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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 main point of this article is to look at the shortcomings of the response to the World Trade Center on 9/11/01 by the NYPD, PAPD, and FDNY. The article shows that the response was plauged by communication breakdowns between fire companies and commanders, a complete lack of communication between fire and law enforcement agencies with heavy roots in the history of the two departments, and an uncoordinated response by off duty firefighters, who swarmed the area after the attacks. The article discusses various improvements that could have been made after the 1993 bombing and would have significantly effected response on 9/11 such as the improvement and standardization of radio hardware and channels between departments, joint training drills, more rigid command durring response, and the adoption of the FEMA incident command system.

FDNY, Fire Department, City of New York
-composed of individual Engine, Truck, Ladder, Rescue, HazMat, and EMS companies, as well as other specialized units which handle most of the city's emergencies that could cause dammage to life and property. The FDNY was technically the agency in command of the response at the WTC site.

NYPD - New York City Police Department. 
-Provides law enforcement for the NYC. Police Emergency Service Units are also mentioned. These are groups which share some of the responsibilities and training of firefighters, and are familuar with technical rescue equiptment.

PAPDNYNJ - Port Authority Police Department of New York and New Jersey. 
-Responsible for providing protection at all of the major ports and entrances to NYC, incluing bus terminals, shipping docks and ports, train stations, rail yards, bridges, tunnels, and other commuter and shipping hubs.

This article is entirely about the shortcomings of emergency response, and how the history and traditions of the FDNY and NYPD got in the way of an effective response, resulting in communication barriers, an uncoordinated response, unknown and unaccounted responders, and even possibly avoidable deaths. Public health was not explicitly mentioned, as this article focused more on the efficacy of the multi-agency response itself.

“A six­month examination by The Times found that the rescuers' ability to save themselves and others was hobbled by technical difficulties, a history of tribal feuding and management lapses that have been part of the emergency response culture in New York City and other regions for years.”

''It's a disgrace,'' he said. ''The police are talking to each other. It's a no­brainer: Get us what they're using. We send people to the moon, and you mean to tell me a firefighter can't talk to a guy two floors above him?''

The author of this article drew on first hand accounts of the WTC attacks from fire, police, and EMS personel, as well as witnesses to reconstruct the events that transpired on the morning of 9/11/01 with regards to the response. The author also conducted and cited interviews with high ranking active and retired members of the Police and Fire Departments, such as FDNY Chiefs and officers and NYPD Commissioners. Based on this, the author examines specific shortcomings, such as lack of coordination between Fire and Police, comminication barriers, and the overwhelming and uncoordinated response by both on and off-duty firefighters.

1. I tried to find more information on the current radio system that the FDNY and NYPD employ to see how they would facilitate interagency communication and communication with mutual aid from departments in surrounding counties.

2. I did more research into the NYPD ESU

3. I attempted to find more information on any FDNY response policies developed after 9/11/01 to limit and coordinate response to major disasters to avoid the confustion found at the WTC response.