saF'lOctober 26, 2012 

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rv -+rn U.S . EPA 

Office of Pollution Prevention & Toxics y W m 

New Chemicals Program (7405M) ~5 

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h? 1200 Pennsylvania Avenue, NW 

Washington, DC 20460 0 

Attn : Kenneth Moss 

RE: Cobalt Lithium Manganese Nickel Oxide - CAS No. 182442-95-1 

Dear Mr. Moss: 

Saft America Incorporated's new lithium-ion battery manufacturing plant located in Jacksonville, Florida plans in 2013 to begin using Cobalt Lithium Manganese Nickel Oxide, which is the subject of 

a SNUR published in the Federal Register/Vol . 76, No 152/Monday, August 8, 2011/Rules and Regulations beginning on page 47996. The Jacksonville lithium-ion battery plant is a newly-built facility and uses state-of-the-art enclosures for powder handling and mixing, and we believe employees will not be over-exposed to the substance. Saft would therefore like to pursue using the NCEL of 0.1 mg/m3 as an 8-hour time-weighted average as an alternative to the § 721 .63 respirator. 

As we have previously discussed, Saft is seeking EPA's approval of our proposed procedures for determining employee exposure to CoLiMnNiO. Saft would like to perform employee exposure monitoring to make sure no one working with the substance is exposed to it at levels above the CoLiMnNiO NCEL. As we discussed, EPA considers the substance to be completely reacted (cured) 

once the substance reaches the finished electrode stage. This means that employees not wearing respiratory protection and working with the powder to make cathode slurry and employees applying the slurry to the substrate material during the electrode manufacturing process must not be exposed 

to CoLiMnNiO at levels equal to or exceeding 0.1 mg/m3. 

Since there are no established specific procedures for monitoring for this substance, Saft proposes to monitor employee exposure to CoLiMnNiO using the same industrial hygiene protocols, filters, 

pumps, and flow rate normally used for metals (cadmium, cobalt, lead, nickel) exposure monitoring. That would be a 0.8 Ng MCE filter appropriately attached to a personal air pump set at a flow rate of 2 liters per minute . 

Calculating exposures to the substance would take into consideration that the CoLiMnNiO material is 

a layered nickel oxide with substitution of nickel with cobalt and manganese in the lattice and having 

a specific molecular structure and weight . The Lit NixMnyCoz02 substance exists in several popular chemical formulations. The most common, and the one we will use, is where x, y, and z in the formula equals 0.33. The calculation for the molecular weight (95.886) based on the empirical formula Li(1)Ni(0 .33)Mn(0.33)Co(0 .33)02 would be: 

6.941 +58.693 X0 .33 + 54.938 X 0.33 + 58.933 X 0.33 + 15 .999 X 2 = 95.886 

Li Ni Mn Co O 

p. 1 

1OWSS-0yg7 

Saft America Inc. 

711 Gil Harbin Industrial Blvd., Valdosta, GA 31601 CONTAINS NO CB! 

Tel: (229) 247-2331 Fax: (229) 245-2810 
Mr. Ken Moss - Page 2 

Exposure to the material could be determined by calculations based on the cobalt, nickel and/or 

manganese fractions of the molecule. For example; using the nickel fraction for determining 

exposure to the whole molecule, the calculation would be: 58.693 X 0.33 = 95.886 X 100 = 20.2% . Since the nickel fraction represents 20 .2% of the mass of the molecule, one would multiply the nickel 

exposure monitoring result (in micrograms or milligrams) by 4.9505 to get the weight value 

representative of the molecule . . .that is, 20.2% X 4.9505 = 100%. The value obtained for the whole molecule in terms of milligrams per cubic meter of air would then be compared against the NCEL value (0.1 mg/m). Similar calculations could be performed for the cobalt and/or manganese fractions . 

Following our discussion during which you told me EPA would require third party verification of Saft's proposed monitoring procedure and exposure calculation from an AIHA-accredited laboratory, I procured a sample of the material from the manufacturer and sent it to Travelers Industrial Hygiene Laboratory in Windsor, Connecticut . Please note that the sample that was sent to Travelers for evaluation was taken directly from a product container. 

Attached is a letter from Mr. Thomas Surveski, Quality Assurance Manager with the well-known, respected and AIHA-accredited Travelers Laboratory. In his letter, Mr. Surveski explains that the material is compatible with the standard digestion procedure normally used for the analysis of various metals and metal oxides and is also compatible with the laboratory's standard ICP procedure which is used for metal analyses. As Mr. Surveski states, all three metals (cobalt, manganese, and nickel) 

were recovered at levels exceeding 95% of their expected values with cobalt and nickel being 

recovered in excess of 97% or their expected values. In order to add additional confidence to the reported results, Mr. Surveski recommends analyzing employee exposure air samples for both cobalt and nickel and using the cobalt and nickel results for calculating exposure to the CoLiMnNiO molecule. Analyzing employee exposure air samples for cobalt and nickel is the procedure Saft would implement in order to demonstrate that employee exposures, if any, were indeed coming from the CoLiMnNiO material and no other sources. 

Saft agrees with Travelers' finding that monitoring employee exposures to airborne CoLiMnNiO using 

a 0.8 Ng MCE filter appropriately attached to a personal air pump set at a flow rate of 2 liters per minute, obtaining cobalt and nickel results using standard digestion and ICP analytical procedures, 

and converting the cobalt and nickel results to CoLiMnNlO (Li NI0.33 Mn0.33 CO0.33 02) is a viable 

way of determining actual employee exposures for comparison with the NCEL for this material . 

Please let me know if this approach is acceptable to EPA. 

Sincerely, 

Chip Wildes 

Saft America Incorporated 

Environmental Manager 

C: Mr. Thomas Surveski -Travelers Laboratory 

Mr. Allen Gilley-MARSH Risk Consulting 

SaftAmerica Inc . 

711 Gil Harbin Industrial Blvd., Valdosta, GA 31601 

Tel: (229) 247-2331 Fax: (229) 245-2810 
TRA1/ELERS J~ 

William 0. Wildes, Jr. 

Environment, Safety and Recycle Programs Manager 

Saft America Incorporated 

71'I Gil Harbin Industrial Boulevard 

Valdosta, GA 31601 

William, 

Thomas Surveski 

QA Manager 

Industrial Hygiene Laboratory 

AIHA Laboratory ID 100126 

90 Lamberton Rd. 

Windsor, CT 08095 

Phone Number 860-687-7414 

tsurvesk@travelers .com 

Travelers Industrial Hygiene Laboratory has completed its' analysls of the (Li Nio.33Mno.33 Coo.33 OZ) material that you 

submitted to us. 

Using our standard microwave digestion procedure, approximately 30 milligrams of the submitted material was 

digested In aqua regia. This digestion procedure Is used for the vast majority of the Industrial hygiene air samples 

that we analyze for various metals and metal oxides. 

The digested sample was analyzed by ICP for Nickel, Manganese and Cobalt using the laboratory's standard ICP 

procedure. All three of these metals were recovered at levels exceeding 95% of their expected values . Nickel and 

Cobalt were both recovered in excess of 97% of their expected values . The table below summarizes our results. 

"Expected" Weight % Weight % in Percentage of 

In the "Mixture" the "Mixture" "Expected" Found 

(calculated from the found by by 

empirical formula: Travelers Travelers 

Element (LI NIo.a3 Mno.33 C00.33 02) ICP Analysis ICP Analysis 

Nickel _ 20.28 20.07 99.0 

Manganese 18 .98 18.18 95.8 

Cobalt 20.36 19.80 97.2 

If we can assume that the only source of Cobalt, Nickel or Manganese Is the (LI NIo.3., Mno.33 Coo.33 02) Material, 

any one of the three metals appear to be a suitable candidate for monitoring the exposure to the mixture. 

Since the recovery of the Cobalt and Nickel are both slightly higher than the Manganese recovery, using either the 

Cobalt or Nickel appears to be a better choice. 

Cobalt and Nickel are present In the bulk material at essentially the same percentage and their molecular weights are 

very similar. The method reporting limit (MRL) for the actual (Li Nio.33 Mno3., Coo.33 02) material will be approximately 

5 micrograms per air sample if quantified using either Cobalt or Nickel . If we collect air samples at the normalv 

recommended 2 liters per minute flow rate, the table below lists the MRL, In milligrams per cubic meter (mg/m ) for 

various sampling scenarios. 

Sampling Time 

Minutes 

Air Volume Collected 

2LPM 

Approx. Sample M RL 

LiNIo.33Mno.33C00.330z 

1_5 STEL 30 0.17 

120 _ 240 0.021 

240 480 0.010 

480 960 0,0052 
To add additional confidence to the reported results, you may want to consider analyzing the air samples for both 

Cobalt and Nickel and reporting the (Li Nio33 Mno.33 Coo.33 OZ) results twice, once based on the Cobalt value and 

again based on the Nickel value. If one of the reported (Li NIo.33 Mno a Coo.33 Oz) results is significantly larger than the 

other, then another source of Cobalt or Nickel (whichever result was higher) other then the (Li Nio.33 Mno.33 Coo.33 Oz) 

must be present. 

I would anticipate the results would be reported something similar to : 

(LI NIo.33 Mno.33 Coo.33 Oz) based on Total Nickel 

and/or 

(LI NIo .33 Mno.33 Coo 33 Oa) based on Total Cobalt 

Hopefully you will agree with our conclusion that as long as no other source of Cobalt and/or Nickel are present in the 

sampling environment analyzing air samples for Cobalt and/or Nickel and converting those results to (Li NI0.33 Mno.33 

CO0.33 OZ) is a viable way of quantifying air samples. 

Thomas Surveski 

QA Manager 

Travelers IH Laboratory