meeting of the committee, Dr. Steven Smythe speaking on behalf of the company, stated that 29 routes to MIC production had been identified, and four had been evaluated in greater detail. Although the materials relating to the alternatives and their evaluation were provided to the committee for review in good faith, the documentation was rather disjointed and discontinuous, with documents ranging from undated handwritten notes without attribution to in-depth typewritten analyses of findings.

Therefore, the process assessments presented here are drawn from documents provided by Bayer and from the current academic and patent literature. Information gaps within the historic documents could result in gaps within these assessments.

ALTERNATIVES ASSESSMENT

In considering the adoption of a new or redesigned process, it is helpful to break down the impact that the proposed redesign would have on the elements outlined in Chapter 4, namely selection of basic technology, implementation of the selected technology, plant design, detailed equipment design, and impact on operations. The options facing the facility’s owners—Bayer CropScience today and the legacy companies in the past—were (1) continuing with the existing process, (2) adopting an alternative chemical process not involving MIC, (3) using an alternative process involving MIC production that would consume MIC immediately (just-in-time) and thus not require storage, and (4) reducing the volume of stored MIC and the risks of transporting MIC from one facility within the site to another by rearranging process equipment. Each of these has implications for the facility as a whole, and the technical considerations for them are presented below. However, a key motivation for this NRC study is to evaluate whether Bayer could have identified a superior process for manufacturing pesticides at the Institute facility that would have reduced risks to the surrounding communities.

Any potential changes proposed by Bayer CropScience were compared to the processes in place in 2008, referred to here as the “existing process,” for the chemistry and production methods in place at that time.

Production of MIC

There are a number of possible methods for production of MIC. This chemistry has been used for decades, and much has been written about the possible paths for production. In light of Bayer’s decision to no longer produce or store large quantities of MIC onsite, a full evaluation of every possible alternative method of production is not presented here. Rather, this section describes four methods evaluated by Bayer and previous owners of the facility. The evaluations of these processes and the role those evaluations played in Bayer’s decision making are described in Chapter 6.



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