CCA Texas has significant concerns about the proposed Synergen Point Comfort Ammonia Plant (Synergen) in Calhoun County. The project site is located between Keller Creek and TX-172, just south of SH-35. We understand the plant intends to utilize brackish groundwater as its source water, treating and filtering it to lower Total Dissolved Solids (TDS) for process and cooling water operations.
Synergen has not yet decided on a discharge location but has identified the Port of Point Comfort, Carancahua Bay, and an evaporation pond as potential options. CCA Texas maintains a clear position on the discharge of desalinated brackish groundwater: we recommend that effluent be pumped back into underground storage where it cannot mix with freshwater aquifer zones. We are therefore opposed to any brackish water desalination discharge into Texas estuaries.
Our opposition is further strengthened by CCA Texas’ substantial investment in Carancahua Bay oyster reef habitat through both regulatory actions and restoration activities. In partnership with Matagorda Bay Foundation, we are currently in the planning phase of a $1 million restoration project for Carancahua Reef near Port Alto. Discharge from the Synergen facility into Carancahua Bay could jeopardize both this investment and future oyster reef restoration efforts.
The impact of this project extends beyond groundwater and discharge concerns. The cultivated oyster mariculture industry has invested millions of dollars in operations within the Olivia Community and Keller Bay. Given the project’s proximity to Keller Creek, there are serious concerns that stormwater runoff will reach Keller Creek and ultimately degrade water quality in Keller Bay, threatening these mariculture investments. When considered alongside our groundwater, disposal, and Carancahua Bay restoration concerns, this project’s scope and complexity raise critical questions that must be thoroughly addressed before any regional groundwater conservation district, county office, or state agency considers approval. The scope and complexity of this project, combined with concerns raised by CCA Texas members in the region, necessitate a thorough analysis of the following questions:
Stormwater Runoff: Will stormwater runoff from plant operations discharge into Keller Creek? If so, what measures will be taken to ensure stormwater contaminants will not reach Keller Creek? What measures will be taken to ensure that cultivated oyster mariculture operations will not be impacted? What measures will be taken to ensure Keller Creek is not ecologically compromised?
Hydrogeologic integrity and monitoring: What baseline data has been collected for both brackish and freshwater aquifers? Have independent peer reviews been conducted of hydrogeologic reports and modeling? What specific monitoring, reporting, and financial assurance requirements will be mandated?
Hydraulic impacts and drawdown: What are the modeled predictions for cone of depression, radius of influence, and drawdown in nearby wells over time? Could pumping create new hydraulic connections between deep brackish and shallow freshwater zones or alter natural groundwater flow patterns?
Salinity migration and freshwater protection: How will the project prevent upward migration of saline water into freshwater zones? What are the trigger levels and response protocols if contamination is detected? Have worst-case scenarios involving casing failure or induced fractures been adequately modeled? Will the TDS of source water change over time?
Contaminant mobilization: Could pressure changes from pumping mobilize naturally occurring arsenic, metals, or radionuclides? What baseline testing has been performed, and what treatment is proposed before any surface discharge?
Community and public health impacts: How many domestic and municipal wells fall within the zone of influence? What protections, notifications, and compensation mechanisms will be established for affected landowners? Has a public health risk assessment been conducted?
Long-term stewardship: What enforceable monitoring networks, trigger levels, corrective action timelines, and financial guarantees will ensure decades-long protection? Has the cumulative impact been assessed alongside other regional groundwater withdrawals and discharges?
Emergency preparedness: What are the protocols for well integrity failures or water quality excursions? How will residents on the Olivia/Port Alto Peninsula evacuate if TX-172 is closed during a plant emergency, and how are volunteer first responders expected to respond?
These questions demand comprehensive, transparent answers supported by independent scientific review before this project is further considered.
*Last updated on 6/22/26
