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June 26, 2012 U.S. EPA Office of Pollution Prevention & Toxics New Chemicals Program(7405M) 1200 Pennsylvania Avenue, NW Washington, DC 20460 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 RegisterNol . 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 . N O

If approved by EPA, Saft will perform employee exposure monitoring to make sure no one working with the substance is exposed to it at levels above the NCEL. During our telephone discussions regarding the SNUR, you explained that EPA considers the substance to be completely reacted (cured) once the substance reaches the finished electrode stage. This means that employees working with the powder to make cathode slurry and those applying the slurry to the substrate material to make electrodes must not be exposed to CoLiMnNiO levels exceeding 0.1mg/m3. Since there are no established specific procedures for monitoring for this substance, Saft proposes to monitor 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 Li1NixMnyCoz02 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



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Saft America Inc. 711 Gil Harbin Industrial Blvd., Valdosta, GA 31601 Tel : (229) 247-2331 Fax: (229) 245-2810To calculate an exposure based on the nickel fraction, 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 could 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) . This calculation could be similarly performed based on the lithium, cobalt, or manganese fractions . Please let me knowif this approach is acceptable to EPA. 

### Sincerely, 

# G'Gy~~l~ ~--, Chip Wildes Saft America Incorporated Environmental Manager Phone: 229-245-2898 Email : chip .wildes@saftbatteries .com

Saft America Inc. 711 Gil Harbin Industrial Blvd., Valdosta, GA 31601 Tel : (229) 247-2331 Fax: (229) 245-2810