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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)

 

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wolmad

The mission statement of the Center for Prisioner Health and Human Rights is as follows:

"The Center for Prisoner Health and Human Rights seeks to improve the health and human rights of criminal justice populations through education, research, and advocacy."

The center's directors, members, and volunteers establish specific priorities on how this mission is going to be approached. Their current focuses as stated on their website are as follows:

– To bring attention to the health and healthcare issues and challenges of prisoners and other criminal justice populations.
– To improve the continuum of care for prisoners from admission to a correctional facility through release, including improving healthcare access and opportunities for criminal justice populations in the community.
– To advance policies and programs that promote both public health oriented approaches to mental illness, addiction, and substance use and [alternatives to][less reliance on] incarceration and the criminal justice system.
– To engage students and health professionals in the Center’s mission with training and education opportunities, and by providing students with practical experiences working directly on concrete issues, problems, and challenges.

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wolmad

In recent years, incarceration rates and prison populations nationwide have grown exponentially for a variety of sociological and political factors. The organization believes that research indicates that this epidemic has had a particularly hard impact on economically vulnerable communities, where a majority of the people brought into custody suffer from addiction, substance use, and/or mental illness. Due to their economic situation these people were likely unable to seek care or treatment from any public health system in the community. This interaction of illnesses and diseases and criminalization in communities and incarceration results in a complex public health and human rights crisis in both correctional and other criminal justice settings. The Center for Prisoner Health and Human Rights seeks to apply new research to help to mitigate this.