INITIAL REVIEW ENGINEERING REPORT
PMN: 11-0270 Standard Review Draft 5/10/2011

ENGINEER: Macek \ BCS PV (kg/yr): 5,060

**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 previous version of the engineering report
include:

1. Revision of the Lifecycle of the PMN chemical to include the following 3 stages:

- Manufacturing and Processing at Lockheed Martin facility; - Incorporation into Article at Lockheed Martin Facility; and - use of 10% of the PV by PKI, Bellefonte PA for incorporation into articles.

2. Use of submitter's monitoring data for lead exposures as well as the OSHA PEL for lead 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. Addressing of the water release potential for each lifecycle stage assessed based on additional review and
discussions with the submitter.

5. Addition of information on the use of PPE by the workers for each lifecycle stage.
6. Added results of submitter's monitoring data of lead
and zirconium levels in wastewater from the Lockheed Martin facility.

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 recommended, but not required. Respirator: A NIOSH/MSHA approved dust/fume respirator shall be worn when airborne exposures may exceed OSHA/ACGIH permissible air concentrations. Health Effects: ACUTE: Exposure to elevated levels of airborne or ingested lead may produce symptoms of anemia, insomnia, weakness, constipation, nausea, abdominal pain, vomiting and neuritis. Extreme overexposure may lead to convulsions, stupor, coma and encephalopathy. Inhalation of Zirconium containing aerosols may cause lung granulomas. // CHRONIC: Chronic exposure to airborne and ingested lead may produce symptoms of persistent fatigue, sleep disturbance, headaches, aching bones and muscles, constipation, abdominal pains and loss of appetite. Excessive exposure may affect the circulatory, nervous, digestive systems, and kidneys. If chronic exposure is left untreated neuromuscular dysfunction and possible paralysis may occur. Women of child bearing age should avoid exposure to lead and its inorganic compounds due to the post-natal effects. Lead can cause potential injury to a developing fetus and possible effects on reproduction. TLV/PEL: Lead Strontium Titanium Zirconium Oxide 100 % 0.05 mg/m3, 8 hr, as Pb TLV-TWA Lead Strontium Titanium Zirconium Oxide 100 % 0.05 mg/m3, 8 hr, as Pb PEL-TWA

CRSS :
Chemical Name: Lead strontium 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 isestimated 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 = 7.5-8.1 g/cc (Sub. Est.); Particle Size D50 = 1.3 μm. Data from Same as Case L-11-0021 by the Same Submitter: Particle Size: Crystals = 1.2 μm, Agglomerates = 1 mm. Estimated Data: VP < 0.000001 torr (Inorganic oxide); WS < 0.000001 g/L (Inorganic oxide).

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. The PMN contains four elements of concern: lead, strontium, 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: 11-0270

Manufacture and Processing at Lockheed Martin Facility

Number of Sites/ Location: 1 Lockheed Martin Liverpool NY 13088 Days/yr: 23 Basis: Submission specifies 23 bt/yr, 4 hr/bt, up to 220 kg/bt for PV of 5,060 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.

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 powder, 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 23 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 from the facility.| | 1/20/11 Lead <0.02 mg/L; 2/11/11 Lead 0.0019 mg/L; 1/27/11 Zirconium <0.010 mg/L. | .

Air Output 2: 1.1E-2 kg/site-day over 23 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 0.3%, CEB model estimates 0.5%). Submitter indicated efficiency of baghouse filter is 98.2%. Calculation: 0.6 x (1-0.982) = 0.011 kg.

Conservative: 4.4E+0 kg/site-day over 23 days/yr from 1

siteor 1.0E+2 kg/yr

to: from: Equipment Cleaning Losses of Solids from Process

Vessels basis: EPA/OPPT Multiple Pr

, CEB standard 2% residual

Output 2: 5.9E-1 kg/site-day over 23 days/yr from 1 site or 1.4E+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 1.2E+2 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 filter) are used whenever there is a potential for lead exposure by inhalation.

Exposure to Particulate (Class I) Output 1: 2.8E-1 mg/day over 23 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 every 6 months. Recent blood lead levels for two employees inthe area were less than 3 mcg/di. The other employee's blood level was 9 mcg/di. CEB estimate is based on 18 ug/m3 (conservatively assumed to be an 8-hr TWA exposure). Chemistry report estimated that PMN material is 65% lead oxide. Calculation: 18 ug/m3 (lead)/0.65 x 1.25 m3/hr x 8 hr/day = 0.28 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 the ceramic area. Nitrile gloves are used when wokring 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 liquids (Tyvek suit and booties, and Nitrile gloves).

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 23 days/yr Number of workers (all sites) with dermal exposure: 2 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: 11-0270

Incorporation into Article at Lockheed Martin Facility

Number of Sites/ Location: 1 Lockheed Martin Liverpool NY 13088

PKI Bellefonte PA Days/yr: 80

Basis: Submission indicated 90% of PV is used at the submitter's site and 80 days/yr. CEB calculates a daily use rate of the PMN chemical of 56.9 kg/site-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. (Submission)

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 release 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 during this stage of the process released into baghouse filter operating at 98.2% efficiency (Loss fraction of 0.2% comparable to CEB Dust emissions model of 0.5%). Calculation of release to air = 0.1 x (1-0.982) = 0.002

Conservative: 1.1E+0 kg/site-day over 80 days/yr from 1

site or 9.1E+1 kg/yr

to: from: Equipment Cleaning Losses of Solids from Process

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

CEB standard 2% residual.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

RELEASE TOTAL 10.0E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of
Basis:

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: 2.8E-1 mg/day over 80 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. See previous section on 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 cerammic areas. 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 Activities (weighing, mixing and transfer of powder and slurries); EPA/OPPT Direct 2-Hand DermalContact with Solids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 11-0270

Incorporation into Article at PKI, Bellefonte PA facility

Number of Sites/ Location: 1

PKI Bellefonte PA Days/yr: 40

Basis: Submission indicated that 10% of the PV will be processed at the PKI facility for 40 days/yr.

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.

Most likely media of release from residues from cleaning operations is landfill.

Output 2: 6.3E-2 kg/site-day over 40 days/yr from 1 site or 2. /yr

to:
from: Dust emissions from solid transfer activities
basis: User-Defined Loss Rate Model. CEB default Loss
fraction of 0.5% from dust emissions model used as a
basis for estimate. Submitter indicated that the small quantities are handled in a hood EPA system and ultimately will be disposed

.

Landfill Output 2: 1.3E-1 kg/site-day over 40 days/yr from 1 site or 5.1E+0 kg/yr

to: Landfill from: Equipment Cleaning Losses of Solids from Process

Vessels basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual. Submitter indicated that equipment is cleaned using vacuum system or removed with cleaning rags. These wastes would be sent off site as hazardous waste with landfill as the most likely media

of release

RELEASE TOTAL 7.6E+0 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 4 Basis: Submission indicated 3 worker activities and up to 4 workers potentially exposed.Inhalation: Submission specified that company uses a vacuum system that goes directly to a HEPA vacuum system.

Exposure to Particulate (Class I) Output 2: 7.7E-1 mg/day over 40 days/yr Number of workers (all sites) with inhalation exposure: 4 Basis: Various activities (including handling and transfers of powders); User-defined Inhalation Model. Estimate of inhalation exposure based on OSHA PEL for lead of 50 ug/m3 (8 hr TWA). Chemistry report estimated that lead oxide portion of the compound is 65%. Calculation: 50/0.65 x 1.25 m3/hr x 8 hr/day = 0.77 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: Submission specified that workers will wear lab coat 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: 4 Basis: Various activities (including handling and transfers of powders); EPA/OPPT Direct 2-Hand Dermal

Contact with Solids Model.MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: Greg Macek Organization: USEPA/OPPT/EETD

CALL TO: Nicholas Caparco

Organization: Lockheed Martin

Date: 05/04/2011

Time:

Phone: 315-456-2606

Concerning what TSCA ?

PMN: 11-0270

Mr. Caparco provided the following additional information in itial phone call of May 4, 2011 and a follow-up phone