Where to begin: the Safety Data Sheet
It starts with the Safety Data Sheet (SDS), which includes, among other things, a list of all hazardous chemicals used in the facility. The primary purpose of the SDS is worker safety, to make sure employees are trained in proper handling of hazardous materials. It also must be on file with the local fire department so firefighters know what to expect in an emergency.
For the purposes of assessing potential environmental pollution, the SDS gives us a starting point of what to test.
We are demanding a Baseline Toxicity Test specifically for toxins found in the declared SDS, and recurring tests every 60 days, to ensure our community is not being polluted like Morrow County, Oregon, or Flint, Michigan.
Different types of baseline tests
There are different types of tests, depending on the substances being tested. A common baseline will test for agricultural (Ag) chemicals and pesticides. An Ag test will not find most of the substances that a data center might spill or leach.
A more appropriate baseline should test for the specific chemicals the facility is known to use, to make sure those toxins don’t escape into the environment.
Why this testing is important
Obviously, to protect our community from dangerous toxins in our soil, water, and air. But there have been some specific incidents in other communities that we don’t want to repeat.
Baseline testing allows us to establish a “before picture,” making it easier to prove the impacts that result from having a data center in our community.
Also, asking for this level of transparency has proven to be a successful way to scare off developers who know they will have a negative impact.
What happened in Morrow County, Oregon
Rowan’s other big client, Amazon, settled a claim in Morrow County, Oregon, for polluting the water supply and causing a rare form of cancer. Amazon denies the allegations but paid a $20 million settlement to end the lawsuit.
At first, Amazon tried to blame it on a local farm.
There was no baseline testing before the data center was built, making it difficult to prove if Amazon was fully responsible for the cancer.
The result was a $20 million settlement for ruining an entire county’s water supply, barely a slap on the wrist for a 2.56 trillion dollar company. Trillion, not billion.
Needs reviewThe $2.56 trillion figure for Amazon has no source on the old site, so add one or remove the figure.
This is why we need a Baseline Toxicity Test and regular testing every 60 days. Read the Rolling Stone report on the settlement.
How much does this testing cost?
These tests can be performed for as little as $300.
Needs reviewThe old site gives no source for the $300 figure, so add a lab quote or other source.
The only reason this hasn’t been done is because someone doesn’t want it done.
Given the potential use as evidence in court, these tests should be performed by someone trained in evidence handling and chain of custody. The tests also should run through multiple independent labs to confirm results.
The City’s responsibility
The City of Temple regularly invites residents of all ages to celebrate sustainability and community, to promote eco-friendly living, conservation, and city beautification. Per our own city leadership, and our responsibility as a community, we must understand the potential impact of data centers in our Temple. The City has not obtained any environmental assessment and has refused to pause while we examine how this may affect our community.
At the April 16, 2026 City Council meeting, Mayor Tim Davis appeared to actually hear the environmental concerns for the first time. The agenda item on deck was voluntary annexation and rezoning of land for the Rowan Ranger project. This would have been the perfect opportunity for the City to delay the request and ask for an independent Baseline Toxicity Test.
The Mayor claimed the City Council does not have the legal authority to do this. They do not have the authority to protect the people of Temple? They most certainly have the ability to deny the request.
We don’t believe the Mayor’s interpretation of the law is correct, and we are actively researching this with the help of lawyers on our team.
Rowan’s testing
Rowan claims to have done their own initial testing but is not yet ready to release the details. They claim this is done for their protection. Even if they do release the information, it would be meaningless until verified by an independent lab.
There are a number of concerns here.
Normal practice in any kind of development project like this is a test called “ESA Phase I.” ESA stands for Environmental Site Assessment, which establishes that the property is safe for the intended use, safe for employees to occupy, has no nuclear waste, and so on. It’s a very basic test and is not the same as the Baseline Toxicity Test that we are asking for.
As we have learned from FOIA document requests, Rowan has a professional relationship with Langan, an environmental engineering company. Both Rowan and Langan have some of the same large shareholders invested in both companies. While these are not “majority shareholders” or “controlling,” a 49% investment is quite significant, and more than enough to imply a conflict that might eliminate the claim of “independent.”
This is one of those cases where a court of law and the court of public opinion might strongly disagree.
Again, they have not released the details. It is merely assumption that Langan may have performed the assessment. It is a service that Langan offers.
What should we test for?
We are still in the process of obtaining the SDS with specific chemicals, but some examples may include:
Needs reviewConfirm whether we have obtained the SDS yet, and update this list if so.
Air
- NO2
- PM2.5 / PM10
- Diesel particulate matter
- VOCs
- CO
- SO2
Wastewater
- PFAS (full panel)
- Glycols
- Biocides
- Corrosion inhibitors
- Heavy metals (lead, cadmium, nickel, chromium)
- Nitrates (from cooling tower blowdown)
Soil
- PFAS
- Diesel range organics (DRO)
- Oil and grease
- Heavy metals
- Fire suppressant residues
Groundwater
- PFAS
- Glycols
- Metals
- VOCs
Our full list of chemicals for baseline testing is also available to download.