NYS Department of Environmental Conservation
Commissioner Joe Martens
625 Broadway
Albany, New York

Suffolk County Executive Steve Bellone
H. Lee Dennison Building, 12th Floor
100 Veterans Memorial Highway
Hauppauge, New York 11788

February 24, 2013

RE: Air Quality Data From Air Curtain Destructors at Brookhaven Landfill (Debris burning for Superstorm Sandy).

Dear Sirs,

I have reviewed six weeks of air quality data provided by Suffolk County DPW as it pertains to the air quality monitoring devices of fine particulate matter located in the Town of Brookhaven. As you are aware, DEC provided Suffolk County and the Town of Brookhaven with a special permit to utilize Air Curtain Destructors at the Brookhaven Landfill in order to expedite the burning of brush and debris from Superstorm Sandy.

Citizens Campaign for the Environment (CCE) and the Brookhaven Community Coalition (BCC) strongly objected to the use of these Air Curtain Destructors due to well-founded concerns about air quality and the dispersion of fine particulate matter. Brookhaven communities are already overburdened with air pollution concerns, and adding emissions from 3 to 4 Air Curtain Destructors (ACD) would only increase that burden. Unfortunately, the concerns of the Brookhaven community were ignored. In addition, this DEC special permit did not require any air quality monitoring as was being mandated in other parts of New York where these devices are used. In December, I spoke with a representative in the Suffolk County Executive office who agreed that Suffolk County would implement air quality monitors. Two air monitors were placed at the landfill and one was placed approximately a mile and half south of the landfill at the Brookhaven Fire Department on Montauk Highway.

While CCE and BCC understand that processing debris from Superstorm Sandy was and is a challenging undertaking, it is not prudent public policy to solve one problem by creating another problem. In specific, air data results clearly show several days over the air standard for fine particulate matter (35 ug/m3). All monitoring data is depicted as a 24-hour rolling Time Weighted Average (TWA) and therefore the charts provided show many days attaining the standard for the day through the TWA. However, several days contain critical segments of time where emissions were significantly over the standard for several hours. These days only attained a total average below standard due to a dramatic reduction for half the day. This provided a false and misleading standard of safety.

For instance, air quality data at the landfill on Jan 2, 2013 shows that between 11 a.m. and 6 p.m. PM 2.5 was detected between 72 and 98 ug/m3. On Jan 5, 2013 levels exceeded the standard from 11 a.m. through 3 p.m. (58ug/m3) and again at 11 p.m.. Additional instances of excess levels are documented on Jan 6, 2013 (47 63ug/m3) and throughout the day on December 23rd and 24th. December 22nd had a TWA of 102.41 and December 30, 2012 had a TWA of 178.54. The Brookhaven Firehouse monitoring device logged Dec 24th, Jan 5th, and Jan 6th with intervals over air standards. In addition, it is critical to understand and note that these readings only apply to south of the Air Curtain Destructors. To believe that the particulate matter only blew in one direction for 5 months is simply absurd. Therefore, it is clearly reasonable to believe that if monitors had been more accurately and appropriately been place around the ACDs, as was done for residents in Brooklyn at the Floyd Bennett Field site, additional detections would have been captured and exceeded health standards. The Floyd Bennett Field operation in Brooklyn, had 2 ACD and were over air quality standards 5 days. Brookhaven had 4 ACDs and inadequate monitoring.

Given that Suffolk County is located in a non-attainment area designated by EPA, locating 4 ACD in one location was an egregious violation by DEC and Suffolk County in their obligation to protect public health. A 24-hour PM2.5 NAAQS is a health-based standard that was specifically revised in 2006 because of "health studies showing that short-term exposure to PM2.5 is associated with increased mortality and a range of serious health effects, including aggravation of lung disease, asthma attacks, and heart problems." (See EPA Memorandum on Area Designations for the Revised 24-Hour

Fine Particle National Ambient Air Quality Standard, June 8, 2007, available at

http://www.epa.gov/pmdesignations/1997standards/documents/Jun07/june_2007_guidance_for_area_designations_for_2006_24-hour_pm2.5.pdf

Although DEC assured CCE and BCC that these Air Curtain Destructors were not a public health concern and stated "they did not rise to the level of concern that you are suggesting" it appears DEC was incorrect. DEC and Suffolk County were lethargic in indifferent to protecting public health. The data regrettably verifies that our concerns were valid and should have been more aggressively addressed by the County and the State. Air Curtain Destructors should not be allowed for use in populated communities such as Suffolk County and especially not in communities that are already unreasonably burdened with air quality problems.

If you have any questions on this matter please contact Adrienne Esposito at 516-390-7150.

 

Sincerely,

The Brookhaven Community Coalition

Cc: Congressman Tim Bishop
DEC Deputy Commissioner Eugene Leff
DEC Region One Director Peter Scully
Senator Lee Zeldin
Assemblyman Ed Hennessey
Assemblyman Bob Sweeney
Suffolk Legislator Kate Browning
Brookhaven Councilwoman Connie Kepert
Brookhaven Councilman Dan Panico