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Technical Summary
Pages 13-20

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From page 13...
... Although no part of the MIC production or storage processes at the Institute facility played a role in the 2008 incident, the U.S. Chemical Safety and Hazard Investigation Board (CSB)
From page 14...
... examine the use and storage of MIC at the Bayer CropScience facility in Institute, West Virginia. The third part of the task was the most complex, containing the following subparts: 3.1.Identify possible approaches for eliminating or reducing the use of MIC in the Bayer carbamate pesticide manufacturing processes; 3.2.Estimate the projected costs of alternative approaches identified above; 3.3.Evaluate the projected benefits of alternative approaches identified above; 3.4.Compare this analysis to the inherently safer process assessments con ducted by Bayer and previous owners of the Institute site; and 3.5.Comment, if possible, on whether and how inherently safer process (ISP)
From page 15...
... administers the Process Safety Management Standard, which has fourteen mandatory elements relating to, among other things, training, documentation, incident investigation, compliance audits, and process hazard analysis. Although companies are required
From page 16...
... INHERENTLY SAFER PROCESS ASSESSMENTS AT BAYER CROPSCIENCE To address the task, a great deal of information was received from Bayer regarding the use and storage of MIC at the facility under their management and the management of the legacy companies, particularly Union Carbide and Rhône Poulenc. This information was examined in order to assess whether ISP assessment or its principles of substitute, minimize, moderate, and simplify were mentioned or evaluated within the analysis of different processes and synthetic routes.
From page 17...
... The legacy owners identi fied possible alternative methods that could have resulted in a reduction in MIC production and inventory, but determined that limitations of technology, product purity, cost, and other issues prohibited their implementation. INHERENTLY SAFER PROCESS ASSESSMENTS Within the statement of task, the NRC was specifically asked to compare its analysis of alternative approaches for eliminating or reducing MIC "to the inherently safer process assessments conducted by Bayer and previous owners of the Institute site." This required consideration of the industry's current understanding of ISPs and assessments as well as the approaches used by Bayer and the legacy companies.
From page 18...
... ISP assessments can be challenging because of the interconnected nature of chemical manufacturing processes, e.g., care must, taken that a risk reduction in one process element does not result in an unexpected risk transfer to a different element. One possible approach for addressing this issue is the use of multi-attribute or -criteria decision analysis, which is described briefly in the next section.
From page 19...
... The process ultimately chosen for the Institute site by the facility's owners, although posing higher risks to the surrounding community due to the volume of MIC stored, decreases the amount of wastewater produced as compared with other methods and thus decreases potential damage to local surface waters. Deciding between multiple process alternatives with conflicting trade-offs is a concern faced by any company.
From page 20...
... Chemical Safety Board and Hazard Investigation Board or other appropriate entity convene a working group to chart a plan for incorporating decision theory frameworks into ISP assessments. The working group should include experts in chemical engineering, ISP design, decision sciences, negotiations, and other relevant disciplines.


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