Comments submitted to NYS DEC by Paul Connett, PhD, on December 5, 2019

Via Email
TO
Joseph M Dlugolenski
NYSDEC Region 7 Cortland Sub-Office
1285 Fisher Ave
Cortland, NY 13045
(607)753-3095
FROM
Paul Connett, PhD,
104 Walnut Street,
Binghamton, NY 13905
607-217-5350
pconnett@gmail.com

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)

 


My Concerns.


1) This project is being rushed through with minimal public input.
2) The facility is being built in a highly populated community, whose residents’ health has already been compromised by industrial operations (e.g. IBM).
3) Lithium batteries are notorious for being a fire hazard, but I do not see any accident analysis. What hazards would a fire cause to this community if tons of lithium batteries are brought to and stored in this location? This analysis should be required by the NY DEC.
4) Obviously, a lot of attention has been paid to this technology but it does pose risks – and no matter what bells and whistles are put on this plant the ultimate fail safe is its location. In this case the location offers no fail safe – if accidents occur – or even malfunctions and upset conditions – people will be immediately in harms’ way. I would like to know the rationale for this siting? Is it the best and safest location that can be found in this area, or in NY State or the region? Or was this siting decision made because Endicott is perceived as a sacrifice area?

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.

endicott-legal.Screen Shot 2019-12-05 at 4.42.29 AM
QUESTIONS: Was only one test performed on this facility? For what duration?  6 hours? Under what conditions? Such spot tests are notorious for underestimating emissions during start-up, shut-down and upset conditions. As a result in Germany, Belgium and some other countries companies are required to use a 4-week continuous sampling system (the AMESA system). Emissions when estimated using this sampling system emissions can be several orders of magnitude higher than the 6-hour spot tests. Thus the conclusions by  Plumley Engineering copied below –  are not based on adequate science and are cavalier to say the least.
endicott-legal.plumley.Screen Shot 2019-12-05 at 4.43.32 AM
If the company has an operating facility such measurements should be made using continuous sampling over a whole year.

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 p
ossible dangers involved in this project.

Sincerely,
Paul Connett,
Dec 5 2019

 

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