You’re invited

The EPA will hold an open house and a 

formal public hearing on the FutureGen 

draft permits at: 

MacMurray College

447 E. College Ave.

Jacksonville, IL 

Wednesday, May 7

Open House and Q&A, 

11 a.m. – 1 p.m. and 5 – 7 p.m.

Public hearing, 7 – 9 p.m.

Oral and written comments will be 

recorded or accepted at the hearing. 

EPA will provide a summary of its 

proposed decision but will not answer 

questions during the hearing.

How to comment

In addition to accepting comments at 

the public hearing, EPA will accept 

written comments until May 15. 

Comments can be sent to Jeffrey 

McDonald or submitted online at the 

web page below: 

Jeffrey McDonald

U.S. EPA

UIC Branch (WU-16J)

77 W. Jackson Blvd.

Chicago, IL 60604-3590

Web resources

www.epa.gov/region5/water/uic/

futuregen/

You may call EPA toll-free at 

800-621-8431, 8:30 a.m. - 4:30 p.m., 

weekdays. 

Public Comment on First

Carbon Storage Draft Permits 

*This map shows where the proposed injection wells will be.

The U.S. Environmental Protection Agency has proposed to approve 

permits to allow FutureGen Industrial Alliance to inject and store carbon 

dioxide, or CO2 , underground at a facility in Morgan County, Illinois, 

approximately 11 miles northeast of Jacksonville. The process is called 

“carbon capture and storage,” or “carbon sequestration.” EPA is accepting 

comments from the public on the draft permits. 

These are the first Class VI permits for carbon sequestration in the United 

States. CO2 is a greenhouse gas that contributes to climate change. Carbon 

sequestration is a means of reducing greenhouse gas emissions.

FutureGen would capture CO2 emissions from a coal-fired power plant in 

Meredosia formerly operated by Ameren Energy Resources. FutureGen 

would then purify the CO2 and put it under high pressure to turn it into a 

liquid so it can be piped to four wells and injected deep into the ground.

FutureGen plans four main wells and several additional wells that the 

company would use to monitor the injection, under EPA oversight. 

FutureGen selected the well locations after a long period of scientific 

research and planning. This is to make sure the wells would work as 

planned according to local geography and geology.

The four injection wells would be drilled from a single location to a depth 

of about 4,000 feet below ground (see figure on fifth page). FutureGen 

plans to inject approximately 1.1 million metric tons of CO2 per year into 

a type of rock known as the Mount Simon Sandstone over 20 years, for a 

total of 22 million metric tons. Sequestering 1.1 million metric tons a 

year is the equivalent of removing 232,000 cars from the road.

FutureGen Industrial Alliance Inc. Carbon Storage Wells 

Morgan County, Illinois April 2014
How did EPA make its draft decision?

In reviewing FutureGen’s permit application, EPA 

evaluated technical information and project-specific 

data, such as: 

• Advanced computational modeling to determine 

the proposed project area.

• The rock layers through which the proposed 

injection wells would be drilled, to confirm that 

the CO2 will stay where it is injected.

• The location of drinking water resources near 

the project and how they will be protected.

• The proposed well construction design.

• The characteristics of the CO2 to be injected.

• The proposed approach and technologies 

FutureGen will use to operate and monitor the 

project during and after injection.

• The financial resources FutureGen will have 

available to responsibly operate, monitor and 

close the project.

• FutureGen’s approach to ensure that the project 

will protect underground sources of drinking 

water, public health and the environment. 

What happens next in the permit process?

EPA will review all public comments before making a 

final decision on whether or not to grant the permits. 

The Agency will respond to all comments on the draft 

permits. 

If EPA decides to issue final permits, FutureGen would 

be allowed to drill the proposed wells. 

Information Repository

The draft permits and fact sheet are available at:

Jacksonville Public Library

201 W. College Ave.

Jacksonville, IL 

Administrative Record

The administrative record index is available on the web page identified below. 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 review the 

administrative record or for additional information, contact Jeffrey McDonald at 312-353-6288 or 

mcdonald.jeffrey@epa.gov.

On the Web

For more information about the FutureGen project:

www.epa.gov/region5/water/uic/futuregen/

Legal Notice

To preserve your right to appeal any final permit decision, you must either comment during the public hearing or send 

in written comments on the draft permit decision by the end of the comment period. 

The first appeal must be made to EPA’s Environmental Appeals Board; only after all EPA review procedures have 

been exhausted may you file an action in the appropriate Circuit Court of Appeals.
Technical background and details of FutureGen’s carbon storage project

The EPA’s review of FutureGen’s permit application 

and supporting documentation indicates no 

environmental impact should result from the proposed 

injection, so EPA intends to issue the permits. 

Because the four injection wells are similar and are 

drilled from a single well pad, the injected CO2 will 

form one comingled plume. Therefore, permit provisions and plans are identical for all four wells.

Title 40 of the Code of Federal Regulations Parts 144 

and 146 require EPA permits for carbon storage, known 

as Class VI permits, to specify conditions for the 

construction, operation, monitoring, reporting, plugging, 

post-injection site care and site closure of Class VI 

injection wells to prevent movement of fluid into any 

underground source of drinking water, or USDW. See 

40 CFR Parts 144 and 146 for the general provisions of 

underground injection permits. 

Here, in accordance with 40 CFR 124.8, is general 

information and highlighted permit conditions specific 

to these wells.

Area of Review and Corrective Action: In accordance 

with 40 CFR 146.84, the Area of Review, or AoR, is the 

area surrounding the injection wells where any 

improperly sealed, completed or abandoned wells that 

penetrate the confining rock zone 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 model that 

predicts the movement of the CO2 plume and pressure 

front based on information about planned injection and 

the subsurface rock. See the figure on the sixth page.

Three wells within the AoR penetrate the confining rock 

zone – a properly constructed test well installed by 

FutureGen and two wells approximately 16 miles from 

the injection site that have been properly plugged. 

As required at 40 CFR 146.84(e), FutureGen will reevaluate the AoR by re-running the models at least 

every five years over the life of the project to verify, 

based on monitoring and operating data, that the CO2 

plume and pressure front are moving as predicted. If 

there are any changes from predictions, FutureGen must 

revise the project-specific plans described here and EPA 

will modify the permits per 40 CFR 144.39.

Underground Sources of Drinking Water: 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 lowest USDW near the wells, the St. Peter 

Sandstone formation, is 1,942 feet below ground.

Injection and Confining Zone: Injection is limited to 

the Mount Simon and Eau Claire rock formations 

between 3,785 feet and 4,432 feet below ground. This 

zone is separated from the lowest USDW by 1,843 feet 

of rock, including an impermeable confining zone as a 

barrier to fluid movement. EPA has reviewed company 

information, including maps, well logs, cores and the 

results of seismic surveys, and determined that geologic 

features will allow the Mount Simon formation to 

receive the amounts proposed to be injected without 

fracturing, and that the confining zone will provide a 

suitable trap so that the CO2 will remain in place and 

USDWs will not be endangered, as required under 40 

CFR 146.83. 

Construction Requirements: Proposed construction of 

the wells meets the regulatory 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. 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 an automatic surface shut-off 

device that will shut off the well if any permitted 

operating parameters – such as injection pressure –

diverge from permit limitations. FutureGen may not 

commence construction, including drilling, of any new 

well until a final permit has been issued and is effective.

Injection Fluid: The permits limit injected fluid 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 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 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).

Monitoring and Reporting Requirements: In 

accordance with 40 CFR 146.90, FutureGen will 

implement an approved Testing and Monitoring Plan. 

The company will analyze the CO2 monthly to provide 

information about its characteristics. FutureGen must

also demonstrate well integrity before injection begins 

and throughout injection operations. FutureGen must 

conduct and pass a two-part mechanical integrity test, in 
accordance with 40 CFR 146.8 and 146.89, before EPA 

will authorize FutureGen to inject. After injection 

begins, the company will continuously observe and 

record injection pressure, flow rate and volume and 

pressure on the annulus to detect any leaks in the casing,

tubing or packer. FutureGen must also demonstrate 

external mechanical integrity using a temperature or 

noise log, or other approved method, yearly to detect 

any fluid movement behind the casing. FutureGen will 

test the wells for signs of corrosion quarterly to provide 

early warning of well material corrosion due to contact 

with CO2 in the presence of water that could 

compromise the well.

FutureGen will also monitor the environment near the 

wells to verify that the project and the injected CO2 are 

behaving as predicted. The company must perform 

groundwater quality monitoring throughout the AoR 

quarterly for the first three years, then on a semi-annual 

or annual basis, to detect geochemical changes that may 

be a result of changes – such as leaching or mobilization 

of heavy metals and organic compounds or fluid 

displacement – that could impact USDWs. Pressure falloff testing will be performed at least every five years to 

verify that the injection zone is responding to injection 

as predicted. FutureGen will also track the movement of 

the CO2 plume and pressure front using direct methods 

(e.g., pressure measurements) and indirect methods 

(e.g., passive seismic monitoring) to verify that the CO2

plume and pressure front are moving as predicted or to 

provide early warning if they are not. 

In accordance with 40 CFR 144.54 and 146.91, 

FutureGen will submit results to EPA semiannually or 

within 30 days of the completion of a mechanical 

integrity test or other required testing. 

Emergency and Remedial Response: In accordance 

with 40 CFR 146.94, FutureGen developed a sitespecific Emergency and Remedial Response Plan that 

identifies resources that may be at risk due to the 

injection activities, including four USDWs. The plan, an 

enforceable part of the permits, also describes 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 permits will facilitate expedient 

responses and prevent or mitigate harm to the 

environment, including USDWs.

Financial Responsibility: In accordance with 40 CFR 

146.85, FutureGen has demonstrated, and will maintain, 

adequate financial responsibility 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 needed 

emergency and remedial response to address adverse 

events at the site. FutureGen will cover these costs and 

demonstrate financial responsibility with a trust fund.

Cost estimates must be updated within 60 days prior to 

the anniversary date of the establishment of the financial 

instruments. This ensures resources are available to 

perform these USDW-protective activities without using 

public/taxpayer money.

Well Plugging: In accordance with 40 CFR 146.92, the 

permits include an Injection Well Plugging Plan for 

environmentally protective well closure at the cessation 

of injection operations. The wells will be plugged using 

approved materials that are compatible with CO2/water 

mixtures to ensure the wells will not serve as a conduit 

for fluid movement.

Post-Injection Site Care and Site Closure: In 

accordance with 40 CFR 146.93, FutureGen must 

implement an approved Post-Injection Site Care and 

Site Closure Plan. Following the cessation of injection, 

the company must continue to monitor groundwater 

quality, track the movement of the CO2 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 CO2 plume and pressure front (i.e., that 

pressure should subside after injection ceases) and 

provide early warning of USDW endangerment. 

FutureGen will continue this post-injection monitoring 

for at least 50 years and until they can demonstrate 

based on monitoring and other site data that the site 

does not pose a risk to any USDWs and that site closure 

may be authorized. Following authorization of site 

closure, FutureGen will plug all monitoring wells with 

CO2-compatible materials to ensure they cannot serve as 

conduits for fluid movement and will restore the site to 

its original condition by removing all equipment and 

planting vegetation.

Issuance and Effective Date of Permits: In accordance 

with 40 CFR 124.15, the permits will become effective 

immediately upon final issuance if no public comments 

are received during the public comment period that 

request a change in the draft permits. However, if public 

comments are received that request a change in the draft 

permits, 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 

EPA. Authorization to inject under the permits will be 

granted following well construction and FutureGen is in

compliance with additional requirements as outlined in 

the permits and regulations at 40 CFR 146.82, 146.86, 

146.87 and 146.89.
For reference, the deepest underground municipal water supply wells in Jacksonville are 95 feet.
Area of Review (10 psi circle) and 22-year CO2 plume