that is tough, firm and durable (i.e., strong), constructed so that its contents cannot pass through (i.e., completely enclosed), and which meets other applicable requirements of § 173.24 and § 173.24b. The container described in your letter would appear to meet the packaging requirements in § 173.240 (c). I hope this satisfies your request. Sincerely, Pon Seet • Iransportation Regulations Specialist Office of Hazardous Materials Standards • 173.240#

Page 2BAH 98-0358 §173.240 $103.240 Trojan November 11, 1998 James E. Jones Chief, Approval Branch 400 7% Street Southwest Room 8436 DOTRSPADHM - 32 15 Washington, DC 20590 Re: Request for approval of an alternative packaging scheme. '3 Dear James E. Jones: !!. Trojan Battery Company is requesting approval of a proposed packaging scheme for shipping of lead pasted plates. Trojan Battery Company is a battery manufacturer which specializes in deep cycle We also manufacture lead pasted plates which are an essential part of the battery manufacturing process. Presently we package our plates for shipment according to 49 CFR $73.240 for bulk packaging of hazardous materials other than Class 1 and Class 7. We use packaging as specified in (d)(1)ii) Flexible. The proper shipping name for the plates is: RQ, Environmentally Hazardous Substances, solld, n.o.s. (Lead), 9, UN 3077, PGIII Our proposed packaging is fully described on the attached document with photos demonstrating and describing each step in the proposed packaging process. At completion of the packaging process the pallet of product weighs between 1050-1700 pounds. We are proposing this packaging scheme because lead pasted plates are considered a low hazard material. Using the proposed packaging scheme assures that all the material is contained within the package. ocus hs rater cone, lease do no tet to cat red anything are, or it you in te noted on this letter at the California location. Very Truly Yours, Diane H. Kennedy Director, Environmental Affairs Enclosure: Proposed Packaging of Plates Procedure, Photos of the packaging process. SANTA FE SPRINGS, CALIFORNIA 90670 12380 CLARK STREET LITHONIA, GEORGIA 30038 5174 MINOLA DRIVE (562) 946-8381 FAX (562) 941-6038 946-1751 FAX (770) 981-7717 (770) 981-8674#

Page 3PROPOSED OPERATING PROCEDURE PAGE 1 OF 1 The Better Ballery Trojan DOC. NO.: SHIP102 Proposed Packaging of Plates DATE: 10/22/98 REVISION: B ORIGINAL RELEASE DATE: TECHNICAL ORIGINATOR: July 13, 1998 REVISION ORIGINATOR: Kelly Smith DOCUMENT RELEASE BY: Chad Bentley, Paul Martinez COMMENT: Initial release of new standard operating procedure. Diane Kennedy, Philip Baker 1.0 PURPOSE Packaging for our Plates with approval from the applicable State/ Federal regulatory The purpose of this proposed procedure is to provide the key components of agencies. 2.0 tacilities of Trojan Battery Company to ensure that packaging and hazardous material This Proposed Operating Procedure will apply to the Ann Street and Clark Street that the Environmental Technician/Engineer be familiar with the procedure and standaras once approved, would be maintained throughout our process. This requires determine that all requirements are being met by periodically auditing this process. 3.0 MATERIALS 3.1 Heavy Duty Pallet: 42 × 42, 7,000 Ibs load capacity, COST $13.50 ea 3.2 Plywood: size 43½ × 43½, COST $6.34 ea 3.2 2 Corrugated Trays: 41½ × 34½ × 3½, 78 Ibs, COST$1.48 ea ($2.96 per pallet) 3.3 Banding: 600 Ibs (hand-banding),$0.020 ft ($0.40 per pallet) 3.3 Stretch Film: 115 gauge, COST $0.030 ft ($0.50 per pallet) 3.4 Honeycomb: size 2½ W × 40L, 13 strips, COST $0.29 ea strip ($3.77 per pallet) 4.0 PROCEDURES 4.1 Proposed Plates Packaging Procedure would fall under Class 9 - Environmentally Hazardous Substance; (RQ) Environmentally Hazardous Substances, nos, 9, UN3077, PG 111 4.2 Stage 42 x 42 size pallet, load capacity 7,000 Ibs., on top of 43½ × 43½ size piece of plywood 4.3 Place a 41½ X 34½ × 3½, corrugated tray on bottom of pallet. 4.4 Stack plates into corrugated tray (do not exceed load capacity of pallet) 4.5 Fill in "spaces" with 13 strips of 2½ W × 40L size honeycomb 4.6 Seal with another corrugated tray 4.7 Apply Class 9 Hazard Label 4.8 Apply Correct Part Number on top of box 4.9 Double band plates to pallet with 600 Ibs of hand-banding 4.10 Plastic rap on Liberty Machine or by hand, plastic should wrap 7 times around pallet 4.11 Plates are ready for shipment BONES FROM BATER CAN Sad To pis alert aton, puBies, or prints prite wit pro lit#

Page 4Step # 1 Set your plates in 1 corrugated tray, on a plywood pallet with 7,000 Ibs load capacity.#

Page 5Step #2 Fill in with Honeycomb.#

Page 6Step # 3 Cover with the second corrugated tray.#

Page 7...... Step #4 Apply Class 9 label to the top of the box.#

Page 8Step # 5 Write correct part # on top of the box.#

Page 9Step # 6 Double band (with 600 lb. banding) around the box.#

Page 10Step #7 On the Liberty machine plastic wrap (with 115 gauge plastic wrap 7 times.#

Page 11Step # 8 After completed and machine wraps around 7 times.#

Page 12Step #9 Task Completed.#

Page 13= : Bonus Picture.#