John Austin, long time environmentalist, is the originator of this effort.
Reasons To Not Approve Seaford and Millsboro Incinerators
1) In Renewable Oil International DE, LLC’s application, they indicate that the feed stocks used at both the Seaford and Millsboro facilities would include “clean, non-hazardous organic materials such as poultry litter.” This description is completely inaccurate as poultry litter is neither clean nor non-hazardous. Poultry litter contains fecal material, bacteria, pesticides, vaccines, as well as heavy metals, antibiotics and coccidiostats that were in the poultry feed.
2) Studies have shown that the use of biochar can improve water quality. The positive qualities are dependent on the properties of the biochar. In this case, biochar produced at these two proposed facilities cannot improve water quality as the use of poultry litter creates a biochar that is heavily laden with concentrated hazardous materials.
3) If there are toxic heavy metals going in one end, they must come out in the products that the facility produces. The Environmental Protection Agency has stated that "Organic arsenic compounds (namely Roxarsone) are extensively added to the feed of animals (particularly poultry and swine) in the United States to improve growth rates by controlling parasitic diseases."[2] Most of it is excreted in the manure. Arsenic is more toxic than lead. The U.S. Geological Survey has conducted studies of the land and water impacts of arsenic-containing poultry litter being land applied in the Chesapeake Bay watershed and have found trace elements of arsenic in Maryland's Pocomoke River.[3,4,5,6,7] I am aware of no quantification of the actual tonnage of poultry litter to be processed at these two facilities annually. Concentrations of 15 to 35 ppm of arsenic have been found to be in poultry litter. [2,3,8] Without knowing the actual tonnage of poultry litter flowing through these two facilities annually, the tonnage of arsenic stored at or leaving these facilities cannot be quantified and therefore the safety of the materials produced at these two facilities cannot be accurately assessed.
4) The UN Environment Program lists dioxins as Persistant Organic Pollutants. Dioxins in the environment are mostly the result of past and current industrial processes. Dioxin production requires hydrocarbons and chlorine. Poultry litter is full of hydrocarbons, both in the manure and the bedding. There should be no shortage of chlorine in the poultry litter, either. One of the sources of chlorine is from the various drugs and pesticides used in the poultry industry.[9] There are at least eight drugs, most of them coccidiostats that are used in the poultry industry and are chlorinated. These chlorine-containing materials are found in the poultry litter. Dioxins are highly toxic in very small amounts. The sheer tonnage of poultry litter moving through these two facilities provides an ample supply of chlorine for dioxin production.
5) The formation of dioxins is enhanced in the presence of metals, especially copper, iron and zinc. Poultry are treated with copper sulfate to avoid a common disease called "aspergillosis." Evidence from chicken litter in Arkansas shows nearly twice as much copper as arsenic in poultry manure[8]. Copper levels in poultry litter are so high that there are documented cases of cows dying from being fed poultry litter. Iron and zinc are also used as feed additives in poultry production. While copper is the most effective catalyst, iron and zinc are also quite effective at boosting dioxin production.
6) Biochar produced from poultry litter binds certain toxic chemicals such as copper, cadmium and zinc [1]. Not only will Renewable Oil International DE, LLC be sequestering carbon for centuries in the biochar, but also heavy metals like arsenic will be sequestered in the soils where the biochar is applied, effectively poisoning the soils where the poultry litter biochar is applied.
7) Regarding ROI’s application section 4.7, this facility should not be permitted to be built at the desired site in Seaford nor Millsboro. Given what we know about the chemicals, heavy metals and various toxins flowing through this facility, it is unsafe for such a facility to be built this close to residences and a church.
8) Further, the application states “The poultry litter will be obtained from Ray Ellis, a poultry grower and poultry litter broker … Ellis has contracts to remove and broker the poultry litter from 600 to 700 houses.” This much litter will not be coming from adjacent farms. The potential for the production of a significant amount of highly concentrated hazardous material at this facility is high.
9) Where and how will the biochar (which is laden with concentrated hazardous materials) be stored safely once produced at this facility?
10) Point 4.4 states “there is no disposal of materials used in the discovery, development and manufacture of veterinary products, medicines and vaccines.” This is simply not true as the poultry litter by nature contains manure from poultry that were given antibiotics, coccidiostats and vaccines. A poultry litter analysis will show that these components are to be found in the poultry litter which will then be processed at the facility in Seaford and also Millsboro.
11) LACK OF MONITORING - Renewable Oil International DE, LLC has developed this new process which they call “fast pyrolysis biorefinery technology” and are trying to fly under the radar because they claim that it does not meet the requirements of a traditional incinerator. It is completely unclear that any monitoring by appropriate officials of the products including the syngas produced by this facility would occur. How will the citizens know what is being emitted into the atmosphere or being sold as biochar for a soil amendment? It appears that not a single toxic pollutant will be monitored on a regular basis. Since testing isn't being done for most of the toxic and hazardous pollutants, any claims of emissions and products produced at the two facilities being "clean" or "safe" need to be understood in the context that no one really knows what's being produced. It is a given that companies have no interest in obtaining data on their emissions if they're not forced to.
Conclusion:
Full and careful risk assessment for all contaminants should be required, in order to relate contaminant toxicity to type and quantity of products to be produced at these two facilities, assess safe application rates and operating pyrolysis conditions.
Respectfully submitted,
Genell Pridgen
Socially Responsible Agricultural Project
PO Box 1390 Molalla, OR 97038
www.sraproject.org
(252)286-7006
Rainbow28580@yahoo.com
Maria Payan
Socially Responsible Agriculture Project
9 Aubel Rd.
Delta, PA 17314
(717)456-5800
payans@zoominternet.net
Bruce Ballantine
Cindy Wilton
27927 Possum Pt Rd.
Millsboro, DE 19966
Members and Representatives
Protecting Our Indian River
Mr. & Mrs. K. Haynes
27976 Old Swimmimg Hole Rd.
Millsboro, DE 19966
Members and Representatives
Protecting Our Indian River
References:
1 - Comis, Don (2010), Better Ballfields and Rain Gardens Start Below the Surface. Agricultural Research Magazine. November/December 2010 ‐ Vol. 58, No. 10.
2 - Momplaisir, G. M; C. G. Rosal; E. M. Heithmar "Arsenic Speciation Methods for Studying the Environmental Fate of Organoarsenic Animal-Feed Additives," U.S. EPA, NERL- Las Vegas, 2001; (TIM No. 01- 11). Available at: http://www.epa.gov/nerlesd1/chemistry/labmonitor/labresearch.htm Arsenic concentrations cited as 15-30 ppm.
3 - Miller, C.V., T.C., Hancock, and J.M. Denver, 2000, "Environmental Fate and Transport of Arsenical Feed Amendments for Animal Agriculture," American Geophysical Union, 2000 Spring Meeting: Integrative Geoscience Solutions -- A Start for the New Millennium, May 30 - June 3, 2000, Washington, DC. Abstract available at: http://va.water.usgs.gov/GLOBAL/Abst/hancock_agu_2000.htm Arsenic concentrations cited as 15-35 ppm.
4 - Miller, C.V., Foster, G.D., and Huff, T.B.. 2000. "Organic compounds and trace elements in the Pocomoke River and Tributaries, Maryland." U.S. Geological Survey Open-File Report 99-57. Available at: http://pubs.usgs.gov/of/1999/ofr-99-057/
5 - "Chickens, manure, and arsenic," Environmental Science & Technology Policy News, March 22, 2001. Available at: http://pubs.acs.org/doi/pdf/10.1021/es012337m Arsenic concentrations cited as 30-50 ppm.
6 - "Poultry's Price: The Cost to the Bay," The Washington Post, August 1, 1999, pA1. Available at: http://www.washingtonpost.com/wp-srv/local/daily/aug99/chicken1.htm
7 - Scientific and Technical Advisory Committee (STAC) Workshop Report, "Non-Nutritive Feed Issues in Chicken Production," Tidewater Inn, Easton, Maryland, October 2, 2001. Available at: http://www.chesapeake.org/stac/pubs/wrkshops/AgReport.PDF
8 - Holleman, John T. In Arkansas Which Comes First, The Chicken Or The Environment? Tulane Environmental Law J. 6.1, 1992. Concentrations of metals in Arkansas poultry manure cited in "Intensive Poultry Production: Fouling The Environment" article by United Poultry Concerns, on the web at http://www.upc-online.org/fouling.html. "Factory poultry manure contains heavy metals. The 5,100 tons of poultry manure produced daily in Arkansas dumps into the environment, each day, 3,100 pounds of manganese, 3,300 pounds of iron, 540 pounds of copper, 3600 pounds of zinc, and 300 pounds of arsenic." The concentrations given for arsenic work out to 29.4 ppm.
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