Monday, August 24, 2020

"It's not an incinerator!!!"

 
I get emails and comments often from people who
loudly and proudly assert, regarding the proposed
SMCC "Battery Recycling Facility" in Endicott, that it is
"NOT AN INCINERATOR!".

Here is my reply:

---------- Forwarded message ---------
From: William Huston <williamahuston@gmail.com>
Date: Mon, Aug 24, 2020 at 12:51 PM
Subject: Re: thoughts on battery recycling
To:

Hi ---------------

Thanks for responding. 

Can you explain to me why you say it is not an Incinerator?
Any evidence or proof? Any official documents? 
You certainly must have something to be so convinced.

FYI: Here's my evidence SMCC's facility IS or will include an Incinerator:

Actually it's worse than a garbage incinerator. 
This is a Hazardous Waste Incinerator.
("Universal Waste" is classified as Hazardous by definition)
  1. Robert Buetner, Chief, Air Compliance Branch of US EPA says this facility meets the Definition of a CISWI unit. (commercial and industrial solid waste Incineration unit)


    https://www.dropbox.com/s/1aqjqqht4dynriu/SMCC_Lithium-Ion_Battery_Recycling_Facility_Applicability_Determination_7.16.2019-OCR.pdf?dl=0

  2. Thomas Elter, regional permit for NYSDEC admits that SMCC's Rotary Kiln would be operated above the ignition temperatures of  "some of the materials" in it, and may be subject to EPAs Incinerator rule. 



      Source: https://www.dropbox.com/s/1aqjqqht4dynriu/SMCC_Lithium-Ion_Battery_Recycling_Facility_Applicability_Determination_7.16.2019-OCR.pdf?dl=0

  3. Former EPA regional administrator Judith Enck has stated at public hearings and has been quoted in the press saying "this is Incineration". 

    source: https://www.pressconnects.com/story/news/local/2020/05/05/why-endicott-board-meeting-lasted-more-than-4-hours/3066700001/

  4. Dr. Paul Connett, an internationally recognized expert on Incinerators and Zero Waste says this is a "2-stage Incinerator".

    source: https://noburnbroome.com/letter-to-governor-cuomo-signed-by-80-residents-of-broome-county/

  5. John Ruspantini, a commercial environmental remediation specialist said at a Town of Union zoom meeting that

    "This Facility is a Universal (Hazardous) Waste TSDF (Treatment, Storage, and Disposal Facility). The purpose is Waste DISPOSAL. NO MATERIALS will actually be recycled here."

    https://youtu.be/7sZynPmzUdw?t=2813


  6. Letter from Thomas J. Fucillo, Esq, an attorney for Barclay Damon, hired by Sungeel, is a gold mine of admissions, including that the the RK Furnace would be regulated under 6 NYCRR Part 374 "Hazardous waste burned in boilers and industrial furnaces" but is "conditionally exempt" pursuant to 6 NYCRR 374-1.8(a)(3). Also, that it would be regulated as an NY Hazardous Waste TSDF, but that these regulations are "onerous", and Sungeel would jump throught hoops to AVOID REGULATION as such, i.e., placing the facility in two buildings instead of one, and that it would create a fictitious business unit if necessary.



    https://www.dropbox.com/sh/r62ur16tvsmmnt4/AACcfdfYVAYsMddEEBr6fpIea/Enter%20Archive/BH%20FOIL%20%231%20W060650-110419?preview=DOC052819-05282019102632-OCR.pdf

  7. In Sungeel's OWN PRESENTATION on the VoE website, in a section called "Incinerator Categorization", they admit that "some of the battery components" will burn.

    \
    https://endicottny.com/smcc-information-package-available-here/

  8. Glendon Archer, President of MCC, Inc. (a partner in SMCC), stated 11/6/2019
    that "electrolytes are incinerated".

    https://www.youtube.com/watch?v=ZU_81sPPC2M&feature=youtu.be&t=1740

    Danish Mir in the same presentation answered a questions about "the incinerator"
    or about "incineration", to which he answered the question directly, and never said,
    "this is not an incinerator"
 
Thanks for your time,
BH



--
William Huston:  WilliamAHuston@gmail.com
Binghamton NY

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