You’re invited

The EPA will hold an open house and a 

formal public hearing on the ADM 

draft permit at: Decatur Public Library, 

130 N. Franklin Street 

May 21, 2014

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. 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 from April 16 until 

May 30, 2014. Comments can be sent 

to Allan Batka or submitted online at 

the web page below 

Allan Batka

U.S. EPA 

UIC Branch (WU-16J) 

77 W. Jackson Blvd. 

Chicago, IL 60604-3590 

Web resources

 

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

You may call EPA toll-free at 

800-621-8437, 8:30 a.m. – 4:30 p.m., 

weekdays.

Public Comments Sought on

Carbon Storage Draft Permit 

This map shows where the proposed injection well will be.

The U.S. Environmental Protection Agency is accepting comments from 

the public (see box, left) on its intent to issue a permit for the Archer 

Daniels Midland Co. to inject and store carbon dioxide, or CO2 , 

underground at its Decatur facility. The process is called “carbon capture 

and storage,” or “carbon sequestration.” 

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

sequestration is a means of reducing greenhouse gas emissions. 

CO2 is created when ADM makes ethanol. In carbon capture and storage, 

the CO2 is captured before it goes into the air. It is then put under high 

pressure and turned into a liquid so it can be injected deep into the ground 

through wells.

ADM selected the well location after a long period of scientific research 

and planning. This is to make sure the well is going to work as planned 

according to local geography and geology. 

ADM has an existing well and plans a new well for CO2 injection. ADM 

plans several other wells that will help the company monitor the main 

wells over time. Scientists will study the CO2 injection process and, after 

the injection ends, the storage site to make sure the CO2 remains in place. 

This information will be used to help similar projects in other places.

The first well, CCS #1, is already working. It is receiving 1 million metric 

tons of CO2 over three years. CCS#1 is operating under a permit issued by 

Illinois EPA. The second well, CCS #2, has not yet been drilled. ADM 

plans to inject 1.1.million metric tons of CO2 per year into this well over 

five years. Sequestering 1.1 million metric tons of carbon dioxide each 

year is the equivalent of eliminating carbon emissions from 232,000 cars. 

Archer Daniels Midland Co. Carbon Storage Well 

Decatur, Illinois April 2014
How did EPA make its decision?

In reviewing ADM’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 well 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 ADM 

will use to operate and monitor the project 

during and after injection. 

• The financial resources ADM will have 

available to responsibly operate, monitor and 

close the project. 

• ADM’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 permit. The 

Agency will respond to all comments on the draft 

permit. 

If EPA decides to issue the final permit, ADM would be 

free to drill the proposed CCS #2. 

Information Repository 

The draft permit and fact sheet are available at:

Decatur Public Library

130 N. Franklin St. 

Administrative Record

The full administrative record, including all data submitted by Archer Daniels Midland Co. 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 review the administrative record or for additional information please contact Allan Batka at 312-353-

7316 or batka.allan@epa.gov.

On the Web

For more information about the ADM project: 

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

Legal Notice

To preserve your right to appeal any final permit decision, you must either participate in 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 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. 
Technical background and details of ADM’s carbon storage project

The EPA’s review of ADM’s permit application 

indicates no significant environmental impact should 

result from the proposed injection, so EPA intends to 

issue a permit for this well. 

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 the movement of fluids into 

any underground source of drinking water, or USDW. 

See 40 CFR Parts 144 and 146 for the general 

provisions of underground injection permits. 

In accordance with 40 CFR 124.8, below is information 

and highlighted permit conditions for the well.

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 well where any 

improperly sealed, completed or abandoned wells that 

penetrate the confining zone could provide a conduit for 

fluid migration. The AoR for this well has a radius of 

approximately two 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 available information about planned injection 

operations and the subsurface rock formations. See the

figure on the sixth page. 

Based on a search of well records, there are two wells 

within the AoR that penetrate the confining zone. Both 

belong to ADM – CCS#1 and Verification Well #1 – 

and were properly constructed. 

As required at 40 CFR 146.84(e), ADM will re-evaluate 

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, ADM must revise the projectspecific plans described here and EPA will modify the 

permit 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 lowermost possible USDW in the vicinity of the 

injection well, the St. Peter Sandstone formation, is 

approximately 2,604 feet below the ground surface. 

Injection and Confining Zone: Injection is limited by 

the permit to the Mount Simon formation between 5,545 

feet and 7,051 feet below ground. This zone is separated 

from the lowest USDW by approximately 2,941 feet of 

rock, including an impermeable confining zone that will 

act as barrier to fluid movement. EPA has reviewed 

company information, including maps, well logs, cores 

and the results of seismic surveys, and determined that 

the regional and local geologic features at the site 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: The proposed 

construction of the injection well 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 CO2and 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. 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 permit limitations. ADM may 

not commence construction, including drilling, of any 

new well until a final permit has been issued and is 

effective.

Injection Fluid: The permit limits injected fluid to 99 

percent pure CO2. The source is ADM’s biofuel 

production facility. The expected maximum daily 

amount of fluid to be injected is 3,000 metric tons. 

ADM anticipates injecting a total of 5,500,000 metric 

tons of CO2 over five years.

Maximum Injection Pressure: The maximum injection 

pressure will be limited to 2,380 pounds per square inch 

gauge (psig) 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, ADM will implement 

an approved Testing and Monitoring Plan. The company 

will analyze the CO2 monthly to provide information 

about its chemical and physical characteristics. ADM 

will also be required to demonstrate well integrity 

before injection begins and throughout injection 

operations. ADM must conduct and pass a two-part 

mechanical integrity test, in accordance with 40 CFR 

146.8 and 146.89, before EPA will authorize ADM to 

inject. After injection begins, 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 using a 

temperature or noise log or another approved method, 

every year to detect fluid movement behind the casing. 

ADM will test the well for signs of corrosion every 

quarter to provide early warning of well material 

corrosion due to contact with CO2 in the presence of 

water that could compromise the well.

ADM will also monitor the environment near the well to 

verify that the project and the injected CO2 are behaving 

as predicted. ADM must 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 – such as leaching or mobilization of 

heavy metals and organic compounds or fluid 

displacement – that could impact USDWs. Pressure falloff testing will be performed half-way through and at 

the end of injection to verify that the injection zone is 

responding to injection as predicted. ADM will also 

track the movement of the CO2 plume and pressure front 

using direct methods (e.g., fluid sampling and 

pressure/temperature monitoring) and indirect methods 

(e.g., seismic surveys) 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, ADM 

will submit results of this monitoring to the 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, 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, ADM facilities, and Richland Community 

College. 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.

Financial Responsibility: In accordance with 40 CFR 

146.85, ADM has demonstrated, and will maintain, 

adequate financial responsibility to perform all needed 

corrective action on wells in the AoR, to plug the 

injection well, to perform all required post-injection site

care and close the site, and to conduct any needed 

emergency and remedial response measures. 

ADM will use a corporate guarantee to cover these costs 

and demonstrate financial responsibility. The 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. 

Plugging and Abandonment: In accordance with 40 

CFR 146.92, the permit includes an Injection Well 

Plugging Plan for environmentally protective well 

closure at the cessation of injection operations. The well 

will be plugged using approved materials that are 

compatible with CO2/water mixtures to ensure the well 

will not serve as a conduit for fluid movement. 

Post-Injection Site Care and Site Closure: In 

accordance with 40 CFR 146.93, ADM 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 pressures should 

subside after injection ceases) and provide early 

warning of USDW endangerment. ADM will continue 

this post-injection monitoring for at least ten (10) years

and until they can demonstrate based on monitoring and 

other site data that the site does not pose a risk to 

USDWs and that site closure may be authorized. 

Following authorization of site closure, ADM 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 Permit: In accordance 

with 40 CFR 124.15, the permit will become effective 

immediately upon issuance if no public comments were 

received that requested a change in the draft permit. 

However, in the event that public comments are 

received that requested 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 year if ADM 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 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. 
Injection Well Schematic
Area of Review: CO2 Plume and Pressure Front