Note: This series concerns a proposal to use incineration to recycle lithium-ion batteries. It was proposed for Endicott in Broome County NY. The proposal resulted in the formation of the group NoBurnBroome on April 15, 2020, to oppose the proposal, which it successfully accomplished in February 2021. The Fluoride Action Network was interested in this project because the novel use of incineration to recoup valuable metals would be a new, and non-assessed, exposure route to large amounts of hydrogen fluoride. Index to the series is here.

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PFAS are commonly called “the Teflon chemicals” and have been dubbed “the forever chemicals” because the Carbon-Fluorine (C-F) bond is very stable. These compounds are highly persistent in the environment and accumulate in the human body. According to the Environmental Working Group, “the rates at which PFAS break down in nature are better measured in geological than in human time frames.” They are also very toxic and have been described as the “dioxins of the twenty first century” by Linda Birnbaum, PhD in an interview on The People’s Pharmacy, a National Public Radio show. Dr Birnbaum was Director of the National Institutes of Environmental Health Sciences from 2009 to 2019.

The following is from the “basic information” on PFAS provided by the Environmental Protection Agency:

“Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many other chemicals. PFAS have been manufactured and used in a variety of industries around the globe, including in the United States since the 1940s. PFOA and PFOS have been the most extensively produced and studied of these chemicals. Both chemicals are very persistent in the environment and in the human body – meaning they don’t break down and they can accumulate over time. There is evidence that exposure to PFAS can lead to adverse human health effects.

“PFAS can be found in:

• Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-contaminated soil or water.
• Commercial household products, including stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams (a major source of groundwater contamination at airports and military bases where firefighting training occurs).
• Workplace, including production facilities or industries (e.g., chrome plating, electronics manufacturing or oil recovery) that use PFAS.
• Drinking water, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility).
• Living organisms, including fish, animals and humans, where PFAS have the ability to build up and persist over time.

“…Although PFOA and PFOS are no longer manufactured in the United States, they are still produced internationally and can be imported into the United States in consumer goods such as carpet, leather and apparel, textiles, paper and packaging, coatings, rubber and plastics…”

It was the Science Team at NoBurnBroome who first discovered that one of the electrolytes used in some lithium-ion batteries was a PFAS.

• May 20, 2020. Letter from NYDEC to SungEel: “Based on this new information, DEC has concluded that a modification to SMCC’s ASF permit is required to process any lithium ion batteries containing PFAS compounds at the facility since this was not part of the original permit application prepared by SMCC. The application for modification of SMCC’s ASF permit must include an estimation of PFAS emissions both prior to and after air pollution control…” http://fluoridealert.org/wp-content/uploads/endicott-legal.dec-letter-to-sungeel.5-20-20.ocr_.pdf

• May 21, 2020. Endicott Battery Recycling Plant Operations Delayed, “With the help of the NYS Attorney General and the science team for the activist group NoBurnBroome, the issue was brought to the attention of the NYDEC after finding that some lithium-ion batteries contain poly fluoroalkyl substances (PFAS).” Fox News40, by Jessica Kisluk.

• May 28, 2020. Letter from NoBurnBroome to NYDEC Commissioner and Empire State Development Corporation signed by 154 organizations: “Neither PFAS nor other fluorinated byproducts were considered in the DEC air permit.” https://noburnbroome.com/letter-to-nys-dec-commissioner-and-the-president-ceo-of-the-empire-state-development-corporation/

• June 1, 2020 (revised June 24). White Paper by NoBurnbBroome’s Science Team, Paul Connett and John Ruspantini: “… The proposed facility is the first of its kind operation in the USA, and when huge profits are at stake, we believe it is imprudent to rely on SMCC for air pollutant emission data without oversight by the DEC itself or an independent third party paid by DEC… In our letter sent to Reginald Parker of the DEC on May 26, 2020 (See Appendix A), we pointed out that a recent presentation by USEPA, (See Appendix B) calls into question a) the adequacy of incineration to destroy PFAS compounds; b) the lack of knowledge regarding the nature of breakdown products of PFAS during incineration; and c) the lack of fully developed lab methods to determine PFAS levels in air samples collected at emission stacks. http://fluoridealert.org/wp-content/uploads/endicott.white-paper.6-24-20.pdf

• June 22, 2020. Letter from NoBurnBroome to Governor Cuomo signed by 80 residents of Broome County: “During the course of the NBB research, they found that at least one PFAS compound; lithium bis(trifluoromethanesulfonyl) imide, is used as an electrolyte in some of these batteries, and it is only now, after the … air permit was issued in March 2020, that this matter is being looked into by DEC to determine whether SMCC can adequately incinerate a highly toxic compound that is designed not to burn.” http://fluoridealert.org/wp-content/uploads/endicott.letter-to-cuomo.6-22-20.pdf

• July 19, 2020. Letter from NoBurnbBroome’s Science Team, Paul Connett and John Ruspantini to Governor Cuomo: “… The air pollution control devices used by SungEel were never designed to filter out PFAS combustion byproducts and nanoparticles that can be generated from a high temperature pyrolytic process… we request that you immediately require your Department of Environmental Conservation (DEC) to rescind the air discharge permit granted for the proposed facility pending a comprehensive environmental and public health impact review (EIS) conducted in strict compliance with all applicable regulatory requirements.” http://fluoridealert.org/wp-content/uploads/endicott.connett-ruspantini.letter-to-governor.7-19-20.pdf

August 1, 2020: Letter from NYDEC to NoBurnBroome John Ruspantini: “… the facility cannot operate without first documenting whether the batteries contain PFAS…. The chemistry of the process is not fully understood… If PFAS is found to be in the batteries that SMCC will process, a permit modification will be required. SMCC has agreed to conduct testing of PFAS at its South Korean facility… At the temperatures we expect, this PFAS will break into two carbon groups, and possibly trifluoro methane or carbon tetrafluoride will result. DEC has an ambient concentration established for carbon tetrafluoride; emissions of this compound will be less than 100 pounds per year. We would expect longer-chain (C8) fluorocarbons, if present, to break down in the proposed oxidizer.” http://fluoridealert.org/wp-content/uploads/endicott.dec-letter-to-ruspantini.8-1-20.pdf

• August 31, 2020. Updated Position Paper by NoBurnBroome Science Team:
This paper presents the fullest information on the PFAS issue relevant to SungEel’s proposed process in Endicott. “Many of these fluorinated by-products, like PFAS, are toxic and highly persistent in the environment because of the stability of the Carbon-Fluorine bond. Unlike the PFAS of original concern, i.e. PFOA (Perfluorooctanoic acid) and PFOS (Perfluorooctanesulfonic acid), many of these shorter chain PFAS and other fluorinated by-products are likely to be fat soluble, not water soluble, and will accumulate in human body fat and will be passed to the fetus during pregnancy.” http://fluoridealert.org/wp-content/uploads/position-paper.no-burn-broome.august.31.2020.pdf

• September 16, 2020. NBB’s response to DEC’s statements in their August 1st letter to John Ruspantini: “DEC does not acknowledge here that it was the NBB science team that first found the presence of these PFAS in some of the lithium-ion batteries during our literature search. This finding eventually made its way to the AG’s office. Knowing the current concern regarding the ubiquitous presence of PFAS in the environment, DEC should have investigated for the presence of the PFAS in these batteries themselves… We are unclear as to why SungEel has yet to prepare a plan for the DEC to review in order to resolve this matter, months after it was brought to their attention. On the technical side of this issue, DEC assumes that … PFAS compounds will simply break down into inert and harmless chemical species, yet offers no chemical mechanisms to support this assertion…” http://fluoridealert.org/wp-content/uploads/endicott.nbb-response-to-dec.elter_.9-16-20.pdf

• September 17, 2020. Request by NoBurnBroome John Ruspantini to NYSDEC Region 7 Permit Administrator to consider the modification, suspension or revocation of the SungEel’s Air Permit. “Research by NBB indicates that it is not just an issue of the PFAS actually used in some of the batteries but that a number of fluorinated materials in the batteries (e.g. PVDF) will generate a number of PFAS when they are heated in the rotary kiln and the resultant gases burned in the afterburner. NEARLY ALL Lithium Batteries contain PFAS. These PFAS products of in complete combustion or PICs must be identified and stack test methods developed to accurately determine community exposure to these toxins that persist in human tissue and the environment.” http://fluoridealert.org/wp-content/uploads/endicott.ruspantini-letter-for-sungeel-air-permit-revocation.9-17-20.pdf

Selected News Articles and Studies:

November 25, 2020. The new ‘gold rush’ for green lithium. BBC Future Planet.

October 2020. STUDY. Blake BE and Fenton SE. Early life exposure to per- and polyfluoroalkyl substances (PFAS) and latent health outcomes: A review including the placenta as a target tissue and possible driver of peri- and postnatal effects. Toxicology 443:152565.

October 5, 2020. Breast milk analysis detects both legacy and emerging fluorinated compounds. By Amy Welch. Chemistry World.

September 30, 2020. Did the White House Stop the EPA From Regulating PFAS? By Sharon Lerner. The Intercept.

September 24, 2020. Why Dangerous ‘Forever Chemicals’ Are Still Allowed in America’s Drinking Water. The federal government still hasn’t set limits for PFAS compounds. Consumer Reports.

September 10, 2020. DOD is spending millions, getting rid of toxic foam by burning it near where people live. By Joce Sterman, Alex Brauer and Andrea Nejman. Sinclair Broadcast Group. WJLA ABC 7 (greater Washington DC area).

June 25, 2020. Destroying Forever Chemicals Ignites N.Y. Town’s ‘Worst Fears’. By Sylvia Carignan and Keshia Clukey. Bloomberg Law.

April 28, 2020. Toxic PFAS Fallout Found Near Incinerator in Upstate New York. By Sharon Lerner, The Intercept.

October 19, 2019. Top U.S. Toxicologist Was Barred From Saying PFAS Cause Disease in Humans. She’s Saying It Now. By Sharon Lerner, The Intercept.

See more selected articles at https://noburnbroome.com/pfas-news-articles/

Good Websites:

EWG (Environmental Working Group). Mapping the PFAS Contamination Crisis: New Data Show 2,230 Sites in 49 States.

EWG (Environmental Working Group). This group has worked on this issue since 2000. They provide the best information.

Earth Justice. What PFAS are, why they’re harmful, and what we can do to protect ourselves from them.