Skip to main content

Analyze

Overview of Formosa Drainage Study

annika

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.

Formosa Drainage Study

annika

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)

 

pece_annotation_1475439014

harrison.leinweber

It appears that this is an NGO report. Human Rights Watch regularly publishes articles in an attempt to draw attention to percieved human rights issues throughout the world. They claim to be an independant organization supported by contributions from private individuals and foundations. They also deny accepting any government funds whether it be directly or indirectly.

pece_annotation_1475441693

harrison.leinweber

The report was written to examine the severe increase in the number of internally displaced people in Bogot and Cartagena, Columbia. HRW was concerned with the number of people and families being forcibly displaced by paramilitary groups and their lack of access to education and public health services.

pece_annotation_1475441923

harrison.leinweber

This report includes a glossary, a summary of the report and situation in Colombia, recommendations from HRW which address education, health needs, and the ability to return home, a section discussing the internal displacement in Colombia, registration and humanitarian assistance, a section discussing access to education, and a section which discusses access to public health services. The report concludes with a list of acknowledgements and a listing of other HRW reports on Colombia.

pece_annotation_1475442786

harrison.leinweber

This report discusses the adverse consequences that result from people being forcibly displaced from their homes. These consequences include reduced or eliminated access to public health and utilities, which can further exacerbate the problem because those native to the area where people are traveling can lose access when immigrants flood their systems.

pece_annotation_1475442929

harrison.leinweber

This report doesn't have a great deal of impact with technical professionals. This report is much more geared toward those in the government in Colombia and actors in the international community. The report touches on the fact that hospitals and clinics are obligated to provide all persons with emergency care, but doesn't address emergency medicine more than that.