### 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 RECEIPTREQUESTED KennethK. Humphreys ChiefExecutive Officer FutureGen Industrial Alliance, Inc. 73 Central ParkPlaza East. Jacksonville, Illinois 62650 REPLY TO THEATTENTION OF: 

### WU-16J



### Subject: Request forAdditionalInformation Regarding four FutureGen 2.0 Wells, United States Environmental ProtectionAgency Underground Injection Control (UIC) PermitApplications for Four Geologic SequestrationWells; United States Environmental Protection Agency UIC PermitNos. 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 withthis letter. The enclosedtable shows the application language in questionthat is promised at a later date as part ofthe permit applications. Ifany of that information is presently available, it should be included in your response. There are also requests for additional informationthat is needed for ourreview ofyour applications. Please submit any informationno laterthan 30 days from the receipt ofthis letter. Inquiries concerning the contents ofthe enclosure maybe directedto Jeffrey McDonald ofmy staffby telephone at (312) 353-6288 or by email to mcdonald.jeffrey@epa.gov. Sincerely,

# (~~~~/ RebeccaHarvey, Chief Underground Injection Control Branch
cc: StephenNightingale, IEPA
EnclosuresEnclosure 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-milong seismic reflection survey across central Illinois as part of

### a DOE-sponsoredresearch project to characterize reservoirrocks forgeologic storage ofcarbon dioxide. The continuous east-west fine extends from Meredosia to southwestern Champaign County (Figure 2.14). This fine, which is currently underre-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 ofvertical seismic profiling data in the stratigraphic well to betterevaluate the cause ofthe 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" orleakofftests to directlymeasure fracture pressure in eitherthe injection orconfining zones. Mini-frac orleakoffdata are required to definitively calculate site-specific fracture gradients, and to produce high confidence failure plots, fault slip tendency estimates, and criticalpore fluidpressure increase estimates. All ofthese tests will be realized in 2013 during the secondphase ofthe projecf' 

### Have these tests been completed? Please report the results. 2.4.2 "Uncalibratedgeomechanical 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 uncafibratedgeomechanicallogs will laterhave been calibrated overthe coredinterval with six triaxial core-plug tests" 

### Has this analysis been completed? Ifso, please report the results. "Data are insufficient at this stage ofanalysis to be able to quantify the horizontal components ofstress 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: "Laboratoryinvestigations are currently quantifying the important ofthese reactions [transformations offormation minerals to carbonate minerals] at the Morgan County C02 storage site. Therefore, not includedin simulations." Will this information be incorporated into the modeling? Please report the results ofthe core investigations. 3.1.2 Capillary Pressure and Saturation Functions: Page 3.15: "Capillarypressure 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 ofthe core evaluations. 3.1.8 Delineation of the Area of Review (AoR) -- "These controlmeasures and naturalgeologic features thatprotect the USDWinclude the following:

... planned development ofenvironmental release model
... to predict vertical C0 2 and/orbrine 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 andresults. Note that these results are for

### a mass flow rate of 1.3 MMT!yrrather than the current design basis of 1.1 MMT!yrbecause the GulfInterstate calculations have not been updatedsince the design basis was changed from 1.3 MMT!yrto 1.1 MMT!yr. The next phase ofthe pipeline design, to be developedin 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 newknowledge 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 ofany wells required to support implementation ofindirect monitoring approaches willbe 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. Ifthe locations do change, the monitoring wells will retain the intent 

### I described 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 ofthe 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 "Createdpriorto injection." These must be established prior to draft permit decisions. Please provide the mechanism to EPA. 10/30/2013Enclosure 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) Branchmust 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 andthreatened species, the 

## urc branch must have location-specific ecological information, such as the presence ofcertain vegetation, soils or surface waterbodies. The U.S. Fish and Wildlife Service has listed the following in Morgan County:

m corridors with lwrllvls; upland forests ing)

sturbed alluvial soils

esic to wet prairies

As a result, we are requiringthe following information to be submitted in each permit application.
a. A sUlllmary ofthe critical habitat which, ifpresent, may support one ofthe above-listed species. Detailed information oncritical habitat canbe found at the following web address: http:/ /www.fws.gov /midwest/endangered/section7Is7process/lifehistory.htmL b. A survey ofthe surface vegetation, soils, topography and hydrologic features in the action areain sufficient detail to address the presence or absence ofcritical habitat for any endangered, threatened, or candidate species. This will include descriptions such as "matnre mixed forest", "plowedfield" or "stabilized dnnes", and may also include specific trees or plants listed as critical to a species.Enclosure 2

c. A description ofthe action area for the well and associated surface facilities. This will include dimensions ofthe affected area, such as the clearing in which the well is located, length ofroad orpipelineto be built, etc., as well as the extent ofdisruption ofthe area. For example, an existingwellwith no construction plan willbe 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 offorest.
This information must be certified in accordance with 40 CFR 144.32(d). EPArecommends thatthis informationbe gathered in consultation with an ecologist, botanist, orother environmental professional. Ifcritical 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 ofnegative impact to the species. We appreciate your cooperation in protectingthese important species from endangerment and extinction.