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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 question of data relates to Denise Brock’s key role in the passage of the Energy Employees Occupational Illness Compensation Program Act (EEOICPA). Brock independently collected thousands of documents related to the health of  workers in nuclear facilities like Weldon Spring in her efforts to show that they had been exposed to pathological levels of radiation. In many cases, their employers were fully aware of the dangers these workers faced, but kept this information to themselves or hidden away in the private documents that Denise uncovered decades later. Prior to Denise's work this information was not publically available, and if workers who had become ill wanted to receive compensation for worksite expose, they would have to undergo exposure reconstruction assessments, which--due to the lack of accurate and available data--were imperfect evaluations of the actual levels of radiation workers had been exposed to. Due to Denise's advocacy, which led to the passage of the EEOICPA, workers at nuclear facilities are exempted from the exposure reconstruction assessments and are eligible for compensation payments up to a maximum amount of $250,000, plus medical expenses for accepted conditions.

Denise's experience raises a few questions and reflections on data in the Anthropocene:

•  Issues like worksite and environmental exposure are often plagued by invisibilities and what STS scholars have referred to as "agnotologies"--where can activists/scholars/any interested party gain access to relevant data in relation to these issues (in a similar fashion to Denise's work)?
• For historians in particular: do the thousands of documents Denise complied consitute an archive? How can these and similar archival practices be Anthropocenic strategies?