The Coalition against Bayer Dangers (CBG) and Friends of the Earth Germany have published their objections to a proposed new Bayer MaterialScience factory at Dormagen, Germany. The plant is intended for production of 300,000 metric tons of toluene diisocyanate (TDI) per year. TDI is an intermediate in the production of flexible polyurethane foams.
The main issues in the objections are the risks associated with toxic chemicals such as phosgene, TDI and carbon monoxide. 360,000 metric tons of phosgene per year are supposed to be used at Dormagen as an intermediary. The substance was used in World War I in chemical warfare.
The Coalition against Bayer Dangers believes that the current planning application submitted by BAYER is not acceptable. “At any point about 60 metric tons of phosgene will be stored inside the plant. Despite this, the planning application does not include any impact assessment whatsoever in case of a leak of large amounts of phosgene. The Fukushima disaster and the serious incidents at BAYER factories in recent years show that accidents do not follow a predictable pattern. Hence contingency plans must also be made for more unlikely scenarios," says Philipp Mimkes of CBG.
Further points of criticism are:
* The production facility is situated at a distance of only 283 metres from the nearest factory perimeter. However, the Commission for the Safety of Industrial Plants, instated by the federal German government, recommends a minimum distance of 1,500 metres from residential areas in the case of phosgene.
* Serious incidents in BAYER factories, where phosgene is used in large amounts (Baytown
/USA 2006, Institute
/USA 2008) are not mentioned in the planning application. Investigations of the incidents showed gross negligence by the management.
* Existing worst case scenarios are also not mentioned.
* The production facility will create 10,900 tons of toxic TDI waste, which is intended to be used as fuel in power plants. This would lead to high emissions of pollutants.
* The production of TDI is extremely energy intensive. Each ton of TDI generates five tons of CO2. However, the planning application is lacking a breakdown of energy usage and CO2 emissions for the complete production process.
* Airplane crashes are not considered in the planning application. In the light of heavy air traffic in the Rhine region, this is unacceptable.
However, the group welcomes that - for the first time ever - phosgene facilities will be protected by a containment: “Finally, the company is responding to this demand stipulated by environmental organisations already decades ago,” Philipp Mimkes adds.
Bayer also announced to produce more than 400,000 metric tons of Methylene diphenyl diisocyanate (MDI) rigid foam at Brunsbuettel/Germany – a doubling of the current factory capacity. In 1998 the construction of a TDI factory in Taiwan was prevented by local opposition groups. Protests were mounted primarily against the threats of phosgene.
It is the view of the Coalition against Bayer Dangers that the company should concentrate all its efforts on developing non-phosgene processes for the production of plastics. To support this demand CBG has collected more than 12,400 signatures. CBG will discuss the concerns at the public meeting about the TDI plant on 5 October 2011.