INITIAL REVIEW ENGINEERING REPORT
PMN: 11-0274 Standard Review Draft 5/11/2011

ENGINEER: Macek \ BCS PV (kg/yr): 1,000

**Revision Notes / Assessment Overview:**

The FOCUS ready draft version of the IRER has been revised to incorporate:

- additional review of information provided by the
submitter in the submission

- supplemental information provided on May 5, 2011 (Letter from Nicholas Caparco of Lockheed Martin to Jim Alwood and Greg Macek of the USEPA) and

- information obtained through phone conversations between Nicholas Caparco and Greg Macek on May 4 and May 10, 2011.

Key changes to the previous version of the engineering report
include:

1. Revision of the assessed Lifecycle of the PMN chemical to include the following 2 stages:

- Manufacturing and Processing at Lockheed Martin facility - Incorporation into Article at Lockheed Martin facility Note: The submitter indicated 100% site-limied use| |

2. Use of submitter's monitoring data for lead exposures as a basis for estimating inhalation exposures.
3. Refinement of the media of release determinations for the
various release sources based on additional discussions
with the submitter

4. Assessment of potential water release based on additional
review and discussions with the submitter
5. Addition of information on PPE use 6. Included results of submitter's wastewater monitoring 7. Added NPDES# for the POTW that receives wastewater from the Lockheed Martin facility.

SUBMITTER: Lockheed Martin

USE: Piezoelectric ceramics used for active and passive underwater acoustic systems. Consolidated Set: P-11-0270, P-11-0271, P-11-0272, P-11-0273, and P-11-0274.

OTHER USES:MSDS: Yes Label: No

Gen Eqpt: Safety glasses are recommended for protection against exposures to dusts. Full body clothing should be worn to prevent potential exposure to skin. Sufficient mechanical ventilation (general and/or local exhaust) shall be provided to| maintain exposures below permissible air concentrations. Protective gloves required. Respirator: A NIOSH approved respirator with P100 filters shall be worn when airborne exposures may exceed OSHA/ACGIH permissible air concentrations. Health Effects: ACUTE: May produce eye, skin and respiratory tract irritation, effects on the nervous system and kidneys, gastrointestinal distress and anemia. Common symptoms are a loss of appetite, nausea, vomiting, stomach cramps, constipation, anxiety, difficulty in sleeping, fatigue, moodiness, headache, joint or muscle aches and decreased sexual drive. Extreme overexposure may lead to tremors, convulsions, paralysis, stupor, coma and death. // CHRONIC: Children have enhanced absorption and retention of ingested lead and are particularly sensitive to the chronic effects of lead, with slowed cognitive| development and reduced growth. May produce effects on the blood, nervous and| immune systems, blood pressure, kidneys as well as skin and pulmonary| inflammatory tissue masses, rickets-like bone deformities, decreased sperm count| and spontaneous abortion. Common symptoms are a loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, fatigue, weakness, insomnia,| headache, nervous irritability, muscle and joint pain or soreness, fine tremors,| numbness, dizziness, hyperactivity and abdominal pain. Maternal overexposure| may produce low birth weight, birth defects and slowed postnatal neurobehavioral| development in the offspring. Extreme overexposure may lead to vomiting,| drowsiness, stupor, poor memory, restlessness, irritability, tremor, convulsions,| coma and death. Muscular weakness may develop and progress to paralysis| observed as "wrist-drop" and/or "foot-drop". TLV/PEL: Calcium Cobalt Lead Strontium Titanium Tungsten Oxide 100 % 0.05 mg/m3, 8 hr, as Pb TLV-TWA Calcium Cobalt Lead Strontium Titanium Tungsten Oxide 100 % 0.05 mg/m3, 8 hr, as Pb PEL-TWA

CRSS :
Chemical Name: Lead niobium titanium zirconium oxide

S-H20: 0.000001 g/L @
VP: 1.0E-6 torr @

MW: %<500 %<1000 Physical State and Misc CRSS Info:Neat: Solid Mfg: Solid Proc/Form: Solid: PMN material in aqueous slurry, then Solid: PMN material with or without
binder End Use: Solid: PMN material formed into article. The molecular weight depends on the particle size. It is estimated that the molecular weight will be >100,000 g/mol. Submitted Data: MP = 1350 °C (Sub. Est.); VP = 0 torr; WS = 0.05 g/L or Non-detect; Density = 7.6-8.1 g/cc (Sub. Est.); Particle Size D50 = 1.3 μm. Estimated Data: VP < 0.000001 torr (Inorganic oxide); WS < 0.000001 g/L (Inorganic oxide). The submitter's water solubility seems too high to be credible.

Consumer Use: No

SAT (concerns) (04/11/2011):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases: Analogs: // Health: Migration to groundwater: Negligible PBT rating: P3B2T3 . Health: 3 Dermal, Drinking Water, Inhalation Eco: 3 Water (All releases to water with a CC = 8.00 ppb)

OCCUPATIONAL EXPOSURE RATING: 1-2A

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. The PMN is manufactured domestically, therefore mfg, proc/use into piezoelectric ceramics are assessed. This PMN is part of a related set including P11-0270 through P11-0274. All cases have the same manufacturing and proc/use and exhibit the same releases and exposures. Changes to the IRER may effect the assessment of the other 4 PMNs in the set. The PMN contains four elements of concern: lead, niobium, titanium, and zirconium. The PMN PB rating is P3B2; therefore, a full assessment is required. Releases are assessed to all media. Note, submission specifies several dust releases to stack air, which is controlled by a bag house. Cleaning releases are collected in a collection sump pit. The submission implies this pit may discharge or be further treated. Solids collected in the bag house from air emissions or from collected sump pit solids are sent off-site as hazardous waste every 3-5 years. Therefore, releases presented in this IRER to air and water may occur regularly; whereas land and incineration releases are expected to collect over time and occur every 3-5 years. Dermal and inhalation exposures to solid have been assessed.POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: NoINITIAL REVIEW ENGINEERING REPORT
PMN: 11-0274

Manufacture and Processing at Lockheed Martin Facility

Number of Sites/ Location: 1 Lockheed Martin Liverpool NY 13088 Days/yr: 40 Basis: Submission specifies 40 bt/yr, 4 hr/bt, up to 25 kg/bt for PV of 1,000 kg/yr.

Process Description: MNFR: Scoop and weigh raw powder materials --> Charge to mixing tank, mix for 20 minutes (LVE formed in slurry) --> Empty slurry from mixing tank into drying pans --> Drying (PMN solid powder, 100%) --> Powder breaker or dry blender to break up powder --> Calcining at 700-900 degC --> Storage in 5-gal pails. (Submission)

PROC: Scoop PMN from pails (solid, 100% PMN) --> charge to mixing tank with water and dispersants --> Pump mixed slurry into vibratory mill --> Pump milled slurry into drying oven --> storage in 5-gallon pails (solid PMN, assume 100%).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources
to the same medium.

Water Output 2: 1.0E-2 kg/site-day over 40 days/yr from 1 site to: Onendaga County Department of Water and Environment Protection (NPDES# NY0002101) from: Water releases from cleanup activities including facility floors
basis: User-Defined Loss Rate Model. Submission estimates release into POTW from the process of 0.01 kg/bt from various cleanup activities. Submitter provided results of water sampling that was conducted form the facility. Samples were taken on 1/13/11. Results: Lead: <0.02 mg/L and 0.0019 mg/L. zirconium: <0.010 mg/L.

Air Output 2: 1.1E-2 kg/site-day over 40 days/yr from 1 site

to: Air from: Air emissions from baghouse
basis: User-Defined Loss Rate Model. Submission estimates 0.6 kg/bt of dust emissions into baghouse filter (corresponds to a Loss fraction of 1.5%. CEB dust model
estimates 0.5% release from solids transfer activities. Submitter indicated that the efficiency of the baghouse filter is 98.2% Calculation: 0.6 x (1-0.982) = 0.011 kg.

Conservative: 5.0E-1 kg/site-day over 40 days/yr from 1site or 2.0E+1 kg/yr

to: from: Equipment Cleaning Losses of Solids from Process

Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model,

Output 2: 5.9E-1 kg/site-day over 40 days/yr from 1 site or 2.4E+1 kg/yr

to: from: Disposal of baghouse filter basis: User-Defined Loss Rate Model. Disposal of baghouse filters (with captured dust emissions). Calculation: 0.6 kg/bt x 0.982 = 0.59.

RELEASE TOTAL 4.4E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes:

B

Inhalation: Submitter indicated that respirators (1/2 face respirator with P100 filter) are used whenever there is a potential for lead exposure by inhalation.

Exposure to Particulate (Class I) Output 2: 2.6E-1 mg/day over 40 days/yr Number of workers (all sites) with inhalation exposure: Basis: Various activities (weighing, mixing and transfer of powder and slurries); User-defined Inhalation Model. Submitter indicated in supplemental information that an industrial hygiene plan for the site is developed each january for the current year. Personal lead exposure is always included in the plan. The sampling plan involves analyzing personal lead exposure for each major process performed in the ceramic area. The plan is based on activity in the area. Recent sample results for the lead breakup process was 13 ug/m3. Recent average sample result for powder fabrication for 220 kg batch was 18 ug/m3. OSHA Action level for lead is 30 ug/m3 and OSHA PEL for lead is 50 ug/m3. Although employees are not exposed above the action level for more than 30 days a year they still require lead levels to be measured every6 months. Recent blood lead levels for two employees in the area were less than 3 mcg/d. The other employee's blood level was 9 mcg/d. CEB estimate is based on 19 ug/m3 (conservatively assumed to be an 8-hr TWA exposure). Chemistry report estimated that the PMN material is 68% lead oxide. Calculation: 18 ug/m3 (lead)/0.68 x 1.25 m3/hr x 8 hr/day = 0.265 mg/day NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? No

OR b) Hazard Rating for health of 2 or greater? 3 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal: Submitter indicated that Tyvek suits and booties are required whenever an employee enters hte ceramic area. Nitrile gloves are used when working with powders. There are several activities when the PMN may be handled in liquid form. The submission indicates that the same PPE requirements would be in place as for solids (Tyvek suit and booties, and nitrile gloves).

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 40 days/yr Number of workers (all sites) with dermal exposure: Basis: Various activities (weighing, mixing and transfer of powder and slurries); EPA/OPPT Direct 2-Hand Dermal

Contact with Solids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 11-0274

Incorporation into Article at Lockheed Martin Facility

Number of Sites/ Location: 1 Lockheed Martin Liverpool NY 13088 Days/yr: 80 Basis: Submission specifies 100% site-limited use and 80 days/yr for this stage. CEB estimates 12.5 kg/day.

Process Description: Unload PMN powder from pails (solid powder, assume 100% PMN) --> pour into feed hopper of press --> powder pressed into ceramic articles in compaction presses (PMN part of an article) --> burnout
and fire to remove binder --> finished article

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources
to the same medium.

Water Output 2: 1.0E-2 kg/site-day over 80 days/yr from 1 site to: Onendaga County Department of Water and Environment Protection (NPDES # NY0002101) from: Water releases from cleanup activities including facility floors
basis: User-Defined Loss Rate Model. Submission estimates releases into POTW from the process of 0.01 kg/bt from various cleanup activities. See previous section for results of facility wastewater monitoring.

Air Output 2: 2.0E-3 kg/site-day over 80 days/yr from 1 site

to: Air from: Air emissions from baghouse
basis: User-Defined Loss Rate Model. Submission estimated 0.1 kg/bt during this stage of the process released into baghouse filter operating at 98.2% efficiency (Loss fraction of 0.8% compared to CEB dust emissions model of 0.5%). Calculation of release to air = 0.1 x (1-0.982) = 0.002

Output 2: 9.8E-2 kg/site-day over 80 days/yr from 1 site or 7.9E+0 kg/yr

to: from: Disposal of baghouse filter
basis: User-Defined Loss Rate Model.

Calculation of release = 0.1 x 0.982 = 0.0982

Conservative: 2.5E-1 kg/site-day over 80 days/yr from 1

site or 2.0E+1 kg/yrto: from: Equipment Cleaning Losses of Solids from Process

Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model,

RELEASE TOTAL 2.9E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes:

Basis:

Inhalation: Submitter indicated that respirators (1/2 face respirator with P100 filters) are used whenever there is a potential for lead exposure by inhalation

Exposure to Particulate (Class I) Output 2: 2.6E-1 mg/day over 80 days/yr Number of workers (all sites) with inhalation exposure: Basis: Various activites (weighing, mixing, and transfer of powder and slurries); User-defined Inhalation Model. See previous section on the use of submitter monitoring data to estimate inhalation exposure at submitter's site. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? No

OR b) Hazard Rating for health of 2 or greater? 3 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal: Submitter indicated that Tyvek suits and booties are required whenever an employee enters the ceramic area. Nitrile gloves are used when working with powders.

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 80 days/yr Number of workers (all sites) with dermal exposure: Basis: Various activites (weighing, mixing, and transfer of powder and slurries); EPA/OPPT Direct 2-Hand Dermal

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