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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 article talks about improving pollution in industrial neighbourhood but they forget to realize that there is water contamination in Newark and also the fact that what can be done to improve pollution rather than just stating to improve pollution but they forget about the pollution thats already been emitted, what can be done regarding that. 

The vulnerability mentioned in this article is about pollution occurred due to port traffic, waste facilities, and industrial plants which cause increased risk of cancer. 

Despite air pollution being a problem for every group, this article specifies children as the victims. For example, the author quotes Congressmen Donald M. Payne, Jr saying, "Every single day, children in Newark are exposed to harmful levels of pollution from the port and other sources that rob them of their health, just because of where they live" (Adams). Adams most likely did this to show the severity of this problem by shedding light onto the victims. Air pollution also increases the chances for children developing asthma. Adams writes, "one in four Newark children suffers from asthma, and the hospitalization rate is 150 percent greater for kids living in the city than in the rest of the state, and more than thirty times the rate nationwide."

Air pollution in Newark that is caused by port traffic, waste facilities, industrial plants, and trucks. Some of the air pollution in New Jersey is also caused by air pollution drifting in from Pennsylvania.