The Reynolds Sherwin Refinery began producing alumina in 1953. In the mid-1960s as the bauxite residue disposal beds at the refinery site were reaching the end of their useful life, siting and construction of the Copano Beds began. Bed 1 operations began in 1969; Beds 2, 3 and 4 operations began in the 1970s and early 1980s; and use of the Copano beds continued until 2016. The Copano site was likely selected because of its size, availability, and geological characteristics of an abundance of clay in the subsurface. The clay deposits were used to construct the levee systems of all four beds and the Decant Pond.

We communicate directly with the public about the conditions and work being performed at the site in multiple ways.  Per the TCEQ Agreement, an initial public meeting was held on July 18, 2018, to introduce the new property owner and meet local residents.  Prior to the meeting, a notice was published, and invitations were mailed to residents within two miles of the site and to local governmental officials.  In addition, a website (www.copanobeds.com) and a telephone hotline were set up.  Following completion of various environmental assessments and at the request of TCEQ to communicate the results of the Affected Property Assessment Report (APAR), a second public meeting was held on December 15, 2020, with similar notices published and mailed out.  All documentation submitted to TCEQ continues to be posted on the Copano website open to the public. And the telephone hotline remains open to receive any questions, comments or concerns from the public.

We are committed to protecting the environment and since 2018, several actions and procedures have been established to ensure protection of the environment:

• All of the levees on Beds 1, 2, 3 and 4 and the Decant Pond have been repaired and are inspected and maintained as needed.
• Beginning in 2018 a perimeter air-monitoring system has operated on a continual basis except for short periods of time to allow for system maintenance; no dusting events off the beds have been detected off site to date.
• Aerial photography is conducted numerous times each year to assess site conditions.
• There are contract employees at Copano on a continual basis. They are working on the Bed 1 cover layer redevelopment, levee maintenance and repair, water management and ranch activities. This allows for rapid response to any observed upset conditions.
• Independent third-party inspections are conducted on an annual basis.
• Continual dust control and foam mitigation operations take place throughout the year.
• Inspection and monitoring programs continue to assure that site conditions are stable and that no releases occur as closure operations continue; all activities are conducted in accordance with requirements of the 9019 Settlement Agreement with TCEQ and with applicable permit conditions.
• Water Balance studies have been performed and Emergency Actions Plans are in place to assure that safe and effective actions are implemented prior to potential future hurricane landfall or other emergency events.

No, there are no current operations or plans to transfer any dredge materials or other sediments or solid wastes to Copano through the buried pipelines.  In 2016 the Port of Corpus Christi (POCC) had reportedly entertained the concept of using the Copano site and infrastructure for dredge material disposal during the time when they were considering site acquisition.  The only current use of the two buried 18-inch diameter pipes is to transfer treated municipal wastewater from the City of Aransas Pass and River Mud from the San Patricio Municipal Water treatment plant (in accordance with our approved permits) for use during dust control and irrigation activities at the site.   

Furthermore, these materials facilitate the establishment of a vegetative cover over the site. Under the agreement with TCEQ, we cannot deposit dredge sediments or other materials onto the Copano Beds without TCEQ approval.

Petroleum hydrocarbons are a class of chemicals that contain carbon and hydrogen and are used for sources of energy e.g., coal, petroleum, natural gas and tar.  There are four main types classified as alkanes, alkenes, alkynes and aromatic hydrocarbons, Hydrocarbons are not used in the bauxite refining process to make alumina nor are they associated with bauxite residue placement. Exceptions would be if diesel- or gasoline-operated equipment is used within the alumina refinery or if a coal- or natural gas-fired power plant is present adjacent to an alumina refinery with the potential for hydrocarbon air emissions or water discharge from the power plant.  The former Sherwin refinery did not have a power plant associated with its operation nor did the use of hydrocarbons in any other industrial operation at the refinery result in the intermingling of hydrocarbons with bauxite during refining or the bauxite residue prior to placement at the Copano beds.

Elemental mercury is not directly used as a feed stock during alumina refining processes.  Only when mercury is present in bauxite ore (typically at very low, trace concentrations) will mercury exist in air emissions during the digestion process or remain in the resultant bauxite residue, but not at levels that would result in any environmental impact.  Dissolved mercury can become co-mingled with bauxite residue if wastewater from an integral chlor-alkali operation (that uses mercury in its process to create caustic soda) is discharged into a residue disposal impoundment.   The Copano site is 10 miles away from the former Sherwin refinery, thus air emission deposition of trace levels of mercury during operations could not have occurred.  Furthermore, the former Sherwin refinery purchased its caustic from the nearby Occidental plant (which did not use mercury in its caustic production process) and did not have a chlor-alkali operation nor any other industrial operation that would result in intermingling of elemental or dissolved mercury with bauxite during refining or during bauxite residue placement operations.

Industry-standard methods for the collection, handling, and analysis of environmental samples (e.g., of soil, sediment or water) are used at the Copano site to assure resultant data meet sampling program objectives and are representative of the environmental media being sampled. Once the selection of sample locations, the number of samples to be collected, and the frequency of sampling has been determined and approved, then the final step is to implement the sampling program:

1)  Sampling methods must be appropriate for the type of sample being collected and the potential contaminants being evaluated. Methods must be documented in detailed, step-by-step Standard Operating Procedures (SOPs) to be used by the field teams.  The use of SOPs ensures that all samples are collected in the exact same manner, which minimizes the variability that could result from the use of inconsistent methods. 

2)  Equipment used to collect the samples must be free from contamination that could result in cross-contamination between samples and bias the analytical results. Non-dedicated sample collection equipment must be decontaminated prior to use (and after each use if used for subsequent sampling), field personnel must use disposable gloves for each sample, and sample containers must be pre-cleaned and certified as non-contaminated by the analytical laboratory.

3)  A field quality assurance/quality control (QA/QC) program must be employed. For example, “equipment blanks” are collected and analyzed at the same time the environmental samples are collected and analyzed to confirm that sampling equipment or containers were not contaminated.

4)  A strict chain-of-custody program must be employed to ensure that all samples are under the control of the sampling personnel or the analytical laboratory during all stages of collection and analysis. A chain-of-custody form accompanies the sample package and is signed by both parties when the control of a sample is relinquished, e.g., when the sampler delivers the samples to the analytical laboratory.  The completed chain-of-custody is included in the final report provided by the analytical laboratory.

5)  The analytical laboratory must be certified and qualified to conduct the analyses being requested, employ its own QA/QC program, and use industry-standard (e.g., USEPA or ASTM) methods to ensure that the analytical results can be used for their intended purpose.

See graphs below from samples obtained within Beds 1, 2 and 3; note the extremely low % of technology enhanced naturally occurring radioactive materials (TENORM):

Copano Bed 1 Chemical Composition Data (%)

Copano Bed 2 Chemical Composition Data (%)

Copano Bed 3 Chemical Composition Data (%)