# saF'lOctober 26, 2012 

# Poy-2 6(7 ills *10 

# C131;2 ::; c--) -v M 

### -an rv -+rn U.S. EPA Office of Pollution Prevention &Toxics y W m New Chemicals Program(7405M) ~5 o 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 performemployee 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 CoLiMnNiOat 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 flowrate 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 flowrate 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 X2 = 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) 245-2810Mr . 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 froman AIHA-accredited laboratory, I procured a sample of the material fromthe 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 froma product container. Attached is a letter fromMr. 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 CoLiMnNiOmaterial 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 flowrate 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~

William0

. 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. Usingour standard microwave digestion procedure, approximately 30milligrams ofthesubmitted 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 ICPfor Nickel, Manganese and Cobalt using the laboratory's standard ICP procedure

. All three ofthese metals were recovered at levels exceeding 95% oftheir 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 fromthe found by by empirical formula: Travelers Travelers Element (LI NIo.a3 Mno.33 C00.33 02) ICPAnalysis ICP Analysis Nickel _ 20 .28 20.07 99.0 Man ganese 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

.3302) Material, any oneof 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, usingeither 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 ifquantified 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 0,0052To add additional confidence to the reported results, you maywant to consider analyzing the air samples for both

Cobalt and Nickel and reporting the (Li Nio33Mno .33 Coo .33OZ) results twice, once based on the Cobalt value and again based on the Nickel value. Ifoneofthe reported (Li NIo .33 Mnoa 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 .33Coo.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

.33Coo33 Oa) based on Total Cobalt Hopefully youwill agreewith 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 wayof quantifying air samples .

Thomas Surveski QA Manager Travelers IH Laboratory