“Adversity does not build character, it reveals it” -James Lane Allen

I have been very interested in what the press has had to say about process safety issues following Hurricane Harvey. I was also very gratified when the U.S. Chemical Safety Board (CSB) put out a warning that start-up was one the most dangerous operations in the life of a chemical process. The CSB noted that following Harvey, operations, maintenance, and technical personnel were going to be tired and vulnerable as they re-started their plants, and the Board urged great care when re-starting them.

I was also very interested when my wife, Chris, mentioned to me that she kept hearing reports on the news about a plant in Texas that was going to blow up because of Hurricane Harvey. I have worked in the chemical industry since I was barely out of high school, including work in various plants on the coast of the Gulf of Mexico. Hurricane season comes every year and every Gulf coast plant where I have worked had contingency plans for an impending hurricane. They shut down processes. They fill empty tanks so they don’t float away in a flood. They send all but essential personnel home to tend to their families and homes. They make arrangements for outages—electricity, water, steam, food.

“That’s just fear mongering,” I assured her. However, on Wednesday night, I sat down with her, high and dry in our home in St. Louis, and watched Rachel Maddow’s report on the Arkema plant in Crosby, Texas.

Leading off with West Fertilizer

Ms. Maddow led off her report with a description of the 2013 disaster at the West Fertilizer Company in West, Texas, outside of Waco. When that portion was done, Chris commented, “I’ve heard you talk about that explosion, but I didn’t realize that they had built the plant right in the middle of all those schools and homes.”

I explained that while there was much that was wrong with what happened in West, Texas, the plant had come first and everything around it had come later. “Nobody even pretends that they didn’t know. If you are from Texas, site of one of the worst ammonium nitrate explosions in the history of the world when the Grand Camp blew up in Texas City in 1947, not knowing that ammonium nitrate can explode is just willful ignorance.”

The Situation at the Arkema Plant in Crosby, Texas

Maddow’s report then shifted to describing the situation at the Arkema plant in Crosby, Texas, where they produce organic peroxides. Just hearing the term, “organic peroxide,” sends shivers down my spine. As a high school chemistry student, I remember finding an ancient bottle of ethyl ether on the shelf and my chemistry teacher going into a full blown panic. That’s when I learned about the incredibly explosive and shock sensitive nature of organic peroxides. While dilute solutions of benzoyl peroxide are great for teenage complexions, the pure staff is an explosive hazard.

I was impressed to learn that Richard Rowe, the CEO of Arkema’s North American unit, had held a press conference to share their very grave concerns about the power loss and resulting loss of refrigeration. The property that makes organic peroxides valuable is that they are very reactive. That is to say, they are unstable. To avoid them going into uncontrolled decomposition, their producers and users store them at temperatures below their self accelerating decomposition temperature (SADT), which are often much lower than ambient temperatures, especially ambient temperature in Texas in August. In other words, they store them in refrigerated warehouses. However, refrigerated warehouses require power to operate and Hurricane Harvey knocked out the power.

The Arkema plant had anticipated that, and had generators on standby. They didn’t go get the generators at the last minute; I doubt there was a generator available to the plant from the moment the tropical depression out in the ocean was named Harvey. The plant also had a back-up plan for its back-up plan. It had refrigerated trailers on site, ready to hold the organic peroxides if they lost power and then also lost their generators.

Despite their normal procedures for safely storing their product, and their back-up plans if their normal procedures failed, and their back-up back-up plans if their back-up plans failed, the personnel at the plant determined that the situation was beyond their control—that they could not guarantee that the organic peroxides would not warm above their SADT and result in either fires or explosions.

They did the responsible thing. They alerted emergency response personnel, they determined a safe evacuation zone and called for the evacuation, they pulled their own personnel out of harm’s way, and they notified the press and the public that there was a problem.

No Good Deed Goes Unpunished

The response by the press in the midst of this crisis was to demand more information. Maddow’s report included an interview with Matt Dempsey with the Houston Chronicle, a reporter with an impressive history of reporting on the chemical industry in the Houston area. He was especially incensed that Arkema would not share the most recent Tier II reports, so that he could judge for himself whether Arkema and local officials were telling the truth about the crisis at the plant. However, based on previous Tier II reports, he was able to find chemical engineering professors who had no familiarity with the specific details of the current crisis at the Arkema plant who were nonetheless willing to offer opinions on the severity of the looming disaster.

In most jurisdiction of the United States, a reporter would be able to obtain a copy of a Tier II report—formally, the Emergency and Hazardous Chemical Inventory Form—from the relevant state and local agency. Covered facilities are required to submit the report to local fire departments, Local Emergency Planning Committees (LEPCs) and State Emergency Response Commissions (SERCs) so those agencies can plan in advance on how to respond to emergencies at those covered facilities. It is required by the EPA under Section 312 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA). In this regard, “the community” is defined as emergency planning and response organizations.

Following the West, Texas disaster, the State of Texas took the unusual and controversial step of prohibiting the release of Tier II reports to the general public—the press and private citizens. Instead, the public was instructed to request chemical inventory information directly from the companies that prepared them. Companies were then put in a position of balancing their private commercial and security interests in confidentiality with the public’s interest in disclosure.

Arkema made the choice not to release their Tier II report to a reporter. Time will tell whether that was a wise choice in the long run. In the short run, during this current crisis, it has been a public relations disaster; releasing some information in the interest of better protecting the public has been greeted with sharp criticism for not releasing more. Arkema probably got it wrong when they decided not release more information about what was likely to be released. No good deed goes unpunished.

“Worst-case Scenarios”

The press has also made much of Arkema’s worst-case scenarios as reported to the EPA in their Risk Management Plans, required under 40 CFR 68, commonly known as the RMP Rule. The reported worst-cast scenarios address the release sulfur dioxide, which is on the RMP list of toxics, and methylpropene, which is on the RMP list of flammables. The “worst-case” scenarios don’t include organic peroxides and don’t consider hurricanes. In the minds of some, Arkema didn’t address the “worst-case”.

To begin with, “worst-case” is a nonsense term. It suggests that there is nothing worse that could happen. However, given any scenario, anyone with some imagination can conceive of something worse. So the EPA defined very specifically what it wanted addressed as a “worst-case” scenario. There is no pretense on anyone’s part that the RMP Worst-Case represents the worst scenario that could possibly happen, or for that matter, a case that is likely to happen.

In the Maddow report, however, reporter Matt Dempsey compounded the misunderstanding when he spoke about the conditions used in calculating the worst case. He made the point that the so-called worst case assumed ideal weather conditions, and clearly the weather was much worse than that. To be clear to anyone who is unfamiliar with the EPA’s requirements for calculating the worst-case, the RMP Rule requires that the worst-case scenario assume an atmospheric stability class F. Atmospheric stability class go from A (very unstable) to F (stable). When the atmosphere is very stable, a plume of toxic gas will travel farther before being diluted to the point of harmlessness. The conditions that are ideal for picnics are also ideal for extending the reach of a toxic release. When the weather is worse—more unstable—a toxic release is dispersed more quickly and has less impact. When Dempsey scoffed at the atmospheric conditions used in the worst-case estimations for Arkema’s RMP report, he was just wrong.

Getting it Right

People look for experts to explain what is happening and leaders to tell them what to do. During a crisis, there are rarely enough of either, and there is never enough time for thoughtful, considered responses. People who are not necessarily qualified step up to fill the void, and even people who are normally very qualified can get it wrong in a crisis.

In this unfolding crisis, there is much to complain about. All across the Houston region, organizations, public and private, failed to adequately prepare for weather catastrophes that are becoming increasingly common. Arkema failed to distinguish between a routine request for information and a request for information borne of a crisis. Reporters, in search of a story, have shaded the Arkema crisis in a way to make it sensational. They’ve all contributed to getting it wrong.

There is also a lot that has been done in the way of getting it right. Arkema did quickly recognize that they had a problem that was beyond their ability to deal with and notify all the correct agencies. They went to the press to enlist their help in getting the word out. The press did take the crisis seriously and did get the word out. Local agencies responded.

At this point, some of the organic peroxides have warmed to temperatures above their SADT, and predictably, have caught on fire or even exploded. While anyone who has been subject to smoke inhalation from this incident should seek medical advice, as would be the case for any kind of smoke inhalation, no one has been killed or even seriously injured and there has been no serious equipment damage.

James Allen said that adversity does not build character, it reveals it. It’s not just character, though. Adversity reveals all of our strengths and all of our weaknesses. Now is not the time for introspection. Now is the time for action. After this crisis passes—and it will pass—we need to look at what worked and what did not work, what we got wrong and what we got right, and adjust accordingly.