Joseph M Dlugolenski
NYSDEC Region 7 Cortland Sub-Office
1285 Fisher Ave
Cortland, NY 13045
Paul Connett, PhD,
104 Walnut Street,
Binghamton, NY 13905
Dear Mr. Dlugolenski,
I have recently been made aware of a proposal to build a lithium battery recycling plant proposed in Endicott, NY. I am very concerned about this project and I would like, as a member of the Tri Cites area (I live in Binghamton, NY), to request that the NY DEC hold a public hearing on this project. To date citizens have only heard from the company.
My background. I am a retired professor of chemistry, who specialized in environmental chemistry and toxicology. I taught at St. Lawrence University, Canton, NY, from 1983- 2006. I have been involved in waste management research since 1985 – and this issue that has taken me to 49 states in the USA, 7 provinces in Canada and 66 other countries. From 1985 to 2000 I headed up the group Work on Waste, USA. I have written extensively on the dangers posed by incineration, including co-authoring 6 papers on dioxin published in the peer-reviewed journal Chemosphere. More recently I published the book “The Zero Waste Solution: Untrashing the Planet One Community at a Time” (Chelsea Green, 2013)
1) This project is being rushed through with minimal public input.
5) I note in one of the schematics of the process in the air permit prepared by .Plumley Engineering the label “PCB” occurs. Do these letters refer to Poly Chlorinated Biphenyls, if so I am particularly concerned a) because they are very toxic in their own right but also b) when they are heated or burned the byproducts poly chlorinated dibenzo furans (PCDFs) are orders of magnitude more toxic than the PCBs themselves. That is why when burned in bulk in hazardous waste facilities they are required to meet a destruction removal efficiency (DRE) of 99.9999.
6) I note that the SUNGEEL facility operating in South Korea has been measured for dioxin – but only a single figure (one test?) has been provided for dioxin emissions – i.e. 0.016 ng I-TEQ/SM3.
Furthermore, I would like to see dioxin measurements made in several locations in the facility (after the heater) and before and after the air pollution control equipment so an estimate can be made of their removal efficiency.
7. Other emission data. Like the dioxin data the metal emissions appear to be based on single measurements i.e. spot tests. Were they based on one spot test? Or many? If many then one would like to see the range of the results.
8. Thermal release vents (i.e. dump stacks). I saw no mention of these in the permit application, but typically when materials are being heated or burned at high temperatures you need some device to vent the gases in the event of some blockage downstream of the heater or burner. When this occurs there is no mitigation from air pollution control and emissions of both toxic metals and dioxins can greatly increased. We need to know the track record of the company’s operation in South Korea in this regard.9. Nanoparticles. I see no discussion of nanoparticles in the application. This is perhaps the most unexpected and serious problem in any high temperature heating or burning operation. It is only in the last few years that we are beginning to find out the health problems these maybe generating. In just the last few weeks a paper has been published indicating a relationship between 2.5 micron particles and brain cancer.10. No emission monitoring proposed. I see in the air permit that as far as emissions are concerned no short term or long term monitoring is proposed, instead the facility will be “monitored” using simple operating criteria – temperature at certain points and pressure drop in the baghouse. I do not find this satisfactory or protective of the community. It may be that such simple measurements could be used once a year’s worth of data has been complied and correlated with these parameters – but not at the outset. Perhaps that has been done in Korea – but if so the data should be provided.
Conclusion: For all of the reasons above I think it is imperative that the NY DEC either reject the permit application outright or organize a hearing where both the citizens and local decision makers hear about the possible dangers involved in this project.
Dec 5 2019