The article below involves laws and ordinances involving PFAS, GenX and other Toxic Chemicals used in Solar Panels, Wiring and Coatings.
Below this article, we have attached a pdf file of the entire 11 page document that you can download FREE.
The summery of this article states:
"Prior to construction, Hecate Energy (the local solar developer) should be held responsible to neighboring residents and Coxsackie’s municipal government by providing documentation that the solar panels, coatings, and electrical infrastructure specified for the project do not contain PFAS or other toxic chemicals.
Attempting to remedy a “forever chemical” such as PFAS contamination over more than a thousand acres of solar coverage would likely be impossible.
While there are a few alternative options that may be safer, these products are more expensive and are manufactured in smaller quantities. Utility-scale solar power plants require hundreds of thousands, if not millions, of photovoltaic panels at the time of installation.
The ability to manufacture and deliver this quantity is limited to the very largest suppliers, most of them based in China, where Material Data and Safety Sheets are limited and if provided the information is questionable.
Reputable solar panel manufacturing companies that freely provide Material Data and Safety Sheets may be limited.
Solar developers that provide toxicity guarantees on their panels being free of dangerous chemicals may be even fewer.
While the level of toxicity of ARC and ASC may lack clarity, the coatings’ exposure to the elements and where the
sloughed-off chemicals will be deposited is not. The chemicals are likely to enter the soil and groundwater.
When reviewing this Application, the Siting Board must not rely on good intentions. As has been noted throughout this proceeding, multiple solar projects will be constructed in the watershed of Sleepy Hollow Lake.
Measures should be taken to determine that panels, electrical infrastructure, and wiring for these projects is PFAS-free.
What we are discussing here is a matter of public health and safety, we encourage the Board to require developers to provide specification sheets, and to describe preventive measures, testing policies, and Material and Data Safety Sheets in order to protect Cox- sackie public health and to protect the town from future liability.
Preventative measures—not after-the-fact remediation—are the answer to avoiding PFAS contamination of soil, stormwater runoff, drinking water, and aquifers surrounding the project.
In July 2021, the Town of Avon, New York adopted Local Law 3 of 2021. This precedent-setting amendment to the local solar law prohibits using solar panels that “utilize or contain any amount of GenX chemicals or polyfluoroalkyl (PFAS) substances.”
1 This position aligns with state and federal laws protecting our water supply. For the longterm safety of Coxsackie residents, Hecate Energy (Hecate) and its successors should agree to a Certificate condition that prior to construction, Hecate will provide documentation verifying that the solar panels and associated electrical equipment used to construct the Greene County Solar Facility (the Facility) do not contain per- and polyfluoroalkyl substances (PFAS), including PFOA, PFOS, and GenX chemicals.
We would like to believe that Hecate’s commitment to our town’s public health and safety, as well as their desire to avoid potential future liability, would encourage them to give these comments careful consideration. Hecate must rely on manufacturers’ data, which may not be fully transparent for solar panels and lithium-ion batteries, especially
when they are manufactured outside of the United States—in this case often in China.
This Certificate condition would help safeguard our soil, surface waters, and ground-water from potential contamination.
While such protection would help protect Sleepy Hollow’s water supply, it provides important safeguards for all residents living in the vicinity of the Facility. Hecate and the Town of Coxsackie should perform pre- and post-installation soil and water testing, with annual monitoring. In addition, the installer should fund an escrow account for the Town to hire an independent, certified third-party laboratory for soil and water testing.
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Below are a few important references and statements made in the article.
PFAS and related compounds
According to the National Institute of Environmental Health Sciences, perfluoroalkyl and polyfluoroalkyl substances (PFAS) are toxic, persistent, and bioaccumulative.
These synthetic fluorochemicals were first developed in the 1930s and have strong carbon-flourine bonds that make the structure repel both oil and water.
The Green Science Policy Institute details that these man-made chemicals are widely used in building materials such as paints, cleaning products, non-stick coatings, sealants, tapes, wire coverings, glass, solar panels, and batteries.
PFAS is commonly found in foam used to extinguish electrical fires.
These “forever chemicals” have been linked to cancer and other health issues. Certain PFAS do not break down easily, causing them to remain indefinitely in the soil and water. Their potential hazard and persistence in the environment may pose a cumulative danger to public health.
PFAS comprise a group of compounds, including PFOA, PFOS and GenX chemicals.
The United States Environmental Protection Agency (EPA) has identified that the potentially toxic and carcinogenic nature of many of these chemicals demands careful evaluation.
PFAS legislation in New York StateThe disposal of PFAS-containing materials is problematic, as evidenced by the recent cleanup and lawsuits filed against Noralite Hazardous Waste Facility in Cohoes, New York.
In July 2021, the village of Hoosick Falls reached a $65 million settlement with Saint-Gobain, Honeywell International, 3M, and DuPont for PFOA contamination of their groundwater that affected at least 544 private wells.
Unfortunately the water remains contaminated, and the plant that used PFOA chemicals has been declared a Superfund site.
In 2016, the NYS Department of Environmental Conservation (DEC) issued a regulatory impact statement to 6 NYCRR Part 597 adding PFOA and PFOS as hazardous substances. This ruling was adopted by the DEC in March 2017.
In July 2020, NYS passed S.8817 and A.4739-C, which ban the use of PFAS in food packaging.
And in August 2020, the NYS Department of Public Health (DPH) voted to set the maximum contaminant levels (MCLs) at 10 parts per trillion (10 ppt) for both PFOA and PFOS in our drinking water supply.
NYS legislation permits the DPH to require that public water systems are tested for the contaminants and ensure that elevated levels are addressed.
North Carolina is among the top three states for solar development. By February 2018, residents and the state were questioning the presence of PFAS in solar panels.
The North Carolina State Journal reported that EPA physical scientist Dr. Mark J. Strynar provided 39 records from the SciFinder database used by the EPA to identify applications of PFAS with solar panels.
In August 2018, The Carolina Journal reported that the EPA confirmed that PFAS are used in solar panel production.
PFAS Federal legislation
Federal regulations surrounding PFAS are being adopted rapidly, and further restrictions at the national level are expected.
US Representative Debbie Dingell (D-MI-12) sponsored Bill H.R.2467, PFAS Action Act of 2021, to “establish requirements and incentives to limit the use of perfluoroalkyl and polyfluoroalkyl substances, commonly referred to as PFAS, and remediate PFAS in the environment.”
The Bill passed the House July 21, 2021 and is awaiting a vote in the Senate.
The Executive Office of the President and other advocacy groups such as Consumer Reports support passage of the
Bill.
Additionally, the Environmental Protection Agency (EPA) proposes reporting and record-keeping requirements for PFAS under the Toxic Substances Control Act (TSCA).
23 PFAS in solar panel and battery manufacturing
Despite industry and a few academic assurances to the contrary, broad research consistently indicates that PFAS chemicals are used in solar panel and battery manufacturing and installation.
PFAS is found in the coatings on electrical wires, backing panels, tapes, and adhesives.
Of particular concern is the use of PFAS in anti-reflective coatings (ARC) and anti-soil coatings (ASC) that are used to increase solar panel productivity.
Material and Data Safety Sheets detail the contents of products manufactured in the United States. However, at this time, China is the major supplier of polysilicon solar panels and batteries.
Accountability and transparency for materials and products made outside of the
United States is questionable.
wo types of solar panel coatings are commonly used: anti-reflective coatings (ARC)
and anti-soil coatings (ASC)
Anti-Reflective Coating (ARC)
A bare silicon glass surface may have a reflection index of more than 30%. 27 Anti-reflec-
tive coatings (ARC) are used to increase solar panel productivity by adding a dielectric
coating on the glass surface. This coating textures the glass surface, which results in spe-
cific bands of wave lengths to be trapped inside the panel where they can generate ad-
ditional electricity by coming in contact with the photovoltaic cells.
In their Application Appendix 15-A: Glare Analysis, Hecate Energy states that the pan-
els they expect to use will have an anti-reflective coating, presumably to increase effi-
ciency.
ASC is typically manufactured with either silicon dioxide (SiO2) or titanium dioxide
(TiO2) nanoparticles combined with long chains of fluoropolymers.
PDF File containing entire report is located HERE.In 2020, Gizelle C. Oehler found that certain ASC break down in as little as two weeks:
The location or accumulated amounts of the degraded chemicals is not discussed in these studies. It is logical to assume that the chemicals sloughing off with the rainwater are deposited into the underlying soil, groundwater and aquifers.
The cumulative effect of tens of thousands of solar panels for 35 or more years would most likely permanently
contaminate the site’s groundwater, soil, and stormwater runoff. If coatings are reapplied during the projects lifetime then additional concerns are raised. How is the ground protected during reapplication? How often is the coating reapplied to the panels on site?
Improper disposal of broken and decommissioned solar panels may permanently contaminate landfills and any nearby aquifers.
If regulations continue to become more restrictive, how will the panels be disposed of, and is the decommissioning fund adequate?
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