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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5

77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590

STATEMENT OF BASIS 

FOR ISSUANCE OF CLASS VI UNDERGROUND INJECTION CONTROL (UIC) PERMITS

Permit Numbers: IL-137-6A-0001, IL-137-6A0002, IL-137-6A-0003 and IL-137-6A-0004

Facility Name: FutureGen 2.0 Morgan County 

CO2 Storage Site

The FutureGen Alliance (Morgan County, Illinois) applied for four U.S. Environmental Protection Agency

(EPA) permits for wells to be used for geologic sequestration of carbon dioxide as Class VI wells. These 

injection wells would be part of a larger Carbon Capture and Storage “CCS” project associated with the 

Meredosia Power Plant which will produce and capture the carbon dioxide (CO2) to be injected –with a 

goal of reducing carbon emissions to the atmosphere to help mitigate climate change. The project is 

proposed to: inject 22 million metric tons of CO2 into the Mt. Simon Sandstone for 20 years; and, monitor 

the CO2 for an additional 50 years during the post-injection site care period. 

EPA reviewed all information submitted by FutureGen to inform the draft permit decisions. EPA 

considered information and issues including:

 Geologic site characterization, injection and confining zone characterization, and project siting;

 Computational modeling of the project’s Area of Review (AoR);

 The proposed well construction and operational conditions; 

 The approach FutureGen proposed to monitor the wells and track the plume and pressure front to

ensure protection of underground sources of drinking water (USDW) for the life of the project –

including both the injection and post-injection site care periods; 

 FutureGen’s financial responsibility demonstration; 

 The strategy to address and mitigate risks associated with induced seismicity; 

 Emergency and remedial response strategy development; 

 The CO2 stream source, characteristics and purity; 

 Environmental justice; 

 Endangered species; and 

 Ensuring USDW protection. 
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EPA’s review of the permit applications indicates that the proposed injection project meets the 

requirements for Class VI injection wells and will not pose a risk of endangerment to USDWs. The EPA, 

therefore, is issuing draft permit decisions for four wells. Under the authority of Title 40 of the Code of 

Federal Regulations (40 CFR) Parts 144 and 146, EPA Class VI permits must specify conditions for the 

construction, operation, monitoring, reporting, plugging, post-injection site care and site closure of Class 

VI injection wells so as to prevent the movement of fluids into any USDW. General provisions for EPA 

UIC permit requirements are found at 40 CFR Parts 124, 144, 146 and 147. In accordance with 40 CFR 

124.7, general information and highlighted permit conditions specific to these wells are discussed in the 

following sections. Additional, substantive discussion of many of these topics is also documented in 

separate documents of the Administrative Record for these permit decisions. 

Area of Review and Corrective Action: In accordance with 40 CFR 144.55, 146.6 and 146.84, the Area 

of Review, or AoR, is the region surrounding the geologic sequestration project where any improperly 

sealed, completed or abandoned wells that penetrate the injection and/or confining zones could provide a 

conduit for fluid migration. The AoR for these wells has a radius of approximately 24 miles and was 

delineated pursuant to 40 CFR 146.84(c)(1) using a computational model that predicts the movement of 

the carbon dioxide plume and pressure front based on available information about planned injection 

operations and the subsurface rock formations. Figure 1 is a map of the project AoR. 
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Figure 1. The FutureGen project proposed Area of Review including: the modeled CO2 plume (in yellow) and 

the predicted area of elevated pressure (the red circle). 

EPA performed an extensive evaluation of the AoR proposed by the permittee by independently modeling 

the AoR using the Subsurface Transport Over Multiple Phases (STOMP) multi-phase transport model, 

based on the site-specific geologic and operational data in the permit application and determined that the 

AoR delineated by the permittee is sufficiently extensive and meets the requirements of 40 CFR 

146.84(c)(1). EPA also evaluated the modeling approach used by the permittee and determined that it 

meets the requirements for computational models to delineate Class VI AoRs. Information about EPA’s 

independent assessment is available in a report in the Administrative Record for these permit decisions.

In accordance with 40 CFR 144.55 and 146.84, the permittee must perform corrective action to address 

any deficiencies identified in wells in the AoR, as described in the Area of Review and Corrective Action 

Plan of the permit. Based on an evaluation of well records, the FutureGen Alliance determined that only

one well penetrates the confining zone –a stratigraphic test well constructed by FutureGen. It was 
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properly constructed and thus no wells require corrective action within the FutureGen AoR.

As required at 40 CFR 146.84(e), FutureGen will reevaluate the AoR using computational modeling at 

least every five years over the lifetime of the project to verify, based on monitoring and operating data, 

that the carbon dioxide plume and pressure front are moving as predicted. FutureGen will also review 

monitoring, operational and other data annually to determine whether additional reevaluations of the AoR 

are needed. This AoR reevaluation, and any additional corrective action that is needed, will be performed 

pursuant to the Area of Review and Corrective Action Plan, which is an enforceable condition of the Class 

VI permits. If this reevaluation indicates that there are changes from predictions, the permittee must revise 

all of the project-specific plans and the permit will be modified per 40 CFR 144.39.

Underground Sources of Drinking Water (USDWs): USDWs are defined by UIC regulations as 

aquifers or portions thereof which contain less than 10,000 milligrams per liter of total dissolved solids 

and are being used, or could be used, as a source of drinking water. The base of the lowermost USDW 

near the wells, the St. Peter Sandstone formation, is at a depth of 1,942 feet below the ground surface. The 

shallow, Quaternary glacial sediments that serve as the source of local drinking water are approximately

150 feet below the ground surface.

Injection and Confining Zone: Injection for geologic sequestration is limited by the permits to the Mt. 

Simon Sandstone and the lower member of the Eau Claire Formation (the Elmhurst Sandstone) in the 

interval between 3,785 feet and 4,432 feet below the ground surface. This injection zone is separated from 

the lowermost USDW by 1,843 feet of rock, including an impermeable confining zone, the upper members 

of the Eau Claire Formation (The Lombard and Proviso Members), which will act as barrier to fluid 

movement. Figure 2 includes a stratigraphic column at the site, including the depth of the injection and 

confining zones.

EPA has reviewed extensive information submitted by the permittee, including maps, well logs, cores, and 

the results of seismic surveys. Based on this information, EPA has determined that the regional and local 

geologic features at the site will allow the Mt. Simon Sandstone to receive the amount of carbon dioxide 

proposed to be injected without a buildup of pressure that would create faults or fractures. EPA also 

determined that the site is free of any known faults or fractures that could affect containment and that the 

Eau Claire Formation will provide suitable containment to ensure that the carbon dioxide remains in place 

and USDWs will not be endangered, as required under 40 CFR 146.83. Additionally, EPA evaluated 

information on seismic history in the area and potential seismic risk to conclude that the project poses a 

low risk of inducing felt seismic events. Information on this evaluation is available in a separate document 

in the Administrative Record for these permit decisions.
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Figure 2. A stratigraphic column of the geology at the project site (on the left) including the Mt Simon Sandstone (the 

injection zone) and the Eau Claire Sandstone (the confining zone) and example well schematics. 

Construction Requirements: The FutureGen project will consist of four horizontal wells that will be 

directionally drilled from a single well pad. Proposed construction of the wells meets the regulatory
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criteria of 40 CFR 146.86. All Class VI wells must be constructed with materials and cements that can 

withstand exposure to CO2 and CO2/water mixtures without excessive corrosion over the life of the project

(See Figure 2). Class VI wells must also be cased and cemented to prevent the movement of fluids into or 

between USDWs. The wells will be equipped with automatic surface shut-off devices that will shut off the 

wells if any permitted operating parameters (such as injection pressure) diverge from limitations set in the 

permits. EPA reviewed the proposed well schematics submitted with the permit applications to verify that 

the cements and other materials proposed for the wells will be compatible with the carbon dioxide stream 

and planned operations (e.g., injection pressures). Following well construction, pursuant to 40 CFR 

146.82(c), EPA will review any final “as built” well schematics to confirm that the wells were constructed 

to ensure USDW protection, meet the goals of the Class VI Rule at 40 CFR 146.86(a), and are equipped 

with the required shut-down devices before injection is authorized.

Injection Fluid: The permits limit the fluid that may be injected to CO2 from the Meredosia Power Plant. 

Captured emissions will be passed through a purification and compression unit, and then transported 

through an underground pipeline to the wells. The fluid will contain trace impurities but will be at least 97 

percent CO2. FutureGen anticipates injecting a total of 22 million metric tons of CO2 over 20 years. 

Maximum Injection Pressure: The maximum injection pressure will be limited to 2,237 pounds per 

square inch gauge (psig) measured at 3,850 feet to ensure that the pressure during injection does not 

initiate fractures in the injection or confining zones, pursuant to 40 CFR 146.88(a). This, in turn, ensures 

that the injection pressure will not cause the movement of injection or formation fluids into a USDW as 

prohibited by 40 CFR 146.86(a). This pressure is 90 percent of the fracture pressure of the Mt. Simon 

Sandstone, which was determined based on data obtained from the FutureGen Project 2.0 stratigraphic 

well. EPA confirmed, based on geomechanical information about the injection and confining zones (e.g., 

fracture pressure, porosity, and permeability), that the injection pressure is appropriate and will not initiate 

fractures in the injection or confining zones.

Monitoring and Reporting Requirements: In accordance with 40 CFR 146.90, FutureGen will 

implement an approved Testing and Monitoring Plan for the project. The multi-faceted Testing and 

Monitoring Plan, which is an enforceable condition of the Class VI permits, includes the following testing 

that FutureGen will undertake to ensure USDW protection:

 Analyzing the carbon dioxide quarterly: to provide information about its chemical and physical 

characteristics. 

 Testing of the injection well: to demonstrate the integrity of the well before injection commences 

and throughout injection operations. FutureGen must conduct and pass a two-part mechanical 

integrity test (MIT), in accordance with 40 CFR 146.8 and 146.89, before receiving authorization 

to inject. After injection commences, the permittee will continuously observe and record injection 

pressure, flow rate and volume and the pressure on the annulus to detect leaks in the casing, tubing 

or packer. In addition, FutureGen must demonstrate external mechanical integrity annually using a 

temperature or noise log or another method approved by the Director to detect fluid movement 

behind the casing. They will also test the well materials for signs of corrosion on a quarterly basis 

to provide early warning of corrosion due to contact with carbon dioxide in the presence of water 

that could compromise the wells.

 Monitoring the environment near the wells: to verify that the project and the injected carbon 

dioxide plume and pressure front are behaving as predicted (See the section entitled “Area of 

Review and Corrective Action” for details on the delineation of this area and Figure 1). FutureGen 

will: 

o Perform monitoring above the confining zone using shallow wells and monitor ground 

water quality in deeper wells to detect geochemical changes that may be a result of changes 
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in the subsurface (such as leaching or mobilization of heavy metals and organic compounds 

or fluid displacement) that could impact USDWs. 

o Conduct annual pressure fall-off testing to verify that the injection zone is responding to 

injection as predicted.

o Monitor the carbon dioxide plume and pressure front using direct methods (e.g., fluid 

sampling and pressure/temperature monitoring) and indirect methods (e.g., pulsed neutron 

capture/reservoir saturation logs and Differential Interferometric Synthetic Aperture Radar) 

to verify that the carbon dioxide plume and pressure front are moving as predicted or

provide early warning if they are not.

 Monitoring for natural or induced seismic events: to verify that the project is operating as predicted 

and the geologic system and injection wells are not compromised by any felt or unfelt 

microseismic events, whether natural or induced. 

In accordance with 40 CFR 144.54 and 146.91, FutureGen will submit the results of this monitoring to the 

permitting authority semiannually or within 30 days of the completion of an MIT or other required testing. 

EPA evaluated the permittee’s proposed Testing and Monitoring Plan to ensure that all testing procedures

are appropriate to the planned operations, the wells’ construction, and the geologic environment and that 

this testing and monitoring meets the requirements of the Class VI Rule at 40 CFR 146.90. The proposed 

well testing is appropriate to the planned well construction and will provide early warning of any problems 

that may occur. EPA also determined, based on information regarding the anticipated movement of the 

carbon dioxide plume and pressure front that the locations and methods for monitoring ground water 

quality and the position of the plume and pressure front will provide the information needed to provide 

early warning of ground water quality changes or carbon dioxide leakage. EPA considered modeling data, 

hydrogeologic information on the properties of the injection and confining zone, and the need to limit the 

number of penetrations of the confining zone in determining the appropriate direct and indirect ground 

water and carbon dioxide monitoring regime. 

Emergency and Remedial Response: In accordance with 40 CFR 146.94, FutureGen developed a sitespecific Emergency and Remedial Response Plan that identifies the resources that may be at risk due to the 

injection activities, including USDWs. The Plan, an enforceable part of the permit, also describes the 

responses that would be taken to address adverse events, and the staff and equipment available to support 

this and other such activities. The Emergency and Remedial Response provisions of the permit will 

facilitate expedient responses and prevent or mitigate harm to the environment, including USDWs. EPA 

evaluated the Emergency and Remedial Response Plan to verify that sufficient, specific procedures are in 

place should an adverse event (including a well failure, leakage of carbon dioxide, or a seismic event) that 

impacts any identified resource in the AoR arise, so that the permittee can expeditiously take effective 

actions to prevent or mitigate harm to USDWs. 

Financial Responsibility: In accordance with 40 CFR 146.85, FutureGen has demonstrated and will 

maintain adequate financial resources to perform all needed corrective action on wells in the AoR, to plug 

the injection wells, to perform all required post-injection site care and close the site, and to conduct any

emergency and remedial responses needed to address adverse events at the site. This financial assurance

confirms that resources will be available to perform all USDW-protective activities without using 

public/taxpayer money. The FutureGen Alliance estimated the costs necessary to cover the activities 

described above and provided a signed Trust Agreement to demonstrate that sufficient resources will be 

available. FutureGen will update the cost estimates on an annual basis and, if necessary, adjust the 

financial responsibility demonstration to address any changes, e.g., based on inflation or changes to the 

project that affect these costs.
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EPA determined that the Trust Agreement amount is adequate by comparing cost estimates provided by

the FutureGen Alliance for the covered activities to estimates EPA independently generated using its Cost 

Estimation Tool, which estimates financial responsibility costs based on site-specific information (e.g., 

about well depth, the presence of USDWs in the AoR, and the volume of carbon dioxide to be injected).

EPA also evaluated the financial responsibility instruments using checklists developed by the UIC 

Program that evaluate the strength of available instruments. Additionally, EPA concluded that the pay-inperiod suggested for funding the instrument is appropriate and protective. Information on EPA’s cost 

estimation analysis is documented in a report that is available in the Administrative Record for these 

permit decisions. 

Plugging and Abandonment: In accordance with 40 CFR 146.92, the permits include Well Plugging 

Plans for environmentally protective closure of the injection wells to ensure that the wells will be plugged 

in a manner that will not allow movement of injected or native fluids into USDWs. The wells will be 

plugged using approved materials that are compatible with carbon dioxide/water mixtures to ensure that 

they will not serve as a conduit for fluid movement. EPA evaluated the permittee’s proposed Injection 

Well Plugging Plans to verify that the wells will be plugged with sufficient numbers and types of plugs 

and cement, based on the proposed depth and design of the wells and geologic information, to ensure that 

after they are plugged, the wells will not serve as a conduit for fluid movement. EPA will review the Well 

Plugging Plans after the permittee submits the final “as built” well schematics following construction of 

the wells to confirm that the Well Plugging Plans are appropriate. The Injection Well Plugging Plans are

enforceable conditions of the Class VI permits.

Post-Injection Site Care (PISC) and Site Closure: In accordance with 40 CFR 146.93, the permittee 

must implement an approved Post-Injection Site Care and Site Closure Plan, which is an enforceable 

condition of the Class VI permit. Following the cessation of injection, FutureGen must continue to monitor 

ground water quality and track the movement of the carbon dioxide plume and pressure front in a manner 

similar to that described under “Monitoring and Reporting Requirements” above. This monitoring will 

help confirm predictions about the behavior of the carbon dioxide plume and pressure front (i.e., that 

pressures will subside after injection ceases), provide early warning of any USDW endangerment, and 

eventually inform a non-endangerment demonstration (i.e., that the site no longer poses a risk of 

endangerment to USDWs and no further monitoring or site care are needed). EPA evaluated the proposed 

post-injection monitoring along with its review of the injection phase ground water and carbon dioxide 

plume and pressure front monitoring, as described under “Monitoring and Reporting Requirements,”

above.

The permittee will continue this post-injection monitoring for at least 50 years and until they can 

demonstrate that the site does not pose a risk of endangerment to USDWs and that site closure may be 

authorized. Post-injection monitoring must continue until the permittee can successfully demonstrate that 

the site does not pose a risk to USDWs, based on site-specific information that is descried in the PostInjection Site Care and Site Closure Plans. This non-endangerment demonstration will be based on a 

comparison of monitoring data to model predictions and an evaluation of the carbon dioxide plume, 

mobilized fluids, reservoir pressure, and potential conduits for fluid movement.

Following authorization of site closure, the permittee will plug all monitoring wells with carbon dioxidecompatible materials to ensure that they cannot serve as conduits for fluid movement and will restore the 

site to its original condition (by removing all equipment and planting vegetation).
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Issuance and Effective Date of Permit: In accordance with 40 CFR 124.15, the permit will become 

effective immediately upon final issuance if no public comments were received during the public comment 

period that requested a change in the draft permits. However, in the event that public comments are 

received that request a change in the draft permits, then the final permits will become effective 45 days 

after the date of issuance unless the permits are appealed. In accordance with 40 CFR 144.36(a), the 

permits will be in effect for the life of the project, unless they are otherwise modified, revoked and 

reissued, or terminated as provided at 40 CFR 144.39, 144.40 and 144.41. The permits will expire in one 

year if FutureGen fails to commence construction, unless a written request for an extension of this one 

year period has been approved by the Director. Authorization to inject under these permits will be granted 

following well construction and compliance with additional requirements as outlined in the permit and 

regulations at 40 CFR 146.82, 146.86, 146.87 and 146.89. If significant changes occur to the permit 

between this draft decision and the authorization to inject, there will be an additional opportunity for 

public comment pursuant to requirements at 40 CFR 144.39. 

Opportunity for Public Input: Questions, comments and requests for additional information may be 

submitted in writing to Jeffrey McDonald at mcdonald.jeffrey@epa.gov via the internet. The public 

comment period on this permitting action will close on May 15, 2014, 45 days after the date of the public 

notice. During the comment period, EPA will also conduct a public hearing, on May 7, 2014 from 7–9 pm 

at MacMurray College, 447 E. College Ave., Jacksonville, IL to facilitate submittal of verbal comments on 

these permits. 

The administrative record index for these permits is available at 

www.epa.gov/region5/water/uic/futuregen/. The full administrative record, including all data and 

information submitted by FutureGen in support of its permit applications, is available for public review at 

EPA’s Chicago regional office. The office is open 8:30 a.m.– 4:30 p.m., weekdays. 

To preserve your right to appeal any final permit decision that may be made in this matter under 40 CFR 

Part 124, you must either participate in the public hearing or send in written comments on the draft permit 

decisions. The first appeal must be made to the Environmental Appeals Board; only after all agency

review procedures have been exhausted may you file an action in the appropriate Circuit Court of Appeals 

for review.