UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5

77 WEST JACKSON BOULEVARD

CHICAGO, IL 60604-3590

STATEMENT OF BASIS FOR ISSUANCE OF A CLASS VI UNDERGROUND INJECTION 

CONTROL (UIC) PERMIT

Permit Number: IL-115-6A-0001

Facility Name: CCS#2

Archer Daniels Midland (ADM) of Decatur, Illinois applied for a U. S. Environmental Protection Agency

(EPA) Underground Injection Control (UIC) injection well permit to be used for geologic sequestration of 

carbon dioxide (CO2) as a Class VI well (CCS#2). ADM is capturing CO2 at its agricultural and biofuels 

facility generated from a fuel ethanol production unit which, when injected underground, will support the

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

ADM has planned for two injection wells at this project location. The first well, CCS#1, is currently 

operating with an injection well permit from the Illinois EPA. It will receive 1 million metric tons of CO2

over three years (2011-2014) and prior to injection at CCS#2. 

EPA reviewed all information submitted by ADM to inform the draft permit decision on CCS#2. 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 ADM proposed to monitor the well 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; 

 ADM’s financial responsibility demonstration;

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

 The proposed alternative post-injection site care timeframe; 

 Emergency and remedial response strategy development; 

 The CO2 stream source, characteristics and purity; 

 Environmental justice; 

 Endangered species; and 

 Ensuring USDW protection. 

EPA’s review of the permit application 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 a draft permit decision for this well. 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 or unauthorized zones. 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 this well 

are discussed in the following sections.

Area of Review (AoR) and Corrective Action: In accordance with 40 CFR 144.55, 146.6, 146.7 and 

146.84, the 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. ADM delineated an AoR of approximately 12.6 square miles, as shown in the map 

below. 

Figure 1. The ADM project proposed AoR including: the modeled CO2 plume (in blue) and the predicted area of 

elevated pressure (outlined in green).
This area 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. EPA performed an extensive evaluation of the 

AoR proposed by ADM 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 ADM 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 this permit decision.

In accordance with 40 CFR 144.55 and 146.84, ADM 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 

attached to the permit. Based on an evaluation of well records, ADM has determined that there are two 

active wells (an injection well and a monitoring well for the nearby CCS#1 site) and no temporarily

abandoned or plugged and abandoned wells within the AoR that penetrate the injection zone. EPA 

confirmed ADM’s assessment of wells in the AoR by reviewing water well databases from the Illinois 

State Geological Survey and the Illinois State Water Survey, and confirmed that no wells in the AoR 

penetrate the confining zone and thus no wells require corrective action.

As required at 40 CFR 146.84(e), ADM 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. ADM will also review monitoring 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 permit. If this reevaluation 

indicates that there are changes from predictions, ADM 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): A USDW is defined by the UIC regulations as an 

aquifer or portion of an aquifer that supplies any public water system or that contains a sufficient quantity

of ground water to supply a public water system, and currently supplies drinking water for human 

consumption, or that contains fewer than 10,000 mg/L total dissolved solids and is not an exempted 

aquifer. The base of the St. Peter Formation, the lowermost USDW in the vicinity of the injection well, has 

been identified at approximately 2,604 feet below the ground surface, based on potentiometric data 

collected from four ground water monitoring wells at the site. The shallow, Quaternary- and

Pennsylvanian-age aquifers that serve as the source of local drinking water are approximately 140 feet 

below the ground surface.

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

Simon Sandstone in the interval between 5,545 and 7,051 feet below the ground surface. This injection 

zone is separated from the lowermost USDW by approximately 2,000 feet of rock, including an 

impermeable confining zone, the Eau Claire Formation, which will act as barrier to fluid movement.

Figure 2 shows the depth of the injection and confining zones.

EPA has reviewed extensive information submitted by ADM, 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 an excessive 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. EPA also evaluated 

information on seismic history in the area and 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.

Construction Requirements: The proposed construction of the injection well meets the regulatory criteria 

of 40 CFR 146.86. All Class VI wells must be constructed with carbon dioxide-compatible materials and 

cements that can withstand exposure to carbon dioxide and carbon dioxide/water mixtures without 

excessive corrosion over the life of the project (see Figure 2 for a construction schematic). This well 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 limitations set in the permit. EPA reviewed the 

proposed well schematics submitted with the permit application to verify that the cements and other 

materials proposed for the well 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 well was constructed to ensure USDW protection,

meet the goals of the Class VI Rule at 40 CFR 146.86(a) and that it is equipped with the required shutdown devices before injection is authorized.

Injection Fluid: The permit limits the fluid that may be injected to the carbon dioxide stream generated 

from ADM’s fuel ethanol production unit and is proposed to be 99.9 percent CO2. The expected maximum 

daily amount of carbon dioxide to be injected is 3,000 megatons. ADM anticipates injecting a total of 5.5 

million tons of carbon dioxide over five years in the CCS#2 well. EPA evaluated historical information 

about the carbon dioxide generated by the ethanol plant provided by ADM and determined that the carbon 

dioxide generated is very pure and contains no hazardous constituents. 

Maximum Injection Pressure: The maximum injection pressure will be limited to 2,380 pounds per 

square inch gauge (psig) measured at the surface. This pressure is 90 percent of the fracture pressure of the 

Mt. Simon Sandstone, which was calculated based on the results of formation testing performed at the 

CCS#1 well near the proposed site. This limitation will 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). 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. 
Figure 2. Injection Well Schematic
Monitoring and Reporting Requirements: In accordance with 40 CFR 146.90, ADM 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 permit, includes the following testing that ADM 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. ADM 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, ADM 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, ADM 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. 

ADM 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 well.

 Monitoring the environment near the well: 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). ADM will: 

o Perform groundwater quality monitoring in shallow wells quarterly in the first years of the 

project and every 6 months later in the project, and monitor ground water quality in deeper 

wells annually to detect geochemical changes that may be a result of changes in the 

subsurface (such as leaching or mobilization of heavy metals and organic compounds or 

fluid displacement) that could impact USDWs. 

o Conduct Pressure fall-off testing half-way through the injection period and at the end of 

injection to verify that the injection zone is responding (to injection) as predicted.

o Track the movement of 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 3D seismic surveys) 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, ADM 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 ADM’s proposed Testing and Monitoring Plan to ensure that all testing procedures are 

appropriate to the planned operations, the well’s 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, ADM developed a site-specific 

Emergency and Remedial Response Plan that identifies the resources that may be at risk due to the 

injection activities, including USDWs; drinking water wells; the Sangamon River; Bois Du Sangamon 

Nature Preserve; and Lake Decatur; and infrastructure, including the wellhead, structures at Richland 

Community College, and the ADM facilities. The Plan, which is 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 ADM can expeditiously take 

effective actions to prevent or mitigate harm to USDWs. 

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

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

injection well, to perform all required post-injection site care activities and close the site, and to conduct 

any emergency and remedial response needed to address adverse events at the site. This financial 

responsibility ensures that resources are available to perform all USDW-protective activities without using 

public/taxpayer money. ADM estimated the costs necessary to cover the activities described above and 

provided financial statements and bond ratings to demonstrate that it has the necessary resources to cover 

these costs. ADM 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.

EPA determined that the amount of funds ADM has set aside is adequate by comparing cost estimates 

provided by ADM 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. Information on EPA’s cost estimation analysis 

is documented in a report that is available in the Administrative Record for this permit decision.

Well Plugging: In accordance with 40 CFR 146.92, the permit includes a Well Plugging Plan for

environmentally protective plugging of the injection well to ensure that the well will be plugged in a 

manner that will not allow movement of injected or native fluids into USDWs. The well will be plugged 

using approved materials that are compatible with carbon dioxide/water mixtures to ensure that it will not 

serve as a conduit for fluid movement. EPA evaluated ADM proposed Injection Well Plugging Plan to 

verify that the well will be plugged with sufficient numbers and types of plugs and cement, based on the 

proposed depth and design of the well and geologic information, to ensure that after it is plugged, the well 

will not serve as a conduit for fluid movement. EPA will review the plugging plan after ADM submits the 

final “as built” well schematics following construction of the well to confirm that the plugging plan is 

appropriate. The Injection Well Plugging plan is an enforceable condition of the Class VI permit.

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, ADM 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.

ADM will continue this post-injection monitoring for at least ten (10) 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. This 

timeframe differs from the 50-year default in the Class VI Rule, and is allowable if a permittee can 

demonstrate, based on significant, site-specific data and information about the site and the proposed 

operation that the project will no longer pose a risk of endangerment to USDWs at the end of this 

alternative post-injection site care timeframe. In approving ADM’s alternative PISC timeframe, EPA 

considered information on the predicted movement of the carbon dioxide plume and pressure front, as 

informed by the AoR delineation modeling; predictions of plume migration, pressure decline, and carbon 

dioxide trapping; site-specific geology; well construction; and the distance between the injection zone and 

the nearest USDWs.

Post-injection monitoring must continue until ADM can successfully demonstrate that the site does not 

pose a risk to USDWs, based on site-specific information that is descried in the Post-Injection Site Care 

and Site Closure Plan. 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, ADM 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).

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 are received during the public comment 

period that request a change in the draft permit. However, in the event that public comments are received 

that request a change in the draft permit, then the permit will become effective 45 days after the date of 

issuance unless the permit is appealed. In accordance with 40 CFR 144.36(a), the permit will be in effect 

for the life of the project, unless it is otherwise modified, revoked and reissued, or terminated as provided 

at 40 CFR 144.39, 144.40 and 144.41. The permit will expire in one (1) year if ADM fails to commence 

construction, unless a written request for an extension of this one (1) year period has been approved by the 

Director. Authorization to inject under this permit 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 Allan Batka at batka.allan@epa.gov via the internet. The public comment period 

on this permitting action will close on May xx, 2014, 45 days after the date of the public notice. During the 

comment period, EPA will also conduct a public hearing on May xx, 2014 at [location, address] to 

facilitate submittal of verbal comments on this permit. 

The administrative record index for this permit is available at www.epa.gov/region5/water/uic/adm/. The 

full administrative record, including all data and information submitted by ADM in support of its permit 

application, 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 

decision. 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.