November 20, 2024
We represent technical experts, scientists, and advocates concerned about plans to incinerate highly toxic waste from Bhopal, India in an incinerator that has failed six of its last seven stack tests. Many of us have first-hand knowledge that hazardous waste incineration damages public health as a remediation method due to its poor operational performance. For example, almost every commercial hazardous waste incinerator in the U.S. has violated its air pollution permits in the last 3 years and emitted toxic air pollution into communities hosting the facilities.
The waste incineration process always creates toxic air emissions and ash that contain several hazardous chemicals like dioxins, furans, PCBs, PFAS, mercury, cadmium, lead… The dangers these chemicals pose when released into the environment is recognized internationally in multinational environmental agreements such as the Stockholm Convention on Persistent Organic Pollutants, the Minamata Convention on Mercury, the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, and the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade. The Indian Government has ratified all of these treaties.
With this in mind, we are alarmed to learn of remediation plans to incinerate highly toxic waste left over from the Bhopal Disaster, arguably the worst industrial chemical disaster to date. The December 1984 tragedy involved the leak of methyl isocyanate gas from a pesticide manufacturing plant owned by Union Carbide. This resulted in an estimated 23,000 deaths and a range of long term environmental and social impacts, including massive amounts of contaminated water, sludges, buildings, and soils which all still remain in Bhopal.
We firmly agree that the disposal of the hazardous wastes requires the most urgent action to end the continued harm to people and the environment of this disaster. However, the Ministry of Chemicals and Fertilizers contract to incinerate 345 MT of waste in a facility in Pithampur, Indore, MP which is over 220 km from Bhopal, is a very ill-advised solution and treats only a small fraction of the waste. In fact, this plan will only serve to spread the contamination at Bhopal into another community due to the poor operational performance of the incinerator. The 345 MT is less than 4% of the estimated 700,000 MT of sludges, soils, water, and contaminated buildings in Bhopal needing a final solution. These contaminated wastes are located less than 500 meters away from residential areas in Bhopal.
We recommend the India government abandon its plans to employ incineration as a remediation plan and instead perform a comprehensive site assessment, and use advanced non-incineration treatment technologies for treatment of the wastes.
The context of our recommendations are:
- The 345 MT of waste includes contaminated soil, Sevin and Napthal tars, reactor sludges, and semi-processed pesticides. Some of these wastes contain persistent organic pollutants that are difficult to destroy, and survive incineration. Furthermore, there is a toxic hotspot in the middle of the city where hundreds of thousands of tonnes of toxic waste remain buried in the pits outside the abandoned Union Carbide factory and within 19 unlined pits. This waste has led to the contamination of groundwater for over two hundred thousand people in 42 communities with Persistent Organic Pollutants, toxic agricultural chemicals, and heavy metals. Unfortunately, these wastes are also laced with hexachlorobenzene, aldrin, dieldrin, and other persistent, organic pollutants.
- Though six out of the seven stack tests for this proposed incinerator have failed and indicate that the poor performance of the incinerator is exposing nearby communities
to hazardous chemicals, the Ministry appears firm in their intent to pursue using this incinerator to burn the Bhopal waste. Community members fear that this plan would just expand the area of contamination to an entire new community.
We urgently propose these recommendations for the specified hazardous wastes:
- The Indian Government should carry out a comprehensive and transparent scientific assessment of the contaminated water, soils, sludges, and buildings with the assistance of the United Nations Environment Program. The extent of the contamination, the chemicals present, and the potential technologies intended to remediate the situation should have environmental impact assessments performed. Some advanced, non-incineration treatment technologies such as Super Critical Water Oxidation and Wet Air Oxidation can treat both the groundwater and the surface contamination. The government of India should prioritize assessing technologies that can treat both the groundwater contamination and the contamination on the surface.All assessments of advanced, non-incineration waste treatment technologies should be done with meaningful public participation and involve the affected communities. The results of these technology assessments should be available to the public.
- The Dow Chemical Company (the current owner of Union Carbide) should be made to pay for the comprehensive environmental assessment, as well as the disposal and remediation costs and must follow international environmental principles such as Polluter Pays and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
We are very concerned about the long-term impacts on people and the environment from the wastes remaining in place from the Bhopal disaster. A new generation of people affected by the intergenerational exposure to these highly toxic chemicals has been born, suffered, and died there and the land has still not been cleaned up. The toxic chemicals remain in place poisoning the soil, the air, the water, and the next generation of survivors
Signed:
Annie Leonard
Asif Qureshin b
Charlie Cray
Daphne Wysham
Jane Williams
Jim Puckett
Jindrich Petrlik
Jorge Emmanuel
Lee Bell
Neil Tangri
Paul Connett
Ravi Agarwal
Rittwick Dutta
Ruth Stringer
Yuyun Ismawati