Analyze

This supplementary legal document describes recommendations for storm- and waste-water management improvements for the Formosa petrochemical plant in Calhoun County, Texas. The text is a fairly standard drainage assessment. The author describes non-trivial discharge of pollutants out of the plant’s outfalls, which drain into local waters, and the inability of the plant’s systems to prevent flooding from even small storms. For some context on this, it is pretty standard to design a stormwater system to be able to drain the 100-year storm (that is, the storm with a 1% or less chance of occurring in any given year). Formosa’s Texas plant demonstrated the inability to convey even the 2-year storm.

Emphases are mine:

“Problem areas were identified based on the results from the outfall drainage studies provided by Formosa. Thus, all the results in the OPCC rely on those studies, uncertainities associated with those studies, and the assumptions made for those studies, some of which may or may not be appropriate as I pointed out in Supplement #2 [Page 4]” (3)

“The proposed improvements assume that the conveyance capacity of the problem areas is increased 100%, which would be able to handle twice as much flow that it currently does. The results from the Drainage Study are not conclusive as to what storm event Formosa’s system currently is capable of conveying. The report does mention that the system is not capable of conveying the 2-year storm, and “sometimes” not even the 1-year storm event.” (3)

“A 45% contingency is applied to the OPCC due to the uncertainties associated with underground utilities, likelihood of existence of low road crossings and need to replace those, groundwater impacts, other unknowns, and additional costs associated with engineering, etc. 45% is reasonable and in line with industry practices in my experience, especially given the large amount of unknown information available.” (4) 

“My opinion from my July 9, 2018 report that “there have been and are still pellets and/or plastic materials discharges above trace amounts through Outfall 001” is further supported by the deposition testimony of Lisa Vitale, as representative for Freese & Nichols, Inc, that she and her colleagues have seen floating white pellets or small plastic pieces in Lavaca Bay and in the area near outfall 001 as part of her work on the receiving water monitoring program for Formosa’s TPDES permit...Ms. Vitale also testified that she told John Hyak of Formosa about these sightings as well as has sent him water samples with the pellets about five or six times, including at least one time prior to 2010. This, along with the June 2010 EPA Report I cited in my July Report, demonstrates to me that Formosa was aware of problems related to discharges of plastics from its facility since at least in 2010.” (6)

The Weldon Spring Interpretive Center was a discursive jamboree for those of us curious about how anthropocenics are narrated. This particular display at the center stood out to me becuase of its resemblance to other interpretive center or science museum displays representing the "life cycle" of an organism or of cycles of ecosystem conditions (e.g. forest succession). One of the first displays visitors see upon entering the center, the display's format and captions read to me as a clear attempt to control the discourse about nuclear contamination and remediation in the area. The image--or its creator--wants to do the work of suggesting that the clean up process has brought the place "back to how it was," cycling back to a good beginning. The text used in this display is exclusively neutral or positive. The arrows moving from each circle to the next purports to display how "this area has served many purposes over the years." It states "these exhibits are designed to educate you on the history, science, and efforts of many to bring the Weldon Spring site full circle." In this cycle, Weldon Spring is not a hazardouse waste site or contaminated site but rather "a site for remedial action." Thus we are to see the space as a "home to many people," then "a TNT and DNT plant," then "a uranium feed and matierals plant," then "a site for remedial action," "an extensive cleanup effort," "a successful solution," and, finally, "a place to enjoy and learn." In this emphasis on a "return" to good conditions, the displacement of residents, health issues plant workers and others' faced, and the uncertainties or messiness of what adequate clean up is are omitted. In this image, and in much of the interpretive center, the discourse around nuclear materials, its effects and cleanup, is neatened, simplified, into a narrative that de-emphasizes the actual health impacts of these processes and of the political wherewithall that was required to make that remediation happen.

The notion of cycling back to something is a particularly intriguing move

children were tested for lead poisoning and their was a correlation between those who had lead poisoning and those who were homeless or a victim to poverty.