CROSBY, Texas - A little more than a month after first responders filed a lawsuit against Arkema for explosions at its Crosby plant, the chemical production company responded with answers to the suit in Harris County District Court.

Arkema’s overarching response states that the lawsuit is based on “incomplete information, false assumptions and intentional misrepresentations.”

In the filing, Arkema states that no one could have predicted “in enough time to act on that prediction” the unprecedented flooding. As far as the amount of rainfall, nearly 9 trillion gallons of water Harris County, Arkema said experts “never fathomed” the amount of rain Harvey would dump on Houston.

Crosby residents protest Arkema chemical plant

They quoted FEMA director William “Brock” Long saying, “We have not seen an event like this … You could not draw this forecast up. You could not dream this forecast up.”

They also cited other local and national meteorologists.

As for the Crosby plant’s location and its flooding, the filing states that the previous benchmark was from 2001 and Tropical Storm Allison, which was called a 500-year storm.

“During Allison,” the filing states, “there was minimal flooding around the Crosby site, minor enough that pickup trucks were still able to traverse the plant site.”

The Crosby plant never experienced flooding during Ike or Rita, according to the document.

The nearly half a million pounds of organic peroxides were also addressed. The first responders who filed the suit felt that Arkema didn’t provide accurate information about the risks caused by the explosion of those chemicals.

Crosby residents file second lawsuit against Arkema following Crosby plant explosion

Arkema’s response calls those claims as “blatantly false.” After the company learned that the refrigerated trailers began losing cooling capacity on Aug. 31, the filing states that Arkema warned federal, state and local officials that a fire could occur.

“Arkema also provided – both orally and in writing – essential information about the site, combustible products and the potential risk posed by the fire,” the document states.

The filing also covers Arkema’s communication with the public to keep them informed, its procedures in place and more.

This is one of two lawsuits the company faces following the explosions that took place at its Crosby plant after Hurricane Harvey. In all, six trailers containing liquid organic peroxide would lose the capacity to be cooled when backup generators were flooded, which caused several explosions over a week.