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. 

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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 is 

EPA SANITIZED Page 2 of 12
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 = 7.5-8.1 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: No 

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INITIAL 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 

site 

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or 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 in 

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the 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. 

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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. 

EPA SANITIZED Page 7 of 12
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 Dermal 

EPA SANITIZED Page 8 of 12
Contact with Solids Model. 

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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. 

EPA SANITIZED Page 10 of 12
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. 

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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 

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