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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 study aimed to do large scale studies on disasters relating to the exposure of a portion of the population to a toxic agent, in order to learn how to better study the long-term medical effects.

The article was published in the International Journal of Environmental Research and Public Health, a well regarded journal dedicated to publishing reliable studies concerning ecological damage and effects, as well as the medical effects due to ecological factors of both natural and human creation.

The study aimed to discover new or more effective methods of studying long term effects of exposure to toxic agents. It describes the new insights including the effectiveness of simple studies, ensuring control groups, and methods to do research by using ecological aspects or involving the community in places where medical researchers are not entirely trusted.

As the disasters studied occurred many years ago and have been thoroughly studied previously this study did not present sufficiently new information to be disseminated through news reports. The study did however provide information of interest for future studies, and has been cited in other articles indicating it was used as reference in determining the effectiveness of research techniques.

The data presented could be used for medical professionals to better understand the cause of similar symptoms, or to treat patients involved in a similar incidents. The methods of research presented could be used by academics and researchers in further study.

The study does not directly address vulnerable populations, but rather focuses on including all relevant populations involved in a disaster including those reluctant to take surveys or be interviewed, or communities that are not often studies or may have had little to no exposure in order to maintain the proper control group.

The study was funded with assistance from the National Institute of Environmental Health Sciences and the Center of Economic Excellence, located in South Carolina, through a program for the Doris Meddin Levkoff Center for Medication Safety.