What is the main argument, narrative and effect of this text? What evidence and examples support these?

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March 17, 2022

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.

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