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Interpretation Response #13-0124 ([URS corporation] [Mr. Andrew N. Romach])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: URS corporation

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

February 25, 2014

 

Mr. Andrew N. Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Suite 400
Morrisville, NC 27560

Reference No.: 13-0124

Dear Mr. Romach:

This is in response to your June 14, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask several questions pertaining to § 173.189, concerning the requirements that apply when shipping UN3292, Batteries containing sodium.   

Your questions are paraphrased and answered as follows:

Q1.  Section 173.189(d) provides the requirements for batteries containing liquid sodium and paragraph (d)(4)(iii) states that no other hazardous materials, with the exception of cells containing sodium, may be loaded in the same transport vehicle or freight container.  Can batteries containing liquid sodium be shipped together in the same transport vehicle or freight container with batteries containing sodium in solid form?

A1.  The answer is yes.  Batteries containing liquid sodium and batteries containing solid sodium are assigned the same identification number and proper shipping name.

Q2. Section 173.189(e) states vehicles, machinery and equipment powered by sodium batteries must be consigned under the entry “Battery-powered vehicle or Battery-powered equipment.” The requirements for “Battery-powered vehicle” or “Battery-powered equipment” are provided in § 173.220.  Would a vehicle, machinery, or equipment powered by a battery containing liquid sodium (where the battery is the only power source) be eligible for the exception in § 173.220(c) and shipped as “not-restricted” when transported by rail, highway or vessel?

A2.  Yes,  if all of the requirements described in § 173.220(c) are satisfied, the vehicle, machinery, or equipment powered by a battery containing liquid sodium is not subject to the requirements of the HMR except for those described in § 173.21.  

Q3.  May vehicles, machinery, or equipment powered by batteries containing liquid sodium that are excepted from further requirements of the HMR in accordance with § 173.220(c) be transported in the same transport vehicle or freight container as disconnected or uninstalled batteries containing liquid sodium?

A3.  Yes, provided the vehicles, machinery, or equipment powered by batteries containing liquid sodium contain no additional materials meeting the definition of a hazardous material.

Q4.  If a sodium battery installed in a vehicle, machinery, or equipment where the sodium battery is not the only power source (the vehicle, machinery, or equipment is also powered by liquid or gas fuel in a hybrid application), what is the proper shipping name?

A4.  As stated in § 172.102(c), Special Provision 134, the following proper shipping names would most appropriately describe a sodium battery installed in a hybrid application: “Vehicle, flammable gas powered”, “Vehicle, flammable liquid powered”, “Engine, internal combustion, flammable gas powered”, or “Engine, internal combustion, flammable liquid powered.”  

Q5.  Could a sodium battery contained in a battery/fuel powered hybrid application be shipped as “not restricted” for transportation by motor vehicle or rail car if the requirements of the exception in § 173.220(c) are met, as well as the requirements under § 173.220 (h)(1) for the fuel, even though such a scenario is not listed in § 173.189(e)?

A5.  The answer is yes.  The proper shipping names described in (A4) above, applicable to sodium batteries installed in hybrid applications reference § 173.220 for packaging exceptions.

Q6.  When shipping batteries containing liquid sodium; if § 173.189(d)(2) states that no battery may be offered for transportation if the temperature at any point on the external surface of the battery exceeds 55 °C (130 °F), then why is there a separate less restrictive limit described in § 173.189(d)(4)(ii) stating that adequate ventilation and/or separation between batteries must be provided to ensure that the temperature at any point on the external surface of the battery casing will not exceed 240 °C (464 °F) during transportation?

A6.  Section 173.189(d)(2) addresses the surface temperature of a battery when offered for transportation.  Section 173.189(d)(4)(ii) addresses the concern of multiple batteries containing liquid sodium transported in close proximity with each other which could result in one battery heating another to an even higher temperature.  In this case, paragraph (d)(4)(ii) requires ventilation and/or separation to prevent heat generated from multiple batteries from reaching a dangerous temperature.   

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.189, 173.220

Regulation Sections

Section Subject
173.189 Batteries containing sodium or cells containing sodium
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery