But facility employees, with the exception of a manager who left in early 2017, "appeared to be unaware of this information," an inquiry by the U.S. Chemical Safety And Hazard Investigation Board found.
The board concluded that Arkema, a French multinational company that manufactures chemicals used to create plastic products, was not prepared for flooding of this magnitude. During Harvey, 6 feet of water wiped out the facility's power and backup generators. With the power out and cooling systems failing, volatile organic peroxides exploded multiple times over the course of a week, producing towering pillars of fire and thick plumes of black smoke.
The board -- an independent federal agency that investigates industrial chemical accidents -- released a 154-page report Thursday morning detailing their findings.
Janet Smith, Arkema spokeswoman, said in a statement that the company was pleased with the board's investigation, largely because it "accurately depicts the unforeseeable nature of the situation Arkema faced during Hurricane Harvey."
"The CSB report shows that Arkema had multiple policies and safeguards in place to address the risks associated with hurricanes, that Arkema followed those policies, and that our employees went to extraordinary lengths, under difficult conditions, to maintain safety at our site," Smith said.
But board members determined that the company's emergency response plan was not enough, confirming a Houston Chronicle report in November.
"Arkema wasn't prepared, but they were not alone," said Vanessa Allen Sutherland, board chairwoman, at a Thursday news conference. "The most valuable lesson here is that facilities should plan and plan again. Don't be lulled into a false sense of security by thinking it can't happen here."
As part of the report, board members issued a number of recommendations to the company, Harris County and industry leaders that include developing better policies for determining flood risks and protecting first responders. The board can offer recommendations and guidance, but it can not fine or punish a company based on its findings.
Their recommendations are particularly pertinent given the timing: the 2018 hurricane season begins June 1.
"We know that in the last several years, severe rainfall has caused increased flooding around the country and government experts believe this trend is likely continue," said board member Kristen Kulinowski, at a Thursday news conference. "Our investigation found a lack of guidance that can help the industry understand and plan for catastrophic flooding."
The Environmental Protection Agency and the Texas Commission on Environmental Quality also are investigating the incident, though their results have not yet been released.
A history of flooding
As Harvey bore down on Southeast Texas and the National Hurricane Center warned of potentially "catastrophic" or "life-threatening" flooding, the company's plans for protecting its product were simple: keep the chemicals cold on-site.
The company had multiple freezer buildings, six backup generators, and, as a last resort, refrigerated trucks. But Arkema didn't consider flooding a "credible risk," the report states, confirming previous reporting by the Chronicle.
Officials thought this despite a 2016 warning from its insurer, Factory Mutual Insurance Co. (FM Global), that the facility was at risk for flooding and parts of its facility sit in the 100-year flood plain and the 500-year flood plain, the report states.
The board found that this thinking was a result of Arkema relying on long-time employee memory of flooding levels. Arkema's Crosby facility has a 40-year history of flooding, but employees could not remember a time when the facility received more than two-feet of water before Harvey.
That method is insufficient, the board reported.
"Companies should develop systems to retain key incident summary information that better document facility risks based on historical external events," the report states.
Along with an inadequate emergency response plan, the board's report confirms other aspects of the facility's failures written by the Chronicle in November: The company's power transformers and backup generators were not high enough off the ground, and it had a tank of an extremely dangerous chemical, isobutylene, located about 40 yards from six refrigerated trailers loaded with organic peroxides that had been relocated during the storm.
Smith pointed out in her statement that the board noted Arkema had "multiple safety systems in place to ensure that organic peroxide products were kept cold."
But in its report, the board said those safety systems were not enough.
Because of this, board members recommended that Arkema develop a policy requiring any facility that manufactures organic peroxides or processes large quantities of highly hazardous chemicals to periodically determine if they're at risk for extreme weather events like hurricanes or floods.
It also recommended that the Crosby facility, specifically, decrease its flood risk to "as low as reasonably practical."
Health and Safety Hazards
Three days after Harvey made landfall Aug. 25, a ride out crew at Arkema's Crosby facility were transporting organic peroxides to nine refrigerated trailers on site in an effort to keep them cool.
In all they transported 350,000 pounds of organic peroxides to those trailers, 2,000 pounds of which had to be transported by hand in the dark, according to a simulation created by the board.
But when those trailers began to fail, the ride out crew evacuated. Officials soon set up a 1.5-mile evacuation zone in anticipation of trailer explosions.
Parts of Highway 90, which runs along the southern end of the plant and bissected the evacuation zone, was kept open to traffic. But the highway remained open to traffic for too long, the report stated, exposing at least 21 people to "decomposition products and smoke from the burning refrigerated trailer and organic peroxides."
Because of this, the board recommended that Harris County make sure emergency personnel are not exposed to hazardous chemical releases.
"Update existing protocols and revise training curricula to include the use of analytical tools, air monitoring, and personal protective equipment, to provide appropriate protection when emergency equipment or personnel need to be moved through an evacuation zone during a hazardous materials release," the report stated.
Several first responders are suing Arkema after they say they were sickened while responding to the fires and chemical releases at the scene. In separate lawsuits, Harris County and hundreds of local residents are trying to hold the company responsible.
Local residents previously told the Chronicle they have been kept in the dark about what they were exposed to because of the explosions on site.
And the board in its report said members aren't aware of whether any long-term health effects would arise from the release of these chemicals.
The board does not conduct these types of tests, they said during the Thursday news conference, and therefore had to rely on EPA data which detected no evidence of organic peroxides.
Alex Stuckey covers science and the environment for the Houston Chronicle. You can reach her at alex.stuckey@chron.com or Twitter.com/alexdstuckey.
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