UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

OCT 3 l 2013 

CERTIFIED MAIL 7009 1680 0000 7674 2019 

RETURN RECEIPT REQUESTED 

Kenneth K. Humphreys 

Chief Executive Officer 

FutureGen Industrial Alliance, Inc. 

73 Central Park Plaza East. 

Jacksonville, Illinois 62650 

REPLY TO THE ATTENTION OF: 

WU-16J 

Subject: Request for Additional Information Regarding four FutureGen 2.0 Wells, 

United States Environmental Protection Agency Underground Injection Control 

(UIC) Permit Applications for Four Geologic Sequestration Wells; United States 

Environmental Protection Agency UIC Permit Nos. IL-137-6A-0001, -0002,-

0003, & -0004 

Dear Mr. Humphreys: 

In order to complete our review ofFutureGen's permit applications, we need additional 

information described in the enclosures with this letter. The enclosed table shows the application 

language in question that is promised at a later date as part of the permit applications. If any of 

that information is presently available, it should be included in your response. There are also 

requests for additional information that is needed for our review of your applications. Please 

submit any information no later than 30 days from the receipt of this letter. 

Inquiries concerning the contents of the enclosure may be directed to Jeffrey McDonald of my 

staff by telephone at (312) 353-6288 or by email to mcdonald.jeffrey@epa.gov. 

Sincerely, 

(~~~~/ 

Rebecca Harvey, Chief 

Underground Injection Control Branch 

cc: Stephen Nightingale, IEP A 

Enclosures 
Enclosure 1 

Section of 

Application 

2 

L_ 

FutureGen 2.0 Permit Applications 

Deficiencies 

Deficiency 

2.3.1.1 "The Illinois State Geological Survey (ISGS) recently acquired a new 120-mi long seismic reflection survey 

across central Illinois as part of a DOE-sponsored research project to characterize reservoir rocks for geologic storage 

of carbon dioxide. The continuous east-west fine extends from Meredosia to southwestern Champaign County (Figure 

2.14). This fine, which is currently under re-processing, will supply additional information about the structure ofthe 

sedimentary layers which will be correlated to the observations made on both profiles L 101 and L201." 

"Future efforts at Morgan County will also include the acquisition of vertical seismic profiling data in the stratigraphic 

well to better evaluate the cause of the vertical disruptions in seismic reflections observed on the two existing seismic 

profiles." 

Have these tests been completed? Please report the results. 

2.4.1 "Various supportive geomechanical data were collected, but there are no available "mini-frac" or leakoff tests to 

directly measure fracture pressure in either the injection or confining zones. Mini-frac or leakoff data are required to 

definitively calculate site-specific fracture gradients, and to produce high confidence failure plots, fault slip tendency 

estimates, and critical pore fluid pressure increase estimates. All of these tests will be realized in 2013 during the 

second phase of the projecf' 

Have these tests been completed? Please report the results. 

2.4.2 "Uncalibrated geomechanical stress properties logs were calculated from the density fog and the compressional 

and shear wave sonic log data. These geomechanica/ logs indicate there is strong stress anisotropy. These 

uncafibrated geomechanicallogs will later have been calibrated over the cored interval with six triaxial core-plug tests" 

Has this analysis been completed? If so, please report the results. 

"Data are insufficient at this stage of analysis to be able to quantify the horizontal components of stress and thus 

distinguish between normal and strike-slip regimes." 

How will you obtain and when will you have sufficient data? 

·-- -
Enclosure 1 

3 

3.1.2 Page 3.3: "Laboratory investigations are currently quantifying the important ofthese reactions [transformations 

of formation minerals to carbonate minerals] at the Morgan County C02 storage site. Therefore, not included in 

simulations." 

Will this information be incorporated into the modeling? 

Please report the results of the core investigations. 

3.1.2 Capillary Pressure and Saturation Functions: Page 3.15: "Capillary pressure data determined from site-specific 

cores were not available at the time the model was constructed." 

Will such data be collected and compared with values used in the simulation? 

Also, please report the results of the core evaluations. 

3.1.8 Delineation of the Area of Review (AoR) --

"These control measures and natural geologic features that protect the USDW include the following: 

... planned development of environmental release model ... to predict vertical C02 and/or brine movement under 

different containment-loss scenarios .... " 

When will this be done? 

As you note, EPA Guidance for AoR delineation suggests that with an over-pressurized injection zone some analytical 

methods for calculating a pressure front can lead to an infinite pressure front. Instead of automatically using the 

separate-phase plume to delineate the AoR, we suggest that you look into other methods to estimate an acceptable 

pressure increase for over-pressurized reservoirs. Refer to "Geologic Sequestration of Carbon Dioxide Underground 

Injection Control (UIC) Program Class VI Well Area of Review Evaluation and Corrective ActionGuidance", page 42, 

which can be found at: 

htt[2://water. e[2a.govlty[2elgroundwaterluiclclass6lu[2loadle[2a816r13005. [2df 

4 

4.1.4 "Table 4.2 contains a summary ofthe pipeline design assumptions and results. Note that these results are for a 

mass flow rate of 1.3 MMT!yr rather than the current design basis of 1.1 MMT!yr because the Gulf Interstate 

calculations have not been updated since the design basis was changed from 1.3 MMT!yr to 1.1 MMT!yr. The next 

phase of the pipeline design, to be developed in 2013, will update this information." 
Enclosure 1 

Please submit the results or provide a date for future submittal. 

5 

Pg. 5.4, Sec. 5.1.2 Par. 1: "As additional characterization data are collected, the site conceptual model will be revised 

and the modeling steps described above will be updated to incorporate new knowledge about the site". i.e., they will 

add information to this section as it becomes available 

When will this be done? 

Pg. 5.8, Sec. 5.1.4 end of Par 2: "The location of any wells required to support implementation of indirect monitoring 

approaches will be determined once candidate technologies have been evaluated and the selection process 

completed'. 

Future Gen has selected locations for the monitoring wells based on the preliminary modeling. Once they begin onsite activity, these locations may change. If the locations do change, the monitoring wells will retain the intent 

described I in this plan. 

When will these technologies be evaluated and when will any changes be proposed? 

6 

EPA Form 7520-14 (Plugging & Abandonment Plan) is missing- please provide it for each well 

Information concerning the slurry volume and slurry weight of the EverCrete cement is needed. 

In Figure 6.2, the 7" casing is set at 3400 feet, however a cement retainer will be at 3900 feet, which is below the ' 

cased hole. Please correct. 

9 

Table 9.1. Approach to Meeting Financial Responsibility Requirements -several financial mechanisms state that they 

are to be "Created prior to injection." These must be established prior to draft permit decisions. Please 

provide the mechanism to EPA. 

10/30/2013 
Enclosure 2 

In accordance with 40 CFR 144.4 (c), the U.S. Environmental Protection Agency (EPA) is required to 

comply with the Endangered Species Act (ESA) when issuing permit decisions. Therefore, when 

considering a permit application, the Underground Injection Control (UIC) Branch must consider the 

potential impacts from the new or existing injection well to endangered species present in the area. In 

order to determine whether an injection well will adversely impact endangered and threatened species, the 

urc branch must have location-specific ecological information, such as the presence of certain 

vegetation, soils or surface water bodies. The U.S. Fish and Wildlife Service has listed the following in 

Morgan County: 

m corridors with 

lwrllvls; upland forests 

in g) 

sturbed alluvial soils 

esic to wet prairies 

As a result, we are requiring the following information to be submitted in each permit application. 

a. A sUlllmary of the critical habitat which, if present, may support one of the above-listed 

species. Detailed information on critical habitat can be found at the following web address: 

http:/ /www.fws. gov /midwest/ endangered/ section 7 I s7 process/lifehistory .htmL 

b. A survey ofthe surface vegetation, soils, topography and hydrologic features in the action 

area in sufficient detail to address the presence or absence of critical habitat for any 

endangered, threatened, or candidate species. This will include descriptions such as "matnre 

mixed forest", "plowed field" or "stabilized dnnes", and may also include specific trees or 

plants listed as critical to a species. 
Enclosure 2 

c. A description of the action area for the well and associated surface facilities. This will 

include dimensions of the affected area, such as the clearing in which the well is located, 

length of road or pipeline to be built, etc., as well as the extent of disruption of the area. For 

example, an existing well with no construction plan will be less disruptive than a proposed 

well, and a proposed well in an open, plowed field will be less disruptive than one which 

requires some clearing of forest. 

This information must be certified in accordance with 40 CFR 144.32(d). EPA recommends that this 

information be gathered in consultation with an ecologist, botanist, or other environmental professional. 

If critical habitat is present, the pennit is not automatically denied. EPA, in conjunction with the U.S. 

Fish and Wildlife Service, will examine more detailed information to detennine the presence of 

endangered species in the area and the likelihood of negative impact to the species. We appreciate your 

cooperation in protecting these important species from endangerment and extinction.