Some highlights:

• SungEel has provided no listing of the compounds present in lithium-ion batteries or even an elemental analysis (percentage of each element in the batteries) so that a mass-balance could be attempted, especially for fluorine.

• Nor did the NYS DEC display any curiosity as to the chemical composition of these batteries at any time to issuing the air permit.

• In a letter dated August 10, 2020, Tom Elter of the NYS DEC wrote,
“We agree that the chemistry is not well understood”

• If the chemistry of the process is not well understood, then the hazards associated with the process are not well understood and NYS DEC cannot adequately protect human health and the environment from hazards associated with the SungEel process.

• The NYS DEC used data that was statistically invalid. All the pollutant emission measurements at the South Korean facility (dioxins, metals etc.) were based on a single measurement on a single day. You cannot do statistical analysis on a single data point. You need a range of values (preferably taken on different days). From this range you can assign a low value, a high value, a geometric mean and an upper 95% confidence value. Only on this basis do you have grounds to estimate annual emissions.

• The presence of PFAS were not disclosed in SungEel’s air permit application. PFAS are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other others. It was NoBurnBroome who disclosed this information.

• NYS DEC is not up to date on the scientific literature on the threat posed by nanoparticles and are thus incapable of protecting the public on this matter.

• The simple and horrible fact is that the production of nanoparticles via incineration constitutes the most devastating delivery system of toxic substances used in consumer products to human tissues, that we have ever invented.

• The fatal flaw in the DEC’s actions in this matter was not to require a Type 1 SEQR review, which would have involved a full Environmental Impact Statement (EIS). Such an EIS would have quickly established that this project in this location,  in this already health-compromised community, was unacceptable by any reasonable standard.

• It is inexplicable that the NYS DEC did not require a Full Environmental Impact Statement (EIS) for this project. We call on Governor Cuomo to insist that a Full EIS be performed BEFORE any consideration be given to re-instating the State Facility Air Permit (currently on hold).

• It was a huge mistake for NY State’s Empire State Development to have put $1.75 million of taxpayers’ money subsidizing a company to take valuable and strategically important metals out of the country.

• We call upon the NYS DEC to vacate its “Negative Declaration” (Notice of Determination of Non-Significance) of March 27,2020, in its SEQR review of this project and to rescind the State Facility Air Permit it issued on March 30, 2020.

• And more….

Link: NoBurnBroome Position Paper_August 28, 2020

NOTE: The original position paper, prepared by the Science Team at No Burn Broome, was released in April 2020 – you can read that report here.