Global Alliance for Incinerator Alternatives

Presented by Sheila Davis

October 2024

Frontline Communities: Battery manufacturing and recycling chemical use and transparency

Overview

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Regional Tech Hubs

Onshoring battery manufacturing operations within domestic national borders

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• Battery Belt - Midwest/South

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• Nevada Lithium Batteries and Other EV Material Loop

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• New Energy New York (NENY) Battery Tech Hub

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• Lithium Valley - Salton Sea, California

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U.S. battery manufacturing and supply chain $ 90 Billion investments announced under President Biden

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• 170 new or expanded sites for EV assembly and EV component or charger manufacturing

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• Over 300 new or expanded minerals, materials processing and manufacturing facilities

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Chemical Risks and Fires in Battery Manufacturing

Detroit Battery Fire

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• In 2024, nearly 100 firefighters and two dozen fire trucks were called to GM’s EV Factory Zero factory in which a fire broke out inside the facility. The fire was likely caused by a forklift accidentally piercing a battery materials container.

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Chemical spill at Ultium plant in Ohio

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• A slurry containing battery materials and a hazardous solvent leaked, spilling a black substance on the ground in the Warren factory's mixing department.
• The slurry that leaked contained n-Methylpyrrolidone (NMP). There is no federal permissible exposure limit for NMP under OSHA.

Ultium Cells is a joint venture between General Motors and LG Energy Solution

Pollution Legacy of Tech Hubs

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Silicon Valley, CA 1983

• The US EPA identified 29 sites that were so polluted that they were placed on the National Priority List as “Superfund” sites
• 2.5 fold increase in miscarriages, birth defects and cancer in the area near the leaking storage tanks
• Silicon Valley Toxics Coalition passed the nation’s first Community Right-to-Know law and a Hazardous Materials Model Ordinance

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2006: Green Chemistry in California: Leadership in Chemicals Policy and Regulations

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Data Gaps—lack of data on industrial materials, including their health impacts, environmental toxicity,and monitoring.

Technology Gaps—lack of technologies and protocols for environmental and health monitoring, detection, and remediation.

Safety Gaps—lack of coordinated, publicly available information about specific chemicals and materials, including where they are being produced and used.

Recycling Processing Steps and Potential Hazards Chemical Release

• Pretreatment
• Sorting, deactivation, dismantling,
• Crushing
• Electrolyte Removal
• Binder Removal
• Black Mass
• Hydrometallurgy

Community concerns about battery recycling facilities

Lack of strong reporting requirements

• NEPA - No environmental impact reports for many facilities
• Reporting on PFAS impacts on air and water not required
• Toxics Release Inventory
• Most reporting under the threshold
• TRI reporting required for 7 additional PFAS, but unclear if the listed PFAS are used in batteries or emitted during recycling

�Lack of strong regulations

• Many PFAS are not regulated
• Air emissions regulations vary and are left up to states

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Proprietary Information

• Confidentiality requested for air emissions

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Environmental Data Justice

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1982 Warren County

Community protest polybrominated bisphenols (PCB) in makeshift landfills in their communities, near their homes

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Environmental Data Justice: Participatory Knowledge

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• Access and participation
• Common ownership of data
• Indigenous data sovereignty
• Examples:
• Lithium Valley - 60 air monitoring stations
• GAIA members in Indonesia setting up air monitoring systems for incinerators

Chemical Data Transparency Critical to Just Energy Transition

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Communities living near the battery manufacturing and recycling facilities need information about potential exposures to toxic chemicals including per- and polyfluoroalkyl substances (PFAS) that could impact their health, safety and well-being.

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Consumers and the general public want to make purchasing choices based on credible and verifiable data about the battery companies’ environmental performance and commitment to reducing and eliminating PFAS and other toxic substances.

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Workers need chemical data in order to protect their health and safety in the workplace.

Chemical Data Transparency Critical to Just Energy Transition

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Government regulatory agencies need chemical data to create and enforce environmental policies that ensure public safety.

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Recycling facilities need information about toxic chemicals in the batteries in order to monitor their air and other emissions.

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Researchers committed to developing safer substances need access to non-proprietary data regarding molecular structures.

THANKS!

Global Alliance for Incinerator Alternatives

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Sheila Davis

sheila@no-burn.org

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