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Norlite Plant burning PFOA's for Department of Defense, Cohoes, NY, USA


This environmental justice conflict stems from the industrial rotary kiln "Norlite" in Cohoes, NY, burning Aqueous Fire Fighting Foam/Aqueous Film Forming Foam (AFFF) in 2018 and 2019 [1]. Norlite has been operating on South Saratoga Street in Cohoes, NY -- a city of 16,500 people eight miles North of Albany --  since the 1950's [13]. However,  Norlite is now a subsidiary of "Tradebe," which is a waste management company based in Barcelona, Spain. Tradebe operates in Spain, France, the United Kingdom, the United States, and Oman [12].  Generally, Norlite acts as an (aforementioned) industrial rotary kiln to produce aggregate shale, mainly used in construction. The mining for this shale occurs in an on-site quarry, in Cohoes, NY, and Norlite's aggregate shale has been used in projects ranging from the TWA terminal at John F. Kennedy Airport in New York to the Francis Scott Key Bridge in Baltimore Maryland [17].

However, this specific issue of environmental injustice revolves around the incineration of AFFF at Norlite. The Aqueous Fire Fighting Foam (used to put out industrial-sized fires) was supplied by the US Department of Defense, which was hoping to dispose of this waste that had been sitting dormant on military  bases prior to being contracted out to Norlite (for incineration). This foam came from the Marines, the Army and the Navy [22]. Prior to the year 2000, all military-grade AFFF used long-chain PFOS chemicals; however, in recent years the Department of Defense has utilized AFFF comprised of shorter-chain fluorochemicals. Unfortunately, this "short-chain" AFFF is similarly persistent in the natural environment, and has even higher mobility in ground water [22]. Fluorine-free flame suppressants are becoming more readily available for use against high-temperature fires (especially outside of the United States), yet the United States Military remains, requiring of the presence of fluorines in the foam that they use [22]. 

Norlite signed a $2.2 million dollar contract with the Department of Defense (through the Defense Logistics Agency [22]) to incinerate this foam [18], and are one of several commercial waste incinerators spanning the country that has been tapped to dispose of the several millions of gallons of AFFF stored at multiple military bases [22]. The Department of Defense is the nation's largest single user of AFFF, comprising 75% of the country's total use [18]. AFFF contains toxic perfluorinated compounds (PFAS) like PFOA and PFOS [2]. This class of chemicals is most commonly used to make products "non-stick," waterproof, and stain-resistant, and can be found in rain jackets, cookware, and dental floss [16]. These chemicals, when present near human activity, have been linked to causation of testicular, kidney and bladder cancer [3]. Exposure to these chemicals has also been known to result in liver disease and infertility [23].  Soil and surface water samples from around the Norlite plant were found to contain PFAS chemicals [3] -- partially due to the very nature of "PFAS" chemicals, seeing as their atomic chains are incredibly strong, and last "forever." This was also partially due to the fact that to get even close to complete combustion of these chemicals, they must be incinerated at around 1,400 degrees Celsius -- Norlite was burning them at a maximum of 800 degrees Celsius [3]. Finally, AFFF is a flame suppressant. By its very nature, complete combustion of AFFF through incineration is nearly impossible, and is not "safe or sensible" [3]. None of this is surprising, given that from the onset, commercial waste facilities are likely to fail when attempting to successfully incinerate fluorochemicals -- the high temperatures and elongated holding time of these chemicals are a recipe for incomplete combustion, especially when the combustion process is taking place in a facility that is not used to dealing with disposal of these chemicals [22]. The attempted incineration of AFFF can also lead to the creation of smaller PFAS products: ones that the scientific community know how to handle even less than the already-difficult and dangerous chemical chains found in undisturbed AFFF [23]. 

Norlite sits in a designated "Potential Environmental Justice Community" as deemed by the state of New York [4], and is 1,000 feet away from a public housing complex called "Saratoga Sites." According to a ProPublica report last copyrighted in 2019, out of the 331 residents living in Saratoga Sites and another HUD-controlled Cohoes Public Housing Complex "Roulier Heights," 54% of the residents living in these two public housing complexes are making below 30% of the area's median income [20]. 9% of these residents identify as being of minority status (which falls in line with the racial makeup of the town, seeing as Cohoes is 82.5% Non-Hispanic white, 3.11% Hispanic white, 5.86% multiracial, and 4.73% Black or African-American [21]). The Department of Defense is well aware of the largely unsatisfactory nature of incinerating PFAS chemicals at Norlite (both in terms of damage to the natural environment and damage to human health) [5], yet they chose to go ahead and incinerate these chemicals, using a public housing complex as both a laboratory and a potential graveyard. 

Norlite was burning AFFF unbeknownst to the primarily low-income residents that inhabit the neighborhood around it (which is formally zoned as "medium industrial") [5]. On top of the detrimental health effects that AFFF can result in, Saratoga Sites residents (even prior to the burning of AFFF) complained about massive amounts of dust (from the on-site mining of shale that occurs at Norlite year-round) that settles on their cars and on (and even inside of) their homes, snow blackened by soot (rendering it un-playable for chilidren) and vibrations from the blasting occurring at these on-site mines. Residents are also concerned about strange "acetone-like" smells coming from Norlite [5]. Even New York State Department of Environmental Conservation Chair Basil Seggos said, "Folks in Saratoga (Sites) for decades have been complaining about the smells and the booms from the excavation over there" [11].  Saratoga Sites residents are also frustrated by the fact that they have "not received a dime" of the fines that Norlite has had to pay out for violating state and federal environmental policy in the past [3].  Norlite has previously been fined for exceeding the pollution and mercury levels on their permits,  that has then has been dumped into the Mohawk River and emitted into the atmosphere [5]. 

One member of the Sierra Club's Clean Air Team, Jane Williams, was the one to break this information about Norlite burning AFFF, through a "Freedom of Information Act" (FOIA) request to the Department of Defense [9]. Once this information was brought to the public, immediate mobilization took place. The compounded injury of AFFF burning, on top of years of community anger and distrust of Norlite, brought forth calls to shut Norlite down...forever. Attention was brought to this issue through public demonstrations, the use of independent and mainstream media, calls to local and state-wide elected officials, and the filing of lawsuits. Because of the COVID-19 pandemic, organizing around this environmental justice issue had to be extra intentional, specific, and safe. While there were "socially-distanced" protests outside of Governor Andrew Cuomo's mansion in Albany, NY [15], a lot of organizing and advocacy work was online -- through virtual "Norlite Town Hall Meetings," news articles, Letters to the Editor in the Albany Times Union, and podcasts/radio programs. The COVID-19 pandemic not only created more barriers around fighting this issue but also added to the issue itself -- human interaction with PFAS chemicals suppress the human immune system [16], creating more vulnerabilities to COVID-19 in the primarily low-income, already-vulnerable residents surrounding Norlite. 

A major case was filed by the Sierra Club, Earthjustice, and other parties in federal court, alleging that the burning of AFFF violated the National Environmental Policy Act [10] and the National Defense Authorization Act [23]. NEPA almost always insures that an environmental impact statement is thoughtfully crafted before any potentially-harmful, human-caused recurring activity, however, this did not happen... simply because the Department of Defense chose to violate federal law [10]. In late April of 2020, the Cohoes Common Council passed a one-year moratorium of the burning of AFFF in Cohoes, fresh off of the release of a Bennington College-backed study led by Dr. David Bond. This study revealed significant levels of toxic chemicals in soil and water samples around the Norlite plant [14] -- on March 3, 2020, Dr. Bond, Bennington College students, and other professors took these aforementioned soil and water samples, and sent them off to the commercial laboratory "EuroFins." These tests revealed much higher concentrations of PFAS chemicals around the Norlite Plant than in areas further away from the plant, and revealed not only many of the 50 "testable" perfluorinated compounds, but also significantly more of these perfluorinated compounds (than the previous 50) that are not even able to be tested for [19]. 

After this law was passed in Cohoes, the "Norlite Bill" ( a bill banning the incineration of AFFF and other perfluorinated compounds in certain cities) unanimously passed the New York State Assembly and Senate [7], and the New York Department of Environmental Conservation passed an administrative ban on the burning of AFFF [3], Norlite reported to have cancelled their contract with the Department of Defense. In October of 2020, NY DEC Chair Seggos said that recent testing Cohoes drinking water revealed no PFAS contamination [11] -- something that directly contradicts the Bennington College study. 

Residents of Saratoga Sites, the city of Cohoes, and the Capital Region of New York await for the final signature from Governor Andrew Cuomo that would finalize the Norlite Bill, legally banning the burning of AFFF in different parts of New York. Although Norlite is not currently burning AFFF, the environmental justice community residing in Cohoes wants a permanent, definitive end to the blatant flippancy and disregard for their quality of life that Norlite has shown time and time again.

Basic Data

Name of conflict:Norlite Plant burning PFOA's for Department of Defense, Cohoes, NY, USA
Country:United States of America
State or province:New York
Location of conflict:Cohoes
Accuracy of locationMEDIUM (Regional level)

Source of Conflict

Type of conflict. 1st level:Waste Management
Type of conflict. 2nd level:Incinerators
Specific commodities:Chemical products
Industrial waste

Project Details and Actors

Project details

-Aside from AFFF, Norlite also burns over 475 chemical descriptions. Of the toxic waste that contains these chemical descriptions, 38% of the waste shipped is from within New York State, 37% is from Connecticut, 9% is from Pennsylvania, and 16% is from other states.

-Norlite is only one of 4 other hazardous waste facilities in the country that have signed 5-year contracts with the Department of Defense, to burn the toxic firefighting foam.

-Norlite burned over 2,000,000 tons of AFFF from 2018 to January of 2020.

-AFFF contains roughly 250 different perfluorinated compounds [19].

-Laboratory standards for testing exist for only 50 out of the 250 perfluorinated compounds found in AFFF (or, one fifth) [19].

-These perfluorinated chemicals that comprise AFFF have a half life of 7 years.

-It takes as little as 14 trillion parts per million in drinking water for PFAS to pose a risk to human health [18].

-The PFOS contamination level in the soil adjacent to the Norlite plant was found to be twice as high than the background PFOS soil contamination of the area [19].

-The AFFF burned at Norlite came from 60 different military sites in 25 different states.

-Over the course of Norlite's history, and up through the end of the incineration of the AFFF, Norlite discharges 100,000 gallons of "treated water" into the Mohawk River.

- There are "70 families in the shadows of the Norlite smoke stacks" [3], in which the closest families sit 1,000 feet away from the Norlite incinerators [5].

-The lawsuit headed by the Sierra Club and Earthjustice was a "26 page document filed in federal court" [1]

-Norlite accepts the hazardous waste that it burns under multiple separate permits: the Title V Air Permit, the Resource Conservation and Recovery Act Permit, and the Part 373 Hazardous Waste Permit. Under the Title V Air Permit, Norlite is allowed to burn substances like hazardous waste and waste oil [5].

-Norlite's Operational Manual, detailing what hazardous materials they are burning and in what combinations, is over 700 pages long.

-The Norlite Bill is formally known as S.7880B/A. 9952B

Level of Investment for the conflictive projectUnclear.
Type of populationUrban
Start of the conflict:2020
Company names or state enterprises:Norlite from Spain - Incineration of toxic chemicals
Tradebe from Spain
Relevant government actors:The United States Department of Defense, The New York State Department of Environmental Conservation, The New York State Assembly and Senate, The Environmental Protection Agency, the Mayor and City Council of Cohoes, NY
Environmental justice organizations (and other supporters) and their websites, if available:Lights Out Norlite
Saratoga Sites Against Norlite Incineration
Hudson Mohawk Environmental Action Network:
The Sanctuary for Independent Media

Conflict & Mobilization

IntensityLOW (some local organising)
Reaction stageIn REACTION to the implementation (during construction or operation)
Groups mobilizing:Local ejos
Local government/political parties
Local scientists/professionals
Forms of mobilization:Community-based participative research (popular epidemiology studies, etc..)
Development of a network/collective action
Involvement of national and international NGOs
Lawsuits, court cases, judicial activism
Media based activism/alternative media
Official complaint letters and petitions
Public campaigns


Environmental ImpactsVisible: Air pollution, Noise pollution, Soil contamination, Groundwater pollution or depletion
Potential: Surface water pollution / Decreasing water (physico-chemical, biological) quality
Health ImpactsVisible: Mental problems including stress, depression and suicide
Potential: Exposure to unknown or uncertain complex risks (radiation, etc…)
Other Health impactsThe inhalation of the dust from the mining of the shale, by the local residents of the community, can lead to respiratory problems. The main/major concern from residents around Norlite are the long-term, detrimental health impacts of the inhalation and consumption of perfluorinated chemicals from the AFFF.
Socio-economical ImpactsPotential: Violations of human rights


Project StatusStopped
Conflict outcome / response:Court decision (undecided)
New legislation
Under negotiation
Project temporarily suspended
Proposal and development of alternatives:The residents of Saratoga Sites Public Housing Complex, and the broader residents of Cohoes and the Capital Region, would like to see Norlite closed forever. However, there are no clear "alternatives" being proposed for Norlite, seeing that Norlite is a non-necessary privately-owned aggregate shale manufacturer. Norlite is not providing any sort of publicly-shared good (such as electricity, gas/oil, etc), so there need not be an "alternative" to Norlite.
Do you consider this an environmental justice success? Was environmental justice served?:Not Sure
Briefly explain:As of now (early November of 2020), Norlite has "stopped burning the chemicals in its kilns which are undergoing scrubber upgrades. But the company will likely start the burning again in an experimental fashion to see if it can safely and efficiently get rid of the compounds" {6}.
Also, as of November 2020, a bill which bans the burning of AFFF in the state of New York has passed both the New York State Legislature and Senate. This bill (S7880B/A9952) is awaiting the signature of New York Governor Andrew Cuomo [7}].
The New York State Department of Environmental Conservation is continuing with the routine re-permitting process of Norlite (Norlite's permit expires in 2021) [11], much to the distress of local activists. However, the New York DEC will be taking around 50 soil and water samples from around 30 different sites, both upstream and downstream from the Norlite plant, to test for prevalence of PFAS compounds and heavy metals [8].

Sources & Materials

Juridical relevant texts related to the conflict (laws, legislations, EIAs, etc)

[13] U.S. Department of Health and Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry: "Public Health Assessment for Norlite Corporation," 12/02/2005.

The "Public Health Assessment was prepared by ATSDR pursuant to the Comprehensive Environmental Response, Compensation, Liability Act."

[22] Sonya Lunder: "Written Testimony for House Committee on Oversight and Reform, Sub Committee Environment: Examining PFAS Chemicals and Their Risks." 03/26/2019.

References to published books, academic articles, movies or published documentaries

[18] Kieran Yater: "Department of Defense Burning PFAS in Cohoes, NY." 05/01/2020.

[19] David Bond and Judith Enck: "News Release," 04/27/2020.

[1] Dave Lucas: "Lawsuit Says PFOA and PFOS Have Been Secretly Incinerated in Cohoes," wamc. org, 02/20/2020.

[2] Bennington College: "Understanding PFOA," 04/2020.

[4] New York Department of Environmental Conservation: "Potential Environmental Justice Areas in Albany County, NY," 2000.

[6] Rick Karlin: "Toxic PFOA and PFOS Burning at Norlite in Cohoes went unreported," 02/25/2020.

[7] Dave Lucas: "New York State Senate, Assembly Pass Bill Banning Burning Firefighting Foam," 06/11/2020.

[8] Emily Burkhard: "DEC discusses plans for PFAS testing around Norlite," 10/21/2020.

[9] Alexis Goldsmith: "Norlite Incinerator a 'serial noncompliar' of environmental law, says chair of National Clean Air Team," 07/22/2020.

[11] Matt Hunter: "DEC To Conduct Soil, Water Testing Near Norlite Plant In Cohoes," 10/01/2020.

[12] Tradebe: "About Us," 2020.

[14] Emily Burkhard: "Cohoes bans burning of firefighting foam containing PFAS chemicals," 04/28/2020.

[15] WRGB Staff: "Residents to Gather at Governor's Mansion, urge signing of bill to ban burning toxic foam," 10/02/2020.

[16] Jamie Dewitt, Phil Brown, Courtney Carignan, Shaina Kasper, Laurel Schaider, Cheryl Osimo, and Maia Fitzstevens: "Op-ed: PFAS chemicals -- the other immune system threat," 07/06/2020.

[17] Norlite Lightweight Aggregate: "Projects," 2013.

[20] ProPublica: "HUD's House of Cards: Roulier Heights/ Saratoga Sites,", 2019.

[21] Data USA: "Cohoes, NY," datausa.

[23] Elizabeth Ahearn: "The Fight Against Burning Toxic 'Forever' Chemicals at Norlite," Sierra Club. 08/19/2020.

[24] About Norlite (November 2020)

Related media links to videos, campaigns, social network

[3] The Sanctuary for Independent Media: "Norlite Town Hall Meeting," 06/22/2020.

[5] Alexis Goldsmith: "An Overview of Norlite," 03/06/2020.

Meta information

Contributor:Gabe Feldman-Schwartz, Skidmore College, [email protected]; Andrew J. Schneller, Skidmore College
Last update21/09/2020
Conflict ID:5229



Potential Environmental Justice Areas in Cohoes, NY

The purple portion of this photograph highlights the "potential environmental justice areas" in the city of Cohoes, as deemed by the New York State Department of Environmental Conservation. Both Saratoga Sites and Norlite lie in the purple portion. From New York Department of Environmental Conservation: "Potential Environmental Justice Areas in Albany County, NY," 2000.

Saratoga Sites in the shadow of Norlite

This photo illustrates the sheer proximity of the Saratoga Sites Public Housing Complex to the Norlite smoke stacks. From: Bennington College: "Understanding PFOA," 04/2020. Accessed 11/29/2020

Mayor Bill Keeler standing in a courtyard at Saratoga Sites.

Cohoes Mayor Bill Keeler stands in a courtyard at the public housing complex. He (along with the Cohoes Common Council) issued a moratorium of the burning of AFFF within the Cohoes city limits. Photo from Kris Maher's "New York Town Discovers a Possibly Toxic Problem," appearing in The Wall Street Journal on 05/20/2020. Photo taken by Christopher Capozziello. Accessed 11/29/2020.

Joe Ritchie

Photograph taken of Joe Ritchie, who is an outspoken advocate and activist leading Saratoga Sites residents to push back against Norlite. He is the president of the non-profit "Saratoga Sites Against Norlite Emissions." From: Steffi Santos, "Norlite Town Hall Preview: Joe Ritchie." The Sanctuary for Independent Media. 07/21/2020. Accessed 11/29/2020.