DEC LETTER ON SUNGEEL BATTERY RECYCLING PROCESS
There has been much debate, energy and attention poured into the Sungeel Lithium-ion Battery Recycling Process. Residents are rightly concerned about new companies entering our beloved Village. It is my sincere hope that reading Reginald Parker’s (DEC) report below will begin to alleviate some of the fears for what Endicott’s future holds.
This is an open invitation for everyone looking for answers about the classification of SungEel MMC Americas (SMCC) battery thermal treatment kiln to read the report that follows by Reginald Parker. Mr. Parker’s report explains the DEC regulations that determined the SMCC facility to be listed as a “process source” rather than an “incinerator”.
Good afternoon Mayor Jackson,
In response to your question, under DEC regulations the battery thermal treatment kiln at the SMCC facility is classified as a "process source" and not an "incinerator" since it is a treatment process to condition the batteries for downstream crushing and grinding. The materials SMCC provided show battery cells going into the dryer, and treated battery cells coming out. (See the picture below.) The definition of “incinerator” under DEC regulations (6 NYCRR Part 219) is “any structure or furnace in which the combustion of any solid waste takes place alone or in conjunction with fossil fuel.” The purpose of the kiln as described by the applicant is not to combust material but to condition the batteries for recovery. Combustion of pollutants does occur in the afterburner which under DEC regulations is classified as an air pollution control device. An afterburner, or thermal oxidizer, is not an uncommon air pollution control device. The purpose of these devices is to destroy gaseous organic compounds emitted from air pollution sources. In this process, emissions from the afterburner are further controlled by an acid gas scrubber and a baghouse for particle removal.
In addition to the above, DEC regulations contain specific definitions for municipal and private incineration facilities. The definition of municipal solid waste incineration is “a facility that is owned, operated, or utilized by, or under contract with, a municipality or political subdivision and which utilizes high-temperature thermal destruction technologies, including combustion for the recovery of thermal value or for the disposal of municipal solid waste". This process, while at a high temperature, is not using a thermal destruction technology, and is not doing this for heat recovery or disposal, and therefore is not classified as a municipal solid waste incinerator. Similarly, it is not classified as a private solid waste incineration facility, because it is not processing municipal solid waste using thermal destruction technologies. The overall purpose of this facility is to recover materials from Lithium-Ion batteries.
Please note that under DEC regulations, the emissions from this facility are subject to stringent requirements as a process source (NYCRR Part 212) that ensure protection of health and the environment. The DEC air permit contains emission limits, as well as monitoring and testing requirements to ensure compliance with DEC regulations. As you know, however, there is an outstanding issue related to PFAS compounds and emissions from this process that DEC identified in a May 20th letter where we informed SMCC that under the existing permit, the facility cannot process batteries containing PFAS. SMCC will need to apply for and receive a permit modification in order to process batteries containing PFAS compounds. DEC has not received a permit application. SMCC has previously committed, in writing, to perform additional testing at its South Korea facility under a DEC-approved test plan to address PFAS compounds. A test plan has not been submitted to DEC at this time.
Please let me know if you have any additional questions.
Reggie Parker
Reggie Parker, PE
Regional Engineer
NYSDEC Region 7
315-426-7420