“continue to evaluate the feasibility of further measures, which may also include the use of alternative process technologies.” MIC production and primary storage occurred at the East Carbamoylation Center along with the manufacture of carbaryl and aldicarb. The aboveground MIC storage and production of methomyl, thiodicarb, carbosulfan, and carbofuran were in the West Carbamoylation Center. Everyday, MIC was transferred from the primary storage facility to the aboveground day-use storage tank. By ceasing production of methomyl and carbofuran, Bayer was able to remove the need for the aboveground tank. This change allowed for reduction in storage capacity. In addition, a new MIC underground storage facility would be built in the East Carbamoylation Center to accommodate the change in production quantity.
In April 2010, in response to the mandate from Congress and acknowledging the 80 percent reduction plan, the CSB issued a draft statement of task for the National Academies in the Federal Register and solicited public comment on the language. The National Academies began its work in early September 2010 under the finalized statement of task, which can be read in Box 1.1 and Appendix A. This report contains the consensus findings, conclusions, and recommendation developed in response to this task.
DEVELOPMENTS IN WEST VIRGINIA
A number of significant changes occurred at the Bayer facility during the course of the study. A timeline of the events can be found in Figure 1.1, and additional details are provided below.
On August 16, 2010, prior to the National Research Council (NRC) beginning its work, Bayer announced that, as part of an agreement with the U.S. Environmental Protection Agency, it would voluntarily cancel the registration of aldicarb (Temik) for use in or on the remaining crops for which the pesticide was being used, including potatoes, citrus, cotton, and peanuts. As part of the phaseout agreement, farmers would be allowed to continue to use aldicarb on potatoes and citrus until the end of 2011.
For all other crops, production would end by December 2014, distribution and sale of aldicarb would end by December 2016, and growers’ stocks should be exhausted by August 2018. Citing this agreement and global restructuring of its parent company, on January 11, 2011 Bayer announced that “the production of certain carbamates is no longer economically viable for Bayer CropScience.” (Bayer CropScience, 2011b) The company’s intention was to finalize the modifications to the MIC plant at Institute; restart manufacturing of aldicarb, carbaryl, and the intermediate materials required for their production, including MIC; and continue manufacturing those materials until mid-2012.
On January 20, 2011, the CSB released its report on the 2008 accident. Key findings from the investigation identified weaknesses in the following areas: the process hazard analysis, the pre-startup safety review, the startup procedures for